Shareholding disclosure on the issuer's own count, with every filing drafted the day a threshold is crossed
Filings drafted the day a threshold is crossed, on the issuer's own voting-share count.
See one case, screen by screen ↓Shareholding Disclosure Monitoring is shareholding disclosure software that tracks 13D, 13G, 13F and global ownership thresholds and drafts each filing. Seven agents read every entity's positions each morning, aggregate them by each country's rule, read the issuer's own voting-share count, recompute every crossing independently and draft the notification in the regulator's form and language. The regulatory reporting manager prepares, Legal approves, and nothing is filed unseen.
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Shareholding disclosure is the duty to tell a regulator and the issuer when your aggregate holding in a listed company crosses a threshold: 5% in the US, where beneficial ownership reporting runs on Schedules 13D and 13G; 3% and up in the UK and Germany, every 1% change in Japan, extra bylaw thresholds at some issuers, in about 40 markets with clocks of two to five trading days — plus the quarterly Form 13F. The arithmetic is easy. The hard parts are which funds, entities and mandates count under each country's rule, by voting power or investment power; the issuer's current voting-share count, which a data vendor often carries stale; and the clock.
Today a rules engine flags crossings on a vendor's share count, and a compliance analyst checks every denominator against the issuer's own filing — often in German, Japanese or Swedish — works out which holdings count, and types the form by hand from spreadsheets, with no record of which number came from where. A capital increase the vendor missed, a buyback that causes a passive crossing with no trade, a bylaw threshold nobody coded or a clock missed over a local holiday is how a filing ends up late. In September 2024 the SEC charged 11 managers for missing Form 13F filings and 23 filers for late Schedule 13D, 13G and Section 16 reporting.
Estimated split for one crossing at a global asset manager, by hand and with the solution.
Seven agents aggregate, read the denominator, recompute and draft; the preparer prepares and Legal approves.
On Wednesday, October 14, 2026, Quillfield Capital's European Equity Fund buys 96,500 shares of Kestrel Bau AG, a German construction company listed on Xetra. Quillfield now holds 5.02% of the voting rights. It is Thursday morning in New York. Here is what happens next, screen by screen, in the working solution.
Priya opens Today: 5 filings owed, next due Mon Oct 19, none late; 17 issuers within half a point of a rung; 9,042 issuers monitored; 0 late filings this year, 247 filed. Her Needs-you list puts Kestrel Bau AG first: draft notification v1.2 ready for review, agents agree on 5.02%, due Tue Oct 20. Beside it, each agent reports its morning in a sentence.
“Priya Raman reviews · Legal approves · nothing is filed unseen”
Priya asks the agents why Kestrel's denominator is 48,210,000. The Denominator agent answers with its sources: Kestrel Bau's own §41 WpHG notice of September 30, 2026; the data vendor still shows 46,900,000 as of June 30 and misses the September 28 capital increase. On the issuer's figure the holding is 5.02%; on the vendor's it would read 5.16%.
Every answer links to the passage it came from, and the question is kept on the audit trail.
The Intake agent read the book of record, the order management system, three custodians, the fund administrator, the securities lending agent, the issuer filings feeds and the data vendor. Custodian C in Asia arrived 22 minutes late; the agent retried every 10 minutes and read it at 06:52. Of three reconciliation breaks it explained two — a trade-date difference at Corbel Therapeutics and the late file — and left one, a fund that moved entity at Castellan Retail, for an analyst to confirm.
“The run never uses yesterday’s file.”
Each bar is Quillfield's aggregate holding climbing past that country's rungs, with a chip on a crossed rung counting the trading days left. Kestrel Bau crossed 5% on Oct 14: 4 trading days, Tue Oct 20. Oriel Logistics crossed 3% with no trade after the issuer canceled shares — a passive crossing, due Mon Oct 19. Valmorel SA crossed a 2% threshold in its own articles, and Lindqvist Medical AB is flagged because two issuer figures disagree.
The thread shows each agent's step and its source: the Intake agent read 6 accounts in 3 entities plus 41,000 shares on loan; the Aggregation agent counted 2,420,142 voting rights under Germany's rule; the Denominator agent read the issuer's notice. The Check agent recomputed from custodian statements, without seeing the first result, on a separate model: 2,323,642 settled plus 96,500 bought, 5.0200% — “Same to the share.”
Rules agent: “Crossed Wednesday, October 14, so the last day is Tuesday, October 20 on the Frankfurt calendar.”
Under §34 WpHG the agent counts the five holdings where Quillfield votes at its own discretion, including the Halden County Pension Fund mandate whose clause 9.1 delegates voting. It leaves out the Northgate Municipal Pension mandate's 64,000 shares because the client keeps the vote — counted in the US view under Rule 13d-3, which reaches 2,484,142. The 41,000 shares on loan go on the form as an instrument under §38, 0.0850%.
The agent opens Kestrel Bau's “Veröffentlichung der Gesamtzahl der Stimmrechte gemäß § 41 WpHG”: 48,210,000 voting rights as of September 30, 2026, after a capital increase registered on September 28. The original German sits beside the agent's English translation, checked against the original. The vendor figure is shown, flagged and not used.
“Issuer figures always win over vendor figures.”
The Drafting agent prepared the standard voting-rights notification to BaFin and the issuer: v1.2, 10 sections, 31 fields, the German on the left as it will be filed and English on the right for review. Checks before Legal all pass, from the independent recompute to the chain of control and the trading-day deadline. Priya can edit a field with a reason; she sends it to Legal as the preparer.
“You are the preparer. Legal approves; you can never approve your own filing.”
Elena opens Approvals and sees what she is signing: 2,420,142 = 5.02%, the issuer notice, Germany 5% crossed by trading, Tue Oct 20, the draft's fingerprint and the agents whose versions were in force. She chooses “Approve · figures and chain of control verified” and attests that she reviewed the calculation, the denominator source and the draft.
Only once Legal has approved does Priya submit. The filing shows Prepared, Checked, Approved and Submitted, with the receipt BaFin-MVP-2026-1015-0442 stored against it. Kestrel Bau is filed days ahead of its Tue Oct 20 deadline, on the issuer's own count.
“Filed · Kestrel Bau AG · receipt BaFin-MVP-2026-1015-0442”
The same crossing, seen by the five people who carry it — what their morning looked like, and what it looks like now.
Seven agents aggregate, read the denominator, recompute and draft; the preparer prepares and Legal approves.
Reads end-of-day positions and pending orders from every legal entity — book of record, order management system, custodians, fund administrator and securities lending agent — and reconciles them, explaining each break.
Sums holdings per issuer under each jurisdiction's rule — voting power, investment power, instruments and shares on loan — across entities, funds and mandates, and keeps the US view beside the local one.
Reads each issuer's voting-share count from its own filing in its own language — a §41 WpHG notice, a 10-Q cover page, a Japanese semiannual report — shows the original beside English and flags stale vendor data.
Recomputes every crossing from custodian records, blind to the first result, on a separate model family, before any draft exists.
Applies country and issuer-bylaw thresholds and trading-day clocks on each exchange's calendar, and reads issuer articles for extra bylaw thresholds.
Drafts each filing in the regulator's form and language with an English side — Schedule 13G/A in EDGAR XML, the German voting-rights notification, TR-1, the Japanese change report — and cites every field.
Reads pending orders and warns the head of trading when an order would cross a rung, with the deadline it would start and the largest size that stays below.
Prepare, approve, decide. The agents propose; a named person decides.
Ask about any holding, threshold, denominator, order or filing. The agents answer from this morning's run and cite each source.
Why is Kestrel Bau at 5.02% and not 5.16%?
Because the issuer's own count is 48,210,000 voting rights after a September capital increase; the vendor's 46,900,000 is from June. 2,420,142 ÷ 48,210,000 = 5.02%, and the Check agent agrees from custodian records.
What is due this week?
Five filings are owed. Nearest first: Oriel Logistics N.V. Mon Oct 19 (with Legal), Kestrel Bau AG Tue Oct 20, Valmorel SA Tue Oct 20 (bylaw), Mizuhana Precision K.K. Wed Oct 21, Corbel Therapeutics Fri Nov 6. Form 13F and nine Schedule 13G amendments are due Mon Nov 16.
Which pending orders would cross a threshold?
The 8:31 a.m. buy of 180,000 Harbourline Group plc would take Quillfield from 9.97% to 10.08% of 163,640,000 voting rights; a TR-1 would be due within 2 trading days. The largest buy that stays below 10% is 49,091 shares. Graham Holt decides.
What does Corbel above 10% mean?
Corbel Therapeutics is at 10.12%. Quillfield is a qualified institution, so a Schedule 13G/A is due within five business days after October ends: Fri Nov 6. On Section 16, Rule 16a-1(a)(1) excludes shares a registered adviser holds for clients in the ordinary course, so I see no Form 3. That is a legal judgment; Daniel Cho or Elena Brandt confirms.
13 screens from the working solution, on its sample data. Pick one to see it large.
The bands, tolerances and aggregation choices every crossing is tested against are settings. Changes that affect a filing are proposed, then approved by Legal.
| Setting | Default | Choose from |
|---|---|---|
| Approaching band | 0.50 points | Show an issuer as approaching within this many points of a rung |
| Pre-trade warning | 0.25 points | Warn the desk when an order would end within this many points, or cross |
| Check agent tolerance | 0.0001 points | Largest difference between the two calculations before drafting stops |
| Denominator confidence floor | 90% | Below this, the Denominator agent asks an analyst |
| Stale denominator | 35 days | An issuer figure older than this is re-read from the issuer's filings |
| Draft by | 4:00 p.m. local | Drafts ready the day of the crossing |
| Mandates where the client keeps the vote | On | Left out where the rule counts voting power only; kept where investment power counts |
| US disaggregation (Release 34-39538) | Off | Report each business unit separately where information barriers exist |
Every figure is labelled: a target the solution is built to, an estimate, a typical published result, or a proven one.
“demo” = seen in the working solution, on its sample data · “target” = the design goal, measured in the live solution · “estimated” = our estimate · “typical” = published figures (SEC press release 2024-148, September 25, 2024, and Morgan Lewis, October 2024 — 23 filers charged over late Schedule 13D/13G and Section 16 reports, entity penalties $40,000 to $750,000; 11 managers charged on September 17, 2024 over missing Form 13F filings; SEC Release 33-11253 on Schedule 13D and 13G deadlines). Quillfield Capital and the people, issuers, funds and filings named on this page are fictional — characters and sample data in the working solution.
Shareholding Disclosure Monitoring is shareholding disclosure software that tracks 13D, 13G, 13F and global ownership thresholds and drafts each filing. Seven agents read every entity's positions each morning, aggregate them by each country's rule, read the issuer's own voting-share count, recompute every crossing independently and draft the notification in the regulator's form and language. The regulatory reporting manager prepares, Legal approves, and nothing is filed unseen.
The rules library holds the US clocks: a Schedule 13D filing within 5 business days, a qualified institution's Schedule 13G within 45 days after quarter end, and an amendment within 5 business days after month end when it passes 10%. The Rules agent counts every deadline on the exchange's calendar, and the filing calendar shows each one with its preparer, approver and SLA. In the working solution the agents draft all nine quarterly Schedule 13G amendments in one go.
The Form 13F workbench matches every holding to the SEC's Official List of Section 13(f) securities — 3,912 rows and $412.6 billion in the sample quarter — explains each exception and produces the information table. It is due 45 days after quarter end, prepared by an analyst and approved by Legal.
The issuer's own, read from its latest publication in its language: a 10-Q cover page in the US, a total voting rights notice under §41 WpHG in Germany, a semiannual report in Japan. The vendor figure is kept for reference only and flagged when it is stale. When two issuer figures disagree, the agent stops and an analyst chooses with a reason.
Yes. The rules library covers 40 jurisdictions and 38 issuer bylaw thresholds, and the Drafting agent prepares the German voting-rights notification, the TR-1 notification of major holdings for the FCA, the AFM substantial holding notification and the Japanese large shareholding report and change report on EDINET, each with English beside the original. The library also holds Australia's substantial holder notice on Forms 603 and 604 and Hong Kong's disclosure of interests forms. It catches passive crossings too, where a buyback or capital change moves the denominator with no trade.
Yes. The Pre-trade agent reads pending orders and warns the head of trading 0.25 points before a threshold, with the resulting holding, the deadline the order would start and the largest size that stays below. The desk proceeds, holds or resizes with a reason; the agent never blocks or routes an order.
Yes. The agents prepare and recompute; they never sign. The preparer sends each draft to Legal and can never approve their own filing, Legal approves with a reason code and an attestation, and only an approved, unchanged version is submitted. Rule and agent changes also need Legal's approval.
The Agentic Solution Engine builds and deploys it from your requirements and documents — your entity map and control chain, your rules and a sample of past filings — and it goes live once every quality gate has passed. We will walk you through it on your own holdings first.
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