It depends whether Citicorp holds the shares for more than one party. If more than one party and those parties are considered to be “associates” then the 20% rules is applicable to them collectively. BNP Paribus also have three separate places in the top 20 but we don’t know if the holders are associated.
A number of the top 20 know each other but doesn’t necessarily mean they are associated. It can be complex. “Warehousing” is illegal, this is where people may have a secret arrangement to build a holding on behalf of another person to get around the 20% rule.
It is designed to force an acquirer to “show their hand.”
It depends whether Citicorp holds the shares for more than one...
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