CIRCULAR
SEBI/HO/AFD/RAC/CIR/2022/088 June 24, 2022
To,
All Alternative Investment Funds (AIFs)
Sir/ Madam,
Sub: Guidelines for Large Value Fund for Accredited Investors under SEBI
(Alternative Investment Funds) Regulations, 2012 and Requirement of
Compliance Officer for Managers of all AIFs
A. Guidelines for Large Value Fund for Accredited Investors
1. Pursuant to introduction of framework for “Accredited Investors” in the
securities market, SEBI (Alternative Investment Funds) Regulations, 2012
(hereafter referred as ‘AIF Regulations’) have been amended to provide
certain relaxations from regulatory requirements to ‘Large Value Fund for
Accredited Investors’ (LVF).
Filing of LVF Schemes with SEBI
2. In terms of proviso to Regulation 12 of AIF Regulations, LVFs are exempt from
filing their placement memorandum with SEBI through Merchant Banker and
incorporate comments of SEBI, if any, in their placement memorandum i.e.
LVFs can launch their scheme under intimation to SEBI.
3. While filing the placement memorandum for LVF schemes with SEBI, a duly
signed and stamped undertaking by CEO of the Manager to the AIF (or person
holding equivalent role or position depending on the legal structure of
Manager) and Compliance Officer of Manager to the AIF shall be submitted in
the format as mentioned at Annexure A.
4. In case of LVF schemes already filed with SEBI, similar duly signed and
stamped undertaking by CEO of the Manager to the AIF (or person holding
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equivalent role or position depending on the legal structure of Manager) and
Compliance Officer of Manager to the AIF shall be submitted to SEBI on or
before July 31, 2022.
Extension of tenure beyond two years
5. Regulation 13(4) of AIF Regulations permits close ended AIFs to extend its
tenure up to two years with the approval of two-third of its unit holders by value
of their investment in the said AIF, while the proviso to Regulation 13 (4) of AIF
Regulations permits LVF to extend its tenure beyond two years, subject to
terms of the contribution agreement, other fund documents and such
conditions as may be specified by the Board from time to time. In this regard,
it is specified as under:
i. In order to enable the investors to take an informed decision, the
placement memorandum, contribution agreement or other fund documents
of LVF shall lay down terms and conditions for extension of the tenure
beyond two years.
ii. LVF shall be required to obtain approval from its Trustee/Board of
Directors/Designated Partners (depending upon the legal structure of the
LVF) for extending the tenure beyond two years, at least one month before
expiration of the fund tenure or extended tenure.
iii. In case requisite conditions specified in the placement memorandum,
contribution agreement or other fund documents of LVF for extension of
tenure beyond two years are not fulfilled, LVF shall liquidate and wind up
in accordance with AIF Regulations and Circulars issued thereunder.
B. Requirement of Compliance Officer for Managers of all AIFs.
6. All AIFs shall ensure that Manager to AIF designates an employee or director
as Compliance Officer who shall be a person other than CEO of the Manager
(or such equivalent role or position depending on the legal structure of
Manager). The compliance officer shall be responsible for monitoring
compliance with the provisions of the SEBI Act, AIF Regulations and circulars
issued thereunder.
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7. This Circular is issued in exercise of powers conferred under Section 11(1) of
the Securities and Exchange Board of India Act, 1992, to protect the interest of
investors in securities and to promote the development of, and to regulate the
securities market.
8. This Circular is available on SEBI website at www.sebi.gov.in under the
categories “Legal Framework - Circulars” and "Info for - Alternative Investment
Funds”.
Yours faithfully,
Deepti Agrawal
General Manager
Tel no.: +91-22-26449616
Email: deeptiv@sebi.gov.in
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ANNEXURE - A
FORMAT FOR UNDERTAKING TO BE SUBMITTED BY CEO (OR EQUIVALENT ROLE OR
POSITION DEPENDING ON THE LEGAL STRUCTURE) OF THE MANAGER TO AIF AND
COMPLIANCE OFFICER OF MANAGER TO AIF
To,
Securities and Exchange Board of India
Dear Sir / Madam,
Sub: Filing of draft placement memorandum of (name of LVF scheme), scheme of (name
of AIF/proposed AIF)
Based on the placement memorandum and supporting documents submitted by
AIF/proposed AIF, we undertake that:
1. We have independently exercised due-diligence regarding information given in the
placement memorandum, including the veracity and adequacy of disclosure made
therein.
2. The AIF, its sponsor and manager are fit and proper persons based on the criteria
specified in Schedule II of the Securities and Exchange Board of India (Intermediaries)
Regulations, 2008. None of the intermediaries named in the placement
memorandum have been debarred from functioning by any regulatory authority.
3. All the material disclosures in respect of the fund raising, investment by the scheme
and management thereof have been made in the placement memorandum and are
based on latest available information.
4. We have satisfied ourselves that the proposed activities of the scheme are bonafide,
fall within the objectives of the fund as specified in the Articles of Association or Trust
Deed or Partnership Deed of the AIF and are to meet the stated investment objective.
5. The disclosures made in the placement memorandum are true fair and necessary to
enable the investors to make an informed decision with respect to the investment in
the proposed scheme and such disclosures are in accordance with the requirements
of SEBI (Alternative Investment Funds) Regulations, 2012, circulars, guidelines issued
thereunder and other applicable legal requirements.
6. We have satisfied ourselves about the capability of the sponsor or manager to fulfil
the requirement of maintaining continuing interest in the scheme as per SEBI
(Alternative Investment Funds) Regulations, 2012.
7. We shall obtain copy of the Accreditation Certificate and an undertaking from the
prospective investor to the effect that:
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a) The prospective investor wishes to avail benefits under the AI framework.
b) The prospective investor has the ability to bear the financial risks associated with
the investment.
c) The prospective investor has the necessary knowledge and means to understand
the features of the Investment Product, including the risks associated with the
investment.
d) The prospective investor is aware that the investment product is meant for AIs
and would not be subject to the same regulatory oversight as over investment
products meant for investors other than AI.
Place:
Date:
Signature: (to be signed by CEO (or equivalent role or position depending on the legal
structure) of the Manager to AIF and Compliance Officer of Manager to AIF)
Enclosed:
1. Annexure I -Details of disclosures in the placement memorandum with respect to
compliance with provisions of SEBI (Alternative Investment Funds) Regulations,
2012, applicable to the proposed LVF scheme.
2. Annexure II -Information with respect to disclosures in the placement
memorandum.
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ANNEXURE I
Details of disclosures in the placement memorandum with respect to compliance with provisions of
SEBI (Alternative Investment Funds) Regulations, 2012, as applicable, to the proposed LVF Scheme
Wherever applicable,
mention Section/
subsection along with
page number of the
S. placement memorandum
Regulation Contents of the Regulation
No. where the Regulation has
been complied with
Otherwise mention ‘not
applicable’ or ‘noted for
compliance’
1 Chapter II – Registration of Alternative Investment Funds
3 Registration of Alternative Investment Funds
3(1) New Fund registration
3(4)(a) Category I AIF
3(4)(b) Category II AIF
3(4)(c) Category III AIF
4 Eligibility Criteria
4(a) - Legal structure – Company;
- Trust;
- LLP
4(b) Whether prohibited from making an invitation to public
4(c) Whether Trust Deed is Registered
4(d) Whether partnership in case of Limited Liability
Partnership is duly incorporated and the deed is filed with
Registrar
4(e) Whether Body Corporate is set up or established under the
laws of the Central or State Legislature and is permitted to
carry activities on AIF
4(f) AIF, Sponsor, Manager (Fit & Proper person)
4(g) (i) Key Investment team of Manager of AIF – adequate
experience
(ii) Professional qualification
4(h) Necessary Infrastructure & Manpower
4(i) - Investment objective
- Targeted investors
- Proposed corpus
- Investment style or strategy
- Tenure of the fund or scheme
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Wherever applicable,
mention Section/
subsection along with
page number of the
S. placement memorandum
Regulation Contents of the Regulation
No. where the Regulation has
been complied with
Otherwise mention ‘not
applicable’ or ‘noted for
compliance’
4(j) Refusal of registration by the Board, if any
7 Conditions of Certificate
8(3) Implication when registration is refused
2 Chapter III – Investment Conditions And Restrictions
9(1) Investment Strategy
9(2) Any material alteration to fund strategy
10 Investment in Alternative Investment Fund
10(a) Raise funds by way of issue of units
10(b) Minimum corpus
10(c) Minimum investment
Minimum investment of 1 crore to not apply to an
accredited investor
10(d) Continuing Interest
10(e) Disclosure of investment made by Manager or Sponsor
10(f) Maximum Investors
10(g) To solicit or collect funds only by way of Private placement
11 Placement Memorandum
11(1) - Placement Memorandum / Information Memorandum
11(2) - Information about
a) AIF
b) Manager
c) Background of key investment team of Manager
d) Targeted investors
e) Fees & all other expenses proposed to be charged
f) Tenure of AIF/Scheme
g) Condition/Limits on redemption
h) Investment strategy
i) Risk management tool & parameters employed
j) Key service providers
k) Conflict of interest & procedure to identify and address
them
l) Disciplinary history
m) Terms & conditions on which manager offers
investment service
n) Affiliation of Manager with other intermediaries
o) Manner of winding up of AIF/Scheme
p) terms of reference of the committee constituted for
approving the decisions of the Alternative Investment
Fund
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Wherever applicable,
mention Section/
subsection along with
page number of the
S. placement memorandum
Regulation Contents of the Regulation
No. where the Regulation has
been complied with
Otherwise mention ‘not
applicable’ or ‘noted for
compliance’
q) Other information for investors to take informed
decision
12(1) Filing of PPM for launch of scheme
12 (2) Filing of PPM through Merchant Banker
12(3) Incorporation of comments in PPM
13 Tenure
13(1) - Category I & II AIF/scheme to be close ended
13(2) - Category I & II AIF/Scheme to have minimum tenure of 3
years
13(3) - Category III AIF/schemes - Whether open ended or close
ended
13(4) - Extension of tenure
13(5) - Liquidation of AIF
14 Listing requirements, as and when made applicable
15 General Investment Conditions
15 (1)(a) - For Investment outside India
15 (1)(b) - Terms of Co-investment not more favourable than
Manager /sponsor/co-investor than AIF
15 (1)(c) - Category I & II AIF
- Not more than 25% of investible funds in an Investee
Company
- Large value fund for Accredited Investor may invest up
to 50% of investible funds in an Investee Company
15 (1)(d) Category III AIF
- Not more than 10% of investible funds or NAV in an
Investee Company
- Large value fund for Accredited Investor may invest up to
20% of investible funds or NAV in an Investee Company
15 (1)(da) AIF not to offer their units to other AIFs if they are investing
in units of other AIFs
15 (1)(e) Approval of 75% of investors by value for investment in
associate or units of AIF managed by Manager, sponsor or
by Associates
15 (1)(f) Investment of un-invested portion of investable funds and
divestment proceeds pending for distribution to investors
as prescribed in Regulations
15 (1)(g) AIF to act as Nominated Investor
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Wherever applicable,
mention Section/
subsection along with
page number of the
S. placement memorandum
Regulation Contents of the Regulation
No. where the Regulation has
been complied with
Otherwise mention ‘not
applicable’ or ‘noted for
compliance’
15 (1)(h) Investment by Category I and Category II Alternative
Investment Funds in the shares of entities listed on
institutional trading platform
16 Conditions for Category I Alternative Investment Funds
16(1)(a) Investment by Category I AIF
16(1)(c) Not borrow funds & shall not engage in leverage except for
meeting temporary requirements
16(2)(a) Venture Capital Fund to invest at least 75% of the
investable funds in un-listed equity shares or equity linked
instruments of VCU or in companies listed or proposed to
be listed on SME exchange
16(2)(c) Venture Capital Fund to enter an Agreement with
Merchant Banker for purpose of market making
16(2)(d) Exemption to Venture Capital funds from certain
provisions of SEBI (PIT) Regulations,2015
16(3)(a) SME Fund investment – for at least 75% of investible funds
16(3)(b) SME Fund to enter an Agreement with Merchant Banker
for purpose of market making
16(3)(c) Exemption to SME Fund from certain provisions of SEBI
(PIT) Regulations, 2015
16(4) (a) Social Venture Fund investment- 75% of investable funds
in un-listed securities or partnership interest of social
ventures
16(4) (b) May accept grants not less than Rs.25 lakhs
-Minimum amount of grant to not apply to accredited
investors:
- no profits or gains to accrue to the provider of such grants
16(4) (c) Grants to social ventures subject to disclosure
16(4) (d) Muted returns
16(5)(a) Infrastructure Funds investment - for at least 75% of
investible funds
16(5)(b) Permissible other investments
17 Conditions for Category II Alternative Investment Funds
17(a) Category II AIFs to invest primarily in un-listed Companies
or in units of Category I & II AIFs
17(c) May not borrow funds & shall not engaged in leverage
except for meeting temporary requirements
17(d) May engage in hedging subject to guidelines as specified
by the Board
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Wherever applicable,
mention Section/
subsection along with
page number of the
S. placement memorandum
Regulation Contents of the Regulation
No. where the Regulation has
been complied with
Otherwise mention ‘not
applicable’ or ‘noted for
compliance’
17(e) May enter into agreement with Merchant Banker for
market making
17(f) Exemption to Category II AIFs exemption from certain
provision of SEBI (PIT) Regulations,2015
18 Conditions for Category III Alternative Investment Funds
18(a) May invest in securities of listed or un-listed Investee
Companies, derivatives, units of other Alternative
Investment Funds or complex or structured products
18(aa) May deal in goods received in delivery against physical
settlement of commodity derivatives
18(c) May engage in leverage or borrow subject to consent from
the investors in the fund and subject to a maximum limit,
as may be specified by the Board
3 Chapter III-A – Angel Funds
19B (2) Applicability to Angel Funds
19C Registration of Angel Funds
19D Investment in Angel Funds
19(D)(1) To raise funds by way of issue of units
19(D)(2) Minimum corpus
19(D)(3) Maximum period for accepting funds from investor for
making investment by Angel funds and Minimum
investment by angel investor
19(D)(4) To raise funds through private placement
19E(1) Launch of scheme
19E(2) Maximum number of investors
19F(1) Investment by Angel Funds in startups
19F(2) Minimum investment by Angel Fund
19F(3) Investment by Angel Fund to be locked in for 1 year
19F(4) Angel funds to not invest in associates
19F(5) Angel funds to not invest more than 25% of the total
investments under all its schemes in one venture capital
undertaking
19F(6) Conditions for Investment outside India
19G(1) The sponsor to ensure that the angel investor satisfy
conditions specified in sub regulation (2) of regulation 19A
19G(2) Continuing interest
19(G)(3) The manager of the angel fund shall obtain an undertaking
from every Angel Investor
19H Prohibition of Listing
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Wherever applicable,
mention Section/
subsection along with
page number of the
S. placement memorandum
Regulation Contents of the Regulation
No. where the Regulation has
been complied with
Otherwise mention ‘not
applicable’ or ‘noted for
compliance’
4 Chapter III-B – Special Situation Funds
19(J) Applicability
19(K) Registration of special situation funds
19(L) Investment in special situation funds.
19(M)(1) Special situation funds shall invest only in special situation
assets and may act as a resolution applicant under the
Insolvency and Bankruptcy Code, 2016
19(M)(2) Any investment by a special situation fund in the stressed
loan acquired under clause 58 of the Master Direction –
Reserve Bank of India (Transfer of Loan Exposures)
Directions, 2021 as amended from time to time shall be
subject to lock-in period as may be specified by the Board
5 Chapter IV – General Obligations And Responsibilities And
Transparency
20 General Obligations
20(1) AIF, KMPs of AIF, Trustee, Trustee company, Directors of
Trustee Company, Designated Partners or directors of AIF,
manager and KMP of manager to abide by Code of Conduct
20(2) The Manager and either the trustee or trustee company or
the Board of Directors or the designated partners of the
Alternative Investment Fund to ensure compliances by AIF
with code of conduct
20(3) AIFs to have detailed policies and procedure to ensure that
all the decisions of the AIF are in compliance with the
provisions of these regulations, terms of the PPM,
agreements made with investors, other fund documents
and applicable laws
20(4) AIFs to review policies and procedures on regular basis
20(5) Manager shall be responsible for every decision of AIF
20(6) Manager shall be responsible for ensuring that every
decision of AIF is in compliance with policies and
procedures laid down by AIF
20(7) Manager may constitute an Investment Committee (by
whatever name called), to approve the decisions of the
Alternative Investment Fund and such constitution shall be
subject to such conditions as specified by the Board from
time to time
20(8) Investment Committee shall be responsible for ensuring
that decisions are in compliance with policies & procedure
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Wherever applicable,
mention Section/
subsection along with
page number of the
S. placement memorandum
Regulation Contents of the Regulation
No. where the Regulation has
been complied with
Otherwise mention ‘not
applicable’ or ‘noted for
compliance’
laid down in terms of sub regulation 20 (3) of this
regulation (Not applicable in case the commitment to
invest is not less than Rs.70 crores and has furnished a
waiver to the AIF
20(9) Members of Investment Committee shall abide by Code of
Conduct applicable to them
20(10) External members of Investment Committee not disclosed
in PPM or in Agreement shall be appointed to the
Investment Committee only with the consent of at least
75% of the investors by value
20(11) -Sponsor/Manager to appoint registered custodian if the
corpus of AIF is more than Rs.500 crores –Category III AIF
to appoint custodian irrespective of the size.
-The custodian appointed by Category III AIF shall keep the
custody of the securities and goods received in delivery
against the physical settlement of commodity derivatives
20(12) AIF to inform SEBI in case of change in the Sponsor,
Manager, Designated Partner or any material change in
information provided at the time of application.
20(13) AIF to obtain prior approval from SEBI in case of change in
control of AIF Sponsor or Manager
20(14) The books of accounts of AIF to be audited annually by a
qualified auditor
20(15) Restriction on Manager to provide advisory services
21 Conflict of Interest
21(1) Sponsor & Manager of the AIF to act in fiduciary capacity
towards its investors
21(2) Manager to establish & implement written policies to
mitigate conflict of interest
21(3) Manager & Sponsor of AIF to abide by high level principles
on avoidance of conflict of interest
22 Transparency: All AIFs to ensure transparency &
disclosure of information to investors on the following
22(a) financial, risk management, operational, portfolio, and
transactional information regarding fund investments to
be disclosed periodically to the investors
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Wherever applicable,
mention Section/
subsection along with
page number of the
S. placement memorandum
Regulation Contents of the Regulation
No. where the Regulation has
been complied with
Otherwise mention ‘not
applicable’ or ‘noted for
compliance’
22(b) any fees ascribed or charged
22(c) Any enquiry /legal action as and when occurred
22(d) Any material liability during the tenure of AIF
22(e) Any breach of provisions of Placement Memorandum or
Agreement
22(f) Change in control of the Sponsor or Manager or Investee
Company
22(g) To provide on annual basis (within 180 days from the year-
end) report to investors including following information;
A) Financial information of Investee Company
B) different Material risk as prescribed in AIF Regulations
& how they are managed
22(h) Category III AIF to provide quarterly report in respect of
regulation 22(g) within 60 days of end of the quarter
22(i) Any significant change in key investment team to be
intimated to investors
22(j) AIF to provide SEBI information for systemic risk purposes
23(1) AIF to provide valuation procedure and methodology to
investors
23(2) Category I & II AIFs to undertake valuation of investment
as prescribed in the Regulations
23(3) Category III AIFs to ensure calculation of NAV is
independent from fund management function of AIF and
disclosure of NAV as prescribed in the Regulations.
24 Obligation of Manager
25 Dispute Resolution- AIFs to lay down procedure for
resolution of dispute between investors and AIFs
27 Obligation of manager to maintain record as prescribed in
AIF Regulations
28 Timely Submission of Reports to the Board
29 Compliance to Winding up provisions
Note: This annexure may be modified in line with any amendments notified under SEBI (AIF)
Regulations, 2012 from time to time.
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ANNEXURE II
INFORMATION WITH RESPECT TO DISCLOSURES IN THE PLACEMENT MEMORANDUM
S. Particulars Yes/ Remarks
No. No (Also provide the
respective page number
of placement
memorandum wherever
applicable)
1. Whether it is stated in the placement memorandum that
the LVF scheme shall be placed only before Accredited
Investors having valid accreditation certificate from SEBI
recognized Accreditation Agency or Deemed AIs as per SEBI
AIF Regulations.
2. Whether the information submitted in the placement
memorandum is consistent with the information submitted
in Form A as specified under First schedule of AIF
Regulations
3. Whether Sponsor and Manager of the scheme is same as
Sponsor and Manager of AIF
4. Whether adequate disclosures are made in all sections and
subsections of the placement memorandum in line with
template placement memorandum provided vide SEBI
circular dated Feb 5, 2020
5. Whether the scheme seeks waiver from requirement of If yes, confirm whether it
placement memorandum as per template prescribed in is disclosed that each
SEBI Circular dated Feb 05, 2020 investor shall commit a
minimum capital
contribution of INR 70
crores and provide a
waiver from the
requirement of placement
memorandum in
prescribed template.
6. Whether it is verified that information provided for a If no, highlight the
particular term is consistent across different sections of the respective
placement memorandum sections/clauses
7. Whether there are any clauses in the placement If yes, also highlight such
memorandum which affect the pro-rata rights of each clauses
investor in each investment of the scheme
8. Whether the investor(s) has/have any role in approving
investment decisions of the scheme
9. Whether it is provided that the scheme proposes to engage
in lending activity, or extending guarantee for investee
company
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S. Particulars Yes/ Remarks
No. No (Also provide the
respective page number
of placement
memorandum wherever
applicable)
10. Whether the sections ‘Investment objective, strategy and
process’, ‘Governance structure’ and ‘principal terms of the
fund/scheme’ contain all material information
11. Whether it is provided in the placement memorandum that
terms of contribution/ subscription agreement shall be in
line with the terms of the placement memorandum
12. Whether type of instruments proposed for temporary If yes, provide the list of
deployment of funds is in line with applicable provision of instruments proposed for
AIF Regulations temporary deployment of
funds
Whether the scheme proposes to invest in such instruments
as part of primary investment objective of the scheme also
In case of Category III AIFs, whether the scheme proposes
to invest in such instruments also to provide applicable
margin to recognized stock exchanges
13. Whether maximum duration for such temporary If yes, mention the
deployment of funds is disclosed duration
14. Whether the scheme intends to invest in units of AIFs If yes, whether necessary
disclosures have been
made in line with SEBI
circular dated June 25,
2021
15. Whether names of key management personnel are
disclosed in the placement memorandum in line with SEBI
circular dated June 25, 2021
16. Whether it is verified that all members of key investment
team are employees or partners or directors (as applicable)
of the manager
17. Whether it is verified the key investment team satisfies the Name(s) of qualifying
experience and professional qualification criteria provided member(s) to be provided
under AIF Regulations
18. Whether the manager has constituted or proposes to If no, also inform whether
constitute an investment committee (by whatever name any committee has been
called) to approve decisions of the scheme set up to provide non-
binding
recommendations on
investment proposals
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S. Particulars Yes/ Remarks
No. No (Also provide the
respective page number
of placement
memorandum wherever
applicable)
19. If the investment committee (as specified in Regulation
20(7) of AIF Regulations) is approving authority, whether:
(a) it is stated that the functioning of the investment
committee shall be in compliance with applicable
provisions of AIF Regulations.
(b) the terms of reference of the investment committee
are disclosed in the placement memorandum
20. Whether it is disclosed that delegation/outsourcing of any
activity of the AIF to a third party will be in compliance with
SEBI circular dated Dec 15, 2011
21. Under section ‘Track Record of Manager’, whether there is
provision for disclosure of performance benchmark
disseminated by a benchmarking agency in terms of SEBI
Circular dated February 05, 2020
22. Whether the eligibility criteria for each class of unit is clearly
specified and differentiated
23. Whether specific instances are disclosed, under which an
investor may be excluded or excused from a particular
investment
24. Whether the list of commercial and non- commercial terms, If yes, provide the list of
on which differential rights may be offered through side terms
letter arrangement or issuance of additional class of units,
is disclosed
25. Whether it is disclosed that the differential rights, if any,
attached to any classes of units or given through side
letters, shall not have any adverse impact on the economic
or any other rights of other investors
26. Whether timelines for making warehoused investment and If yes, state the timelines
transferring such investment are disclosed for warehousing and
transferring of the
warehoused investment
27. Whether timelines for intimation regarding warehoused If yes, state the timelines
investments to existing and prospective investors, are for such intimation
disclosed
28. Whether it is provided that a defaulter, i.e., investor who
defaults in bringing drawdown amount within the
timeline specified, can no longer participate in
subsequent investments of the scheme till the default is
cured and that there are clauses providing steps to be taken
against the defaulting investor
29. Whether specific instances are disclosed under which in-
specie distribution / distribution in kind may be made
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S. Particulars Yes/ Remarks
No. No (Also provide the
respective page number
of placement
memorandum wherever
applicable)
30. Whether it is disclosed that co-investment by investors of
AIF shall be made in compliance with applicable provisions
of AIF Regulations and PMS Regulations
31. Whether it is disclosed that the manager will establish
written down conflict management policy and whether
timeline for adopting such policy has been provided
32. Whether the distribution waterfall illustrations have been If yes, whether it is
provided for different scenarios verified that the
illustrations are accurate
and complete
33. Whether necessary disclosure has been made regarding the
disciplinary history in terms of SEBI Circulars dated June 19,
2014 and July 18, 2014
Note:
(i) If any of the points above is not applicable to the proposed scheme, it may be mentioned as “not
applicable”.
(ii) Additional material information, in similar format, may also be provided which is not covered in the
above table and any other information which is necessary to be highlighted or requires specific
attention.
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