Guide
What is a Record of Depositors? A guide for Bursa Malaysia listed companies
The Record of Depositors (ROD) is how a Malaysian listed company finds out who holds its shares. This guide explains what is in it, why it is hard to read, and how to turn it into a picture of real ownership.
What is a Record of Depositors (ROD)?
A Record of Depositors is the list of every Central Depository System (CDS) account holding a Bursa Malaysia listed company's shares as at a given date, maintained by Bursa Malaysia Depository and obtained by the company through its share registrar. It is the closest thing a listed Malaysian company has to a shareholder register.
What does a Record of Depositors contain?
Each row is one CDS account: the account holder's name, a qualifier, the broker (ADA) code, branch and account number, the number of shares held, and usually the holder's address, nationality and investor type. It lists accounts, not people, so one investor can appear many times.
Why does one shareholder appear in several rows?
Investors often hold shares through more than one broker and through nominee companies. A nominee row shows the bank's nominee company as the holder and names the real investor in the qualifier, for example "Pledged securities account for …". Adding those rows back together is the only way to see what one person really owns.
What do Tempatan and Asing mean in a nominee name?
They mark the nominee company's side of the register: "Tempatan" nominees hold for local investors and "Asing" nominees hold for foreign investors. Foreign institutions frequently hold through Malaysian-registered custodians, so nationality alone understates foreign ownership.
How often can a listed company get its Record of Depositors?
A ROD is always produced for a general meeting and for an entitlement such as a dividend, and many issuers also request one every month through their share registrar so they can follow how their shareholder base is changing.
Who is a substantial shareholder in Malaysia?
Under the Companies Act 2016, a substantial shareholder holds an interest in 5% or more of a company's voting shares. Interests held through nominee accounts count, which is why grouping accounts back to the beneficial owner matters when watching that line.
How do you analyse a Record of Depositors?
Group the CDS accounts back to beneficial owners, compare each owner's total with the previous register, and separate genuine buying and selling from shares moved between the same owner's accounts. From there you can track concentration (for example the share held by the top 10 owners), new and exiting holders, persistent accumulators and distributors, and broker flow.