Luck101 That's not how I read it. I believe it is the short seller who has to register the short sale - not the lender.
From https://asic.gov.au/regulatory-resources/markets/short-selling/requirements-for-disclosure-and-reporting-of-short-sales/
Short sale transaction reporting
Where a person (a seller) executes a short sale and relies on an existing securities lending arrangement to have a ‘presently exercisable and unconditional right to vest’ the products in the buyer at the time of the sale, the sale of the products is a covered short sale. Covered short selling is permitted under the Corporations Act 2001 (Corporations Act). For a detailed overview of the short selling provisions of the Corporations Act, please see Regulatory Guide 196 Short selling (RG 196).Sellers and brokers who make a short sale on a licensed market may be required to comply with the short sale transaction reporting requirements.If a seller engages a broker to make a covered short sale on its behalf, the seller must report the particulars of the sale to the broker: s1020AB(3).A broker must not make a short sale on a licensed market on behalf of a seller unless, before making the sale, the broker has asked the seller whether the requested sale is a short sale and has recorded in writing the seller’s answer: s1020AE.
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