Xinja APS 330 disclosures

So today we publish our quarterly APS 300 Disclosures. Actually quite interesting :ninja_emojis_pink_01: @XinjaMaker our CEO takes you thru the detail of what these are and what they mean for Xinja - check it out on our blog here.


If I look at the December numbers and then the March numbers total capital has only grown by $8m. I’m a shareholder but didn’t participate in the last exquitise round because then min was too large for me. Looked closely at the documents which said you had already raised $20m of the $50m for series D and other communications said you were very confident in filling the total $50m. I under stand the Middle East money is taking longer than expect but what happened to the other $42m of the $50m ?


I see that @CaptainXinja mentioned in another thread last week that another A$10m had been raised, which I assume was part of the Series D raise. The March 2020 Investor Update reported that A$20m of the A$50m had been raised as at that time. The March update also reported that Xinja had launched a sophisticated investor raise through crowdfunding partner Equitise targeting between A$1-2m for that raise.
So to @XinjaInvetsor’s point please can some clarity be provided to the state of the Series D Raise and also the Sophisticated Investors Raise. What is the total Capital position of Xinja as at end of May?
Thanks Glenn

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Hi @XinjaInvetsor! Our series D opened in November 2019 so a significant portion of capital was raised in 2019. Series D remains open and now we’ve raised over half of the $50m target.

Hi Glenn! Great questions. So Series D remains open and now we’ve raised over half of the $50m target. We typically disclose our capital on a quarterly basis; our March-20 capital position is available via our website and June-20 position will be available in due course :blush:

Re APS 330 -standard - see 43…”disclosures must be updated within seven calendar days” so if new capital had been received late in 2019 it should have been reported within 7 days. Likewise if new capital was received ‘last week’ as announced 7 days ago ( Captain Xinja) it should be already public now. An accurate and timely update on the series D capital raise and total capital is not unreasonable request by @glstafford.

Eric in the blog piece mentioned that “remuneration practices” are included in APS 330, but I haven’t found any rem disclosures in either of the 2 linked reports.

Am I missing something?

Hi @XinjaInvetsor - we update the VALUE of existing capital instruments each quarter and would disclose the FEATURES of any new capital instruments within 7 days - as APS 330 43 specifies. So next specific update re capital will be the disclosures end of June but as per above, we’re well north of $25m in series D and as per our comments last week, increasing.

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Thanks for the response.

43…”The disclosures must be updated within seven calendar days if the following occurs:”

43.a “a new capital instrument is issued and included in Regulatory Capital;

If you have received new capital (like the $10m a week and a half ago) and issued new shares (shares are a capital instrument)and that counts as reg capital, then I can’t see how that shouldn’t be disclosed within 7 days.

Happy to be pointed elsewhere in the standard if I have read this wrong. I’ve noticed the other independent neo bank I’ve been following and friends have invested in Volt Bank update their disclosures every time new shares are issued.

As a min anyway can I suggest it would be helpful for Eric to clear these matters up with an email to investors via the portal.

Thanks again.

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I am not on top of the legal / disclosure aspects of this, but in theory and as a shareholder this is a concept I am broadly in agreement with.

Hi @Jill - thanks for the question - the remuneration part is only disclosed after an ADI’s (bank’s) annual report (within 3 months of that) - ie: it’s part of our annual not quarterly reporting. As our first annual report will be October 2020, we’ll publish before end of Jan 2021 (take a look at attachment I, table 24 of APS 330 here - you have to scroll quite a lot.)

Appreciate the clarification, @CaptainXinja. I forgot about the fact that Xinja was yet to release its first annual report. Cheers!


@CaptainXinja or anyone else - have you had a chance to re-read 4.3a yet ? It just seems clear to me that if Xinja has issued any new shares it must disclose within 7 days like every other ADI does. Perhaps you could get one of your compliance experts to have a look at it and respond ?

Hi @XinjaInvetsor Thanks for this and apologies for the delay in getting back to you - was checking with the team. Whilst the capital injections were agreed a few weeks ago, the actual share purchases were processed last week, and the reg disclosures have now been updated which is within the 7 days. (see here)

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Thanks just saw that now. So my read was correct and you will be complying with the standard from now on rather than just doing a quarterly update ?

Given you haven’t been doing that to date are you going to go back and provide the amounts and changes between the quarters so investors like myself can get a accurate picture of what has happened when.

Better still, how about a investor update with exactly the amount raised in series D, any incentives given to last min investors ( rumour has it they got some extras sweeteners ).

I’d suggest a honest and realistic assessment/update on the World Investments $443m is overdue also given the Equitise program was held open so this positive news could be announced.


Hi @XinjaInvetsor not sure where you get your rumours from, but no sweeteners as far as we are aware :ninja_emojis_pink_03: Eric’s actually sending out an update to investors tomorrow, so watch out in your inbox for that.

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Would be great if you can confirm you will be complying with APS330 from here on eg reporting any change in capital within 7 days or if the disclosure ( thanks) was just a one off because raised here ? Thanks.

Hi @XinjaInvetsor - just to clarify, the recent update was made within the 7 day window. The APS 330 disclosure ‘capital instrument’ will be updated within 7 days of any share issuance. Many thanks!