Yes it the sub holders responsibility, more reading can be done here if your interested: http://download.asic.gov.au/media/1236706/rg5-published-20-december-2013.pdf
Esentially once you go past 1% you have 2 business day to report. If you don't you can be fined 25 penalty units (total $5250) or 6 months jail.
But we all know what asic is like they don't care about these type of things it is merely a formality and would only come into consideration in a takeover scenario or if seriously negative news followed the sell down.
IMO
Ann: IAM - Top 20 Report, page-94
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Mkt cap ! $16.01M | |||
| Open | High | Low | Value | Volume |
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| No. | Vol. | Price($) |
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