thoughts on spp and placement

One thing that I've been wondering about is the amounts of money involved here.

SPP to raise $10 million, at 8.1 cents per share.

Placement on top of this, for 15% of the shares.

Now, 15% of the shares is about 45 million, which at 8.1 cents is only a bit over $3.5 million.

Unlike other recent placements (most famously NAB, but also a dozen others), the majority of the funds are to be raised from retail shareholders. In fact, the retail base is targeted to cover the full amount of $8-10 million required.

Both of these options (SPP for $5,000 per shareholder, and 15% placement) are at the upper limits of what is permitted by law.

So - are they that desperate, or is there something going on with the 15% placement?

thoughts?