Yep, what bb said...this furphy has been flogged to death multiple times. ASIC has no hard and fast rules as far as timing goes (some companies/Boards do, but not ours), and advise that everything is a matter of individual context and assessment: company/Board need 'only' make the case to ASIC that this or that trade can be reasonably demonstrated to not represent an exploitation of not-declared-to-market knowledge. In the case of FP's smallish, regular, long-term superannuation fund buying there is just no chance in hell that ASIC would ever find that it was. The end.