No loophole but a holder who had their holding in a nominee and then changes to 2 custodians or even registers directly in their own name - it may always have been in 2 sub accounts in nominee could disappear of the top 20 holdings as it does not consolidate them and not have to lodge a change in substantial holding as their holding did not change - just the manner in which it was held.
The nominee for example may have held for 10 clients - all below 5% so never needed to report a substantial holding unless a single party had underlying control.
The only real way to know is to get copy of register or inspect it at dates before change and after change and note teh holder changes.
Many company sec are happy to supply a top 40 - or top 100 as they can just print it off as part of of the registry package they have
General Discussion, page-2059
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