Securities and Exchange Board of India
Monday 30th September 2024– SEBI Board Meeting
Amendments to the Securities and Exchange Board of India (Mutual Funds) Regulations, 1996 for introduction of regulatory framework for a new investment product – ‘(nomenclature excised)’
1. Objective
1.1. This memorandum seeks approval of the Board for amendments to the Securities and Exchange Board of India (Mutual Funds) Regulations, 1996 (hereinafter referred to as ‘MF Regulations’) to establish a regulatory framework for a new investment product, proposed to be named as (nomenclature excised) (hereinafter referred to as ‘New Product’ or ‘NP’), within the existing Mutual Fund structure.
1.2. The proposed framework is intended to bridge the gap between Mutual Funds (hereinafter referred to as ‘MFs’) and Portfolio Management Services (hereinafter referred to as ‘PMS’) in terms of flexibility in portfolio construction, and also aims to curtail the proliferation of unregistered and unauthorized investment management services that often pose significant risk of loss of capital for the investors.
2. Background
2.1. The landscape of investment management in India has significantly evolved over the years, marked by the introduction and development of various investment products. SEBI has adopted a segmented risk-based approach to regulation for these products depending on their complexity, sophistication of target investors, minimum investment size etc.
2.2. The current range of investment products with varying risk-reward profiles, are intended to meet the investment needs of retail, high net-worth and institutional investors. These products include MF schemes which are retail oriented with a low ticket size, PMS with a ticket size of INR 50 lakhs and Alternative Investment Funds (hereinafter referred to as ‘AIF’) with a minimum investment value of INR 1 crore. The regulatory framework and prudential norms governing these investment vehicles become progressively more flexible from MFs to AIFs, in sync with the investment profile and investment size.
2.3. Over the years, a gap has emerged between MFs and PMS in terms of portfolio flexibility, creating an opportunity for a new investment product. The absence of such a regulated investment product appears to have inadvertently propelled a segment of investors towards unregistered and unauthorized investment schemes/entities, which often promise unrealistic high returns and exploit investors’ expectations for better yields, leading to potential financial risks.
2.4. To address this gap, there is a need for a new investment product that caters to investors who require more flexibility in portfolio construction than traditional MFs but do not meet the higher investment thresholds for PMS. The proposed introduction of new investment product seeks to provide these investors a professionally managed and well regulated product that offers greater flexibility, higher risk-taking capabilities and higher ticket size, while ensuring that appropriate safeguards and risk mitigation measures are in place.
3. Public consultation
3.1. Based on industry feedback and internal discussions, a consultation paper titled “Introduction of New Asset Class/Product Category” was issued on July 16, 2024, seeking feedback from all stakeholders on the new investment product. A copy of the consultation paper is placed as Annexure A1. The consultation period, which concluded on August 06, 2024, received over 70 responses from a diverse group of stakeholders, including MFs, PMS, AIFs, industry associations, exchanges and individual investors. A summary of the public comments is provided in Annexure A2, and the analysis of public comments including the rationale for acceptance or non-acceptance of the suggestions is provided in Annexure A3.
3.2. Pursuant to the public consultation process, the proposal was also deliberated in the Mutual Fund Advisory Committee (hereinafter referred to as ‘MFAC’) on August 30, 2024.
4. Global practices
4.1. The proposed introduction of the new investment product aligns with global financial trends, where similar products are available to cater to investors’ need for higher returns and greater flexibility in portfolio construction. Countries with mature financial markets, such as the United States of America (hereinafter referred to as ‘USA’) and Australia, have permitted similar products such as Liquid Alternatives or Hedge Fund Lite in USA and Inverse Funds in Australia.
4.2. With a rapidly growing stock market and investor base, the Indian market is well-positioned to adopt more sophisticated investment products. The proposed framework would align the country’s financial landscape with global practices, offering investors a wider range of investment options and tools to diversify investments.
5. Regulatory framework for the New Product
Taking into consideration the comments received on the consultation paper from various stakeholders, media feedback, recommendations of MFAC and further internal deliberations, the following is proposed:
5.1. Structure of the new investment product
5.1.1. Suggestion in the consultation paper
The consultation paper, inter alia, proposed that given the new investment product is intended to have a risk-return profile between MFs and PMS, the proposed regulatory framework should enable higher risk-taking than traditional MFs, while incorporating commensurate safeguards and risk mitigation measures. Therefore, it was suggested that the new investment product may be introduced under the existing Mutual Fund structure with necessary and adequate relaxations in prudential norms. It was further suggested that the new investment product may be established as a distinct segment or vertical within the Mutual Fund framework, such that all provisions of the MF Regulations, the Master Circular for Mutual Funds, and any other applicable circulars also extend to this new investment product.
5.1.2. Public comments
a) Some respondents, particularly PMS and AIFs, advocated for a level playing field for offering the products under the proposed framework. They suggested that PMS and AIFs, who already undergo adequate due diligence and fit and proper checks, should also be allowed to offer strategies under the proposed new investment product.
b) Few other respondents suggested creating a separate chapter under the MF Regulations or making necessary amendments in PMS and AIF regulations, so as to enable PMS and AIFs to offer the new product.
5.1.3. Consideration of issues
a) The Mutual Fund industry in India has a long-established history and well-regulated framework, marked by a three-tier governance structure. This structure, comprising the sponsor, trustees, and Asset Management Company (hereinafter referred to as ‘AMC’), is critical in managing retail and small-ticket investors, ensuring a high level of investor protection through comprehensive risk management, governance, and disclosure standards. Additionally, the regulatory framework for MFs has well-established liquidity risk management practices, extensive disclosures, reporting requirements, strict codes of conduct for fund managers and dealers and various investor protection measures. These guardrails collectively ensure a high standard of investor protection, foster confidence in the investment process, and contribute to the stability and integrity of the Mutual Fund ecosystem.
b) Mutual Funds are also uniquely positioned due to their extensive experience in catering to retail investors, supported by a widespread network of MF distributors, which enhances their ability to effectively manage and distribute investment products to a broader investor base.
c) The existing regulatory frameworks for PMS and AIFs, while commensurate with their intended purpose and investor base, do not incorporate the same level of regulatory standards when compared to those applicable under the Mutual Fund framework. PMS and AIFs primarily cater to a more sophisticated investor base, which generally requires relatively less regulatory oversight. Allowing such entities to offer products under the proposed new product without adhering to regulatory framework for MFs, could potentially be a riskier proposition from investor perspective. Therefore, it is crucial that proposed product operates within the Mutual Fund framework in the interest of better investor protection.
d) While existing PMS and AIF entities may not be able to offer the new investment product under their respective frameworks, they can do so by obtaining registration as Mutual Funds and fulfilling the eligibility criteria for the new investment product.
5.1.4. Proposal
In view of the above, it is proposed that the new investment product may be introduced under the existing Mutual Fund framework.
5.2. Nomenclature for the new investment product
5.2.1. Suggestions in the consultation paper and public comments
The consultation paper invited suggestions from the public regarding the nomenclature for the new investment product. The public comments highlighted importance of selecting a name that distinctly differentiates this product from existing Mutual Funds, while effectively communicating its advanced features and higher investment threshold. Some of the suggestions for nomenclature of new investment product include ‘Restricted Mutual Fund’, ‘High-Risk Investment Fund’, ‘Specialized Investment Fund’, ‘Strategy Fund’ etc. Additionally, MFAC suggested that the words ‘Mutual Fund’ may be avoided in the nomenclature.
5.2.2. Consideration of issues and proposal
(This has been excised. Amendment to SEBI (Mutual Funds) Regulations, 1996 shall be notified.)
5.3. Definition of ‘Investment Strategy’
5.3.1. Suggestions in the consultation paper and public comments
a) The consultation paper, inter alia, proposed that pooled offerings under the new investment product may be referred to as ‘Investment Strategies’ rather than ‘schemes’, so as to clearly distinguish the offerings under the new investment product from those under the traditional Mutual Funds. An illustration on potential investment strategies that may be permitted to be launched under the NP, is placed at Annexure A4.
b) A majority of respondents concurred with this nomenclature, endorsing the use of ‘Investment Strategy’ as an appropriate term that reflects the innovative and differentiated nature of the product.
5.3.2. Proposal
In view of the above, the proposal made in the consultation paper may be accepted and the following definition of ‘Investment Strategy’ may be inserted into the MF Regulations:
(This has been excised. Amendment to SEBI (Mutual Funds) Regulations, 1996 shall be notified.)
5.4. Branding provisions
5.4.1. Suggestion in the consultation paper
a) The consultation paper, inter alia, proposed that, given the relatively higher risk profile of the new investment product compared to traditional Mutual Fund schemes, it is crucial to maintain a clear distinction between the branding and advertising of these two products.
b) To ensure this distinction, it was suggested that the new investment product be positioned as a product distinct from the traditional MFs, both from branding and advertisement perspectives, including the manner of usage of distinct brand name, distinct logo, specific disclaimers in advertisements etc.
5.4.2. Public comments
a) While majority of respondents supported the proposal for distinct branding to clearly differentiate NP from traditional MFs, some also suggested to permit the use of sponsor’s brand name to benefit from existing brand recognition and reputation. It was also suggested that a separate section or even a dedicated website be maintained by the AMC specifically for the NP, to further distinguish it from traditional MF offerings.
b) MFAC was of the view that Mutual Funds may be allowed to use sponsor’s brand name for promotion and advertising of NP.
5.4.3. Consideration of issues
a) As the products offered under the NP will be relatively riskier than the traditional Mutual Fund schemes, it is essential to maintain a clear distinction between the branding of products under the NP and those under the traditional Mutual Funds. Thus, mandating certain branding restrictions for NP shall ensure that any potential underperformance or capital loss in NP does not result in brand contamination or any adverse impact on the confidence and trust in the traditional Mutual Fund offerings.
b) It may thus be desirable that NP are launched under a distinct brand name and logo, separate from those of the AMC, MF, or sponsor. For instance, a Mutual Fund like ‘ABC Mutual Fund’ could create a distinct brand, such as ‘XYZ,’ with a unique logo. The NP could then be marketed under this new brand as ‘XYZ New Product’. Further, NP may be permitted to use sponsor or MF name for promotion and advertising of NP during the initial years, which can be gradually weaned off in the long term once the NP brand name and logo are established.
c) It may also be desirable that a separate website or portal dedicated to NP is mandated so as to ensure clear differentiation between Mutual Fund and NP products, offered under the same sponsor and MF.
5.4.4. Proposal
a) In view of the above, it is proposed that MF Regulations may be amended to insert the following enabling clause:
(This has been excised. Amendment to SEBI (Mutual Funds) Regulations, 1996 shall be notified.)
b) It is also proposed that the following may be specified by way of a circular:
(This has been excised due to reasons of confidentiality.)
5.5. Eligibility Criteria
5.5.1. Suggestion in the consultation paper
In order to facilitate existing as well as newly registered MFs to offer products under the new investment product, the consultation paper, inter alia, proposed following two eligibility routes:
a) Route 1: Sound track record
All registered MFs fulfilling the below mentioned criteria shall be eligible to launch the new investment product:
i. Mutual Fund shall be in operation for minimum of 3 years and has average Asset Under Management (hereinafter referred to as ‘AUM’) of not less than INR 10,000 crores, in immediately preceding 3 years.
ii. No action initiated or taken against the sponsor/AMC under section 11, 11B, and/or Section 24 of the SEBI Act, 1992 during the last 3 years.
b) Route 2: Alternate Route
All newly registered as well as existing MFs, not fulfilling the requirements under Route 1 above, shall also be eligible to launch the new investment product, subject to compliance with the following requirements:
i. AMC shall appoint a Chief Investment Officer for the New Investment Product with an experience of fund management of at least 10 years and managing AUM of not less than INR 5,000 crores, AND an additional Fund Manager for the New Investment Product with experience of fund management of at least 7 years and managing AUM of not less than INR 3,000 cr.
ii. No action initiated or taken against the sponsor/AMC under section 11, 11B, and/or Section 24 of the SEBI Act, 1992 during the last 3 years.
5.5.2. Public comments
a. Many respondents expressed concern that the proposed AUM thresholds under Route 2 are overly restrictive and could potentially limit inclusion of talent from outside the Mutual Fund industry. It was highlighted that only around 300 schemes under MFs have an AUM of more than INR 5,000 crores, indicating a need to re-evaluate these thresholds. Alternatively, few respondents suggested adopting a team-based experience approach for Route 2 instead of focusing solely on individual qualifications.
b. Some of the respondents also recommended mandating National Institute of Securities Markets (hereinafter referred to as ‘NISM’) certification for fund managers of the new investment product.
c. MFAC broadly agreed with the proposed Route 1 i.e. MFs having a strong track record. However, it was suggested that the Route 2 may be facilitated in a phased manner.
5.5.3. Consideration of issues
a) Considering that the proposed product is being placed under the MF framework, and in order to provide a level playing field between all MFs as well as between MFs and other asset managers, it would be prudent to allow existing as well as newly registered MFs to be eligible to launch this product. This approach would ensure that even PMS and AIFs, desirous of offering this product, would be eligible to do so by taking a MF registration and fulfilling criteria under the Alternate Route.
b) Additionally, considering the limited universe of experienced fund managers, there may be merit in the suggestion for reviewing of eligibility criteria for proposed alternate route. While the experience requirement for the CIO under the alternate route may be retained, it may be considered to reduce the experience criteria for the additional Fund Manager of an NP from 7 years to 3 years, and the AUM requirement from INR 3,000 crores to INR 500 crores. This shall ensure that the CIO has substantial experience and competence, while also allowing for the inclusion of additional talent with lesser experience and AUM, thereby broadening the pool of eligible entities beyond the traditional MF asset management.
c) Regarding the suggestion to mandate NISM certification, while fund managers in Mutual Funds are currently not required to obtain NISM certification, given the high-risk nature of NP, the fund managers of NP may be required to obtain the relevant NISM certification, as may be specified by the Board from time to time.
5.5.4. Proposal
a. In view of the above, it is proposed that the eligibility criteria as specified at para 5.5.1 may be accepted for the NP and specified by way of a circular, subject to following modification to para 5.5.1.b).i):
(This has been excised for the reasons of confidentiality.)
b. It is proposed that MF Regulations may be amended to insert the following enabling clause with respect to NISM certification:
(This has been excised. Amendment to SEBI (Mutual Funds) Regulations, 1996 shall be notified.)
5.6. Registration/approval requirements
5.6.1. Suggestion in the consultation paper
The consultation paper, inter alia, proposed that the registration process for new investment product may be a two-stage process, consisting of in-principle and final approval, similar to the registration process currently followed for Mutual Funds.
5.6.2. Public Comments
While majority of respondents agreed with the proposals regarding registration/approval requirements, it was recommended that instead of a separate two stage registration process for NP, a one-step prior approval process may be considered.
5.6.3. Consideration of issues
a. Considering that Mutual Fund registration would be a pre-requisite for launching of NP, following a process for grant of prior approval by SEBI to eligible Mutual Funds for launching NP, may suffice.
b. Once the prior approval is received by a Mutual Fund, it may be eligible to launch one or more eligible investment strategies, subject to approval from the trustees of Mutual Fund and issuance of final observations on the offer documents by the SEBI. The same shall be in line with the process followed for issuing observations on the Scheme Information Documents in case of Mutual Fund schemes. Further, as the NP strategies shall be riskier than conventional Mutual Fund schemes, it may be desirable to prescribe a list of permissible strategies, in consultation with the MF industry.
5.6.4. Proposal:
In view of the above, it is proposed that the MF Regulations may be suitably amended to insert the following:
(This has been excised. Amendment to SEBI (Mutual Funds) Regulations, 1996 shall be notified.)
5.7. Minimum investment threshold
5.7.1. Suggestion in the consultation paper
The consultation paper, inter alia, proposed that the minimum investment amount for investment under the NP shall be INR 10 lakh per investor across all investment strategies at the level of the new investment product within the AMC/MF.
5.7.2. Public Comments
a) While majority of respondents supported the proposal for a mandatory minimum investment threshold, emphasizing its importance as a safeguard to ensure that only investors with a higher risk appetite can access the product, some expressed concerns regarding the specific quantum for the threshold.
b) While some of the respondents suggested a lower investment threshold during the public consultation, few members of the MFAC recommended for a higher investment threshold.
c) It is also suggested that the minimum investment threshold should not apply to accredited investors, in view of their advanced financial acumen and capability to assess and manage higher risks.
5.7.3. Consideration of issues
a. Considering the high risk nature of the proposed NP, it may be desirable to have a reasonably high investment threshold for investors for such funds. The same shall deter retail investors from investing in this product, while attracting investors, with investible funds between INR 10 lakhs – INR 50 lakhs, who are presently being drawn to unauthorized and unregistered portfolio management service providers.
b. In line with the exemption from minimum investment limits granted to accredited investors in AIFs and PMS, it is appropriate to extend a similar exemption to accredited investors investing in NP.
5.7.4. Proposal
a. In view of the above, it is proposed that the MF Regulations may be suitably amended to insert the following:
(This has been excised. Amendment to SEBI (Mutual Funds) Regulations, 1996 shall be notified.)
b. It is further proposed that the manner of applicability of minimum investment threshold may be specified by way of a circular.
5.8. Permissible investments
5.8.1. Suggestions in the consultation paper
a. The consultation paper, inter alia, proposed that all investments permissible to Mutual Funds under the MF Regulations may also be available for the new investment product.
b. Additionally, it was proposed that new investment product may be allowed to take limited exposure (i.e. up to 50% of the AUM of NP strategy) in derivatives, for purposes other than hedging and portfolio rebalancing, subject to compliance with relevant provisions.
c. It was further proposed that provisions regarding gross exposure i.e. leverage and borrowings may be kept in line with the existing regulatory framework for Mutual Fund schemes.
5.8.2. Public comments
a. While the comments received are broadly in favour permitting NP to invest in all asset classes currently permissible under the existing MF Regulations, some have stated that NP may be allowed to have 100% exposure in derivatives, so as to not restrict the flexibility and innovative strategies that NP are intended to offer.
b. Some respondents also suggested permitting investments in commodity derivatives, unlisted and unrated debt and equity securities. Additionally, there were suggestions to allow NP to utilize leverage and borrowing for investment purposes.
5.8.3. Consideration of issues
a) Considering the objective is to introduce a new investment product with greater flexibility in terms of portfolio construction, there may be a merit in considering enhanced portfolio exposure to derivatives. However, allowing leverage and borrowing for NP may not align with the product’s intended risk profile and investor protection standards, as such practices are typically allowed only for AIFs targeting sophisticated and ultra-high-net-worth investors. Thus, while NP may be allowed to take exposure up to 100% of the AUM of any NP strategy in derivatives, for purposes other than hedging and portfolio rebalancing, undertaking borrowing (other than as permitted under the MF Regulations) and leverage may not be allowed to NP.
b. As regards permitting investment in commodity derivatives, as Mutual Funds are currently permitted to invest in this asset class with certain restrictions, considering the complexities associated with this asset class, the extant limits as applicable to Mutual Funds may be retained for NP.
c. Given the moderate ticket size and open-ended nature of the proposed product, it may not be prudent to permit investments in unlisted and unrated instruments, other than as permitted under the extant MF Regulations, so as to ensure adequate liquidity, sound risk management, and adherence to appropriate risk profiles.
5.8.4. Proposal
a. In view of the above, it is proposed that the MF Regulations may be suitably amended to insert the following:
(This has been excised. Amendment to SEBI (Mutual Funds) Regulations, 1996 shall be notified.)
b. It is further proposed that the following may be specified by way of a circular:
(This has been excised due to reasons of confidentiality.)
5.9. Relaxations from prudential norms
5.9.1. Suggestions in the consultation paper
The extant regulatory framework for Mutual Funds, imposes specific investment restrictions on Mutual Fund schemes. Accordingly, in the context of new investment product, the consultation paper, inter alia, proposed following relaxations to the investment restrictions:
i. An investment strategy shall not invest more than 20% of its NAV in debt instruments issued by a single issuer which are not rated below investment grade. Such investment limit may be extended to 25% with the prior approval trustees and board of AMC.
ii. No NP under all its schemes should own more than 15% of any company’s paid up capital carrying voting rights.
iii. No investment strategy of NP shall invest more than 15% of its NAV in the equity shares and equity related instruments of any company.
iv. No NP under all its investment strategies shall own more than 20% of units issued by a single issuer of REIT and InvIT; and
v. An investment strategy under NP shall not invest:
– More than 20% of its NAV in the units of REIT and InvITs; and
– More than 10% of its NAV in the units of REIT and InvIT issued by a single issuer.
vi. An investment strategy under NP shall not invest more than 20% of its NAV in debt and money market securities issued by a single issuer and rated AAA or 16% in securities rated AA or 12% in securities rated A and below. These instrument limits may be extended by up to 5% of the NAV of investment strategy with prior approval of trustees and board of AMC.
vii. An investment strategy under NP shall not invest more than 25% of its NAV in debt and money market securities of a particular sector.
5.9.2. Public comments
a. The majority of respondents agreed with the proposed relaxations of investment restrictions under the NP, recognizing the need for greater flexibility in portfolio construction. Some however, suggested further relaxing certain investment limits for NP, including investments in REITs and InvITs.
b. Certain AIFs raised concerns regarding relaxation of the single issuer concentration limit from 10% to 15% for equity investments, making NP riskier than Category III AIFs, which are presently permitted investments upto 10% of corpus in a single investee company.
5.9.3. Consideration of issues
a) The relaxations are proposed with the underlying objective of providing NP with greater flexibility in portfolio construction while maintaining adequate safeguards to manage risk. Therefore, the relaxations to the investment restrictions, as proposed in the consultation paper, may be accepted for NP.
b) As regards the proposed concentration limit, there may be merit in limiting the same to existing limit of 10%, as the intended investor base for NP is with a ticket size significantly lower than that mandated for AIFs.
c) A comparative analysis of the proposed relaxations for NP vis-à-vis existing limits for Mutual Fund schemes, is provided in Annexure A5.
5.9.4. Proposal
a) In view of the above, the MF regulations may be suitably amended to provide relaxations specified in para 5.9.1.i) to 5.9.1.v), subject to the following modification:
“No investment strategy of NP shall invest more than 10% of its NAV in the equity shares and equity related instruments of any company.”
b) It is also proposed that for passively managed investment strategies, the above concentration limit may be in line with the limits as currently applicable to passively managed Mutual Fund schemes.
c) It is further proposed that the investment relaxations specified in para 5.9.1.vi) and 5.9.1.vii) may be specified by way of a circular.
5.10. Miscellaneous
5.10.1. Suggestions in the consultation paper
a) The consultation paper, inter alia, also included proposals (details provided in Annexure A6). on separate depiction of risk indicator, monthly portfolio disclosures, public availability of constitutional documents, investments through systematic plans, staggered redemption frequencies of investment strategies, notice and settlement periods for redemption from NP and listing of units of investment strategies.
5.10.2. Public comments
No specific comments on the above proposals were received during the consultation process, except certain respondents suggested quarterly frequency for portfolio disclosures. Additionally, mandatory listing was suggested only for close-ended funds and investment strategies with more than quarterly interval frequency.
5.10.3. Consideration of issues and proposal
a) While there appears to be merit in considering further relaxation from monthly to quarterly frequency for portfolio disclosures, in the interest of transparency to the investors, portfolio disclosures at a periodic interval of every two months may be mandated for NP.
b) As regards listing of units, all interval and close ended strategies under the NP may be mandated to be listed on stock exchanges, for facilitating adequate liquidity to the investors.
c) In view of the above, the proposals mentioned in Annexure A6 may be accepted, subject to changes proposed at para 5.10.3.a) & 5.10.3.b) and the same may be specified by way of a circular.
6. Regulatory amendments to the MF Regulations
6.1. It is proposed that a new chapter may be incorporated into the SEBI (Mutual Funds) Regulations, 1996, outlining the regulatory framework for New Product. Accordingly, the SEBI (Mutual Funds) Regulations, 1996 may be amended by inserting Chapter VI-C on New Product.
7. Proposal for consideration and approval of the Board
7.1. The Board may consider and approve the proposals outlined in paragraphs 5.1.4, 5.2.2.b), 5.3.2, 5.4.4, 5.5.4, 5.6.4, 5.7.4, 5.8.4, 5.9.4, 5.10.3.c) and 6.1 above. Draft amendments to the SEBI (Mutual Funds) Regulations, 1996, and the draft notification for the proposed amendment are placed at Annexure B1 and Annexure B2 respectively.
7.2. It is proposed that the proposals at paragraphs 5.1.4, 5.2.2.b), 5.3.2, 5.4.4.a), 5.5.4.b), 5.6.4, 5.7.4, 5.8.4.a), 5.9.4.a) and 6.1 may be incorporated in the SEBI (Mutual Funds) Regulations, 1996 and proposals at paragraphs 5.4.4.b), 5.5.4.a), 5.8.4.b), 5.9.4.b), 5.9.4.c) and 5.10.3.c) may be specified by way of a circular.
7.3. A reasonable time, in consultation with AMFI, may be provided for implementation to facilitate stakeholders to have required systems in place.
7.4. The Board may authorize the Chairperson to carry out suitable amendments to the regulations and to take any other consequential or incidental steps for implementation of the decisions of the Board.
Annexure A1
This has been excised for reasons of confidentiality.
Annexure A2
This has been excised for reasons of confidentiality.
Annexure A3
This has been excised for reasons of confidentiality.
Annexure A4
This has been excised for reasons of confidentiality.
Annexure A5
This has been excised for reasons of confidentiality.
Annexure A6
This has been excised for reasons of confidentiality.
Annexure B1
This has been excised for reasons of confidentiality.
Annexure B2
This has been excised for reasons of confidentiality.
