CIRCULAR
SEBI/HO/IMD/IMD-PoD-1/P/CIR/2025/26 February 27, 2025
To,
All Mutual Funds
All Asset Management Companies (AMCs)
All Trustee Companies/ Board of Trustees of Mutual Funds
All Registrar and Share Transfer Agents (RTAs)
All Recognized Stock Exchanges
All Recognized Clearing Corporations
All Depositories
Association of Mutual Funds in India (AMFI)
Madam/ Sir,
Subject: Regulatory framework for Specialized Investment Funds (‘SIF’)
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 of these products
depending on their complexity, sophistication of target investors, minimum investment
size etc.
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. The regulatory framework and prudential norms governing these investment
vehicles become progressively more flexible from Mutual Funds (‘MFs’) to Portfolio
Management Services (‘PMS’) to Alternative Investment Funds (‘AIFs’), in sync with
the investment profile and investment size of these products.
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. To bridge this gap, the
SEBI (Mutual Funds) Regulations, 1996 have been amended to introduce the broad
regulatory framework for the new investment product – Specialized Investment Fund
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(SIF). The amendment notification is available at link.
4. The comprehensive regulatory framework for the Specialized Investment Fund is
provided in Annexure A to this circular.
5. This circular shall come into force with effect from April 01, 2025.
6. AMFI shall issue necessary guidelines/standards as required under this circular by
March 31, 2025.
7. The Stock Exchanges, Clearing Corporations and Depositories are directed to:
7.1. take necessary steps and put in place necessary systems for the implementation
of this circular;
7.2. make necessary amendments to the relevant bye-laws, rules and regulations,
wherever applicable, for the implementation of this circular;
7.3. bring the provisions of this circular to the notice of market participants and also
disseminate the same on their website.
8. This circular is issued in exercise of the powers conferred by Section 11(1) of the
Securities and Exchange Board of India Act, 1992 read with Chapter VI-C of the SEBI
(Mutual Funds) Regulations 1996 to protect the interest of investors in securities and
to promote the development of, and to regulate the securities market.
9. This circular is available at www.sebi.gov.in under the link “Legal ->Circulars”.
Yours faithfully,
Peter Mardi
Deputy General Manager
Investment Management Department
+91-22-26449233
peterm@sebi.gov.in
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ANNEXURE A
1. Eligibility criteria for Specialized Investment Fund
1.1. In terms of Regulation 49W(1) of the SEBI (Mutual Funds) Regulations, 1996 (‘MF
Regulations’), a mutual fund registered under Regulation 9 may be granted an
approval to establish SIF subject to fulfilling such eligibility criteria and in the manner,
as may be specified by the Board. In this regard, the following has been decided:
1.1.1. A registered mutual fund may establish SIF, provided they meet the eligibility
criteria under one of the following routes:
1.1.1.1. Route 1 - Sound track record:
i. Mutual Fund has been in operation for a minimum period of 3 years and has
an average asset under management (‘AUM’) of not less than INR 10,000
crores, in immediately preceding 3 years.
ii. No action has been initiated or taken against the sponsor/asset management
company (‘AMC’) under section 11, 11B, and/or Section 24 of the SEBI Act,
1992 during the last 3 years.
1.1.1.2. Route 2 – Alternate route:
i. The AMC has appointed:
a. A Chief Investment Officer (‘CIO’) for the SIF with an experience of fund
management of at least 10 years and has managed an average AUM of
not less than INR 5,000 crores, and
b. An additional Fund Manager for the SIF with experience of fund
management of at least 3 years and has managed an average AUM of not
less than INR 500 crores.
ii. No action has been 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.
1.1.2. The AMC may share resources for operations across mutual fund and SIF.
1.1.3. A registered Mutual Fund shall file an application for prior approval with SEBI for
establishment of an SIF, in the manner as may be specified by SEBI.
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2. Branding and advertisement requirements
2.1. In terms of Regulation 49AB(1), the AMC shall ensure that the SIF has distinct
identification, separate from that of the Mutual Fund, to maintain clear differentiation
between the offerings of the SIF and that of a mutual fund. Further, in terms of
Regulation 49AB(2) of the MF Regulations, the AMC shall comply with the provisions
relating to branding, advertising, standard disclaimers, guidelines on usage of
sponsor or asset management company or mutual fund’s brand name, and
maintenance of a separate website, as may be specified by the Board from time to
time. In this regard, the following has been decided:
2.1.1. In order to clearly differentiate the Specialized Investment Fund and maintain
brand integrity of its Mutual Fund business, AMCs shall ensure that the SIF has
a distinct brand name and distinct logo, separate from that of its regular Mutual
Fund.
Provided that, to facilitate the establishment and initial recognition of the SIF’s
brand, the AMC may use the sponsor’s or mutual fund’s brand name in the offer
documents, advertisements and promotional materials of the SIF for a period of
five years from the date of SEBI’s approval for the launch of the SIF.
2.1.2. When referring to the sponsor’s or mutual fund’s brand name for SIF, the AMC
shall use phrases such as “brought to you by,” “offered by,” or similar terms.
Illustration: An AMC managing “ABC Mutual Fund” may create a distinct SIF
brand, such as “XYZ,” with a unique logo. The SIF may initially be marketed as
‘XYZ SIF – brought to you by ABC Mutual Fund’ or ‘XYZ SIF – offered by ABC
Mutual Fund.’
2.1.3. The font size of the sponsor’s or Mutual Fund’s brand name in all offer
documents, marketing, and promotional materials shall be equal to or smaller
than the font size of the SIF’s brand name.
2.1.4. The AMC shall adhere to the advertisement guidelines applicable to Mutual Fund
schemes for all investment strategies offered under the SIF.
2.1.5. The AMC shall maintain a separate website or dedicated webpage exclusively
for the SIF, ensuring clear differentiation between the SIF’s offerings and the
regular Mutual Fund offerings.
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3. Investment strategies
3.1. In terms of Regulation 49U(c) of the MF Regulations, Investment Strategy means a
scheme of mutual fund launched under the Specialized Investment Fund. Further, in
terms of Regulation 49Y(1) of the MF Regulations, the investment strategies under
the SIF shall be launched in accordance with the procedure applicable to the
schemes of mutual funds, as laid down in Regulation 28; provided that a SIF may
launch such investment strategies in the manner as may be specified by the Board
from time to time.
3.2. Accordingly, in consultation with MF industry, it has been decided that the following
investment strategies shall be permitted to be launched under SIF, at this stage:
A) Equity Oriented Investment Strategies
Sr. Category of Characteristics of Type of Minimum
No. Investment Investment strategy investment redemption
Strategy strategy frequency
(uniform
description of
investment
strategy)
1. Equity Long- Minimum investment An open Daily or any
Short Fund in equity and equity ended/interval lesser
related instruments – equity investment redemption
80% and strategy investing frequency
in listed equity as may be
Maximum short
and equity related decided by
exposure through
instruments the AMC
unhedged derivative
including limited
positions in equity
short exposure in
and equity related
equity through
instruments: 25%
derivative
instruments.
2. Equity Ex- Minimum investment An open Daily or any
Top 100 in equity and equity ended/interval lesser
Long-Short related instruments of investment redemption
Fund stocks excluding top strategy investing frequency
100 stocks by market in equity and as may be
capitalization – 65% equity related decided by
instruments the AMC
&
including limited
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Maximum short short exposure in
exposure through equity through
unhedged derivative derivative
positions in equity instruments, of
and equity related stocks other than
instruments of other large cap stocks.
than large cap stocks:
25%
3. Sector Minimum investment An open Daily or any
Rotation in equity and equity ended/interval lesser
Long-Short related instruments of investment redemption
Fund maximum 4 sectors – strategy investing frequency
80% in equity and as may be
equity related decided by
&
instruments AMC
Maximum short
including limited
exposure through
short exposure in
unhedged derivative
equity through
positions in equity
derivative
and equity related
instruments, of
instruments: 25%*
maximum four
*Short exposure shall sectors.
apply at the sector
level, covering all
stocks within that
sector held in the
portfolio. For
instance, if the fund
takes a short position
in the Auto sector, all
Auto sector stocks in
the portfolio must be
held as short
positions.
B) Debt Oriented Investment Strategies
Sr. Category of Characteristics of Type of Minimum
No. Investment Investment strategy investment redemptio
Strategies strategy n
(uniform frequency
description of
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scheme)
1. Debt Long- Investment in debt Interval Once in a
Short Fund instruments across investment week or
any lesser
duration, including strategy investing
redemption
unhedged short in debt
frequency
exposure through instruments
as may be
exchange traded debt including limited
decided by
derivative short exposure in AMC
instruments. debt instruments.
2. Sectoral Investment in debt Interval Once in a
Debt Long- instruments of at least investment week or
any lesser
Short Fund two sectors, with strategy investing
redemption
maximum investment in debt
frequency
of 75% in a single instruments
as may be
sector. including limited
decided by
short position in AMC
Maximum short
debt instruments,
exposure through
of minimum two
unhedged derivative
sectors.
positions in debt
instruments: 25%*
*Short exposure shall
be across the sector,
applicable for all the
instruments of that
particular sector held
in the portfolio.
Example: If the fund is
short on Auto sector,
then all debt
instruments of the
Auto sector, held in
portfolio, shall be held
as short positions.
C) Hybrid Investment Strategies
Sr. Category of Characteristics of Type of Minimum
No. Investment Investment strategy investment redemption
Strategies strategy frequency
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(uniform
description of
scheme)
1. Active Asset Dynamic investment Interval Two Times
Allocator across following asset investment in a week or
Long-Short classes: strategy any lesser
Fund dynamically redemption
Equity, debt, equity
investing across frequency
and debt derivatives,
equity, debt, as may be
REITs/InVITs and
equity and debt decided by
commodity
derivatives, AMC
derivatives.
REITs/InVITs and
Maximum short
commodity
exposure through
derivatives,
unhedged derivative
including limited
positions in equity and
short exposure on
debt instruments:
permitted
25%
instruments
through
derivatives.
2. Hybrid Long- Minimum investment Interval Two Times
Short Fund in equity and equity investment in a week or
related instruments - strategy investing any lesser
25% in equity and debt redemption
securities, frequency
Minimum investment
including limited as may be
in debt instruments –
short exposure in decided by
25%
equity and debt AMC
Maximum short
through
exposure through
derivatives.
unhedged derivative
positions in equity and
debt instruments:
25%
3.3. To avoid proliferation of investment strategies and in line with the approach followed
for categorization of MF schemes, only one investment strategy shall be permitted to
be launched under each of the aforementioned categories.
4. Minimum investment threshold
4.1. In terms of Regulation 49X(1) of the MF Regulations, the SIF shall not accept from
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an investor, an investment amount less than ten lakh rupees across all investment
strategies in the manner as may be specified by the Board; provided that the
requirement of minimum investment amount shall not apply to an accredited investor.
In this regard, the following has been decided:
4.1.1. The AMC shall ensure that an aggregate investment by an investor across all
investment strategies offered by the SIF, at the Permanent Account Number
(‘PAN’) level, is not less than INR 10 lakh (hereinafter referred to as the ‘Minimum
Investment Threshold’).
4.1.2. The Minimum Investment Threshold of INR 10 lakh shall apply exclusively to
investments under SIF and shall not include investments made by the investor in
regular MF schemes of the same AMC.
4.1.3. The AMC may offer systematic investment options such as Systematic
Investment Plan (‘SIP’), Systematic Withdrawal Plan (‘SWP’) and Systematic
Transfer Plan (‘STP’) for investment strategies launched under the SIF, while
ensuring compliance with the Minimum Investment Threshold.
4.1.4. Breach of Minimum Investment Threshold:
4.1.4.1. The AMC shall monitor compliance with the Minimum Investment Threshold
on a daily basis and ensure that there are no active breaches. The AMC shall
ensure that the investor's total investment value does not fall below the
Minimum Investment Threshold due to redemption transactions initiated by
the investor.
4.1.4.2. Passive breaches (occurrence of instances not arising out of omission and
commission by AMC), such as those caused by a decline in Net Asset Value
(NAV), shall not be treated as a violation of the Minimum Investment
Threshold. However, if the total investment value falls below the threshold due
to a passive breach, the investor shall only be permitted to redeem the entire
remaining investment amount from the SIF.
4.1.4.3. AMFI shall coordinate with recognized stock exchanges, depositories, and
Mutual Fund RTAs to deploy systems and processes for the active monitoring
of the Minimum Investment Threshold.
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5. Restriction on investments
5.1. In addition to Regulation 49(AA) of the MF Regulations which specifies various
investment restrictions for investments under SIF, other investment restrictions shall
be as follows:
5.1.1. An investment strategy under SIF 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 of MF and board of AMC.
5.1.2. An investment strategy under the SIF shall not invest more than 25% of its NAV
in debt and money market securities of a particular sector.
6. Investment in derivatives
6.1. In terms of Regulation 49Z(1) of the MF Regulations, SIF may invest monies
collected under any of its investment strategies in instruments permitted under sub-
regulation (1) of Regulation 43 of mutual funds schemes, provided that the manner
of investment by a SIF may be specified by the Board. In this regard, investment by
SIF in eligible derivative products shall be as follows.
6.1.1. The investment strategies under the SIF may take exposure of up to 25% of the
net assets in permissible exchange traded derivative instruments, specifically for
purposes other than hedging and portfolio rebalancing.
Explanation: This provision allows an investment strategy under the SIF to take
unhedged short exposure through derivative instruments of up to 25% of net
assets, in addition to derivative exposure undertaken for hedging and portfolio
rebalancing purposes
6.1.2. In line with the definition of exposure in case of derivative positions for MF, as
specified under paragraph 12.25.11.1 of the Master Circular for Mutual Funds
dated June 27, 2024, the exposure to derivative contracts for the investment
strategies under SIF shall be computed as follows:
6.1.2.1. Futures (long and short) = Futures Price * Lot Size * Number of Contracts
6.1.2.2. Options bought = Option premium paid * Lot size * Number of contracts
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6.1.2.3. Options sold = Market price of the underlying * Lot size * Number of contracts
6.1.2.4. In case of any other derivative exposure, the exposure shall be calculated as
the notional market value of the contract.
6.1.3. The total exposure at any point of time shall be the sum of exposure through
instruments in both the cash market and derivatives market.
6.1.4. Offsetting of exposure at the portfolio level shall be allowed for:
6.1.4.1. Cash and derivative positions on the same underlying security
6.1.4.2. Between derivative positions on the same underlying security
The illustration on exposure calculation and offsetting of derivative positions
is provided in Annexure A1.
6.1.5. In accordance with the clause 12.24.1 of the Master Circular for Mutual Funds
(‘Master Circular’) dated June 27, 2024, the cumulative gross exposure through
equity, debt, derivative positions (including commodity and fixed income
derivatives), repo transactions and credit default swaps in corporate debt
securities, Real Estate Investment Trusts (REITs), Infrastructure Investment
Trusts (InvITs), other permitted securities/assets and such other
securities/assets as may be permitted by the Board from time to time should not
exceed 100% of the net assets of the investment strategy.
7. Subscription and redemption of units of investment strategies
7.1. In terms of Regulation 49Y(2) of the MF Regulations, an investment strategy under
the SIF may be launched as an open-ended investment strategy or close-ended
investment strategy or interval investment strategy, with subscription and redemption
frequency appropriately disclosed in the offer document. Accordingly, the following
has been decided:
7.1.1. Subscription and redemption frequencies:
7.1.1.1. The subscription and redemption frequency of investment strategy under SIF
may be based on the nature of investments, including daily, weekly, fortnightly,
monthly, quarterly, annually, fixed maturity, or other suitable intervals. The SIF
may decide on the appropriate frequency of subscription/ redemption to allow
the fund managers to adequately manage liquidity of the fund without
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imposing undue constraints on the investors.
7.1.1.2. The subscription frequency and redemption frequency of an investment
strategy may be distinct from each other.
Illustration: An investment strategy may permit daily subscriptions, while
offering weekly redemptions.
7.1.2. Notice periods:
7.1.2.1. Based on structure of the investment strategy and the liquidity risk associated
with it, AMC may implement appropriate notice periods for redemption from
the investment strategy of SIF, in the following manner:
i. In case of notice period, the redeeming investor shall receive the value of
units sold based on the fund’s NAV at the end of the notice period.
ii. Maximum duration of notice period shall not exceed 15 working days.
8. Listing of units of investment strategies
8.1. To provide an exit option for the redeeming investors, the units of all close ended and
interval investment strategies of SIF shall be mandatorily listed on recognized stock
exchange(s).
8.2. Investment strategies with subscription and/or redemption frequency other than daily
shall be classified as ‘Interval investment strategies’ for the purpose of SIF.
9. Benchmarking of Investment Strategies
9.1. The investment strategies of SIF shall follow a single-tier benchmark structure.
Provided that, AMC at its discretion may also provide second tier benchmark for
investment strategies as applicable for schemes of Mutual Funds under para 1.9 of
the Master Circular.
9.2. The AMC shall appropriately select any of broad market indices available, as a
benchmark index depending on the investment objective and portfolio of the
investment strategy.
9.3. The guiding principles for selection of benchmarks are as follows:
9.3.1. Equity oriented investment strategies shall be compared against a suitable broad
market index such as BSE Sensex or NSE Nifty or BSE 100 or CIRISL 500 etc.
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9.3.2. Debt oriented investment strategies shall be compared with a suitable broad
market index that is a representative of the fund’s portfolio.
9.3.3. Hybrid investment strategies shall be compared with suitable broad market
benchmark wherever available.
10. Distribution of Specialized Investment Funds
10.1. An entity engaged in sale and/or distribution of Mutual Fund products, shall also be
eligible to offer products under the SIF, subject to such entity having passed
National Institute of Securities Markets (‘NISM’) Series-XIII: Common Derivatives
Certification Examination.
10.2. AMFI and the AMCs shall ensure compliance with the above requirement by their
agents and distributors.
11. Disclosure in offer documents: The following information shall be disclosed in the
offer documents to enable the investors and unit holders to take an informed decision:
11.1. Redemption and subscription frequency of the investment strategy.
11.2. Notice period of the investment strategy, if any.
11.3. Frequency of portfolio disclosure
11.4. Scenario analysis for derivative positions
11.5. Disclosures regarding investment in derivatives along with the maximum limit on
investment in derivatives for other than hedging and portfolio rebalancing exposure
11.6. Disclosure of liquidity risk management tools and its applicability
11.7. Any other relevant information.
12. Risk-Band
12.1. Similar to Mutual Fund schemes, the potential risk associated with the investment
strategies of the SIF shall be depicted through a pictorial risk meter, termed as
“Risk-band”.
12.2. The Risk-band shall have following five levels of risks for investment strategies of
SIF:
12.2.1. Risk band level 1 (Lowest risk)
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12.2.2. Risk band level 2
12.2.3. Risk band level 3
12.2.4. Risk band level 4
12.2.5. Risk band level 5 (Highest Risk)
12.3. The detailed standards regarding Risk-Band including the depiction, evaluation and
calculation of risk levels of the Risk-Band shall be issued by AMFI, in consultation
with SEBI, on or before March 31, 2025.
12.4. Based on the scheme characteristics, SIF shall assign risk level for schemes at the
time of launch of New Fund Offer of the investment strategy.
12.5. Any change in risk band shall be communicated by way of Notice cum Addendum
and by way of an e-mail or SMS to unitholders of that particular investment strategy.
12.6. Risk-band shall be evaluated on a monthly basis and SIF/AMCs shall disclose the
risk-band for all their investment strategies on their respective websites and on
website of AMFI within 10 days from the close of each month.
12.7. SIFs shall disclose the risk level of investment strategies as on March 31st of every
year, along with number of times the risk level has changed over the year, on their
websites and AMFI website.
13. Disclosure requirements
13.1. Portfolio disclosure: The SIF shall disclose portfolio (along with ISIN), including
derivative instruments, as on the last day of every alternate month (i.e. as on the
end of May, July, September, November, January and March) for all its investment
strategies (including debt based investment strategies) on the respective AMC
website and on the website of AMFI within 10 days from the close of such month in
a user friendly and downloadable spreadsheet format. All other provisions regarding
portfolio disclosure applicable to Mutual Fund schemes, shall also be applicable to
the investment strategies under the SIF.
13.2. Scenario analysis: The Investment Strategy Information Document (ISID) shall
include a scenario analysis, depicting the expected loss to the investor due to
market movements. AMFI, in consultation with SEBI, shall prescribe a model format
for scenario analysis on or before March 31, 2025.
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13.3. Offer documents: All offer documents (i.e. ISID/SAI/KIM) shall be available
publicly and also on the website of the SIF and AMFI.
13.4. Standard disclaimer: All advertisements and promotional materials shall be
accompanied by a standard warning in a legible fonts which shall state:
“Investments in Specialized Investment Fund involves relatively higher risk
including potential loss of capital, liquidity risk and market volatility. Please read all
investment strategy related documents carefully before making the investment
decision.”
No addition or deletion of words shall be made to the standard disclaimer.
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ANNEXURE A1: ILLUSTRATION ON DERIVATIVE EXPOSURE
Investment strategy ‘ABC Long-Short Equity Fund’ has AUM of 100 crore. The
following table specifies the list of securities identified for investment:
Security details Price Lot size
XYZ Ltd. 2500 N.A.
XYZ Futures 2525 500
XYZ Call option 2500 90 500
XYZ Put option 2500 85 500
A) Maximum exposure limits:
The following table illustrates the maximum amount/contracts that can be bought/sold
under the investment strategy:
Details Provisions/Exposure Maximum Maximum
calculation amount that no. of
can be contracts
invested that can be
bought/sold
XYZ Ltd. futures short Maximum 25% of INR 10 crore 79 contracts
position (without hedging/ unhedged short exposure
without having underlying = 10 crore /
security in the portfolio) Exposure to single stock (2525*500)
<= 10% of investment
strategy
Overall stock futures short Maximum 25% of INR 25 crore -
position at portfolio level unhedged short exposure
across multiple securities
XYZ Call option 2500 long Max 20% exposure (ref. INR 10 crore 2222
position 12.25.2 of Master Circular contracts
for Mutual Funds)
= 10 crore /
Exposure to single stock (90 * 500)
<= 10% of investment
strategy
XYZ Call option 2500 Max 20% exposure (ref. INR 10 crore 80 contracts
short position 12.25.2 of Master Circular
for Mutual Funds) = 10 crore /
(2500 * 500)
Exposure to single stock
<= 10% of investment
strategy
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B) Illustration on portfolio composition:
The following examples illustrates possible usage of derivatives for portfolio construction
of the investment strategy:
Example 1 Example 2
Investment Amount (Total: Investment Details Amount (Total:
Details INR 100 crore) INR 100 crore)
Investment in EQ INR 70 crore Investment in EQ INR 62.5 crore
Cash holding INR 5 crore Investment in EQ INR 10 crore
Long Futures & Long
options
Short exposure INR 25 crore Cash holding INR 2.5 crore
using stock/index
Short exposure using INR 25 crore*
futures
stock/index futures
*Since unhedged short exposure of upto 25%
is additional to the investment in derivatives
for purposes other than hedging and portfolio
rebalancing.
Represents unhedged short exposure through derivatives
Represents derivatives exposure for the purpose of hedging and portfolio rebalancing
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C) Offsetting of transactions:
As per the provisions of the circular, the investment strategy is allowed to offset certain
derivative transactions. Below are some of the illustrative scenarios for offsetting of
positions on the same underlying security.
Sr. Position 1 Position 2 Offsetting Net exposure to be
No. allowed/not? considered
1 Equity Long Futures Short Yes Equity Long only
2 Equity /Futures Call option Short Yes Equity /Futures
Long Long only
3 Equity /Futures Put option Long Yes Equity /Futures
Long Long only
4 Futures Short Call option Long Yes Futures Short only
5 Futures Short Put option Short Yes Futures Short only
6 Call option Long Call option Short Yes Call option Short
only
7 Put option Long Put option Short Yes Put option short only
8 Equity Long Futures Long No Equity Long +
Futures Long
9 Equity /Futures Call option Long No Equity /Futures
Long Long + Call option
Long
10 Equity /Futures Put option Short No Equity /Futures
Long Long + Put option
Short
11 Futures Short Call option Short No Futures short + Call
option short
12 Futures Short Put option Long No Futures short + Put
option Long
13 Call option Long Put option Short No Call option Long +
Put option Short
14 Call option Short Put option Long No Call option Short +
Put option Long
*For offsetting of positions, the futures and options contracts shall be on the same
underlying security and having same expiry date.
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