Consolidated Report of Comments offered to PFRDA (Custodian of Securities ) Regulations 2014

Name of the Person: Organisation: ICICI Prudential Pension Fund Company Designation:

Sr. No.

Pertains to which regulation /Sub-regulation (Regulation No. & Clause No.)

Proposed/suggested changes*

Rationale

1. Regulation 3 (2): Certificate of registration: The Authority may if deemed necessary in subscriber‘s interest select one or more than one custodians.

We suggest the Authority to mandate minimum of 2 custodians at all times.

Ensuring 2 custodians at all times would promote healthy competition in the industry with regards to maintaining higher quality of services and choice for the PFMs.

2. Regulation 14. Period of validity: (1) Every Certificate of Registration granted under these regulation shall be valid for a period of 5 years from the date of grant of registration

An on-going / perpetual license may be issued subject to provision for cancelling license based on adverse findings of periodic / annual review and subject to provision for review of charges / fees in line with guidelines from the authority

The authority may issue perpetual / ongoing license in line with the licenses issued for other financial products like banking, mutual funds, insurance etc. issued by RBI, SEBI and IRDA respectively. We submit that a limited 5 years validity of license creates doubts regarding ongoing nature of the business and entails the intermediary to work on a short term business plan which is in conflict with the long term nature of pension product and the long investment horizon of the customer.

3. Regulation 20. General obligations of Custodian of Securities

The custodian should be capable of allowing:

Net settlement of funds for purchase and sale of securities

Payment of funds by the PF for purchase of securities on settlement date

Receipt of funds by the PF for sale of securities on settlement date

The current custodian guidelines by the authority require payment for purchase of government securities on transaction date. This results in the customer’s funds remaining idle till settlement date resulting in loss of income and lower returns to subscribers. RBI guidelines require that the custodian should confirm the availability of funds for purchase of securities before settling the trade. The custodian may confirm the same by looking at holding statement of liquid funds by the PF along with a copy of redemption request sent. Similarly, the current guidelines require the sale proceeds to be transferred by the custodian to the PF on the next business day after the settlement day. This again results in the customer’s funds remaining idle till settlement date resulting in loss of income and lower returns to subscribers.

4. Fourth schedule: Code of conduct

Request the Authority to prescribe same day transfer of dividends,

A time gap results in the customer’s funds remaining idle resulting in loss of income and ultimately lower returns to

II. Disbursal of Amounts 2.1 Disbursal of Amounts A custodian of securities shall be prompt in disbursing dividends, interests or any such accrual income received or collected by it on behalf of its Authority/ NPS Trusts/subscribers.

interests, other accrual income as well as sale proceeds for the interest of the subscribers. Similarly, the Authority may prescribe that the custodian shall require payment of funds by PF for purchase of securities on the settlement date.

subscribers.

5. Regulation 8(2) (a) Eligibility criteria: The applicant has necessary infrastructure… VI. Custodian of Securities Infrastructure Requirements

The custodian should be required to provide access to NDS OM for smooth transactions and settlements of government securities.

Name of the Person: Mr. R.Anand

Organisation: Stock Holding Corporation of India Ltd.

Designation: Vice President

Sr. No

Reference No.& Clause No.

Extracts of clause Suggested Change Rationale

1 3 (4)

Cert. Of Registration

However, any Custodian of Securities, who had been associated with a pension scheme and appointed to act as such by the Interim Pension Fund Regulatory and Development Authority immediately before the establishment of the Authority under this Act for which no Registration Certificate was necessary prior to such establishment, may continue to do so for a period of six months from such establishment or, if

Existing custodian can be provided deemed registration till the validity of his existing terms.

The applicable fee may be collected from the existing custodian

he has made an application for such registration within the said period of six months, till the disposal of such application in the manner as specified in Regulation 15.

2 8. 1.(d)

Eligibility Criteria

The applicants‘ holding of Assets under Custody on the date of application must be at least equal to the total Assets Under Management of NPS as on 31st March of the preceding financial year.

The applicants‘ holding of Assets under Custody on the date of application must be at least 5 times the total Assets Under Management of NPS as on 31st March of the preceding financial year.

The change will ensure that from a risk perspective, NPS AUM does not form more than 20% of the total assets of the custodian.

Also the NPS assets will increase each year and hence this will also consider the expected increase over the term of the appointment.

3 8. Eligibility Criteria

New Clause suggested

Applicant is not an intermediary offering advisory or banking services to the NPS Trust

This will ensure proper focus on the core competency expected from the service provider and help mitigate risks attributed to bias / revenue off-setting business

4 8. 2. (b)

Eligibility Criteria

The applicant has the ability to segregate activities of National Pension system/other pension schemes regulated by the Authority from its other custodial clients and maintain firewall.

The mention about “maintain firewall” may be removed.

It is understood that activities relate to transactions, assets, data of the NPS Trust and these have to be recorded/ identified/ kept in a separate and distinctive form vis-a-vis transactions, assets of other clients. The mention about “maintain firewall” may be removed.

5 8. 2.(c)

Eligibility Criteria

The applicant has the capacity to employ identifiable and dedicated resources for activities related to National Pension System/any other pension scheme regulated by the Authority.

The applicant has the capacity to employ identifiable resource as a relationship manager, who will act as the one point contact for the NPS Trust / any other pension scheme regulated by the Authority.

It is understood that such resources should be identified at the Relationship Manager Level, who will act as the one point contact for NPS Trust.

6 8.2.(g)

Eligibility

Whether the applicant or any of its associates have in

Whether the applicant or any of its associates have in

A custodian who was once issued a Certificate of Registration, but the same is not renewed by SEBI will not

Criteria the past been refused certificate of registration by any of the financial sector regulators in India including, RBI, SEBI, IRDA and PFRDA and if so, the ground for such refusal.

the past been refused certificate of registration or renewal of the certificate of registration by any of the financial sector regulators in India including, RBI, SEBI, IRDA and PFRDA and if so, the ground for such refusal.

be covered unless changes incorporated in the clause

7 8 2.(h)

Eligibility Criteria

Whether the applicant have in the past 5 years been imposed with penalties by any of the financial regulators (RBI, SEBI, IRDA and PFRDA) or by a court of law or tribunal, on the matters concerning violation of regulations, directions, guidelines and circulars of the regulator and if so, the ground for such refusal.

Whether the applicant have in the past 5 years been imposed with penalties by any of the financial regulators (RBI, SEBI, IRDA and PFRDA) or by a court of law or tribunal, on the matters concerning violation of regulations, directions, guidelines and circulars of the regulator pertaining to provision of Custodial Services and if so, the ground for such refusal.

Clause is open ended as it covers all business verticals. Instead, since the service offering is for Custody, penalties for the same can be covered. However, if penalties on other business verticals results in cancellation of license/ approval for that vertical, then the same can be included from a cautious approach perspective

8 9 (1)

Exemptions from Eligibility Criteria

Every applicant must mandatorily meet the minimum eligibility criteria as specified in the Regulations in 8(1) above

However, existing/ past custodians having serviced assets of the NPS Trust without any major penalties etc., can request for exemption under clause 8(1)

If an existing or past custodian has offered services to the satisfaction of the NPS Trust, he can be given an opportunity as he was then considered eligible.

9 10 (4)

Procedure for Grant of Certificate of Registration

No existing custodian of securities shall be entitled to claim any priority or privilege for grant of Certificate of Registration under the selection process undertaken subsequently.

An existing custodian, if otherwise the NPS Trust is satisfied with the services, and there being no major penalties levied against him, may be accorded a first right of refusal.

10 13 (1) Upon completion of documentation by

Upon completion of documentation by the

The change will help convey that this is for servicing pension

Commencement of Business

the Custodian and other related formalities for undertaking its operations for which it has been granted registration, the Custodian shall seek issuance of Certificate for Commencement of Business from the Authority

Custodian and other related formalities for undertaking its operations for which it has been granted registration, the Custodian shall seek issuance of Certificate for Commencement of Servicing for Pension Funds from the Authority

business as most custodians have already commenced business

11 14 (4)

Period of Validity

The Custodian of Securities shall be liable to pay fees as specified in Part A and B of the Schedule II on pro rata basis for the extended period.

Since custodian currently pays fees to other regulators (currently SEBI charges fees while RBI does not charge any fee), PFRDA may consider moderation of the fee structure or the regulators may decide amongst themselves that any duplication of levy of fee by various regulators on same assets be avoided.

This will avoid duplication of fees for the same set of assets. Alternatively, the other regulator may levy very nominal fees while the main regulator for the asset levies normal fees

12 15 (3)

Transitory provisions for registration of Existing Custodian

Any existing Custodian of Securities specified under sub-regulation (i) shall not be entitled to claim any priority or privilege for grant of registration under the selection process undertaken subsequently

An existing custodian, if otherwise the NPS Trust is satisfied with the services, and there being no major penalties levied against him, then accord a first right of refusal.

This may be made in line with suggestion made for clause 10(4)

13 16 1 (c)

Cessation or Cancellation or withdrawal or suspension of Certificate of Registration

The Registration granted by the Authority to act as a Custodian of Services is liable to be cancelled, suspended or

withdrawn, if ; contravenes any of the provisions of the Act, rules or regulations framed thereunder or any guidelines or notifications, directions, instructions or

The Registration granted by the Authority to act as a Custodian of Services is liable to be cancelled, suspended or withdrawn, if ; contravenes and does not rectify the same or regularly contravenes any of the provisions of the Act, rules or regulations framed thereunder or any guidelines or notifications,

Suggested that Regulator may like consider a one off case of contravention, depending its seriousness and if it remains unrectified as otherwise this measure would be too stiff.

Even RBI takes the strong measure of suspending operations on 3 instances of SGL bouncing in half a year.

circulars issued thereunder

directions, instructions or circulars issued thereunder

14 17. 2.(c)

Effect of cancellation or withdrawal or cessation of suspension of certificate of registration.

Transfer the assets, records, documents or information that are in its custody or control to another Custodian of Securities if so directed by the Authority at its own cost;

If there is a change of custodian in the normal course, then the outgoing custodian may not bear the costs associated with such transfers.

It is suggested that where there is a change of custodian in normal course, then the outgoing custodian may not be required to bear the cost.

15 20 New clause 20 (17) It shall be the duty of the custodian of securities to adhere to all applicable rules, regulations, circulars, guidelines etc framed/ recommended/ mandated by any regulator/ authority/ clearing corporation/ exchange/ depository etc for the various functions/ service offerings to the NPS Trust

This will ensure that all assets are serviced by the custodian by adhering to all regulatory requirements, process flows etc and thereby facilitate complete operations of all risk mitigation measures adopted / recommended /mandated of various authorities

16 20 (13)

General Obligation of Custodian of Securities

The Custodian of Securities shall not encumber the securities in any manner including by an act of pledging, hypothecating or creating any charge or lien on the said securities. The Custodian shall not convert the securities in any manner without the approval of the Authority or National Pension System Trust.

The Custodian of Securities shall not encumber the securities in any manner including by an act of pledging, hypothecating or creating any charge or lien on the said securities. The Custodian shall not convert the securities in any manner without the approval of the Authority or National Pension System Trust. Except for any corporate action which is voluntarily carried out by the company in normal course of action as also conversion of physical holdings into electronic holdings that can be

Modification suggested to ensure smooth continuous operations as a custodian hardly has any role in case of voluntary corporate action like mergers, bonus, consolidation/ split, change of face value etc

initiated by the custodian based on availability of ISIN in electronic mode. In all such instances, custodian to report such instances to NPS Trust and the PFM

17 20 (16)

General Obligation of Custodian of Securities

The custodian shall have its books of accounts / holding audited quarterly by an internal auditor and submit the same to the Authority or National Pension System Trust within 3 months from the date of audit.

The custodian shall have its books of accounts / holding audited quarterly by an internal auditor and submit the an extract thereof relating to the assets / business of the Pension Fund to the Authority or National Pension System Trust within 3 months from the date of audit.

The entire audit report may contain remarks on various other business verticals.

18 Schedule II Part A, Explanation I

Debt assets to be valued at face value while equity assets at market value

This clarity which is in line with clause 18 (2) will avoid later confusions/ queries as regards valuation to be adopted for payment of fees

PFRDA (Custodian of Securities) Regulations, 2014 Name of the Person: Aashish Mishra Organization: Citibank N.A., India Designation: Director and Country Head – Securities Services

Sr. No. Pertains to which regulation /Sub regulation (Regulation No. & Clause No.)

Regulation Proposed/suggested changes*

Rationale

1.

Clause 8 (1) on Eligibility Criteria, Sub-clause (c)

(c) Direct or indirect foreign holding in the Custodian of Securities should not be more than 26%

We request that this clause be removed from the minimum eligibility criteria.

The rationale to use a large custodian, including internationally reputed custodians, are as below:

Criteria of foreign holding should apply to PFMs and not Custodians –

Currently the Authority has a similar eligibility criteria for PFMs and rightly so, since the PFMs are directly responsible for managing the funds of the NPS subscribers. However, in case of any custodian, the securities are held at central depositories (demat account) which are independent and regulated bodies. Accordingly, in our opinion, all SEBI registered custodians should be

eligible to apply to the Authority for empanelment as a custodian to NPS assets

Value Added Services - Backed by

international network, Global Custodians are able to offer multiple value added solutions that help in risk mitigation, yields enhancement and thereby reduction in the overall costs. For example, Citi offers the following solutions: a. Performance Management & Risk Analytics : Across the full range of asset

classes with specialized analysis for equity and fixed income managers b. Compliance Monitoring : Flexible

and robust solution to clients’ post-trade compliance monitoring requirements, whether they are regulatory or contractual c. Securities Lending : Parameterized

securities lending solution that provides clients with a customized service and is designed to enhance portfolio performance d. Global Custody: Owing to the

international network, Global Custodians can seamlessly support investments in international markets, which is a trend today among all large pension funds across the world to manage their risk and enhance returns through diversification.

Optimized set-up and benefits from

differentiated expertise and solutions

– A Global Custodian uses state of the art technology and has world class capabilities based on which it would be in a position to offer better quality of services

Scalability of operations & Better Operations Risk Mitigation –

Leveraging on its global experiences, a global custodian like Citi has robust processes and contingency plans to ensure risk free and continuity of processing. For example, Citi has parallel processing sites in Mumbai and Bangalore which provides unique capability to deal with a contingency scenario in either of the cities. Further, most custodians are banks as it leads to efficient processing and thereby also optimization of costs. The FDI policy permits foreign investments in Indian banks to be up to 74%. Also, the RBI permits foreign banks to operate as branches or a foreign subsidiary thereby continues to be 100% foreign owned. Accordingly, expanding the eligibility criteria to include large and reputable custodians would be in the interest of the subscribers thereby endorsing the

requirements of regulation 8(2)(j).

2.

Clause 8 (2) on Eligibility Criteria, Sub-clause (b), (c)

(b) the applicant has the ability to segregate activities of National Pension system/other pension schemes regulated by the Authority from its other custodial clients and maintain firewall. (c) The applicant has the capacity to employ identifiable and dedicated resources for activities related to National Pension System/any other pension scheme regulated by the Authority

(b) the applicant has the ability to segregate activities undertaken as a custodian, including the activities of National Pension system/other pension schemes regulated by the Authority, from its other businesses and maintain firewall. (c) The applicant has the capacity to employ identifiable and dedicated resources for activities related to its custodian services

There are multiple activities undertaken by the custodians like clearing and settlement, corporate action, public offer, reconciliation of holding, etc. that are centralized from a processing perspective since the same leads to faster turnarounds with enhanced controls. Further, creating segregation in people and systems would render the operations inefficient and deprived for the global best practices, robust contingency measures including loss of people, etc. Accordingly, custodian should maintain firewall between processing for its custody clients and other non-custody businesses of the entity and along with the same ensure that there are measures and controls in place to ensure confidentiality of information pertaining to its clients. Clause 8 (2) sub-clause (f) anyways require custodian to have arm’s length distance with other business. Further, SEBI (Custodian of Securities) Regulations, 1996 specifies as follows: “Where a custodian of securities is carrying on any activity besides that of acting as custodian of securities, then,— (i) the activities relating to his business as custodian of securities shall be separate and segregated from all other activities;

(ii) its officers and employees engaged in providing custodial services shall not be engaged in any other activity carried on by him.”

3.

Clause 8 (2) on Eligibility Criteria, Sub-clause (g), (h)

(g) Whether the applicant or any of its associates have in the past been refused certificate of registration by any of the financial sector regulators in India including, RBI, SEBI, IRDA and PFRDA and if so, the ground for such refusal.

(g) Whether the applicant or any of its associates have in the past been refused certificate of registration in relation to custody services by any of the financial sector regulators in India including, RBI, SEBI, IRDA and PFRDA and if so, the ground for such refusal. (h) whether the applicant have in the past 5 years

Since most large custodians have diversified businesses, many of which may be entirely unrelated to custodian services, in order to keep the information specific and relevant it is suggested that the details of rejection, fines and penalties be restricted in relation to custody services.

(h) whether the applicant have in the past 5 years been imposed with penalties by any of the financial regulators (RBI, SEBI, IRDA and PFRDA) or by a court of law or tribunal, on the matters concerning violation of regulations, directions, guidelines and circulars of the regulator and if so, the ground for such refusal.

been imposed with penalties by any of the financial regulators (RBI, SEBI, IRDA and PFRDA) or by a court of law or tribunal, on the matters concerning violation of regulations, directions, guidelines and circulars of the regulator in relation to custody services and if so, the ground for such refusal.

4.

Clause 11 on Terms and Conditions of Certificate of Registration, Sub-clause 1(b)

The Custodian shall provide all Custodial and depository participant services related to all securities permitted to be held under the pension schemes regulated the Authority.

We request that this clause be removed from the Terms and Conditions of Certificate of Registration.

Majority of the custodians in the local market today do not provide custodial services for assets like Gold, Commodities etc which may be permitted by the Authority to be held under the pension schemes.

5.

Clause 11 on Terms and Conditions of Certificate of Registration, Sub-clause 1(f)

Custodian shall maintain confidentiality with respect to all transactions, records, data and information received while discharging its obligations and shall not, without the prior permission of Authority, produce or share such data or information as evidence or for any other purpose except as required under the process of law;

Custodian shall maintain confidentiality with respect to all transactions, records, data and information received while discharging its obligations and shall not, without the prior permission of Authority, produce or share such data or information as evidence or for any other purpose except as required under the process of law or in cases wherein the custodian is required to disclose any information for confidential use in connection with the provision of custodian services

Custodians may be required to share client related information to its internal and statutory auditors, risk and compliance teams etc.

6.

Clause 11 on Terms and Conditions of Certificate of Registration, Sub-clause (j)

(j) No Custodian of Securities shall assign or delegate or outsource any part of its functions as a Custodian of Securities to any other entity without the prior permission of the Authority.

(j) No Custodian of Securities shall assign or delegate or outsource any part of its functions pertaining to activities of National Pension system/other pension schemes regulated by the Authority to any other entity without the prior permission of the Authority.

SEBI (Custodian of Securities) Regulations, 1996 specifies that no custodian of securities shall assign or delegate its functions as a custodian of securities to any other person unless such person is a custodian of securities. Accordingly, the custodian should be have the provision to delegate or outsource any part of its functions not pertaining to activities of National Pension system/other pension schemes regulated by the Authority, to another entity as long as such entity is a custodian of securities.

7.

Clause 18 on Asset Servicing Charges, Sub-clause (1)

(1) The asset servicing charges that can be levied by the Custodian of Securities on the asset held under the pension schemes regulated by the Authority shall be determined as per procedure laid down by the Authority.

- The procedure for determination of asset servicing charges to be levied by the custodian should be specified by the Authority.

8.

Clause 20 on General Obligations of Custodian of Securities, Sub-clause (6)

The Custodian of Securities shall ensure that all the rights or entitlements on the securities held in its custody for pension schemes / NPS Trust are received on time and in the manner specified by the Authority/ NPS Trust

The Custodian of Securities shall ensure adequate internal controls to prevent any manipulation of records and documents including audits for securities and rights or entitlements arising from the securities held by it in its custody for pension schemes / NPS Trust.

A Custodian of Securities can only ensure collection; reporting and follow up with the issuers / market intermediaries for the rights or entitlements on the securities held on behalf of its clients.

9.

Clause 20 on General Obligations of Custodian of Securities, Sub-clause (10)

The Custodian of Securities shall ensure that the securities handled by it under the National Pension System or any pension scheme regulated by the Authority are adequately insured.

The Custodian of Securities shall ensure that appropriate insurance is in place to cover for errors and omissions in the activities undertaken for the National Pension System or any pension scheme regulated by the Authority

The securities, except physical securities (if any), are held with the Central Depositories / Public Debt Office of the Reserve Bank of India. Accordingly, insuring the entire value of the securities may not be warranted and would lead to increase in costs substantially which would not be in the best interests of the subscribers.

10.

Second Schedule – Fees Payable under the Regulations, Part A, Amount to be paid as Fees

Annual Fee - 0.0005% of Assets under Custody or Rs 10,00, 000 Whichever is higher Assets under Custody shall be considered as on 31st March of preceding financial year.

Annual Fee - 0.0005% of Assets [as defined under clause 2 (d) of these Regulations] under Custody or Rs 10,00,000 Whichever is higher Assets under Custody shall be considered as on 31st March of preceding financial year.

Prescribed fees will be recovered by the custodian as part of its expenses and hence such charges won’t be in the best interest of the subscribers. Further, all Custodians are regulated by SEBI and are required to pay similar fee based on the assets held under Custody. Accordingly, these fees should not be levied or else exemption should be sought from SEBI for fees otherwise payable to SEBI to avoid double levy.

11 Fourth Schedule – Code of Conduct Clause I on Subscriber Protection, Sub-clause 1.4 on Fee

A custodian of securities shall levy charges/ fees for the services rendered as determined by the Authority

The procedure for determination of charges/ fees for the services rendered by the custodian should be specified by the Authority.

12.

Fourth Schedule – Code of Conduct Clause I on Subscriber Protection, Sub-clause 5.2 on Compliance And Corporate Governance

A custodian of securities shall take adequate and necessary steps to ensure that continuity in data and record keeping is maintained and that the data or records are not lost or destroyed. It shall also ensure that for electronic records and data, up-to-date back up is always available with it.

The custodian of securities shall create and maintain the records of securities held in custody in such manner that the tracing of securities or obtaining duplicate title documents is facilitated, in the event of loss of original records for any reason. Where custodian records are kept electronically, the custodian of securities shall take precautions necessary to ensure that continuity in record keeping is not lost or destroyed and that sufficient back up of records is available.

For physical securities, in the extreme event of loss of records, the custodian should be required to facilitate obtaining duplicate title documents. The suggested clauses are similar to the requirements enunciated by the SEBI (Custodian of Securities) Regulations, 1996.

13 Fourth Schedule – Code of Conduct Clause I on Subscriber Protection, Sub-clause 5.6 on Compliance And Corporate Governance

A custodian of securities shall also comply with the award of the Ombudsman passed under the PFRDA (Subscriber grievance Redressal Mechanism) Regulation 2014.

We suggest that this clause be deleted due to the reasons listed below:

ot be maintaining subscriber level data in its books

with the NPS Trust and it would be subject to the terms and conditions specified in such an agreement

not an intermediary as per the draft PFRDA (Subscriber grievance Redressal Mechanism) Regulation 2014 issued by the Authority.

14.

Fourth Schedule – Code of Conduct Clause I on Subscriber Protection, Sub-clause 5.7 on Compliance And Corporate Governance

A custodian of securities shall ensure that the Authority is promptly informed about any action, legal proceedings, etc., initiated against it in respect of any material breach or non-compliance by it, of any law, rules, regulations, and directions of the Authority or of any other regulatory body.

A custodian of securities shall ensure that the Authority is promptly informed about any action, legal proceedings, etc., initiated against it in respect of any material breach or non-compliance by it, of any law, rules, regulations, and directions of the Authority or of any other regulatory body, as a result of which there may be a potential impact to the provision of custodial services itself.

Most large custodians have diversified businesses, many of which may be entirely unrelated to custodian services. Accordingly, in order to keep the information specific, it is suggested that the requirement to inform the Authority about any action, legal proceedings, etc., initiated against the custodian in respect of any material breach or non-compliance by it, of any law, rules, regulations of any other regulatory body should be restricted to cases wherein there may be an impact to the provision of custodial services itself only.

15 Fourth Schedule – Code of Conduct Clause VI on Custodian of Securities Infrastructure Requirements, Sub-clause 6.5 (a)

A custodian of securities or any of his employees shall not render, directly or indirectly any investment advice about any security in the publicly accessible media, whether real-time or non-real-time, unless a disclosure of his interest including long or short position in the said security has been made, while rendering such advice.

Employees of the Custodian who are involved directly or indirectly in the provision of custodian services, shall not render, directly or indirectly any investment advice about any security in the publicly accessible media, whether real-time or non-real-time.

An entity providing Custodian services may also have other businesses like Private Bank, Wealth Management etc by nature of which employees managing such businesses may be required to render investment advices. However, the Custodian should be required to maintain firewall between its custodian and other businesses

Instruction to fill up the format: 1. All letters or emails to clearly specify the name and number of the regulation, sub-regulation and clause.

2. Separate letters/emails to be used for different regulations.

3. Each proposed amendment to be given separately.

4. Each proposed amendment (preferably) not to exceed 200 words*