“Personally, I will be applying for maximum allocation across 4...

“Personally, I will be applying for maximum allocation across 4 accounts and expect 100% allocation”

Hi Lev

SPP regulations specify that the $15,000 limit relates to each individual holder and not to each individual holding account. It is an aggregate limit applied to SPP participation of each holder’s combined accounts over a 12-month period. ASIC’s Regulatory Guide 125 gives more detail. See for example:

RG 125.15
[CO 09/425] restricts the value of shares that can be issued to shareholders under our class order relief. Generally, no registered shareholder may be issued shares under the class order relief with an application price totalling more than $15,000 in any consecutive 12-month period (excluding shares applied for but not issued).

and

RG 125.18
When completing the certification in RG 125.16, or making the representation in RG 125.17, the registered holder must aggregate all securities issued to them, whether directly as the registered holder or in a joint capacity: see RG 125.19–RG 125.26.

I agree entirely with your belief that Management should not apply a total limit and accept all oversubscriptions, and more so that funds arising from the SPP should be used to advance the midkine programs (which currently are supported by a $2M loan attracting a15% interest rate).

Cheers