Comments on the process for Opening of Mutual Fund Folios and Execution of First Investment as stated in the draft circular
Whether it would be appropriate for issuers to offer higher coupon rate or discount to the issue price to certain categories of investor, but limited to the initial allottee only? If yes, which categories of investors may be permitted for the same?
Whether modifications in Regulation 61A(3) of the LODR Regulations, as suggested at paragraph 2.4.2. of the consultation paper is appropriate and adequate?
Whether there are any suggestions on the proposed draft MF Regulations?
Whether there are any provisions that may require further clarification, consolidation, or cross-referencing?
Whether there are any existing provisions that should have been retained but appear to have been omitted in the proposed draft MF Regulations?
Whether there are any suggestion on the current three tier structure of the mutual funds i.e. the requirement of a Sponsor, Trustee and AMC?
Whether there is a need to review the provisions relating to disassociation of sponsor from AMC?
Whether there are any specific suggestions on the existing provisions relating to MF Lite?
Whether there are any specific suggestions on the existing provisions relating to governance standards prescribed for Trustees and Board of AMCs?
Whether any system or process changes be required by AMCs, custodians, or registrars to implement the proposed reporting framework effectively?
Whether there are any suggestions on the revised provision relating to Other permissible business activities of the asset management company?
Whether the guard rails for enabling relaxation of business activity of the asset management company to provide management and advisory to non-board based funds, as specified in the consultation paper dated July 07, 2025, are appropriate? Alternatively whether trustee oversight may be enhanced to address conflict of interest identified in the said consultation paper?
Whether the provisions on eligibility of sponsor under both Route 1 and Route 2 needs to be reviewed?
Whether there are any suggestions on specifying minimum experience requirement for Chief Executive Officer, Chief Operating Officer, Risk Officer, Chief Compliance Officer and Chief Investment Officer?
Whether the requirement of minimum experience for Chief Executive Officer, Chief Operating Officer, Risk Officer, Chief Compliance Officer and Chief Investment Officer be made applicable for Route 1, 2 and MF Lite?
Whether the current structure of registration of Mutual Fund is appropriate or whether an alternate structure of registration of AMC be introduced?
Whether a concept of umbrella license for investment management for AMC be introduced?
Any other comments or suggestions?
Whether the proposal to increase the threshold for identification for HVDLEs from INR 1000 crores to INR 5000 crores is appropriate and adequate?
Whether the proposal to substitute the term 'income' with the term 'turnover' in Regulation 62L(1) in order to align with similar amendment made for equity listed entities is appropriate and adequate?
Whether the proposal to get approval of shareholders for continuation of directorship of Non-executive director beyond the age of seventy- five years to ensure alignment with similar amendment made for equity listed entities is appropriate and adequate?
Whether the proposal to exclude time taken for regulatory, statutory or government approvals from the timeline specified for obtaining shareholder approval for appointment or reappointment of director of a listed entity to align with similar amendment made for equity listed entities is appropriate and adequate?
Whether the proposal to exempt HVDLEs from obtaining shareholder approval for nominee directors of financial sector regulators or those appointed by Court or Tribunal to align with similar amendment made for equity listed entities is appropriate and adequate?
Whether the proposal to provide a timeline of 3 months to fill up vacancies in Board Committees i.e. Audit Committee, Nomination and Remuneration Committee, Stakeholders Relationship Committee and Risk Management Committee to align with similar amendment made for equity listed entities is appropriate and adequate?
Whether the proposal on recommendations of the Board to the shareholders to specifically include the rationale on each item of special business, to align with similar amendment made for equity listed entities is appropriate and adequate?
Whether the proposal to substitute the term 'year' with the term 'financial year' in regulations 62D(6)(Board of Directors), 62D(11)(d)(Board of Directors), 62F(2) (Audit committee), 62G(6) (Nomination and remuneration committee), 62H(5) (Stakeholders Relationship Committee) and 62I(4) (Risk Management committee) to align with similar amendment made for equity listed entities is appropriate and adequate?
Whether the proposal of omitting the requirement that an independent director who resigns or is removed from the board of directors of the HVDLE shall be replaced by a new independent director by the HVDLE not later than three months from the date of such vacancy provided that where the HVDLE fulfils the requirement of independent directors in its board of directors without filling the vacancy created by such resignation or removal, the requirement of replacement by a new independent director shall not apply, to align with similar amendment made for equity listed entities, is appropriate and adequate?
Whether the proposal of exemption from the requirement of approval of shareholders for sale, disposal and leasing of assets, as long as such sale, disposal or lease of assets is between two wholly-owned subsidiaries of the HVDLE, to align with similar exemption made for equity listed entities is appropriate and adequate?
Whether the proposal of providing timeline of 3 months from approval of the Resolution plan for filling up the vacancy of KMPs subject to having at least one full-time KMP for HVDLEs for which a resolution plan under Insolvency code has been approved, to align with similar amendment made for equity listed entities is appropriate and adequate?
Whether the proposal to replace the timelines of 21 days to HVDLEs to submit the periodic compliance report with enabling provision for Board to prescribe timeline from time to time, to align with similar amendment made for equity listed entities is appropriate and adequate?
Whether the proposal to omit the requirement of disclosure of material transactions with related parties along with the periodic compliance report of HVDLE, since the same already exists in Regulation 23(9) of LODR, and to align with similar amendment made for equity listed entities in the interest of ease of doing business is appropriate and adequate?
Whether the proposal of introducing provisions relating to appointment, reappointment, removal and disqualifications for Secretarial Auditor of HVDLE in line with the amendments made for equity listed entities is appropriate and adequate?
Whether the proposal of harmonising the provisions related to RPTs, by cross referencing of provisions of Regulation 23 in Regulation 62K of LODR while retaining the requirements of NOC of Debenture trustee and the debenture holders is appropriate and adequate?
Whether to review/ expand the definition of 'Associated Persons (para 3.1.1)
Whether to include long term courses / long duration programs of NISM as manner of obtaining NISM certification and CPE (para 3.2.1 and 3.4.1(e))
Whether to include electronic mode of delivery of participation for CPE programs (para 3.3.1)
Whether to replace the individual exemptions provided by criteria of 'Principal', 'Age' and 'Experience' in Regulation 4 (2) and 4 (3) for obtaining Certification with a new exemptions based on combined criteria of 'Age' and 'Experience' for obtaining Certification (para 3.4.1)
Whether the date of calculating the 'Age' and 'Experience' for a candidate can be linked to the date of examination or CPE (para 3.4.1(b))
Drawdown Methodology - Commitment may be construed as �commitment� or �undrawn commitment� for drawing down capital from investors for investment (Para 4.1, 4.2 and 4.3 of the draft circular)
Conditions and disclosures with respect to adopting a drawdown methodology (Para 4.4, 4.5 and 4.6 of the draft circular)
Applicability of drawdown methodology on existing AIF schemes (para 4.7, 4.8 and 4.9 of the draft circular)
Drawdown and distribution in open ended schemes of Category III AIFs (Para 5.1, 5.2 and 5.3 of the draft circular)
Applicability with respect to distribution of existing investments made by AIFs (Para 6.1 and 6.2 of the draft circular)
Proposal related to carried interest and other clarity (Para 7.1, 7.2 and 8 of the draft circular)
Whether you agree with the proposal to amend the ICDR Regulations to include the following proviso to enable the pledged shares to be treated as locked-in for the purpose of compliance of Regulation 17 of ICDR.
"Provided further that, in cases where lock-in of the specified securities cannot be created, the depositories, upon receipt of instructions from the issuer, shall record such securities as ‘non-transferable’ for the duration of the applicable lock-in period."
Whether you agree with the proposal to amend ICDR Regulations to make Offer Document Summary available separately from the draft offer document and offer document and hosted on the website of the issuer, the Board, stock exchanges where specified securities are proposed to be listed and lead manager(s) associated with the issue.
Whether you agree with the proposal to amend the ICDR Regulations to rationalize the disclosures made in the Offer Document Summary.
With the availability of the Offer Document Summary, whether you agree with the proposal to amend the ICDR Regulations to dispense with the requirement of abridged prospectus.