6 February 2008
ASX Regulatory Policy Unit
20 Bridge Street (Level 7)
SYDNEY NSW 2000
regulatorypolicy@asx.com.au
Dear Sir/Madam
Omnibus Listing Rule Amendments
The Group of 100 (G100) is an organisation of chief financial officers from Australia’s largest business enterprises with a purpose of advancing Australia’s financial competitiveness. The G100 is pleased to provide comments on the proposed changes to the ASX Listing Rules.
ASX proposes to introduce a requirement that entities announcing an SPP nominate the day prior to the announcement as the record date for eligibility to participate.
The G100 supports the proposal which will remove uncertainty and clarify which party has the entitlement. The proposal is unlikely to increase the cost burden for companies.
The ASX proposes to amend admission rules to enable the listing of SIVs.
The G100 supports the proposal to amend the admission rules for these entities.
ASX proposes that a shareholder mandate be obtained every 12 months and in any event for any capital raising excess of 25% of a company’s capital?
The G100 supports this proposal.
ASX proposes companies seeking listing to have at least 200 shareholders (currently 400), each with holdings of at least $2000 worth of shares; and net tangible assets of at least $4 million (currently $2 million).
The G100 supports this proposal.
ASX proposes that companies seeking listing to no longer be subject to the requirement that at the time of initial listing the issue price of sale price of all the securities for which the entity seeks quotation (except options) must be at least 20 cents.
The G100 supports this proposal.
While supporting the proposals in respect of capital raising rules (para 3.32), shareholder speed rule (para 4.10) and the minimum issue price, the G100 suggests that consideration be given to having separate boards for entities with significant market capitalisation and those which are described as SMEs which have a market capitalisation of $100 million or less.
Yours sincerely
Tony Reeves
National President