Fair point but at 0.5c difference v market it’s $540 in total,...

Fair point but at 0.5c difference v market it’s $540 in total, not $5,500. I wondered about this point but for small shareholders with under say 2K, if their broker charges a minimum brokerage of more than say $10, they would be marginally worse off net by selling on market. Even for a 10K holding the net effect is probably only about $30. I don’t see how acceptances could be audited, as that really means ‘what were the holder’s reasons for accepting off market?’ No one would know without asking the holders why they did so- for example were they misled?