As is currently the case, ASX may ask some holders of limited securities (e.g., related parties. B, project proponents and essential holders) and their processing managers to execute a formal trust contract in the form of Schedule 9A. However, under the proposed regime, ASX will allow companies with smaller holdings to avail themselves of a provision in their constitution that imposes appropriate receivership restrictions on holders of limited securities and simple disclosure to the holder of limited securities in the form of a new Schedule 9C informing them of these restrictions. As announced by ASX on November 28, 2018 in its public consultation paper “Simplifying, Clarifying and Enhancing the Integrity and Efficiency of the ASX Listing Rules,” ASX proposes the establishment of a two-tiered fiduciary regime that will take effect on December 1, 2019. The proposed changes include an update to the ASX 15.12 listing rule for companies that are on or issue limited securities on or after December 1, 2019. Companies that have been on the official list and have issued limited securities prior to that date must continue to comply with the provisions of the 15.12 listing rule in effect immediately prior to that date.