Will the exchange disclose the volume of rights a given voter or aggregator controls?
The exchange will disclose no information on the volume of rights controlled by smaller aggregators or voters. It will disclose limited information on the volume controlled by larger aggregators or voters. it will do this to protect privacy and discourage the buying or selling of rights. Consider an example of how full disclosure might lead to problems. Suppose a hedge fund wanted to buy voting rights from a willing wealthy investor. It would 1) want to know how many rights the wealthy investor controlled, and 2) it would want some way to check if the wealthy investor actually transferred the rights to them. If the exchange disclosed the actual volume of rights participants controlled, the hedge fund could easily check the former, and by monitoring if its account balance rose on the day the wealthy investor was to transfer the rights, it could reasonably check the latter. By not fully disclosing the volume of rights each participant controls, the exchange will largely preclude the buying and selling of rights. Still, it will be useful for the exchange to give some indication of the volume of rights larger voters and aggregators control. The exchange will develop policies for such disclosures. Likely, it will indicate some range for the volume of rights a larger voter or aggregator controls, and the exchange will update the information infrequently—perhaps quarterly.