On 8 September 2021, SWE FI fined Carve Capital SEK 1,900,000 late flagging.
- Carve Capital AB fined SEK 1,900,000 penalty for late substantial shareholding disclosure for shares in Attendo AB (publ).
- Under Fnancial Instruments Trading Act (1991:980), breached timely notification.
- Carve Capital AB notified SWE FI on 22 January 2019, that on 10 October 2018, it had reduced its shareholding in Attendo AB, falling below 5% of all shares and votes.
- On 23 January 2019, the company made three further disclosures: firstly, that on 29 November 2017, it increased its shareholding so that it exceeded 5% of all shares and votes.
- On 30 November 2017, its shareholding decreased to below 5% of all shares and votes.
- On 6 December 2017, it increased its shareholding to exceed 5% of all shares and votes.
- On 18 June 2019, SWE FI questioned late disclosures, referred to potential fine.
- Until 2020, Carve Capital was an AIF manager authorized for management activities.
- Admitted late disclosures s but offered mitigating circumstances, e.g., staff illness.
SWE FI Assessment
- Disclosure should have been made without delay, within 3 days of each transaction.
- Applied own guidelines/standard model and number of trading days to calculate fine.
- Said staff misunderstandings/portfolio manager illness did not make infringements minor and found no other circumstances for reducing fee; the decision can be appealed.