SEBI's New Disclosure Guidelines for Mutual Funds

InGovernimagesGuest post from Shriram Subramanian, founder of InGovern Research Services with the objective of facilitating shareholder activism by institutional investors and thereby enhancing corporate governance in India. Proxy Advisory Services, Corporate Governance Research, Risk Monitoring, and Proxy Services. India’s SEBI, through a circular dated March 24th, 2014, released a new set of disclosure guidelines to be followed by mutual funds. These guidelines will be applicable from April 1st, 2014. Some of the important guidelines are:
Disclosure of AUM

  1. Disclosure of assets under management (AUM) on a monthly basis.
  2. The disclosures will include contribution of AUM from
    1. different category of schemes,
    2. top tier and other cities,
    3. sponsors and associates,
    4. entities other than sponsor and associates,
    5. investors type (retail, corporate, etc) in different scheme type (equity, debt, ETF, etc.),
    6. AUM garnered through sponsor group/ non-sponsor group distributors, and
    7. State-wise/Union territory-wise contribution to AUM.
  3. This information will be disclosed on the respective AMC’s website and on AMFI website.

Disclosure of Voting Exercise

  1. AMCs will record and disclose specific rationale supporting their voting decision (for, against or abstain) with respect to each vote proposal.
  2. AMCs will publish summary of votes cast across all its investee companies and along-with break-up of for, against or abstained votes.
  3. AMCs will disclose voting exercises on their website on a quarterly basis, within 10 working days from the end of the quarter and also in their annual report.
  4. AMCs will obtain Auditor’s certification on voting reports being disclosed by them which will be submitted to trustees and also disclosed in the annual report & website.
  5. Board of AMCs and Trustees will review and ensure that AMCs have voted on important proposals and the rationale recorded for vote decision is prudent and adequate.

Other Disclosures

  1. Mutual Funds will make available printed literature on mutual funds in regional languages.
  2. Mutual Funds will introduce Investor awareness campaign in regional languages both in print and electronic media.
  3. AMCs will develop a system for active support to PSU banks to distribute Mutual Fund products through them.
  4. Mutual funds will also provide an online investment facility on their websites

The spreadsheet format of disclosures can be downloaded from here.

The SEBI circular can be downloaded from here. The InGovern CG platform helps in all respects and makes the tasks of record keeping, audit trails, rationale capturing, etc. easy and streamlined. Additionally, as fields are locked down after voting, the data can be easily certified by the Auditor. Disclosing voting data is very easy as it has to be generated out of the Excel file output with from and to dates to get the data. The InGovern CG platform meets all these requirements and makes it easier for you to meet these compliance requirements. Fund managers can see shareholder meetings and proposals on a daily basis.A brief on the InGovern CG platform can be read here. To know more about the platform, please write us at

To subscribe to any of our vote recommendation reports or other services, please write to us at To know more about our services, please visit our website at

Please reach us with any questions:

Shriram Subramanian
Founder & Managing Director
T: +91 80 4227 9150

Disclaimer: This note is confidential and may not be reproduced in any manner without the written permission of InGovern Research Services Pvt. Ltd. (“InGovern”). This analysis does not constitute investment advice and investors should not rely on it for investment or other purposes. No warranty is made as to the completeness, accuracy or utility of this analysis. InGovern does not provide consulting services to issuers. Some institutional investor affiliates of issuers may have purchased a subscription to InGovern services, which is disclosed on relevant reports. In addition, advisors to issuers such as law firms, accounting firms, rating agencies or others may subscribe to InGovern services. InGovern does not discuss our analysis or reports with any entity prior to publication.

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