It likely is - the $140m quoted in the media has been attributed to NAB/HSBC. Don't be surprised if it includes cost accruals etc. (such as legal and professional advisor costs and interest earned but not paid) which push it over the $135m facility limit. The MQG trade finance facility of $30m ($20m owing at VA appt) is separate to this amount.
Whilst internal policies are important (you have probably found something relevant in 7.3 (c) in their policy - and might want to make the Senate inquiry aware of it) the listing rules you are referring to are more so. See Rules 3.1 (continuous disclosure) and exceptions from it (Rule 3.1A). Possibly it could be argued discussions with bankers did not need to be disclosed as it related to an incomplete negotiation until the Dec-15 accounts were available and a financial covenant was breached (see examples of events requiring disclosure in rule 3.1 - internal policy 7.3 (p) is one of the examples given).
DSH Price at posting:
35.5¢ Sentiment: None Disclosure: Not Held
