Interesting conspiracy, and everything is possible, but correct me if Im wrong, but substantial holder interests are required to be reported when the total interest is at the leve requiring reporting. If a few investors are splitting their interest across different accounts to keep an individual account's holding below the top 20, they still are required to report their total interest and where the interests are held (affiliate companies, subsiduaries etc).
I'm not too strong on ASX rules, but this is what I understood. It has appeared in substantial holder reports in the past, where there was a breakdown of shares by entity holding them (I think, most definitely for directors interest reports).
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