(a) any issuer in which a mutual fund holds voting securities carrying more than 10% of the voting rights attached to all outstanding voting securities of the issuer or in which the mutual fund and related mutual funds hold voting securities carrying more than 20% of the voting rights attached to all outstanding voting securities of the issuer shall be deemed to be a related person of that mutual fund or of each of those mutual funds, and

(b) the acquisition or disposition by an insider of a put, call or other transferable option with respect to a security shall be deemed to be a change in the beneficial ownership of the security to which the put, call or other transferable option relates.