Company Law Reform Bill [HL]

My Lords, is the noble Lord saying under Clause 530(3)(a), any firm of stockbrokers can send out any number of offers of any number of shares to any number of individuals provided that there is no mechanism for those shares to be traded in any way and to be transferred from the individual who has received the offer? Does a private company with, for example, 120 shareholders have to re-register as a public company if it wants to create a market in its shares? Is that the noble Lord’s understanding of the provision?