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SEBI Clarifies Rs 10 Lakh Minimum Investment for SIFs at PAN Level

Published on April 12, 2025
Current Context: The SEBI clarification regarding the Rs 10 lakh minimum investment for Social Impact Funds (SIFs) at the PAN level was issued on April 9, 2025.
SEBI Clarifies Rs 10 Lakh Minimum Investment for SIFs at PAN Level
Explanation and Highlights:
  • PAN-Level Aggregation: The Rs 10 lakh minimum investment requirement applies cumulatively across all SIF strategies under a single Asset Management Company (AMC) at the PAN level. This ensures transparency and prevents investors from splitting investments across schemes to bypass the threshold.
  • Exemptions: Accredited investors and mandatory investments made by AMC employees under the "skin-in-the-game" rule are exempt from this requirement.
  • Systematic Investment Options: Investors can opt for systematic investment plans (SIPs), systematic withdrawal plans (SWPs), or systematic transfer plans (STPs) under SIFs, provided the total investment remains above Rs 10 lakh.
  • Interval Strategies: SEBI has granted flexibility to interval strategies under SIFs, exempting them from strict maturity-matching rules. This allows fund managers to invest in longer-tenure or less liquid instruments.
  • Impact on Investors: The clarification simplifies portfolio diversification across multiple SIF strategies within the same AMC, ensuring efficient capital allocation.
This move by SEBI aims to enhance governance, promote impactful ventures, and provide clarity to investors participating in SIFs.

Question:

Q.1 As per SEBI, The Rs 10 lakh minimum investment requirement for Social Impact Funds (SIFs) applies at which level?
a) Per scheme level
b) PAN level across all SIFs under a single AMC
c) Only for non-accredited investors
d) Only for lump-sum investments

Answer: b) SEBI clarified that the Rs 10 lakh threshold is calculated cumulatively across all SIF strategies under a single AMC at the PAN level, preventing investors from splitting investments to bypass the requirement.
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