Broker Data, page-731

Thanks @Dabbler009 - I appreciate your doing the work and sharing the updated registry data. I agree with most of your inferences around custody transfers but I’ll give my thoughts line by line below.

Bearing in mind that Datt (3.3m), Tali (8.9m) and O&Ds (~12m) are all held in name and accounted for, i.e. omitted from your list, the main other publicly disclosed holders held in street name are Regal (6.9m), Global X Copper Miners (1.4m) and 1832 Asset Management (1.3m) which should be accounted for in the below.

---

1. Citicorp Nominees: 4.8m; Already ~3m held in the annual report in September 2023. It's not Regal (see their filings). By process of elimination from all of the below, I infer that 1832 Asset Management's 1.3m shares are among those held in this account. In addition to this, we presumably have one large unknown holder here, close to the 5% threshold (~3.2m shares). The delta relative to WA1's 2023 annual report registry data matches pretty closely with Citi broker data, i.e. these holders are likely using Citi for both execution and custody.

2. HSBC Custody Nominees (Australia): 4.7m; Goldman account - Regal had 350k here at last count (see last filing), seems like 650k were also transferred from the MS entrepôt (cf below). Given that Regal currently have ~7m shares total, and the UBS and ML custody accounts are also down >500k relative to Regal's filing, I estimate Regal currently have ~3.5m shares custodied here.

3. JP Morgan Nominees: 3.7m; I believe this is the 1.3m shares held by Global X Copper Miners ETF (cf. Neweconomy below) and ~2.1m held by Regal (see their last filing).

4. UBS Nominees; 1.6m; Regal had 2.1m here (see last filing).

5. Neweconomy Com Au Nominees <900 account>: 0; the 1.3m previously held here matches very closely with the Global X Copper Miners ETF holding (c.f. JPM above); as you mentioned this is a JPM-associated entity, so this ties out - looks like they were transferred.

6. Merrill Lynch (Australia) Nominees: 1.3m; Regal had 1.7m here at last count (see last filing).

7. BNP Paribas Nominees <IB AU Noms Retail Client> : 1m; Interactive Brokers account for Au-listed shares; I can say with surety that a material fraction of these are held long-term by a very enthusiastic US-based retail investor with a WA1 cap.

8. HSBC Custody Nominees (Australia) A/C 2; 750k; Morgan Stanley account - Regal had 500k here at last count (see last filing).

9. Morgan Stanley Australia Securities : 0; presumably an entrepôt for newly-issued shares and now the 650k in the Goldman Custody account (see above), so presumably Regal involved, who took 850k shares total in the cap raise (see latest filing).

10. Warbont Nominees ; as you say, this is a UBS-associated entity, presumably entrepôt cap raise shares as above, including Regal, distributed to their various custody accounts (no clear match from the holding changes).

11. BNP Paribas Noms Pty Ltd: as you say, presumably an entrepôt for the Interactive Brokers account (see above).

12. HSBC Custody Nominees : Goldman custody account, presumably for a foreign client.

13. HSBC Custody Nominees - GSI EDA: Goldman custody account, as above.

---

Let me know if I've messed any arithmetic or the allocations up.