Thanks for that Zubana! That is certainly how the Form 106's are...

Thanks for that Zubana! That is certainly how the Form 106's are being used by PEN.

I got my cue from ASIC's REGULATORY GUIDE 5 -
Relevant interests and substantial holding notices. This states, on page 66:

"A person must provide a substantial holding notice if, in relation to an entity that is a listed company, listed registered managed investment scheme or a listed body incorporated or formed in Australia, the person:

(a) begins to have, or ceases to have, a substantial holding;
(b) has a substantial holding and there is a movement of at least 1% in their holding;"

Seems to be an anomaly there?