Great to see an argument supported by evidence. However, I'd like to question a few of your points.
Point 2 - If the amount of shares you need to get into the top 20 has increased, doesn't that suggest it's more difficult to become a top 20 holder; ergo, the top 20 hold a greater proportion of shares held by them is greater than before? Bit confused about this point because it seems to contradict Point 1.
Point 3 - It's not that simple. Due to low volumes, attempting to buy 2.1M shares in one go would send the price shooting up. It's not just 2.1M multipled by 40c. If you split a 2M order into 4 parcels of 500k, imagine what would happen. First parcel would send this to 45c, then 50c, then 54c, then 58c. This is one of the arguments for why there are bots accumulating slowly. We only get about 300k volume per day and any accumulation is split between a number of different players.
Point 4 - All funds have strict investment mandates they need to follow. As the stock fell out of the ASX300 many funds would have been forced to sell out because their mandates don't allow them to invest in smaller companies. Super funds in particular are much more strict (ethical) about this stuff than investment banks (for example).
Point 5 - I wouldn't say this means much at all. A whole bunch of people could have just bought 5k worth of stock in speculation. A big holder could have split their holdings across multiple entities for tax reasons.
I'm agnostic to whether there is any institutional manipulation because I don't like to fret about things that can't be changed. Whether or not there is, there always will or will not be, therefore my investment should not rely on that piece of information. However, I do think it's undeniable that someone is cleverly pushing down the price with tiny orders to then accumulate more cheaply - I just don't know who's behind it and don't think there's any value to jumping at conclusions and then basing my investment on that.
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