The bank that holds your shares also holds a stake in the company

Healius's share registry is currently managed by Computershare, while MUFG-through its asset management arm-has become a substantial shareholder. That is the kind of juxtaposition most shareholders might glance at and file away under "admin." Registry providers process dividends, forward meeting notices, and keep the ledger of who owns what. It is unsexy infrastructure.

And here's the twist: MUFG isn't just a potential back-office vendor. It's already inside Healius as a substantial shareholder.

In June 2025, First Sentier Investors - a wholly owned MUFG subsidiary - filed a notice that it had crossed the 5% substantial holding threshold in Healius on the ASX. That made MUFG, through its asset management arm, one of the company's institutional blocks. The same financial group, through its acquisition of Link Market Services, now has the capacity to manage registers for ASX-listed companies.

The basic point is that this isn't really a story about registry fees or customer service quality. It's a story about plumbing convergence. One institution could move from being a capital allocator in Healius to also being the keeper of the books on Healius's entire shareholder base.

For the ordinary reader, "share registry" doesn't conjure much. The registry is the entity that holds the official record of share ownership, processes dividend payments, handles transfers, and distributes voting materials. It doesn't make investment decisions or sit on the board. It's more like the notary public of equity ownership: a trusted neutral administrator that stands between the company and its shareholders.

If MUFG were to acquire that role for a company, the structure changes even if the legal obligations don't. MUFG Corporate Markets - formerly Link Market Services, which MUFG bought in May 2024 and renamed in January 2025 - already services dozens of ASX-listed companies. The acquisition turned what was Australia's independent market infrastructure player into a unit inside one of the world's largest banks. Companies whose registries transferred to MUFG during the migration (Dyno Nobel, among others) haven't raised alarms. The service is the same. The name changed, and the parent company got bigger.

That's the normal version of the story. The Healius scenario adds an extra layer.

Here is the setup: First Sentier, acting as MUFG's investment arm, accumulates enough Healius shares to become a 5%+ holder. That triggers disclosure obligations - MUFG must file, the market learns about it, and governance watchers take note. Separately, imagine Healius decides to move its registry from Computershare (which has served them through 12,000+ shareholders) to MUFG Corporate Markets. The registry arm and the investment arm are different divisions with different mandates. They're not supposed to talk to each other about individual client holdings. But they share the same parent, the same consolidated balance sheet, and the same ultimate board in Tokyo.

Investor: I'm buying shares in Healius. Registry (MUFG): Welcome. Your holding is recorded here. Also MUFG, through a different subsidiary: We already own more than 5% of this company.

That's not, by itself, a conflict. The registry doesn't vote shares on behalf of the company - shareholders do. It doesn't set the share price. And the Australian Corporate Regulations around substantial holders, disclosure, and registry independence don't prohibit a bank from running a registry and holding shares through a separate asset management vehicle.

But it's the kind of overlap worth noticing. If the entity that maintains the authoritative record of Healius's ownership is part of a group that has a direct financial stake in the company's performance, information that flows through the registry - aggregate holder data, voting patterns, concentration signals - sits inside the same corporate universe that has a position to gain or lose.

This is basically the same question that comes up whenever market infrastructure gets acquired by a bank. When Link Market Services was independent, it was a pure plumbing company. Now it's part of MUFG, which lends money, manages assets, trades securities, and - apparently - is happy to service the registry of a company it's invested in. The respectable label is "comprehensive corporate services." The economic reality is that MUFG is building a stack around Australian equities where it can touch the investment, the custody, the registry, and possibly the lending. Each layer is fee-bearing. Each layer deepens the client relationship.

The simplest model is this: MUFG gets a better view of the Australian small-cap ecosystem when it owns more of the infrastructure that runs through it. Being the registry isn't the most lucrative layer, but it's a sticky one. Companies don't switch registries often. It's the financial equivalent of being the utility company - low margin, high retention, and you see everything.

Whether such a move would be cost-driven, a legacy result of the Link acquisition, or a deliberate play to consolidate Healius within MUFG's Australian footprint, I don't know. Healius hasn't spelled out any intention, and registry switches rarely do. The fee differential between Computershare and MUFG Corporate Markets could be enough to explain it on its own.

What I can say is that the structure deserves a quick glance. MUFG is already a significant shareholder in Healius. If it were also to become the keeper of the shareholder register, that would be a notable overlap. That's not a scandal. It's not even a traditional conflict. But it is a reminder that the plumbing beneath listed companies is no longer as independent as it used to be - and the companies watching your shares most closely might be the ones writing the ledger.