I don't think so. In all my years I have never seen a director declare a CFD trade or interest in a long/short position. Only laws they must still obey are those relevant to insider trading.
Where are you going with this? Do you think it's possible that the 10% of stock sold short are mostly director CFD short positions?
question :director interest notices, page-2
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| Open | High | Low | Value | Volume |
| $2.68 | $2.68 | $2.67 | $21.90M | 8.188M |
Buyers (Bids)
| No. | Vol. | Price($) |
|---|---|---|
| 44 | 1171979 | $2.67 |
Sellers (Offers)
| Price($) | Vol. | No. |
|---|---|---|
| $2.68 | 528780 | 22 |
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