Koon Yew Yin's late disclosures (2)

Koon Yew Yin has replied regarding his late reporting, some snippets:


The reason why I reported late is because of the cumbersome system of reporting to the Bursa Malaysia. To fill up Form 29A & B requires details such as the number of shares and the date I bought or sold. Moreover, the buying or selling price frequently changes. To report the price I have to work out the average price I traded in the whole day.

To complicate the whole issue, I have margin accounts with TA Securities, Maybank, Kenanga, CIMB, RHB, HLIB, Alliance and Affin. My total margin loan is about Rm 150 million, my average daily trading exceeds Rm one million and the number of shares I buy and sell every day is quite many.

As I have so many trading accounts and I am 83 years old, I do not key in my orders to buy or sell myself. I simply give instructions to my remisiers to buy or sell and at a certain price. I have to watch to see the number of buyers and sellers so that I can change my previous instruction in order to succeed in my buying or selling. For example, if I see there are a lot of buyers willing to take the sellers, I will offer a higher price if I want to buy or sell. If there are less buyers, I will have to reduce my price offer to buy or sell.

A few times I made the mistake of instructing one remisier to sell in the morning the same share that I instructed another remisier to buy in the afternoon. In fact, the authorities had reprimanded my remisers who were involved in these transactions that may seem to mislead investors. Those were honest mistakes.

As a result of the above difficulties, I waited until I have sold enough to own less than 5% of the total issued shares of the company. I just have to fill up one form to state that I have ceased to be a substantial shareholder without the requirement of stating the dates and the prices I sold.


I have some sympathy regarding dealing with a cumbersome system.

But rules are rules, and they are there for a clear reason.

I assume that there were two easy ways out for Mr. Koon:

• The easiest way to deal with the situation is to make sure that one never breaches the 5% rule, so no announcements have to be made
• If however one wants to breach the 5% rule, and the process is too cumbersome to do oneself, then one should hire a good secretary for that job

The Star reported: "Koon not the only one", and gives several other examples of breaches of the reporting rule.

I always had the same impression, that enforcement was really lax on this rule, for instance here, here and here. If it is so easy to find examples, there must be many, many more examples, especially with shareholders often registering shares under someone else's name.

Some more observations from The Star's article (emphasis mine):

Areca Capital fund manager and CEO Danny Wong notes that timely disclosure is very important to ensure fairness and transparency across the market.

“It improves market efficiency for timely decisions and an inefficient market will discourage investors as it will only benefit insiders,” he says.

Wong also suggests that there should be a more robust system for disclosure here.

“It should be automated.”

Another observer who is well-versed with the local capital market concurs.

“In order to protect minority shareholders, substantial shareholders who are often the controlling shareholders should make the disclosure within 24 hours as opposed to the current seven market days so at least the minorities are aware that they (the substantial shareholders) have sold in the case of a disposal,” he says.

He points out that after seven days, a stock may have already lost a lot of value without the minorities being aware of what had actually happened.

In neighbouring Singapore for instance, the disclosure period requirement is much shorter, that is within two business days.

Fortress Capital Asset Management CEO Thomas Yong shares the same view as the rest.

“Trade actions of company insiders or even substantial shareholders are generally considered as material price sensitive information and as such require timely disclosures in the interests of protecting other minority shareholders and smaller-scale investors.”

It is about time that things change in Malaysia, both the cumbersome reporting and the lax enforcement. Both jobs are begging to be automated, something that should be pretty straight forward.

It would also require that the ultimate beneficial shareholders are revealed in a proper way, something that was also long overdue.

Koon Yew Yin's late disclosures

Article in The Star: "Koon in the spotlight over untimely disclosures", some snippets:


The late disclosures to Bursa Malaysia by savvy investor and philanthropist Koon Yew Yin on the disposal of his shares are now raising questions.

Based on Bursa’s listing requirements, a substantial shareholder needs to give notice on their acquisitions or disposals two weeks from the day they buy or sell the shares. In Koon’s case, he disclosed weeks later the disposal of his shares in VS Industry Bhd and Latitude Tree Bhd.

Being a substantial shareholder in both companies, his late announcements on the disposals have put him in the spotlight among his followers and the investing community.


No reason has yet been given for the lapses in making timely announcements.

The case is rather peculiar since Koon Yew Yin is also an active blogger, writing (amongst other subjects) about many of his share purchases, including those regarding VS Industry.

On i3investor there is a lively discussion ongoing (here and here, see the comments), whereby questions are asked if Koon had (apart from the legal obligation) the moral obligation to announce the selling of his shares since he also wrote when he was buying them.


In general, I am rather puzzled, why in this digital age are these kind of announcements not (semi) automated, at Bursa level, at company secretary level or both?

It should also not be much trouble to at least trigger an automatic alert within two weeks that a major shareholder has not yet filed the proper announcement since he changed his shareholding.

I have written in the past about this issue before.

Bursa limits information to 5 years ONLY? (3)

Good news, from Bursa's announcement website:


"Bursa Malaysia had on 20 April 2015 replaced the announcement dissemination system known as Bursa LINK. As we have over 1 million records of announcements made by listed issuers over a span of 15 years,  the data migration and verification has to be carried out progressively to ensure data integrity and reliability. During the initial period of migration, only announcements for a period of 5 years from 1 January 2010 are made available on the website. Thereafter, the remaining past announcements on Bursa Malaysia website will be progressively increased to 15 years within 3 months from 20 April 2015."

Bursa limits information to 5 years ONLY? (2)

MSWG comments on the same issue in their newsletter for April 30, 2015:


"On the capital market scene, recently, to our surprise, we learnt of a significant change in the provision of statistics and information pertaining to public listed companies (PLCs) on Bursa Malaysia website.

We have received complaints from retail investors and noticed that statistics and information including company announcements, quarterly financial results and annual reports were only available on the Bursa Malaysia website for 5 years. Hitherto, these information were generally made available for 10 years. We do not know why Bursa has taken this step to truncate information available to the public to only 5 years. In addition, no announcement was made on such a change.

Also, we believe this new development is somewhat regressive. It is always preferable for investors to have longer period of 10 years’ statistics including historical data and announcements at a one-stop centre to enable investors to carry out meaningful research. Particularly, if they need to do a time-series analysis which requires longer historical data.

We urge Bursa to reconsider providing these important statistics for the consumption of the general investing public who relies on reliable and up-to-date information in order to develop a more vibrant retail investors’ market."


First of all great that MSWG puts pressure on Bursa to reconsider the change.

I am also rather surprised, I would have thought that MSWG would have been kept in the loop of radical changes like this, but apparently not.

As far as I remember, Bursa started with their platform in (probably, I do remember some material from before 2000) 1999, and simply kept all announcements ever made.

In other words a great archive of all kind of information: financial results, IPO documents, shareholder changes of directors and major shareholders, related party transactions, etc.

I have been critical of Bursa on many occasions (mostly on enforcement related matters), but I have praised their website, for instance here:


"Despite having an otherwise excellent announcement website (I can't stress this enough, it is much better than all other announcements websites that I frequent), there is always room for improvement I guess."


If Bursa restricts the announcements to only the last five years, then I am afraid I have to take back my compliment.

The HKEX for instance gives information starting 1999:

SGX seems to be the worst of the three. They only offer announcements since 2010, also the user interface is confusing (their last update made things even worse), at least, that is my opinion. In addition to that, they even make  money on advertisements through Googleads, which I think they really should not do (users might mistakenly think that the companies featured in the ads are supported by SGX, which they aren't). SGX is making enough money as an exchange, they don't need this extra source of income.

Bursa limits information to 5 years ONLY?

I noticed the blog posting on Serious Investing:


"While checking out some information, I realised that I am able to search for information on a particular company only for the last 5 years (see below diagram). In the past I was able to obtain information for any particular company since 1999 if not mistaken as long as they were around since then.

Information for more than 5 years is definitely needed as one will need to look at trends or any changes that occurred, or even identify the progress of each of the company.

I am not so sure if this is due to Bursa limiting it temporarily due to some housekeeping reasons or is this permanent. If it is permanent, I will definitely need all readers to lobby to request for it to be reinstated to what was offered before. This is the period where information is more than important and critical for the sake of investor's knowledge. It is also when stock exchanges competes for clients - limiting information is many steps backward.

I thought Bursa was doing something great before."


I can't agree more with this, am absolutely shocked.

When I read the above I was sure that something had gone wrong, but it seems "Serious Investing" is indeed right. All information from before 2010 is gone.

These days hard disk space is almost for free while Bursa is making huge profits, having a monopoly, so money can not be the issue.

Especially in the light of the (terribly slow enforcement), where many cases take 7 years or more before they are even mentioned, how can anyone do serious research on Bursa counters, if one can not even find back what the enforcement was about? I have mentioned many cases in my blog dating back from before 2010, all those announcements are now not available anymore?

I hope all parties involved will pressure Bursa to restore the announcements website back to its old glory. This looks like a move completely in the wrong direction.