I've been doing some research on this. I must say upfront that...

I've been doing some research on this. I must say upfront that sub holder rules are not a strong point of mine. If I have any of this incorrect, please let me know.

I think the holding belongs to Vanguard but is held by a number of custodians, including JP Morgan.

I base this on two reasons:

1. Vanguard run a couple of listed property funds in Australia and are known for their investments in LPTs. They would not be a stranger to the industry.

2. Section 609 (3) of the Corporations Act, when talking about 'Relevant Interest' says:

(Quote)
Holding of securities by financial services licensee.

A financial services licensee does not have a relevant interest in securities merely because they hold securities on behalf of someone else in the ordinary course of their financial services business.
(Ends)

Vanguard has a financial services license so if it was holding them on behalf of the parties, it would not be required to report. If any of the parties mentioned held more than 5% relevant interest, they would be required to report on their own.

However, if Vanguard holds 5% or greater itself, it is required to report a sub holding under S671b, which I think is what we have seen today.

See also the disclosure from Orbis on CER which is not dissimilar.