Valuation discretion for COVID-related debt restructuring permitted; conservative valuations required when agencies disagree for mutual fund securities.
Valuation agencies engaged by AMCs/AMFI may, where restructuring proposals are solely due to COVID-19 stress, refrain from recognising such restructuring or non-receipt of dues as default for valuation of money market and debt securities. Debenture Trustees, issuers and lenders must immediately communicate restructuring proposals to investors, valuation agencies, credit rating agencies and AMFI, which shall disseminate the information to members. Valuation must reflect changed terms, issuer stress and repayment capacity; if two agencies differ, the conservative valuation prevails. AMCs remain responsible for true and fair valuation under fair valuation principles and regulations.

Relaxation in issue size revision extended and validity of SEBI observations prolonged subject to lead manager undertaking.
Regulatory relaxation allowing revision in issue size up to fifty percent is extended until March 31, 2021, and validity of SEBI observations expiring between October 1, 2020 and March 31, 2021 is extended until March 31, 2021, subject to an undertaking by the lead manager confirming compliance with Schedule XVI of the ICDR Regulations, 2018 when submitting the updated offer document.

Recovery of defaulter assets: exchanges and clearing corporations must liquidate member assets to satisfy client obligations and amend bye laws.
Stock Exchanges and Clearing Corporations must initiate recovery by liquidating movable and immovable assets of a declared defaulter member, including sale of securities of debit balance clients to the extent of their debit, and commence court proceedings where assets are not in SE/CC possession. Such actions are to be taken within six months of declaration of default. Exchanges and Clearing Corporations must notify members, amend bye laws as needed, and report implementation status monthly to the regulator.

Investment Adviser registration in IFSC now requires separate net worth per activity and annual compliance audit.
Eligibility permits entities recognised in their parent jurisdiction to form a company or LLP to operate in IFSC as Investment Advisers, with no separate formation required if already a company or LLP in IFSC. IAs must provide services only to persons specified in the IFSC Guidelines and comply with relevant overseas regulator requirements for non-resident clients. The IA or parent must meet the net worth requirement separately for each activity, and IAs must conduct an annual audit of compliance with the Investment Adviser Regulations and these Guidelines by a chartered accountant or company secretary.

Preferential issue pricing flexibility for listed REITs permits alternative VWAP-based floor with a three-year lock-in.
REITs may not undertake a subsequent institutional placement until two weeks after a prior institutional placement effected via special resolution. For preferential issues made until December 31, 2020, REITs may opt for a pricing floor equal to the higher of a 12 week or 2 week weekly high low VWAP average; units issued under this method will be locked-in for three years and all allotments from the same unitholders' approval must follow the same pricing method. Previously locked sponsor units may be counted for lock-in computation but will not be freshly re-locked if free of lock-in at the time of issue.

Preferential issue pricing revised: temporary two week or twelve week VWAP option with three year lock in for listed InvITs.
The circular permits listed InvITs to use, for preferential issues until December 31, 2020, a pricing method where the issue price is not less than the higher of a twelve-week or two-week VWAP-based weekly average, mandates a three-year lock-in for units issued under that method, and requires uniform pricing method across allotments from the same unitholder approval. It also provides that no subsequent institutional placement may occur until two weeks after a prior institutional placement, and that previously sponsor-locked units count toward lock-in computation without being re-locked if free of lock-in at the time of the preferential issue.

Resources for trustees compliance deferred; earlier trustee resource guidelines now applicable from January 1, 2021.
Compliance with prior guidelines on resources for trustees of mutual funds is deferred and shall apply from January 01, 2021; all substantive obligations and conditions of the August 10, 2020 circular remain unchanged. The circular emphasizes statutory authority to support investor protection and trustee governance standards applicable to Mutual Funds, Asset Management Companies, trustee companies and boards of trustees.

Client level segregation of advisory and distribution mandates single service choice within adviser groups and strict compliance obligations.
SEBI requires Investment Advisers to implement client-level segregation of advisory and distribution services within adviser groups using PAN as control, treat dependent family members as a single client where applicable, obtain annual auditor certification of segregation compliance, and advise direct (non commission) plans where available. Advisers must enter into prescribed written investment advisory agreements prior to rendering advice or charging fees, follow specified fee regimes under Assets under Advice or Fixed Fee modes with supporting documentation and restrictions, maintain verifiable client interaction records for prescribed retention periods, conduct annual compliance audits with reporting, and comply with registration, qualification, risk profiling and disclosure requirements within stated timelines.

System-Driven Disclosures require listed companies to provide promoter PANs to depositories, with prompt sharing and same-day updates.
Listed companies must provide PAN numbers of promoters, promoter group members, designated persons and directors to the designated depository in the prescribed format; for PAN exempt entities, investor demat account numbers are to be provided. The designated depository will share this information with the other depository. Listed companies must update the designated depository on the same day for any subsequent changes, and the designated depository will share incremental changes the same day. Other procedural requirements of the earlier SDD circular remain applicable.

Write-off of shares: FPIs may now write off all unsellable holdings when surrendering registration, subject to prescribed process.
Write-off of shares held by Foreign Portfolio Investors is expanded to permit FPIs to write off shares of any company they are unable to sell when surrendering registration, replacing the prior limitation to unlisted, illiquid, suspended, or delisted shares; the write-off must follow the process set out in paragraph 17 of Part C of the Operational Guidelines and custodians are to notify their FPI clients.

Alternate Risk Management Framework mandates alternative margining and pricing when commodity futures approach near zero or negative prices.
An Alternate Risk Management Framework applies when commodity futures approach near zero or negative prices: activation follows CC review upon specified triggers; prices are modelled as normally distributed with EWMA volatility on absolute price differences; initial margin floors include an absolute currency floor plus percentage floor on absolute prices; spread margin benefits are withdrawn; option pricing models suitable for negative underlyings are used; pre expiry and Extreme Loss Margins may be levied; deactivation requires cessation of triggers, time lag, exit thresholds, and margin convergence.

Uniform NAV applicability: closing NAV applies when funds are available, with strengthened OMS controls and allocation safeguards.
Subscriptions (except liquid and overnight schemes) receive closing NAV on the day funds are available; AMCs must adopt board and trustee approved written policies detailing OMS use, scheme wise order placement, inbuilt regulatory limits, dedicated dealers, dealing room controls, concrete pooled order allocation rules with pro rata weighted average pricing, constrained deviations requiring multi officer written approvals, segregation of margins/collaterals among schemes, and system based monitoring with audit trails, time stamping and trustee reporting of non compliance.

Listing of InvIT and REIT units in IFSC permitted subject to jurisdictional incorporation, regulation and specified exchange listings.
SEBI permits listing and trading of Units of InvITs and REITs on IFSC stock exchanges provided the trusts are incorporated/settled in Government notified Permissible Jurisdictions, regulated by the securities regulator(s) in those jurisdictions, and already listed on specified international exchanges; Annexure A contains the lists of jurisdictions and exchanges.

Margin collection requirement: upfront VaR and ELM mandatory; other margins deemed collected if pay in occurs within two working days or by early pay in.
TMs and CMs must collect upfront VaR margin and ELM from clients prior to trade; other margins may be collected within a two working day window. If client pay-in (funds or securities) occurs within two working days, or securities are early pay in to the Clearing Corporation, other margins are deemed collected and penalties for short/non-collection do not apply. If pay-in is not made within two working days and other margins are not collected by that time, applicable penalties may be levied. Clearing Corporations continue to collect upfront VaR plus ELM and other margins from TMs/CMs.

Multi Cap fund asset allocation mandates equal minimum investments across large, mid and small cap segments, compliance required.
SEBI requires Multi Cap funds to maintain a minimum equity investment of 75% of total assets, with at least 25% allocated to each of large-cap, mid-cap and small-cap equity and equity-related instruments; existing schemes must comply within one month from AMFI's next stock list publication (January 2021).

System driven disclosures enable automated identification and public dissemination of insider trading-related transactions by tagged entities.
Implementation of system driven disclosures automates continual disclosure obligations under Regulation 7(2) for promoters, promoter-group members, designated persons and directors by requiring listed companies to provide PAN or demat details to a designated depository, which will tag demat accounts at ISIN level and share daily transaction and corporate-action feeds with stock exchanges; exchanges will identify, consolidate and disseminate trades that trigger disclosure obligations on their websites on a T+2 basis.

Portfolio Managers in IFSC must meet registration, net worth, certification, client eligibility, minimum investment and fund segregation rules.
The guidelines apply SEBI PMS Regulations and IFSC Guidelines to Portfolio Managers in IFSC, permit branches of SEBI-registered intermediaries and separate companies/LLPs, require Board approval and parent entity responsibility for branch compliance and ring-fencing, and prescribe registration procedures and fees. Operational rules mandate certification standards (NISM for Indian securities), minimum net worth of USD 750,000 (with parent/subsidiary specifications), client eligibility per IFSC Guidelines Clause 9(3), minimum client investment of USD 70,000, and segregation of client funds in IFSC Banking Unit accounts, with applicability subject to conditions by SEBI, RBI and other authorities.

e-KYC Aadhaar Authentication service: NSE added to authorised providers, subject to existing compliance conditions and oversight.
Permission is granted for an additional market entity to undertake e-KYC Aadhaar Authentication service, expanding authorised providers to include the National Stock Exchange subject to existing compliance conditions. Stock exchanges and depositories must notify intermediaries, amend bye-laws for uniform implementation, report the implementation status in the next Monthly Development Report, and monitor compliance with the circular, under the regulator's powers to protect investors and regulate the securities markets.

Re-lodgement deadline for physical transfer requests: re-lodged share transfers must be completed only in dematerialised form.
Transfer deeds in physical form that were lodged before the discontinuation of physical transfers and returned for deficiencies may be re-lodged by the specified cut-off; any shares re-lodged for transfer, including pending requests, will be issued only in demat form upon re-lodgement.

Segregated portfolio trigger date set as restructuring proposal; immediate reporting obligations and temporary applicability until year-end.
The date an AMC receives a proposal for debt restructuring shall be treated as the trigger date for creation of a segregated portfolio; AMCs must immediately report such proposals to Valuation Agencies, Credit Rating Agencies, Debenture Trustees and AMFI, which will disseminate the information to members; other provisions of prior SEBI circulars on segregation and the Prudential Framework remain applicable; the modification is effective immediately for a temporary period and issued under Section 11(1) of the SEBI Act read with Regulation 77.