haha, first class rant @Scoonie

You're not far off the mark I think :)

I agree with most of what you're saying. There are a lot of bad actors and not may examples where it makes sense to pay NTA.

The only thing I would say is that closed end funds (in theory) should perform way better than open ended ones. Money flowing in when things are going well and then flowing out when things aren't going so well is kryptonite to any active management strategy.

Nine holdings though. Wouldn't take much to have a bad month/quarter/year. All that concentration to do ~7% since inception. The luxury of closed end fund I guess.

Some of their holdings are rubbish though. Take MOV - so illiquid they only traded on 4 days through the entire month of March and they currently have 3 bids on the buy side (and one of those is for a grand total of 6 shares) and zero offers on the sell side. MOV has a $58m market cap, so must be held in their "emerging" fund (NCC). MOV is featured on page 21 of their NCC-Q2-FY24-Investor-Update-and-QA---Presentation-Materials.PDF.

The other company featured on that page was Maxiparts (MXI) which has fallen from a $2.98 high in mid-August to end Feb and March at $2.39.

In every one of the NCC monthly NTA reports for this FY (so the July, August, September, October, November, December, January, February and March reports) they have highlighted the same three companies:

And here's the 12 month charts for those three companies:

Which charts are you looking at @neke86_ ?

By the way, another drag on their performance, apart from terrible stock picking, is their high base management fees.

So very true @Bear77. A woeful peformance and the hide to draw such high fees.

This Fund shoud be more properly named to align with the realities - The 'Seb Evans Retirement Fund'

In the case of Seb, his conviction is highly aligned to the degree of his ownership of the above companies.

And there are more than a few others out there as well. I'm thinking The 'Michael Glennon Retirement Fund' for Clennon Capital (GC1)

The LIC model is moribund and there are better solutions out there for passive investible funds.

With deep regret, I must fess up and say that I have made past contributions to both of these turkeys.

I think @Solvetheriddlegave some great advice about analysts and gurus recently.

It is my opinion that very concentrated funds - i.e. funds with very few holdings and therefore sizable positions in each company they hold - and that certainly includes NAOS as they are "Subs" for many of the companies they hold and claim to have 7 board seats - i.e. due to their substantial shareholder positions in their core 15 holdings they have been able to nominate 7 people to the boards of 7 of those 15 companies - have an advantage in being so close to management - but they also can have a disadvantage and that disadvantage is around not always having a wide enough perspective of where that company sits within (a) their own industry, and (b) the range of alternative investments there are to choose from out there. The advantages are that they may feel they always have the inside running on what is going on within the company, but I even have doubts about just how accurate that is. Even board members don't get to know everything that is going on within a company in many cases, and management are very unlikely to want to share negative news with one of their largest backers (owners) if they can get away with not sharing it. They will always want to keep the relationship sweet by always giving them all of the good news and presenting everything with a positive spin.

Perspective is gained from a distance, not from being up close. Ideally, good fund managers can do both - they can maintain a healthy relationship with a company's management and also maintain some perspective so they understand where the company sits in relation to their competitors, their industry, and alternative investment opportunities. I have little evidence to make me think that NAOS are good fund managers however. What they seem to be good at is maintaining a decent income for themselves at the expense of their investors.

You have to remember that Warwick Evans has done his time and made his money - he's a legend in the industry with over 35 years of equity markets experience, most notably as Managing Director for Macquarie Equities (Globally) from 1991 to 2001 as well as being an Executive Director for Macquarie Group. He was the founding Chairman and CEO of the Newcastle Stock Exchange (NSX), and was also the Chairman of the Australian Stockbrokers Association. Prior to these positions he was an Executive Director at County NatWest. Warwick doesn't need this (or any) gig now, he is basically retired, but he's set up NAOS for his son Sebastian Evans to run.

Sebastian is young, and inexperienced in the industry, and his Dad is letting him make mistakes. The issue is that NAOS either do not want to exit their mistakes, or don't want to acknowledge their mistakes. And in some cases - such as MOV - they can't get out without completely trashing the share price, because of their position, and the illiquidity of the stock, so they don't have much choice other than to hope the bad company comes good.

Further Reading:

https://www.naos.com.au/team/warwick-evans

Where are they now? (afr.com) [27-Apr-2001]

https://www.naos.com.au/team/sebastian-evans

Sebastian is the CIO (Chief Investment Officer) across all of the NAOS investment strategies, so NAOS is his company, set up by his Dad, Warwick, but it's Seb's show and while he's making a good living for him and a few choice friends, NAOS' investors haven't done so well.

Source: https://www.naos.com.au/about-our-firm#people

The issue is that either NAOS do not want to exit their mistakes, or don't want to acknowledge their mistakes.

I think the bigger issue is that as with most of these LICs, you raise the money once and then that's it. If people are unhappy they sell their shares. There's no accountability in this structure at all and the performance bears out that fact. You can make it even less likely to attract activism by putting the FUM into illiquid micro/smallcaps that makes value realisation via a wind-up not worth the effort.

Evans is late 30s. If he hasn't learnt the trade by now he likely never will. I suspect, you are right that his dad set this up for him and it's really just a way for a guy of average ability to LARP as a fund manager. I mean come on, he went to Bond University when it was still anyone gets in as long you pay the fees. You don't go there because you got into Sydney/UNSW/UTS etc.

@PortfolioPlus i always had a sneaking suspicion NaoS was a gift from father to son, for Seb to play around in. Seb is not a bad guy, but i cant understand their approach or stock selection. i am about to write a piece (unfavourable) about LIC's in general as well

Their figures they calculate themselves, ignore all IPO costs and subsequent dilutive capital raising effects, report before all base and any other performance fees. In reality, probably performance would lucky to be half of the 7% p.a. they are trying to tell us. Money going backwards after inflation. As others have implied, to be only trading at such a small discount amazes me. It is the sort of fund that should trade at a 25% discount at least. For those stuck in it but liking some of the portfolio's holdings, seems like a no brainer to exit, buy some small parcels of their 9 securities they own directly if you are keen on some of them.

Fair points @UlladullaDave - and OK, he's not quite as young as he looks clearly, but he's young enough, and certainly inexperienced in terms of his investment experience being limited to NAOS:

Source: https://www.linkedin.com/in/sebastian-evans-bb663528/

Interesting that he started at NAOS (as a PM) in 2006, and they claim to have started in 2013:

"NAOS established its first Listed Investment Company (LIC) in 2013 with 400 shareholders, today NAOS manages three LICs and one private investment fund for approximately 7,000 investors."

Source: https://www.naos.com.au/about-our-firm#firm

In terms of your point about the CEF nature of LICs providing a disincentive to perform, I take your point, however while a 1.25% (plus GST) p.a. management fee is guaranteed regardless of performance, NCC has a 20% performance fee payable if they beat their benchmark index (the S&P/ASX Small Ordinaries Accumulation Index) so you'd think that would provide some incentive to be better than mediocre. The fortunate thing for NCC shareholders (and there isn't much for them to be happy about) is that there is a watermark feature, so any underperformance to the Benchmark Index is carried forward to future performance calculation periods and must be recouped before the Investment Manager is entitled to a performance fee. So perhaps they have just given up on earning performance fees as a result of that watermark feature.

Compared to NCC's 1.25% and 20% fee structure (and +7.26%p.a. investment portfolio performance since inception, before fees), NSC has a 1.15% and 20% fee structure (and +1.59%p.a. investment portfolio performance since inception, before fees), and NAC has a 1.75% and 20% fee structure (and +8.97%p.a. investment portfolio performance since inception, before fees), so their base management fees all vary, but their performance fees are all 20% and all have that watermark feature.

They don't all have the same benchmarks however. NAC Benchmark = S&P/ASX 300 Industrials Accumulation Index, NCC & NSC Benchmark = S&P/ASX Small Ordinaries Accumulation Index.

NAOS didn't start NCC, they took over the Contango Microcap Fund in 2017 - see here: Contango Asset Management parts ways with listed micro-cap fund, NAOS in frame (afr.com) [21-Oct-2017]

And here: Contango MicroCap Limited: Change of Investment Manager, board and company secretary changes (naos.com.au) [25-Oct-2017]

Yet, in February (2024, so 2 months ago) NAOS were claiming +7.76%p.a. performance since inception for NCC, and stating that "inception" included part of February 2013, being the inception month of the fund:

NAOS had nothing to do with the fund until late 2017. And NCC's performance under NAOS management was a lot worse than under Contango's management, as shown by those 1 year, 3 year and 5 year performance numbers (p.a.) highlighted above. I do note that as soon as NAOS took over CTN (the Contango Microcap fund) they sold every single company out of the portfolio and replaced those companies with ones they held in their existing two funds, so prior to October 2017 and post-October 2017 the portfolios were completely different and bore zero similarities to each other. I believe the bulk of that +7.76% p.a. portfolio performance was actually obtained prior to October 2017 when the fund had a different name and a different manager.

Additional: I believe they pay high dividend yields for two reasons, being (1) because they hold shares in the LICs so gain additional income from the divs, and (2) because without the income aspect why would anyone invest in those funds considering their sub-par after-fee performance? So it means they can trade around NTA, sometimes.

They have traded at significant discounts to NTA in the past, as they should, but LIC discounts have been reducing lately as a number of underperforming LICs and LITs have been converting back to open ended structures that trade at NTA (latest being FOR) or else are being wound up.

The LIC structure gives them far more leeway to pay much higher dividends than their actual fund earnings, and also doesn't require forced selling due to fund redemptions (that would obviously occur if these were open-ended funds). So the structure certainly suits them. No doubt about that.

All good points @Bear77. I think we are in violent agreement.

Just on this...

In terms of your point about the CEF nature of LICs providing a disincentive to perform, I take your point, however while a 1.25% (plus GST) p.a. management fee is guaranteed regardless of performance, NCC has a 20% performance fee payable if they beat their benchmark index (the S&P/ASX Small Ordinaries Accumulation Index) so you'd think that would provide some incentive to be better than mediocre.

I'm sure they try and beat the index, I just don't think they have the skill to do it. And who will roll Evans and the two PMs for chronic underperformance? They should have been booted out years ago.

Well picked up @Bear77 with the contango history. From my memory when Naos suddenly came in and turned over the Contango portfolio within a month or so, they got off to a terrible start and shareholders would have been much better sticking with the stocks Contango had. Since then Naos have always used some "very friendly" assumptions when stating their NCC performance.

Got to give Seb credit, he does hold a Masters in Applied Finance from FINSIA. But I can tell you one thing, Applied Finance does not make you a great trader or stock picker. I'm doing the degree right now at MQ and not really learning much other than how to be a good mathematician/statistician or maybe risk management. You can and search for some of the Applied finance programs to find the subjects covered. I'm doing the barebones pathway to complete the course as I now don't have time to explore the optional subjects but there is a 3rd year accounting subject on ASIC reporting that looks interesting.

Probably the only LIC that did well for me was Templeton Global Growth which got taken over by WGB (Wilson Global Growth). If I converted my TGG shares to WGB I will probably be nearly breakeven if I decided to not take the cash (that money from TGG is now sitting in a global ETF which has outperformed WGB). Herein lies the challenge of LICs as highlighted they find it hard to beat the market and yet the fees they charge eat into the investment. Not appealing for an investor.

I also held TGG back in the day @edgescape - but sold out a year or two before Wilson's took them over. The funny thing about the Templeton Global Growth Fund (was TGG.asx) was that despite having the word "Growth" in their name, they were a traditional "Value Fund", in the spirit of the company's founder Sir John Templeton.

During a roadshow, back when they did those (before Covid), I asked the previous portfolio manager (back when it was still TGG and Geoff Wilson's WAM Funds were just holders of TGG shares and quietly agitating for change rather than moving to take the fund over, which they ultimately did) why the fund name had the word "Growth" in it despite being a value fund, and he (I think his name was Peter something) said that Sir John believed that the best way to achieve growth was to buy good stocks at bargain prices and then wait, so value investing was the best way to achieve growth. Interesting POV, but I still believed the fund name at the time was misleading for most investors. I do remember they held a bunch of tradional global energy companies (oil producers) at the time I sold out.

Speaking of roadshows, I attended a NAOS roadshow the same year with a friend who asked Sebastian directly about their intentions relating to the Contango Convertible Notes and he said that was not his area of expertise and couldn't answer. He was the MD of NAOS and the CIO of all three LICs and he couldn't answer. Here is what they did in November 2019: https://announcements.asx.com.au/asxpdf/20191128/pdf/44c1sy5ynqgk0r.pdf

He may have had reasons to not want to answer, but he managed to convince us both that he really didn't know as those sort of decisions were being made by others - such as his Father. There were other answers given to questions at the two NAOS roadshows I attended that left me feeling less and less inclined to invest in their LICs at the time and afterwards. We had invested in one of their LICs in prior years and were still invested in that one when we attended the first roadshow in Adelaide, but we had moved on (sold out of it) by the time I attended the second one. I can't remember all of the details but, as well as highlighting some of their favourite companies, they also highlighted some companies they would never invest in and why, and their reasons struck me as a little naive bordering on blinkered (tunnel vision), but I won't go on as I can't remember the actual companies they discussed. I did take notes at the time but I don't have them now. This was 6 years ago. Sometimes you get a strong feeling of unease about a management team and that's what I got about Seb and his mates - Warwick was in the background (in the room) but never got involved in the presentations or the Q&A at the end.

@Bear77

Unlike NAOS, TGG appeared to be active traders which seem to be the opposite of what you had when you held. Every 6 months they would change their holdings. One time they had Silbanye stillwater and that Japanese company that had a share of Nothparkes gold/copper mine before gold prices mooned and sold at the highs. Then next period they have Johnson and Johnson etc. However they did hold a few long term such as Samsung, FedEx. Overall it annoyed the hell out of me that they kept switching but at least they got the timing right.

I bought TGG around the COVID period when I wanted something with global exposure that had minimal admin on my side (I wanted to avoid having more of those managed fund tax statements) plus they had a few holdings I liked including FedEx, Google and Samsung and they just sold Shell (or was it BP?) which must your reference to oil producers.

Anyway I digress. Going back here, NAOs appears to be one of those high conviction funds. Pity it hasn't turned out right.

Hi @Bear77 I looked at the three you mentioned, the only three they repeatedly highlight as you say (screaming red flag) but then I looked at these:

I inferred that, if they were notable, they must be most of the other holdings. Of course it's impossible to make any judgement without weightings so can only back-of-the-envelope this roughly.

I agree with everything you said!

Fair call @neke86_ - we know that NAOS hold MOV because they lodged a notice today saying they have just increased their position from 15.59% to 16.59% - see here: SPH-Notice---NAOS-(MOV).PDF

And MOV's SP has been all south east, not north east. The following graph shows the share price movements of those 7 listed companies that you highlight there over three years (one or more of them hasn't been around for 5 years because the graph would not go back that far with all of them):

We know they hold 16.59% of MOV, a NZ based company with a $58m market cap.

They may have a stake in Tuas (TUA) however TUA is a $1.8 Billion company now (go Teoh!) and so too big for NAOS to show up as holding 5% or more. My question would be, if you held Tuas shares, why would you not highlight THEM in your monthly reports rather than SND or BRI?? Also, Tuas are too large for the "emerging companies" fund (NCC) and the Small Cap Opportunities Fund (NSC). If they held Tuas, it would have to be only in NAC, their ex-50 LIC.

After Tuas, the next best performer has been Sigma Healthcare (SIG), however SIG's market cap is over $2 Billion, so could only be held in NAC, as they don't qualify as an emerging company (NCC) or a small cap (NSC).

QAL has a $760m m/cap and NAOS are not Subs of Qualitas.

Dropsuite (DSE) is a $209m company so they do qualify as a small cap and probably also an emerging company, however NAOS are not Subs of DSE either.

Mach7 Technologies (M7T) is a $172m company and NAOS are not Subs once again.

And that leaves Paragon Care (PGC), a $214m company, but again NAOS do not appear on the PGC Substantial Shareholder list either.

---

By contrast, Saunders International (SND) is a $105m company and NAOS are Subs with 24.57%, so almost one quarter of the entire company, Big River Industries (BRI) is a $143m company and NAOS are Subs with 36.42% of BRI, and COG Financial (COG) is a $269m company and NAOS are Subs with 31.24%, so almost one third of the company.

SND and BRI have dropped a fair way in the past year, so both would have had m/caps of closer to $200m this time last year.

NAOS talk about having nominated a director to the boards of 7 of their 15 core holdings. One name that pops up is Brendan York.

Brendan joined NAOS in July 2021 as a portfolio manager. Brendan is also a non-executive director of Big River Industries Limited (BRI), BSA Limited (BSA), Saunders International Limited (SND), Wingara AG Limited (WNR), BTC health Limited (BTC) and MitchCap Pty Ltd.

Brendan has over 19 years’ finance, accounting and M&A experience. Most recently, Brendan had a 15-year career with ASX-listed marketing services business Enero Group Limited, initially in finance roles and ultimately as CFO and Company Secretary for a nine-year period. Prior to that, Brendan spent four years at KPMG. Brendan is a chartered accountant and holds a Bachelor of Business Administration and a Bachelor of Commerce from Macquarie University.

Source: https://www.naos.com.au/team/brendan-york

BSA is a $47m microcap which NAOS own 38% of.

WNR is a nanocap worth less than $3m, and NAOS held almost half of the company (45.31%) at last notice (March 2023) - see here: Change-in-substantial-holding-NAOS-for-Wingara(WNR).PDF

BTC is a nanocap $17m company and NAOS own 25.72% of it.

So we know that NAOS are substantial holders of BTC, WNR, BSA, MOV, SND, BRI and COG, and have Brendan York on the board of 5 of those 7. Here's the 3 year graph of those 7:

Both this chart and the previous one only go back to just before July 2022 and the common dominator is MOV who have only been listed since 05-July-2022, so these are really 21 month charts, however what we can see is that over that time period only BSA has provided a positive share price return for NAOS.

We can also see that many of their holdings are very illiquid and trade rarely, hence the straight lines instead of sqiggly ones. These are "lobster pot" stocks - you can get into them if you take your time, but getting out in a hurry is damn near impossible.

Anyway, if I remove MOV, we can get a 5 year graph of those other 6 companies:

And so we find that despite the past couple of years being negative for most of them, over 5 years they have had three out of the six that provided positive returns from a higher share price. The net result has been poor returns, and even worse for shareholders after fees. These LICS have provided some decent dividends, but those divs have also had the effect of reducing the LICs' NTAs even further as that capital went out to shareholders.

In terms of those 7 listed companies that you mentioned @neke86_ - leaving out Ordermentum as it is unlisted - it appears that they likely only hold one (MOV) of the 7 that we can confirm anyway and I would suggest they have mentioned meetings with companies like TUA and SIG to infer that they may own them, when in fact they probably do not. JMO FWIW.

Yes @edgescape TGG still held both Shell and BP when I sold out, and they did have some reasonably regular portfolio turnover, unlike a deep value fund, but at the time I was following them (pre-covid), they weren't invested in a lot of stocks that people would generally term growth stocks, with some exceptions, like Samsung. They seemed to be buying undervalued companies and waiting for a positive rerate and then selling them, so shorter-term investing based on value rather than growth. Traditional value funds tend to hold for longer periods, as do tradional growth funds too I guess. Perhaps they were just very good at identifying value that could be realised over shorter timeframes. I remember that their dividends were decent and they had a reasonable profit reserve to fund those dividends.

My concerns at the time were around not really being comfortable knowing what I held via TGG at any given time because there was a lot of chopping and changing as you say and they moved in and out of sectors seemingly on a whim but more likely related to where they identified value at the time.

Additional: I just thought to look at the NSC and NAC reports for their "Core Investment Portfolio Examples" and NAC have been highlighting MOV, MXI (Maxiparts) and UBN (Urbanise), while NSC have been highlighting MOV, MXI and BRI.

So in addition to those companies listed in my previous post, NAOS own 18.2% of MXI, a $141m microcap company, and 26.8% of UBN, a $22m nanocap. Here is how those two have performed over the past five years:

Clearly lots of crossover between the three LICs and it doesn't seem to matter much how big they (the companies they hold) are either - the LIC titles don't seem to apply very much.

The crossover always annoyed me. Especially when two of the LICs are clearly subscale.

It is crucial that these 3 LICs stay listed separately, which paves the way for 3 sets of directors' fees contracts. This helps with the Australia's cost of living crisis, so the directors on the boards of each can boost their cashflow in these tough times.

This is an amazing reply thank you Bear!

No problem at all @neke86_ - as I said, looks like NAOS do not have much if any exposure to those companies on your list (except MOV) of companies they've held meetings with recently, but I could be wrong. Actually I am - they hold Dropsuite (DSE) - or at least they did in November:

Source: NAOS-NCC-Prospectus.pdf [1 for 5 NCC options prospectus last year]

By the way APL (Associate Global Partners Ltd, formerly Contango Asset Management Limited and also once known as Antipodes Global Investment) has a market cap of $5.4m (yep, less than $6 million) so another nanocap, and NAOS own 23.4% of APL, however NAOS do NOT show up as substantial holders of Dropsuite (DSE) despite DSE being a $209m microcap that is well within the size range of companies where they HAVE taken substantial stakes (of over 5%).

Have a gander at those NCC performance numbers, their portfolio performance after operating expenses but BEFORE all fees, taxes, IPO costs and subsequent capital raising costs, was (at that time) negative over 1 month, 1 year and 3 years, and they had underperformed their benchmark (the small ords accumulation index) over every time period up to 10 years.

So we can add DSE and APL (Associate Global Partners) to the list of what they hold, and that makes 11 companies that we know of (APL, BRI, BSA, BTC, COG, DSE, MOV, MXI, SND, UBN and WNR). Note however that MOV, MXI and UBN (three companies that we know NAOS are substantial shareholders of) were not held in NCC, so they were held in either NAC, NSC, or both, but not NCC.

I tried to do a 10 year chart of those 8 companies on the left in that list above (page 14 of that prospectus, the listed companies, the other two on the right are unlisted, and I've ignored the BSA options) however Big River Industries (BRI) has only been listed since 28-April-2017, so a 10 year chart does not work with BRI in there, however here's the 5 year chart of all of those companies listed above that were in the NCC portfolio on 30-Nov-2023:

Ain't that a bitch - the one that has performed best is the one they hold the least amount of, i.e. less than 5% of the SOI. (Dropsuite. +719%).

Including Dropsuite (DSE), they have 4 in positive territory (DSE, SND, BRI, COG) and 4 in negative territory (BTC, BSA, APL, WNR) over 5 years.

Over 3 years there are also 4 positive (DSE, COG, SND, BRI) and 4 negative (BTC, BSA, WNR, APL). Same 4 in each case.

Over 1 year there are 3 positive (BTC, DSE, BSA) and 5 negative (COG, SND, BRI, APL, WNR).

Only DSE has been positive over 1 year, 3 years and 5 years (i.e. all 3 time periods), however WNR and APL have provided negative returns over all three time periods. The companies that were positive and negative over 3 and 5 years were the same over both time periods, however the order changed (I have listed them in descending order of returns for each time period - from best returns down to worst returns).

Not sure what happened with DSE (where NAOS are not Subs) but NAOS' M.O. is usually to take significant stakes in smaller companies, and they almost always show up as "Subs" in those companies - meaning owning 5% or more of the SOI (shares on issue) of those companies, such as with MOV where they own 16.59%. They don't have a board seat at MOV, but then they would likely need more than 20% to get that, and MOV is HQ'd in New Zealand, which makes it a little more difficult unless everything is done via Zoom meetings. And they say that they have 15 core holdings (combined) across all three of their LICs, and we know 11 of those 15 - APL, BRI, BSA, BTC, COG, DSE, MOV, MXI, SND, UBN and WNR. And the two unlisted companies, MitchCap Pty Ltd and Ordermentum Pty Ltd. That makes 13. If anyone knows who the other 2 companies are that are core NAOS positions, please chirp in!

They talk about Mitchcap in detail here: https://www.naos.com.au/ncc-monthly-investment-reports/ncc-investment-report-nta-september-2022

They talk about a heap of those companies here: https://www.listcorp.com/asx/nsc/naos-small-cap-opportunities-company/news/naos-quarterly-investment-report-q2-fy24-2986270.html on pages 5 and 6, and then they devote two pages to Maxiparts (MXI, pages 8 & 9), then one page each to SND, COG, UBN, GTK and MitchCap. They discuss BSA on page 16 and 17.

Gentrack (GTK) was a core investment of NAOS, and they raved about the company on page 13 of that report (first link above) - which was released in January 2024 and is for the quarter ended 31-Dec-2023, however at the top of page 14 they say, "The future of GTK remains as bright as ever and as management have delivered or exceeded expectations a number of times, the valuation of GTK has been re-rated significantly. Due to this GTK is no longer a NAOS core investment, but it remains a company we will be watching closely as the growth prospects for this business remain far greater than its existing operational footprint."

Indeed, NAOS sold all 6.27m GTK shares on 29-May-2023, so they don't hold GTK shares now.

I have found a few other companies - as well as Gentrack - that NAOS were previously Subs (substantial shareholders) of - but they appear to have sold out now:

1. Experience Co. (EXP) - NAOS held 15.97% of EXP in March 2020, but have been progressively selling down and are now out, having sold their last 14,199,751 EXP shares for a total of $2,927,735.41 on 7-July-2022, so not holding any EXP now. EXP's current market cap is $110m.
2. Over The Wire (OTW) - NAOS were substantial holders of OTW, but OTW was acquired by Aussie Broadband (ABB) in May 2022, and NAOS do not appear to be invested in ABB.
3. EGH was one they talked about a fair bit in various newsletters and reports, however Eureka Group Holdings is a $164m microcap and NAOS are no longer "Subs" for them.
4. 360 Capital REIT (TOT, formerly 360 Capital Total Return Fund), NAOS ceased to be substantial shareholders of TOT on 27-Sep-2021, and it looked like they sold all of their TOT shares on that day.
5. URF Masters Residential Property Fund (URF) - NAOS became "Subs" for URF in July 2021, but are not now.
6. FFT/ASV - in January 2022, NAOS became "Subs" for Future First Technologies (holding 6.6%), however this happened to FFT and they changed their name to Asset Vision Co. (ASV) and are now worth a grand total of $11.6m. NAOS sold all of their ASV shares on 05-July-2023 before that name change. At the time, according to Commsec, NAOS sold 50,324,926 ASV shares which was 7.85% of the company, however according to their (NAOS') ceasing notice (Ceasing-to-be-a-substantial-holder-FFT-(NAOS).PDF) it was 24,998,688 shares and they received $262,475.17 for them, so a bee's whisker over 1 cent per share. ASV closed on Friday at 1.6 cps.

That'll do for tonight.

Is it working?

These are some of the images that NAOS have been using either on their website or in their various reports and presentations. Why? Dunno, but could be to try to calm their investors down after they read the performance numbers.

Further Reading: How can the worst feature of LICs also be the best? (morningstar.com.au) by Graham Hand [17 February 2022]

It's outrageous that it takes this much effort to figure out their holdings, and that they obviously are being a bit misleading with the way they list "notable reporting" for companies that you as the unit holder would have no exposure too at all? They may as well list NVDA.

Agreed @neke86_ and their reports often do not age well, when they say they've met with a company that they do not hold, and continue to not hold, and then that company does a lot better than many of the companies they do hold.

Because of the severe lack of liquidity with a few of the smaller companies they hold - the illiquid nanocaps - they would understandably not want to advertise that they were building a position, because building a sizable position in such companies takes considerable time, and they don't want to alert the market that they see that company as one of the best opportunities available to them at that point in time and then see the share price go up and cause them to pay more - that I can understand, and maybe they never really know whether they have as much as they want to hold, but if they ever do say to themselves, "Yep, that's enough of that one," then I reckon they might actually benefit from saying, "We hold XYZ", but then again, perhaps they are saying that via their various "Becoming a substantial holder" and "Change in substantial holding" notices that they are required to lodge every time they go over 4.99% or their position changes by 1% or more while they remain over 4.99%.

However, for the sake of clarity, in terms of shareholders knowing what they have exposure to, and prospective shareholders knowing what they would be gaining exposure to if the bought some shares in these LICs, it would be a lot better if they published their holdings regularly like most LICs do, even if only in alphabetical order rather than in weighting order. I believe the reasoning they (NOAS management) gave when I once asked them about their secrecy in regards to their holdings (or disclosing all of them) was that if the market knew what they were doing, it could impede their ability to do it at the best possible prices. That was at a roadshow pre-Covid, and with the benefit of hindsight I probably should have replied with something like, "And how's that working out for you?"