DIRECTOR_PRESENTATION_-_NEERAJ

Comprehensive Programme on
Capital Markets

Capital Markets
STRUCTURE OF THE PRESENTATION
• UNDERSTANDING THE FRAMEWORK
• PROFILE OF TRUST AND AMC DIRECTORS
• REGULATORY REQUIREMENTS TRUST/AMC
• KEY PERSONNEL RESPONSIBILITIES
• PERSONNEL/PROCESS OWNERSHIP
• REGULATORY REPORTING STRUCTURE
• QUICK COMPLIANCE WALKTHROUGH

Capital Markets
Trust Company
Sponsors
Custodian
Mutual Fund
(Schemes)
Savings
AMC
Investment Manager
R & T Agent
Stake Holders
Unit Holders (Investors)
Units & Returns
SEBI
The Regulator
Stake Holders
Investment Management
Agreement
AMFI
MF Structure in India

Capital Markets
Towards Integrity Driven Performance
•Compliance training an integral part of induction programme for
each employee.
•Access to Corporate Governance Manual and Compliance Manual
through intranet.
•Periodic updates to branches and individual employees on
regulatory and compliance developments.
•High level of hand-holding of branches and hands on approach.
•Direct updates at Ops./Sales meets on key areas of
Compliance(especially on gap bridging).
•High level regulatory interaction and trust building.
•Key driver in guiding future regulation through contribution in
regulation formulation both directly with SEBI and through AMFI.
Pro-active Compliance Program Delivery

Capital Markets
To assist the Boards of the AMC and the Trustee in
ensuring preservation of Sponsor Group’s
reputation and integrity by complying with all local laws,
regulations and ethical standards applicable to
the Asset Management/ Mutual fund business.
To add value to the operations of the AMC.
To implement the best practices in the interest of the
customers of the Fund.
To enable the business to sustain and maintain its lead
over competition and to emerge as Leading player in the
industry.
COMPLIANCE OBJECTIVES

Capital Markets
Towards Integrity Driven Performance
Compliance Monitoring is structured through a Risk based
annual Compliance Plan approved by the Board and ACM.
•Risks are analysed for each Compliance component.
•Weightages are assigned on the basis of the probability
and the impact(Reputational, Regulatory and Financial)
and ARS is arrived.
•Based on ARS the intensity of compliance monitoring is
then determined through compliance tests which are
applied at defined frequencies.
•Assurance reporting to ACM and Board at defined
intervals provide confirmation about robustness of the
compliance framework.
Risk Based Compliance Approach

Capital Markets
There are many constituencies involved in the structure and set up of a mutual fund:

Capital Markets
Compliance Head – Facilitates Functional Heads achieve Compliance in their
domain – Overall responsibility rests with Compliance but ownership is shared.
Ensuring that
units are sold in harmony
with the applicable regulations.
· Setting parameters for empanelling brokers
agents, banks and other third party distributors
· Monitoring selling practices of distributors.
· Ensuring that the literature and sales materi
being distributed by the sales force
conform to the Regulatory requirements.
All investments related matters:
Complying with Regulatory/prudential limits/
Complying with investment restrictions
· affiliate transactions.
· inter scheme transfers.
affiliate and non affiliate broking limits.
· allocation of trades.
Units creation and redemption.
· pricing of securities as per the Regulations
NAV computation
· adhering to Regulations on custody of Fund’s securities.
· delivery of customer service as per committed parameters.
· making disclosure to unit holders/trustees
· Ensuring compliance with recurring expenses limits.
· Documents for Regulatory filings.
Hiring of employees to conform to the
regulatory requirements.
The terms of employment, service conditions
and compensation policies conform to local laws.
Policies for deduction of provident fund,
pension and profession tax from the salaries
· Filing of statutory returns on various deductions
made from the salaries of employees.
Insulate the organisation from regulatory risks
Ensure Compliance with all applicable regulations
Obtain Regulatory Approvals
Handle all Legal Matters
Fulfill mandate by Board
CIO –
Ops. –
Sales–
Ensuring that the advertisement
material, conform to regulatory guidelines
Ensuring that customer complaints are
redressed quickly.
Ensuring that product material is in
line with the various terms and
conditions of the schemes
and conforms to Regulatory requirements
Mktg.–
HR -
Compliance,Legal,
Company Secretary –NEERAJ VE

Capital Markets
SHAREHOLDERS
General PublicInvestors
Audit Committees
Board of Directors -Direction
External Auditors
Employees Senior Management - Executive Action
and Supervision
Service Providers
and Vendors
Investm
ents
Returns
&
Service
Info requests
Correct Info
Remuneration
Tasks
Consideration
Services
Flow of Corporate Governance

Capital Markets
Credit
Selling
Operational
Investment
Business
Environment
Regulatory
Compliance
Exposure to forces in the external
environment that could significantly change
the fundamentals that drive the overall
objectives and strategy
Risks caused by changes in the compliance/regulatory environments
for financial services products or failure to understand or effectively
apply and comply with compliance/regulatory standards, principles and
practices
Ineffective, inefficient
or inadequate senior
management
processes for the
development and
implementation of
business strategy
in relation to the
business environment
and the Group’s
capabilities
Exposure arising from the
possibility that customers or
third parties are unable or
unwilling to meet their financial
obligations when due or that
such exposures
are inappropriately managed
Risks arising
from the sale of
products,
including mis-
selling the terms
and
benefits of those
products and the
impact of
variations
from assumptions
on profit
Risks arising from changes in the market
value of assets, changes in the investment
return of assets held or failure to match
assets and liabilities or inappropriate treasury
management
Risk of direct or indirect loss resulting
from inadequate or failed internal
processes, people and systems or from
external events
Strategic

Capital Markets
The Fund will be sponsored by Mahindra & Mahindra
Financial Services Ltd As per the Regulations, the
Sponsors/Settlers appoint a Trustee Co (Trust Limited)
to supervise the activities of the Fund.
The Sponsors

Capital Markets
Trustee for *Mahindra Mutual Fund.
Trustee has overall responsibility to supervise and oversee the
affairs of Fund and ensure that the Regulations are complied with.
The Trustee is ultimately responsible to the unit holders.
The Trustee Company is managed by Board of Directors.
Trustee has several rights and responsibilities under Regulations.
*Proposed subject to SEBI Approval
Mahindra Trustee Co Private Limited

Capital Markets
A trust under Indian Trusts Act.
An umbrella Fund, with a provision to have several portfolios
(Schemes).
The Fund’s corpus is contributed by Sponsors-MMFSL
The Sponsors had set up the Fund by executing a Trust Deed. The
Trust Deed contains provisions of SEBI Regulations.
Each portfolio (Scheme) is a distinct entity.
The Trustee for the Fund is Mahindra Trustee Company Private Co
Limited, which is a Corporate Trustee.
*Mahindra Mutual Fund (Fund)

Capital Markets
•Corporate entity managed by Board of Directors.
•Entrusted with the responsibility of investment management and day
to day operations of the Schemes of Mutual Fund.
•Responsible for launch of Schemes, providing systems, marketing,
personnel accounting and compliance requirements.
•Responsible to Board of Trustees. Required to manage the Funds
diligently and as per Regulations.
MAHINDRA ASSET MANAGEMENT
COMPANY CO PVT LTD

Capital Markets
AMC shall take all reasonable steps and exercise due diligence to
ensure that the investment of funds pertaining to any scheme is not
contrary to the Regulations.
AMC shall be responsible for acts of commissions or omissions by
its employees or any of its agents.
AMC’s Obligations

Capital Markets
REGULATORY PRESCRIPTIONS ON WHO CAN ACT AS TRUSTEES.
(1) A mutual fund shall appoint trustees in accordance with these regulations.
(2) No person shall be eligible to be appointed as a trustee unless -
(a) he is a person of ability, integrity and standing; and
(b) has not been found guilty of moral turpitude; and
(c) has not been convicted of any economic offence or violation of any securities laws;
(d) has furnished particulars as specified in Form C.
(3) An asset management company or any of its officers or employees shall not be eligible to
act as a trustee of any mutual fund.
(4) Two thirds of the trustees shall be independent persons and shall not be associated with
the sponsors or be associated with them in any manner whatsoever.
(6) In case a company is appointed as a trustee then its directors can act as trustees of any
other trust provide that the object of the trust is not in conflict with the object of the
mutual fund.
Approval of the Board for appointment of trustee

Capital Markets
BOARD OF TRUSTEES –Mahindra Trustee Co Private Limited

1) Mr. M.G.BHIDE -Chairman-Independent

2) Mr. R.K.Kulkarni Independent

3) Mr. Uday Y. Phadke Associate

4) Mr. Independent
3 OUT OF 4 DIRECTORS SHOULD BE INDEPENDENT DIRECTORS
COMPLYING WITH THE REGULATORY REQUIREMENT UNDER SEBI
REGULATIONS.

Capital Markets
Rights and Obligations of the Trustee under the Trust Deed and the Regulations
Pursuant to the Deed of Trust constituting the Mutual Fund and in terms of the Regulation the rights and obligations
of
the Trustee are as under:
1.        The Trustee shall have a right to obtain from the AMC such information as is considered necessary by it.
2.        The Trustee shall ensure before the launch of any scheme that the Asset Management Company has :
      i.    systems in place for its back office, dealing room and accounting;
     ii.  appointed all key personnel including fund manager(s) for the Scheme and submitted to the
Trustee their bio-data which shall contain the educational qualifications, past experience in the
securities market within fifteen days of their appointment;
   ii.   appointed auditors to audit the accounts of the scheme;
    iv. appointed a compliance officer to comply with regulatory requirements and to redress Investor
grievances;
    v. appointed registrars and laid down parameters for their supervision;
vi.    prepared a compliance manual and designed internal control mechanisms including
internal audit systems and
vii.   Specified norms for empanelment of brokers and marketing agents.
3.    The Trustee shall ensure that the AMC has been diligent in empanelling the brokers, in monitoring
securities transactions with brokers and avoiding undue concentration of business with any broker.
4.   The Trustee is required to ensure that the AMC has not given any undue or unfair advantage to any
associate or dealt with any of the associates of the AMC in any manner detrimental to the interests of the
Unitholders.
5.      The Trustee is required to ensure that the transactions entered into by the AMC are in accordance with the
Regulations and the provisions of the Scheme.

Capital Markets
Rights and Obligations of the Trustee under the Trust Deed and the
Regulations
6. The Trustee is required to ensure that the AMC has been managing the Scheme independently of other
activities and has taken adequate steps to ensure that the interest of Investors under the Scheme are not
compromised with those of any other Scheme or of other activities of the AMC.
7.   The Trustee is required to ensure that all the activities of the AMC are in accordance with the provisions of
the Regulations and shall exercise general and specific due diligence as required under the Regulations.
8. Where the Trustee has reason to believe that the conduct of the business of the Fund is not in accordance
with these Regulations and the provisions of the Scheme launched there under, it is required to take such
remedial steps as are necessary by it and to immediately inform SEBI of the violation and the action taken
by it.
9. Each Director of the Trustee is required to file with the Trust the details of his securities transactions on a
quarterly basis.
10. The Trustee is accountable for and is required to be the custodian of the Fund’s property of the respective
of the Scheme and to hold the same in trust for the benefit of the Unitholders in accordance with the
Regulations and the provisions of the Trust Deed.
11. The Trustee is required to take steps to ensure that the transactions of the Mutual Fund are in accordance
with the provisions of the Trust Deed.
12. The Trustee is responsible for the calculation of any income due to be paid to the Mutual Fund and also of
any income received in the Mutual Fund for the holders of the units of any Plan of the Scheme in
accordance the Regulations and the Trust Deed.
13. The Trustee is required to obtain the consent of the Unitholders of the Scheme :
When the Trustee is required to do so by SEBI in the interest of the Unitholders; or
a.      Upon a requisition made by three-fourths of the Unitholders of the Scheme; or
b.      If a majority of the Trustees decide to wind up the Scheme or prematurely redeem the Units

Capital Markets
Regulations

14.     The Trustee shall ensure that no change in the fundamental attributes of the
Scheme or the trust or fee and expenses payable or any other change which would
modify the Plan and affects the interests of unit holders, shall be carried out
unless:
(i)   a written communication about the proposed change is sent to each
15. The Trustee is required to ensure that there is no conflict of interest between the manner of
deployment of its net worth by the AMC and the interest of the Unitholders.
20. The Trustee is required to periodically review the Investor complaints received and the redressal of the same
by the AMC.
21. The Trustee is required to abide by the Code of Conduct as specified in the Fifth Schedule of the
Regulations.
22.. The Trustee has to furnish to SEBI on a half-yearly basis:-
(a)      a report on the activities of the Fund covering the details as prescribed by SEBI;
(b)     a certificate stating that the Trustees have satisfied themselves that there have been no instances
of self dealing or front running by any of the Trustee, directors and key personnel of the AMC;
(c)    a certificate to the effect that the AMC has been managing the schemes independently of any
other activities and in case any activities of the nature referred to in sub Regulation (2) of
Regulation 24 of the Regulations have been undertaken, the AMC has taken adequate steps to
ensure that the interest of the Unitholders is protected
23.. The independent Directors of the Trustee are required to give their comments on the report received from
the AMC regarding the investments by the Mutual Fund in the securities of the group companies of the
sponsors.

Capital Markets
Regulations
27.Trustee shall render at all times high standards of service, exercise due diligence, ensure proper care and
exercise independent professional judgement.
28. The independent directors of the Trustee shall pay specific attention to the following as may be applicable,
namely :
i.      The Investment Management Agreement and the compensation paid under the agreement.
ii.    Service contracts with affiliates – whether the asset management company has charged higher fees
than outside contractors for the same services.
iii.     Selection of the asset management company’s independent directors
iv.     Securities transactions involving affiliates to the extent such transaction are permitted.
v.     Selecting and nominating individuals to fill independent directors vacancies.
vi.    Code of ethics must be designed to prevent fraudulent, deceptive or manipulative practices by insiders
in connection with personal securities transactions.
vii.    The reasonableness of fees paid to sponsors, asset management company and any others for
services provided.
viii.    Principal underwriting contracts and renewals
ix.     Any service contracts with the associates of the asset management company.
29. Notwithstanding anything contained in sub-regulations (1) to (25) of regulation 18 of the Regulations, the
Trustees shall not be held liable for acts done in good faith if they have exercised adequate due diligence
honestly.
30. The Regulations provide that the meetings of the Trustees shall be held at least once in every TWO months
and at least SIX such meetings will be held every year. Further, as per the Regulations, for the purposes of
constituting the quorum for the meetings of the Trustees, at least one Independent Trustee or Director
should be present during such meetings.

Capital Markets
REGULATORY PROVISIONS APPLICABLE TO AMC
APPROVAL FOR AMC IS GIVEN ONLY ON FULFILLING THE FOLLOWING
CRITERIA
a) The directors of the asset management company are persons having adequate
professional experience in finance and financial services related field and not found guilty of
moral turpitude or convicted of any economic offence or violation of any securities laws;
(b) The key personal of the asset management company have not been found guilty of moral
turpitude or convicted of economic offence or violation of securities laws13 [or worked]14 for
any asset management company or mutual fund or any intermediary [during the period
when its]15 registration has been suspended or cancelled at any time by the Board;
(c) The board of directors of such asset management company has at least fifty percent
directors, who are not associate of, or associated in any manner with, the sponsor or any of
its subsidiaries or the trustees;
(d) The Chairman of the asset management company is not a trustee of any mutual fund;
(e) The asset management company has a networth of not less than rupees ten crores:

Capital Markets
Rights and Obligations of the Directors of the AMC under the
Regulations
1.        The duties and responsibilities of the AMC shall be governed by the Regulations and the Investment Management Agreement. The AMC, in
the course of managing the affairs of the Mutual Fund, has the power, inter-alia:
(a) to invest in, acquire, hold, manage or dispose of all or any securities and to deal with, engage in and carry out all other functions and to
transact all business pertaining to the Fund;
(b) to keep the moneys belonging to the Trust with scheduled banks and Custodians as it may deem fit;
(c) to issue, sell and purchase Units under any Scheme;
(d) to repurchase the Units that are offered for repurchase and hold, reissue or cancel them;
(e) to formulate strategies, lay down policies for deployment of funds under various Schemes and set limits collectively or separately fo
privately placed debentures, unquoted debt instruments, securitised debts and other forms of variable securities which are to form part o
the investments of the Trust Funds;
(f) to arrange for investments, deposits or other deployment as well as disinvestment or refund out of the Trust Funds as per the set strategies
and policies;
(g) to make and give receipts, releases and other discharges for moneys payable to the Trust and for the claims and demands of the Trust;
(h) to get the Units under any scheme listed on any one or more stock exchanges in India or abroad;
(i) to open one or more bank accounts for the purposes of the Fund, to deposit and withdraw money and fully operate the same;
(j)             to pay for all costs, charges and expenses, incidental to the administration of the Trust and the management and maintenance of the
Trust property, Custodian and/or any other entities entitled for the benefit of the Fund, audit fee, management fee and other fees;
(k)             to furnish compliance reports to the Trustees as prescribed by SEBI.
(l)              to provide or cause to provide information to SEBI and the Unitholders as may be specified by SEBI and
(m)            to generally do all acts, deeds, matters and things which are necessary for any object, purpose or in relation to the Mutual Fund in any
manner or in relation to any scheme of the Mutual Fund.

Capital Markets
Rights and Obligations of the Directors of the AMC under the Regulations

The Asset Management Company shall maintain high standards of integrity and fairness in all their
dealings and in the conduct of their business.

The Asset Management Company shall render at all times high standards of service, exercise due
diligence, ensure proper care and exercise independent professional judgement.

The independent directors of the Asset Management Company shall pay specific attention to the
following as may be applicable,
namely :
i.     The Investment Management Agreement and the compensation paid under the agreement.
ii.    Service contracts with affiliates – whether the company has charged higher fees than outside
contractors for the same services.
iii.   Securities transactions involving affiliates to the extent such transaction are permitted.
iv.   Code of ethics must be designed to prevent fraudulent, deceptive or manipulative practices
by insiders in connection with personal securities transactions.
v.     The reasonableness of fees paid to sponsors, asset management company and any others
for services provided.
vi.   Principal underwriting contracts and renewals
vii.  Any service contracts with the associates of the company.
In terms of the Investment Management Agreement and the Regulations, the AMC is entitled to an
Investment management fee at 1.25% per annum of the average net assets for a corpus up to
Rs.100 crores and at 1.00% per annum for the corpus amount in excess of Rs.100 crores.

Capital Markets
Sr
no
Designation of
function head
Regulation, rules, codes,
practices and undertakings.
1. Investment •All investments related
matters:
•Regulatory/prudential limits/
•Investment restrictions in
respect of on Fund’s
investments.
•Affiliate transactions.
· Inter scheme transfers.
· Affiliate and non affiliate
broking limits.
· Allocation of trades.
KEY PERSONNEL

Capital Markets
KEY PERSONNEL
2. Operations – • Units creation and redemption.
pricing of securities as per the 3.
Regulations and offer documents of the
schemes,
NAV computation and compliance
withthe accounting policies laid down by
the Regulations, offer documents and
the Trustees.
· adhering to Regulations on custody of
Fund’s securities.
· delivery of customer service as per the
Regulations and the parameters set in
the offer documents of the schemes.
· making disclosure to unit
holders/trustees in regard to affiliate
transactions, and accounting information
relating to the funds.
· Ensuring that the recurring expenses of
the schemes are with in regulatory
limits.
· Regulatory filings.

Capital Markets
KEY PERSONNEL
Sales and
Distribution
Retail
· Compliance with the Regulations in
respect of all matters relating to the
manner and information disclosure
to the investors in connection with
the sales of units of the funds.
· Setting parameters for
empanelling brokers, agents, banks
and other third party distributors.
· Monitoring the selling practices of
distributors.
· Ensuring that the literature and
sales material being distributed by
the sales force conform to the
Regulatory requirements.

Capital Markets
KEY PERSONNEL
4. Marketing. •Ensuring that the
advertisement material, product
literature, brochures etc
conform to the advertisement
guidelines issued under the
Regulations.
· The customer complaints are
redressed quickly.
· The material released to the
Press for publication is in line
with the various terms and
conditions of the schemes and
conforms to Regulatory
requirements.

Capital Markets
KEY PERSONNEL
5. Human
Resources
• Policies for hiring of employees
conform to the regulatory
requirements.
The terms of employment, service
conditions and compensation policies
conform to local laws.
· Policies for deduction of provident
fund, pension and profession tax from
the salaries of employees, remittance
of the same to the appropriate
authorities.
Registration under Shops and
Establishments Act.

· Filing of statutory returns on various
deductions made from the salaries of
employees.

Capital Markets
KEY PERSONNEL
6. Head of
Compliance /
Compliance
officer and
Company
Secretary.
• Ensuring that the business of Mutual
Fund and AMC is conducted as per
the Regulations, professional and
ethical standards as are expected in
mutual fund industry and the
standards set by the Sponsors/
Shareholders/Boards of Management
of AMC and Trust Company.

· Monitoring compliance environment
and overseeing the compliance with
Regulations, internal guidelines and
standards by the departments and
staff of AMC in respect of various
operations and business activities of
AMC/Fund.

· Ensuring that the interests of
investors of the Fund are always
protected and there is no conflict of
interest between the activities of
AMC.

Capital Markets
COMPLIANCE OWNERSHIP CONTD.
Compliance with the provisions of Companies Act in regard to:
•Drawing up and submission of annual accounts of the Company to its
shareholders.
•Convening and holding of Board/Annual/Extra ordinary General meetings.
•Drafting of minutes.
•All matters relating to appointment and election of directors, auditors Filing
of statutory returns and final accounts.
•Monitoring personal trades of employees and Insider Trading Regulations.
•Comprehensive review of AMC and Trustee obligations.

Capital Markets
Compliance environment:
Existing regulatory environment:
Nature of business activities Name of the Regulator
Mutual fund business and
Portfolio Management Activities
Securities and Exchange Board of India.
Public Limited Companies and all
matters relating to Companies
Act, 1956.
Registrar of Companies, Department of Company Affairs,
Government of India.
Revenue and Income Tax. Central Board of Direct Taxes, Commissioner of Income Tax,
Mumbai.
Human Resources Provident Fund Commissioner (for provident fund
deductions/remittances), respective Municipal
Corporations( for deduction and remittance of profession tax)
where the sales offices and Corporate office are located.
Foreign Exchange and all related
matters.
Reserve Bank of India.
Customer complaints Consumer forums of respective areas.

Capital Markets
SEBI is the prime Regulator.
Securities and Exchange Board of India (Mutual Funds) Regulations, 1996
govern Fund operations.
Regulations are comprehensive and encompass all critical areas.
Aims at protecting the interests of investors and promoting development of
Fund industry.
Companies Act, Income-tax Act, Foreign Exchange Management Act are
some of the other legislations.
Regulatory Environment

Capital Markets
Compliance Objectives

Mission Statement for Compliance Function

“The Compliance Function will strive to ensure that the customers of the
Fund are treated fairly and with professional skill. The Compliance Function is
committed to add value to the operations of the AMC and implement the best
practices in the interest of the customers of the Fund”.

Capital Markets
Ownership and understanding of Compliance
Business Commitment to compliance and principle of investor protection
Mutual Fund operations in India are governed by the Securities and Exchange Board of India
(Mutual funds) Regulations 1996, as amended from time to time, the applicable guidelines issued
by SEBI and Reserve Bank of India. The AMC has the primary responsibility to ensure that the
regulations are complied with in letter and spirit and that highest professional and ethical
standards are maintained in carrying out the AMC’s business. The Trustees of the Mutual Fund, in
discharge of their fiduciary responsibility, shall have to ensure that the various activities of the
AMC are in the best interests of the unit holders or the customers of the Fund and that the
operations of the AMC are in conformity with the regulatory provisions, norms and guidelines
(Regulations).
Compliance risk arises if the Regulations are not complied with either partially or fully and are
breached in spirit. This will lead to impairment of the reputation and integrity of Peerless Group
Non compliance with the Regulations will also result in regulatory strictures, fines and penalties on
AMC and in extreme cases of regulatory breaches suspension of the license of the AMC to carry
on the asset management business. The Regulations make the AMC liable to make good any
loss that a unit holder may suffer due to the failure of AMC to comply with Regulations, lack of
professional skill and integrity. The Regulations further make it clear that the employees of the
AMC are responsible for omissions and commissions.

Capital Markets
Ownership for setting and developing compliance standards.
The Function Head or Chief Officer of each function in coordination with the Compliance Head is
primarily responsible for upholding the compliance culture of the AMC, carry out the day to day
activities according to the Regulations, standards and internal guidelines set by the Board of the
Company. Each functional head is responsible, inter alia, to proactively develop and devise
compliance processes and institute suitable mechanism for monitoring that such compliance
processes are being adopted and followed by the staff of the functional unit.
It is also the responsibility of Head of each functional Unit to keep himself/herself abreast of the
on going changes in the compliance environment, the Regulations that impact his/her functional
area and accordingly revise the existing processes and guidelines for adoption by the department
staff. Needless to state, such initiatives, where necessary will be carried out with the assistance of
Compliance Head.

Capital Markets
To sum up, Consistent with the Compliance principles:
• ·  Ultimate and collective responsibility for compliance rests with the C. E. O. and
the Board of AMC.
•·   The Head of Compliance function in overseeing/reviewing the Compliance frame work and
procedures and assisting the Managing Director and Corporate Boards of AMC and Trust
Company.
•·    The Heads of the Department at Corporate Office for their respective
functions/activities/operations at Corporate/ Zonal/ Branch/Sales Offices.
•·    The Zonal Managers/Branch in charges for all the functions/ activities carried out in their
respective offices/locations.
Further, the Heads of the Departments (HODs) at Corporate Office will have responsibility for
their respective functions both at the Corporate office and the Zonal/Branch offices. HODs shall
ensure that in these offices all applicable Regulations relating to their function are complied
with. HODs, for this purpose, in co ordination with the Zonal/Sales offices, where necessary,
will furnish to the Compliance function information/reports and confirmations as may be
required by the Compliance function from time to time.
The Zonal/Branch Managers will primarily be responsible and accountable for ensuring
compliance with the Regulations in their respective jurisdictions. They will also assist the HODs
by furnishing the data/information as required by the HODs.

Capital Markets
JUST A FLAVOUR OF WHAT REGULATION PRESCRIBES
SAMPLE - INVESTMENT RESTRICTIONS ON MUTUAL FUNDS
A mutual fund scheme shall not invest more than 15% of its NAV in debt
instruments issued by a single issuer which are rated not below investment
grade by a credit rating agency authorised to carry out such activity under the
Act. Such investment limit may be extended to 20% of the NAV of the scheme
with the prior approval of the Board of Trustees and the Board of asset
management company.
Provided that such limit shall not be applicable for investments in government
securities and money market instruments.
[Provided further that investment within such limit can be made in mortgaged
backed securitised debt which are rated not below investment grade by a credit
rating agency registered with the Board.]72

Capital Markets
1A. A mutual fund scheme shall not invest more than 10% of its NAV in unrated
debt instruments issued by a single issuer and the total investment in such
instruments shall not exceed 25% of the NAV of the scheme. All such
investments shall be made with the prior approval of the Board of Trustees and
the Board of asset management company]73
.
2. No mutual fund under all its schemes should own more than ten per cent of
any company's paid up capital carrying voting rights.
3. Transfers of investments from one scheme to another scheme in the same
mutual fund shall be allowed only if, -
a. such transfers are done at the prevailing market price for quoted
instruments on spot basis.
[Explanation - "spot basis" shall have same meaning as specified by stock
exchange for spot transactions.]74
(b) the securities so transferred shall be in conformity with the investment
objective of the scheme to which such transfer has been made.

Capital Markets
4. A scheme may invest in another scheme under the same asset management
company or any other mutual fund without charging any fees, provided that
aggregate interscheme investment made by all schemes under the same
management or in schemes under the management of any other asset
management company shall not exceed 5% of the net asset value of the
mutual fund.

5. Every mutual fund shall buy and sell securities on the basis of deliveries
and shall in all cases of purchases, take delivery of relative securities and in
all cases of sale, deliver the securities and shall in no case put itself in a
position whereby it has to make short sale or carry forward transaction or
engage in badla finance.
[Provided that mutual funds shall enter into derivatives transactions in a
recognised stock exchange for the purpose of hedging and portfolio
balancing, in accordance with the guidelines issued by the Board.]75

Capital Markets

6. Every mutual fund shall, get the securities purchased or transferred
in the name of the mutual fund on account of the concerned scheme,
wherever investments are intended to be of long term nature.
7. No mutual fund [scheme]76
shall make any investment in;
a) any unlisted security of an associate or group company of the
sponsor; or
b) any security issued by way of private placement by an associate
or group company of the sponsor; or
c) the listed securities of group companies of the sponsor which is in
excess of 25% of the net assets [***]77
}78

Capital Markets
[8. No mutual fund scheme shall invest more than 10 per cent of its NAV
in the equity shares or equity related instruments of any company.
Provided that, the limit of 10 per cent shall not be applicable for
investments [in case of]79
index fund or sector or industry specific scheme.

9.[ A mutual fund scheme shall not invest more than 5% of its NAV in the
unlisted equity shares or equity related instruments in case of open ended
scheme and 10% of its NAV in case of close ended scheme.]80

Capital Markets
Reporting Requirements
To the Regulator
– SEBI, Reserve Bank of India
To the Sponsor
– Mahindra & Mahindra Financial Services Company Limited
– Mahindra Trustee Co Pvt Ltd
To the Investors/Existing Unit-holders

Capital Markets
Compliance requirements to Unit-
holders
NAV related compliances
– Computation
– Publication as specified in the offer document (in newspaper)
– Display on Notice Board
– Display on Web-site (AMFI and AMC)
– On IVR
Dispatch of Redemption Warrants within 10 days of receipt of
redemption request.
Delay and result in penal interest @ 15% p.a.
Dispatch of Dividend Warrant within 30 days of the date of declaration.

Capital Markets
Compliance requirements to Unit-
holders
Providing Account Statements.
Providing disclosures in the Offer Documents for taking investment
decisions.

Capital Markets
Other Disclosures
Scheme Portfolio : Half-yearly - within 30 days of the end of half year
Publication of Half-yearly unaudited Results - within one month of
closure
Annual Report - By 30 Sept.
In case of change in fundamental attributes of the Scheme - newspaper
ad, written communication to each unit-holder and exit option without
exit load.

Capital Markets
Compliance Reporting to SEBI
Quarterly Compliance Test Report
Quarterly Net Asset and Portfolio Movement
Half-yearly Compliance Report by Trustees
Advertisement within 7 days of publication
Monthly Cumulative Mobilisation Report
Annual Statistical Report
New Schemes Report

Capital Markets
Compliance Reporting to Trustee
Quarterly Report on MF operations
Quarterly Compliance Report
Half-yearly Compliance Report to Trustees
Bi-Monthly Compliance Certificate
Associate Transactions Report
Report on Unit-holders holding more than 5% NAV per scheme
Securities Transactions of Key personnel

DIRECTOR_PRESENTATION_-_NEERAJ

Recommended

Recommended

More Related Content

What's hot

What's hot (20)

Viewers also liked

Viewers also liked (12)

Similar to DIRECTOR_PRESENTATION_-_NEERAJ

Similar to DIRECTOR_PRESENTATION_-_NEERAJ (20)

DIRECTOR_PRESENTATION_-_NEERAJ