CIRCULAR
CIR/IMD/DF/14/2014                                                                                    June 19, 2014

To

All Alternative Investment Funds (“AIFs”) registered with SEBI

All custodians of Category III Alternative Investment Funds

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All Alternative Investment Funds which are exempt from registration under sub-regulation (1) of Regulation (3) of the SEBI (Alternative Investment Funds) Regulations, 2012 (“AIF Regulations”)

Dear Sir /Madam,

Sub: Guidelines on disclosures, reporting and clarifications under AIF Regulations

SEBI (Alternative Investment Funds) Regulations, 2012 were notified on May 21, 2012. A Circular no.CIR/IMD/DF/10/2013 dated July 29, 2013 was also subsequently issued for operational, prudential and reporting requirements for AIFs. Certain amendments were also made to the AIF Regulations on September 16, 2013. It is decided to provide certain clarifications on the AIF Regulations, increase transparency to the investors and provide reporting norms for AIFs as under:

  1. Submission of information to SEBI under sub-regulation (1) of Regulation (3) of AIF Regulations

a. Circular no. CIR/IMD/DF/10/2013 dated July 29, 2013 requires that all Category III AIFs report to the custodian on a daily basis the amount of leverage at the end of the day (based on closing prices) and whether there has been any breach of limit during the day.

b. It has been observed that with respect to reporting of amount of leverage at the end of the day, the AIF is dependent on various parties in order to calculate and submit to the custodian the amount of leverage as at the end of the day. Such various parties provide information at varied time periods due to which the AIFs are finding it difficult to report to the custodian the amount of end-of-day leverage on the same day.

c. Therefore, in part modification of the aforesaid circular dated July 29, 2013, all Category III AIFs shall report to the custodian the amount of leverage at the end of the day (based on closing prices) by the end of next working day.

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