Should Mutual Funds be allowed to invest the residual portion of their equity category schemes in a diversified mix of asset classes such as debt (including money market instruments), gold, silver (as permitted by SEBI), REITs, and InvITs-subject to regulatory limits for each asset class?
Should Mutual Funds be allowed to offer both Value and Contra funds, provided that the portfolio overlap between the two does not exceed 50%?
Is maximum overlap of 50% amongst schemes within the sectoral/thematic and equity categories (excluding large cap schemes), sufficient in order to ensure scheme differentiation? If not, please indicate the suitable % of maximum overlap permissible along with suitable rationale.
Should the overlap condition be monitored at the time of NFO deployment and subsequently on a semi-annual basis using month-end portfolios?
Should the name of the debt category scheme be changed from "Duration" to "Term" to provide better nomenclature that enhances investor clarity?
Should the nomenclature of the "Low Duration Fund" be changed to " Ultra Short to Short Term Fund " to better reflect the investment objective and improving investor clarity?
Should mutual funds be allowed to launch sectoral debt fund subject to ensuring that no more than 60% of the portfolio in a sectoral debt scheme overlaps with any other sectoral debt scheme/debt category scheme, while also ensuring sufficient availability of investment-grade paper in the chosen sectors, and exempting such schemes from the sectoral exposure limits under Clause 12.9.1 of the Master Circular?
Should Mutual Funds be allowed to invest the residual portion of their debt category schemes in REITs and InvITs except for the schemes with shorter duration (e.g. Overnight Fund, Liquid Fund, Ultra-Short Duration Fund, Low Duration Fund, and Money Market Fund) subject to regulatory limits for this asset class?
Should the name of the debt category scheme include duration of the fund such as Overnight Fund (1 Day) or Medium Term Fund (3 to 4 years)?
Should Arbitrage Fund category scheme be allowed to take exposure in debt instruments only in government securities with a maturity of less than one year and in repos backed by government bonds?
Should the net equity exposure and arbitrage exposure be mandated between 15%-40% in the equity saving scheme category?
Should Mutual Funds be allowed to invest the residual portion of their hybrid category schemes in REITs and InvITs except for Dynamic Asset Allocation and Arbitrage Fund subject to regulatory limits for this asset class?
Should Mutual Funds be allowed to offer different type of schemes in the solution oriented category offering a different mix of equity and debt portion? Is the asset allocation stated above appropriate for the solution oriented category schemes?
Should Mutual Funds be allowed to invest the residual portion of their solution category schemes in REITs and InvITs except for the Retirement Fund - Hybrid and Children's Fund - Hybrid, subject to regulatory limits for this asset class?
Should Mutual Funds be allowed to offer solutions oriented life cycle fund of funds with a target date in the structure as stated in the draft circular?
Should Mutual Funds be allowed to offer solution oriented life cycle fund of funds, with a lock in, for other specific goals such as housing, marriage etc? If yes, provide specific goals with rationale.
Should Mutual Funds be allowed to offer solutions oriented life cycle fund of funds with different lock in period such as 3 years, 5 years or 10 years? If yes, provide lock in period with rationale.
Should Mutual Funds be allowed to offer additional scheme in the existing scheme category such to conditions as specified in the clause 2.6.6 of the draft circular?
Should the term 'fund' in the scheme name be changed to 'scheme' for e.g. Large Cap Scheme instead of Large Cap Fund?
Any other suggestion may be provided with appropriate rationale.
The spot price published by a SEBI regulated Indian commodity exchange can be used for the valuation of gold and silver, in which the MF schemes invest. Please provide your comments with sufficient rationale.
Please provide your comments with sufficient rationale regarding what should be the domestic benchmark that may be used for valuation of gold and silver, instead of LBMA pricing
Whether the principles of polling for the spot price calculation at paragraph D (2) of the consultation paper is adequate or any additional regulatory requirement is needed to ensure transparency in the process of arriving the spot price. Please provide your comments with sufficient rationale.
Do you agree with the proposal to permit CRAs to undertake rating of financial instruments which fall under the purview of other Financial Sector Regulators (FSR), where no rating related guidelines may have been issued by the relevant FSR?
If yes, whether the proposed conditions (specified at Para 2.3.1 to 2.3.12 of the Consultation Paper) are appropriate and adequate?
Whether the proposal regarding relaxation of broad-based criteria for AMCs is appropriate?
If pooled non-broad based funds are allowed to be managed by AMCs, whether there are any additional conflicts of interest that need to be considered apart from those mentioned at para 3.1.5?
Whether the proposals regarding safeguards required to be imposed at paras 3.1.6 and 3.1.7 are appropriate? Whether there are any additional safeguards to be imposed to address each of the conflicts mentioned at para 3.1.5?
As regards the conflicts relating to fee differential and diversion of resources, which of the two approaches mentioned at para 3.1.6.1 (b) (i) would be more effective?
Whether there are any perceived risks associated with sharing of Compliance Officer, top management functions like CEO, CFO etc. when the AMC undertakes management and advisory services for both broad based and pooled non-broad based funds?
Any additional suggestion may be provided with appropriate rationale.
Whether the proposals at para 3.2.6 are appropriate?
Whether any additional safeguards are required to be put in place to enhance the effectiveness of the proposals at para 3.2.6?
Whether there are any perceived risks associated with sharing of research personnel and resources (subscriptions, research reports etc.) between Mutual Funds operations and PMS unit?
Whether the compliance officer should be allowed to be common in MF and PMS function?
Any additional suggestion may be provided with appropriate rationale.
Whether the proposals at para 3.3.4 to 3.3.9 are appropriate?
Whether there are any additional safeguards that need to be imposed to ensure that such ancillary activities do not create conflict of interest with the core fund management responsibilities of the AMC?
Whether any additional compliance/ disclosure measures should be considered for the subsidiary when acting as POP/ distributing funds managed and advised by AMC other than mutual fund schemes, to ensure transparency and accountability in the operations of such subsidiaries?
Any additional suggestion may be provided with appropriate rationale
Whether the proposals at para 3.4.5 and 3.4.6 are appropriate?
Whether there are any specific types of entities or investment strategies (within the FDI/ FVCI framework) that should be explicitly excluded or subject to enhanced scrutiny under this proposal?
Whether there are any additional safeguards or disclosure requirements to be imposed on the AMC when advising on investments in unlisted securities?
Any additional suggestions may be provided with appropriate rationale.
Are the proposed provisions in the Draft Circular appropriate and adequate to operationalize the mechanism of SSE-EBP?
The provisions in para 2.1 of the draft circular are appropriate.
The provisions in para 2.2 of the draft circular are appropriate.
Revised Capacity Planning and Real Time Performance Monitoring framework of MIIs with Commodity Derivative Segment