cudeco(cdu) trading - representations, page-54

Hi CDU'ers,


The following is the text of a letter that I have forwarded on the 6th Octobe, 2012, to Mr. Michael D’Ascenzo, Commissioner of Taxation, Australian Taxation Office, Canberra. ACT.
Subject: CuDeco(CDU) Limited - Trading.

"Dear Mr. D’Ascenzo,

I refer to my letters to you on the 12th December, 2011, and the 10th February, 2012, concerning the trading of CuDeco(CDU) Limited Securities. I have not yet received a
reply from you to my representations.

In the meantime, further research on the “CuDeco Shareholder Research” Document has been undertaken.

Therefore, to give you an overview of the situation I have made a précis as to how I see the situation with CuDeco(CDU) Trading on the Australian Securities Exchange(ASX):-

CuDeco(CDU) Limited is a Junior Mining Company located in Cloncurry, Queensland.

The mining tenement is called Rocklands and to date has over 1 million tonne of mineralisation, such as copper, gold and cobalt ready to be mined when all structures are completed. Mining is expected to start late 2013.

Since CuDeco(CDU) Limited started drilling at Rocklands in 2006, on most occasions when a good drilling announcement has been made by the Australian Securities
Exchange(ASX), the CDU share price has been capped as a result of share churning by an unknown Group.

As a result, a “CuDeco Shareholder Research” Document has been developed by a CDU shareholder.

This Document can be downloaded on:-

http://www.s......com/cudeco_research/collections

Reports completed up to the present time reveal the need for a forensic examination of CDU Securities traded on the ASX.

The Australian Securities and Investments Commission(ASIC), have indicated that they do not have unlimited resources, and have not acted. It would appear surveillance techniques used are not able to detect some forms of manipulation evident in trading as revealed by the research in the “CuDeco Shareholder Research” Document.

In Chapter 5.4 of the “CuDeco Shareholder Research” Document, the research has indicated that there is a need for a number of Audits into the following Issues of trading in CuDeco(CDU) Securities:-

Issue 1 The Dominance Over Trading by Institutions.

Issue 2 Transactions that bypass Normal Trading (i.e. Off Market).

Issue 3 Dominance Over Auction Pricing.

Issue 4 Dominance Over Price Movements (Up Ticks and Down Ticks).

Issue 5 Repetitive Selling into Significant Announcements.

Issue 6 Algorithmic Trading.

Issue 7 Confusion over the use of Broker Settlement Accounts.

Issue 8 Possible Loss Making Trading – Genuineness of Trading.

Issue 9 Short Selling.

Issue 10 Misinformation Related to ASX JORC Compliance.

Issue 11 18th August, 2110, Trading of CDU Securities on the ASX.

Issue 12 Regulatory Issues.



Chapter 5.4 - pages 3-13, give an excellent summary of the above 12 Issues.They make very compelling reading. Other areas of the Australian Securities Exchange may also be affected.

In addition, Chapter 6, Section 4 – pages 34-38, give an overview of Share Market Trends, Trading Behaviours and Market Trends over 2.5 years of CDU trading from January, 2010, through to June, 2012.


Some questions needing investigation are:-

1. How can such levels of Wash Trades evident in the trading of CDU not be viewed upon with suspicion?

2. What steps have been taken by the Australian Securities and Investments Commission(ASIC), to ensure that these Wash Trades are above board?

3. How can persistent data anomalies associated with shorting CDU, where reported data doesn’t match daily trading or the register, be sanctioned by Authorities, when it clearly doesn’t add up and looks to short circuit
price discovery by allowing covering off-market?

4. How can high volumes of Dark Trades be judged as not presenting market issues when clearly nothing is known about such activity?

5. Why has there not been an investigation by ASIC into an unsigned document “F..... S...........” circulated to subscribers about CDU around the 18th August, 2010?

6. Why the misinformation related to the ASX JORC Compliance?

7. Why no Forensic Audit of the trading of CDU Securities on the 18th August, 2010?


Thousands of people associated in some way with CuDeco(CDU) share trading have suffered as a result of financial losses and/or severe stress. It is incumbent that malpractice in the share market be eliminated by the Authorities responsible for the oversight of the ASX. So far there has not been any positive action by the Regulator(ASIC). However,I feel you need to be informed.

The “CuDeco Shareholder Research” Document reveals the extensive use of dubious trading strategies at levels that seriously put into doubt the integrity of trading in CDU Securities on the ASX over the 2.5 year period documented by the research. Wash Trades and Dark Pool Trades have resulted in disturbing volumes of share exchanges taking place that have been completely opaque to the market.
The transactions equate to well over 200 million buys and 200 million sells about which very little is known including what impact they have had on the share price and on the fairness of trading taking place.

There may be serious Taxation implications insofar as Taxation Revenue is concerned. I would like this matter to be thoroughly investigated to ensure the integrity of the share market is upheld and any possible financial malfeasance eliminated.

Yours sincerely,

Maxw..........."



Referred for the information of CDU shareholders concerned.

cheers,

Max