Alerts & Updates 11th Nov 2021

Related party transactions put under tighter scrutiny | Co-investment through portfolio managers notified by SEBI

Authors

Manendra Singh Partner | Mumbai

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Certain regulatory changes to the framework for related party transactions (RPTs) and co-investment by investors of Alternative Investment Funds (AIFs) through portfolio management route have been notified by SEBI.

  • A. Amendment to the SEBI (Listing Obligations and Disclosure Requirements) Regulations, 2015 (LODR Regulations): Key changes include following:
    • Change in definition of related party | Scope expanded;
    • Amendment to the definition of ‘related party transaction’;
    • Revised threshold for materiality of RPT;
    • Prior approval of the audit committee for RPTs and subsequent material modifications | Expanded scope of role of the audit committee;
    • Prior shareholders’ approval for RPTs and subsequent material modifications;
    • Exemption from the requirement of prior approval of the audit committee and shareholders for RPTs between two WOS;
    • Disclosure of RPTs;
    • Amended role of the audit committee.

  • B. Amendment to the SEBI (Alternative Investment Funds) Regulations, 2012 (AIF Regulations) and SEBI (Portfolio Managers) Regulations, 2020 (Portfolio Managers Regulations): Key changes include following:

    • Insertion of the definition of ‘co-investment’ and general investment conditions for co-investment;
    • Investment conditions for Category III AIFs for investment in listed equities of companies;
    • Restriction on advisory services by Manager; and
    • Changes to the Portfolio Managers Regulations

    The aforesaid amendments have been analysed in the attached file.

    Read more

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