TaxTMI 
TaxTMI 
Trading Window closure period under Clause 4 of Schedule B read with Regulation 9 of SEBI (Prohibition of Insider Trading) Regulations, 2015 (“PIT Regulations”) – Extending framework for restricting trading by Designated Persons (“DPs”) by freezing PAN at security level to all listed companies in a phased manner
X X X X Extracts X X X X
X X X X Extracts X X X X
....restricting trading by Designated Persons ("DPs") by freezing PAN at security level to all listed companies in a phased manner. 1. Clause 4 (1) of Schedule B read with Regulation 9 of PIT Regulations, inter-alia, states that "Designated persons may execute trades subject to compliance with these regulations. Towards this end, a notional trading window shall be used as an instrument of monitoring the trading by the designated persons. The trading window shall be closed when the compliance officer determines that a designated person or class of designated persons can reasonably be expected to have possession of UPSI. Such closure shall be imposed in relation to such securities to which such UPSI relates. Designated persons and their immediat....
X X X X Extracts X X X X
X X X X Extracts X X X X
....tock Exchanges and Depositories, the above framework is hereby extended to all the listed companies. 6. To ensure smooth implementation of the framework, glide path is being prescribed as under: Table 1: Timelines for phase wise implementation of the framework Sr. No. Companies to be covered PAN freeze start date 1 Listed companies that are part of benchmark indices i.e. NIFTY 50 and SENSEX Already applicable as on date 2 Top 1,000 companies in terms of BSE Market Capitalization as of June 30, 2023 (excluding companies part of benchmark indices) October 1, 2023 3 Next 1,000 companies in terms of BSE Market Capitalization as of June 30, 2023 January 1, 2024 4 Remaining companies listed on BSE, NSE & MSEI April ....
X X X X Extracts X X X X
X X X X Extracts X X X X
....implementation of the system - Annexure A. 2. Process flow chart - Annexure B. 3. Quarterly reporting format by the Depositories - Annexure C ANNEXURE - A Trading Window closure period under Clause 4 of Schedule B read with Regulation 9 of SEBI (Prohibition of Insider Trading) Regulations, 2015 ("PIT Regulations") - Extending the framework for restricting trading by Designated Persons ("DPs") by freezing PAN at security level Process for implementation of the system: 1. The Designated Depository ("DD") appointed by the listed company pursuant to the SEBI Circular No. SEBI/HO/CFD/DCR1/CIR/P/2018/85 dated May 28, 2018 shall enable access to the respective listed company on the portal/ platform. 2. Upon login, DD shall auto-pop....
X X X X Extracts X X X X
X X X X Extracts X X X X
....9, 2023. 6. DD shall provide the details received from the listed company (i.e. Commencement Date and End Date of the trading window closure period, Name and PAN of DPs, ISIN, etc.) to the Stock Exchanges and other Depository atleast 1 trading day prior to the commencement of trading window closure commencement date (T-1 day). For example, for financial results for the quarter ending September 30, 2023, the DD shall provide the details by September 30, 2023. Further, during the trading window closure period, DD shall also provide the aforesaid details and changes therein, if any, to the Stock Exchanges and other Depository on a daily basis. 7. The demat accounts shall be identified by the Depositories based on the PAN of the DP of Sole / ....
X X X X Extracts X X X X
X X X X Extracts X X X X
....use 4 (3) of Schedule B read with regulation 9 of PIT Regulations. In such cases, the restriction shall be removed within 2 trading days from the date of receipt of request from the listed company. As per the example given at para 10 above, if the listed company provides exemption to any DP on October 11, 2023, then the change i.e. de-freeze shall be effected on or before October 13, 2023. The restriction shall be re-introduced automatically post lapse of the exemption period or completion of the transaction by the DP. 12. The freezing/de-freezing of PAN at the security level on account of changes due to addition or deletion will be effected post market hours. 13. Pay-in and pay-out obligations in respect of transactions, if any, taken pl....
X X X X Extracts X X X X
X X X X Extracts X X X X
....with regulation 9 of PIT Regulations Depositories shall be required to separately provide the details as mentioned above in the Quarterly report submitted to SEBI. ============= Document 1 Designated Depository to provide access to listed company on a portal/platform Portal will auto- populate details of designated person (PAN and Name) obtained for the purpose of system driven disclosure Listed company to update/confirm a) PAN of DPS to be frozen b) ISIN and c) "Start and End date of trading window closure period Listed company shall select or de-select PAN of DPS at least 2 trading days prior to trading window closure start date Le. T-2 days Designated depository shall provide relevant data to the sto....