Wednesday, November 23, 2011

Agreement entered into by AAI stockholders re: sale of AAI shares to Prime Metroline Transit Corporation 23-Nov-2011 Disclosure No:8183-2011


A day after Active Alliance, Inc. (AAI) voluntarily suspended the trading of their shares on Nov. 22, five of AAI's major shareholders agreed to sell 60,000,000 shares (75% of AAI's outstanding shares) to Prime Metroline Transit Corporation for Php 200,000,000 (roughly Php 3.33 a share).

Much to my surprise, well not really, Prime Metroline Transit Corporation happens to be owned and controlled by Enrique K. Razon, Jr. (also the owner of Bloomsbury Investment). In light of this, we can safely draw an end to the week long speculation that Razon's new company Bloomsbury Investments, which is constructing a $1 billion integrated casino resort complex, will most likely use AAI as a vehicle to go public.

The question now is, will the Exchange or the SEC accuse and charge anyone for insider trading? Just to make sure we understand what insider trading is, Investopedia.com defines it as "the buying or selling of a security by someone who has access to material, nonpublic information about the security".


They go on to describe insider trading as an illegal activity "when the material information is still nonpublic--trading while having special knowledge is unfair to other investors who don't have access to such knowledge. Illegal insider trading therefore includes tipping others when you have any sort of nonpublic information. Directors are not the only ones who have the potential to be convicted of insider trading. People such as brokers and even family members can be guilty." (http://www.investopedia.com/terms/i/insidertrading.asp#ixzz1hR3d2Y1c)

If material information was only disclosed today, then how come we've seen unusual trading patterns occurring more than a week earlier? Why was AAI not aware of this possible material information especially since a majority of their shareholders were already planning to sell their equity ownership of the company? Or had they been aware, then why couldn’t they, on a more practical sense, have voluntarily suspended the trading of their shares a week earlier or once the rumors have somewhat started to affect their share prices rather than waiting a day before they disclose such material information?  If the argument was based on the fact that no deal was material yet, then why couldn’t they disclose that a discussion or deal was going on once their share prices were sporadically moving? Take Zeus Holdings, Inc. (ZHI) as an example. Earlier this year, ZHI also had rumors of a possible backdoor listing by a mining company which consequently had an impact on their share prices.  However, ZHI openly disclosed that it “has always been in continuing discussions with owners of mining claims” (DCL #5305: Zeus Holdings reply to unusual price movement) and does not deny the possibility that material news may occur. Therefore, the investing public can fairly speculate at their own risk without having to rely on pure hearsay.


Moving forward, what sort of action can we expect from the regulating bodies of the Philippine security markets? In a private interview with Market Surveillance Analyst with the PSE, the standard protocol for these types of occurrences is to process an incident validation, a review of whether or not a stock needs to be further investigated, after a series of unusual price movements have stabilized. They then analyze the movement of stock prices along with disclosures to verify the possibility of insider trading.  With the Market Surveillance group being private and all, I couldn’t fish any deeper than that. Frankly, I just want to see something concrete happening with issues like these. I wouldn’t mind watching a security related scandal erupting in the news since I find this crap exciting.

With insider trading becoming a prevalent issue in the Philippines, our regulators must work harder to identify and prevent such activity as to allow a fairer market place. If they can’t, I’d at least like to see them try and make a ruckus in the media. It would certainly draw a lot more attention to the market and the industry in general.

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