Ann: Change in substantial holding, page-7

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    The absence of real-time data for covered short-selling in Australia can be attributed to how short-selling is regulated and reported under current laws. Here's a breakdown of why this data is not available in real time:

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    1. Regulatory Framework in Australia

    Ban on Naked Short-Selling: The ban ensures all short-sellers have borrowed or located the shares before executing trades, reducing settlement risks.

    Covered Short-Selling Allowed: While this practice is legal, it requires participants to report positions post-trade rather than pre-trade or in real time.

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    2. ASIC’s Short-Selling Reporting Mechanism

    Delayed Reporting: ASIC mandates short-sellers to report their positions on a T+2 (trade date plus two days) basis. This means short-selling data is published with a delay, not in real time.

    Daily Aggregated Reports: These reports show the total short interest for each stock but do not provide a breakdown of intraday activities or trade-by-trade details.

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    3. Practical Limitations of Real-Time Reporting

    Complexity of Tracking Securities Lending: Covered short-selling involves borrowing shares through agreements, which are processed across multiple intermediaries. Real-time reporting would require significant system changes and coordination across brokers, clearinghouses, and regulators.

    Market Stability Concerns: Real-time short-selling data could amplify market volatility, as investors might react impulsively to short positions rather than considering fundamentals.

    Administrative Burden: Implementing real-time reporting would impose operational and cost challenges on brokers and financial institutions.

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    4. International Comparisons

    United States: Short interest is reported bi-weekly by the SEC, with no real-time reporting requirement. Daily data on executed short sales is available but does not distinguish between new short positions and routine trades.

    China: Short-selling is entirely banned, so no data exists.

    Europe: Some countries provide more frequent updates, but real-time data is rare due to similar concerns about volatility and administrative feasibility.

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    Implications for BOE Retail Investors

    Delayed Insights: Retail investors can only access short interest data with a delay, making it harder to interpret real-time market dynamics caused by short-selling activity.

    Monitoring Alternatives: Use the daily ASIC short position reports (link) to track trends over time, even if not immediate.

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    Closing Thought

    The lack of real-time data reflects a trade-off between market transparency and practicality. While real-time reporting could provide valuable insights for retail investors, the administrative and systemic challenges currently outweigh the benefits in Australia’s regulatory framework.


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