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INVESTMENT STRATEGY INFORMATION DOCUMENT
SO.1
SECTION I
WSIF Hybrid Long-Short Fund
(An Interval investment strategy investing in equity and debt securities, including limited short
exposure in equity and debt through derivatives.)
Scrip Code NSE: Scrip code to be updated at the time of listing of units of Investment Strategy
This product is suitable for Risk-band** Benchmark Risk- band -
investors who are seeking* NIFTY 50 HYBRID
SO.3
COMPOSITE DEBT 50:50
INDEX
• Long term Capital
appreciation
• An Interval investment
strategy investing
predominantly in equity
and debt securities,
including limited short Risk band Level 2 Risk band Level 2
exposure in equity and
debt through derivatives.
*Investors should consult their financial advisers if in doubt about whether the product is suitable for them
**The Risk Band has been as specified by AMFI.
The above Product labelling assigned during the New Fund Offer (NFO) is based on internal assessment of
the investment strategy characteristics or model portfolio and the same may vary post NFO when the actual
investments are made.
Offer of units of Rs.10 each for cash during the New Fund Offer and Continuous offer for Units at NAV based
prices.
New Fund Offer Opens on:
New Fund Offer Closes on:
Investment strategy re-opens on: Investment Strategy will re-open for continuous Sale and
Repurchase within 5 business days from the date of allotment of units under NFO
Name of SIF WSIF (offered by The Wealth Company Mutual Fund)
Name of the Mutual The Wealth Company Mutual Fund
Fund
Name of Asset Wealth Company Asset Management Holdings Private Limited
Management Company
Name of Trustee Pantomath Trustee Private Limited
Company
Address, Website of the Pantomath Nucleus House, Saki-Vihar Road, Andheri east,
entities (including SIF) Mumbai – 400 072
https://www.wealthcompanyamc.in/wsif/
1The particulars of the investment strategy have been prepared in accordance with the Securities and
Exchange Board of India (Mutual Funds) Regulations 2026, (herein after referred to as SEBI (MF)
Regulations) as amended till date and circulars issued thereunder filed with SEBI, along with a
Due Diligence Certificate from the AMC. The units being offered for public subscription have not been
approved or recommended by SEBI nor has SEBI certified the accuracy or adequacy of the Investment
Strategy Information Document.
The Investment Strategy Information Document sets forth concisely the information about the investment
strategy that a prospective investor ought to know before investing. Before investing, investors should also
ascertain about any further changes to this Investment Strategy Information Document after the date of this
Document from the SIF/Mutual Fund / Investor Service Centers / Website / Distributors or Brokers.
The investors are advised to refer to the Statement of Additional Information (SAI) for details of WSIF,
Mutual Fund, Standard Risk Factors, Special Considerations, Tax and Legal issues and general
information on https://www.wealthcompanyamc.in/wsif/
SAI is incorporated by reference (is legally a part of the Investment Strategy Information Document).
For a free copy of the current SAI, please contact your nearest Investor Service Centre or log on
to our website https://www.wealthcompanyamc.in/wsif/
The Investment strategy Information Document (Section I and II) should be read in conjunction
with the SAI and not in isolation.
Investors are advised to note that 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.
Disclaimer by National Stock Exchange of India Limited (NSE)
As required, a copy of this Investment Strategy Information Document has been submitted to
National Stock Exchange of India Limited (hereinafter referred to as NSE). NSE has given vide its
letter NSE/LIST/6010 dated February 13, 2026, permission to the Mutual Fund to use the Exchange's
name in this Investment Strategy Information Document as one of the stock exchanges on which the
Mutual Fund's units are proposed to be listed subject to, the Mutual Fund fulfilling various criteria for
listing. The Exchange has scrutinized this Investment Strategy Information Document for its limited
internal purpose of deciding on the matter of granting the aforesaid permission to the Mutual Fund.
It is to be distinctly understood that the aforesaid permission given by NSE should not in any way be
deemed or construed that the Investment Strategy Information Document has been cleared or
approved by NSE; nor does it in any manner warrant, certify or endorse the correctness or
completeness of any of the contents of this Investment Strategy Information document; nor does it
warrant that the Mutual Fund's units will be listed or will continue to be listed on the Exchange; nor
does it take any responsibility for the financial or other soundness of the Mutual Fund, its sponsors,
its management or any scheme of the Mutual Fund.
Every person who desires to apply for or otherwise acquire any units of the Mutual Fund may do so
pursuant to independent inquiry, investigation and analysis and shall not have any claim against the
Exchange whatsoever by reason of any loss which may be suffered by such person consequent to
or in connection with such subscription /acquisition whether by reason of anything stated or omitted
to be stated herein or any other reason whatsoever.
This Investment Strategy Information Document is dated , 2026.
2INDEX
SECTION I .............................................................................................................................................................. 4
PART I. HIGHLIGHTS/SUMMARY OF THE INVESTMENT STRATEGY .............................................................. 4
DUE DILIGENCE BY THE ASSET MANAGEMENT COMPANY ....................................................................... 10
PART II. INFORMATION ABOUT THE INVESTMENT STRATEGY ................................................................... 11
A. HOW WILL THE INVESTMENT STRATEGY ALLOCATE ITS ASSETS? ....................................................... 11
B. WHERE WILL THE INVESTMENT STRATEGY INVEST? .............................................................................. 14
C. WHAT IS THE INVESTMENT APPROACH?................................................................................................... 15
D. HOW WILL THE INVESTMENT STRATEGY BENCHMARK ITS PERFORMANCE? ..................................... 16
E. WHO MANAGES THE INVESTMENT STRATEGY? ....................................................................................... 17
F. HOW IS THE INVESTMENT STRATEGY DIFFERENT FROM EXISTING INVESTMENT
STRATEGIES OF THE SIF?....................................................................................................................... .. 17
G. HOW HAS THE INVESTMENT STRATEGY PERFORMED (IF APPLICABLE) .............................................. 17
H. ADDITIONAL INVESTMENT STRATEGY RELATED DISCLOSURES ........................................................... 17
PART III- OTHER DETAILS ................................................................................................................................. 19
A. COMPUTATION OF NAV ................................................................................................................................ 19
B. NEW FUND OFFER (NFO) EXPENSES ......................................................................................................... 20
C. ANNUAL RECURRING EXPENSES ............................................................................................................... 20
D. LOAD STRUCTURE ........................................................................................................................................ 22
SECTION II ........................................................................................................................................................... 24
I. INTRODUCTION .............................................................................................................................................. 24
A. DEFINITIONS/INTERPRETATION .................................................................................................................. 24
B. RISK FACTORS .............................................................................................................................................. 24
II. INFORMATION ABOUT THE INVESTMENT STRATEGY: ............................................................................. 33
A. WHERE WILL THE INVESTMENT STRATEGY INVEST ................................................................................................................. 33
B. WHAT ARE THE INVESTMENT RESTRICTIONS? ........................................................................................................................... 43
C. FUNDAMENTAL ATTRIBUTES .............................................................................................................................................................. 52
D. OTHER INVESTMENT STRATEGY SPECIFIC DISCLOSURES ................................................................................................... 53
III. OTHER DETAILS ............................................................................................................................................ 69
A. PERIODIC DISCLOSURES SUCH AS HALF YEARLY DISCLOSURES, HALF YEARLY RESULTS,
ANNUAL REPORT ......................................................................................................................................................................................69
B. SCENARIO ANALYSIS FOR DERIVATIVES POSITIONS ............................................................................................................... 71
C. LIQUIDITY RISK MANAGEMENT TOOLS AND ITS APPLICABILITY ........................................................................................... 72
D. TRANSPARENCY/NAV DISCLOSURE ............................................................................................................................................... 73
E. TRANSACTION CHARGES AND STAMP DUTY ............................................................................................................................... 73
F. ASSOCIATE TRANSACTIONS ............................................................................................................................................................... 73
G. TAXATION .................................................................................................................................................................................................... 73
H. RIGHTS OF UNITHOLDERS ................................................................................................................................................................... 75
I. LIST OF OFFICIAL POINTS OF ACCEPTANCE .................................................................................................................................. 75
J. PENALTIES, PENDING LITIGATION OR PROCEEDINGS, FINDINGS OF INSPECTIONS OR INVESTIGATIONS
FOR WHICH ACTION MAY HAVE BEEN TAKEN OR IS IN THE PROCESS OF BEING TAKEN BY ANY
REGULATORY AUTHORITY ..................................................................................................................................................................... 75
3SECTION I
PART I. HIGHLIGHTS/SUMMARY OF THE INVESTMENT STRATEGY
Sr. Title Description
No.
Name of the WSIF Hybrid Long-Short Fund
I.
Investment Strategy
Category of the Hybrid Long-Short Fund
II.
Investment Strategy
III. Type of Investment Interval investment strategy investing in equity and debt securities,
Strategy including limited short exposure in equity and debt through
derivatives.
IV. Investment strategy (To be disclosed after obtaining investment strategy code)
code SO.7
Investment objective
The primary objective of the investment strategy is to generate capital
appreciation through equity and equity related instruments and
income through arbitrage, derivatives strategies, special situations
V.
and fixed income investments.
There is no assurance that the investment objective of the Investment
strategy will be achieved.
SO.5
VI. Liquidity/listing Through Stock Exchanges (for units held in demat mode):
details Currently, the Investment Strategy is proposed to be listed on
National Stock Exchange of India Limited (NSE). Buying or selling of
units of the Investment Strategy by investors can be done on all the
Trading Days of the stock exchanges. The minimum number of units
that can be bought or sold is 1 (one) unit.
Further, the Investment strategy offers redemptions / switch out
facility twice a week (Every Monday and Every Wednesday*)
*Next business day in case Monday and Wednesday is a non-
business day
VII. Benchmark (Total NIFTY 50 HYBRID COMPOSITE DEBT 50:50 INDEX SO.25
Return Index)
Justification:The selected benchmark is comparable with the
investment objective of the fund since the investment strategy is
focused toward generating returns over the medium to long term
through a combination of capital appreciation and income by
investing in equity & equity related and fixed income instruments.
The Trustee reserve the right to change the benchmark if due to a
change in market conditions, a different index /indices appears to
provide a more appropriate basis for comparison of performance of
Investment Strategy.
VIII. Subscription Daily (only Business days)
frequency
IX. Redemption Every Monday and Wednesday* of the week.
frequency
*Next business day in case Monday and Wednesday is a non-business
day.
Redemption requests for unitholders holding units in physical mode
can be submitted to the Fund during the Redemption frequency
For investors holding units in demat mode, they shall submit the
redemption request the Redemption frequency to the depository
participant (DP). Such request accepted and processed by the DP
shall be recognized by the Registrar and Transfer Agent (RTA) for
changes in the beneficiary position (BENPOS) on the NAV date.
Accordingly, redemption proceeds shall be paid to the unitholders
4whose names are appearing in the BENPOS on the NAV date.
Investors wishing to purchase/redeem on dates other than
subscription dates or the notice period may do so, in demat mode, by
transacting through National Stock
Exchange of India Ltd. or any of the stock exchange(s) where
the strategy will be listed as the Trustee may decide from time
to time.
Investors shall note that the brokerage on sale of the units of the
strategy on the stock exchanges shall be borne by the investors.
For units bought/sold on the exchange, settlement of the trade shall
be as per settlement cycle of the NSE.
The Trustees reserves the right to suspend/deactivate/freeze trading,
ISIN of the Strategy at any time. The Fund will, under normal
circumstances, endeavour to dispatch redemption proceeds within 3
Business Days from the date of request for redemption.
In case of switch-out request for investment in a New Fund
Offers/open- ended Strategy, the request shall be processed only
if it coincides with the New Fund Offer period or it being a business
day in the Target open- ended strategy. This facility is not applicable
for Units held in demat form.
NAV disclosure The AMC will prominently calculate and disclose the first NAV under
X. the Investment Strategy not later than 5 Business Days from the
date of allotment under the NFO.
The AMC will calculate and disclose the NAVs on all Business Days.
The AMC shall update the NAVs on website of the Association of
Mutual Funds in India - AMFI (www.amfiindia.com) before 11.00 p.m.
on every Business Day and shall also update the NAVs on the
website of AMC https://www.wealthcompanyamc.in/wsif/ before
11.00 p.m. on every Business Day.
Further Details in Section II. SO.41
XI. Applicable timelines Time line for:
Dispatch of redemption proceeds: The Fund will, under normal
circumstances, endeavor to dispatch redemption proceeds within 3
Business Days from the date of redemption or repurchase.
Further, in exceptional situations additional timelines in line with
AMFI letter no. AMFI/35P/MEM -COR/74/2022-23 dated January
16, 2023 will be applicable for transfer of redemption or repurchase
proceeds to the unitholders.
Dispatch of IDCW (if applicable): Within 7 working days from the
record date.
XII. Plans and Options Investors are offered the following Investment Plan(s) to invest
in the Investment strategy:
Plans/Options and sub
options under the Each Plan offers Regular Plan and Direct Plan.
Investment strategy
i. Direct Plan: Direct Plan is only for investors who purchase
/subscribe Units in Investment strategy directly with the Fund and is
not available for investors who route their investments through a
Distributor.
ii. Regular Plan: Regular Plan is available for all types of investors
investing through a Distributor.
All the plans will have common portfolio.
Options under each Plan(s) –
5i. Growth
ii. Income Distribution cum Capital Withdrawal (IDCW) (Payout
and Re- investment Facility)
Default Plan Options –
- Between “Growth” or “IDCW” option, the default will be treated
as “Growth”.
- In “IDCW” option between “IDCW Payout” or “IDCW
Reinvestment”, the default will be treated as “IDCW Reinvestment”
For detailed disclosure on default plans and options, kindly refer SAI.
XIII. Load Structure Exit Load: NIL.
The AMC reserves the right to modify / change the load structure
on a prospective basis.
XIV. Minimum Application Minimum amount of initial investment during NFO and On an
Amount/Switch in Ongoing basis under all Plans and Options:
• During NFO: Rs.10,00,000/- and in multiples of Re. 100/-
thereafter
• On continuous basis: Rs.10,00,000/- and in multiples of Re.
100/- thereafter
• Minimum amount for accredited investor during NFO and
Continuous basis: Rs.1,00,000/- and in multiples of Re. 100/-
thereafter.
Systematic Investment Plan (SIP) / Systematic Withdrawal Plan
(SWP) /Systematic Transfer Plan (STP) shall only commence upon
re-opening of the Investment Strategy.
The clauses on SWP and STP will be subject to compliance with
provisions mentioned under “Minimum investment threshold” as
stated under Clause “Minimum threshold requirement and
consequences of non- maintenance” of this ISID.
Note:
Allotment of units will be done after deduction of applicable stamp
duty.
SIP Rs. 1000/- and in multiples of Re. 100 thereafter
[Minimum 6 installments]
SWP Rs. 1000/- and in multiples of Re. 100 thereafter
[Minimum 6 installments]
STP Rs. 1000/- and in multiples of Re. 100 thereafter
[Minimum 6 installments]
*As per Clause 21.4 of SEBI master Circular dated March 20, 2026
with respect to Regulatory Framework for Specialized Investment
Funds (‘SIF’), the aggregate investment by an investor across all
investment strategies offered by the SIF, at the Permanent Account
Number (‘PAN’) level, shall not less be than INR 10 lakh. Accordingly,
an existing investor under WSIF shall have an option to invest such
amount as stated under the clause “minimum additional purchase
amount” below.
6XV. Minimum Additional Rs. 10,000/- and in multiples of Re. 100/- thereafter
Purchase Amount
XVI. Minimum There will be no minimum redemption criterion. The Redemption /
Redemption/switch Switch out would be permitted to the extent of credit balance in the
Unit holder’s account of the Plan(s) / Option(s) of the Scheme
(subject to release of pledge / lien or other encumbrances).
Amount based redemptions will be in multiples of Re. 1.
In case of Units held in dematerialized mode, the Unit Holder can
give a request for Redemption only in number of Units which can
be fractional units also. Depository participants of registered
Depositories can process only redemption request of units held in
demat mode.
The AMC/ Trustee reserves the right to change/ modify the terms
of minimum redemption amount/switch-out.
XVII. Notice Period Every Monday and Every Wednesday*of the week.
*Next business day in case Monday and Wednesday is a
non-business day.
XVIII. New Fund Offer Period NFO Opens on:
SO.34
This is the period during NFO Closes on:
which a new investment
strategy sells its units to Minimum duration to be 3 working days and will not be kept open for
the investors. more than 15 days.
Any changes in dates will be published through notice on AMC
SIF website i.e. https://www.wealthcompanyamc.in/wsif/
XIX. New Fund Offer Price: Rs. 10/- per unit
This is the price per unit
that the investors have to
pay to invest during the
NFO.
XX. Segregated portfolio/ The AMC / Trustee shall decide on the creation of segregated
side pocketing portfolio of the Investment strategy in case of a credit event/actual
disclosure default at issuer level. Accordingly, Investor holding units of
segregated portfolio may not able to liquidate their holding till the
time recovery of money from the issuer.
SO.53
For Details, kindly refer SAI.
XXI. Swing pricing Not Applicable.
SO.54
disclosure
XXII. Stock lending/short Stock Lending by the Investment Strategy
selling The Investment Strategy shall adhere to the following limits should
it engage in Stock Lending:
1. Not more than 20% of the net assets of the Investment Strategy
can generally be deployed in Stock Lending.
2. Not more than 5% of the net assets of the Investment Strategy
can generally be deployed in Stock Lending to any single
approved intermediary i.e the limit of 5% will be at broker level.
Short Selling by the Investment Strategy
The Investment Strategy may engage in short selling of securities in
accordance with the framework relating to Short Selling as specified
by SEBI.
For Details, kindly refer SAI
7XXIII. How to Apply Investors can obtain application forms and Key Information
SO.35
Memorandum from the Official Points of Acceptance (OPAs) of
AMC and RTA’s (KFin) branch office. Investors can also download
application form / Key Information Memorandum or apply through
the website of SIF viz. https://www.wealthcompanyamc.in/wsif/
Applications for purchase/redemption/switches to be submitted at
any of the Designated Investor Service Centers (DISC) mentioned
in this Scheme Information Document or any other location
designated as such by the AMC, at a later date. The addresses of
the DISC are given on the website
https://www.wealthcompanyamc.in/wsif/
Investors in cities other than where the DISC are located, may
forward their application forms to any of the nearest DISC, or apply
online on our website https://www.wealthcompanyamc.in/wsif/
More Details in section II.
XXIV. Investor services Contact details for general service requests & complaint resolution:
Investors may contact at toll free number 1800 267 3454
Email: investorcare@wealthcompany.in
Investor Relations Officer:
Mr. Sachin Shah
Wealth Company Asset Management Holdings Private Limited
Pantomath Nucleus House, Saki Vihar Road, Andheri East,
Mumbai – 400072
Email: investorcare@wealthcompany.in
The AMC will at all times endeavor to handle transactions efficiently
and to resolve any investor grievances promptly.
For any grievances with respect to transactions through Stock
Exchange Platform for Mutual Funds, the investors should
approach either the stockbroker or the investor grievance cell of the
respective stock exchange.
It may be noted that all grievances/ complaints with regard to demat
mode of holding shall be routed only through the DP/NSDL/CDSL.
Please refer Investor Charter in our Website for more and latest
information about Grievance Redressal Mechanism, Service
Standards, etc.
Investors also have an option to approach SEBI, by logging a
complaint on SEBI’s complaints redressal system (SCORES 2.0),
the website address is: https://scores.sebi.gov.in.
In addition to SCORES, investors can go for online dispute
resolution (ODR) mechanism https://smartodr.in/login, which
includes mediation and/or conciliation and/or arbitration, in
accordance with the procedure specified by the SEBI.
For any grievances with respect to transactions through
NSE/BSE, the investors/Unit Holders should approach the
investor grievance cell of the
stock exchange.
XXV. Specific attribute of the WSIF Hybrid Long-short Fund is an Interval Fund with stipulated
investment strategy (such frequencies for redemption
as lock-in, duration in case
of close ended investment
8strategies as applicable)
XXVI. Special product / facility The Investment Strategy offers following facilities during NFO:
available during the NFO 1. Systematic Investment Plan
and on ongoing basis For investors, the SIF offers a Systematic Investment Plan (SIP) at
all our Official point of acceptance of the AMC locations. Under this
Facility, an investor can invest a fixed amount per frequency.
The Investment Strategy offers daily, weekly, fortnightly, monthly or
quarterly Systematic Investment Plan.
On continuous basis:
Systematic Investment Plan (SIP) / Systematic Withdrawal Plan
(SWP)
/Systematic Transfer Plan (STP) shall only commence upon re-
opening of the Investment Strategy.
(i) Systematic Investment Plan - daily, weekly, fortnightly, monthly or
quarterly
(ii) Systematic Withdrawal Plan - monthly, quarterly
(iii) Systematic Transfer Plan - daily, weekly, fortnightly, monthly,
quarterly basis
SIP Rs. 1000/- and in multiples of Re. 100 thereafter
[Minimum 6 installments]
SWP Rs. 1000/- and in multiples of Re. 100 thereafter
[Minimum 6 installments]
STP Rs. 1000/- and in multiples of Re. 100 thereafter
[Minimum 6 installments]
Applications Supported by Blocked Amount (ASBA) facility
ASBA facility will be provided to the investors subscribing to NFO of
the Investment Strategy. It shall co-exist with the existing process,
wherein cheques / demand drafts are used as a mode of payment.
Please refer ASBA application form for detailed instructions.
Stock Exchange Infrastructure Facility*:
The investors can subscribe to the Units of the Investment Strategy
through Mutual Fund Service System (“MFSS”) platform of National
Stock Exchange and “BSEStAR MF” platform of Bombay Stock
Exchange Ltd.
MF Utility (MFU)*:
Investor can also subscribe to the Units of the Investment Strategy
through MFU which allows transacting in multiple Investment
Strategies of various Specialized Investment Funds with a single
form / transaction request and a single payment instrument /
instruction. The list of Point of Services of MFUI is published on the
website of MFUI at http://www.mfuindia.com/ and may be updated
from time to time.
Further, Systematic Investment Plan (SIP) / Systematic Withdrawal
Plan (SWP) / Systematic Transfer Plan (STP) facilities would be
available to the investors. For further details of above special products /
facilities, investors/ unit holders are kindly requested to refer SAI.
*If these are offered by the respective intermediaries and permitted
by SEBI
XXVII. Weblink TER for last 6 months, Daily TER and Investment strategy factsheet
are not applicable as this is a new investment strategy.
Refer https://www.wealthcompanyamc.in/wsif/ for these
details.
9DUE DILIGENCE BY THE ASSET MANAGEMENT COMPANY SO.55
It is confirmed that:
(i) The Investment Strategy Information Document submitted to SEBI is in accordance with the SEBI
(Mutual Funds) Regulations, 2026 and the guidelines and directives issued by SEBI from time to
time.
(ii) All legal requirements connected with the launching of the Investment strategy as also the guidelines,
instructions, etc., issued by the Government and any other competent authority in this behalf, have
been duly complied with.
(iii) The disclosures made in the Investment Strategy Information Document are true, fair and adequate to
enable the investors to make a well informed decision regarding investment in the Investment Strategy.
(iv) The intermediaries named in the Investment Strategy Information Document and Statement of
Additional Information are registered with SEBI and their registration is valid, as on date.
(v) The contents of the Investment Strategy Information Document including figures, data, yields etc. have
been checked and are factually correct
(vi) A confirmation that the AMC has complied with the compliance checklist applicable for Investment
Strategy Information Document other than cited deviations/ that there are no deviations from the
regulations
(vii) Notwithstanding anything contained in this Investment Strategy Information Document, the provisions
of the SEBI (Mutual Funds) Regulations, 2026 and the guidelines there under shall be applicable.
(viii) The Trustees have ensured that the WSIF Hybrid Long-Short Fund approved by them is a new product
offered by WSIF and is not a minor modification of any existing Investment Strategy.
SO.63
Sd/-
Suruchi Wanare
Chief Compliance Officer
Place: Mumbai
10PART II. INFORMATION ABOUT THE INVESTMENT STRATEGY
A. HOW WILL THE INVESTMENT STRATEGY ALLOCATE ITS ASSETS?
This includes asset allocation table giving the broad classification of assets and indicative exposure level in
percentage terms. The asset allocation should be consistent with the investment objective of the Investment
Strategy and SEBI circular on Regulatory framework for Specialized Investment Funds (SIF).
Under normal circumstances, asset allocation will be as follows:
Instruments Indicative allocations (% of total assets)
Minimum Maximum
Investment in equity and equity-related instruments 25% 75%
Investment in debt and money market instruments 25% 75%
Short exposure through unhedged derivative 0 25%
positions in equity and debt instruments
Investment in InVITs 0 20%
Money Market instruments includes commercial papers, commercial bills, treasury bills, Tri-party repo,
Government securities having an unexpired maturity up to one year, call or notice money, certificate of deposit,
usance bills, and any other like instruments as specified by the Reserve Bank of India from time to time.
In accordance with clause 13.18.1 of the SEBI Master Circular for Mutual Funds (‘Master Circular’) dated March
20, 2026, 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, Infrastructure
Investment Trusts (InvITs), other permitted securities/assets and such other securities/assets as may be
permitted by SEBI from time to time should not exceed 100% of the net assets of the investment strategy.
SO.1
SO.19
7
Indicative Table (Actual instrument/percentages may vary subject to applicable SEBI circulars)
SO.18
SI. Type of Instrument Percentage of exposure Circular references
NO
1 Securities Lending The Investment strategy shall adhere to Clause 13.6 of SEBI Master
the following limits should it engage in Circular on Mutual Funds dated
Stock Lending: March 20, 2026
1. Not more than 20% of the net assets
of the Investment strategy can
generally be deployed in Stock
Lending.
2. Not more than 5% of the net assets
of the Investment strategy can
generally be deployed in Stock
Lending to any single approved
intermediary i.e the limit of 5% will be
at broker level.
2 Derivatives for non- Long: Upto 50% Clause 8.5 and 13.15 of SEBI
hedging and other than Master Circular dated March
for portfolio rebalancing Unhedged Short Exposure: Upto 25% 20, 2026
purposes
Clause 21.6.1 of SEBI Master
SO.20 Circular dated March 20,
2026
3. Securitized Debt Upto 25% of debt portion of the Clause 13.1 and 21.5 of SEBI
investment strategy Master Circular on Mutual
11Funds dated March 20, 2026
4. InVITS Upto 20% of the net assets of the clause 21.5 of SEBI Master
Investment strategy and not more circular dated March 20, 2026
than 10 per cent of its NAV in the
units of InvIT issued by a single
issuer.
5. Debt Instruments having Upto 10% of debt portfolio of the point 9 & 10 of clause 13.1 of
Structured Obligation (SO Investment strategy SEBI Master circular,
rating) and / or Credit March 20, 2026
Enhancements (CE rating)
and Debt Instruments with
special features i.e.
Additional Tier I (AT1)/
Perpetual Bonds and
Tier 2 Bonds
6. Triparty Repo (TREPS) on To meet liquidity requirements or In line with the Asset Allocation
Government securities or pending deployment as per of the scheme
treasury regulatory limits
bills.
7. Repo/ reverse repo Not exceeding 10% of the net Clause 13.8 of SEBI Master
transactions in corporate assets of the investment strategy Circular for Mutual Funds dated
debt securities March 20, 2026.
8. Credit Default Swaps Exposure to a single counterparty in Clause 13.17 of the SEBI
CDS transactions shall not exceed Master Circular for Mutual
10% of the net assets of the Funds dated March 20, 2026.
Investment strategy.
The total exposure related to premium
paid for all derivative positions,
including CDS, shall not exceed 20%
of the net assets of the Investment
strategy.
9. Hedged positions in Upto 100 % of the net assets of the -
equity and debt investment strategy
The investment strategy shall not invest in following:
Overseas securities
As per clause 13.18.6 of SEBI Master Circular dated March 20, 2026 , Cash or cash equivalents with residual maturity
of less than 91 days may be treated as not creating any exposure. SEBI vide letter dated November 3, 2021 has
clarified that Cash Equivalent shall consist of Government Securities, T-Bills and Repo on Government Securities.
SO.14
The fund will use any of the following strategies for portfolio construction / rebalancing i.e. an unhedged long-only
portfolio, partially-hedged long-only portfolio using index / stock futures or index / stock options, fully-hedged portfolio
using index / stock futures or index / stock options, unhedged-long-short portfolio with 25% naked-short positions
using stock futures or stock options, partially-hedged long-short portfolio with 25% naked-short using index / stock
futures or index / stock options, fully-hedged long portfolio along with 25% naked-short using index / stock futures or
index / stock options
DEPLOYMENT OF FUNDS DURING NEW FUND OFFER (NFO) PERIOD:
As per Regulation 32(4) of MF Regulations 2026 and clause 7.24 of SEBI Master Circular dated March 20, 2026
, the AMC shall deploy the funds garnered in the NFO within 30 business days from the date of allotment of
units.
In an exceptional case, if Wealth Company Asset Management Holdings Private Limited is not able to deploy
the funds in 30 business days, reasons in writing, including details of efforts taken to deploy the funds, shall be
placed before the Investment Committee of Wealth Company Asset Management Holdings Private Limited. The
Investment Committee may extend the timeline by 30 business days, while also making recommendations on
how to ensure deployment within 30 business days going forward and monitoring the same. The Investment
Committee shall examine the root cause for delay in deployment before granting approval for part or full
12extension. The Investment Committee shall not ordinarily give part or full extension where the assets for any
investment strategies are liquid and readily available.
In case the funds are not deployed as per the asset allocation mentioned in the ISID as per the aforesaid
mandated plus extended timelines, AMC shall:
i. not be permitted to receive fresh flows in the investment strategy till the time the funds are deployed
as per the asset allocation mentioned in the ISID.
ii. not be permitted to levy exit load, if any, on the investors exiting the investment strategy after 60
business days of not complying with the asset allocation of the investment strategy.
iii. inform all investors of the NFO, about the exit option without exit load, via email, SMS or other similar
mode of communication.
iv. report deviation, if any, to Trustees at each of the above stages.
To effectively manage the fund flows in NFO, the fund manager(s) may extend or shorten the NFO period,
based on their view of the market dynamics, availability of assets and their ability to deploy funds collected
in NFO. However, the same shall be subject to compliance with Para 1.7 of the SEBI Master Circular for
Mutual Funds dated March 20, 2026.
CHANGES IN ASSET ALLOCATION PATTERN / PORTFOLIO REBALANCING:
SO.23
SO.24
Short Term Defensive Consideration:
Subject to SEBI (MF) Regulations the asset allocation pattern indicated above may change from time to time,
keeping in view market conditions, market opportunities, applicable regulations and political and economic
factors. It must be clearly understood that the percentages stated above are only indicative and not absolute and
that they can vary substantially depending upon the perception of the Investment Manager, the intention being
at all times to seek to protect the interests of the Unit holders. As per clause 1.9.1.b of SEBI Master Circular on
Mutual Funds dated March 20, 2026, as may be amended from time to time, such changes in the investment
pattern will be for short term and for defensive consideration only.
In the event of change in the asset allocation, the fund manager will carry out portfolio rebalancing within 30
calendar days or such other timeline as may be prescribed by SEBI from time to time.
Portfolio Rebalancing (in case of passive breaches):
SO.22
As per clause 3.11 of SEBI Master Circular on Mutual Funds dated March 20, 2026, as may be amended/
clarified from time to time, in the event of change in the asset allocation due to passive breaches (occurrence of
instances not arising out of omission and commission of the AMC), the fund manager is required to carry out
portfolio rebalancing within 30 Business Days.
In case the portfolio is not rebalanced within the period of 30 Business Days, justification in writing, including
details of efforts taken to rebalance the portfolio shall be placed before the Investment Committee. The
Investment Committee, if it so desires, can extend the timeline for rebalancing up to 60 Business Days from the
date of completion of mandated rebalancing period. In case the portfolio of the investment strategy is not
rebalanced within the aforementioned mandated plus extended timelines, the AMC shall follow the requirements
specified under the aforesaid circular including reporting the deviation to Trustees at each stage.
13B. WHERE WILL THE INVESTMENT STRATEGY INVEST? SO.29
Equity and equity related instruments
1. Equity Instruments
2. Equity related instruments including convertible bonds and debentures and warrants carrying the right to
obtain equity shares
3. Equity Derivatives including stock futures/options and index futures/options
Debt & Money Market Instruments SO.13
1. Non-Convertible Debentures
2. Non-Convertible Preference Shares (NCPS)*
3. Floating rate debt instruments
4. Securitised Asset
5. Pass Through Certificate
6. Securities created and issued by the Central and State Governments as may be permitted by RBI
7. Debt Instruments with special features i.e. Additional Tier I (AT1) / Perpetual Bonds and Tier 2 Bonds
8. Debt Instruments having Structured Obligation (SO rating) and / or Credit Enhancements (CE rating)
9. Debt Derivative Instrument like Interest Rate Swaps, Forward Rate Agreement and such other derivative
instruments as may be permitted under the Regulations
10. Certificate of Deposits
11. Commercial Paper
12. Treasury Bills
13. Non-Convertible Debentures of original or initial maturity upto one year issued by corporate (including
NBFCs) by way of private placement in accordance with the provisions of master circular of RBI vide reference
no. RBI/MRD/2016- 17/32 dated July 7, 2016
14. Tri-party Repo
15. Reverse Repo in securities other than corporate debt securities
16. Cash Management Bills
17. Bills Rediscounting
18. Units of Debt Schemes of Mutual Fund
19. Credit default swaps
20. Pending deployment of funds, the Investment strategy may park funds in Short Term Deposits of Scheduled
commercial banks
21. Obligations/ Term Deposits of banks (both public and private sector) and development financial institutions
to the extent permissible under SEBI Regulations
22. Any other securities as permitted by SEBI/RBI from time to time
*As per note 2 of clause 13.1 of SEBI Master Circular on Mutual Funds dated March 20, 2026, Non-Convertible
Preference Shares (NCPS) shall be treated as Debt instruments.
Securitised debt may be held up to 25% of debt portfolio. The securities/debt instruments mentioned above
could be listed or unlisted, secured or unsecured, rated and of varying maturities and other terms of issue. The
securities may be acquired through Initial Public Offerings (IPOs), secondary market operations, private
placement, rights offer or negotiated deals. The Investment strategies may also enter into repurchase and
reverse repurchase obligations in all securities held by it as per guidelines/regulations applicable to such
transactions. Investment in IPOs/FPO/OFS/QIBs: This strategy attempts to make investments in companies
through Initial Public offers or secondary offers through Follow-on Public Offers or OFS or Qualified Institutional
Buyers route.
Transfer of investments from one strategy to another strategy in the same SIF, shall be allowed, in lines with
clause 13.19 of SEBI Master Circular on Mutual Funds dated March 20, 2026.
Real Estate Investment Trusts (REITs) & Infrastructure Investment Trusts (InVITs)
14C. WHAT IS THE INVESTMENT APPROACH? SO.27 SO.28
This active investment approach seeks to balance growth, income, and risk management through a diversified
portfolio with flexible allocations across equity and equity-related instruments (25%–75%), debt and money market
instruments (25%– 75%), unhedged derivative short positions in equity and debt (0%–25%), InVITs (0%–20%),
and hedged positions in equity and debt (0%–100%). By dynamically adjusting allocations based on market
conditions, economic outlook, and rigorous asset selection, the strategy emphasizes high-quality equities,
investment-grade debt, and stable REITs/InVITs, while utilizing hedging and derivatives to mitigate volatility and
capitalize on opportunities. Diversification, active risk management, and periodic rebalancing ensure resilience
and adaptability, aiming for long- term capital appreciation and income generation within a disciplined framework.
Tentative list of derivative strategies to be deployed for short exposure.
Short Description Max Max Loss Risk When will the
Strategies Profit Level strategy be
used
Short Shorting Index or High Theoretically Very Strong bearish
Futures Stock Futures to (if market unlimited. Risk High outlook
benefit from price falls) management
decline to ensure
adherence to
internally
defined risk
limits
Synthetic Buy a put and sell a High Theoretically Very Strong bearish
Short call at the same strike (if market unlimited. Risk high outlook
and expiration to falls) management
mimic a short stock adherence to
position. Profits from a internally
significant price defined risk
decline limits
Long Put Buy a put option to High Premium paid Low Strong bearish
profit from a decline in (if market Outlook
the asset price below falls)
the strike
Bear Put Buy a put at a higher Moderate Premium Low Moderate
Spread strike and sell a put at paid bearish view
a lower strike, same
expiration.
Profits from a
moderate price
decline
Short Call Sell a call option, Premium Theoretically Very high Bearish to
profiting if the asset received unlimited. Risk neutral, risky
price stays below the management
strike for adherence to
internally defined
risk limits
Bear Call Sell a call at a lower Premium Limited Moderate Mild bearish or
Spread strike and buy a call received neutral
at a higher strike,
same expiration.
Profits if price
stays below the lower
strike
15Long Put Buy one put at a Limited Premium Low Limited
Butterfly lower strike, sell two paid bearish
puts at a middle move
strike, buy one put at
a higher strike, same
expiration. Profits
from a
limited move to the
middle strike
Long Put Sell a near-term put Moderate Premium Low Expect
Calendar and buy a longer- to high paid gradual
term put at the same bearish
strike. Profits from a move
gradual price
decline and time
decay
Long Put Sell a near-term put Moderate Premium Low Moderate
Diagonal at a lower strike and to high paid bearish
buy a longer-term put with
at a higher strike. income
Profits from
a moderate decline
and premium
collection
Ratio Put Buy one put at a Moderate Theoretically High Bearish with
Spread higher strike and sell unlimited. Risk premium
multiple puts at a management- collection
lower strike, same adherence to
expiration. Profits internally
from a moderate defined risk
decline with premium limits
collection
For detailed derivative strategies, please refer to SAI.
Portfolio Turnover: Portfolio turnover is defined as lesser of purchases and sales as a percentage of the average
corpus of the investment strategy during a specified period of time. Portfolio turnover in the investment strategy will
be a function of market opportunities. The investment strategy is interval ended investment strategy. It would be
difficult to set the target for the portfolio turnover as it would be a function of purchases/redemptions, general
market conditions, trading opportunities, creation of liquidity to meet income distribution etc. Consequently, it is
difficult to estimate with any reasonable measure of accuracy, the likely turnover in the portfolio. There may be an
increase in transaction cost such as brokerage paid, if trading is done frequently. However, the cost would be
negligible as compared to the total expenses of the investment strategy. Frequent trading may increase the profits
which will offset the increase in costs. The AMC will endeavour to optimise portfolio turnover to optimise risk
adjusted return keeping in mind the cost associated with it. A high portfolio turnover rate is not necessarily a drag
on portfolio performance and may be representative of arbitrage opportunities that exist for securities held in the
portfolio rather than an indication of change in AMC’s view on a security etc. However, the AMC will take advantage
of the opportunities that present themselves from time to time because of the inefficiencies in the securities
markets
The investment strategy has no specific target relating to portfolio turnover.
D. HOW WILL THE INVESTMENT STRATEGY BENCHMARK ITS PERFORMANCE?
SO.33
NIFTY 50 HYBRID COMPOSITE DEBT 50:50 INDEX
Justification:The selected benchmark is comparable with the investment objective of the fund since the
investment strategy is focused toward generating returns over the medium to long term through a combination
of capital appreciation and income by investing in equity & equity related and fixed income instruments.
16E. WHO MANAGES THE INVESTMENT STRATEGY?
Name Qualification Tenure for Type and nature of Other
and Age investment past experience Investment
strategy including Strategy
management assignment held Managed
during the last 10
years
Chinmay B.E, PGDM NA, since it is a first Mr. Sathe brings with him -
Sathe investment Strategy over 21 years of
of WSIF experience in the Asset
Age : 48 Management Services
industry, with expertise in
fund management, equity
research and across
diverse asset classes.
He has spent over 11
years at Bajaj Allianz Life
as as Senior Fund
Manager.
His earlier stints where
with L&T Mutual Fund,
DSP Merrill Lynch and
UTI Mutual Fund as
Equity Research Analyst.
SO.32
.
F. HOW IS THE INVESTMENT STRATEGY DIFFERENT FROM EXISTING INVESTMENT
STRATEGIES OF THE SIF?
This investment strategy is a first Interval Investment Strategy and hence not applicable
G. HOW HAS THE INVESTMENT STRATEGY PERFORMED (if applicable)
This investment strategy is a new strategy and hence not applicable.
H. ADDITIONAL INVESTMENT STRATEGY RELATED DISCLOSURES
This investment strategy is a new strategy and hence additional investment strategy related disclosures not
applicable.
i. Investment Strategy’s portfolio holdings (top 10 holdings by issuer and fund allocation towards various
sectors to be provided through a functional website link that contains detailed description.)
ii. Functional website link for Portfolio Disclosure - https://www.wealthcompanyamc.in/wsif/
iii. Portfolio Turnover Rate particularly for equity oriented Investment Strategies shall also be disclosed.
iv. Aggregate investment in the Investment Strategy by:
17Sr. No Category of Persons Net Value
1. Concerned Investment Strategy’s Fund Units NAV per unit
Manager(s)
For any other disclosure w.r.t investments by key personnel and AMC directors including regulatory
provisions in this regard kindly refer SAI.
v. Investments of AMC in the Investment Strategy – This is a new Investment Strategy and hence not
applicable. Disclosure - https://www.wealthcompanyamc.in/wsif/
The AMC reserves the right to invest its own funds in the Investment Strategy as may be decided by the AMC from
time to time. Under the Regulations, the AMC is not permitted to charge any investment management and
advisory services fee on its own investment in the Investment Strategy.
SO.58
Subject to the Regulations, the AMC may invest either directly or indirectly, in the Investment Strategy during
Ongoing Offer Period. However, the AMC shall not charge any investment management fee on such investment
in the Investment Strategy.
As per the amended regulations i.e. sub-regulation 3(a) in Regulation 22 of SEBI (Mutual Funds) Regulations,
2026 (‘MF Regulations’), the asset management companies (‘AMCs’) are required to invest such amount in such
Investment Strategy (s) of the Specialized Investment Fund, based on the risk associated with the investment
strategy, as may be specified by the Board from time to time. –
Accordingly, it is decided that based on the risk band assigned to the Investment Strategy(s), in terms of Clause
6.16 of SEBI Master Circular on Mutual Funds dated March 20, 2026, the AMC shall invest minimum amount as a
percentage of assets under management (‘AUM’) in their Investment Strategy (s) in line with the Clause 7.13 of
SEBI Master Circular on Mutual Funds dated March 20, 2026.
18PART III- OTHER DETAILS
A. COMPUTATION OF NAV
The Net Asset Value (NAV) per Unit under the Investment Strategy will be computed by dividing the net assets
of the Investment Strategy by the number of Units outstanding on the valuation day. The Specialized Investment
Fund will value its investments according to the valuation norms, as specified in Schedule VII of the SEBI (MF)
Regulations, or such norms as may be specified by SEBI from time to time.
The broad valuation norms policies w.r.t computation of NAV, rounding off, procedure in case of delay in
disclosure of NAV etc. are detailed in the SAI.
The Net Asset Value (NAV) of the Units will be determined daily or as prescribed by the Regulations. The NAV
shall be calculated in accordance with the following formula, or such other formula as may be prescribed by
SEBI from time to time.
NAV =
Market/Fair value of Scheme’s Investments + Current Assets – Current Liabilities and Provisions
No. of units outstanding under Investment Strategy/ Plan
Where the assets include the value of securities and liquid cash. The securities in which the Investment Strategy
has invested include both equity, debentures, bonds, bills of exchange, commercial paper. It also includes the
interest accrued and dividend earned.
The liabilities and expenses include the money payable, interest payable, fund management expenses.
The NAV shall be calculated up to four decimal places. However, the AMC reserves the right to declare the
NAVs up to additional decimal places as it deems appropriate. Separate NAV will be calculated and disclosed
for each Option. The NAVs of the Growth Option and the IDCW Option under each of the Plans will be different
after the declaration of the first IDCW.
The AMC will calculate and disclose the first NAV of the Investment Strategy within a period of 5 business days
from the date of allotment. Subsequently, the NAVs will be calculated and disclosed on all the Business Days.
Illustration on Computation of NAV: SO. 42
Illustration: Assumptions - on the day of calculation of NAV:
Market or Fair Value of the Scheme’s Investments = 10600 Current Assets = 250
Current Liabilities & provisions = 150
No of units outstanding in the plan = 1000 NAV = (10600+250-150)/1000 = 10.70
Any change in Load structure will be effective on prospective basis and will not affect the existing Unit holder in
any manner. However, the Specialized Investment Fund will ensure that the Redemption Price will not be lower
than 97% of the Applicable NAV. The Purchase Price shall be at applicable NAV.
Methodology of calculating the sale price:
The price or NAV an investor is charged while investing in an open-ended scheme is called sale / subscription
price. Pursuant to clause 11.7.1 of the SEBI Master circular for Mutual Funds dated March 20,2026 no entry
load will be charged by the Scheme to the investors.
Therefore, Sale / Subscription price = Applicable NAV
Methodology of calculating the repurchase price
Repurchase or redemption price is the price or NAV at which an open-ended scheme purchases or redeems its
units from the investors. It may include exit load, if applicable. The exit load, if any, shall be charged as a
percentage of Net Assets Value (NAV) i.e. applicable load as a percentage of NAV will be deducted from the
“Applicable NAV” to calculate the repurchase price.
Therefore, Repurchase / Redemption Price = Applicable NAV *(1 – Exit Load, if any) For example, If the
Applicable NAV of the Scheme is Rs. 10 and the Exit Load applicable at the time of investment is 1% if redeemed
before completion of 1 year from the date of allotment of units and the investor redeems units before completion
19of 1 year, then the repurchase/redemption price will be: = Rs. 10*(1-0.01) = Rs. 9.90
B. NEW FUND OFFER (NFO) EXPENSES
These expenses are incurred for the purpose of various activities related to the NFO like marketing and
advertising, registrar expenses, printing and stationary, bank charges etc. All the expenditures pertaining to
launch of new fund offer till the date of allotment of mutual fund units to investors, shall be borne by the AMC or
Trustees or Sponsor.
C. ANNUAL RECURRING EXPENSES
These are the fees and expenses for operating the Investment Strategy. These expenses include Investment
Management and Advisory Fee charged by the AMC, Registrar and Transfer Agents’ fee, marketing and
selling costs etc. as given in the table below:
The AMC has estimated that upto 1.85 % of the daily net assets of the Investment Strategy will be charged to
the Investment Strategy as expenses. For the actual current expenses being charged, the investor should refer
to the website of the SIF https://www.wealthcompanyamc.in/wsif/
% p.a. of daily Net
Expense Head Assets*
(Estimated p.a.)
Investment Management & Advisory Fees (AMC Fees)
Audit fees/fees and expenses of trustees
Custodial Fees
Registrar & Transfer Agent Fees including cost of providing account statements /
IDCW / redemption cheques/ warrants
Marketing & Selling Expenses including Agents Commission and statutory
Advertisement
Costs related to investor communications
Upto 1.85%
Costs of fund transfer from location to location
Cost towards investor education, awareness and financial inclusion
Brokerage & transaction cost pertaining to execution of trade
Cost of statutory advertisements
Other Expenses* (to be specified as per Reg 66 of SEBI MF Regulations)
Maximum Base expenses ratio (BER) permissible under Upto 1.85%
Regulation 66
Statutory levies (including GST) on all expenses excluding brokerage and As applicable
transaction cost
Statutory levies (including GST) on brokerage and transaction cost As applicable
*Any other expenses which are directly attributable to the Investment Strategy, may be charged with the approval
of the Trustee within the overall limits as specified in the Regulations except those expenses which are
specifically prohibited.
All fees and expenses charged in a Direct Plan (in percentage terms) under various heads including the
investment and advisory fee shall not exceed the fees and expenses charged under such heads in Regular
Plan.
Direct Plan shall have a lower expense ratio excluding distribution expenses, commission, etc. and no
commission for distribution of Units will be paid/ charged under Direct Plan.
1. The Total Expense Ratio shall consist of the following components:
a) Base expense ratio (BER) (sub-regulation 7 of Regulation 66) - The BER shall be charged to the
scheme(s) within the base expense ratio limits specified under the MF Regulations, 2026.
20The BER shall include:
• Investment and Advisory fees (sub-regulation 4 of Regulation 66)
• Recurring scheme expenses (sub-regulation 5 of Regulation 66)
• Charges/ commission/ fees related to distribution of mutual fund schemes (Sub-regulation 6 of
Regulation 66)
but exclude statutory levy applicable, if any, on above expenses and transaction cost specified under
sub-regulation 10 of Regulation 66. The base expense ratio shall be subject to the limits specified
under the Regulations.
b) Brokerage Cost (sub-regulation 9 of Regulation 66)
Schemes may charge expense incurred towards brokerage, for the purpose of execution of trade, over and
above the base expense ratio subject to a maximum of 0.06 per cent of trade value in case of cash
market transactions and 0.02 per cent of trade value in case of derivatives transactions. Expense
charged towards brokerage, over and above the specified limit, shall be part of the base expense ratio
limit specified under sub regulation 7 of Regulation 66.
c) Transaction cost (sub-regulation 10 of Regulation 66)
Shall mean regulatory levies and any other expenses charged by the stock exchanges, clearing
corporation, and clearing house, as applicable. Such transaction costs shall not form part of the base
expense ratio.
d) Statutory levy (clause yy of sub regulation 1 of Regulation 2) means levy imposed by state government
and central government.
2. Any expense other than those specified in sub-regulation (4), sub-regulation (5), sub regulation (6), sub-
regulation (9) and sub-regulation (10), as mentioned above, shall not be charged to the scheme and shall
be borne by the AMC or trustee or sponsors.
3. No charges other than the base expense ratio, brokerage cost, transaction cost, statutory levy and exit
load including levies as may be specified by SEBI, shall be charged to the investors.
4. Any expenditure in excess of the base limits specified in the MF Regulations shall be borne by the AMC or
the trustees or sponsors. If any expense of the scheme is borne by the AMC or by the trustees or sponsors,
the same shall be done only after the investment and advisory fees charged to the scheme, if any, is fully
reversed.
The expenses towards Investment Management and Advisory Fees under Regulation 66 (4) and the various
sub-heads of recurring expenses mentioned under Regulation 66 (5) of SEBI (MF) Regulations can be
apportioned under various expense heads/ sub heads without any sub limit, as permitted under the applicable
regulations.
These estimates have been made in good faith as per the information available to the Investment Manager and
are subject to change inter-se or in total subject to prevailing Regulations. The base expense ratio of the
Investment Strategy (including the Investment Management and Advisory Fees) shall be as per the limits
prescribed under the Regulation 66(7)(c)of SEBI (MF) Regulations.
Assets under management Slab (In Rs. crore) Total expense ratio limits
On the first Rs. 500 crores of the daily net assets 1.85%
On the next Rs. 250 crores of the daily net assets 1.65%
On the next Rs. 1250 crores of the daily net assets 1.40%
On the next Rs. 3000 crores of the daily net assets 1.25%
On the next Rs. 5000 crores of the daily net assets 1.15%
On the next Rs. 40,000 crores of the daily net assets Expense ratio reduction of 0.05% for
every increase of
Rs.5,000 crores of daily net assets or part
thereof.
On the balance of the assets 0.70%
21A. Within the Total Expense Limit chargeable to the investment strategy, following will be charged to the
Investment Strategy:
a. 0.02 % daily net assets of the Scheme for investor education, awareness and financial inclusion initiatives
as per clause 11.9.1 of SEBI Master Circular dated March 20, 2026
B. Further with reference clause 11.6.3 of SEBI Master Circular dated March 20, 2026 the additional distribution
commission shall be paid from the 2 basis points on daily net assets, mandatorily set aside annually by the AMC
towards investor education, awareness, and financial inclusion initiatives, subject to applicable clawback
provisions AMC fees charged by Wealth Company Asset Management Holdings Limited to the investment
strategy will be within the Total Expense Limit as prescribed by SEBI Regulations, as amended from time to time.
No charges other than the base expense ratio, brokerage cost, transaction cost, statutory levy and exit load
including levies as may be specified by the SEBI, shall be charged to the investors.
Expenses over and above the prescribed limit shall be charged / borne in accordance with the Regulations
prevailing from time to time.
The Specialized Investment Fund would update the current expense ratios on its website
(https://www.wealthcompanyamc.in/wsif/ ) atleast three working days prior to the effective date of the change.
Investors can refer ‘Total Expense Ratio of SIF Investment Strategy’ section on
https://www.wealthcompanyamc.in/wsif/ for Total Expense Ratio (TER) details.
Illustration of impact of expense ratio on Investment Strategy’s returns
For any Investment Strategy, NAV is computed on a daily basis factoring in all the assets as well as liabilities of
the Investment Strategy (including expenses charged). Expenses charged to the Investment Strategy bring
down its NAV and hence the investor's net returns on a corresponding basis.
Illustration: SO.44
Regular Plan (Amount Direct Plan (Amount in Rs.)
Particulars
in Rs.)
Amount Invested at the beginning of the year 10,000 10,000
Returns before Expenses 1,500 1,500
Expenses other than Distribution Expenses 150 150
Distribution Expenses 50 -
Returns after Expenses at the end of the Year 1300 1350
Please Note:
• The purpose of the above illustration is purely to explain the impact of expense ratio charged to the
Investment Strategy and should not be construed as providing any kind of investment advice or
guarantee of returns on investments.
• It is assumed that the expenses charged are evenly distributed throughout the year. The expenses
of the Direct Plan under the Investment Strategy may vary with that of the Regular Plan under the
Investment Strategy.
• Calculations are based on assumed NAVs, and actual returns on your investment may be more, or less.
• Any tax impact has not been considered in the above example, in view of the individual nature of the tax
implications. Each investor is advised to consult his or her own financial advisor.
D. LOAD STRUCTURE
Exit Load is an amount which is paid by the investor to redeem the units from the Investment Strategy. Load
amounts are variable and are subject to change from time to time. For the current applicable structure, please
refer to the website of WSIF (https://www.wealthcompanyamc.in/wsif/ ) .
SO.47
22Type of Load Load chargeable (as %age of NAV)
Exit Load NIL
Units issued on reinvestment of IDCW shall not be subject to Load. No load shall be levied on switches between
options and sub-options of the Investment strategy.
For switches between the Growth and IDCW Option, no load will be charged by the Investment Strategy. Also,
for switches between the Plans i.e. between Regular and Direct Plan or vice versa, no load will be charged by
the Investment Strategy. Exit load, if any, charged to the investors will be credited back to the Investment
Strategy net of GST. The Investor is requested to check the prevailing Load structure of the Investment Strategy
before investing.
For any change in Load structure, AMC will issue an addendum and display it on the website/ Investor
Service Centres.
Under the Investment Strategy, the AMC/ Trustee reserves the right to change / modify the Load structure if it
so deems fit in the interest of smooth and efficient functioning of the Specialized Investment Fund. The AMC/
Trustee reserves the right to introduce / modify the Load depending upon the circumstances prevailing at that
time subject to maximum limits as prescribed under the Regulations.
The Redemption Price however, will not be lower than 97% of the NAV. Any imposition or enhancement of
Load in future shall be applicable on prospective investments only.
SO.47
At the time of changing the Load Structure:
1. An Addendum detailing the changes will be attached to Investment Strategy Information Document and
Key Information Memorandum. The addendum may be circulated to all the distributors / brokers so that
the same can be attached to all Investment Strategy Information Document and Key Information
Memorandum already in stock.
2. The addendum will be displayed on the website of the AMC and arrangements will be made to display
the addendum in the form of a notice in all the Investor Service Centres and distributors / brokers office.
3. The introduction of the Exit Load along with the details may be stamped in the acknowledgement
slip issued to the Investors on submission of the application form and may also be disclosed in the
statement of accounts issued after the introduction of such Load.
4. Any other measure which the Specialized Investment Fund may consider necessary.
The Trustee/AMC reserves the right to change the load structure subject to the limits prescribed under
the Regulations. Any change in load structure shall be only on a prospective basis i.e. any such changes
would be chargeable only for Redemptions from prospective purchases (applying first in first out basis).
23Section II
I. Introduction
A. Definitions/interpretation
Please refer to our website at https://www.wealthcompanyamc.in/wsif/
B. Risk factors
SO.8
Investment strategy Specific Risk Factors
Some of the specific risk factors related to the Investment strategy include, but are not limited to the following:
(i) Risk factors associated with investing in equities and equity related instruments
• Equity shares and equity related instruments are volatile and prone to price fluctuations on a daily basis.
Investments in equity shares and equity related instruments involve a degree of risk and investors should
not invest in the Investment strategy unless they can afford to take the risks.
• Securities, which are not quoted on the stock exchanges, are inherently illiquid in nature and carry a larger
amount of liquidity risk, in comparison to securities that are listed on the exchanges. Investment in such
securities may lead to increase in the investment strategy portfolio risk.
• While securities that are listed on the stock exchange carry lower liquidity risk, the ability to sell these
investments is limited by the overall trading volume on the stock exchanges and may lead to the
Investment strategy incurring losses till the security is finally sold.
• Investment strategy's performance may differ from the benchmark index to the extent of the investments
held in the debt segment, as per the investment pattern indicated under normal circumstances.
(ii) Risk factors associated with investing in Fixed Income Securities
• The Net Asset Value (NAV) of the Investment strategy, to the extent invested in Debt and Money Market
instruments, will be affected by changes in the general level of interest rates. The NAV of the Investment
strategy is expected to increase from a fall in interest rates while it would be adversely affected by an
increase in the level of interest rates.
• Money market instruments, while fairly liquid, lack a well developed secondary market, which may restrict
the selling ability of the Investment strategy and may lead to the Investment strategy incurring losses till
the security is finally sold. ● Investments in money market instruments involve credit risk commensurate
with short term rating of the issuers.
• Investment in Debt instruments are subject to varying degree of credit risk or default (i.e. the risk of an
issuer's inability to meet interest or principal payments on its obligations) or any other issues, which may
have their credit ratings downgraded. Changes in financial conditions of an issuer, changes in economic
and political conditions in general, or changes in economic or and political conditions specific to an issuer,
all of which are factors that may have an adverse impact on an issuer's credit quality and security values.
The Investment Manager will endeavour to manage credit risk through in-house credit analysis. This may
increase the risk of the portfolio. The Investment Manager will endeavour to manage credit risk through
in-house credit analysis.
• Prepayment Risk: Certain fixed income securities give an issuer the right to call back its securities before
their maturity date, in periods of declining interest rates. The possibility of such prepayment may force the
Investment strategy to reinvest the proceeds of such investments in securities offering lower yields,
resulting in lower interest income for the Investment strategy.
• Reinvestment Risk: This risk refers to the interest rate levels at which cash flows received from the
securities in the Investment strategy are reinvested. The additional income from reinvestment is the
"interest on interest" component. The risk is that the rate at which interim cash flows can be reinvested
may be lower than that originally assumed.
• Settlement risk: Different segments of Indian financial markets have different settlement periods and
such periods may be extended significantly by unforeseen circumstances. Delays or other problems in
settlement of transactions could result in temporary periods when the assets of the Investment strategy
are uninvested and no return is earned thereon. The inability of the Investment strategy to make intended
securities purchases, due to settlement problems, could cause the Investment strategy to miss certain
investment opportunities. Similarly, the inability to sell securities held in the Investment strategy's
portfolio, due to the absence of a well-developed and liquid secondary market for debt securities,
24may result at times in potential losses to the Investment strategy in the event of a subsequent
decline in the value of securities held in the Investment strategy's portfolio.
• Government securities where a fixed return is offered run price-risk like any other fixed income security.
Generally, when interest rates rise, prices of fixed income securities fall and when interest rates drop, the
prices increase. The extent of fall or rise in the prices is a function of the existing coupon, days to maturity
and the increase or decrease in the level of interest rates. The new level of interest rate is determined by
the rates at which government raises new money and/or the price levels at which the market is already
dealing in existing securities. The price-risk is not unique to Government Securities. It exists for all fixed
income securities. However, Government Securities are unique in the sense that their credit risk generally
remains zero. Therefore, their prices are influenced only by movement in interest rates in the financial
system.
• Different types of fixed income securities in which the Investment strategy would invest as given in the
Investment strategy Information Document carry different levels and types of risk. Accordingly, the
Investment strategy risk may increase or decrease depending upon its investment pattern. e.g. corporate
bonds carry a higher level of risk than Government securities. Further even among corporate bonds, AAA
rated bonds are comparatively less risky than AA rated bonds.
• The AMC may, considering the overall level of risk of the portfolio, invest in lower rated / unrated securities
offering higher yields as well as zero coupon securities that offer attractive yields. This may increase the
absolute level of risk of the portfolio.
• As zero coupon securities do not provide periodic interest payments to the holder of the security, these
securities are more sensitive to changes in interest rates and are subject to issuer default risk. Therefore,
the interest rate risk of zero coupon securities is higher. The AMC may choose to invest in zero coupon
securities that offer attractive yields. This may increase the risk of the portfolio. Zero coupon or deep
discount bonds are debt obligations that do not entitle the holder to any periodic payment of interest prior
to maturity or a specified date when the securities begin paying current interest and therefore, are generally
issued and traded at a discount to their face values. The discount depends on the time remaining until
maturity or the date when securities begin paying current interest. It also varies depending on the prevailing
interest rates, liquidity of the security and the perceived credit risk of the Issuer. The market prices of zero
coupon securities are generally more volatile than the market prices of securities that pay interest
periodically.
• The Investment strategy at times may receive large number of redemption requests, leading to an asset-
liability mismatch and therefore, requiring the investment manager to make a distress sale of the securities
leading to realignment of the portfolio and consequently resulting in investment in lower yield instruments.
Risks associated with investment in unlisted securities:
• Except for any security of an associate or group company, the investment strategy can invest in securities
which are not listed on a stock exchange (“unlisted Securities”) which in general are subject to greater
price fluctuations, less liquidity and greater risk than those which are traded in the open market. Unlisted
securities may lack a liquid secondary market and there can be no assurance that the Investment strategy
will realise their investments in unlisted securities at a fair value.
• Investment in unrated instruments may involve a risk of default or decline in market value higher than
rated instruments due to adverse economic and issuer-specific developments. Such investments display
increased price sensitivity to changing interest rates and to a deteriorating economic environment. The
market values for unrated investments tends to be more volatile and such securities tend to be less liquid
than rated debt securities.
(iii) Risks associated with Investing in Structured Obligation (SO) & Credit Enhancement (CE) rated
securities The risks factors stated below for the Structured Obligations & Credit Enhancement are in
addition to the risk factors associated with debt instruments.
• Credit rating agencies assign CE rating to an instrument based on any identifiable credit enhancement for
the debt instrument issued by an issuer. The credit enhancement could be in various forms and could
include guarantee, shortfall undertaking, letter of comfort, etc. from another entity. This entity could be
either related or non-related to the issuer like a bank, financial institution, etc. Credit enhancement could
include additional security in form of pledge of shares listed on stock exchanges, etc. SO transactions are
asset backed/ mortgage backed securities, securitized paper backed by hypothecation of car loan
receivables, securities backed by trade receivables, credit card receivables etc. Hence, for CE rated
instruments evaluation of the credit enhancement provider, as well as the issuer is undertaken to determine
25the issuer rating. In case of SO rated issuer, the underlying loan pools or securitization, etc. is assessed
to arrive at rating for the issuer.
• Liquidity Risk: SO rated securities are often complex structures, with a variety of credit enhancements.
Debt securities lack a well-developed secondary market in India, and due to the credit enhanced nature of
CE securities as well as structured nature of SO securities, the liquidity in the market for these instruments
is adversely affected compared to similar rated debt instruments. Hence, lower liquidity of such
instruments, could lead to inability of the investment strategy to sell such debt instruments and generate
liquidity for the investment strategy or higher impact cost when such instruments are sold.
• Credit Risk: The credit risk of debt instruments which are CE rated is based on the combined strength of
the issuer as well as the structure. Hence, any weakness in either the issuer or the structure could have an
adverse credit impact on the debt instrument. The weakness in structure could arise due to inability of the
investors to enforce the structure due to issues such as legal risk, inability to sell the underlying collateral
or enforce guarantee, etc. In case of SO transactions, comingling risk and risk of servicer increases the
overall risk for the securitized debt or assets backed transactions. Therefore apart from issuer level credit
risk such debt instruments are also susceptible to structure related credit risk.
(iv) Risk factors associated with investment in Tri-Party Repo
The SIF is a member of securities segment and Triparty Repo trade settlement of the Clearing Corporation
of India (CCIL). All transactions of the SIF in government securities and in Tri-party Repo trades are settled
centrally through the infrastructure and settlement systems provided by CCIL; thus reducing the settlement
and counterparty risks considerably for transactions in the said segments. The members are required to
contribute an amount as communicated by CCIL from time to time to the default fund maintained by CCIL
as a part of the default waterfall (a loss mitigating measure of CCIL in case of default by any member in
settling transactions routed through CCIL). As per the waterfall mechanism, after the defaulter's margins
and the defaulter's contribution to the default fund have been appropriated, CCIL's contribution is used to
meet the losses. Post utilization of CCIL's contribution if there is a residual loss, it is appropriated from the
default fund contributions of the non-defaulting members. Thus the investment strategy is subject to risk
of the initial margin and default fund contribution being invoked in the event of failure of any settlement
obligations. In addition, the fund contribution is allowed to be used to meet the residual loss in case of
default by the other clearing member (the defaulting member). CCIL shall maintain two separate Default
Funds in respect of its Securities Segment, one with a view to meet losses arising out of any default by its
members from outright and repo trades and the other for meeting losses arising out of any default by its
members from Triparty Repo trades. The fund is exposed to the extent of its contribution to the default
fund of CCIL, in the event that the contribution of the fund is called upon to absorb settlement/default losses
of another member by CCIL, as a result the investment strategy may lose an amount equivalent to its
contribution to the default fund.
(v) Risk factors associated with Repo in Corporate Debt Securities
In repo transactions, also known as a repo or sale repurchase agreement, securities are sold with the
seller agreeing to buy them back at later date. The repurchase price should be greater than the original
sale price, the difference effectively representing interest. A repo in corporate debt securities is
economically similar to a secured loan, with the buyer receiving corporate debt securities as collateral to
protect against default. Some of the risks associated with repo in corporate debt are given below:
• Counterparty Risk: Counterparty risk refers to the inability of the seller to meet the obligation to buy back
securities at the contracted price on the contracted date. In case of over the counter (OTC) repo trades, the
investment manager will endeavour to manage counterparty risk by dealing only with counterparties
having strong credit profiles. Also, the counter-party risk is to an extent mitigated by taking collateral
equivalent in value to the transaction after knocking off a minimum haircut on the intrinsic value of the
collateral. In the event of default by the repo counterparty, the investment strategy shall have recourse to
the corporate debt securities. In case the repo transaction is executed on exchange platform approved by
RBI/SEBI, the exchange may also provide settlement guarantee.
• Collateral Risk: Collateral risk arises when the market value of the securities is inadequate to meet the
repo obligations. This risk can be partly mitigated by restricting participation in repo transactions only in
corporate debt securities which are approved by credit risk team. Additionally, to address the risk related
to reduction in market value of corporate debt security held as collateral due to credit rating downgrade,
the repo contract can incorporate either an early termination of the repo agreement or call for fresh margin
to meet the minimum haircut requirement or call for replacement of security with eligible security.
Moreover, the investment manager may apply a higher haircut on the underlying security than required as
per RBI/SEBI regulation to adjust for the illiquidity and interest rate risk on the underlying instrument. To
26mitigate the risk of price reduction due to interest rate changes, the adequacy of the collateral can be
monitored on a daily basis by considering the daily market value & applying the prescribed haircut. The
investment manager or the exchange can then arrange for additional collateral from the counterparty,
within a prespecified period. If the counterparty is not able to top-up either in form of cash / collateral,it
would tantamount to early termination of the repo agreement, and the outstanding amount can be
recovered by sale of collateral.
(vi) Risk factors associated with investing in Non- Convertible Preference Shares
• Credit Risk: Credit risk is the risk that an issuer will be unable to meet its obligation of payment of dividend
and/ or redemption of principal amount on the due date. Further, for non-cumulative preference shares,
issuer also has an option to not pay dividends on preference shares in case of inadequate profits in any
year.
• Liquidity Risk: The preference shares generally have limited secondary market liquidity and thus we may
be forced to hold the instrument till maturity.
• Unsecured in nature - Preference shares are unsecured in nature and rank lower than secured and
unsecured debt in hierarchy of payments in case of liquidation. Thus there is significant risk of capital
erosion in case the company goes into liquidation.
(vii) Related to WSIF Hybrid Long-Short Investment Strategy
A. The primary objective of WSIF Hybrid Long-Short Investment Strategy is to achieve a blend of capital
appreciation and income generation by maintaining a balanced exposure to equity and debt instruments,
with a minimum of 25% in each, while utilizing up to 25% in short derivative positions to enhance returns
and manage risk efficiently. The identification and execution of long and short strategies involve inherent
uncertainties, and no assurance can be given that the Fund Manager will successfully locate profitable
opportunities or accurately predict market movements. Market conditions, such as reduced volatility or
limited pricing inefficiencies, may constrain the fund’s ability to generate alpha, potentially impacting
returns. The fund’s active management approach may lead to high portfolio turnover, resulting in elevated
transaction costs. Additionally, there may be instances where market liquidity is insufficient to execute
trades at optimal prices, increasing the cost and risk of implementing the strategy. While the portfolio
typically includes liquid equities, differences in stock liquidity can pose challenges, making the long-short
strategy complex, costly, and occasionally difficult to execute effectively.
B. Risk factors associated with potential change in tax structure
An equity oriented fund has been defined under the Income Tax Act as a investment strategy where the
investible funds are invested in equity shares of domestic companies to the extent of more than 65 per
cent of the total assets of such fund. The percentage of equity shareholding of the fund shall be computed
with reference to the annual average of the monthly averages of the opening and closing figures. As per
the asset allocation, under normal circumstances, the Investment strategy shall invest minimum 80% of
its total assets in Equity and Equity Related instruments. However, under defensive circumstances, where
the debt / money market instruments offer better returns than the arbitrage opportunities available in cash
and derivatives segments of equity markets, then the investment manager may choose to have a lower
equity exposure for a prolonged period. In such a case, the fund may be regarded as a debt oriented fund
as per extant Income Tax laws and consequently may not enjoy the favourable tax provisions available
for equity oriented funds in that particular financial year. In such situation, a Unitholder who has redeemed
the units during that financial year may end up paying capital gain tax as applicable to a debt fund and
consequently would also not be able to derive any benefit of STT paid at the time of redemption. In view
of the forgoing and individual nature of tax consequences, each Unit holder is advised to consult his / her
own professional tax advisor.
(viii) General Risk factors
• Trading volumes, settlement periods and transfer procedures may restrict the liquidity of the investments
made by the Investment strategy. Different segments of the Indian financial markets have different
settlement periods and such periods may be extended significantly by unforeseen circumstances leading
to delays in receipt of proceeds from sale of securities. The NAV of the Units of the Investment strategy
can go up or down because of various factors that affect the capital markets in general.
• As the liquidity of the investments made by the Investment strategy could, at times, be restricted by trading
volumes and settlement periods, the time taken by the Fund for redemption of Units may be significant in
the event of an inordinately large number of redemption requests or restructuring of the Investment
strategy. In view of the above, the Trustee has the right, in its sole discretion, to limit redemptions (including
27suspending redemptions) under certain circumstances.
• At times, due to the forces and factors affecting the capital market, the Investment strategy may not be able
to invest in securities falling within its investment objective resulting in holding the monies collected by it
in cash or cash equivalent or invest the same in other permissible securities / investments amounting to
substantial reduction in the earning capability of the Investment strategy. The Investment strategy may
retain certain investments in cash or cash equivalents for its day-to-day liquidity requirements.
• Investment strategy to be adopted by the Investment strategy may carry the risk of significant variance
between the portfolio allocation of the Investment strategy and the Benchmark particularly over a short to
medium term period.
• Performance of the Investment strategy may be affected by political, social, and economic developments,
which may include changes in government policies, diplomatic conditions, and taxation policies.
SO.11
SO.28
(ix) Risk factors associated with investing in Derivatives
• The AMC, on behalf of the Investment strategy may use various derivative products, from time to time, in
an attempt to protect the value of the portfolio and enhance Unit holders' interest. Derivative products are
specialized instruments that require investment techniques and risk analysis different from those
associated with stocks and bonds. The use of a derivative requires an understanding not only of the
underlying instrument but of the derivative itself. Other risks include, the risk of mispricing or improper
valuation and the inability of derivatives to correlate perfectly with underlying assets, rates and indices.
• Derivative products are leveraged instruments and can provide disproportionate gains as well as
disproportionate losses to the investor. Execution of such strategies depends upon the ability of the fund
manager to identify such opportunities. Identification and execution of the strategies to be pursued by the
fund manager involve uncertainty and decision of fund manager may not always be profitable. No
assurance can be given that the fund manager will be able to identify or execute such strategies.
• The risks associated with the use of derivatives are different from or possibly greater than, the risks
associated with investing directly in securities and other traditional investments.
• Credit Risk:
The credit risk in derivative transaction is the risk that the counter party will default on its obligations and is
generally low, as there is no exchange of principal amounts in a derivative transaction
• Market Risk:
Market movements may adversely affect the pricing and settlement of derivatives.
• Illiquidity risk:
This is the risk that a derivative cannot be sold or purchased quickly enough at a fair price, due to lack of
liquidity in the market.
(x) Risks Factors associated with investing in Derivatives for short exposure
• Derivative strategies are designed to capitalize on price movements in underlying assets. However,
significant market volatility may lead to substantial losses, particularly in directional strategies or
uncovered positions, where unexpected price swings could impact performance.
• Strategies employing options, are subject to time decay, where the value of options decreases as
expiration nears. If anticipated price movements do not materialize within the option’s lifespan, these
positions may become unprofitable, affecting returns.
• Derivative trading involves costs such as premiums, commissions, and bid-ask spreads, which can erode
returns. This is particularly relevant for strategies with narrow profit margins, or complex strategies like
spreads and combinations requiring multiple transactions.
• Certain derivatives may exhibit lower liquidity, resulting in wider bid-ask spreads or challenges in entering
or exiting positions at optimal prices. This may increase costs or complicate trade execution, especially in
advanced strategies like diagonal spreads or synthetic positions.
• Sudden market events or shifts in implied volatility can disrupt strategies, which rely on the underlying
asset remaining within a specific price range. Misalignment with market conditions may lead to losses.
• Strategies involving short positions, such as synthetic stock or income generation through writing options,
may require significant margin reserves. Failure to meet margin obligations could result in forced
liquidations at unfavorable prices, impacting portfolio performance.
28(xi) Additional Risk viz. Basis Risk associated with imperfect hedging using Interest Rate Futures (IRF): The
imperfect correlation between the prices of securities in the portfolio and the IRF contract used to hedge
part of the portfolio leads to basis risk. Thus, the loss on the portfolio may not exactly match the gain from
the hedge position entered using the IRF.
(xii) Risk factors associated with Securities Lending: As with other modes of extensions of credit, there are
risks inherent to securities lending, including the risk of failure of the other party, in this case the approved
intermediary, to comply with the terms of the agreement entered into between the lender of securities i.e.
the Investment strategy and the approved intermediary. Such failure can result in the possible loss of
rights to the collateral put up by the borrower of the securities, the inability of the approved intermediary
to return the securities deposited by the lender and the possible loss of any corporate benefits accruing to
the lender from the securities deposited with the approved intermediary. The investment strategy may not
be able to sell lent out securities, which can lead to temporary illiquidity & loss of opportunity.
(xiii) Risk factors associated with investing in Securitized Debt : The Risks involved in Securitized Papers
described below are the principal ones and does not represent that the statement of risks set out
hereunder is exhaustive.
• Limited Liquidity & Price Risk
There is no assurance that a deep secondary market will develop for the Certificates. This could limit the
ability of the investor to resell them.
• Limited Recourse, Delinquency and Credit Risk
The Credit Enhancement stipulated represents a limited loss cover to the Investors. These Certificates
represent an undivided beneficial interest in the underlying receivables and do not represent an obligation
of either the Issuer or the Seller or the originator, or the parent or any affiliate of the Seller, Issuer and
Originator. No financial recourse is available to the Certificate Holders against the Investors'
Representative. Delinquencies and credit losses may cause depletion of the amount available under the
Credit Enhancement and thereby the Investor Payouts to the Certificate Holders may get affected if the
amount available in the Credit Enhancement facility is not enough to cover the shortfall. On persistent
default of a Obligor to repay his obligation, the Servicer may repossess and sell the Asset. However many
factors may affect, delay or prevent the repossession of such Asset or the length of time required to realise
the sale proceeds on such sales. In addition, the price at which such Asset may be sold may be lower than
the amount due from that Obligor.
• Risks due to possible prepayments and Charge Offs
In the event of prepayments, investors may be exposed to changes in tenor and yield. Also, any Charge
Offs would result in the reduction in the tenor of the Pass Through Certificates (PTCs).
• Bankruptcy of Bank with Liquidity facility
If the Bank with Liquidity facility, becomes subject to bankruptcy proceedings then an investor could
experience losses or delays in the payments.
• Risk of Co-mingling
With respect to the Certificates, the Servicer will deposit all payments received from the Obligors into the
Collection Account. However, there could be a time gap between collection by a Servicer and depositing
the same into the Collection account especially considering that some of the collections may be in the
form of cash. In this interim period, collections from the Loan Agreements may not be segregated from
other funds of originator. If originator in its capacity as Servicer fails to remit such funds due to Investors,
the Investors may be exposed to a potential loss.
(xiv) Risk factors associated with investments in Perpetual Debt
nstrument (PDI)
Perpetual Debt instruments are issued by Banks, NBFCs and corporates to improve their capital profile.
Some of the PDIs issued by Banks which are governed by the RBI guidelines for Basel III Capital
Regulations are referred to as Additional Tier I (AT1 bonds). While there are no regulatory guidelines for
issuance of PDIs by corporate bodies, NBFCs issue these bonds as per guidelines issued by RBI. The
instruments are treated as perpetual in nature as there is no fixed maturity date. The key risks associated
with these instruments are highlighted below:
Key Risk Factors: -
• Risk on coupon servicing Banks
As per the terms of the instruments, Banks may have discretion at all times to cancel distributions/
payment of
29coupons. In the event of non-availability of adequate distributable reserves and surpluses or inadequacy
in terms of capital requirements, RBI may not allow banks to make payment of coupons.
NBFCs
While NBFCs may have discretion at all times to cancel payment of coupon, coupon can also be deferred
(instead of being cancelled), in case paying the coupon leads to breach of capital ratios.
Corporates
Corporates usually have discretion to defer the payment of coupon. However, the coupon is usually
cumulative and any deferred coupon shall accrue interest at the original coupon rate of the PDI.
• Risk of write-down or conversion into equity Banks
As per the regulatory requirements, Banks have to maintain a minimum Common Equity Tier-1 (CET-1)
ratio of
Risk Weighted Assets (RWAs), failing which the AT-1 bonds can get written down. Further, AT-1 Bonds
are liable to be written down or converted to common equity, at the discretion of RBI, in the event of Point
of Non Viability Trigger (PONV). PONV is a point, determined by RBI, when a bank is deemed to have
become non-viable unless there is a write off/ conversion to equity of AT-1 Bonds or a public sector capital
injection happens. The write off/conversion has to occur prior to public sector injection of capital. This risk
is not applicable in case of NBFCs and Corporates.
• Risk of instrument not being called by the Issuer Banks
The issuing banks have an option to call back the instrument after minimum specified period from the date of
issuance
and thereafter, subject to meeting the RBI guidelines. However, if the bank does not exercise the call on
first call date, the Investment strategy may have to hold the instruments for a period beyond the first call
exercise date.
NBFCs
The NBFC issuer has an option to call back the instrument after minimum specific period as per the
regulatory requirement from date of issuance and thereafter, subject to meeting the RBI guidelines.
However, if the NBFC does not exercise the call option the Investment strategy may have to hold the
instruments for a period beyond the first call exercise date. Corporates There is no minimum period for call
date. However, if the corporate does not exercise the call option, the Investment strategy may have to hold
the instruments for a period beyond the call exercise date.
(xv) Risk factors associated with Short Selling
Short-selling is the sale of shares which are not owned by the seller at the time of trade. Instead, he
borrows it from someone who already owns it. Later, the short seller buys back the stock he shorted and
returns the stock to close out the loan. If the price of the stock corrects, Short seller can buy the stock back
for less than he received for selling it and earn profit (the difference between higher short sale price and
the lower purchase price).If the price of stock appreciates, short selling results in loss. Thus, Short
positions carry the risk of losing money and these losses may grow theoretically unlimited if the price
increases without limit and shall result into major losses in the portfolio.
(xvi) Risk factors associated with processing of transaction through Stock Exchange Mechanism
The trading mechanism introduced by the stock exchange(s) is configured to accept and process
transactions for fund units in both Physical and Demat Form. The allotment and/or redemption of Units
through NSE and/or BSE or any other recognised stock exchange(s), on any Business Day will depend
upon the modalities of processing viz. collection of application form, order processing/settlement, etc. upon
which the Fund has no control. Moreover, transactions conducted through the stock exchange mechanism
shall be governed by the operating guidelines and directives issued by respective recognized stock
exchange(s).
(xvii) Risk factors associated with REITs and InvITs:
• Price Risk: Securities/Instruments of REITs and InvITs are volatile and prone to price fluctuations on a
daily basis owing to market movements. The extent of fall or rise in the prices is a fluctuation in general
market conditions, factors and forces affecting capital market, Real Estate and Infrastructure sectors, level
of interest rates, trading volumes, settlement periods and transfer procedures.
• Interest Rate Risk: Securities/Instruments of REITs and InvITs run interest rate risk. Generally, when
interest rates rise, prices of units fall and when interest rates drop, such prices increase.
• Credit Risk: Credit risk means that the issuer of a REIT/InvIT security/ instrument may default on interest
payment or even on paying back the principal amount on maturity. Securities/ Instruments of REITs and
InvITs are likely to have volatile cash flows as the repayment dates would not necessarily be
pre scheduled.
30• Liquidity Risk: This refers to the ease with which securities/instruments of REITs/InvITs can be sold.
There is no assurance that an active secondary market will develop or be maintained. Hence there would
be time when trading in the units could be infrequent. The subsequent valuation of illiquid units may reflect
a discount from the market price of comparable securities/instruments for which a liquid market exists. As
these products are new to the market they are likely to be exposed to liquidity risk.
• Reinvestment Risk: Investments in securities/instruments of REITs and InvITs may carry reinvestment
risk as there could be repatriation of funds by the Trusts in form of buyback of units or Dividend pay-outs,
etc. Consequently, the proceeds may get invested in assets providing lower returns.
• Legal and Regulatory Risk: The regulatory framework governing investments in securities/instruments
of REITs and InvITs comprises a relatively new set of regulations and is therefore untested, interpretation
and enforcement by regulators and courts involves uncertainties. Presently, it is difficult to forecast as to
how any new laws, regulations or standards or future amendments will affect the issuers of REITs/InvITs
and the sector as a whole. Furthermore, no assurance can be given that the regulatory system will not
change in a way that will impair the ability of the Issuers to comply with the regulations, conduct the
business, compete effectively or make distributions.
(xviii) Risk factors associated for investments in SIF Investment strategy
1. Movements in the Net Asset Value (NAV) of these Investment strategy may impact the performance.
Any change in the investment policies or fundamental attributes of these Investment strategies will
affect the performance of the Investment strategy to the extent of investment in such investment
strategy.
2. Redemptions by in these Investment strategy would be subject to applicable exit loads.
(xix) Risk Factors Associated with Investments in Credit Default Swaps (CDS)
• Model Risk: Valuing CDS requires complex models, especially for spread curves, hazard rates, and
correlation in CDS indices.
• Liquidity Risk: CDS markets can become illiquid, especially in times of market stress. Wide bid-ask
spreads and difficulty exiting positions can lead to unexpected losses or mark-to-market issues.
• Settlement Risk: Following a credit event, settlement (especially physical settlement) can be
operationally complex
C. Risk mitigation strategies
SO.9
Equity:
• Liquidity Risk: The fund will try to maintain a proper asset-liability match to ensure redemption payments
are made on time and not affected by illiquidity of the underlying stocks.
• Concentration Risk: The investment strategy will endeavour to have a well-diversified equity portfolio
comprising stocks across various sectors of the economy. This would aid in managing concentration risk
and sector-specific risks. Generally, diversification across market cap segments also aids in managing
volatility and ensuring adequate liquidity at all times.
Debt
• Interest Rate Risk: The Fund seeks to mitigate this risk by keeping the maturity of the investment strategy
in line with the interest rate expectations.
• Credit risk or default risk: Management analysis will be used for identifying company specific risks.
Management’s past track record will also be studied. In order to assess financial risk a detailed assessment
of the issuer’s financial statements will be undertaken.
• Reinvestment Risk: Reinvestment risks will be limited to the extent of coupons received on debt
instruments, which will be a very small portion of the portfolio value.
• The Investment strategy may invest in derivative for the purpose of hedging, portfolio balancing and other
purposes as may be permitted under the Regulations. Interest Rate Swaps will be done with approved
counter parties under pre-approved ISDA agreements. Interest rate swaps and other derivative instruments
will be used as per local (RBI and SEBI) regulatory guidelines.
• Liquidity or Marketability Risk: Liquidity risk may be high on select securities due to duration and/or issue
structure and/ or issuer-specific risk. Liquidity Risk can be partly mitigated by diversification, staggering of
maturities as well as internal risk controls that lean towards purchase of liquid securities.
Trading in Derivatives
31The Investment strategy may invest in derivatives based on the opportunities available subject to the
guidelines provided by SEBI from time to time and in line with the overall investment objective of the
Investment strategy. The Investment strategy may invest in derivative instruments like Futures, Options,
Interest Rate Swaps, Forward Rate Agreements, and such other derivative instruments as may be
permitted by SEBI from time to time. Derivative investments may be undertaken to hedge the portfolio, re-
balance the same or to undertake any other strategy as permitted under SEBI (MF) Regulations from time
to time. Hedging could be perfect or imperfect. In case the Investment strategy has investment in foreign
securities, then it may hedge the exchange rate risk on all receivables on these instruments through various
derivative products such as forwards, currency futures/ options, etc. Derivatives can be traded over the
exchange or can be structured between two counter-parties. Those transacted over the exchange are called
Exchange Traded derivatives whereas the other category is referred to as OTC (Over the Counter)
derivatives. Some of the differences of these two derivative categories are as under:
Exchange traded derivatives: These are quoted on the exchanges like any other traded asset class. The
most common amongst these are the Index Futures, Index Options, Stock Futures and Options on individual
equities / securities. The basic form of the futures contract is similar to that of the forward contract, a futures
contract obligates its owner to purchase a specified asset at a specified exercise price on the contract
maturity date. Futures are cash-settled and are traded only in organised exchanges. Exchange traded
derivatives are standardised in terms of amount and delivery date. Standardisation and transparency
generally ensures a liquid market together with narrower spreads. On the other hand, for delivery dates far
in the future, there may be insufficient liquidity in the futures market whereas an OTC price may be
available.
OTC derivatives: OTC derivatives require the two parties engaging in a derivatives transaction to come
together through a process of negotiation. It is a derivative that is customised in terms of structure, amount,
tenor, underlying assets, collateral etc. Some of the common examples are interest rate and currency
swaps, Forward Rate Agreements (FRAs) etc.
Trading in derivatives for short exposure
• Investment team will select derivatives with high liquidity to minimize the impact of wide bid-ask
spreads, ensuring smoother entry and exit from positions. This reduces transaction costs and enables
trade execution at desired prices, especially for complex strategies requiring multiple transactions.
• Investment team will enforce rigorous risk management protocols to limit potential losses, particularly
in speculative or volatility-sensitive strategies. By setting predefined loss thresholds for automatic
position exits, AMC will prevent significant drawdowns and preserve capital.
• To reduce concentration risk, investment team will diversify its positions across various assets,
strategies, and expiration dates. This approach mitigates the impact of unfavorable price movements
in any single position, enhancing portfolio stability in volatile market conditions.
• Investment team will ensure sufficient margin reserves to cover potential obligations, especially for
strategies involving short positions. This prevents forced liquidations at unfavorable prices and
supports portfolio stability during adverse market movements.
• Investment team will continuously monitor implied volatility and market trends to make dynamic
adjustments to positions. By exiting options early to minimize time decay or rebalancing complex
strategies to align with market trends, AMC will enhance profitability and reduce exposure to
unexpected market shifts.
• Investment team will select cost-effective derivatives and partner with low-cost brokers to minimize
transaction expenses. This ensures that premiums and commissions do not erode returns,
particularly in high-frequency or low- margin strategies like arbitrage, preserving overall profitability.
Exposure to Derivatives
Please refer to Asset Allocation of the investment strategy for the details of maximum exposure to
investment in Derivatives by the Investment strategy.
Exposure Limits
The exposure limits for trading in derivatives by SIF are as specified by SEBI vide its Master Circular for
Mutual Fund dated March 20, 2026, as amended from time to time are as follows:
1. The cumulative gross exposure through equity, debt, derivative positions (including fixed income
derivatives), repo transactions and credit default swaps in corporate debt securities,
Infrastructure Investment Trusts (InvITs), other permitted securities/assets and such other
securities/assets as may be permitted by SEBI from time to time shall not exceed 100% of the
net assets of the investment strategy.
2. SIF shall not write options or purchase instruments with embedded written options.
323. The total exposure related to option premium paid must not exceed 20% of the net assets of the
investment strategy.
4. Cash or cash equivalents i.e. Government Securities, T-Bills and Repo on Government Securities
having residual maturity of less than 91 days may be treated as not creating any exposure.
5. Exposure due to hedging positions may not be included in the above mentioned limits subject to
the following:
• Hedging positions are the derivative positions that reduce possible losses on an existing
position in securities and till the existing position remains.
• Hedging positions cannot be taken for existing derivative positions. Exposure due to such
positions shall have to be added and treated under limits mentioned in Point 1.
• Any derivative instrument used to hedge has the same underlying security as the existing
position being hedged.
• The quantity of underlying associated with the derivative position taken for hedging purposes
does not exceed the quantity of the existing position against which hedge has been taken.
6. (a) SIF may enter into plain vanilla Interest Rate Swaps (IRS) for hedging purposes. The value of
the notional principal in such cases must not exceed the value of respective existing assets being
hedged by the investment strategy.
(b) In case of participation in IRS is through over the counter transactions, the counter party has
to be an entity recognized as a market maker by RBI and exposure to a single counterparty in
such transactions should not exceed 10% of the net assets of the investment strategy. However,
if SIF are transacting in IRS through an electronic trading platform offered by the Clearing
Corporation of India Ltd. (CCIL) and CCIL is the central counterparty for such transactions
guaranteeing settlement, the single counterparty limit of 10% shall not be applicable.
7. Exposure due to derivative positions taken for hedging purposes in excess of the underlying
position against which the hedging position has been taken, shall be treated under the limits
mentioned in point
8. Definition of Exposure in case of Derivative Positions:
Each position taken in derivatives shall have an associated exposure as defined under. Exposure
is the maximum possible loss that may occur on a position. However, certain derivative positions
may theoretically have unlimited possible loss. Exposure in derivative positions shall be computed
as follows:
Position Exposure
Long Future Futures Price * Lot Size * Number of Contracts
Short Future Futures Price * Lot Size * Number of Contracts
Option Bought Option Premium Paid * Lot Size * Number of Contracts
Option Sold Market price of the underlying * Lot size * Number of contracts
9. In case of any other derivative exposure, the exposure shall be calculated as the notional market
value of the contract.
10. The total exposure at any point of time shall be the sum of exposure through instruments in both
the cash market and derivatives market
II. Information about the investment strategy:
SO.29
A. Where will the investment strategy invest – In terms of Regulation 51of SEBI (MF) Regulations,
detailed description of the instruments as permitted under Regulation 39 for investment strategies
(including overview of debt markets in India, if applicable) mentioned in Section I
The corpus of the investment strategy, subject to the enabling provisions of asset allocation pattern, will be
invested in securities/ instruments which will include but not limited to:
Equity and equity related instruments
1. Equity Instruments and Equity related instruments including convertible bonds and
debentures and
warrants carrying the right to obtain equity shares
2. Equity Derivatives including stock futures/options and index futures/options
Debt & Money Market Instruments SO. 13
1. Non-Convertible Debentures
2. Non-Convertible Preference Shares (NCPS)*
3. Floating rate debt instruments
4. Securitised Asset
335. Pass Through Certificate
6. Securities created and issued by the Central and State Governments as may be permitted by RBI
7. Debt Instruments with special features i.e. Additional Tier I (AT1) / Perpetual Bonds and Tier 2 Bonds
8. Debt Instruments having Structured Obligation (SO rating) and / or Credit Enhancements (CE rating)
9. Debt Derivative Instrument like Interest Rate Swaps, Forward Rate Agreement and such other
derivative instruments as may be permitted under the Regulations
10. Certificate of Deposits
11. Commercial Paper
12. Treasury Bills
13. Tri-party Repo
14. Reverse Repo in securities other than corporate debt securities
15. Cash Management Bills
16. Bills Rediscounting
17. Units of Debt Schemes of Mutual Fund
18. Pending deployment of funds, the Investment strategy may park funds in Short Term Deposits of
Scheduled commercial banks
19. Obligations/ Term Deposits of banks (both public and private sector) and development financial
institutions to the extent permissible under SEBI Regulations
20. Credit default swaps
21. Any other securities as permitted by SEBI/RBI from time to time
*As per note 2 of clause 13.1 of SEBI Master Circular on Mutual Funds dated March 20, 2026, Non-Convertible
Preference Shares (NCPS) shall be treated as Debt instruments.
Securitised debt may be held up to 25% of debt portfolio. The securities/debt instruments mentioned above
could be listed or unlisted, secured or unsecured, rated and of varying maturities and other terms of issue.
The securities may be acquired through Initial Public Offerings (IPOs), secondary market operations, private
placement, rights offer or negotiated deals. The Investment strategies may also enter into repurchase and
reverse repurchase obligations in all securities held by it as per guidelines/regulations applicable to such
transactions. Investment in IPOs/FPO/OFS/QIBs: This strategy attempts to make investments in companies
through Initial Public offers or secondary offers through Follow-on Public Offers or OFS or Qualified
Institutional Buyers route. Transfer of investments from one strategy to another strategy in the same SIF,
shall be allowed, in lines with clause 13.19 of SEBI Master Circular on Mutual Funds dated March 20, 2026.
SO. 16 Real Estate Investment Trusts (REITs) & Infrastructure Investment Trusts (InVITs)
Investments in Derivative Instruments
As part of the Fund Management process, the Trustee may permit the use of derivative instruments such
as index futures, stock futures and options contracts, warrants, convertible securities, swap agreements,
Forward Rate Agreement (FRA) or any other derivative instruments that are permissible or may be
permissible in future under applicable regulations and such investments shall be in accordance with the
investment objectives of the investment strategy. Index futures/options are meant to be an efficient way of
buying/selling an index compared to buying/selling a portfolio of physical shares representing an index for
ease of execution and settlement. Index futures/options can be an efficient way of achieving the investment
strategy’s investment objective.
On the fixed income side, an interest rate swap agreement from fixed rate to floating rate is an example of
how derivatives can be an effective hedge for the portfolio in a rising interest rate environment. Derivatives
can be either exchange traded or can be over the counter (OTC). Exchange traded derivatives are listed
and traded on Stock Exchanges whereas OTC derivative transactions are generally structured between
two counterparties. Derivatives may be high risk - high return instruments, upon leveraging. As they are
highly leveraged, a small price movement in the underlying security could have a large impact on their value
and may also result in a loss.
Position Limits:
The investment strategy may enter into derivative transactions in line with the guidelines prescribed by
SEBI from time to time. The exposure limit per scrip/instrument shall be to the extent permitted by the SEBI
Regulation for the time being in force. These limits will be reviewed by the AMC from time to time. Trading
in derivatives by the investment strategy shall be restricted to hedging, portfolio balancing purposes and
34upto 25% unhedged short derivative exposure.
Currently, the position limits for Specialized Investment Fund and its investment startegies, as permitted by
the SEBI Regulations, are as under: The cumulative gross exposure through equity, debt and derivative
positions (including commodity and fixed income derivatives), and repo transactions 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 SEBI from time to
time) should not exceed 100% of the net assets of the investment strategy. Exposure due to hedging
positions may not be included in the above mentioned limit subject to the following:
• Hedging positions are the derivative positions that reduce possible losses on an existing position in
securities and till the existing position remains.
• Hedging positions cannot be taken for existing derivative positions. Exposure due to such positions
shall have to be added and treated under limits mentioned above.
• Any derivative instrument used to hedge has the same underlying security as the existing position
being hedged.
• The quantity of underlying associated with the derivative position taken for hedging purposes does not
exceed the quantity of the existing position against which hedge has been taken.
Exposure due to derivative positions taken for hedging purposes in excess of the underlying position against
which the hedging position has been taken, shall be treated under the limits mentioned above. Further, the
total exposure related to option premium paid must not exceed 20% of the net assets of the investment
strategy. Pursuant to SEBI letter dated November 03, 2021, Cash or cash equivalents shall consist of
following securities having residual maturity of less than 91 days which are not considered for the purpose
of calculating gross exposure limit:
1) Government Securities
2) T-Bills
3) Repo on Government Securities
Exposure to Derivatives: The exposure limits for trading in derivatives by Specialized Investment Fund
specified by SEBI vide its clause 8.5, 13.15 and 21.6 of Master Circular dated March 20, 2026 and as
amended from time to time are as follows:
The Investment strategy may take position in derivative instruments like Futures, Options, and such
other derivative instruments as may be permitted by SEBI from time to time.
Equity Derivatives including Index/Stock Futures & Options - Equity derivatives are financial
instruments, generally traded on an exchange, the price of which is directly dependent upon (i.e. “derived
from”) the value of equity shares or equity indices. Derivatives involve the trading of rights or obligations
based on the underlying, but do not directly transfer property.
Futures - Futures are exchange-traded contracts to sell or buy financial instruments for future delivery at
an agreed price. There is an agreement to buy or sell a specified quantity of financial instrument on a
designated future date at a price agreed upon by the buyer and seller at the time of entering into a contract.
To make trading possible, the exchange specifies certain standardized features of the contract. A futures
contract involves an obligation on both the parties to fulfill the terms of the contract.
SEBI has permitted futures contracts on indices and individual stocks with maturity of 1 month, 2 months
and 3 months on a rolling basis. The futures contracts are settled on last Thursday (or immediately
preceding trading day if Thursday is a trading holiday) of each month. The final settlement price is the
closing price of the underlying stock(s)/index. However, pursuant to SEBI Circular No.
SEBI/HO/MRD/DOPI/ CIR/P/2018/161 dated December 31, 2018, stock derivatives are physically settled.
Option - Option is a contract which provides the buyer of the option (also called holder) the right, without
the obligation, to buy or sell a specified asset at the agreed price on or upto a particular date. For acquiring
this privilege, the buyer pays a premium (fee) to the seller. The seller on the other hand has the obligation
to buy or sell specified asset at the agreed price and for this obligation he receives a premium. The premium
is determined by considering number of factors such as the market price of the underlying asset/security,
number of days to expiry, risk free rate of return, strike price of the option and the volatility of the underlying
35asset. Option contracts are of two types viz:
Call Option - The option that gives the buyer the right to buy a specified quantity of the underlying asset
at the strike price is a call option. The buyer of the call option (known as the holder of call option) can call
upon the seller of the option (writer of the option) and buy from him the underlying asset at the agreed price
at any time on or before the expiry of the option. The seller (writer of the option) on the other hand has the
obligation to sell the underlying asset if the buyer of the call option decides to exercise his option to buy.
Put Option - The right to sell is called put option. A Put option gives the holder (buyer) the right to sell
specified quantity of the underlying
asset at the strike price. The seller of the put option (one who is short Put) however, has the obligation to
buy the underlying asset at the strike price if the buyer decides to exercise his option to sell. There are two
kinds of options based on the date of exercise of right. The first is the European Option which can be
exercised only on the maturity date. The second is the American Option which can be exercised on or
before the maturity date.
Example on options: Buying a Call Option: Assume that the investment strategy buys a call option at the
strike price of Rs. 2,000 and pays a premium of Rs. 100. If the market price of the underlying stock is Rs.
1,900, the investment strategy will not exercise the option and it shall lose the premium of Rs. 100. Thus,
in the above example, the loss for the investment strategy, as the buyer of the option, is limited to the
premium paid by him while the gains are unlimited.
Buying a Put Option: Assume that the investment strategy buys a put option at the strike price of Rs. 2,000
and pays a premium of Rs. 100.If the market price of the underlying stock decreases to Rs. 1,850 the
investment strategy would be protected from the downside and would be able to gain Rs. 50 (Strike Price
– Spot Price of underlying – Premium paid) whereas if the stock price moves up to say Rs. 2,150 the
investment strategy may let the option expire and forego the premium of Rs. 100.
Writing a Call Option: Assume that the investment strategy writes a call option at the strike price of Rs.
2,050 and earns a premium of Rs.100. If the market price of the underlying stock on the date of expiry
increases to Rs. 2,200 (i.e. more than Rs. 2,050) then the option is exercised. The investment strategy
earns the premium of Rs. 100 but loses the difference between the market price and the exercise price
i.e. Rs. 150. In case the market price of the underlying stock decreases to Rs. 2,000, the investment
strategy gets to keep the premium of Rs. 100.
Writing a Put Option: Assume that the investment strategy writes a put option at the strike price of Rs.
2,050 and earns a premium of Rs. 50. If the market value of the underlying stock decreases to Rs. 2,000
the put option will be exercised and the investment strategy will earn the premium of Rs. 50 but loses the
difference between the exercise price and the market price which is Rs. 50. However, if the market price
of the underlying stock is Rs. 2,100, the option-holder will not exercise the option. As a result of which the
option will expire and the investment strategy will earn the premium income of Rs. 50. The option premium
received shall be the part of covered call strategy and shall be invested in Debt and once the contract
expires it shall get adjusted in NAV of the investment strategy.
Exposure on account of call option written under the covered call strategy:
The investment strategy will write call options only under a covered call strategy for constituent stocks of
NIFTY 50 and BSE SENSEX subject to the following:
a) The total notional value (taking into account strike price as well as premium value) of call options written shall
not exceed 15% of the total market value of the underlying equity shares held at all points in time. In case of
any passive breach, the investment strategy shall have 7 trading days to rebalance the portfolio. During the
rebalancing period, no additional call options will can be written in the investment strategy.
b) The total number of shares underlying the call options written shall not exceed 30% of the unencumbered
shares of the particular company held in the investment strategy at all points in time. The unencumbered shares
in a investment strategy shall mean shares that are not part of Securities Lending and Borrowing Mechanism
(SLBM), margin or any other kind of encumbrances.
c) In case the investment strategy needs to sell securities on which a call option is written under a covered call
strategy, it must ensure compliance with (a) and (b) above while selling the securities
d) The investment strategy shall not write a call option without holding the underlying equity shares. A call option
can be written only on shares which are not hedged using other derivative contracts.
e) The total gross exposure related to option premium paid and received will not exceed 20% of the net assets
36of the investment strategy.
In case of any passive breach of the requirement at Paragraph (a), the respective investment strategy shall have
7 trading days to rebalance the portfolio. During the rebalancing period, no additional call options can be written
in the said investment strategy.
(a) The fund has an existing equity portion invested in a basket of stocks. In case the fund manager has a view
that the equity markets are headed downwards, the fund can then hedge the exposure to equity either fully or
partially by initiating short futures positions in the index. A similar position in the long direction can also be
initiated by the fund to hedge its position of cash and permissible equivalents. The extent to which this can be
done is determined by existing guidelines.
(b) To the extent permissible by extant regulations the investment strategy can initiate a naked short position in
an underlying index future traded on a recognized stock exchange. Further the Investment strategy may use
index and stock futures and options to create an unhedged 25% short derivative exposure. For example: The
investment strategy may buy put options of stocks that it does not hold in cash market, thus creating a net short
exposure.
In case the Nifty near month future contract trading at say, 1500, and the fund manager has a view that it will
depreciate going forward, the fund can initiate a sale transaction of nifty futures at 1500 without holding a
portfolio of equity stocks or any other underlying long equity position. Once the price falls to 1400 after say, 20
days the fund can initiate a square- up transaction by buying the said futures and book a profit of 100.
Correspondingly the fund can take a long position without an underlying cash/ cash equivalent subject to the
extant regulations. Risks:
· The risks associated with index futures are similar to those associated with equity investments. Additional risks
could be on account of illiquidity and potential mis– pricing of the futures and the inability of derivatives to
correlate perfectly with underlying assets, rates and indices.
· The Long position in the Nifty will have as much loss as the gain in the short portfolio if hedged completely and
would be vice versa if we were holding long portfolio, short Index. Strategies that employ Stock Futures: Sell
Spot Buy Future: To illustrate, let us assume the fund holds the stock XYZ Ltd which is trading @ Rs. 100/- at
the spot market. If for some reasons the stock trades at Rs. 98 in the futures, the fund may sell the stock and
buy the futures. On the date of expiry, the fund may reverse the transactions (i.e. Buy Spot & Sell futures) and
earn a risk-free Rs. 2/- (2% absolute) on its holdings. Since this is done without diluting the fund’s view on the
underlying stock, the fund will benefit from any upside move i.e. if on the date of futures expiry, the stock is
trading at Rs. 110/- the futures too will be trading at Rs. 110- and the fund will capture the 10% upside the stock
provided and along with it the 2% arbitrage too, thereby enhancing returns to 12% Risks:
• While Futures markets are typically more liquid than the underlying cash market, there can be no assurance
that ready liquidity would exist at all points in time for investment strategy to purchase or close out a specific
futures contract.
• The risks associated with stock futures are similar to those associated with equity investments. Additional risks
could be on account of illiquidity and potential mis– pricing of the futures. Buy Spot Sell Future: If the fund holds
a stock XYZ Ltd which trades @ Rs 100/- at the spot market and is trading at Rs. 102/- in the futures market. The
fund may buy the spot and sell the futures and earn the premium of Rs.2 /- which is risk-free. However this
strategy can be used only when the fund is sitting in cash and is looking at enhancing the returns on the cash.
Risks:
• While Futures markets are typically more liquid than the underlying cash market, there can be no
assurance that ready liquidity would exist at all points in time for investment strategy to purchase or close
out a specific futures contract.
• Trading in derivatives by the investment strategy shall be restricted to hedging, portfolio balancing and upto
25% unhedged short exposure.
• The investment strategy shall fully cover its positions, except for the permissible short position, in the
derivatives market by holding underlying securities/cash or cash equivalents/option and/or obligation for
acquiring underlying assets to honour the obligations contracted in the derivatives market.
• Separate records shall be maintained for holding the cash and cash equivalents/securities for this purpose.
• The securities held shall be marked to market by the AMC to ensure full coverage of investments made in
derivative products at all time.
37The Investment strategy may take position in derivative instruments like Futures, Options, and such
other derivative instruments as may be permitted by SEBI from time to time.
Valuation:
• The traded derivatives shall be valued at market price in conformity with the stipulations Seventh Schedule
of Securities and Exchange Board of India (Mutual Funds) Regulations, 2026.
• The valuation of untraded derivatives shall be done in accordance with the valuation method for untraded
investments prescribed in Seventh Schedule of the Securities and Exchange Board of India (Mutual
Funds) Regulations, 2026.
Interest Rate Swaps:
The Indian markets have faced high volatility in debt and equity markets. An interest rate swap is a contractual
agreement between two counter-parties to exchange streams of interest amount on a national principal basis. In
this, one party agrees to pay a fixed stream of interest amount against receiving a variable or floating stream of
interest amount. The variable or floating part is determined on a periodical basis. The Investment strategy may
enter into plain vanilla Interest Rate Swaps (IRS) for hedging purposes. The value of the notional principal in
such cases must not exceed the value of respective existing assets being hedged by the investment strategy.
In case of participation in IRS is through over the counter transactions, the counter party has to be an entity
recognized as a market maker by RBI and exposure to a single counterparty in such transactions should not
exceed 10% of the net assets of the investment strategy. However, if Investment strategy is transacting in IRS
through an electronic trading platform offered by the Clearing Corporation of India Ltd. (CCIL) and CCIL is the
central counterparty for such transactions guaranteeing settlement, the single counterparty limit of 10% shall
not be applicable.
Purpose of Interest Rate Swaps: - The Indian markets have faced high volatility in debt and equity markets. An
interest rate swap is a contractual agreement between two counter-parties to exchange streams of interest
amount on a national principal basis. In this, one party agrees to pay a fixed stream of interest amount against
receiving a variable or floating stream of interest amount. The variable or floating part is determined on a
periodical basis.
The investment strategy shall use derivative position for hedging the portfolio risk on a nonleverage basis. The
investment strategy shall fully cover their positions in the derivatives market by holding underlying securities /
cash or cash equivalents / option and / or obligation for acquiring underlying assets to honour the obligations
contracted in the derivatives market.
Example of an interest rate swap: Entity A has Rs.20 crores, 3 month asset which is being funded through call.
Entity B, on the other hand, has deployed Rs.20 crores in overnight call money market, 3 month liability. Both the
entities are taking on an interest rate risk. To hedge against the interest rate risk, both the entities can enter into
a 3 month swap agreement based on say MIBOR (Mumbai Inter Bank Offered Rate). Through this swap, entity
B will receive a fixed pre-agreed rate (say 8%) and pay NSE MIBOR (“the benchmark rate”) which will neutralize
the interest rate risk of lending in call. Similarly, entity A will neutralize its interest rate risk from call borrowing
as it will pay 8% and receive interest at the benchmark rate. Assuming the swap is for Rs.20 crores 1 September
to 1 December, Entity A is a floating rate receiver at the overnight compounded rate and Entity B is a fixed rate
receiver. On a daily basis, the benchmark rate fixed by NSE will be tracked by them. On December 1, they will
calculate as explained below:
Entity A is entitled to receive daily compounded call rate for 92 days and pay 8% fixed. Entity B is entitled to
receive interest on Rs.20 crores @ 8% i.e. Rs.40.33 lakhs, and pay the compounded benchmark rate. Thus on
December 1, if the total interest on the daily overnight compounded benchmark rate is higher than Rs.40.33
lakhs, entity B will pay entity A the difference and vice versa.
Forward Rate Agreement (FRA) A FRA is basically a forward starting IRS. It is an agreement between two
parties to pay or receive the difference between an agreed fixed rate (the FRA rate) and the interest rate
(reference rate) prevailing on a stipulated future date, based on a notional principal amount for an agreed
period. The only cash flow is the difference between the FRA rate and the reference rate. As is the case with
IRS, the notional amounts are not exchanged in FRAs. Example: Let us assume that a investment strategy
has an investment of Rs.10 crore in an instrument that pays interest linked to NSE Mibor. Since the NSE Mibor
would vary daily, the investment strategy is running interest rate risk on its investment and would stand to lose
if rates go down.
To hedge itself against this risk, the investment strategy could do an IRS where it receives a fixed rate.
(assume 10%) for the next 5 days on the notional amount of Rs. 10 crore and pay a floating rate (NSE Mibor).
In doing this, the investment strategy would effectively lock itself into a fixed rate of 10% for the next five days.
38The steps would be:
1. The investment strategy enters into an IRS on Rs. 10 crore from December 1 to December 6. It receives a
fixed rate of interest at 10% and the counter party receives the floating rate (NSE Mibor). The investment
strategy and the counter party exchange a contract of having entered into this IRS.
2. On a daily basis, the NSE Mibor will be tracked by the counterparties to determine the floating rate payable by
the investment strategy.
3. On December 6, the counterparties will calculate the following:
The investment strategy will receive interest on Rs. 10 crore at 10% p.a. for 5 days i.e. Rs.1,36,986/-
The investment strategy will pay the compounded NSE Mibor for 5 days by converting its floating rate asset
into a fixed rate through the IRS.
If the total interest on the compounded NSE Mibor rate is lower than Rs. 1,36,986/-, the investment strategy
will receive the difference from the counterparty and vice- versa. In case the interest on compounded NSE
Mibor is higher, the investment strategy would make a lower return than what it would have made had it not
undertaken IRS. Risks: Interest rate swaps and Forward Rate Agreement require the maintenance of adequate
controls to monitor the transactions entered into, the ability to assess the risk that the derivative adds to the
portfolio and the ability to forecast failure of another party (usually referred to as the “counter-party”) to comply
with the terms of the derivatives contract. Other risks in using derivatives include the risk of mis-pricing or
improper valuation of derivatives, the credit risk where the danger is that of a counter-party failing to honour its
commitment, liquidity risk where the danger is that the derivative cannot be sold at prices that reflect the
underlying assets, rates and indices, and price risk where the market price may move in adverse fashion. As
is clear from the above examples, engaging in derivatives has the potential to help the investment strategy in
minimising the portfolio risk and/or improve the overall portfolio returns.
These examples are hypothetical in nature and are given for illustration purposes only. The actual returns may
vary depending on the market conditions. The AMC retains the right to enter into such derivative transactions
as may be permitted by the applicable regulations from time to time.
SECURITIES LENDING.
If permitted by SEBI under extant regulations/guidelines, the Investment strategy may also engage in scrip
lending as provided under Securities Lending 1997, as per Para 13.6 of SEBI Master Circular on Mutual Funds
dated March 20,2026 and other applicable guidelines/regulations, as amended from time to time. Scrip lending
means lending a security to another person or entity for a fixed period of time, at a negotiated
compensation. The security lent will be returned by the borrower on or before the expiry of the stipulated period.
The AMC will comply with the required reporting obligations and the Trustee will carry out the reviews required
under SEBI/RBI guidelines. Further a maximum of 20% of net assets will be deployed in securities lending and
the maximum single party exposure will be restricted to 5%# of net assets outstanding at any point of time.
# Presently, Securities lending and borrowing (SLB) is an Exchange traded product. Counterparty is not known
for transactions carried out under SLB segment and they are guaranteed by Clearing Corporations and hence
do not carry any counter party risk. Accordingly, single party exposure limit will not apply to trades on Stock
Exchange platform. Single party exposure limits can only apply in case of OTC (over the counter) trades where
counterparty can be identified. Engaging in scrip lending is subject to risks related to fluctuations in the
collateral value / settlement / liquidity / counter party.
INVESTMENT IN SECURITISED DEBT
1. How the risk profile of securitized debt fits into the risk appetite of the investment strategy
Securitization is the fact or process of securitizing assets i.e. the conversion of loans into securities, usually
in order to sell them on to other investors. This is done by assigning the loans to a special purpose vehicle (a
trust), which in turn issues Pass-Through-Certificates (PTCs). These PTCs are transferable securities with
fixed income characteristics. The risk of investing in securitized debt is similar to investing in debt securities.
However, it differs mainly in two respects. One, the liquidity of securitized debt is less than similar debt
securities. Two, for certain types of securitized debt (backed by mortgages, personal loans, credit card debt,
etc.), there is an additional pre-payment risk. Pre-payment risk refers to the possibility that loans are repaid
before they are due, which may reduce returns if the re-investment rates are lower than initially envisaged.
Because of these additional risks, securitized debt typically offers higher yields than debt securities of similar
credit rating and maturity. After considering these additional risks, the investment is no different from
investment in a normal debt security. Considering the investment objective of the investment strategy, these
instruments with medium risk profile can be considered in the investment universe. Thus if the Fund Manager
judges that the additional risks are suitably compensated by the higher returns, he may invest in securitized
39debt up to the limits specified in the asset allocation table.
2. Policy relating to originators based on nature of originator, track record, NPAs, losses in earlier
securitized debt, etc
Investments in securitized debt will be done based on the assessment of the originator and the securitized
debt which is carried out by the Fixed Income team based on the in-house research capabilities as well as
the inputs from the independent credit rating agencies and by following internal credit process. Specifically,
in order to mitigate the risk at the issuer/originator level the Fixed Income team will consider various factors
which will include - - Track record of the originator in the specific business to which the underlying loans
correspond to; - size and reach of the issuer/originator; - Collection infrastructure & collection policies; - Post
default recovery mechanism & infrastructure;
- Underwriting standards & policies followed by originator; - Management information systems; -
Financials of the originators including an analysis of leverage, NPAs, earnings, etc.; - Future strategy of the
company for the specific business to which the underlying loans correspond to; - Performance track record of
Originator’s portfolio & securitized pools, if any; - Utilization of credit enhancement in the prior securitized pools;
- The quality of information disseminated by the issuer/ originator; and - The credit enhancement for different
types of issuer/originator. Also, assessment of business risk would be carried out which includes - - Outlook
for the economy (both domestic and global); and - Outlook for the industry
In addition, the fund analyses the specific pool and the broad evaluation parameters are as follows: - Average
seasoning of the loans in the pool - Average Loan to value ratio of the loans in the pool - Average ticket size
of the loans - Borrower profile (salaried / self employed, etc) - Geographical profile of the pool - Tenure profile
of the pool
- Obligor concentration - Credit enhancement cover available over and above the historic losses on
Originator’s portfolio - Expected Prepayment rate in the specific asset class experienced by the originator in
the past as well as the industry - Limited Liquidity and Price Risk. The investment strategy will invest in
securitized debt which are rated investment grade and above by a credit rating agency recognized by SEBI.
The investment team analyses the Rating Rationale in detail before investing in any PTCs, and also discusses
with the concerned rating agency on a need basis. The rating agency would normally take in to consideration
the following factors while rating a securitized debt:
Credit risk at the asset/originator/portfolio/pool level
- The quality of the pool is a crucial element in assessing credit risk. In the Indian context, generally, pools
are ‘cherry- picked’ using positive selection criteria. To protect the investor from adverse selection of pool
contracts, the rating agencies normally take into consideration pool characteristics such as pool seasoning
(seasoning represents the number of installments paid by borrower till date: higher seasoning represents
better quality), over dues at the time of selection and Loan to Value (LTV). To assess its risk profile vis-à-vis
the overall portfolio, the pool is analyzed with regard to geographical location, borrower profile, LTV, and
tenure. Counterparty risk - This includes Servicer Risk, co-mingling risk etc. The rating agencies generally
mitigate such risks though the usage of stringent counterparty selection and replacement criteria to reduce
the risk of failure.
Bankruptcy risk - Of the Originator – o Normally, specific care is taken in structuring the securitization
transaction so as to minimize the risk of the sale to the trust not being construed as a 'true sale'. It is also in the
Interest of the originator to demonstrate the transaction as a true sell to get the necessary revenue recognition
and tax benefits. - Of the Investors’ agent o All possible care is normally taken in structuring the transaction
and drafting the underlying documents so as to provide that the assets/receivables if and when held by
Investor’s Agent is held as agent and in Trust for the Investors and shall not form part of the personal assets
of Investor’s Agent. Legal risks - The rating agency normally conducts a detailed study of the legal documents
to ensure that the investors' interest is not compromised and relevant protection and safeguards are built into
the transaction. o Various market risks like interest rate risk, macro-economic risks o Assessment of risks
related to business for example outlook for the economy, outlook for the industry and factors specific to the
issuer/originator.
3. Risk mitigation strategies for investments with each kind of originator
The examples of securitized assets which may be considered for investment by the Investment strategy and the
various risk mitigation parameters (please read in continuation with point 2 above) which will be considered
include;
40A. Asset backed securities issued by banks or non-banking finance companies. Underlying assets may include
receivables from loans against cars, commercial vehicles, construction equipment or unsecured loans such
as personal loans, consumer durable loans. The various factors which will be usually considered while
making investments in such type of securities include profile of the issuer, analysis of underlying loan portfolio
– nature of asset class, seasoning of loans, geographical distribution of loans and coverage provided by
credit-cum-liquidity enhancements.
B. Mortgage backed securities issued by banks or housing finance companies, where underlying assets are
comprised of mortgages/home loan. The various factors which will be usually considered while making
investments in such type of securities include issuer profile of the issuer, quality of underlying portfolio,
seasoning of loans, coverage provided by credit-cum-liquidity enhancements and prepayment risks.
C. Single loan securitization, where the underlying asset comprises of loans issued by a bank/non-banking
finance company.
The factors which will be usually considered while making investments in such type of securities include
assessment of credit risk associated with the underlying borrower as well as the originator. The Fixed Income
team will adhere to internal credit process and perform a detailed review of the underlying borrower prior to
making investments. This analysis is no different from the analysis undertaken by Fund when it invests in
Debentures or Commercial papers issued by the same borrower. Critical Evaluation Criteria Typically the Fund
would avoid investing in securitization transaction (without specific risk mitigation strategies / additional
cash/security collaterals/ guarantees) if there are concerns on the following issues regarding the originator /
underlying issuer:
1. High default track record/ frequent alteration of redemption conditions/covenants
2. High leverage ratios – both on a standalone basis as well on a consolidated level/ group level
3. Higher proportion of re-schedulement of underlying assets of the pool or loan, as the case may be
4. Higher proportion of overdue assets of the pool or the underlying loan, as the case may be
5. Poor reputation in market
6. Insufficient track record of servicing of the pool or the loan, as the case may be.
Further, investments in securitized debt will be done in accordance with the investment restrictions specified
under the SEBI Regulations/ this Investment strategy Information Document which would help in mitigating
certain risks. Currently, as per the Regulations, the Investment strategy cannot invest more than 10% of its net
assets in debt instruments (irrespective of residual maturity) issued by a single issuer which are rated not below
investment grade by a credit rating agency authorized to carry out such activity under the Act. Such investment
limit may be extended to 12% of the net assets of the Investment strategy with the prior approval of the Board
of Trustees and the Board of the AMC.
4. The level of diversification with respect to the underlying assets, and risk mitigation measures for
less diversified investments
The framework which will generally be applied by the Fund Manager while evaluating the investment
decision with respect to securitized debt will be as follows:
Characteristics/ Mortgag Commercia1 CAR 2 wheelers Micro Personal Single Others
Type of Pool e Loan Vehicle and Finance Loans Sell
Construction Pools down$
Equipment
Approximate Upto 10 Upto 5years Upto 5 Upto 48 Upto 80 Upto 3 Case by As and when
Average maturity years years months weeks years case new
(in Months) basis
Collateral margin In excess In excess of In In excess of In excess In excess Case by asset
(including cash, of 3% 4% excess 4% of 5% of 5% case classes of
guarantees, of 4% basis securitized
excess interest debt are
spread, introduced,
subordinate the
tranche) investment
Average Loan to 95% or 100% or lower 95% or 95% or Unsecur Unsecur Case by such
Value Ratio lower ** lower lower ed ed case instruments
basis will be
Average Minimum Minimum 2 Minimu Minimum 2 Minimum Minimum Case by evaluated
seasoning of the 2 months months m 2 months 2 weeks 2 months case on a case by
41Pool months basis case basis
Maximum single < 5% < 5% NA NA NA NA NA
exposure range * (retail (retail pool) (Very (retail
pool) Small pool)
retail
pool)
Average single < 5% 5% < 2% < 1% < 1% < 1% NA
exposure range%
*
* denotes % of a single ticket/loan size to the overall assets in the securitized pool.
** LTV Based on chassis value
$ Broad evaluation criteria as per point 3 above
Notes:
a) Retail pools are the loan pools relating to Car, 2 wheeler, micro finance and personal loans, wherein the
average loan size is relatively small and spread over large number of borrowers.
b) The information illustrated in the table above is based on current scenario relating to securitized debt market
and is subject to change depending upon the change in the related factors.
In addition to the framework stated in the table above, in order to mitigate the risks associated with the underlying
assets where the diversification is less, at the time of investment the Fixed Income team could consider various
factors including but not limited to –
- Size of the loan - the size of each loan is generally analysed on a sample basis and an analysis of the static
pool of the originator is undertaken to ensure that the same matches with the static pool characteristics. It
also indicates whether there is high reliance on very small ticket size borrower which could result in delayed
and expensive recoveries.
- Average original maturity of the pool of underlying assets
- The analysis of average maturity of the pool is undertaken to evaluate whether the tenor of the loans are
generally in line with the average loans in the respective industry and repayment capacity of the borrower.
- Loan to value ratio, average seasoning of the pool of underlying assets - these parameters would be
evaluated based on the asset class as mentioned in the table above.
- Default rate distribution - the Fixed Income team generally ensures that all the contracts in the pool are
current to ensure zero default rate distribution.
- Geographical distribution - the analysis of geographical distribution of the pool is undertaken to ensure
prevention of concentration risk.
- Credit enhancement facility - credit enhancement facilities in the form of cash collateral, such as fixed
deposits, bank guarantee etc could be obtained as a risk mitigation measure.
- Liquidity facility - these parameters will be evaluated based on the asset class as mentioned in the table
above.
- Structure of the pool of underlying assets - The structure of the pool of underlying assets would be either
single asset class or combination of various asset classes as mentioned in the table above. We could add
new asset class depending upon the securitization structure and changes in market acceptability of asset
classes.
5. The minimum retention period of the debt by the originator prior to securitization
The minimum retention period of the debt by the originator prior to securitization and the minimum retention
percentage by originator of debts will be as per the guidelines/regulations issued by the RBI/other regulatory
agencies from time to time. Also, please refer the table in point 4. The Fund will adopt that policy, whichever
is stricter.
6. Minimum retention percentage by originator of debts to be securitized
Same as point 5 above.
7. The mechanism to tackle conflict of interest when the Specialized Investment Fund invests in
securitized debt of an originator and the originator in turn makes investments in that particular
investment strategy of the fund
42An investment by the investment strategy in any security is done after detailed analysis by the Fixed Income
team and in accordance with the investment objectives and the asset allocation pattern of a investment
strategy. All investments are made on an arm’s length basis without consideration of any investments
(existing/potential) in the investment strategies made by any party related/involved in the transaction. The
robust credit process ensures that there is no conflict of interests when a investment strategy invests in
securitized debt of an originator and the originator in turn makes investments in that particular investment
strategy.
8. The resources and mechanism of individual risk assessment with the AMC for monitoring
investment in securitized debt
The resources for and mechanisms of individual risk assessment with the AMC for monitoring investment
in securitized debt are as follows: -
- Fixed Income Team – Currently, the AMC has a well experienced team, which is responsible for credit
research, monitoring and fund management, for all exposures including securitized debt.
- Ratings are monitored for any movement – Based on the cash flow report and Fixed Income Team’s view,
periodic review of company credit appraisal shall be conducted & monitored accordingly.
As per the prevailing SEBI guidelines, the investments in securitised debt instruments will be shown as a
separate category under debt instruments in the half yearly disclosure of investment strategy portfolio.
• Usage of Short Term Deposits: Pending deployment of the funds in securities in terms of investment
objective of the Investment strategy, the AMC may park the funds of the Investment strategy in short term
deposits of the Scheduled Commercial Banks, subject to the guidelines issued by SEBI vide clause 13.7 of
SEBI Master Circular on Mutual Funds dated March 20, 2026, as may be amended from time to time.
B. What are the investment restrictions?
In pursuance of the Regulations, the following restrictions are currently applicable to the investment strategy:
1. The Investment strategy shall buy and sell securities on the basis of deliveries and shall in all cases of
purchases, take delivery of relevant securities and in all cases of sale, deliver the securities; provided that
the Investment strategy may engage in short selling of securities in accordance with the framework
relating to short selling and securities lending and borrowing specified by SEBI; provided further that the
Investment strategy may enter into derivatives transactions in a recognised stock exchange, subject to
the framework specified by SEBI; provided further that sale of government security already contracted for
purchase shall be permitted in accordance with the guidelines issued by the Reserve Bank of India in this
regard.
2. The Specialized Investment Fund shall, get the securities purchased or transferred in the name of the
Specialized Investment Fund on account of the concerned investment strategy, wherever investments
are intended to be of long term nature.
3. No investment shall be made in any Fund of Funds investment strategy.
4. The Specialized Investment Fund shall not advance any loans for any purpose.
5. The Investment strategy may invest in any other investment strategy without charging any fees, provided
that aggregate inter investment strategy investment made by all investment strategies under the
management of Wealth Company Asset Management Holdings Private Limited or in investment
strategies under the management of any other AMC shall not exceed 5% of the net asset value of the
Specialized Investment Fund.
6. Specialized Investment Fund under all its investment strategies should not own more than fifteen per cent
of any company’s paid up capital carrying voting rights, as per point 3 of clause 21.5 of SEBI Master
Circular dated March 20, 2026
Provided that investment in the asset management company or the trustee company of a Specialized
Investment Fund shall be governed by clause (a) of sub-regulation (1) of regulation 6:
Provided further that the limit mentioned above shall be inclusive of ten per cent limit for mutual fund
schemes as specified under clause 13.1 (5) of Master Circular dated March 20, 2026.
Explanation: If a Mutual Fund under all its schemes owns ten per cent of any company’s paid up capital
carrying voting rights, then the Specialized Investment fund under all its investment strategies shall not
own more than five per cent of that company’s paid up capital carrying voting rights.
7. All investments by the investment strategy in equity shares and equity related instruments shall only be
made provided such securities are listed or to be listed.
438. The investment strategy shall not invest more than 10% of its net assets in the equity or equity related
instruments of any company.
9. Investment in unlisted debt instruments:
9.1. The investment strategy shall not invest in unlisted debt instruments including commercial papers (CPs),
other than (a) government securities, (b) other money market instruments and (c) derivative products
such as Interest Rate Swaps (IRS), Interest Rate Futures (IRF), etc. which are used for hedging.
However, the investment strategy may invest in unlisted Non-Convertible Debentures (NCDs) not
exceeding 10% of the debt portfolio of the investment strategy subject to the condition that such unlisted
NCDs have a simple structure (i.e. with fixed and uniform coupon, fixed maturity period, without any
options, fully paid up upfront, without any credit enhancements or structured obligations) and are rated
and secured with coupon payment frequency on monthly basis.
10. Investment in unrated debt and money market instruments, other than government securities, treasury
bills, derivative products such as Interest Rate Swaps (IRS), Interest Rate Futures (IRF), etc. by the
investment strategy shall be subject to the following:
a. Investments should only be made in such instruments, including bills rediscounting, usance bills, etc., that
are generally not rated and for which separate investment norms or limits are not provided in
SEBI Master Circular dated March 20, 2026 .
b. Exposure of the investment strategy in such instruments, shall not exceed 5% of the net assets of the
investment strategy.
c. All such investments shall be made with the prior approval of the Board of AMC and the Board of Trustees.
d. The Investment strategy may enter into plain vanilla Interest Rate Swaps (IRS) for hedging purposes. The
value of the notional principal in such cases must not exceed the value of respective existing assets being
hedged by the investment strategy.
e. In case of participation in IRS is through over the counter transactions, the counter party has to be an
entity recognized as a market maker by RBI and exposure to a single counterparty in such transactions
should not exceed 10% of the net assets of the investment strategy. However, if Investment strategy is
transacting in IRS through an electronic trading platform offered by the Clearing Corporation of India Ltd.
(CCIL) and CCIL is the central counterparty for such transactions guaranteeing settlement, the single
counterparty limit of 10% shall not be applicable.
SO. 31
11. Sector Exposure – The exposure in a particular sector (excluding investments in Bank CDs, TREPs,
GSecs, T- Bills and AAA rated securities issued by Public Financial Institutions and Public Sector Banks)
under the portfolio will not exceed 20% of the net assets on account of purchase. An additional exposure
to financial services sector (over and above the limit of 20%) not exceeding 10% of the net assets of the
investment strategy on account of purchase shall be allowed by way of increase in exposure to Housing
Finance Companies (HFCs) only.
Further, an additional exposure of 5% of the net assets of the investment strategy shall be allowed for
investments in securitized debt instruments based on retail housing loan portfolio and/or affordable
housing loan portfolio. Provided that the additional exposure to such securities issued by HFCs are rated
AA and above and these HFCs are registered with National Housing Bank (NHB) and the total investment/
exposure in HFCs shall not exceed 20% of the net assets of the investment strategy on account of
purchase. The above restriction will not be applicable to the equity portion of the Investment strategy’s
portfolio (where applicable). b. Group Exposure - The total exposure of Investment strategy in a Group
(excluding investments in securities issued by Public Sector Units, Public Financial Institutions and Public
Sector Banks) will not exceed 20% of the net assets of the Investment strategy. Such investment limit may
be extended to 25% of the net assets of the Investment strategy with the prior approval of the Board of
Trustees. Investments by the Investment strategy in debt and money market instruments of group
companies of both the sponsor and the asset management company shall not exceed 10% of the net
assets of the investment strategy. Such investment limit may be extended to 15% of the net assets of the
Investment strategy with the prior approval of the Board of Trustees. For this purpose, a group means a
Group as defined under regulation 2 (1) (x) of SEBI (Mutual Funds) Regulations, 2026 (Regulations) and
shall include an entity, its subsidiaries, fellow subsidiaries, its holding company and its associates. The
above restrictions will not be applicable to the equity portion of the Investment strategy’s portfolio.
12. Debentures, irrespective of any residual maturity period (above or below one year), shall attract the
investment restrictions as applicable for debt instruments as specified under Clause 13.1 and 21.5 of
SEBI Master circular dated March 20, 2026.
13. Transfers of investments from one investment strategy to another will be done in inconformity with as per
44Para 13.19 of SEBI Master Circular on Mutual Funds dated March 20, 2026.
14. No investment shall be made in - any unlisted security of an associate or group company of the sponsor;
or - any security issued by way of private placement by an associate or group company of the sponsor; or
- the listed securities of group companies of the sponsor which is in excess of 25% of the net assets.
15. Pending deployment of funds in securities in terms of investment objectives of the Investment strategy,
the Specialized Investment Fund can invest the funds of the investment strategy in short term deposits of
scheduled commercial banks in line with Para 13.7 of SEBI Master Circular on Mutual Funds dated
March 20, 2026 as amended from time to time. The Investment strategy shall abide by the following
guidelines for parking of funds in short term deposits:
• Such short term deposits shall be held in the name of the investment strategy.
• The investment strategy shall not park more than 15% of the net assets in Short term deposit(s) of all
the scheduled commercial banks put together. However, such limit may be raised to 20% with prior
approval of the Trustees.
• Parking of funds in short term deposits of associate and sponsor scheduled commercial banks
together shall not exceed 20% of total deployment by the Specialized Investment Fund in short term
deposits.
• The investment strategy shall not park more than 10% of the net assets in short term deposit(s), with
any one scheduled commercial bank including its subsidiaries.
• The Investment starategy shall not park funds in short-term deposit of a bank, which has invested in
the Investment strategy. The bank in which the investment strategy has short-term deposit shall not
be permitted to invest in the said investment strategy until the investment strategy has short-term
deposit with such bank.
• AMC shall not charge any investment management and advisory fees for parking of funds in short
term deposits of scheduled commercial banks.
• The aforesaid limits are not applicable to term deposits placed as margins for trading in cash and
derivatives market.
16. Restrictions on Investment in debt instruments having Structured Obligations / Credit Enhancements:
• Investment of the investment strategy in the following instruments shall not exceed 10% of the debt portfolio of
the investment strategy and the Group exposure in such instruments shall not exceed 5% of the debt portfolio of
the investment strategy: a) Unsupported rating of debt instruments (i.e. without factoring-in credit enhancements)
is below investment grade.; and b) Supported rating of debt instruments (i.e. after factoring-in credit enhancement)
is above investment grade. For this purpose, a group means a Group as defined under regulation 2 (1 )(x) of SEBI
(Mutual Funds) Regulations, 2026 (Regulations) and shall include an entity, its subsidiaries, fellow subsidiaries,
its holding company and its associates.
• These investment limits mentioned above shall not be applicable on investments in securitized debt instruments,
as defined in SEBI (Public Offer and Listing of Securitized Debt Instruments) Regulations 2008.
• Investment in debt instruments, having credit enhancements backed by equity shares directly or indirectly, shall
have a minimum cover of 4 times considering the market value of such shares. AMC may ensure that the
investment in debt instruments having credit enhancements are sufficiently covered to address the market volatility
and reduce the inefficiencies of invoking of the pledge or cover, whenever required, without impacting the interest
of the investors. In case of fall in the value of the cover below the specified limit, AMC shall initiate necessary
steps to ensure protection of the interest of the investors.
17. Repo transactions in corporate debt securities
• The gross exposure of any mutual fund investment strategy to repo transactions in corporate debt
securities shall not be more than 10 % of the net assets of the concerned investment strategy.
• The cumulative gross exposure through repo transactions in corporate debt securities along with equity,
debt and derivatives shall not exceed 100% of the net assets of the concerned investment strategy.
18. The investment strategy may invest in certain debt instruments with special features viz. subordination to equity
(absorbs losses before equity capital) and /or convertible to equity upon trigger of a pre-specified event for loss
absorption (For eg. Additional Tier I bonds and Tier 2 bonds issued under Basel III framework) subject to the
following: a) Specialized Investment Fund under all its investment strategies shall not own more than 10% of such
instruments issued by a single issuer b) A Specialized Investment Fund shall not invest: a. more than 10% of its
NAV of the debt portfolio of the investment strategy in such instruments; and b. more than 5% of its NAV of the
debt portfolio of the investment strategy in such instruments issued by a single issuer. The above investment limit
for a investment strategy shall be within the overall limit for debt instruments issued by a single issuer, as specified
45at clause 13.1 and 21.5 of the SEBI Master circular dated march 20, 2026 and other prudential limits with respect to
the debt instruments.
19. The investment strategy may consider investment in other financial market investments as per guidelines issued
by the Central Government/SEBI/RBI from time to time. The AMC/Trustee may alter these investment restrictions
from time to time to the extent SEBI regulations/applicable rules change/permit so as to achieve the investment
objective of the investment strategy. Such alterations will be made in conformity with SEBI regulations. Further,
apart from the investment restrictions prescribed under SEBI regulations, the investment strategy may follow any
internal norms vis-à-vis limiting exposure to a particular scrip or sector, etc. The investment restrictions specified
as a percentage of net assets will be computed at the time of making the investment and it is clarified that changes
need not be effected, merely by reason of appreciation or depreciation in value or by reason of factors beyond the
control of the investment strategy (such as receipt of any corporate or capital benefits or amalgamations). In case
the limits are exceeded due to reasons beyond its control, the AMC shall adopt necessary measures of prudence
to reset the situation having regard to the interest of the investors.
20. Transfer of instruments from one investment strategy to another investment strategy in the same Specialized
Investment Fund is permitted provided:
a. Such transfers are done at the prevailing market price for quoted instruments on spot basis (spot basis
shall have the same meaning as specified by a Stock Exchange for spot transactions); and
b. the securities so transferred shall be in conformity with the investment objective of the investment strategy to
which such transfer has been made.
However, in terms of Clause 13.19 of SEBI Master Circular dated March 20, 2026, ISTs are allowed only in
case of raising liquidity and for duration/Issuer/Sector/Group rebalancing with the following conditions:
In case of Raising Liquidity, ISTs permitted if:
SO. 30
a) Use of investment strategy cash & cash equivalent
b) Use of market borrowings
c) Selling of investment strategy securities in the market
d) After attempting all the above, if there is still a investment strategy level liquidity deficit, then out of the remaining
securities, outward Inter Investment strategy Transfers (ISTs) of the optimal mix of low duration paper with
highest quality shall be effected.
The use of market borrowing before ISTs will be optional and Fund Manager may at his discretion take decision
on borrowing in the best interest of unitholders.
In case of Duration/Issuer/Sector/Group rebalancing, ISTs permitted if:
a) ISTs shall be allowed only to rebalance the breach of regulatory limit.
b) ISTs can be done where any one of duration, issuer, sector and group balancing is required in both the
transferor and transferee investment strategies.
No ISTs of a security shall be allowed, if there is negative news or rumors in the mainstream media or an alert is
generated about the security, based on internal credit risk assessment in terms of clause 13.19 of SEBI Master
Circular dated March 20, 2026 during the previous four months.
21. The Specialized Investment Fund shall buy and sell securities on the basis of deliveries and shall in all cases
of purchases, take delivery of relevant securities and in all cases of sale, deliver the securities:
Provided that the Specialized Investment Fund may engage in short selling of securities in accordance with the
framework relating to short selling and securities lending and borrowing specified by the Board:
Provided further that the Specialized Investment Fund may enter into derivatives transactions in a recognized
stock exchange, subject to the framework specified by SEBI.
Provided further that sale of government security already contracted for purchase shall be permitted in
accordance with the guidelines issued by the Reserve Bank of India in this regard.
22. The Investment strategy shall not make any investment in any fund of funds investment strategy.
The Investment strategy will comply with the following restrictions for trading in exchange traded derivatives, as
specified by SEBI Master Circular dated March 20, 2026:
i. Position limit for the Specialized Investment Fund in equity index options contracts
a. The Specialized Investment Fund position limit in all index options contracts on a particular underlying
46index shall be Rs. 500 crores or 15% of the total open interest of the market in index options, whichever is
higher, per stock exchange.
b. This limit would be applicable on open positions in all options contracts on a particular underlying index.
ii. Position limit for the Specialized Investment Fund in equity index futures contracts:
a. The Specialized Investment Fund position limit in all index futures contracts on a particular underlying
index shall be Rs.500 crores or 15% of the total open interest of the market in index futures, whichever
is higher, per stock exchange.
b. This limit would be applicable on open positions in all futures contracts on a particular underlying index.
iii. Additional position limit for hedging
In addition to the position limits at point (i) and (ii) above, the Specialized Investment Fund may take
exposure in equity index derivatives subject to the following limits:
a. Short positions in index derivatives (short futures, short calls and long puts) shall not exceed (in notional
value) the Specialized Investment Fund’s holding of stocks.
b. Long positions in index derivatives (long futures, long calls and short puts) shall not exceed (in notional
value) the Specialized Investment Fund’s holding of cash, government securities, Treasury Bills and
similar instruments.
iv. Position limit for Specialized Investment Fund for stock based derivative contracts
The combined futures and options position limit shall be 20% of the applicable Market Wide
Position Limit (MWPL).
v. Position limit for each investment strategy of a Specialized Investment Fund
The investment strategy-wise position limit / disclosure requirements shall be:
i. For stock option and stock futures contracts, the gross open position across all derivative contracts
on a particular underlying stock of a investment strategy of a Specialized Investment Fund shall not
exceed the higher of 1% of the free float market capitalization (in terms of number of shares)
or
5% of the open interest in the derivative contract on a particular underlying stock (in terms of number of
contracts).
ii. This position limits shall be applicable on the combined position in all derivative contracts on an underlying
stock at a Stock Exchange.
iii. For index based contracts, Specialized Investment Funds shall disclose the total open interest held
by its investment strategy or all investment strategies put together in a particular underlying index, if such
open interest equals to or exceeds 15% of the open interest of all derivative contracts on that
underlying index.
vi. Offsetting of transactions: As per the clause 21.6 of SEBI Master Circular dated March 20,
2026 , 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 considered
No. allowed/n
ot?
1 Equity Long Futures Short Yes Equity Long only
Equity /Futures Call option
2 Yes Equity /Futures Long only
Long Short
Equity /Futures Put option
3 Yes Equity /Futures Long only
Long Long
Call option
4 Futures Short Yes Futures Short only
Long
Put option
5 Futures Short Yes Futures Short only
Short
Call option
6 Call option Long Yes Call option Short only
Short
Put option
7 Put option Long Yes Put option short only
Short
8 Equity Long Futures No Equity Long + Futures Long
47Long
Call
Equity /Futures Equity /Futures Long + Call
9 option No
Long option Long
Long
Put
Equity /Futures Equity /Futures Long + Put option
10 option No
Long Short
Short
Call
11 Futures Short option No Futures short + Call option short
Short
12 Futures Short Put No Futures short + Put option Long
option
Long
13 Call option Long Put No Call option Long + Put option
option Short
Short
14 Call option Put No Call option Short + Put option
Short option Long
Long
*For offsetting of positions, the futures and options contracts shall be on the same underlying security and having same expiry
date.
1. Pending deployment of the funds of the Investment strategy in securities in terms of the investment
objective of the Investment strategy, the AMC may park the funds of the Investment strategy in short
term deposits of scheduled commercial banks, subject to the guidelines issued by SEBI:
The Investment strategy will comply with the following guidelines/restrictions for parking of funds in short
term deposits:
i. “Short Term” for such parking of funds by the Investment strategy shall be treated as a period not
exceeding 91 days. Such short-term deposits shall be held in the name of the Investment strategy.
ii. The Investment strategy shall not park more than 15% of the net assets in short term deposit(s) of all
the scheduled commercial banks put together. However, such limit may be raised to 20% with
prior approval of the Trustee.
iii. Parking of funds in short term deposits of associate and sponsor scheduled commercial banks
together shall not exceed 20% of total deployment by the Specialized Investment Fund in short
term deposits.
iv. The Investment strategy shall not park more than 10% of the net assets in short term deposit(s), with
any one scheduled commercial bank including its subsidiaries.
v. The Investment strategy shall not park funds in short term deposit (STD) of a bank which has invested
in that Investment strategy. Further Trustees/ AMCs shall also ensure that the bank in which the
Investment strategy has STD do not invest in the said investment strategy until the Investment strategy
has STD with such bank.
vi. The AMC will not charge any investment management and advisory fees for funds parked in short
term deposits of scheduled commercial banks.
However, the above provisions will not apply to term deposits placed as margins for trading in cash and
derivatives market.
2. The Investment strategy shall not advance any loans.
3. The Investment strategy shall not borrow except to meet temporary liquidity needs of the Investment
strategy for the purpose of repurchase / redemption of Units or payment of interest and/or dividend to
the Unit holders. Provided that the Fund shall not borrow more than 20% of the net assets of the
individual Investment strategy and the duration of the borrowing shall not exceed a period of 6 months.
The Investment strategy will comply with the other Regulations applicable to the investments of
Mutual Funds from time to time.
4. SEBI vide its Clause 13.15, 13.18 and 21.6 of Master Circular dated March 20, 2026 has prescribed the
following investment restrictions w.r.t. investment in derivatives:
Sr. Particulars
No.
48
SO.141. 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. Cash or cash equivalents with residual
maturity of less than 91 days shall be treated as not creating any exposure.
2. The Investment strategy shall not write options or purchase instruments with embedded
written options except call options under a covered call strategy as specified in Clause
13.15 of Master Circular dated March 20, 2026 as amended from time to time.
3. The total exposure related to option premium paid shall not exceed 20% of the net
assets of the investment strategy.
4.. Exposure due to hedging positions may not be included in the above mentioned limits
subject to the following:
a. Hedging positions are the derivative positions that reduce possible losses on an
existing position in securities and till the existing position remains.
b. Hedging positions cannot be taken for existing derivative positions. Exposure due
to such positions shall have to be added and treated under limits mentioned in
Point 1.
c. Any derivative instrument used to hedge has the same underlying security as the
existing position being hedged.
The quantity of underlying associated with the derivative position taken for hedging
purposes does not exceed the quantity of the existing position against which hedge has
been taken.
5. Exposure due to derivative positions taken for hedging purposes in excess of the
underlying position against which the hedging position has been taken, shall be treated
under the limits mentioned in point 1.
6. Each position taken in derivatives shall have an associated exposure as defined under.
Exposure is the maximum possible loss that may occur on a position. However, certain
derivative positions may theoretically have unlimited possible loss. Exposure in
derivative positions shall be computed as follows:
Position Exposure
Long Future Futures Price * Lot Size * Number of Contracts
Short Future Futures Price * Lot Size * Number of Contracts
Option bought Option Premium Paid * Lot Size * Number of Contracts
Option Sold Market price of the underlying * Lot Size * Number of Contracts.
7. a) The Investment strategy may enter into plain vanilla interest rate swaps for hedging
purposes. The value of the notional principal in such cases must not exceed the value
of respective existing assets being hedged by the investment strategy.
In case of participation in IRS is through over the counter transactions, the counter party
has to be an entity recognized as a market maker by RBI and exposure to a single
counterparty in such transactions should not exceed 10% of the net assets of the
investment strategy. However, if Specialized Investment Funds are transacting in IRS
through an electronic trading platform offered by the Clearing Corporation of India Ltd.
(CCIL) and CCIL is the central counterparty for such transactions guaranteeing
settlement, the single counterparty limit of 10% shall not be applicable. The counter party
in such transactions has to be an entity recognized as a market maker by RBI. Further, the
value of the notional principal in such cases shall not exceed the value of respective
existing assets being hedged by the investment strategy. Exposure to a single counterparty
in such transactions shall not exceed 10% of the net assets of the investment strategy.
8. In case of any other derivative exposure, the exposure shall be calculated as the notional
market value of the contract
9. The total exposure at any point of time shall be the sum of exposure through instruments
in both the cash market and derivatives market
495. The Investment strategy may write call options only under a covered call strategy for constituent stocks
of NIFTY 50 and BSESENSEX subject to the following:
(i) The total notional value (taking into account strike price as well as premium value) of call options written
by a investment strategy shall not exceed 15% of the total market value of equity shares held in that
investment strategy.
(ii) The total number of shares underlying the call options written shall not exceed 30% of the unencumbered
shares of a particular company held in the investment strategy. The unencumbered shares in a
investment strategy shall mean shares that are not part of Securities Lending and Borrowing
Mechanism(SLBM), margin or any other kind of encumbrances.
(iii) At all points of time the investment strategy shall comply with the provisions at paragraph (i) and
(ii) above. In case of any passive breach of the requirement at paragraph (i), the respective investment
strategy shall have 7 trading days to rebalance the portfolio. During the rebalancing period, no
additional call options can be written in the said investment strategy.
(iv) In case the Investment strategy needs to sell securities on which a call option is written under a covered
call strategy, it must ensure compliance with paragraphs (i) and (ii) above while selling the securities.
(v) In no case, the investment strategy shall write a call option without holding the underlying equity shares.
A call option can be written only on shares which are not hedged using other derivative contracts.
(vi) The premium received shall be within the requirements prescribed in terms of Clause 13.18.3 of Master
Circular dated March 20, 2026 i.e. the total gross exposure related to option premium paid and
received must not exceed 20% of the net assets of the investment strategy.
(vii) The exposure on account of the call option written under the covered call strategy shall not be considered
as exposure in terms of Clause 13.18.6 of Master Circular dated March 20, 2026.
a. The Investment strategy shall participate in repos in corporate debt securities as per the guidelines
issued by SEBI and/ or RBI from time to time and the guidelines framed by the Board of Directors
of Trustee Company and the Asset Management Company, from time to time.
At present the following conditions and norms shall apply to repo in corporate debt securities:
(i) The gross exposure of the Investment strategy to repo transactions in corporate debt securities shall not
be more than 10% of the net assets of the Investment strategy.
(ii) The cumulative gross exposure through repo transactions in corporate debt securities along with
equity, debt, units issued by REITs & InvITs and derivatives shall not exceed 100% of the net
assets of the Investment strategy.
(iii) The Investment strategy shall participate in repo transactions only in AA and above rated corporate
debt securities.
(iv) The Investment strategy shall borrow through repo transactions only if the tenor of the transaction
does not exceed a period of six months.
(v) The Trustee and the Asset Management Company have framed guidelines interalia considering the
following aspects:
i. Category of counterparty
ii. Credit rating of counterparty
iii. Tenor of collateral
iv. Applicable haircuts
(vi) Counterparty selection & credit rating
The counterparty must be an acceptable counterparty for debt transactions. The Specialized Investment Fund
follows a counterparty empanelment process for fixed income transactions and the same shall be used
for selection of counterparties for corporate bond repos. All repo transactions in corporate bonds will be
governed by a repo agreement as specified by FIMMDA and / or other specified authorities.
(vii) Collateral tenor & quality
The exposure limit/investment restrictions prescribed under the sixth Schedule of the Regulations and
circulars issued there under (wherever applicable) shall be applicable to repo transactions in corporate bonds.
The Investment strategy shall further follow guidelines framed by Trustee and the AMC from time to time.
(viii) Applicable haircuts
Currently Specialized Investment Funds are permitted to carry out repo transactions in government securities
without any haircuts. The Reserve Bank of India has notified a minimum haircut based on rating of the
corporate bond and other securities. In addition, the Fixed Income and Money Market Dealers Association
(FIMMDA) would maintain a rating-haircut matrix on an ongoing basis. The Investment strategy shall further
follow guidelines framed by Trustee and the AMC from time to time.
50The haircuts seek to protect the lender of funds from the event of the counterparty failing to honor the
repurchase leg of the repo. In such a circumstance, the Fund would suffer a loss if the value of the collateral
depreciates by more than the haircut. The fall in the value of the collateral could be on account of higher
yields and/ or deterioration of credit quality.
As the typical tenor of repos is short (typically overnight), the haircuts represent a relatively high
degree of safety in relation to the interest rate risk on the collateral. The risk of collateral depreciation
based on historical volatility is given in the table below:
Bond Tenor (yrs) 1 3 5 10
Price Volatility (%) 0.6 1.2 1.7 3.4
(annualized)
Repo Tenor Number of standard deviations needed to lose 10%
1 day 258 13 94 48
6
7 days 98 52 36 18
In the above table, the price volatility of a 10-year bond is about 3.4% annualized. That is a 10% price
move represents nearly a 3-sigma event on an annualized basis. For overnight tenors, this represents
a 48-sigma event (for comparison a 6-sigma event occurs about once in a million observations).
It is apparent that the haircuts stipulated by RBI are more than sufficient to mitigate interest rate risk.
Credit event risk remains (the collateral could default during the tenor of the repo). This risk is to be
mitigated by ensuring that the collateral is acceptable from a credit point of view.
6. As per Regulation 52 of SEBI (Mutual Funds) Regulations, 2026 Restrictions on investments are as follows:
(1) An investment strategy under Specialized Investment Fund shall not invest more than 20 per cent of its
NAV in debt instruments comprising money market instruments and non-money market 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 25 per cent of the NAV of the investment strategy with the
prior approval of the Board of Trustees and Board of Directors of the asset management company:
Provided that such limit shall not be applicable for investments in Government Securities, treasury bills
and triparty repo on Government securities or treasury bills:
Provided further that investments 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:
Provided further that such limit shall not be applicable for investments in case of debt exchange traded
funds or such other funds as may be specified by the Board from time to time.
(2) No Specialized Investment Fund under all its investment strategies should own more than fifteen per
cent of any company’s paid up capital carrying voting rights:
Provided that investment in the asset management company or the trustee company of a mutual fund
shall be governed by clause (a) of sub-regulation (1) of regulation 6:
Provided further that the limit mentioned above shall be inclusive of ten per cent limit for mutual fund
schemes as specified under clause 13.1 (5) of SEBI Master circular dated March 20, 2026. .
Explanation: If a mutual fund under all its schemes owns ten per cent of any company’s paid up capital
carrying voting rights, then the Specialized Investment fund under all its investment strategies shall not
own more than five per cent of that company’s paid up capital carrying voting rights.
(3) No investment strategy of a Specialized Investment Fund shall invest more than 10 per cent of its NAV
in the equity shares and equity-related instruments of any company.
(4) A Specialized Investment Fund may invest in the units of REITs and InvITs subject to the following:
(a) No Specialized Investment Fund under all its investment strategies shall own more than 20 per cent
of units issued by a single issuer of REIT and InvIT: Provided that the limit mentioned herein shall be
inclusive of 10 per cent limit for mutual fund schemes as specified under clause 13.13.5 SEBI Master
circular dated March 20, 2026.
51(b) An investment strategy under Specialized Investment Fund shall not invest –
(i) more than 20 per cent of its NAV in the units of REITs and InvITs; and
(ii) more than 10 per cent of its NAV in the units of REIT and InvIT issued by a single issuer:
Provided that the limits mentioned in sub-clauses (i) and (ii) above shall not be applicable for investments
in case of index fund or sector or industry specific scheme pertaining to REIT and InvIT.
(5) All other investment restrictions applicable for schemes of mutual funds as specified under Seventh
Schedule shall apply to investment strategies under the Specialized Investment Fund.
(6) 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.
(7) 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.
(8) Investment in derivatives: An investment strategy may take derivatives exposure for hedging, portfolio
rebalancing & upto 25% unhedged short exposure.
The Specialized Investment Fund /AMC shall make investment out of the NFO proceeds only on or after the
closure of the NFO period. The Specialized Investment Fund/ AMC can however deploy the NFO proceeds
in TREPS before the closure of NFO period. However, AMCs shall not charge any investment management
and advisory fees on funds deployed in TREPS during the NFO period. The appreciation received from
investment in TREPS shall be passed on to investors.
Further, in case the minimum subscription amount is not garnered by the investment strategy during the NFO
period, the interest earned upon investment of NFO proceeds in TREPS shall be returned to investors, in
proportion of their investments, along with the refund of the subscription amount.
The exposure limit/ investment restrictions prescribed under the sixth Schedule of the Regulations and
circulars issued there under (wherever applicable) shall be applicable to repo transactions in corporate
bonds.
The investment strategy will comply with the other Regulations applicable to the investments of Mutual Funds
from time to time.
All the investment restrictions will be applicable at the time of making investments.
The AMC/Trustee may alter these above stated restrictions from time to time to the extent the Regulations
change, so as to permit the Investment Strategy to make its investments in the full spectrum of permitted
investments for Speacialized Investment funds to achieve its respective investment objective.
C.Fundamental Attributes SO.59
Following are the Fundamental Attributes of the investment strategy, in terms of Clause 1.9 of SEBI
Master Circular for Mutual Funds dated March 20, 2026:
i. Type of investment strategy:
• An Interval investment strategy investing in equity and debt securities, including limited short exposure
in equity and debt through derivatives.
ii. Investment Objective Main Objective - Growth.
• The primary objective of the investment strategy is to generate capital appreciation through equity and
equity related instruments and income through arbitrage, derivatives strategies, special situations and
fixed income investments. There is no assurance that the investment objective of the Investment
strategy will be achieved.
• Investment pattern - Please refer to ‘How will the Investment Strategy Allocate its Assets?’ under
the Part II ‘INFORMATION ABOUT THE INVESTMENT STRATEGY’.
SO.5
52iii. Terms of Issue
• Liquidity provisions such as listing, repurchase, redemption. (please refer to relevant provisions on
listing, repurchase, redemption in section II ‘Other Investment Strategy Specific Disclosures’)
• Aggregate fees and expenses charged to the investment strategy (please refer to Annual
Investment Strategy Recurring Expenses under Part III – Other Details).
• Any safety net or guarantee provided - This Investment Strategy does not provide any guaranteed
or assured return.
In accordance with Regulation 12 (3)(b) and 22(9)( c) of the SEBI (MF) Regulations and Clause 1.2.2
and 1.9.2 of SEBI Master Circular for Mutual Funds dated March 20, 2026, the AMC shall ensure that
no change in the fundamental attributes of the investment strategy or fees and expenses payable or any
other change that would modify the investment strategy and affect the interest of unit holders, shall be
carried out unless
• written communication (including digital modes such as email/sms etc.) about the proposed
change is sent to each unit holder;
• details, as specified by the Board, are appropriately displayed on the website of asset
management company; and
• unit holders are given an option to exit at the prevailing Net Asset Value without any exit load.
D. Other Investment Strategy Specific Disclosures:
Listing and transfer of units Presently it is proposed to list the investment strategy on NSE.
However the Trustee reserves the right to list the units of the
investment strategy on any
other Stock Exchange The Units of the investment strategy are
available for trading and transfer only in demat mode via the stock
exchanges.
Dematerialization of units The Unit holders would have an option to hold the Units in demat
form or account statement (non-demat) form. Units held in Demat
Form are freely transferable. The Applicant intending to hold Units in
demat form will be required to have a beneficiary account with a
Depository Participant (DP) of the NSDL/ CDSL and will be required
to mention in the application form DP's Name, DP ID No. and
Beneficiary Account No. with the DP at the time
of purchasing Units.
SO.57 (a)(b)
Minimum Target amount Rs. 10 crores.
(This is the minimum amount required
to operate the investment strategy and
if this is not collected during the NFO
period, then all the investors would be
refunded
the amount invested without any
return.)
Redemption and subscription Subscription Frequency: Daily (only Business days).
frequency of the investment strategy
Redemption Frequency: Every Monday and Wednesday* of the
week.
*Next business day in case Monday and Wednesday is a non-
business day.
Notice period of the investment Every Monday and Every Wednesday*of the week.
strategy *Next business day in case Monday and Wednesday is a
non-business day.
Maximum Amount to be raised (if any) Not Applicable
Dividend Policy (IDCW) Under the IDCW option, the Trustee will have the discretion to
declare the IDCW, subject to availability of distributable surplus
calculated in accordance with the Regulations. The actual
declaration of IDCW and frequency will inter-alia, depend on
53availability of distributable surplus calculated in accordance with
SEBI (MF) Regulations and the decisions of the Trustee shall be final
in this regard. There is no assurance or guarantee to the Unit holders
as to the rate of IDCW nor that it will be paid regularly.
The AMC/Trustee reserves the right to change the frequency of
declaration of IDCW or may provide for additional frequency for
declaration of IDCW.
IDCW Distribution Procedure
In accordance with Clause 12 of SEBI Master Circular on Mutual
Funds dated March 20, 2026, the procedure for distribution would be
as under:
1. Quantum of IDCW and the record date will be fixed by the
Trustee. IDCW so decided shall be paid, subject to availability of
distributable surplus.
2. Within one calendar day of the decision by the Trustees, AMC
shall issue notice to the public communicating the decision including
the record date. The record date shall be 2 working days from the
date of publication in at least one English newspaper or in a
newspaper published in the language of the region where the
Head Office of the fund is situated, whichever is issued earlier.
3. Record date shall be the date, which will be considered for the
purpose of determining the eligibility of investors whose names
appear on the register of Unit holders for receiving IDCW.
4. The notice will, in font size 10, bold, categorically state that
pursuant to payment of dividend, the NAV of the Investment
strategy would fall to the extent of payout and statutory levy (if
applicable).
5. The NAV will be adjusted to the extent of IDCW distribution and
statutory levy, if any, at the close of business hours on record date.
Before the issue of such notice, no communication indicating the
probable date of IDCW declaration in any manner whatsoever will
be issued by Fund.
However, the requirement of giving notice shall not be
applicable for IDCW options having frequency up to one month.
Allotment (Detailed procedure) All Applicants whose monies towards purchase of Units have been
realised by the Fund will receive a full and firm allotment of Units,
provided also the applications are complete in all respects and are
found to be in order. Any application for subscription of units may be
rejected if found invalid, incomplete or due to unavailability of
underlying securities, etc. For applicants applying through
'APPLICATIONS SUPPORTED BY BLOCKED AMOUNT (ASBA)',
on allotment, the amount will be unblocked in their respective bank
accounts and account will be debited only to the extent required to
pay for allotment of Units applied in the application form. Units will
be allotted upto 3 decimals. Face Value per unit of all Plans/ Options
under the Investment strategy is Rs. 10-/. Any application for
subscription of units may be rejected if found invalid, incomplete or
due to unavailability of underlying securities, etc. Applicants under
the Investment strategy will have an option to hold the Units either
in physical form (i.e. account statement) or in dematerialized form.
Accordingly, the AMC shall allot units either in physical form (i.e.
account statement) or in dematerialized form within 5 working days
from the date of closure of the NFO period.
Dematerialization: The Applicants intending to hold the Units in
dematerialized mode will be required to have a beneficiary account
with a Depository Participant (DP) of the NSDL/CDSL and will be
required to mention in the application form DP's Name, DP ID No.
and Beneficiary Account No. with the DP at the time of purchasing
54Units. The Units allotted will be credited to the DP account of the
Unit holder as per the details provided in the application form. The
statement of holding of the beneficiary account holder for units held
in demat will be sent by the respective DPs periodically.
Units held in demat form are freely transferable. If the Unit holder
desires to hold the Units in a Dematerialized / Rematerialized form
at a later date, the request for conversion of units held in Account
Statement (non demat) form into Demat (electronic) form or vice
versa should be submitted alongwith a Demat/Remat Request Form
to their Depository Participants. However, the Trustee / AMC
reserves the right to change the dematerialization /
rematerialization process in accordance with the procedural
requirements laid down by the Depositories, viz. NSDL/ CDSL and/or
in accordance with the provisions laid under the Depositories Act,
1996 and Regulations thereunder. All Units will rank pari passu,
among Units within the same Option in the Investment strategy
concerned as to assets, earnings and the receipt of Distributions, if
any, as may be declared by the Trustee.
Allotment Confirmation
An allotment confirmation specifying the units allotted shall be sent
by way of email and/or SMS within 5 working days of the closure of
the NFO Period to the Unit holder's registered e-mail address and/or
mobile number.
Note: Allotment of units will be done after deduction of applicable
stamp duty.
Note: For the purpose of allotment of units / refund of monies under
NFO the term "working days" shall include Business Days but shall
not include Holidays.
Refund If application is rejected, full amount will be refunded within 5
working
days of closure of NFO. If refunded later than 5 working days @ 15%
p.a. for delay period will be paid and charged to the AMC.
Who can invest this is an indicative list The following persons (i.e. an indicative list of persons) are eligible
and investors shall consult their and may apply for subscription to the Units of the Investment
financial advisor to ascertain whether strategy provided they are not prohibited by any law/ Constitutive
the investment strategy is suitable to documents governing them:
their risk profile 1. Resident adult individuals either singly or jointly (not exceeding
three) or on an Anyone or Survivor basis;
2. Karta of Hindu Undivided Family (HUF);
3. Minor (as the first and the sole holder only) through a natural
guardian (i.e. father or mother, as the case may be) or a court
appointed legal guardian. There shall not be any joint holding in a
minor’s folio . Payment for investment shall be accepted from the
bank account of the minor, parent or legal guardian of the minor or
from a joint account of the minor with the parent or legal guardian.
4. Partnership Firms & Limited Liability Partnerships (LLPs);
5. Companies, Bodies Corporate, Public Sector Undertakings,
Association of Persons or bodies of individuals and societies
registered under the Societies Registration Act, 1860, Co-operative
Societies registered under the Co-Operative Societies Act, 1912,
One Person Company;
6. Banks & Financial Institutions;
7. Mutual Funds/ Alternative Investment Funds registered with SEBI;
8. Religious and Charitable Trusts, Wakfs or endowments of private
trusts (subject to receipt of necessary approvals as required) and
Private trusts authorised to invest in mutual fund schemes under
their trust deeds;
9. Non-resident Indians (NRIs)/Persons of Indian Origin residing
55abroad (PIO)/ Overseas Citizen of India (OCI) on repatriation basis
or on non- repatriation basis;
10. Foreign Portfolio Investors (FPI) registered with SEBI in
accordance with applicable laws;
11. Army, Air Force, Navy and other paramilitary units and bodies
created by such institutions;
12. Council of Scientific and Industrial Research, India;
13. Multilateral Financial Institutions/ Bilateral Development
Corporation Agencies/ Bodies Corporate incorporated outside India
with the permission of Government of India/Reserve Bank of India;
14. Other investment strategies of WSIF (offered by The Wealth
Company Mutual Fund) subject to the conditions and limits
prescribed by SEBI (MF) Regulations;
15. Trustee, AMC, Sponsor and their associates may subscribe to
Units under the Investment strategy;
16. Such other category of investors as may be decided by the AMC /
Trustee from time to time provided their investment is in conformity
with the applicable laws and SEBI (MF) Regulations.
Note:
1. Non Resident Indians (NRIs) and Persons of Indian Origin (PIOs)
residing abroad / Overseas Citizens of India (OCI) / Foreign
Portfolio Investors (FPIs) have been granted a general permission
by Reserve Bank of India under Schedule 5 of the Foreign
Exchange Management (Transfer or Issue of Security by a Person
Resident Outside India) Regulations, 2000 for investing in /
redeeming units of the mutual funds subject to conditions set out in
the aforesaid regulations.
2. In case of application(s) made by Individual Investors under a
Power of Attorney, the original Power of Attorney or a certified true
copy duly notarised should be submitted. In case of applications
made by Non- Individual Investors, the authorized signatories /
officials of Non-Individual investors should sign the application
under their official designation and as per the authority granted to
them under their Constitutive Documents/Board resolutions, etc. A
list of specimen signatures of the authorized officials, duly certified
/ attested should also be attached to the Application Form. The
Fund/AMC/Trustees shall deem that the investments made by
the Investors are not prohibited by any law/Constitutive
documents governing them and they possess the necessary
authority to invest/transact.
3. Investors desiring to invest / transact in investment strategies are
required to mandatorily furnish PAN (PAN of the guardian in case
minor does not have a PAN) and comply with the KYC norms
applicable from time to time. Under the KYC norms, Investors are
required to provide prescribed documents for establishing their
identity and address including in case of non-individuals copy of the
Memorandum and Articles of Association / bye- laws/trust deed/
partnership deed/ Certificate of Registration along with the proof of
authorization to invest, as applicable, to the KYC Registration
Agency (KRA) registered with SEBI.
The Fund / AMC / Trustees / other intermediaries will rely on the
declarations/affirmations provided by the Investor(s) in the
Application/Transaction Form(s) and the documents furnished to
the KRA that the Investor(s) is permitted/ authorised by the
Constitution document/their Board of Directors etc. to make the
investment / transact.
56Further, the Investor shall be liable to indemnify the Fund / AMC
/ Trustee / other intermediaries in case of any dispute regarding the
eligibility, validity and authorization of the transactions and / or the
applicant who has applied on behalf of the Investors. The Fund /
AMC / Trustee reserves the right to call for such other information
and documents as may be required by it in connection with the
investments made by the investor. Where the Units are held by a
Unit holder in breach of any Regulations, AMC / the Fund may effect
compulsory redemption of such units. Returned cheques are liable
not to be presented again for collection, and the accompanying
application forms are liable to be rejected. In case the returned
cheques are presented again, the necessary charges are liable to
be debited to the investor.
4. Subject to the SEBI (MF) Regulations, the Trustee may inter-
alia reject any application for the purchase of Units if the
application is invalid or incomplete or non-permissible under law
or if the Trustee for any other reason does not believe that it
would be in the best interest of the Investment strategy or its
Unitholders to accept such an application
Who cannot invest The aforementioned persons/entities as specified under section
“Who Can Invest?” shall not be eligible to invest in the Investment
strategy, if such persons/entities are:
1. United States Person (U.S. person*) as defined under the extant
laws of the United States of America, except the following:
a. NRIs/PIOs may invest/transact, in the Investment strategy,
when present in India, as lump sum subscription, redemption
and/or switch transaction and registrations of systematic
transactions only through physical form and upon submission of
such additional documents/undertakings, etc., as may be
stipulated by AMC/ Trustee from time to time and subject to
compliance with all applicable laws and regulations prior to
investing in the Investment strategy.
b. FPIs may invest in the Investment strategy as lump sum
subscription and/or switch transaction (other than systematic
transactions) through submission of physical form in India,
subject to compliance with all applicable laws and regulations
and the terms, conditions, and documentation requirements
stipulated by the AMC/Trustee from time to time, prior to
investing in the Investment strategy.
The Trustee/AMC reserves the right to put the transaction requests
received from such U.S. person on hold/reject the transaction
request/redeem the units, if allotted, as the case may be, as and
when identified by the AMC that the same is not in compliance with
the applicable laws and/or the terms and conditions stipulated by
Trustee/AMC from time to time. Such redemptions will be subject to
applicable taxes and exit load, if any.
The physical application form(s) for transactions (in nondemat
mode) from such U.S. person will be accepted ONLY at the Investor
Service Centres (ISCs) of Wealth Company Asset Management
Holdings Private Limited (AMC). Additionally, such transactions in
physical application form(s) will also be accepted through
Distributors and other platforms subject to receipt of such additional
documents/undertakings, etc., as may be stipulated by AMC/
Trustee from time to time from the Distributors/ Investors.
2. Residents of Canada;
3. Investor residing in any Financial Action Task Force (FATF)
designated High Risk jurisdiction.
*The term “U.S. person” means any person that is a U.S. person
57within the meaning of RegulationS under the Securities Act of 1933 of
U.S. or as defined by the U.S. Commodity Futures Trading
Commission or as per such further amended definitions,
interpretations, legislations, rules etc, as may be in force from time to
time.
The Applications Forms shall be made available at Investor Service
SO.35
How to Apply (details) Centers (ISCs)/Official Points of Acceptance (OPAs) of the Fund
and/ or may be downloaded from the AMC SIF website
https://www.wealthcompanyamc.in/wsif/
For further details, refer to the SAI and Application form for the
instructions.
1. The list of the Investor Service Centers (ISCs)/Official Points of
Acceptance (OPAs) of the Specialized Investment Fund will be
provided on the website of the AMC SIF website
https://www.wealthcompanyamc.in/wsif/
2. Please our website for Name, address and contact no. of Registrar
and Transfer Agent (R&T), email id of R&T, website address of
R&T, official points of acceptance, collecting banker details etc. at
end of ISID.
As per the directives issued by SEBI it is mandatory for an investor
to declare his/her bank account number.
SO. 61
To safeguard the interest of Unitholders from loss or theft of their
refund orders/redemption cheques, investors are requested to
provide their bank details in the Application Form.
In case an existing Unitholder is submitting a request for Change in
his Bank Details, he needs to submit a copy of cancelled cheque
leaf of the new bank account or Bank statement of the new bank
account attested by his banker with seal & signature of banker or
letter from the Banker of the investor. In the absence of the same,
the request for Change in Bank Mandate is liable to be rejected.
Investors are required to note that it is mandatory to mention their
bank account numbers in their applications/requests for
redemption. At the time of redemption, investors can select the
bank account to receive the amount.
The policy regarding reissue of The number of Units held by the Unit holder under his folio / Demat
repurchased units, including the Account will stand reduced by the number of Units redeemed.
maximum extent, the manner of
reissue, the entity (the investment Presently, the AMC does not intend to reissue the repurchased
strategy or the AMC) involved in units. However, the Trustee reserves the right to reissue the
the same. repurchased units at a later date after issuing adequate public
notices and taking approvals, if any, from SEBI.
Restrictions, if any, on the right to SUSPENSION OF SALE OF UNITS OF THE INVESTMENT
freely retain or dispose of units STRATEGY
being offered.
The Specialized Investment Fund at its sole discretion reserves the
right to withdraw the Sale of Units i.e. subscriptions in the
Investment strategy(s) (including any one Plan/ Option) temporarily
or indefinitely, if in the opinion of the AMC the general market
conditions are not favourable and / or suitable investment
opportunities are not available for deployment of funds or if in the
view of AMC/Trustee changing the size of the corpus may prove
detrimental to the existing Unit holders of the Investment strategy(s)
or for any other reason deemed fit by the AMC / Trustee. Further,
the indicative list of circumstances under which sale of units may
temporarily be suspended is as follows:
1. When one or more stock exchanges or markets, which provide
basis for valuation for a substantial portion of the assets of the
58Investment strategy are closed otherwise than for ordinary
holidays.
2. In case of natural calamities, war, strikes, riots and bandhs.
In the event of any force majeure or disaster that affects the
3. normal functioning of the AMC or the Official Point(s) of
Acceptance.
4. If so directed by SEBI.
RIGHT TO RESTRICT REDEMPTION AND / OR SUSPEND
REDEMPTION OF THE UNITS (as per para 5.3 of SEBI Master
Circular dated March 20, 2026 as may be amended from time to
time):
The Fund at its sole discretion reserves the right to restrict
Redemption (including switch-out) of the Units (including Plan
/Option) of the Investment strategy of the Fund upon occurrence of
the below mentioned events for a period not exceeding ten (10)
working days in any ninety (90) days period subject to approval of
the Board of Directors of the AMC and the Trustee. The restriction
on Redemption (including switch-out) shall be applicable where the
Redemption (including switch-out) request is for a value above Rs.
2,00,000/- (Rupees Two Lakhs). Further, no restriction shall be
applicable to the Redemption / switch-out request upto Rs.
2,00,000/- (Rupees Two Lakhs). It is further clarified that, in case
of redemption request beyond Rs. 2,00,000/- (Rupees Two
Lakhs), no restriction shall be applicable on first Rs. 2,00,000/-
(Rupees Two Lakhs). The Trustee / AMC reserves the right to restrict
Redemption or suspend Redemption of the Units in the Investment
strategy of the Fund on account of circumstances leading to a
systemic crisis or event(s) that severely constrict market liquidity
or the efficient functioning of the markets.
A list of such circumstances under which the restriction on
Redemption or suspension of Redemption of the Units in the
Investment strategy of the Fund may be imposed are as follows:
1. Liquidity issues- when market at large becomes illiquid affecting
almost all securities rather than any issuer specific security; or
2. Market failures / exchange closures; or
3. Operational issues; or
4. If so directed by SEBI
It is clarified that since the occurrence of the abovementioned
eventualities have the ability to impact the overall market and liquidity
situation, the same may result in exceptionally large number of
Redemption requests being made and in such a situation the
indicative timelines, if any mentioned by the Fund in the investment
strategy offering documents, for processing of requests for
Redemption may not be applicable.
Any restriction on Redemption or suspension of Redemption of the
Units in the Investment strategy(s) of the Specialized Investment
Fund shall be made applicable only after specific approval of the
Board of Directors of the AMC and Trustee Company and thereafter,
immediately informing the same to SEBI.
The AMC / Trustee reserves the right to change / modify the
provisions of right to restrict Redemption and / or suspend
Redemption of the Units in the Investment strategy of the Fund.
59Cut off timing for subscriptions/ The below cut-off timings and applicability of NAV shall be
redemptions/ switches applicable in respect of valid applications received at the Official
Point(s) of Acceptance on a Business Day:
This is the time before which your A] For Purchase (including switch-in) of any amount:
application (complete in all respects)
should reach the official points of • In respect of valid applications received upto 3.00 p.m. and
acceptance.) where the funds for the entire amount are available for
utilization before the cut-off time i.e. credited to the bank
account of the investment strategy before the cut-off time - the
closing NAV of the day shall be applicable.
• In respect of valid applications received after 3.00 p.m. and
where the funds for the entire amount are credited to the bank
account of the investment strategy either at any time on the
same day or before the cut-off time of the next Business Day i.e.
available for utilization before the cut-off time of the next
Business Day - the closing NAV of the next Business Day shall
be applicable.
• Irrespective of the time of receipt of application, where the funds
for the entire amount are credited to the bank account of the
investment strategy before the cut-off time on any subsequent
Business Day i.e. available for utilization before the cut-off time
on any subsequent Business Day - the closing NAV of such
subsequent Business Day shall be applicable.
B] For Switch-ins of any amount: For determining the applicable
NAV, the following shall be ensured:
• Application for switch-in is received before the applicable
cutoff time.
• Funds for the entire amount of subscription/purchase as per
the switch-in request are credited to the bank account of the
Investment Strategy before the cut-off time.
• The funds are available for utilization before the cut-off time.
• In case of ‘switch’ transactions from one Investment Strategy
to another, the allocation shall be in line with redemption
payouts.
C]Redemptions including Switch - outs:
• In respect of valid applications received up to 3.00 p.m. – same
day’s closing NAV shall be applicable.
• In respect of valid applications received after 3.00 p.m. - the
closing NAV of the next Business Day shall be applicable.
• With respect to investors who transact through the stock
exchange, a confirmation slip given by the stock exchange
mechanism shall be considered for the purpose of
determining Applicable NAV for the Investment Strategy and
cut off timing for the transactions.
60Where can the applications for The Applications Forms shall be made available at Investor Service
purchase/redemption switches be Centres (ISCs) / Official Points of Acceptance (OPAs) of Fund and/
submitted? or may be downloaded from the website of AMC
https://www.wealthcompanyamc.in/wsif/
For further details, refer to the SAI and Application form for the
instructions.
1. The list of the Investor Service Centres (ISCs)/Official Points
of Acceptance (OPAs) of the Fund will be provided on the
website of the AMC https://www.wealthcompanyamc.in/wsif/
2. Please refer back cover page of SID for Name, address
and contact no. of Registrar and Transfer Agent (R&T),
email
3. id of R&T, website address of R&T, official points of
acceptance, collecting banker details etc.
As per the directives issued by SEBI it is mandatory for an investor
to declare his/her bank account number.
Minimum amount for Minimum amount of investment during NFO and On an Ongoing
purchase/ redemption/ switches basis under all Plans and Options:
• During NFO: Rs.10,00,000/- and in multiples of Re. 100/-
thereafter
• On continuous basis: Rs.10,00,000/- and in multiples of
Re. 100/- thereafter
Systematic Investment Plan (SIP) / Systematic Withdrawal Plan
(SWP)
/Systematic Transfer Plan (STP) shall only commence upon re-
opening of the Investment Strategy.
The clauses on SWP and STP will be subject to compliance with
provisions mentioned under “Minimum investment threshold” as
stated under Clause “Minimum threshold requirement and
consequences of non- maintenance” of this ISID.
Note:
Allotment of units will be done after deduction of applicable stamp
duty and transaction charges, if any.
For Additional Purchases: Rs. 10,000/- and in multiples of Re. 100/-
61Minimum threshold requirement and The AMC shall ensure that an aggregate investment by an investor
consequences of non- maintenance across all investment strategies offered by the SIF, at the
Permanent Account Number (‘PAN’) level, is not less than INR 10
lakh.
Provided that the requirement of minimum investment amount shall
not apply to an accredited investor.
Provided that, the above provisions shall not be applicable for
mandatory investments made by AMC for designated employees
under paragraph 7.14 and 21.4.1 of the Master Circular for Mutual
Funds dated March 20, 2026.
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.
SO.36
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.
Active Breaches shall mean fall in the aggregate value of an
investor’s total investment across all investment strategies of SIF,
below the Minimum Investment Threshold of INR 10 lakh, on account
of any transactions (i.e. redemption, transfer, sale etc.) initiated by
the investor.
In case of any active breach of the Minimum Investment Threshold
by an investor including through transactions on stock exchanges or
off-market transfers:
(a) all units of such investor held across investment strategies of the
concerned SIF shall be frozen for debit, and
(b) a notice of 30 calendar days shall be given to such investor to
rebalance the investments in order to comply with the Minimum
Investment Threshold.
Pursuant to the said notice issued to the investor:
(i) in case investor rebalances his/her investments in SIF within the
notice period of 30 calendar days, the units of SIF of such investor
shall be unfreezed, and no further action shall be taken with regard to
compliance with Minimum Investment Threshold.
(ii) in case the investor fails to rebalance the investments within the
aforesaid 30 calendar day period, the frozen units shall be
automatically redeemed by the AMC, at the applicable Net Asset
Value of the next immediate business day after the 30th calendar day
of the notice period.
Accounts Statements The AMC shall send an allotment confirmation specifying the units
allotted by way of email and/or SMS within 5 business days of receipt
of valid application/transaction to the Unit holders registered e-mail
address and/ or mobile number (whether units are held in demat
mode or in account statement form).
A consolidated Account Statement and Monthly CAS shall be issued
to investors that have opted for delivery via electronic mode (e-CAS)
62by the twelfth (12th) day from the month end, detailing all the
transactions across all investment strategies of Specialized
Investment Fund and to investors that have opted for delivery via
physical mode by the fifteenth (15th) day from the month end.
The CAS will be dispatched by email to all the investors whose email
addresses are registered with the Depositories and AMCs/MF-RTAs.
However, where an investor does not wish to receive CAS through
email, option shall be given to the investor to receive the CAS in
physical form at the address registered with the Depositories and the
AMCs/MF-RTAs. The depositories shall also intimate the investor on
quarterly basis through the SMS mode specifying the email id on
which the CAS is being sent.
If there is any transaction in any of the demat accounts of the investor
or in any of his Specialized Investment Fund folios, then CAS shall
be sent to that investor through email on monthly basis. In case there
is no transaction in any of the Specialized Investment Fund and
demat accounts then CAS with holding details shall be sent to the
investors by email on half yearly basis.
The depositories shall dispatch the CAS to investors that have opted
for delivery via electronic mode, on or before the eighteenth (18th)
day of April and October and to investors that have opted for delivery
via physical mode, on or before the twenty-first (21st) day of April
and October.
However, where an investor does not wish to receive CAS through
email, option shall be given to the investor to receive the CAS in
physical form at the address registered with the Depositories and the
AMCs/MF-RTAs.
In the event the account has more than one registered holder, the
first named Unit holder shall receive the CAS/ account statement.
The transactions viz. purchase redemption, switch, etc., carried out by
the Unit holders shall be reflected in the CAS on the basis of
Permanent Account Number (PAN).
The CAS shall not be received by the Unit holders for the folio(s) not
updated with PAN details. The Unit holders are therefore requested
to ensure that the folio(s) are updated with their PAN.
In case of a specific request received from the Unit holders, the AMC
will provide an account statement (reflecting transactions of the
Fund) to the investors within 5 Business Days from the receipt of
such request, by mail/email.
SO.60
The Unit holder without any charges may request for a physical
account statement by writing to/calling the AMC/ISC/RTA. The
Specialized Investment Fund / AMC shall dispatch an account
statement within 5 Business Days from the date of the receipt of
request from the Unit holder.
Half Yearly CAS shall be issued to investors that have opted for e-
CAS on or before the eighteenth (18th) day of April and October, to
all investors providing the prescribed details across all investment
strategies of Specialized Investment Fund and to investors that have
opted for delivery via physical mode by the twenty first (21st) day of
April and October.
The statement of holding of the beneficiary account holder for units
held in demat will be sent by the respective DPs periodically.
The Account Statement shall state that the net investment as gross
subscription less transaction charges, if any and specify the no. of
units allotted against the net investment.
63CAS for investors having Demat account:
• Investors having MF investments and holding securities in
Demat account shall receive a single Consolidated Account
Statement (CAS) from the Depository.
• Consolidation of account statement shall be done on the basis
of Permanent Account Number (PAN). In case of multiple
holding, it shall be PAN of the first holder and pattern of holding.
The CAS shall be generated on a monthly basis.
• If there is any transaction in any of the Demat accounts of the
investor or in any of his Specialized Investment Fund folios,
depositories shall send the CAS within ten days from the month
end. In case, there is no transaction in any of the Specialized
Investment Fund folios and demat accounts then CAS with
holding details shall be sent to the investor on half yearly basis.
• In case an investor has multiple accounts across two
depositories, the depository with whom the account has been
opened earlier will be the default depository.
• No Account Statements will be issued by the AMC to Unit
holders who hold units in dematerialized mode. For Units in
dematerialised mode, the Account Statements may be obtained
by the Investor from the depository participants with whom the
investor holds the DP account.
The dispatch of CAS by the depositories would constitute compliance
by the AMC/ the Specialized Investment Fund with the requirement
under Regulation 34 of SEBI (Mutual Funds) Regulations 2026.
For further details, refer SAI.
Dividend/ IDCW The payment of dividend/IDCW to the unitholders shall be made
within seven working days from the record date.
Redemption The redemption or repurchase proceeds shall be dispatched to the
unitholders within three working days.
For list of exceptional circumstances refer Clause 15.3.3 of SEBI
Master Circular for Mutual Funds dated March 20, 2026.
For investment strategies investing atleast 80% of total assets in
permissible overseas investments (as per Clause 13.11 of SEBI
Master Circular for Mutual Funds dated march 20, 2026), the transfer
of redemption or repurchase proceeds to the unitholders shall be
made within five working days from the date of redemption or
repurchase.
Bank Mandate As per the directives issued by SEBI it is mandatory for an investor to
declare his/her bank account number. To safeguard the interest of
Unitholders from loss or theft of their refund orders/redemption
cheques, investors are requested to provide their bank details in the
Application Form.
In case an existing Unitholder is submitting a request for Change in
his Bank Details, he needs to submit a copy of cancelled cheque leaf
of the new bank account or Bank statement of the new bank account
attested by his banker with seal & signature of banker or letter from
the Banker of the investor. In absence of the same, the request for
Change in Bank Mandate is liable to be rejected.
Investors have an option of registering multiple bank accounts, by
submitting the necessary forms & documents. At the time of
redemption, investors can
select the bank account to receive the amount.
64Delay in payment of redemption / The Asset Management Company shall be liable to pay interest
repurchase proceeds/dividend to the unitholders at rate as specified vide clause 15.4 of SEBI
Master Circular for Mutual Funds dated March 20, 2026 for the period
of such delay.
Unclaimed Redemption and The unclaimed Redemption and IDCW amounts shall be deployed
Income Distribution cum Capital by the Fund in money market instruments and such other
Withdrawal Amount instruments/securities as maybe permitted from time to time. The
investment management fee charged by the AMC for managing such
unclaimed amounts shall not exceed 50 basis points. The circular also
specifies that investors who claim these amounts during a period of
three years from the due date shall be paid at the prevailing NAV. Thus,
after a period of three years, this amount can be transferred to a pool
account and the investors can claim the said amounts at the NAV
prevailing at the end of the third year. In terms of the circular, the onus
is on the AMC to make a continuous effort to remind investors through
letters to take their unclaimed amounts. The details of such
unclaimed amounts shall be disclosed in the annual report sent to
the Unit Holders.
Disclosure w.r.t investment by Payment for investment by any mode shall be accepted from the bank
minors account of the minor, parent or legal guardian of the minor, or from a
SO.37 joint account of the minor with parent or legal guardian. For existing
folios, the AMC shall accept a Change of Pay-out Bank mandate
before redemption is processed.
SO.52
Irrespective of the source of payment for subscription, all redemption
proceeds shall be credited only in the verified bank account of the
minor, i.e. the account the minor may hold with parent/legal guardian
after completing all KYC formalities.
Upon the minor attaining the status of major, the minor in whose
name the investment was made, shall be required to provide all the
KYC details, updated bank account details including cancelled
original cheque leaf of the new account. No further transactions shall
be allowed till the status of the minor is changed to major.
The claimant has to submit the Transmission Request Form (TRF)
and NOC form along with the prescribed common set of documents.
All such forms and formats are available on AMC website, RTA and
AMFI.
AMCs shall not accept requests for redemption from a claimant
pending completion of the transmission of units in his / her favour.
The Stamp duty is payable by the claimant with respect to the
indemnity bond and affidavit, shall be in accordance with the stamp
duty prescribed by law.
65Acceptance of financial Non-individual Investors are requested to note the following:
transactions through email in 1. Risks Involved in Transacting via Email the Non-individual investor
respect of non- individual investor acknowledges and accepts the inherent risks associated with
conducting financial transactions via email. These risks include, but are
not limited to, the possibility of unauthorized access to email
communications, transmission delays, data loss, or alteration due to
technical glitches or cyberattacks, which could impact the
completeness or accuracy of the transaction. Additionally, emails may
be susceptible to interception, unauthorized access, and other security
vulnerabilities, which could lead to fraudulent transactions. Therefore,
investors must be cautious while initiating financial transactions via
email and should ensure the confidentiality and integrity of their
communication.
2. Limitation of Liability of AMC / RTA The Asset Management Company
(AMC) and the Registrar and Transfer Agent (RTA) shall not be held
liable for any loss or damage caused by the non-receipt or delay in
receiving any transaction sent by the investor via email. This includes
situations where emails are not delivered, are delayed, or are
intercepted due to issues beyond the control of the AMC or RTA,
including but not limited to, technical failures, service provider errors,
or unauthorized access to the email account. The AMC and RTA will
not be responsible for any transactions that are erroneously processed
or not processed due to such issues. The liability of the AMC and RTA
is limited solely to the extent of ensuring that the transaction is
processed once received in the proper format and within a reasonable
timeframe, subject to system availability and security checks.
3. Security Measures to Ensure Safe Email Communication The AMC
and RTA are committed to ensuring the highest level of security
for email communications and shall implement appropriate
safeguards. These measures include the use of encrypted
email services, secure authentication protocols, and
virus/malware scanning for all incoming and outgoing emails.
Additionally, access to email accounts and transaction systems
shall be restricted to authorized personnel only, and multi-factor
authentication will be employed to verify the identity of the
individuals initiating transactions. The AMC shall take all
reasonable steps to prevent unauthorized access, disclosure,
or alteration of the financial data transmitted via email.
4. Retention of Transaction Records The AMC and RTA will retain
records of all transactions routed via email in accordance with
applicable laws and regulations. These records will include, but are not
limited to, transaction requests, email correspondence, and
confirmation receipts, for a minimum period as mandated by regulatory
authorities. The Non- Individual investor agrees that these records
shall be stored in a secure digital format to ensure their integrity and
availability for future reference. In addition, the AMC shall maintain an
audit trail for each transaction, allowing for the traceability of emails and
the status of each request submitted via email.
5. Procedure for Addition/Deletion of Authorized Signatories The facility
to transact via email shall follow an appropriate procedure for the
addition or deletion of authorized signatories. Such changes must
be communicated to the AMC through a formal notification, in the form
of a signed letter or email from the authorized representative of the
entity,
66accompanied by the requisite board resolution or authority
letter. The AMC shall process these changes only upon receipt
of valid documentation confirming the updated list of authorized
signatories. These changes will only be effective once the AMC
has acknowledged receipt and validation of the notification.
6. Authorization for Non-Individual Investors For non-individual
investors, including registered Specialized Investment Fund
distributors or third parties authorized by the investor, to submit
financial transactions via email on behalf of the entity, the AMC
and RTA require prior written authorization from the investor.
This authorization should clearly state the scope of authority
granted to the third party and must be submitted with each
transaction request. The AMC will accept such transactions
only if the relevant authorization documents are in place and
the email corresponds with the pre-registered contact
information for the entity or authorized third party.
7. Security Procedures for Transaction Confirmation To confirm
and authenticate email-based financial transactions, the AMC
will employ a range of security procedures, including digital
signatures, encrypted communication, and multi-step verification
processes. These procedures are designed to verify that the
transaction is genuinely authorized by the investor and ensure
that the instructions have not been tampered with. Upon receipt
of an email transaction, the AMC will conduct thorough checks
to confirm the authenticity of the request, including comparing it
against the pre-registered information (email addresses,
signatories, etc.). Only upon successful verification will the
transaction be processed.
8. Electronic Time Stamping and Audit Trail for Email Transactions
Each transaction processed via email shall be subject to an
electronic time- stamping mechanism that records the exact time
and date of receipt. This time stamp will serve as a reference
point for any future inquiries or disputes regarding the
transaction. Furthermore, AMC shall maintain an audit trail,
tracking all actions related to the email transaction, including
receipt, verification, and processing. The audit trail will provide
transparency, ensure accountability, and facilitate the
resolution of any issues related to email-based transactions.
9. Change in Registered Email Address / Contact Details Any
change in the registered email address or contact details of the
entity must be communicated to the AMC via a physical letter,
including a scanned copy, signed by the designated authorized
officials of the entity. This change request must also be
supported by a copy of the relevant board resolutions or
authority letter from the entity, issued on the official letterhead.
The AMC will not accept email requests for such changes.
Further, changes in the registered email address will not be
processed unless the request complies with these
requirements. This ensures that only authorized personnel can
modify the contact details associated with the Non-individual
investor’s account.
10. Changes in Bank Mandate No changes to the bank mandate
(including adding or modifying bank account details) will be
accepted via email. Such changes must be submitted using the
prescribed service request form, duly signed by the entity’s
authorized signatories. The form must also be accompanied by
the wet signatures of the designated officials of the entity. This
ensures the authenticity and validity of any change in the bank
details associated with the Non- individual Investor’s account,
and that no unauthorized modifications are made via email.
6711. Digital Signatures and Validity of Electronically Executed
Documents In case of any document executed electronically,
the AMC recognizes the validity of Digital Signature Certificates
(DSCs) or Aadhaar-based e- signatures provided by the
authorized officials of the entity. These digitally signed
documents will be treated as legally binding and valid, even if
they are not sent from the registered email address of the
authorized officials. However, the email domain from which
the document is sent must match the official domain name of the
entity. Such documents, when executed with a valid DSC or e-
signature, will be processed by the AMC without requiring
further verification through physical signatures
68III. Other Details
a. Periodic Disclosures such as Half yearly disclosures, half yearly results, annual
report
Portfolio Disclosures: The SIF shall disclose portfolio (along with ISIN), including
derivative instruments, as on the last day of every alternate month
This is a list of securities where (i.e. as on the end of May, July, September, November, January
the corpus of the investment and March) for all its investment strategies (including debt based
strategy is currently invested. The investment strategies) on the respective AMC SIF website
market value of these https://www.wealthcompanyamc.in/wsif/ and on the website of
investments is also stated in AMFI within 10 days from the close of such month in a user
portfolio disclosures. friendly and downloadable spreadsheet format. All other
provisions regarding portfolio disclosure applicable to schemes
of mutual fund shall also be applicable to the investment
strategies under the SIF.
In accordance with Para 6.1 of SEBI Master circular dated March
20, 2026, unitholders whose e-mail addresses are registered,
AMC shall send the details of the strategy portfolio including the
Investment strategy risk-band, name of benchmark and risk-
band of benchmark while communicating the, monthly statement
of strategy portfolio via email within 10 days from the close of
each alternate month.
AMCs shall provide a link to investors to their registered email to
enable the investor to directly view/download only the portfolio of
strategy subscribed by the said investor. The SIF / AMC shall
provide a physical copy of statement of its strategy portfolio,
without charging any cost, on specific request received from a
unit holder. AMCs shall declare on their website the hosting of
the monthly statement of its strategy portfolio on their respective
websites and on the website of AMFI and the modes such as
SMS, telephone, email or written request (letter) through which a
unit holder can submit a request for a physical or electronic copy
of the statement of strategy portfolio.
The AMC will also provide a dashboard, in a comparable,
downloadable (spreadsheet) and machine readable format,
providing performance and key disclosures like Investment
strategy’s AUM, investment objective, expense ratios, portfolio
details, investment strategy’s past performance etc. on website.
Half Yearly Results The Specialized Investment Fund shall within one month from the
close of each half year, that is on 31st March and on
30th September, host a soft copy of its unaudited financial results
on the AMC SIF website and AMFI.
Written communication (including digital modes such as
email/SMS etc.) shall be sent to unitholders by the asset
management company about the availability of financial results.
Annual Report Pursuant to Regulation 70(1) of SEBI (Mutual Funds) Regulations,
2026 read with Para 6.4 of SEBI Master circular dated March 20,
2026, the strategy wise annual report or abridged summary thereof
in machine readable format will be hosted on the
https://www.wealthcompanyamc.in/wsif/ in machine readable
format and on the website of AMFI, immediately after approval in
Annual General Meetings within a period of four months, from the
date of closing of the financial year (31st March).
The AMCs shall display the link prominently on the website
https://www.wealthcompanyamc.in/wsif/ and make the physical
copies available to the unitholders, at their registered offices at all
times.
69The unit holders may request for a physical copy of strategy annual
reports at a nominal price and the text of the relevant strategy by
writing to the Wealth Company Mutual fund or its RTA . AMC shall
provide a physical copy of abridged report of the annual report,
without charging any cost, on specific request received from a unit
holder.
AMCs shall e-mail the scheme annual reports or abridged summary
thereof, in machine readable formats, to all such unit holders, whose
email addresses are registered with the Mutual Fund. The said
communication shall also include details of modes such as SMS,
telephone, email or written request (letter), etc. through which unit
holders can submit a request for a physical copy of the scheme wise
annual report or abridged summary thereof. AMCs shall send an
email/SMS to all unitholders regarding the hosting of scheme wise
annual report on their website and on the website of AMF. The link
for the mentioned disclosures
https://www.wealthcompanyamc.in/wsif/
Risk Band Risk band forms part of the Product labeling and depicts Risk band
of the investment strategy. The risk band of the investment
strategy shall be in accordance with clause 21.12 of SEBI Master
circular dated March 20, 2026. and regulatory framework issued by
AMFI communication No. 35P/ MEM-COR/ 14 / 2025-26 dated
April 21, 2025.
Disclosure of Risk band of In terms of Clause 6.17 and 21.12 of SEBI Master Circular on
investment strategies and Mutual Funds dated March 20, 2026 and regulatory framework
benchmark issued by AMFI communication No. 35P/ MEM- COR/ 14 / 2025-
26 dated April 21, 2025.the risk band of the investment strategies
SO.38
and benchmark shall be disclosed while disclosing the
performance of the investment strategies from time.
Disclosure of Investment The Investment Strategy Summary Document of each
Strategy Summary Document investment strategy shall be disclosed on AMC SIF website and
to be uploaded AMFI portal in three different formats, ie. Pdf,
excel and xml.
70b. Scenario Analysis for Derivatives Positions (As specified by AMFI) Hybrid Investment Strategies
The following table shows the performance of Nifty50 The following table shows the interest rate
index and individual performance of other indices: change for various sectors:
Nifty50 10.00% Government Bonds 1.00%
IT Sector -15.00% Auto Sector -1.25%
Banking Sector 8.50% Pharma Sector 0.50%
The following table shows the performances of various
asset classes:
Gold Futures 5.00%
REITs/INVITs 2.50%
Total AUM of Investment Strategy ₹ 100,000,000
Scenario 1: Without any unhedged short
derivative exposure
PnL
Weight PnL (Market (Market
Modified Net Asset
Portfolio (NAV/Total up, interest down,
Duration Value(NAV)
NAV) rate down) interest
rate up)
₹35,000,000 ₹3,500,000 ₹-3,500,000
Equity Nifty50 35.0%
Debt instruments Government 5 35.0% ₹35,000,000 ₹1,750,000 ₹-1,750,000
Bonds
₹
₹- ₹-
Commodity Gold Futures 0.0% -
₹ 20,000,000 ₹ 500,000 ₹-500,000
REITs/INVITs 20.0%
₹10,000,000 ₹- ₹-
Cash - 10.00%
₹ 100,000,000 ₹ 5,750,000 ₹-5,750,000
Total 100.0%
5.75% -5.75%
Scenario 2: 10% short exposure in Equity IT Sector and
15% short exposure in bonds of Auto Sector
Weight PnL (Nifty
Modified Net Asset PnL (Nifty
Portfolio (NAV/Tota down by 10%)
Duration Value(NAV) up by 10%)
l NAV)
₹35,000,000 ₹ 3,500,000 ₹-3,500,000
Equity Nifty50 35.0%
Debt instruments Government 5 20.0% ₹20,000,000 ₹1,000,000 ₹-1,000,000
Bonds
₹- ₹- ₹-
Commodity Gold Futures 0.0%
₹15,000,000 ₹500,000 ₹-500,000
REITs/INVITs 15.0%
71Unhedged Equity
Futures IT
₹10,000,000 ₹ 1,500,000 ₹-1,500,000
Short Secto 10.0%
r
Unhedged Debt
Futures Auto -4.5
₹15,000,000 ₹843,750 ₹-843,750
Short Secto 15.0%
r
₹5,000,000 ₹- ₹-
Cash 5.0%
₹100,000,000 ₹7,343,750 ₹-7,343,750
Total 100.000%
7.34% -7.34%
Scenario 3: 10% short exposure in Equity Banking Sector and 15% short exposure in bonds of Pharma
Sector
Weight PnL (Nifty
Beta/Modified Net Asset PnL (Nifty up
Portfolio (NAV/Total down by
Duration Value(NAV) by 10%)
NAV) 10%)
₹ 25,000,000 ₹ 2,500,000 ₹- 2,500,000
Equity Nifty50 25.0%
Government 25.0% ₹25,000,000 ₹ 1,250,000 ₹-1,250,000
Debt instruments 5
Bonds
₹- ₹ - ₹-
Commodity Gold Futures 0.0%
₹15,000,000 ₹ 500,000 ₹-500,000
REITs/INVITs 15.0%
Unhedged Equity
₹10,000,000 ₹-850,000 ₹850,000
Futures Short Banking Sector 10.0%
Unhedged Debt
₹15,000,000 ₹- 337,500 ₹337,500
Futures Short Pharma Sector -4.5 15.0%
₹10,000,000 ₹- ₹-
Cash 10.0%
₹100,000,000 ₹3,062,500 ₹-3,062,500
Total 100.00%
3.06% -3.06%
Note:
1 Equity Derivatives may include exchange traded Futures and Options on equity securities
2 NAV is representative of the market value at the asset level and aggregates to 100% at the
fund level
3 Bond Price change is computed as : ( - Modified Duration * Interest Rate Shift )
4 Bond Derivatives may include IRS, IRF,CDS etc
5 NAV is representative of the market value at the asset level and aggregates to 100% at the
fund level
c. Liquidity risk management tools and its applicability – Not Applicable, as it is a Hybrid investment strategy.
72d. Transparency/NAV Disclosure (Details with reference to information given in Section I)
SO.41
Net Asset Value The AMC will calculate and disclose the first NAV of the
Investment Strategy within a period of 5 business days from the
This is the value per unit of the date of allotment. Subsequently, the NAVs will be calculated and
investment strategy on a particular day. disclosed on all the Business Days.
You can ascertain the value of your
investments by multiplying the NAV with The AMC shall update the NAVs on the website Association of
your unit balance. Mutual Funds in India - AMFI (www.amfiindia.com ) before
11.00 p.m. on every Business Day and shall also update the
NAVs on the website of AMC
(https://www.wealthcompanyamc.in/wsif/) before 11.00 p.m. on
every Business Day for a given business day. If the NAVs are not
available before the commencement of Business Hours on the
following day due to any reason, the Specialized Investment Fund
shall issue a press release giving reasons and explaining when
the Specialized Investment Fund would be able to publish the
NAV.
e. Transaction charges and stamp duty
Transaction Charges Not Applicable
Stamp Duty Specialized Investment Fund units issued against Purchase
transactions (whether through lump-sum investments or switch-ins or
reinvestment under IDCW Option) would be subject to levy of stamp
duty @ 0.005%* of the amount invested. Transfer of Specialized
Investment Fund units (such as transfers between demat accounts)
are subject to payment of stamp duty @ 0.015%. The rate and levy
of stamp duty may vary as amended from time to time.
*Pursuant to Notification No. S.O. 4419(E) dated December 10, 2019
issued by Department of Revenue, Ministry of Finance, Government
of India, read with Part I of Chapter IV of Notification dated February
21, 2019 issued by Legislative Department, Ministry of Law and
Justice, Government of India on the Finance Act, 2019, and
subsequent Notification dated March 30, 2020 issued by Department
of Revenue, Ministry of Finance, Government of India.
The stamp duty will be deducted from the net investment amount i.e.
gross investment amount less any other deduction like transaction
charge. Units will be created only for the balance amount i.e. net
investment amount as reduced by the stamp duty. The stamp duty will
be computed at the rate of 0.005% on an inclusive method basis:
f. Associate Transactions- Please refer to Statement of Additional Information (SAI)
g. Taxation - For details on taxation please refer to the clause on Taxation in the SAI apart from the following:
The information is provided for general information purposes only. However, in view of the individual nature of
tax implications, each investor is advised to consult his or her own tax adviser with respect to the specific tax
implications arising out of his or her participation in the scheme.
73Tax Resident Investors Non-Resident Mutual
Investors Fund
Tax on Income Distribution Slab rates plus 20% plus applicable Nil
under IDCW Option applicable surcharge surcharge and cess 2
and cess2
Capital Gains Slab rates plus Slab rates plus Nil
Short Term Capital Gains on applicable surcharge applicable surcharge
investments in Specified and cess and cess 2
Mutual Funds 1
Slab rates plus
(irrespective of period of Slab rates plus applicable surcharge
holding) applicable surcharge and cess 2
and cess
Short Term Capital Gains on
Non- Equity Funds (other
than Specified Mutual
Funds) 1
(period of holding up to 24
months)
Long Term Capital Gains on 12.50% 12.50% (without Nil
Non- Equity Funds (other (without indexation indexation and
than Specified Mutual Funds benefit) foreign exchange
)1 fluctuation benefit)2
(period of holding more than
24 months)
1. Non-Equity Funds are those funds wherein equity exposure is less than 65% of total proceeds of such fund.
As per Section 50AA of the Income-tax Act, 1961, investments in Specified Mutual Funds on or after April 1,
2023 shall be deemed to be short term capital assets irrespective of holding period.
Up to 31st March 2025, a “Specified Mutual Fund” means a Mutual Fund by whatever name called, where not
more than 35% of its total proceeds is invested in the equity shares of domestic companies. The percentage of
equity shareholding held in respect of the Specified Mutual Fund shall be computed with reference to the annual
average of the daily closing figures. It is possible that an “equity-oriented fund” which invests in units of another
equity fund instead of investing directly in equity shares of domestic company may be regarded as “specified
mutual fund” and taxed accordingly.
From 1st April 2025 onwards, a “Specified Mutual Fund” means: (a) a Mutual Fund by whatever name called,
which invests more than 65% of its total proceeds in debt and money market instruments; or (b) a fund which
invests 65% or more of its total proceeds in units of a fund referred to in (a). The percentage of investment in
debt and money market instruments or in units of a fund, as the case may be, in respect of the Specified Mutual
Fund, shall be computed with reference to the annual average of the daily closing figures.
2. The Mutual Fund will pay/deduct taxes as per the applicable tax laws on the relevant date considering the
provisions of the Income-tax Act, 1961 read with the Income-tax Rules, 1962 and any circulars or notifications or
directives or instructions issued thereunder. Please note that grant of DTAA benefit, if any, is subject to fulfilment
of stipulated conditions under the provisions of the Income-tax Act, 1961 and the relevant DTAA as well as
interpretation of relevant Article of such DTAA.
In case of Resident Investors: TDS is applicable at the rate of 10% on income distributed in excess of Rs.10,000
by a mutual fund.
In case of Non-Resident Investors: TDS is applicable on any income in respect of units of a Mutual Fund at lower
of 20% (plus applicable surcharge and cess) or rate of income-tax provided in the relevant DTAA (read with CBDT
Circular no. 3/2022 dated 3rd February 2022), provided such investor furnishes valid Tax Residency Certificate
(TRC) for concerned FY. Tax will be deducted on Short-term/Long-term capital gains at the tax rates (plus
applicable Surcharge and Health and Education Cess) specified in the Finance Act 2025 at the time of redemption
of units in case of Non-Resident investors (other than FIIs) only.
74TDS at higher rates: In case PAN is not furnished or PAN is inoperative, then TDS as per Section 206AA of the
Income-tax Act, 1961 would apply (higher of specified rate or rates in force or 20%) would apply, subject to Rule
37BC of the Income-tax Rules, 1962.
Investors are requested to note that the tax position prevailing at the time of investment may change in
future due to statutory amendment(s). The Mutual Fund will pay/deduct taxes as per the applicable tax laws on the
relevant date considering the provisions of the Income-tax Act, 1961. Additional tax liability, if any, imposed on
investors due to such changes in the tax structure, shall be borne solely by the investors and not by the AMC or
Trustee.
Under section 10(23D) of the Income tax Act, 1961, income earned by a Mutual Fund registered with SEBI is
exempt from income tax. The Wealth Company Mutual Fund is registered with Securities and Exchange Board of
India (SEBI) and is as such eligible for benefits u/s. 10(23D) of the Income-tax Act, 1961.
h. Rights of Unitholders- Please refer to SAI for details.
i. List of official points of acceptance:
The details pertaining to official points of acceptance of AMC and RTA are available on the website of the
AMC at https://www.wealthcompanyamc.in/wsif/
Details of the Registrar and Transfer Agent:
Name KFin Technologies Limited
Selenium Building, Tower-B, Plot No 31 & 32,
Address Financial District, Nanakramguda, Serilingampally,
Hyderabad, Rangareddy, Telangana India - 500 032.
Website Address wwww.kfintech.com
In addition to the existing official points of acceptance (“OPA”) for accepting transactions in the units of the investment
strategies of the Fund as disclosed in the ISID , online transactions may also be done on the transaction portal of MFU
i.e. https://www.mfuindia.com/
j. Penalties, Pending Litigation or Proceedings, Findings of Inspections or Investigations for which action may
have been taken or is in the process of being taken by any Regulatory Authority.
SO. 48
SO. 49
Please refer AMC SIF website https://www.wealthcompanyamc.in/wsif/ for latest updates.
The Investment Strategy under this Investment Strategy Information Document was approved by the Trustee Company
on November 27, 2025. The Trustees have ensured that the WSIF Equity Long-Short Fund approved by them is a new
product of WSIF (offered by The Wealth Company Mutual Fund) and is not a minor modification of any existing Investment
Strategy.
Notwithstanding anything contained in this Investment Strategy Information Document, the provisions of the
SEBI (Mutual Funds) Regulations, 2026 and the guidelines there under shall be applicable.
For and on behalf of SO.63
Wealth Company Asset Management Holdings Private Limited
sd/-
Suruchi Wanare
Chief Compliance Officer
Place: Mumbai
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
75