Using the last T20 from the AR as at 24/7/19.
We only had two sub holders - Gary & QF.
If Gary did any selling/buying he would have to declare that, even if it was a small amount. (as he is a Director).
QF had 8.74%. If he sold more than 1%, and reduced his holding to say 7.72% he would have to put in a Change of Sub Holding Notice.
If there was a lot of dilution and QF didn't sell any shares or participate in the CR, it's possible his holding could have been diluted by more than 1%. In that case he would have to put in another Change of Sub Holder Notice.
My understanding is it's QF's responsibility to lodge the Notice and then the company announces it to the market.
As we know since the AR both R & B have come on board and sat below the 5% Sub Holder level.
In theory Regal could sell without having to report anything to anybody.
I'm not sure that Bombora could do that given the board position now held by Gregg (but I'd need to check that). It would be poor form, but it can't be ruled out.
At the start of this year our former Chairman (PB via Westedge Investments) slipped under the 5% threshold after the CR. He is now free to sell down as he sees fit, without informing anyone.
(When the TSN SP went for a gallop in 2016 that's what Kirk originally from the QED days did, he sold into the momentum).
Given all of the above - I'm not surprised we haven't seen any change of substantial shareholding notices despite the volumes and change in sentiment.
Hope that helps.
