" Still waiting on the sub holder notice for the 20m to turn up "
AKA,
So am I. But, if those 20m shares have been allocated or passed on to a few different holders, you won't be able to know as to where they went, and as to whom they were allocated to.
As you've said, the 5% figure is what is relevant in having to disclose one's holdings. 4.999% will not have to be disclosed to anyone.