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.

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 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 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.

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.

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.

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.

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.

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.

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.

Direct investor access to stock exchange infrastructure allowed for purchasing and redeeming mutual fund units; exchanges to amend byelaws accordingly.
Permits investor access to recognised stock exchange infrastructure to purchase and redeem mutual fund units directly from Mutual Funds/Asset Management Companies; requires recognised stock exchanges, clearing corporations and depositories to amend their byelaws, rules and regulations as necessary to operationalise such access.

Margin pledge requirement: client securities must be pledged and re pledged through the depository system, prohibiting title transfers.
SEBI requires client collateral in dematerialised securities to be accepted only as a margin pledge in the depository system, prohibits off market title transfers for margin, mandates segregated tagged demat accounts for client securities margin pledges and margin funding, and prescribes a chain of pledge and re pledge (client TM CM CC) with client confirmation, visibility, and specified procedures for release and invocation to ensure re pledged securities are applied only to the pledgor's exposure.

Margin framework revision: standardized VaR, extreme loss margins, scan ranges and consolidated crystallized obligation margin.
The circular revises margining for cash and derivatives: cash VaR margins by liquidity group with 6 methodology and specified minima; an Extreme Loss Margin for stocks and broad based ETFs; for derivatives, fixes the EWMA at 0.995, prescribes product specific Price Scan and Volatility Scan Ranges with scaling rules, standardizes Calendar Spread Charges, removes separate short option minimum charge, prescribes product Extreme Loss Margins with special rules for deep OTM and long dated contracts, replaces various crystallized/assignment margins with a consolidated crystallized obligation margin, and imposes additional margins for repeatedly volatile securities.

Portfolio manager fee restrictions ban upfront fees, cap operating expenses, and limit exit loads over investment years.
SEBI mandates that Portfolio Managers cannot charge upfront fees, must charge brokerage at actuals, and cap operating expenses (excluding brokerage) at 0.50% per annum of a client's average daily AUM; exit loads are tiered with no load after three years. Managers must offer direct client on boarding without intermediary charges, standardise and disclose investment approaches across documents, submit monthly reports to SEBI and quarterly reports to clients, provide annual audited firm level performance and compliance certifications, and ensure distributors meet qualification, payment, disclosure and conduct requirements.

Disclosure standards for alternative investment funds require standardized PPM templates and mandatory performance benchmarking for funds.
SEBI mandates a two-part Private Placement Memorandum (PPM) template for Category I and II AIFs and a separate template for Category III, requires alignment of subscription agreements with the PPM, and an annual audit of PPM compliance (with certain audit items optional). Mandatory industry and fund-level performance benchmarking is introduced: Associations representing a majority of AIFs shall appoint Benchmarking Agencies, AIFs must report scheme-level valuation and cash-flow data for schemes one year past first close, and benchmarking reports must accompany any disclosed past performance; exemptions apply to certain Angel Funds.

Performance review of commodity derivatives contracts: mandatory annual review, disclosure and consultation requirements for exchanges to evaluate contract performance.
Mandate for performance review of commodity derivatives contracts requiring recognized stock exchanges to evaluate every contract against structured parameters, consult the Product Advisory Committee, and disclose the review and methodology annually on their websites; the framework covers commodity fundamentals, detailed trading metrics, price movement analysis, hedge effectiveness, delivery infrastructure and stakeholder outreach, and exchanges must amend rules, inform brokers, and report implementation to the regulator.

Common Application Form for Foreign Portfolio Investors streamlines FPI registration, PAN allotment and KYC processes for intermediaries.
The Government notified a Common Application Form for FPI registration, PAN allotment and KYC; applicants must submit the CAF and Annexure with supporting documents and applicable fees, intermediaries may rely on CAF for KYC, DDPs may accept earlier-form applications for a sixty-day transition, and custodians must inform FPI clients of the CAF and operational guidelines issued under the regulator's statutory powers.

Position limits for Rupee derivatives in IFSC restrict open positions across participant categories to defined caps.
Introduction of Rupee derivatives with settlement in foreign currency on IFSC exchanges establishes position limits per currency pair per exchange: identical gross open position caps for trading members, institutional investors, and eligible foreign investors across all contracts measured against total open interest or a currency-equivalent cap, and a lower cap for other clients; Institutional Investors are defined to include specified IFSC and offshore entities. Exchanges must impose penalties for violations and implement the limits pursuant to regulatory powers to protect investors and regulate the market.

IPF Trust composition norms apply uniformly across MIIs; functions limited to exchanges, with committee names updated accordingly.
Composition standards for the IPF Trust from the February 2017 circular apply uniformly to Exchanges and Depositories, while the functions prescribed for the IPF Trust in that provision apply only to Exchanges; Depositories must comply with composition norms within three months. The circular also directs that "Investor grievance redressal committee" be read as "Grievance redressal committee" and "Member selection committee" be read as "Member committee."

Margin Floor Requirements for commodity derivatives tied to volatility categorisation and phased implementation mandated.
SEBI revises the commodity derivatives margin framework by mandating realised volatility based categorisation of commodities into Low, Medium, and High buckets using three years of daily log returns, with the Lead Exchange's Clearing Corporation to determine categories. Based on category and agri/non agri status, the circular prescribes minimum Initial Margin floors and minimum MPOR values, specifies rollover and review procedures (semi annual reviews, downgrade requiring two consecutive reviews), requires disclosure of margin breakups and volatility, and mandates phased implementation within three months with notification within 15 days.