c I get the point you were alluding to but two facts in relation to ASIC rlues apply here.
1) Your aformention rule re 20% for TO purposes. In this event if FCW put forward JV with Blackrock and another party accumulating (example only) then this would ultimately be in breach. Down the track, as "Partners of"
2) FCW would have had to disclose already any Sub change if exceeding 1% (regardless of directorship)
3) Substantial holder = +5% so eluding back to point 1, if accumulating and his partners were taking place two parties could accumulate 3 to 4% each so that FCW holding increased at low SP to 20% but my guess is he would end up in breach of the ASIC rules for Sub holders or partners of a sub holder.
Only my take DYOR
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