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Circular No. FITTC/CUST/3/1998
November 20, 1998

To
All Foreign Institutional Investors through
Custodians of Securities

Dear Sir,

Sub: Reporting of transactions by registered Foreign Institutional Investors (FII).

With a view to monitor the trends of investment by FIIs, SEBI had asked the FIIs to submit the details of transactions made by them on daily basis. These reports are being submitted by the respective custodians on behalf of their FII clients on daily and monthly basis. SEBI has developed a new software for maintenance of FII investment data. The issue has been discussed at the meeting with custodians held on August 12, 1998. It has been decided to implement the new reporting format w.e.f. November 16, 1998. The details thereof are mentioned below :
A. Daily Reports (DTR):Custodians would henceforth submit a Daily Transaction Report (DTR) along with the Daily Transaction Summary (DTS) in new formats. The formats of DTR, DTS, explanation of codes, field widths etc. are enclosed as Annexure A, B and E respectively. Custodians would, however, continue to report the daily transactions in the existing format (i.e. DBF format) also till further instructions.

The new DTR and DTS would be implemented with effect from November 30, 1998 and would be submitted by 11.00 a.m. of the following working day. All statements should be signed by the Head of Custodial Operations of the custodian.
Initially the DTR and DTS would be submitted in both hard and soft forms. At a later date, the hard copy of DTR would be discontinued.

The data as per revised DTR would be submitted in ” TEXT ” format with fields separated by “l” (i.e. Pipe).

It has also been decided that henceforth all transactions will have a unique transaction identification number which would be given by the custodians at their end. Further, to avoid any confusion regarding the scrip name, ISIN numbers should be used. The appropriate ISINs for scrips as applicable for the physical and demat form, etc. are to be used. The list of ISIN numbers is available on SEBI web site : www.sebi.gov.in. In case ISIN number is not available for a particular scrip, the custodian may contact the Division Chief, IES Department, in SEBI for the same.
It is also proposed to give a code number to the various sub accounts. The code numbers for existing accounts would be generated by SEBI and communicated at the time of grant of registration.

In case of any amendment of the transactions, the amended transaction may be reported again with same Transaction Identity No. and Reporting Type as : Amendment (the appropriate codes as given in the annexure are to be used in the soft copy of the report).

In case of deletion of a transaction, the transaction be reported with same Trade ID and Reporting Type as : Deletion. A statement may be submitted in case of amendment / cancellation of transactions mentioning the reasons therefor.
All amendments / deletions should be reported on the day when information about the same is received by the custodian. Delay in reporting would be viewed seriously.

At present debt fund and equity fund transactions are being reported as separate files. Henceforth, they will be reported in the same file and the segregation would be done through the field ‘nature of fund’ which will be kept in

FII Master.
Monthly Reports

The custodians are required to submit a Monthly Portfolio Report (MPR). MPR would detail the portfolio holdings of the FII and would be submitted in soft and hard form (format enclosed as Annexure C). It may be submitted by 10th of the following month after incorporating all the amendments and cancellations till that date.

C. RECONCILIATION OF TRANSACTION DATA

i) DTS

The daily (and monthly report) would be reconciled daily (monthly). The custodians are therefore advised to ensure proper supervision at their end before sending the reports. As and when the DTS does not match (either because of physical damage, error records* or wrong data) with the data submitted, the floppy would be returned to the custodian and the same would have to be rectified and resubmitted on the same day. In case the rectified file is resubmitted on the next day, it should be clubbed with the next day’s reporting with report date and file name both bearing the current date as reporting date.

*Error records would be generated if the mandatory fields in the DTR are not filled.

ii) MPR

When the MPR is not matching with SEBI’s data, SEBI would be sending the transaction records, which are not matching, to the custodians for reconciliation. The custodian would thereafter send the records, which are amended, deleted or not reported earlier, in a separate file along with a hard copy of the same by the fifteenth of the current month.

RECONCILIATION OF EXISTING HOLDINGS OF THE FIIs.

It is also proposed to reconcile the holdings of the FIIs with our records. However, some of the custodians have expressed their inability to provide old data for various reasons such as change in software, non-availability of old records etc. After discussions, it has been decided that all FIIs would provide the details of their portfolio holdings (sub account wise) in the format enclosed at Annexure D, as on March 31, 1998 along with cost hereof. This data is to be submitted by November 30, 1998. All FIIs are requested to advise their custodians to submit the above data by the stipulated date.

The custodians are also required to submit the monthly investment figures for the FIIs handled by them, as per annexure F. These figures are to be provided for the period January 1993 till March 1998. The figures may be provided in either rupee terms or US dollar terms.

Besides the above, all amendments/cancellations of transactions made after March 31, 1998 may also be submitted in hard form by November 25, 1998.

Certain operational notes on reporting are also enclosed in the annexure.

D. GENERAL ASPECTS :

The date format to be used all the reports submitted to SEBI would be DD-MON-YYYY.
Custodians must ensure that the data submitted is accurate and complete and does not contain any blank or incomplete records.

It has been observed that on many occasions, reports are received late or are incomplete or are submitted with different parameters than prescribed. This results in problems and delay in compilation of data. It is therefore suggested that all reports should be duly verified before submission and be signed by the Head of Custodial Operations. SEBI shall be monitoring the quality of reports being submitted and action may be taken against erring custodians.

The files names to be used for submitting the report in soft copies are as follows :

DTR: DR<ddmmyy>.txt

DTS: DS<ddmmyy>.txt

MPR: MP<ddmmyy>.txt

Requests for clarifications, if any, may be addressed to Shri Manoj K Jain, Officer, on phone : 91-22-285 0451 / 288 0962 Extn. 144 or facsimile no. 91-22-284 5776 or e-mail – pgupta@sebi.gov.in.

E. APPOINTMENT OF COMPLIANCE OFFICER

All custodians are requested to appoint a Compliance Officer for ensuring correctness of reporting and compliance with the Regulations. The name, designation, office address, email address (if any), telephone and fax number may be communicated to SEBI within 10 days.

The custodians of securities are requested to bring the contents of this circular to the notice of their constituents.

Yours faithfully,

O.P.GAHROTRA
SENIOR EXECUTIVE DIRECTOR

Encl : Annexures

LIST OF ANNEXURES

ANNEXURE DESCRIPTION FILE NAME TYPE OF FILE
A Daily Transaction Report Annexure A Excel
B Daily Transaction Summary Annexure B Word
C Monthly Portfolio Report Annexure C Excel
D Holdings Statement Annexure D Word
E Description of Codes and Operational Notes Annexure E Word
F Monthly Investment Figures Annexure F Word

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