One thing I'm still not clear on going back to their last response to the ASX released on 14/01/21 - DOU seemed to give a non-answer to question 5. The ASX asked:
"Please explain how it was decided that Tyrrhenian would be allocated 3,350,000 shares in the Re- Compliance Capital Raising, being the 4th largest all bookbuild for the raising was multiple times in excess of the of the $6 million In answering this question, have regard to the fact that the application form for Tyrrhenian is for the full amount of shares that were eventually issued to it indicating that Tyrrhenian was not scaled back."Put a different way: How did Tyrrehenian (Mondello) get full allocation when most applications were presumably scaled back?
There are only two answers to this question, either: 1) the lead manager decided this independently (i.e. the fact that it was a related party is pure co-incidence), OR, 2) the lead manager was instructed to give full allocation by someone at DOU (which would contradict the previous statements made by DOU).
DOU's response was to go with option 1:
"The lead manager to the Re-Compliance Capital Raising circulated a proposed final list of the 345 participants in the Re-Compliance Raising, which was then reviewed and accepted by the Board."i.e. the lead manager decided independently. However, DOU specifically do not explain the co-incidence that it was a related party who got full allocation, even though the ASX prompted them to explain this in their question ("have regard to the fact that...").
If I was the ASX, I would be wondering the following:
- How many applications got full allocation?
- What was the average scale back?
- Was it random who got full allocation? Or maybe all large applications get full allocation? Or was it any application from an entity starting with the letter T get full allocation?
- How about a letter from the lead manager attesting to their decision making?
- etc.
Could this be the reason for the delay in clearing this matter?
(20min delay)