Kat, Have a chat to the guys at BoNY. I spent a lot of time...

Kat,

Have a chat to the guys at BoNY. I spent a lot of time dealing and working with them in the 80/90's. I was a director of coy that had 7000+ US holders and half of our global turnover was done via ADRs on NASDAQ yet we didn't have the criteria you espouse. Yes, there were different criteria then, but cut and paste the link below.

Also check out the NASDAQ listings for CBD energy (MC $2m), Novogen ($8m), Prima Biotech etc etc.

Getting an Aussi stock onto a US trading platform is not that difficult. Onerous? Yes. But depends on what level of listing the company is going for.

But the important question here is not whether they can or cant. Its why. NEA's level1 ADR program was initiated before SC took the helm...more a legacy item than a strategic initiative.

All very easy to say the US insto/investor base will really/better appreciate the value of this business and need an in-country trading/reporting platform. But in reality, there are very, very few US insto's that don't have capacity/mandates to purchase/trade shares on O/S markets. And retail investors now have so many options to purchase/trade O/S stocks from their broker on-line platforms.

I have spoken with pretty much every Aust coy with NASDAQ/US listings over nearly a 25 year period from 80 through to about 2004. The benefits were easy to measure in the early periods but became more and more onerous with regards to reporting and disclosure especially when SOX came in the early 00's. And then global trading platforms came in which further reduced the need to have a US listing. Anyhow, very few, if any coys sub $1b market cap, reported any material benefit of having a US listing of any type.

The only reason for a coy to initiate a NASDAQ/US listing would be to raise capital which is a whole different story for reasons I have previously stated.

So the real question remains...Why?

https://listingcenter.nasdaqomx.com/assets/initialguide.pdf

Cheers,