Do you agree with the proposal of specifically permitting portfolio managers to invest in "to be listed securities"?
Do you agree with the proposal of permitting a portfolio manager to invest up to 10% of its client's AUM in investment grade unlisted debt securities under DPMS?
Do you agree with the proposal of permitting a portfolio manager to invest in foreign securities?
If yes to consultation 4, do you agree with the list of permitted instruments mentioned at para 2.3.1?
Do you agree with the proposal of allowing a MF only PMS (MF-PMS)?
If yes to consultation 5, whether the relaxation proposed for minimum ticket size, reduced net worth, relaxation in qualification, experience and certification of the Principal Officer, additional employee, dealing room requirements, waiver from exit load appropriate?
Whether charging of management fees with a cap of 2.5% of client's AUM, segregation of activities and client-level segregation appropriate?
Should the MF-PMS be allowed to charge performance based fees considering that it is providing service of only scheme selection and individual stock picking will be done by the mutual fund-fund manager?
Should there be any other safeguards or conditions specified for the MF-PMS framework? Mention the conditions or safeguards along with rationale.
Do you agree with quantum of total exposure to be permitted with the use of exchange traded derivatives? If no, provide rationale.
Do you agree with the manner of calculation of exposure as detailed in Annexure C? If no, provide an alternative with rationale.
Do you agree with the limit on unhedged short positions and limit on options? If no, provide rationale.
Should there be any other limits or suggestion on the usage of exchange traded derivatives contracts by the portfolio managers?
Do you agree with the aforesaid ease of compliance measures? If no, provide rationale.
Are there any other suggestions for consolidation and simplification of portfolio managers Regulations. If yes, please mention along with rationale.
Whether there are any existing provisions that should have been retained but appear to have been omitted in the proposed draft Portfolio Managers Regulation?
Whether there are any provisions that may require further clarification, consolidation or cross-referencing?
Whether there are any other suggestions on the proposed draft Portfolio Managers Regulations?
Do you agree with proposal of modification of grandfathering clauses mentioned at para 5.6 and para 5.7 above?
Do you agree with the proposal to relax the requirement of dealing room for portfolio managers having less than 10 clients or AUM below INR 100 crores? If yes, what safeguards should be implemented?
Should the requirement of dealing room be also relaxed for portfolio managers placing and generating orders through automated execution logic (Algos)?
If portfolio managers are now allowed to invest in foreign securities on behalf of their clients who are resident in India, should Eligible Fund Managers under the Regulations be also permitted to manage and advice their overseas clients in overseas securities?
If yes to consultation 22, should there be a requirement of having the execution platform (dealing room) located within India? What other conditions should be put in place on Eligible Fund Managers, provide with rationale.
Do you agree with the model of independent fund managers operating under a registered Portfolio Manager? If yes, what safeguards should be implemented?
Whether demat account portability for clients of portfolio managers as envisaged be permitted? If yes, what procedures should be implemented to facilitate the same?
Do you agree with the operational relaxation from obtaining POA? If yes, provide rationale and adequate safeguards which should be implemented to ensure investor protection.
Whether you agree that online Conciliation and arbitration platform, including the empanelment of Conciliators and arbitrators, operated by MIIs, will enhance efficiency and enforceability?
Whether you agree that proposed process of appointment of arbitrators be done by MIIs after taking into consideration of preference of names taken from both parties?
Whether you agree that AIF Investors should have choice to opt for other dispute resolution mechanism than the ODR platform?
Whether you agree that unresolved investor grievances, after review by the Designated Bodies in SCORES, be allowed to directly escalated to the Conciliation stage in ODR mechanism?
Whether you agree that the protection available to investors of AIF, if it is constituted as a Trust, be extended to investors of all AIF, irrespective of its mode of incorporation, be it Company/LLP?
Please mention relevant Para/s of the Consultation Paper while submitting the comments.
Do you agree that Manager may be permitted to determine and record the accredited status of an investor?
Do you agree with the proposed validity for Manager led accreditation?
a) For onboarding in investment products launched by different managers: The accreditation is proposed to be undertaken each time an investor is onboarded by a manager.
b) For onboarding in investment products launched by the same manager: The accreditation status may be given a validity period of 3 years from the date of eligibility assessment.
Do you agree that the manager led accreditation may be accompanied with certain safeguards such as mandating a laid down policy for accreditation (at manager level), maintenance of records, independent oversight, and an accountability framework?
Do you agree that the accreditation agency route may continue alongside the proposed manager led accreditation route?
Do you agree that the validity norms of accreditation granted through the Accreditation Agency route may also be aligned with the validity norms prescribed for manger-led accreditation for own schemes?
Do you agree that �securities market asset� is an appropriate eligibility criteria for assessing sophistication of an investor? Do you agree with the proposed thresholds of INR 5 crore for individual investors and INR 20 crore for body corporates?
Do you agree that Deemed Accredited Investor criteria may be extended to all Person Resident Ouside India (PROI), including all FPIs, as per FEMA,1999 definition?
Do you agree that a �look through� may be brought in for Limited Liability Partnerships (LLPs), where if each partner individually an accredited investor, the LLP is granted the accreditation status? If yes, what safeguards be incorporated for such inclusion?
Do you agree that a wholly owned subsidiary of a company may be recognized as accredited, if the parent company holds the prescribed net-worth? If yes, what safeguards be incorporated for such inclusion?
Do you agree with the draft of regulatory amendments to be carried out placed at Annexure D of the consultation paper?
Proposals related to allowing additional ISINs to mature in a financial year.
Proposal related to amending the requirement to list all outstanding unlisted debt securities by a listed entity, in terms of Regulation 62A of LODR Regulations
Question 1: Whether the proposed amendments to the extant SEBI (Vault Managers) Regulations, 2021, as mentioned at para 15.1 of this consultation paper, are adequate for facilitating the expansion of scope of VM Regulations for coverage of all bullion underlying ETFs, derivatives on bullion, and any other SEBI-specified bullion-related instruments, that is stored in SEBI-registered vaults?
Question 2: In light of the proposals mentioned at para 15.2 of this consultation paper, public comments, if any, on the Chapters 2, 3 and 4 of the draft Circular.
FPI Participation in Non-Agricultural Index Derivatives Contracts
FPI Participation in Non-Cash Settled Non-Agricultural Commodity Derivatives Contracts
FPI Participation in Non-Cash Settled Non-Agricultural Commodity Derivatives Contracts
Draft Circular in Annexure-A of the Consultation Paper
Review of shortfall of pay-in of funds: Linking of action in case of pay-in shortfall to a standardized amount, other than BMC(Base Minimum Capital)
Replace of references to Stock Exchanges with Clearing Corporations on provisions related to Settlement, Margins, and Risk management
Discontinuation of T+5 reporting by TM/CMs to Clearing Corporations
Segregation of responsibility and standardization on the verification of availability of margins with TM and SCM/TMCM/PCM
Rationalization of Report on the penalties as collected by the Clearing Corporations
Discontinuation of the requirement of submission of quarterly Net-worth certificate by Managing Director of Clearing Corporation(CC) to SEBI
Discontinuation of the requirement of submission of report on PFMIs to SEBI.
Discontinuation of requirement of submission of report on Periodic Risk evaluation to SEBI and delegated to Regulatory Oversight Committee of Clearing Corporation.
Delegation of formulation of SOP(Standard Operating Procedure) to Clearing Corporations on operational activities related to settlement in case of Unscheduled Holidays.
Removal of obsolete provisions pertaining to Base Minimum Capital for stock exchanges having average daily turnover of less than Rs. 1 crore and Refund of excess BMC over Rs. 1 lakh
Risk Management framework for dedicated debt segment on stock exchanges
Removal of references related to T+2 and T+2 settlement schedule in cash segment.
Removal of overlapping duplicate provisions on T+1 settlement
Removal of obsolete provisions pertaining to T+2 rolling settlement cycle
Removal of references related to direct pay out of securities by brokers
Removal of references related to direct pay -out of securities by brokers
Removal of references related to direct pay-out of securities by brokers
Obsolete provision on no-delivery period to be removed
Clarification and rewording of provision on Systems for effecting settlement on T+1 basis
Discontinuation of the requirement of submission of comprehensive review report on delivery centers to PAC(Product Advisory Committee) by stock exchanges. Further this provision shall be moved to Stock Exchange circular.
Disclosures on websites which are generic in nature to be extended to all segments and shall be disclosed on the respective websites of the CC.
Discontinuation of submission of periodic DP (Depository Participant) related reports/filings to depositories by Clearing Corporations.
Demerger of requirements already covered in Master Circular for Stock Brokers
Removal of duplicate requirements which are already covered in separate chapter of Master Circular for Stock Exchanges and Clearing Corporations
Provisions pertaining to Stock Exchanges as per S.no 2.25 of the consultation paper to be moved to proposed Master Circular for Stock Exchanges and will not be covered in proposed Master Circular for Clearing Corporations
Provisions pertaining to Clearing Corporations present in the current Master Circular for Commodity Derivatives (MCCD) as well as MSECC (Master Circular for Stock Exchanges and Clearing Corporations) are being merged into the proposed Master Circular for Clearing Corporations.
Inclusion of new circulars/communications pertaining to Clearing Corporations in the proposed Master Circular for Clearing Corporations up to the cutoff date June 30, 2026
Whether provisions covered under Master Circular for Stock Exchanges and Clearing Corporations dated December 30, 2024 and the Master Circular for Commodity Derivatives dated August 04, 2023 be merged?
Whether provisions related to Stock exchanges and Clearing Corporations covered in Master Circulars dated December 30, 2024 and August 04, 2023 be separated?
Wherever the above two is proposed, (3.1.1, 3.1.2 ) whether any risks or issues are envisaged? Safeguards to protect against possible risks?
Whether there is any discrepancy w.r.t merged provisions being made applicable to a segment/MII, they are not intended to?
Whether provisions from MCCD pertaining to Risk management and settlement are adequately covered in merged provisions in Circular for Clearing Corporation?
Whether any other circular/communication needs to be incorporated in the Master Circular for Clearing Corporation?
Specific comments on the detailed provisions in this consultation paper.
Permitting issuance of Depository Receipts for REITs and Publicly Listed InvITs
Draft Framework for issuance of Depository Receipts on units of REITs and Publicly Listed InvITs, attached at Annexure - A
Do you agree with the proposal for the mandatory adoption of a Credit Risk-o-Meter as an additional disclosure mechanism for debt securities? Please provide your comments/views on the draft circular mentioning the relevant paragraph and the supporting rationale for the same.
Amendment in the Regulation 18(5)(a) of the REIT Regulations and Regulation 18(5)(b)(i) of InvIT Regulations to facilitate minority investment in under construction infrastructure projects/real estate projects
Conditions proposed to be specified for such investments as mentioned in Consultation No. 1(a)
Amendment in the basis of threshold for unitholder approval to ‘total votes cast for the resolution’ instead of ‘value’ for the aforesaid matters.
Amend the definition of “dissenting unitholders” to include only those unitholders who have voted against the proposed resolution.
Amend Regulation 22(7)(b) of the InvIT Regulations/Regulation 22(8)(b) of the REIT Regulations and the definition of ‘Acquirer’ in the InvIT/REIT master circular to provide clarification on who would be offering exit option in case of exit of one sponsor in an InvIT/REIT with multiple sponsors
Amend Chapter 11 of the InvIT Master Circular/Chapter 13 of the REIT master Circular to specify time period of one year for re-achieving MPU compliance in cases when such MPU norms are breached due to exit offer provided to dissenting unitholders
Amend Master Circular of REITs/InvITs to specify timelines for activities pertaining to exit offer as mentioned in Annexure I and Annexure II
Amending Regulation 2(1)(zi) to classify remote common infrastructure as "real estate"
Omitting Regulation 18(5)(k), as the direct classification of common infrastructure under real estate renders separate equity investment pathways redundant.
Whether cooling-off period for illiquid, privately placed InvITs may be reduced from 12 weeks to 8 weeks?