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Circulars
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Temporary relaxation in processing of documents pertaining to FPIs due to COVID-19
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Temporary relaxation of FPI document processing permits scanned or encrypted submissions, subject to later original verification and reporting.
SEBI permits DDPs and Custodians to process FPI registrations, KYC and material changes on the basis of scanned signed documents and uncertified copies received from verified global custodian/client e mail accounts or encrypted/password protected new client e mails; such documents may be uploaded to KRAs and relied upon by intermediaries. Intermediaries must perform regulatory and risk based AML due diligence on scan copies. Originals and/or certified documents must be obtained after the temporary relaxation period, with account blocking and reporting consequences if documents are not furnished within prescribed follow up periods.
Continuation of Phase II of Unified Payments Interface with Application Supported by Block Amount due to Covid-19 virus pandemic
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UPI ASBA continuation due to pandemic, implementation of next phase deferred pending stakeholder deliberations and SEBI guidance.
UPI ASBA Phase II is continued until further notice due to Covid 19 related operational constraints; advancement to Phase III is deferred pending stakeholder deliberations and notification of modalities. The circular is issued under the powers of section 11 read with section 11A of the SEBI Act and communicated to exchanges, intermediaries and the payments corporation.
Extension of deadline for implementation of the circular on Stewardship Code for all Mutual Funds and all categories of AIFs due to the CoVID– 19 pandemic
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Stewardship code extension delays compliance deadline for mutual funds and AIFs due to COVID-19 operational disruptions.
Extension of the implementation deadline for the Stewardship Code governing investments in listed equities by mutual funds and all categories of alternative investment funds is granted due to COVID-19-related operational constraints that impede monitoring and engagement with investee company management and boards. The postponement of the Code's effective date is issued pursuant to the regulator's statutory powers under the applicable fund regulatory framework and the circular directs stakeholders to the published notice for compliance reference.
Relaxation from compliance with certain provisions of the circulars issued under SEBI (Credit Rating Agencies) Regulations, 1999 due to the COVID-19 pandemic and moratorium permitted by RBI.
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Loan moratorium treatment: CRAs may forbear default recognition where delays stem solely from lockdown or moratorium.
SEBI permits CRAs, on a case by case assessment, to refrain from recognizing payment delays as default when delays arise solely from lockdown conditions or the RBI permitted moratorium, with such determinations disclosed in press releases; the relaxation also covers issuer rescheduling with investor/lender approval and remains effective for the moratorium period. SEBI further extends timelines for rating actions, press releases and website disclosures, requires best effort completion and ratification by the Rating Sub Committee, and allows an additional extension for annual and semi annual disclosures for the period ended March 2020.
Relaxation from compliance with certain provisions of the SEBI (Substantial Acquisition of Shares and Takeovers) Regulations, 2011 due to the COVID-19 pandemic.
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SAST compliance relaxation extended for disclosure filings to address COVID-19 related logistical constraints and travel restrictions.
Extension of filing deadlines for disclosures under the SAST Regulations is granted as temporary regulatory relief due to COVID-19 logistical constraints; disclosures required under Regulations 30(1), 30(2) and 31(4) for the financial year ending March 31, 2020 are extended to June 01, 2020, effective immediately, with stock exchanges instructed to notify stakeholders.
Further relaxations from compliance with certain provisions of the SEBI (Listing Obligations and Disclosure Requirements) Regulations, 2015 (LODR) and the SEBI circular dated January 22, 2020 relating to Standard Operating Procedure due to the CoVID -19 virus pandemic
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Compliance relaxations under LODR extend filing and committee meeting deadlines and defer SOP enforcement to later compliance periods.
SEBI temporarily extends selected LODR compliance timelines and defers the operation of its SoP on enforcement. Extensions cover the half yearly Practicing Company Secretary certificate and AGM timing for top listed entities; annual meeting requirements for Nomination and Remuneration, Stakeholders Relationship and Risk Management Committees are permitted within an extended window. The SoP on enforcement is deferred to a later compliance period while an earlier SoP remains effective until then. Publication of notices in newspapers is exempted for a specified interim period. Stock exchanges must notify listed entities and disseminate the circular under SEBI's regulatory powers.
Interoperability among Clearing Corporations: Revision of criteria for entering the risk-reduction Mode
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Risk-reduction mode triggered when broker collateral is substantially exhausted; exchanges must update systems, rules and notify members.
The circular withdraws the prior lower collateral-utilization trigger and requires stock exchanges and clearing corporations to apply the pre-existing Risk Reduction Mode criteria from the 2012 circular; brokers must be mandatorily placed into risk-reduction mode when their collateral available for adjustment against margins becomes substantially exhausted by trades under the margining system. Exchanges and clearing corporations must implement systems, amend bye-laws, notify members, publish the provisions, and report implementation status to the regulator.
Relaxation in compliance with requirements pertaining to Mutual Funds
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Regulatory relaxation for mutual funds extends NFO validity and delays compliance and implementation deadlines to ease operational burdens.
Temporary regulatory relief permits a one year validity for NFO observation letters and extends filing timelines for half yearly unaudited results, distributor commission disclosures, and annual investor complaint reports; implementation dates for specified mutual fund policy initiatives are postponed by about one month, and AMC dealing room access controls are temporarily relaxed subject to electronic confirmations with audit trails.
Relaxation from compliance with certain provisions of the SEBI (Listing Obligations and Disclosure Requirements) Regulations, 2015 and certain SEBI Circulars due to the CoVID -19 virus pandemic – continuation
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Relaxation of SEBI compliance timelines for debt and money market issuers extends filing and issuance deadlines to ease COVID 19 disruptions.
SEBI temporarily relaxes compliance timelines for issuers of NCDs, NCRPS, CPs and Municipal Debt Securities, permitting reliance on audited financials as of the specified cutoff or filing unaudited financials with limited review for stub periods, and extends due dates for periodic LODR filings (including Large Corporate disclosures and Regulation 52 financial results) and ILDM prescribed filings; these extensions are effective immediately and stock exchanges must disseminate the circular.
Encumbrance on units of Real Estate Investment Trusts (REITs)
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Encumbrance on REIT units requires re-designation of sponsor before invocation and mandates prompt exchange disclosure.
Encumbrance on REIT units may be created during the mandatory sponsor holding period but agreements must include the circular's creation and invocation conditions. Invocation during the mandatory period is permitted only if the invoker causes itself or its nominee to be re-designated as sponsor (unless already in sponsor group) and the re-designated sponsor fulfils sponsor obligations. Sponsors must notify the REIT manager of encumbrance creation within two working days and report any subsequent changes; the REIT must disclose these details to listed exchanges within two working days. The unit holding pattern disclosure is modified to capture mandatory holdings and encumbered units.
Encumbrance on units of Infrastructure Investment Trusts (InvITs)
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Encumbrance on InvIT sponsor units: creation allowed but invocation barred during mandatory holding; prompt disclosure required.
Sponsors may create encumbrance on units they are required to hold, provided the encumbrance agreement includes the circular's creation and invocation conditions and the encumbrance is not invoked during the mandatory holding period. Sponsors must notify the InvIT's investment manager of creation, release, invocation or other changes within two working days; thereafter the InvIT must disclose the information to stock exchanges within two working days. The unit holding pattern disclosure is amended to record sponsor encumbrance details, and Annexure I specifies required fields.
Relaxation from compliance to REITs and InvITs due to the CoVID -19 virus pandemic
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Compliance deadline extension for REITs and InvITs relaxing regulatory filing timelines in view of the pandemic.
Extension of regulatory filing timelines for REITs and InvITs by one month for compliances due for the period ending March 31, 2020, as a temporary relaxation in view of the COVID 19 pandemic; the circular takes immediate effect and requires stock exchanges to notify and disseminate the extension to affected entities.
Relaxation from compliance with certain provisions of the SEBI (Listing Obligations and Disclosure Requirements) Regulations, 2015 due to the CoVID -19 virus pandemic
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Relaxation of compliance timelines for listed entities extends filing and meeting deadlines due to pandemic.
Temporary extensions allow listed entities additional time to file specified LODR submissions for the quarter/financial year ending March 31, 2020, including compliance certificate on share transfer facility, investor complaints statement, secretarial compliance report, corporate governance report, shareholding pattern and quarterly/annual financial results, with due dates moved by approximately three weeks to one month. A limited exemption relaxes the 120 day maximum gap between board and audit committee meetings for meetings held or proposed between December 1, 2019 and June 30, 2020, while preserving the obligation to meet at least four times a year.
General Information Document
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General Information Document requirements: updated GID must be provided to investors and published by lead managers and exchanges.
Mandates for a General Information Document require merchant bankers and lead managers to adopt the specified generic disclosures, include the date of last updation, provide updated copies to investors on request in the requested form and manner, and publish the updated GID on the stock exchange(s) and lead manager(s) websites where issue documents are available; generic information need not be repeated in the abridged prospectus.
Amendments to guidelines for rights issue, preferential issue and institutional placement of units by a listed InvIT
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Fast-track rights issue eligibility tightened with specified listing, disclosure, complaint and audit qualification conditions for InvITs.
Introduces a fast-track rights issue option for listed InvITs subject to detailed eligibility criteria (listing tenure, dematerialisation, minimum public market capitalisation, disclosure compliance, investor complaint redressal, absence of regulatory prosecutions or settlements, no trading suspensions or audit qualifications, and no lead banker conflicts), requires filing a letter of offer and paying fees, mandates statutory-auditor-certified pro forma financials where material asset transactions occur after the last disclosed period, specifies sponsor lock-in regimes for preferential/institutional placements, and requires lead merchant bankers to ensure financial particulars are current within six months.
Amendments to guidelines for rights issue, preferential issue and institutional placement of units by a listed REIT
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Fast track rights issue eligibility clarified for listed REITs; adds compliance, disclosure and lock-in rules.
A new fast track rights issue route requires listed REITs to satisfy specified eligibility conditions immediately prior to the record date (including listing tenure, dematerialisation, minimum public market capitalisation, listing and disclosure compliance, investor complaint redressal, absence of regulatory or disciplinary actions and audit qualifications, sponsor subscription, and no lead banker conflicts). REITs using fast track must file the letter of offer and pay fees under REIT Regulations. Preferential and institutional placement rules amend sponsor lock-in, require pro forma audited financials for post-disclosure material asset changes and ensure placement financials are recent.
Amendment in ‘Rights and Obligations of Members, Authorized Persons and Clients’ of FMC circular No. FMC/COMPL/IV/KRA-05/11/14 dated February 26, 2015
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Electronic Contract Note consent streamlined to allow electronic email updates without physical form, easing investor receipt of contract notes.
The amendment substitutes the handwritten physical ECN declaration requirement for commodity derivatives clients with the electronic consent procedure used in other segments, allowing clients to provide an appropriate email and to change it via secured electronic access where internet trading is enabled; the prior ECN declaration retention clause is rescinded.
Review of Norms regarding Regaining Matched Book for Commodity Derivatives Segment
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Regaining matched book norms updated: revised tear-up compensation and penalty and mandatory automated implementation deadline.
Review updates norms for regaining matched book by revising compensation and penalty for tear-up under Alternatives 3 and 4: voluntary tear-up at last mark-to-market price with prescribed compensation and penalty credited to the settlement guarantee fund, and partial pro-rata tear-up at last mark-to-market price with prescribed compensation and penalty credited to the settlement guarantee fund. Other provisions continue to apply.
Operating Guidelines for Investment Advisers in International Financial Services Centre (IFSC) – Clarifications
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Networth requirement for IFSC investment advisers revised; existing IFSC entities can register without forming a new company.
The networth threshold for registered Investment Advisers in the IFSC is revised to USD 700,000, and existing recognized entities in IFSC may apply for Investment Adviser registration without forming a separate company or LLP; the clarification is issued under Section 11(1) of the Securities and Exchange Board of India Act, 1992 and published on SEBI's website.
Securities and Exchange Board of India (International Financial Services Centres) Guidelines, 2015 - Amendments
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Intermediary access in IFSCs permits registered intermediaries and associates to provide services without separate companies, subject to approval.
SEBI amends IFSC guidelines to allow SEBI-registered intermediaries (except trading/clearing members) or their international associates to provide securities-market financial services in IFSCs without forming a separate company, subject to Board approval, with exceptions for services offered exclusively to institutional investors and for recognized foreign entities. Entities issuing or listing debt in IFSCs must prepare accounts under IFRS/US GAAP/Ind AS or home accounting standards; where not using those standards, a quantitative summary of significant differences from IFRS must be included in disclosure documents.

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