Master Circular for Alternative Investment Funds (AIFs)
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....dependently comply with the other requirements specified by SEBI for market intermediaries such as the 'Levy of Goods & Services Tax (GST) on the fees payable to SEBI', 'Approach to securities market data access and terms of usage of data provided by data sources in Indian securities market', 'Digital mode of payment', 'Information regarding Grievance Redressal Mechanism' and 'Guidelines on Outsourcing of Activities by Intermediaries', etc. 4. With respect to any other directions or guidance issued by SEBI, as specifically applicable to AIFs, the same shall continue to remain in force in addition to the provisions of this Master Circular or any other law for the time being in force. 5. This Master Circular shall come into force from the date of its issuance. With the issuance of this Master Circular, all the circulars mentioned in Annexure 17 of this Master Circular shall stand rescinded. 6. Notwithstanding such rescission: a) anything done or any action taken or purported to have been done or taken under the rescinded circulars, including registrations or approvals granted, fees collected, registration suspended or cancelled, any inspection or investigation or enquiry or adju....
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....s for Category III AIFS. .16 Chapter 6 - Norms for Special Situation Funds (SSF). .21 Chapter 7 - Guidelines for overseas investments by AIFs and related reporting............22 Chapter 8 - Investment in units of AIFS......... .25 - Chapter 9 – Participation of AIFs in Credit Default Swaps........... .26 Chapter 10 - Transaction in Corporate Bonds through Request for Quote (RFQ) platform by AIFS............. ..28 -------------- Chapter 11 - Other prudential and operational norms and related clarifications ........... 29 Chapter 12 - Framework for Accredited Investors ....... .31 -------------------------- Chapter 13 - Obligations of manager, sponsor and trustee of AIFs .34 Chapter 14 - Constitution of investment committee .37 Chapter 15 - Reporting by AIFS...... 38 Chapter 16 - Performance Benchmarking of AIFs 40 -------------- Chapter 17 - Investor Charter and Disclosure of complaints by AIFs 42 Chapter 18 - Collection of stamp duty on issue, transfer. .43 and sale of units of AIFs.............. .43 Chapter 19 - Change in Sponsor and/or Manager or Change in control of Sponsor and/or Manager of AIF .44 Chapter 20 - Issuance and credit of units of AIFs in dematerialised form ....
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....¡ Securities and Exchange Board of India Chapter 1 – Online Filing System for AIFs¹ All applicants desirous of seeking registration as an Alternative Investment Fund ('AIF') are required to submit their applications only online, through the SEBI Intermediary Portal at https://siportal.sebi.gov.in. Further, all SEBI registered AIFs are required to file their compliance reports and submit applications for any request under the provisions of AIF Regulations and circulars issued thereunder, only through the SEBI Intermediary Portal. In case of any queries and clarifications, users may refer to the manual provided in the SEBI Intermediary Portal or contact the Portal Helpline as specified in the manual. 1 SEBI Circular No. SEBI/HO/IMD/DF1/CIR/P/2017/87 dated July 31, 2017 Page 6 of 126 5-31 à¤à¤¾à¤°à¤¤à¥€à¤¯ पà¥à¤°à¤¤à¤¿à¤à¥‚ति और विनिमय बोरà¥à¤¡ - Securities and Exchange Board of India Chapter 2 – Filing of Private Placement Memorandum ('PPM') and related compliance requirements 2.1. Template(s) for PPM² and disclosures in PPM³ 2.1.1. Private ....
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.... by the Board or any other regulatory authority. In case of operational actions such as administrative warnings/deficiency letters, the same may be grouped together and summarized. However, if the investor seeks details of the summarized portion, the same shall be provided by the AIF to the investor. Any further litigations/cases, etc. as may arise in the course of the activities of the AIF shall be appropriately incorporated in the PPM and intimated to the investors. 2.1.6. With respect to disclosure of disciplinary history as per para 2.1.5 above, the same shall be applicable for the last 5 years and where monetary penalty is involved, in all cases where such penalty is greater than 5 lakh rupees. With respect to disputed tax liabilities, the same shall not apply to liabilities in personal capacity of an individual. Contingent liabilities shall be as disclosed in books of accounts of the entity. 2.2. Modalities for filing of PPM through a Merchant Banker4 In terms of Regulation 12(2) of the AIF Regulations, AIFs shall launch scheme(s) subject to filing of PPM with SEBI through a SEBI registered Merchant Banker. In this context, the following is specified: 2.2.1. The Merchant Bank....
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....on for launch of the said scheme as per applicable provisions of AIF Regulations by paying requisite fee to SEBI. 2.4. Audit of terms of PPM6 2.4.1. In order to ensure compliance with the terms of PPM, it is mandatory for AIFs to carry out an annual audit of such compliance. The audit shall be carried out either by an internal or external auditor/legal professional. However, audit of sections of PPM relating to 'Risk Factors', ‘Legal, Regulatory and Tax Considerations' and 'Track Record of First Time Managers' shall be optional. 5 SEBI circular No. SEBI/HO/AFD-1/POD/P/CIR/2022/155 dated November 17, 2022 6 SEBI Circular No. SEBI/HO/IMD/DF6/CIR/P/2020/24 dated February 05, 2020 and SEBI Circular No. SEBI/HO/IMD/DF6/CIR/P/2020/99 dated June 12, 2020 Page 9 of 126 5-31 à¤à¤¾à¤°à¤¤à¥€à¤¯ पà¥à¤°à¤¤à¤¿à¤à¥‚ति और विनिमय बोरà¥à¤¡ Securities and Exchange Board of India 2.4.2. Audit of compliance with terms of PPM, shall be conducted at the end of each Financial Year and the findings of audit along with corrective steps, if any, shall be communicated to the Trustee or....
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....in the placement memorandum is given at Annexure 5. The Merchant Banker appointed for filing of PPM shall not be an associate of the AIF, its sponsor, manager or trusteeâ¹. 2.5.4. 'Material changes' may be construed as changes in the fundamental attributes of the fund/scheme. In case of material changes significantly influencing the decision of the investor to continue to be invested in the AIF, the process as mentioned hereunder shall be complied with. Such changes shall include, but not be limited to the following: (a) Change in sponsor/manager (not including an internal restructuring within the group), (b) Change in control of sponsor/manager, (c) Change in fee structure or hurdle rate which may result in higher fees being charged to the unit holders. The following process shall be followed by the AIF: (i) Existing unit holders who do not wish to continue post the change shall be provided an exit option. The unit holders shall be provided not less than one month for expressing their dissent. (ii) In case of open-ended schemes of the AIF, the exit option may be provided by either of the following: A. Buying out of units of the dissenting investors by the manager/ any other pe....
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.... AIF11 Regulation 7(2) of AIF Regulations specifies as under: "An Alternative Investment Fund which has been granted registration under a particular category cannot change its category subsequent to registration, except with the approval of the Board." In this regard, it is specified as under: 3.2.1. Only AIFs who have not made any investments under the category in which they were registered earlier shall be allowed to make application for change in category. 3.2.2. Any AIF proposing to change its category shall make an application to SEBI for the same along with an application fees of 1 lakh rupees. The application shall include the updated Form A (Refer First Schedule to the AIF Regulations), other updated supporting documents, if any and rationale for the proposed change. Registration fees shall not apply for such applications. 3.2.3. If the AIF has received commitments/ raised funds prior to application for change in category, the AIF shall be required to send letters/emails to all its investors providing them the option to withdraw their commitments/ funds raised without any penalties/charges. Any fees collected from investors seeking to withdraw commitments/funds shall be ret....
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....ction having a strategic Anti-Money Laundering or Combating the Financing of Terrorism deficiencies to which counter measures apply; or (ii) a jurisdiction that has not made sufficient progress in addressing the deficiencies or has not committed to an action plan developed with the Financial Action Task Force to address the deficiencies. 12 SEBI circular No. CIR/IMD/DF/14/2014 dated June 19, 2014 and SEBI Circular No. CIR/IMD/DF/16/2014 dated July 18, 2014 13 SEBI circular No. SEBI/HO/AFD-1/POD/P/CIR/2022/171 dated December 09, 2022 and SEBI circular no. SEBI/HO/AFD/POD1/CIR/2024/2 dated January 11, 2024 Page 14 of 126 4.2. 4.3. 4.4. 4.5. 4.6. 4.7. 5-31 à¤à¤¾à¤°à¤¤à¥€à¤¯ पà¥à¤°à¤¤à¤¿à¤à¥‚ति और विनिमय बोरà¥à¤¡ Securities and Exchange Board of India In case an investor who has been on-boarded to scheme of an AIF, subsequently does not meet the conditions specified at para 4.1 above, the manager of the AIF shall not drawdown any further capital contribution from such investor for making investment, until the investor again meets the said conditions. All AIFs shall en....
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....ity to Category III AIFS, including large value funds for accredited investors of Category III AIFs, to calculate investment concentration norm based either on investable funds or net asset value ('NAV') of the scheme while investing in listed equity of an investee company, subject to the conditions specified by SEBI from time to time. In this regard, the following is specified: 5.1.1. All Category III AIFS shall disclose the basis for calculation of investment concentration norm in the PPM of their schemes. 5.1.2. The basis for calculating investment concentration norm shall not be changed during the term of the scheme. 5.1.3. Category III AIFs which choose to calculate investment concentration norm based on NAV, shall comply with the following 17: (i) The limit for investment in listed equity shall be calculated based on the NAV of the fund on the business day immediately preceding the date on which the Category III AIF makes such investment. (ii) NAV of the AIF shall be the sum of value of all securities adjusted for mark to market gains/losses (including cash and cash equivalents). The NAV shall exclude any funds borrowed by the AIF. (iii) Passive breach of concentration norm, ....
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....notional market value of the contract. 5.2.7. Idle cash and cash equivalents shall not be included in the calculation of total exposure. Long put positions shall be considered as short exposure and short put positions shall be considered as long exposure. Short selling of a stock through Securities Lending and Borrowing Mechanism (‘SLBM’) shall be treated as short exposure. Temporary borrowing arrangements which relate to and are fully covered by capital commitments from investors need not be included in calculation of leverage. 5.2.8. Offsetting of positions shall be allowed for calculation of leverage for transactions entered into for hedging and portfolio rebalancing as provided in para 12.25 of Master Circular No. SEBI/HO/IMD/IMD-POD- 1/P/CIR/2023/74 for Mutual Funds dated May 19, 2023. 19 SEBI Circular No. SEBI/HO/IMD-I/DF6/P/CIR/2021/584 dated June 25, 2021 Page 17 of 126 5-31 à¤à¤¾à¤°à¤¤à¥€à¤¯ पà¥à¤°à¤¤à¤¿à¤à¥‚ति और विनिमय बोरà¥à¤¡ Securities and Exchange Board of India 5.2.9. Sum of all exposures without offsetting transactions for hedging an....
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....endent risk management function, appropriate to the size, complexity and risk profile of the fund. 5.3.2. have a strong and independent compliance function appropriate to the size, complexity and risk profile of the fund supported by sound and controlled operations and infrastructure, adequate resources and checks and balances in operations. 5.3.3. maintain appropriate records of the trades/transactions performed and such information should be available to SEBI, whenever sought. 5.3.4. provide full disclosure and transparency about conflicts of interest and how they manage them from time to time, to investors, in accordance with Regulation 21 of the AIF Regulations and any other guidelines as may be specified by SEBI from time to time. Such conflicts shall be disclosed to the investors in the placement memorandum and by separate correspondences as and when such conflicts may arise. Such information shall also be disclosed to SEBI as and when required by SEBI. 5.4. Redemption norms²² 5.4.1. These norms shall apply to open ended schemes of Category III AIFs. 5.4.2. The Manager of such AIFs shall ensure adequate and sufficient degree of liquidity of the scheme/ fund in order to ....
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....eme size to twenty crore rupees within 3 months from the date of such breach. 5.5.3. In case the AIF fails to bring back the corpus within the specified period, it shall redeem entire units of all investors and wind up the scheme in terms of Regulation 29 of AIF Regulations. 5.5.4. In case of repeated violations by the AIF, SEBI may take action against the AIF, as may be appropriate. 23 SEBI circular No. CIR/IMD/DF/14/2014 dated June 19, 2014 Page 20 of 126 6.1. 6.2. 6.3. 6.4. 5-31 à¤à¤¾à¤°à¤¤à¥€à¤¯ पà¥à¤°à¤¤à¤¿à¤à¥‚ति और विनिमय बोरà¥à¤¡ Securities and Exchange Board of India Chapter 6 – Norms for Special Situation Funds (SSF) 2 - 24 Each scheme of SSF shall have a corpus of at least one hundred crore rupees. SSF shall accept an investment of value not less than ten crore rupees from an investor. In case of an accredited investor, the SSF shall accept an investment of value not less than five crore rupees. Further, in case of investors who are employees or directors of the SSF or employees or directors of the manager of the SSF, the minimum value of investm....
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....eme of the AIF. 7.1.4. AIFs shall invest in an overseas investee company, which is incorporated in a country whose securities market regulator is a signatory to the International Organization of Securities Commission's Multilateral Memorandum of Understanding (Appendix A Signatories) or a signatory to the bilateral Memorandum of Understanding with SEBI. 7.1.5. AIFs shall not invest in an overseas investee company, which is incorporated in a country identified in the public statement of Financial Action Task Force (FATF) as: (i) (ii) a jurisdiction having a strategic Anti-Money Laundering or Combating the Financing of Terrorism deficiencies to which counter measures apply; or a jurisdiction that has not made sufficient progress in addressing the deficiencies or has not committed to an action plan developed with FATF to address the deficiencies. 25 SEBI Circular No. SEBI/HO/AFD-1/POD/CIR/P/2022/108 dated August 17, 2022, SEBI Circular No. SEBI/HO/IMD/DF1/CIR/P/2018/103/2018 dated July 03, 2018 and SEBI Circular No. CIR/IMD/DF/7/2015 dated October 1, 2015 Page 22 of 126 7.2. 5-31 à¤à¤¾à¤°à¤¤à¥€à¤¯ पà¥à¤°à¤¤à¤¿à¤à¥‚ति औà¤....
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....¯ बोरà¥à¤¡ Securities and Exchange Board of India 7.2.5. If an AIF liquidates investment made in an overseas investee company previously, the sale proceeds received from such liquidation, to the extent of investment made in the said overseas investee company, shall be available to all AIFs (including the selling AIF) for reinvestment. 7.3. Reporting of overseas investments 7.3.1. AIFs shall report the utilization of the overseas limits within 5 working days of such utilization on SEBI intermediary portal at https://siportal.sebi.gov.in. 7.3.2. AIFs shall also report the following through SEBI intermediary portal: (i) In case an AIF has not utilized the overseas limit granted to them within a period of four months 27 from the date of SEBI approval (hereinafter referred to as 'validity period'), the same shall be reported within 2 working days after expiry of the validity period; (ii) In case an AIF has not utilized a part of the overseas limit within the validity period, the same shall be reported within 2 working days after expiry of the validity period; (iii) In case an AIF/ VCF wishes to surrender the overseas limit at any point of time within the validity....
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....à¤à¤¾à¤°à¤¤à¥€à¤¯ पà¥à¤°à¤¤à¤¿à¤à¥‚ति और विनिमय बोरà¥à¤¡ Securities and Exchange Board of India Chapter 9 – Participation of AIFs in Credit Default Swaps 30 Regulations 16(1)(aa), 17(da), 18(ab) and 20(11) of AIF Regulations enable AIFs to participate in CDS in terms of the conditions as may be specified by SEBI from time to time. In this regard, the following is specified: 9.1. Conditions applicable to Category I, II and III AIFs for buying CDS 9.1.1. Category | AIFs and Category II AIFs may buy CDS on underlying investment in debt securities, only for the purpose of hedging. 9.1.2. Category III AIFs may buy CDS for the purpose of hedging or otherwise, within permissible leverage as specified in para 5.2 of this Master Circular. 9.2. Conditions applicable to Category II and III AIFs for selling CDS 9.2.1. Category III AIFs may sell CDS, subject to the condition that effective leverage undertaken is within the permissible limits as specified in para 5.2 of this Master Circular. 9.2.2. Further, Category II AIFs and Category III AIFs may sell CDS, by earmarki....
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.... and engage in leverage except for meeting temporary funding requirements for not more than thirty days, not more than four occasions in a year and not more than ten percent of the investable funds. In this regard, Category I and Category II AIFs which transact in CDS, shall maintain thirty days cooling off period between the two periods of borrowing or engaging in leverage. 9.3.7. All CDS transactions shall be on a platform regulated by SEBI or RBI, to enhance transparency and disclosure. 9.3.8. AIFs transacting in CDS, shall also ensure compliance with applicable provisions of RBI notification on ‘Master Direction - Reserve Bank of India (Credit Derivatives) Directions, 2022', dated February 10, 2022 and other directives issued by RBI in this regard from time to time. Page 27 of 126 5-31 à¤à¤¾à¤°à¤¤à¥€à¤¯ पà¥à¤°à¤¤à¤¿à¤à¥‚ति और विनिमय बोरà¥à¤¡ Securities and Exchange Board of India Chapter 10 - Transaction in Corporate Bonds through Request for Quote (RFQ) platform by AIFs 31 10.1. AIFs shall undertake at least 10% of their total secondary market trades in....
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.... to be. The investment portfolio of a Category II AIF ought to be more in unlisted securities as against the aggregate of other investments. 11.2. Schemes of AIFS which have adopted priority in distribution among investors 33: 11.2.1. As per AIF Regulations, "Alternative Investment Fund" is a privately pooled investment vehicle, which collects funds from investors, for investing it in accordance with a defined investment policy for the benefit of its investors. 11.2.2. As per para 11.1.1 of this Master Circular, with respect to investment by the sponsor/manager in the AIF, the sharing of loss by the sponsor/manager shall not be less than pro rata to their holding in the AIF vis-à -vis other unit holders. While it has not been explicitly restricted in AIF Regulations that the sharing of loss by a class of investors shall not be less than pro rata to their holding in the AIF vis-à -vis other classes of investors/unit holders, it was 32 SEBI Circular No. CIR/IMD/DF/14/2014 dated June 19, 2014 and SEBI Circular No. CIR/IMD/DF/16/2014 dated July 18, 2014 33 SEBI Circular No. SEBI/HO/AFD-1/POD/P/CIR/2022/157 dated November 23, 2022 Page 29 of 126 5-3 à¤à¤¾à¤°à¤¤à¥€à....
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.... and Exchange Board of India Chapter 12 - Framework for Accredited Investors 35 12.1. Pursuant to public consultation and approval of the SEBI Board, the framework for "Accredited Investors" (Als) has been introduced in the securities market. 12.2. Under the aforesaid framework, Als may avail flexibility in minimum investment amount ("Lower ticket size") or concessions from specific regulatory requirements applicable to investment products, subject to conditions applicable for specific products/ services under SEBI (Alternative Investment Funds) Regulations, 2012, SEBI (Portfolio Managers) Regulations, 2020 and SEBI (Investment Advisers) Regulations, 2013. The modalities of accreditation are provided in Annexure 8. Accreditation Agency 12.3. Persons desirous of being reckoned as Als shall approach an Accreditation Agency for accreditation. Accreditation Agencies shall be responsible for: a) Verification of documents submitted by applicants for accreditation, b) Timely processing of applications for accreditation and issuance of accreditation certificate, c) Maintaining data of accredited investors, d) Verification of accreditation status, e) Maintaining confidentiality of investor ....
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.... shall be valid for a period of two years from the date of issuance. 12.10.2. If the applicant meets the eligibility criteria in each of the preceding two financial years, the accreditation certificate issued shall be valid for a period of three years from the date of issuance. 12.10.3. If the applicant is a newly incorporated entity, which does not have financial information for the preceding financial year but meets the applicable net- worth criteria as on the date of application, the accreditation certificate issued shall be valid for a period of two years from the date of issuance. Filing of LVF Schemes with SEBI36 12.11. Pursuant to introduction of framework for "Accredited Investors" in the securities market, AIF Regulations were amended to provide certain relaxations from regulatory requirements to ‘Large Value Fund for Accredited Investors' (LVF). 12.12. In terms of proviso to Regulation 12 of AIF Regulations, LVFs are exempt from filing their placement memorandum with SEBI through Merchant Banker and incorporate comments of SEBI, if any, in their placement memorandum i.e. LVFs can launch their scheme under intimation to SEBI. 36 SEBI Circular No. SEBI/HO/AFD/RAC/CIR/....
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....ager³8 13.1.1. AIFs shall ensure that Manager of AIF designates an employee or director as Compliance Officer who shall be a person other than Chief Executive Officer of the Manager or such equivalent role or position depending on the legal structure of Manager. The compliance officer shall be responsible for monitoring compliance with the provisions of the SEBI Act, AIF Regulations and circulars issued thereunder. 13.1.2. For the purpose of provisions of AIF Regulations, 'key management personnel' shall mean: (i) members of key investment team of the Manager, as disclosed in the PPM of the fund; (ii) employees who are involved in decision making on behalf of the AIF, including but not limited to, members of senior management team at the level of Managing Director, Chief Executive Officer, Chief Investment Officer, Whole Time Directors, or such equivalent role or position; (iii) any other person whom the AIF (through the Trustee, Board of Directors or Designated Partners, as the case may be) or Manager may declare as key management personnel. 13.1.3. AIFs shall disclose the names of all the key management personnel of the AIF and Manager as specified in para 13.1.2 above, in the....
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....e placement memorandum is provided to the investors prior to providing commitment or making the investment in the AIF and ensure that an appropriate acknowledgement is received from the investor for such receipt. (iv) ensure scheme-wise segregation of bank accounts and securities accounts. (V) not make any exaggerated statement, whether oral or written, either about their qualifications or capability to render investment management services or their achievements. 40 SEBI Circular No. CIR/IMD/DF/7/2015 dated October 01, 2015 Page 35 of 126 5-31 à¤à¤¾à¤°à¤¤à¥€à¤¯ पà¥à¤°à¤¤à¤¿à¤à¥‚ति और विनिमय बोरà¥à¤¡ Securities and Exchange Board of India 13.3.2. The AIF, manager, trustee and sponsor shall: (i) act in the interest of unitholders of the AIF/scheme and not take any action which is prejudicial to the interest of the unitholders and not place the interest of the sponsor/manager/trustee of the AIF or any of their associates above the interest of the unitholders of the scheme/AIF. (ii) maintain high standards of integrity and fairness in all their dealings and in the con....
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....ners of the Manager) and/or external members. In this regard, SEBI has written to Government and RBI seeking clarity on the applicability of clause (4) of Schedule VIII under Foreign Exchange Management (Non-debt Instruments) Rules, 2019, to investment made by an AIF whose Investment Committee approves investment decisions and consists of external members who are not 'resident Indian citizens'. 14.4. Pending clarification as mentioned at Para 14.3 above, the applications for registration of AIFs and launch of new schemes shall be dealt with as under: (i) (ii) The applications wherein Investment Committee proposed to be constituted to approve investment decisions of AIF includes external members who are 'resident Indian citizens', shall be duly processed. The applications wherein Investment Committee proposed to be constituted to approve investment decisions of AIF includes external members who are not 'resident Indian citizens', shall be considered only after receipt of clarification as stated in Para 14.3 above. 43 SEBI Circular No. SEBI/HO/IMD-I/DF6/P/CIR/2021/584 dated June 25, 2021 and SEBI circular No. SEBI/HO/IMD/DF6/CIR/P/2020/209 dated October 22, 2020 Page 37 of 126 5-31 ....
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.... 19, 2014 Page 38 of 126 5-31 à¤à¤¾à¤°à¤¤à¥€à¤¯ पà¥à¤°à¤¤à¤¿à¤à¥‚ति और विनिमय बोरà¥à¤¡ Securities and Exchange Board of India 15.2.3. In case of any observations/comments on the CTR, the trustee/sponsor shall intimate the same to the manager within 30 days from the receipt of the CTR. Within 15 days from the date of receipt of such observations/comments, the manager shall make necessary changes in the CTR, as may be required, and submit its reply to the trustee/sponsor. 15.2.4. In case any violation of AIF Regulations or circulars issued thereunder is observed by the trustee/sponsor, the same shall be intimated to SEBI as soon as possible. 15.3. Term Sheet - Angel Funds 46 15.3.1. Angel funds may launch schemes subject to filing of a Term Sheet in the format as specified in Annexure 13. 15.3.2. Such Term Sheet shall contain material information regarding the scheme. 15.3.3. Such Term Sheet shall be filed with the Board within ten days of launching the scheme. 15.4. Reporting of investments of AIFs under custody47 In terms of Regulation 20(11) of AIF Regulations, t....
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....n will appoint Benchmarking Agencies and thereafter will set timeline for reporting of requisite data to Benchmarking Agencies by all the registered AIFs. 16.3.2. The agreement between the Benchmarking Agencies and AIFs shall cover the mode and manner of data reporting, specific data that needs to be reported, terms including confidentiality in the manner in which the data received by the Benchmarking Agencies may be used, etc. 16.3.3. AIFs, for all their schemes which have completed at least one year from the date of 'First Close', shall report all the necessary information including scheme-wise valuation and cash flow data to the Benchmarking Agencies in a timely manner. 16.3.4. The form and format of reporting shall be mutually decided by the Association and the Benchmarking Agencies. 16.3.5. If an applicant claims a track-record on the basis of India performance of funds incorporated overseas, it shall also provide the data of the investments of the said funds in Indian companies to the Benchmarking Agencies, when they seek registration as AIF. 48 SEBI Circular No. SEBI/HO/IMD/DF6/CIR/P/2020/24 dated Feb 05, 2020 49 SEBI Circular No. SEBI/HO/IMD/DF6/CIR/P/2020/99 dated June 12,....
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....cement Memorandum (PPM). 17.3. Additionally, in order to bring about further transparency in the Investor Grievance Redressal Mechanism, data on investor complaints received against AIFs and each of their schemes and redressal status thereof shall be disclosed by all AIFs as per format at Annexure 16, as a separate chapter in the PPM. 17.4. For effective monitoring, AIFs shall maintain data on investor complaints as per Annexure 18, which shall be compiled latest within 7 days from the end of quarter. 17.5. These disclosure requirements are in addition to the existing requirements pertaining to the investor grievance handling mechanism under various Regulations, circulars and directions, issued by SEBI. 50 SEBI Circular No. SEBI/HO/IMD/IMD-I/DOF9/P/CIR/2021/682 dated December 10, 2021 Page 42 of 126 5-31 à¤à¤¾à¤°à¤¤à¥€à¤¯ पà¥à¤°à¤¤à¤¿à¤à¥‚ति और विनिमय बोरà¥à¤¡ Securities and Exchange Board of India Chapter 18 - Collection of stamp duty on issue, transfer and sale of units of AIFs 51 18.1. Government vide Gazette notification S.O.116(E) dated January 08, 2020 notif....
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....ponsor and in case of change in manager/sponsor. The cost paid towards such fee by manager/sponsor shall not be passed on to the investors of the AIF in any manner. 19.1.2. In case change in control of manager/change of manager and change in control of sponsor/change of sponsor of an AIF is proposed simultaneously, aforesaid fee equivalent to single registration fee shall be levied. 19.1.3. The aforesaid fee shall not be levied in the following cases for change in sponsor or change in control of sponsor: (i) The manager is acquiring control in or replacing the sponsor and Exit of sponsor(s) in case of AIF having multiple sponsors. (ii) 19.1.4. The aforesaid fee shall be paid within 15 days of effecting the proposed change in manager/sponsor or change in control of manager/sponsor. 19.1.5. In case of the applications pending with SEBI as on November 17, 2022, for change in control of manager/sponsor or change in manager/sponsor, the requirement of fee shall be applicable only in those applications where none of the schemes of AIFs managed/sponsored by manager/sponsor had declared their First Close. 19.1.6. The prior approval granted by SEBI in this regard shall be valid for a period....
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.... of AIFs in dematerialised form 54: In terms of Regulation 10(aa) of AIF Regulations, AIFS shall issue units in dematerialised form subject to the conditions specified by SEBI from time to time. In this regard, the following is specified - 20.1. All schemes of AIFs shall dematerialise their units in the following time frame: Particulars Schemes of AIFs with corpus = 2 Crore rupees; OR (b) Net Worth >= 7.5 Crore rupees, out of which at least 3.75 Crore rupees is in the form of financial assets; OR (c) Annual Income >= 1 Crore rupees + Net Worth >= 5 Crore rupees, out of which at least 2.5 Crore rupees is in the form of financial assets; Partnership Firms set up under the Indian Partnership Act, 1932 in which each partner independently meets the criteria for accreditation. (iii) Trusts (other than family trusts) with net worth greater than or equal to 50 Crore rupees. (iv) Body Corporates with net worth greater than or equal to 50 Crore rupees. 1.2. Foreign investor incorporated/established in form other than those mentioned at para 1.1. above shall be subject to eligibility criteria as applicable to Body Corporates. 1.3. In case of accreditation of individual investors, HUFs and Sol....
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....information and does not in any way exempt market intermediaries and pooled investment vehicles from any due diligence required to be carried out of the accredited investors at the time of on-boarding them as their clients. 3. Validity of Accreditation 3.1. If the applicant meets the eligibility criteria for preceding one financial year, the accreditation certificate issued shall be valid for a period of two years from the date of issuance. 3.2. If the applicant meets the eligibility criteria in each of the preceding two financial years, the accreditation certificate issued shall be valid for a period of three years from the date of issuance. 3.3. If the applicant is a newly incorporated entity, which does not have financial information for the preceding financial year but meets the applicable net-worth criteria as on the date of application, the accreditation certificate issued shall be valid for a period of two years from the date of issuance. Page 78 of 126 5-31 à¤à¤¾à¤°à¤¤à¥€à¤¯ पà¥à¤°à¤¤à¤¿à¤à¥‚ति और विनिमय बोरà¥à¤¡ Securities and Exchange Board of India 4. P....
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....regulatory framework for the particular investment product, within the timeframe specified in the client agreement. (b) If an investor who has availed concessions to the regulatory framework withdraws the 'Consent' furnished to the investment provider before the expiry of the client agreement, the investments already made shall be 'grandfathered' i.e. such investments shall continue to be reckoned as investments by an Al. With effect from the date of withdrawal of consent, any further transaction shall be in accordance with the regulatory framework applicable to investors other than Als. 5.2. Investors in pooled investment products which are launched exclusively for Als, in which concessions to regulatory framework have been availed, shall not have the flexibility to withdraw their Consent. 5.3. The client agreement between the investment service provider and Al shall, inter-alia, provide the modalities for withdrawal of 'Consent' and consequences of the investor withdrawing the 'Consent'. Page 80 of 126 5-31 à¤à¤¾à¤°à¤¤à¥€à¤¯ पà¥à¤°à¤¤à¤¿à¤à¥‚ति और विनिमय बोरà¥à¤....
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.... Board of India Dear Sir/Madam, Sub: Filing of draft placement memorandum of (name of LVF scheme), scheme of (name of AIF/proposed AIF) Based on the placement memorandum and supporting documents submitted by AIF/proposed AIF, we undertake that: 1. We have independently exercised due-diligence regarding information given in the placement memorandum, including the veracity and adequacy of disclosure made therein. 2. The AIF, its sponsor and manager are fit and proper persons based on the criteria specified in Schedule II of the Securities and Exchange Board of India (Intermediaries) Regulations, 2008. None of the intermediaries named in the placement memorandum have been debarred from functioning by any regulatory authority. 3. All the material disclosures in respect of the fund raising, investment by the scheme and management thereof have been made in the placement memorandum and are based on latest available information. 4. We have satisfied ourselves that the proposed activities of the scheme are bonafide, fall within the objectives of the fund as specified in the Articles of Association or Trust Deed or Partnership Deed of the AIF and are to meet the stated investment objective. ....
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....h respect to compliance with provisions of Securities and Exchange Board of India (Alternative Investment Funds) Regulations, 2012, as applicable, to the proposed LVF Scheme S. No. Regulati Contents of the Regulation on Wherever applicable, mention Section/ subsection along with page number of the placement memorandum where the Regulation has been complied with. Otherwise mention 'not applicable' or 'noted for compliance' 1 Chapter II - Registration of Alternative Investment Funds 3 Registration of Alternative Investment Funds 3(1) New Fund registration 3(4)(a) Category | AIF 3(4)(b) Category II AIF 3(4)(c) Category III AIF 4 Eligibility Criteria 4(a) | - Legal structure - Company; 4(b) 4(c) 4(d) 4(e) - Trust; - LLP Whether prohibited from making an invitation to public Whether Trust Deed is Registered Whether partnership in case of Limited Liability Partnership is duly incorporated and the deed is filed with Registrar Whether Body Corporate is set up or established under the laws of the Central or State Legislature and is permitted to carry activities on AIF Page 84 of 126 S. No. 2 5-31 à¤à¤¾à¤°à¤¤à¥€à¤¯ पà¥à¤°à¤¤à¤¿à¤à¥‚ति ....
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....) Affiliation of Manager with other intermediaries Page 86 of 126 S. No. 5-31 à¤à¤¾à¤°à¤¤à¥€à¤¯ पà¥à¤°à¤¤à¤¿à¤à¥‚ति और विनिमय बोरà¥à¤¡ Securities and Exchange Board of India Wherever applicable, mention Section/ Regulati Contents of the Regulation on 12(1) 12(4) 13 13(1) 13(2) o) Manner of winding up of AIF/Scheme p) terms of reference of the committee constituted for approving the decisions of the Alternative Investment Fund q) Other information for investors to take informed decision Filing of PPM for launch of scheme Timeline for declaring first close of scheme Tenure - Category I & II AIF/scheme to be close ended - Category I & II AIF/Scheme to have minimum tenure of 3 years - Category III AIF/schemes - Whether open ended or close ended Calculation of tenure 13(3) 13(4) 13(5) 13(6) - Liquidation of AIF 14 Extension of tenure subsection along with page number of the placement memorandum where the Regulation has been complied with. Otherwise mention 'not applicable' or 'noted for compliance' Listing requirements, as and when made applicable General Investment Co....
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....stments in dematerialised form 16 Conditions for Category I Alternative Investment Funds 16(1)(a) Investment by Category I AIF 16(1)(aa) Investment in Credit Default Swaps subject to conditions 16(1)(c) 16(2)(a) 16(2)(c) 16(2)(d) Not borrow funds & shall not engage in leverage except for meeting temporary requirements Venture Capital Fund to invest at least 75% of the investable funds in un-listed equity shares or equity linked instruments of VCU or in companies listed or proposed to be listed on SME exchange Venture Capital Fund to enter an Agreement with Merchant Banker for purpose of market making Exemption to Venture Capital funds from certain provisions of Securities and Exchange Board of (Prohibition of Insider India Trading) 16(3)(a) SME Fund investment Regulations, 2015 75% of investable funds - for at least Page 89 of 126 S. No. 5-31 à¤à¤¾à¤°à¤¤à¥€à¤¯ पà¥à¤°à¤¤à¤¿à¤à¥‚ति और विनिमय बोरà¥à¤¡ Securities and Exchange Board of India Wherever applicable, mention Section/ Regulati Contents of the Regulation on 16(3)(b) 16(3)(c) 16(4)(a) 16(4) (b) SME Fund to ent....
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....) Applicability to Angel Funds Page 91 of 126 subsection along with page number of the placement memorandum where the Regulation has been complied with. Otherwise mention 'not applicable' or 'noted for compliance' S. No. 5-31 à¤à¤¾à¤°à¤¤à¥€à¤¯ पà¥à¤°à¤¤à¤¿à¤à¥‚ति और विनिमय बोरà¥à¤¡ Securities and Exchange Board of India Regulati Contents of the Regulation on 19C 19D 19(D)(1) 19(D)(2) 19(D)(3) Registration of Angel Funds Investment in Angel Funds To raise funds by way of issue of units Minimum corpus Maximum period for accepting funds from investor for making investment by Angel funds and Minimum investment by angel investor funds through private 19(D)(4) Το raise placement 19E(1) Launch of scheme 19E(2) Maximum number of investors 19F(1) Investment by Angel Funds in start-ups 19F(2) Minimum investment by Angel Fund 19F(3) Investment by Angel Fund to be locked in for 1 year 19F(4) 19F(5) 19F(6) 19G(1) 19G(2) Angel funds to not invest in associates Angel funds to not invest more than 25% of the total investments under all its schemes in one venture capital und....
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....0(4) 20(5) 20(6) 20(7) 20(8) AIFs to have detailed policies and procedure to ensure that all the decisions of the AIF are in compliance with the provisions of these regulations, terms of the PPM, agreements made with investors, other fund documents and applicable laws AIFs to review policies and procedures on regular basis Manager shall be responsible for every decision of AIF Manager shall be responsible for ensuring that every decision of AIF is in compliance with policies and procedures laid down by AIF Manager may constitute an Investment Committee (by whatever name called), to approve the decisions of the Alternative Investment Fund and such constitution shall be subject to such conditions as specified by the Board from time to time Investment Committee shall be responsible for ensuring that decisions are in compliance with policies & procedure laid down in terms of sub regulation 20 (3) of this regulation (Not applicable in case the commitment to invest is not less than 70 crore rupees and has furnished a waiver to the AIF) subsection along with page number of the placement memorandum where the Regulation has been complied with. Otherwise mention 'not applicable' or 'noted fo....
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.... investors Manager to establish & implement written policies to mitigate conflict of interest Manager & Sponsor of AIF to abide by high level principles on avoidance of conflict of interest Transparency: All AIFs to ensure transparency & disclosure of information to investors on the following financial, risk management, operational, portfolio, and transactional subsection along with page number of the placement memorandum where the Regulation has been complied with. Otherwise mention 'not applicable' or 'noted for compliance' information regarding fund investments Page 96 of 126 S. No. 5-31 à¤à¤¾à¤°à¤¤à¥€à¤¯ पà¥à¤°à¤¤à¤¿à¤à¥‚ति और विनिमय बोरà¥à¤¡ Securities and Exchange Board of India Wherever applicable, mention Section/ Regulati Contents of the Regulation on to be disclosed periodically to the investors any fees ascribed or charged subsection along with page number of the placement memorandum where the Regulation has been complied with. Otherwise mention 'not applicable' or 'noted for compliance' 22(b) 22(c) Any enquiry/legal action as and when occurred 22(d) An....
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....tents of the Regulation subsection along with page number of the placement memorandum where the Regulation has been complied with. Otherwise mention 'not applicable' or 'noted for compliance' 25 25 27 27 28 29 Dispute Resolution- AIFs to lay down procedure for resolution of dispute between investors and AIFS Obligation of manager to maintain record as prescribed in AIF Regulations Timely Submission of Reports to the Board Compliance to Winding up provisions Note: This annexure may be modified in line with any amendments notified under SEBI (AIF) Regulations, 2012 from time to time. Page 99 of 126 5-31 à¤à¤¾à¤°à¤¤à¥€à¤¯ पà¥à¤°à¤¤à¤¿à¤à¥‚ति और विनिमय बोरà¥à¤¡ Securities and Exchange Board of India Annexure B Information with respect to disclosures in the placement memorandum S. Particulars No. Yes/ Remarks No (Also provide the respective page number of placement memorandum 1. Whether it is stated in the placement memorandum that the LVF scheme shall be placed only before Accredited Investors having valid accreditation certificate from SEBI recognized Accreditation A....
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....e of the scheme also In case of Category III AIFs, whether the scheme proposes to invest in such instruments also to provide applicable margin to recognized stock exchanges 13. Whether maximum duration for such temporary deployment of funds is disclosed 14. Whether the scheme intends to invest in units of AIFs wherever applicable) If yes, also highlight such clauses If yes, provide the list of proposed temporary instruments for deployment of funds If yes, mention the duration If yes, whether necessary disclosures have been made in line with Page 101 of 126 5-31 à¤à¤¾à¤°à¤¤à¥€à¤¯ पà¥à¤°à¤¤à¤¿à¤à¥‚ति और विनिमय बोरà¥à¤¡ Securities and Exchange Board of India S. Particulars No. Yes/ Remarks No (Also provide the respective page number of placement memorandum wherever applicable) Chapter 8 of SEBI Master Circular for AIFs 15. Whether names of key management personnel are disclosed in the placement memorandum in line with para 13.1.2 and 13.1.3 of SEBI Master Circular for AIFs 16. Whether it is verified that all members of key investment team are employees or partners or....
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....ate the for warehousing and the 27. Whether timelines for intimation regarding warehoused investments to existing and prospective investors, are disclosed transferring of warehoused investment If yes, state the timelines for such intimation Page 103 of 126 5-31 à¤à¤¾à¤°à¤¤à¥€à¤¯ पà¥à¤°à¤¤à¤¿à¤à¥‚ति और विनिमय बोरà¥à¤¡ Securities and Exchange Board of India S. Particulars No. Yes/ Remarks No (Also provide the respective page number of placement memorandum 28. Whether it is provided that a defaulter, i.e., investor who defaults in bringing drawdown amount within the timeline specified, can no longer participate in subsequent investments of the scheme till the default is cured and that there are clauses providing steps to be taken against the defaulting investor 29. Whether specific instances are disclosed under which in-specie distribution / distribution in kind may be made 30. Whether it is disclosed that co-investment by investors of AIF shall be made in compliance with applicable provisions of AIF Regulations and PMS Regulations 31. Whether it is disclosed that th....
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....stitutional investors should have a clear policy on how they manage conflicts of interest in fulfilling their stewardship responsibilities and publicly disclose it. Guidance As a part of the aforesaid comprehensive policy, institutional investors should formulate a detailed policy for identifying and managing conflicts of interest. The policy shall be intended to ensure that the interest of the client/beneficiary is placed before the interest of the entity. The policy should also address how matters are handled when the interests of clients or beneficiaries diverge from each other. The conflict of interest policy formulated shall, among other aspects, address the following: 1. Identifying possible situations where conflict of interest may arise. E.g. in case of investee companies being associates of the entity. Page 105 of 126 5-31 à¤à¤¾à¤°à¤¤à¥€à¤¯ पà¥à¤°à¤¤à¤¿à¤à¥‚ति और विनिमय बोरà¥à¤¡ Securities and Exchange Board of India 2. Procedures put in place by the entity in case such conflict of interest situations arise which may, inter alia, include: a. Blanket bans ....
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....Environmental, Social and Governance (ESG) risks f. Shareholder rights, their grievances etc. 3. Identification of situations which may trigger communication of insider information and the procedures adopted to ensure insider trading regulations are complied with in such cases. Principle 4 Institutional investors should have a clear policy on intervention in their investee companies. Institutional investors should also have a clear policy for collaboration with other institutional investors where required, to preserve the interests of the ultimate investors, which should be disclosed. Guidance Institutional investors should have a clear policy identifying the circumstances for active intervention in the investee companies and the manner of such intervention. The policy should also involve regular assessment of the outcomes of such intervention. Intervention should be considered even when a passive investment policy is followed or if the volume of investment is low, if the circumstances so demand. Circumstances for intervention may, inter alia, include poor financial performance of the company, corporate governance related practices, remuneration, strategy, ESG risks, leadership iss....
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....every proposed resolution in investee companies i.e. For, Against or Abstain c. Rationale for voting d. Manner of disclosure — e.g. in annual report to investors, quarterly basis on website etc. 4. In case of use of proxy voting or other voting advisory services, disclosures on: a. Scope of such services b. Details of service providers c. Extent to which the investors rely upon/use recommendations made by such services Principle 6 Institutional investors should report periodically on their stewardship activities. Page 108 of 126 Guidance 5-31 à¤à¤¾à¤°à¤¤à¥€à¤¯ पà¥à¤°à¤¤à¤¿à¤à¥‚ति और विनिमय बोरà¥à¤¡ Securities and Exchange Board of India Institutional investors shall report to their clients/ beneficiaries periodically on how they have fulfilled their stewardship responsibilities as per their policy in an easy-to- understand format. However, it may be noted that the compliance with the aforesaid principles does not constitute an invitation to manage the affairs of a company or preclude a decision of the institutional investor to sell a holding when it is in t....
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....IF/Scheme) shall be responsible for ensuring that every decision of (Name of the AIF/Scheme) is in compliance with the policies and procedures laid down for the (Name of the AIF/Scheme) in terms of Regulation 20(3) of SEBI (AIF) Regulations, 2012, and other internal policies of the (name of the AIF/Scheme), as applicable. 7. Notwithstanding the waiver granted herein, if any contractual responsibility is cast on the members of investment committee in terms of the provisions of the fund documents, they shall not be absolved from such responsibilities. 8. Further, we understand that (Name of Manager), the manager of (name of the AIF/Scheme) shall at all times be responsible for ensuring that the investments of (name of the AIF/Scheme) are in compliance with the provisions of SEBI (AIF) Regulations, the terms of the placement memorandum, agreement with the undersigned, other fund documents and applicable laws. (Signed by the investor or two authorized signatories of the investor) Page 110 of 126 5-31 à¤à¤¾à¤°à¤¤à¥€à¤¯ पà¥à¤°à¤¤à¤¿à¤à¥‚ति और विनिमय बोरà¥à¤¡ Securities ....
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....¤¤à¥€à¤¯ पà¥à¤°à¤¤à¤¿à¤à¥‚ति और विनिमय बोरà¥à¤¡ Securities and Exchange Board of India Sr. No Compliance with respect to Details of memorandum has been filed with SEBI at least thirty days prior to launch of scheme along with the scheme fees. 11. Regulation 13(5) & 13(6): Whether there has been any extension of the tenure of the close ended AIF. If yes, whether the same is not more than two years and approved by two-thirds of the unit holders by value of their investment in the AIF. In the absence of consent of unit holders, whether the AIF has fully liquidated within one year following expiration of the fund tenure or extended tenure. 12. Regulation 14(1): In case the units of the AIF are listed during the year, whether the listing is after final close of the fund or scheme. 13. Compliance with every clause of Regulation 15 (Separate compliance for every clause shall be provided) 14. Compliance clause of with every Regulation 16/17/18/19, as applicable (Separate compliance for every clause shall be provided) 15. Compliance with every clause of Regulation 20 compliance Any ....
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....ds A. Investment and Investee Company Related Information 1. Name of the Angel Fund 2. SEBI Registration No. 3. Name of Scheme 4. 345 Name of investee company Investee Company profile and Product details/ services offered by the investee company Business/ industry details of the Investee company Present Investment size/ Amount of the offering Investment highlights 7. པ[གྲྠ6. 8. 9. 10. Capital drawn by the fund 11. Total Capital Commitment by investors Type of Securities (Equity Shares / Compulsorily Convertible Preference Shares / Compulsorily Convertible Debenture) Number of securities along with description Price per share/ unit of the security Conversion Price and terms, in case convertible securities 12. 13. 14. 15. Details of lock in for share/ unit of fund 16. Co-investment, if any 17. Details of Valuation of investee company 18. Fee and expenses details for the fund 19. Annexure 13 20. 21. - Exit strategy for the Angel Fund Termination of the investment/exit provisions Distribution waterfall (distribution to the investors) Exit/ transfer rights for investors B. Compliance with SEBI (Alternative Investment Funds) Regulations, 2012 1. 2. List of investor....
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....plementation of Performance Benchmarking Section A: a) Performance Benchmarking shall be done on a half yearly basis based on the data as on September 30 and March 31 of each year. b) AIFs/ Schemes that have completed at least one year from First Close, shall provide all the necessary information/data to the Benchmarking Agencies. c) AIFs shall provide data on cash flows and valuation of their scheme-wise investments to the Benchmarking Agencies in the form and format required by each Benchmarking Agency, within 45 days from the end of every half-year ending on 30th September and within 6 months from the end of every half-year ending on 31st March. The format of data reporting shall mandatorily include details of valuation principles and the name of the Valuation Agency appointed by the AIF. d) Periodicity of valuation of investments shall be as provided in the AIF Regulations. e) Data provided for March 31 of every year shall be audited data and for September 30 may be unaudited data. f) Valuation of investments shall be in the manner provided in the specific Scheme's PPM or fund documents, as the case may be. Any change to valuation principle shall be informed to the Benchmarking....
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....encies. (v) Customized performance reports thus generated shall be called "Performance Report†as against the nomenclature “Benchmark Report", which shall be used for the standard benchmark reports generated based on SEBI mandate. Page 119 of 126 5-31 à¤à¤¾à¤°à¤¤à¥€à¤¯ पà¥à¤°à¤¤à¤¿à¤à¥‚ति और विनिमय बोरà¥à¤¡ Securities and Exchange Board of India Annexure 15 Investor Charter for Alternative Investment Funds A. Vision and Mission Statement: Vision To develop the Alternative Investment Fund ("AIF") industry on professional and ethical lines and maintain high standards of governance and transparency. Mission • . Maintain high professional and ethical standards within the AIF industry. Comply with all applicable regulations and co-operate with the regulators in all aspects of the AIF activity. Act in a fiduciary capacity towards the investors. B. Details of business transacted by the organization with respect to the investors: • To raise capital from domestic and global investors. • • To invest in portfolio companies in accordance wi....
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....of the activity/services provided to investors: Sr. No. Description of activity/services provided Timeline for completion of by Alternative Investment Funds (AIFs) to activity its investors Valuation related disclosures: 1. a. Valuation of investment by Category I and II Alternative Investment Fund Page 121 of 126 At least once every six months. Can be extended to once a year with approval of 75% of its investors by value of investment. 5-31 à¤à¤¾à¤°à¤¤à¥€à¤¯ पà¥à¤°à¤¤à¤¿à¤à¥‚ति और विनिमय बोरà¥à¤¡ Securities and Exchange Board of India b. Disclosure of NAV of scheme(s) of the Category III Alternative Investment Fund Close ended fund - quarterly basis Open ended fund -monthly basis 2. Transparency related disclosures: a. Disclosure of financial information of investee companies b. C. d. e. Disclosure of Material risks: concentration risk, foreign exchange risk at fund level and leverage risk, realization risk, strategy risk, reputation risk at investee company level, extra-financial risks such as social and corporate governance risks etc. at fund and investee compa....
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.... Mumbai - 400 051. F. Responsibilities of investors 1. Responsibility to inform and educate yourself 1.1. Read thoroughly all fund documents including Private Placement Memorandum, Contribution Agreement, sales literature, newsletters and understand the product. 1.2. Carefully consider all investment risks, fees, and/or other factors detailed in these documents. 1.3. Ensure and make certain that the proposed investment in the Fund meets your investment objective and is in alignment with your risk appetite. 1.4. Review your portfolio holdings, account statements and transaction confirmation on regular basis to ensure that you aware of all transactions and securities where you are invested. 2. Responsibility to timely update your KYC and information with the Intermediary 2.1 Provide complete and accurate information in your KYC documents, including financial/ income status. 2.2 Timely updation of KYC information. 3. Responsibility to abide by the contribution agreement. 3.1. The investor needs to read carefully and understand the agreement that he/she is entering into with the Alternative Investment Fund and abide by the terms thereof. Page 123 of 126 3.2. 5-31 à¤à¤¾à¤°à¤....
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