Which type of shares are excluded from vote holder DTR requirements?

Shares held by a custodian are excluded from vote holder DTR (Disclosure and Transparency Rules) requirements because the custodian does not have the beneficial ownership of the shares. Instead, custodians typically hold shares on behalf of clients, such as institutional investors or other individuals, who retain the rights associated with the actual ownership. The DTR requirements focus on the voting rights that come with direct ownership of shares, hence shares held in this way do not impose disclosure requirements on the custodian itself.

In contrast, shares held in trust generally do have identifiable beneficiaries whose interests may need to be disclosed. Shares acquired through personal loans could still confer voting rights to the holder, as they have an interest in the shares, despite the method of acquisition. Lastly, shares held by institutional investors do not fall under such an exclusion since these entities often manage the shares themselves and may hold voting rights that would need to be disclosed under the DTR guidelines.