After extensive consultation with Members, SDIA has made a broad-ranging submission to ASX and Treasury.  Amongst the points made are:
o lender data reporting should be explored
o post-trade reporting of covered shorts is preferred to ‘real-time’ reporting
o enhanced disclosure would obviate the need for the tick test
o approved list be maintained for naked shorts only
o the buy-in process should not be re-introduced
o a thorough review of the area is justified, and
o above all, any new disclosure requirements need to be meaningful, effective and to enhance investment decisions.

Our thanks to all the Members who contributed to the framing and writing of this submission.  SDIA submissions are available to Members on our website.