Ann: Appendix 4C Commentary, page-322

I'm actually rather surprised. Between 23/5 and this morning, TEN fell from 21c to 16.5c, on increased volume (14.2M+ shares traded between 23/5 and 26/5, including all of today to date). Since 1/4 however, the daily trading volume has been 2.6M shares. Since 23/5, the volume has been 3.55M shares traded (including for today). This week, the daily trading average has been 3.4M (including today) whilst the last 5 (excluding today) has been 2.5M.

In comparative terms, at a time when the SP has dropped by 4.5c (or >20%), on increased trading volume (>35%, last 4 days, including today), when compared to the trading average since 1/4, the fortunes of AHF have been (at least) similar (but not necessarily so to the ASX).

In April, the trading average was 225,000 within a price range of 14c flat. Then, between 1/5 and 4/5, the trading volume went up to >1.45M (ie: 6.5x the April trading average). More shares were traded in those first 4 days (5.83M) than were traded in the whole of April (3.8M). Indeed, the first 4 trading volume for May was 1.5x that of all of April, at a time when the SP fell by 40% from 14 to 10c, before rebounding slightly.

Comparing the pair, the following has so far been obvious:
* TEN
- SP falls by >20% over a 4 day period
- trading volume is up 35% in the same period compared to the whole of period since 1/4 (through to 22/5).
- attracts a "please explain" from the ASX.
- MC = $61M

* AHF
- SP falls by 40% over a 3 day period
- trading volume is up 6.4x in the same period compared to the whole of period since 1/4 (through to 30/4).
- does not attracts a "please explain" from the ASX.
- MC = $21M.

This means either:
* ASX is only looking at larger, more popular (as in, talked about) companies (doubtful, as ASX has previously moved on companies big, small and indifferent);
* ASX was over stretched at the end of April with all the quarterly reporting that was occurring and so therefore missed out on seeing what had happened to AHF (very likely, as some 700+ companies reported their quarterlies during this time period);
* ASX doesn't care about companies like AHF (very doubtful, but unlikely to have sufficient resources available to devote too much attention to the smaller caps absent some courteous tips being provided); or
* ASX doesn't care for reining in and ensuring ongoing compliance by small caps (doubtful; contrary to its own regulatory oversight and social licence).

Michael might therefore have dodged a bullet back at end of April, but ASX has a nasty, sneaky habit, of catching up with them sooner or later (ie: as they wade their way through the reams of information provided, and then crosscheck this against trading patterns, behaviours, price trends and volume direction). Michael might well be thinking that everything's safe but, as we all know with the ASX and its market surveillance team, no-one (listed, managing, directing or disclosing, or failing in regard to same) is ever truly safe from their ever piercing oversight.