February 2017

As from 1 March 2017, positions held for the account of third parties can be aggregated at the level of the entity that has the discretionary authority to exercise the relevant voting rights (typically an asset manager) or - alternatively - at the level of the person who ultimately controls such entity.

The new rules provide for a transition period of six months for implementation.

Filings made prior to March 2017 are not grandfathered - Previous disclosures of client positions must be updated by 31 August 2017.