In order to avoid tripping over the 10% rule -
The first four owners of LCH hold less than 10% each.
These owners need to be different from the beneficiaries of the 3 trusts and 
must not be family relations of those beneficiaries.
For no beneficiaries of the three trusts to have rights to more than 10% of LCH 
there must be a minimum of 30 beneficiaries who cannot be immediate family of 
each other.
That means that we have a minimum of 34 owners none of whom are immediate 
family relatives of each other.

I'm not sure how there can be a entirely discretionary trust arrangement but at 
the same time an imposed restriction of rights to less than 10% of anything.
If there is a restriction then it cannot be entirely discretionary. 

IMHO whoever drafted this has tripped themselves up in an attempt to circumvent 
the arguments behind the new rules.

I suspect that this will not be acceptable to the PL (still squirming with 
embarrassment about Portsmouth) who will in turn make it not acceptable to the 
FL.
 
Much will also depend upon whatever the FL were told previously. They are 
supposed to know about the ownership already but hid behind the data protection 
act. 
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