I do understand that lodging a notice is the responsibility of...

I do understand that lodging a notice is the responsibility of the sub holder BUT (1) a change can be just 1% (if already above 5%) AND MORE IMPORTANTLY (2) if the management has the knowledge that a sub holder is failing to lodge a notice and that the change was due to a placement BY the company (/management) and that the management was not keen for the investor to be known ... then I am sure ASIC would be interested to look at ALL aspects not just the failure by the sub holder to lodge.