No this interpretation is negated by sec 2-2, it has to be a "controlling holding" to count as a "covered holding": > (2) CONTROLLING HOLDING.—The term “contro

No this interpretation is negated by sec 2-2, it has to be a "controlling holding" to count as a "covered holding": > (2) CONTROLLING HOLDING.—The term “controlling holding” means a holding with the power, whether direct or indirect and whether exercised or not exercised, to determine, direct, or decide important matters affecting an entity.