Substantial shareholder disclosure

[donmihaihai]

Hi guys, I have another question regarding substantial shareholder disclosure.

A is a substantial shareholder (around 10 to 20%) of company X. If there is a change in the shareholding, A will need to make a disclosure right? And we should see this in SGX announcement. Even if A is just transfering shares around its subsidiaries and still effectively own the same number of shares in X, it still has to make this disclosure right?

So recently I noticed from Annual reports of X that A now owns less number of shares compare to previous year. However I did not see any disclosure on SGX over the past years that they dispose any shares.   
Could this be a breach of disclosure rules?
How long can A take to make a disclosure?

Not all changes require disclosure. There is a 1% rule for changes in interest of substantial shareholder.