Why hasnt the ASX questioned XPE ?, page-8

You may be referring to a Price query letter. Refer regulation below


7.3 Price query letters

As mentioned above, ASX will generally issue a price query letter when it detects abnormal trading in a listed entity‟s securities and, in its discussions with the entity about that matter, the entity tells ASX that it is not aware of any information which has not been announced to the market and which could explain the abnormal trading.161 Usually a price query letter is issued on the same day as those discussions and requires the entity to provide a prompt response – often before the beginning of trading on the next trading day but sometimes even more promptly.
The purpose of a price query letter is to enable ASX to be satisfied that the entity is in compliance with its continuous disclosure obligations under the Listing Rules.162 The entity must respond to a price query letter by the time specified by ASX in the letter.163 Price query letters tend to follow a standard format. Generally, they will identify the abnormal trading and ask the entity to respond separately to each of the following questions:164

1. Is the entity aware of any information concerning it that has not been announced to the market which, if known by some in the market, could explain the recent trading in its securities?

2. If the answer to question 1 is “yes”: (a) Is the entity relying on Listing Rule 3.1A not to announce that information under Listing Rule 3.1? 161 As noted above, if the entity tells ASX that it is aware of information which has not been announced to the market and which could explain the abnormal trading in its securities and it cannot point to any other reason to explain that abnormal trading, ASX will generally require the entity to make an immediate announcement about the information under either Listing Rule 3.1 or 3.1B. The making of such an announcement avoids the need for a price query letter. 162 Price query letters are issued under Listing Rule 18.7. 163 Listing Rule 18.7. 164

Additional questions may be added to a price query letter if there are other disclosure issues about which ASX wishes to be satisfied. For example, if the price query letter is issued around half year or full year balance date, it may include questions intended to elicit whether the entity is expecting to announce earnings that might come as a surprise to the market.

A price query letter will usually ask for a response to be sent to a nominated listings adviser by email and advise that it should not be sent to the ASX Market Announcements office. It will also contain a statement that ASX reserves the right, under Listing Rule 18.7A, to release the letter and the entity‟s response to the market and therefore ask the entity to prepare its response in a form suitable for release to the market. ASX LISTING RULES Guidance Note 8 ASX Listing Rules Guidance Note 8 Page 42 XX January 2013 Please note that the recent trading in the entity’s securities would suggest to ASX that such information may have ceased to be confidential and therefore the entity may no longer be able to rely on Listing Rule 3.1A. Accordingly, if the answer to this question is “yes”, you need to contact us immediately to discuss the situation. (b) Can an announcement be made immediately? Please note, if the answer to this question is “no”, you need to contact us immediately to discuss requesting a trading halt. (c) If an announcement cannot be made immediately, why not and when is it expected that an announcement will be made? 3. If the answer to question 1 is “no”, is there any other explanation that the entity may have for the recent trading in its securities? 4. Please confirm that the entity is in compliance with the Listing Rules and, in particular, Listing Rule 3.1. Once the entity‟s response has been received and reviewed by a listings adviser, both the price query letter and the response will usually be published on the ASX Market Announcements Platform together, so that the market is aware that ASX has made enquiries of the entity about the abnormal trading in its securities and of the entity‟s response to those enquiries.165 7.4 Aware letters When ASX has concerns about whether a listed entity has disclosed market sensitive information at the time it.

You will note that the company issues the Appendix 3B and then a significant sell off and drop in SP that can be explained due to the conversion which is a normal occurence. In this case, no price query is needed as the company has issued an announcement on this beforehand.

IMO