My reading of the rule is that they are technically an insider, and have to disclose anything more than 1% difference within ten days, and must not trade for ten days after disclosure. If they are up or down .99% from their reported number, they don't need to report but once a year. What is 1% of the outstanding shares?
You might want to ask an Attorney for a more reliable answer. I can only say what my reading gave me, and the legalese is tough to read.
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