Disclosure of Conflicts

If you own an index mutual fund or actively managed mutual you have to discose if you own the specific stock you are doing research on right? I thought it may be difficult to know what the actively managed fund held on a continous basis.

No, if you dont have any discretion over the portfolio. If you have discretion over the holdings then yes you have to disclose. If its a mutual fund you wont have discretion so no, you dont have to disclose.

so if you hold a just an index fund/active fund you don’t, I thought if you were the beneficial holder you had to?

No. you don’t have to disclose in case you hold a MF/ETF.