Top 20 shareholders vs Substantial shareholders lists

I tried to post this under an old "Top 20" thread, but it didn't work. So apologies for creating a new thread.

I have been comparing the Top 20 shareholder / Substantial Shareholders lists for March 2019 and 2020 (the latest list being in the company's just released annual report).





Comparing the substantial shareholders statements is interesting:

• Ausbil's shareholding of 8.99% of issued capital (36,642.243 shares) remains the same in both years. (Yesterday though, Ausbil notified the market that its substantial holding has now fallen since 13 March 2020 to 7.952% or 32,563,438 shares).
• Blackrock Group (the ones who we hear are getting out of fossil fuels and getting into renewables) have dropped off the list. They previously accounted for 6.62% of issued capital. Of course, they sold a significant amount of their shares last year to help Macquarie cover a short position which it needed to close.
• Credit Suisse are now a significant holder, accounting for 7.26% of the issued capital (29,733,993 shares).
• Anthony Tse's holding has increased from 1.16% to 1.6%. Ok, he didn't buy these shares, but he now has more skin in the game than he did last year. Gratifyingly, he hasn't sold any of his holding.
• Rowley Super Investments has dropped off the Top 20 list (maybe they are at No. 21).

There was a lot of complaining last year (including by me) about the difficulty of obtaining an updated Top 20 list during the course of the year. It seems we just have to wait until the annual reports (unless we want to pay a substantial fee to the share registry). There was also a lot of debate about what it means to be on the Top 20 shareholders list compared with what it means to be on the substantial shareholders list. My understanding is that those on the Substantial Holders list are the actual owners (e.g. Ausbil) but they place the shares they hold with Nominee companies to be managed for a fee. Those nominee companies in turn lend the shares to institutions like Credit Suisse and Macquarie and the like who then short them.

Interestingly, when I add the percentage of issued capital controlled by the Nominee companies on the Top 20 shareholders list, this totalled 45.67% in March 2019 but has reduced to 32.77% in March 2020. This indicates to me that shares are being called back by the substantial owners. The declining percentage of shares held by nominees is probably the reason why the percentage of GXY shares being shorted has dropped in recent weeks from 20% to 16% (although GXY is still at the top of the Shortman list of most shorted stocks).

My analysis of all this is:

1. Credit Suisse has acquired a substantial shareholding. This has to be right doesn't it, given that they are on the list of substantial shareholders? But I wonder how this could be possibly be? How could they have acquired that many shares without the share price going up? And if they do own them, why was there no notice of significant shareholding released to the ASX? Hopefully someone on HC can explain what is going on here.
2. Ausbil has taken a substantial loss in the order of $3 per share for each of the GXY shares it has had to sell. All because it placed its shares with nominees who were then allowed to do what they liked with them (lend them to Credit Suisse and the like to be shorted, thus adversely affecting the returns to those who have placed their funds with Ausbil managed investments).
3. Shares being held by nominees are being called back and the number of short positions is falling as a consequence.
4. Paradoxically, despite the number of shares being held by nominees falling and despite the falling percentage of short positions, the GXY share price is also falling. This must then be due to them being held down artificially (possibly as part of the covering) - which is of course is the manipulation which we see occurring every day, but which the ASX and ASIC consider to be business as usual.

I welcome being corrected if anyone believes that my above analysis is incorrect. I am always trying hard to improve my understanding of what is going on.