SIF minimum investment rule: How is the ₹10 lakh threshold calculated for an investor? Experts weigh in
A Specialised Investment Fund (SIF) has a minimum investment requirement of ₹ 10 lakh, but this does not mean an investor has to put ₹ 10 lakh in a single SIF strategy.
Here’s what investors need to know about the ₹ 10 lakh SIF investment requirement.
SIF strategies are broadly divided into equity-oriented, debt-oriented, and hybrid strategies , depending on the type of assets they invest in and the approach they follow.
Nitin Agrawal, CEO, Mutual Funds by InCred Money, explained that the ₹ 10 lakh threshold is not a per-strategy requirement but an AMC-level aggregate.
“An investor can split their investment across multiple SIF strategies offered by the same AMC, and the combined value counts toward meeting the threshold,” he added.
Agrawal explained that Sebi tracks eligibility at the individual investor level (PAN) for each AMC separately. The ₹ 10 lakh check applies across all SIF strategies of a given AMC, not to each strategy separately.
Sougata Basu, Founder, CashRich, explained that the PAN level means every folio and holding mode tagged to one PAN gets added up across the investment strategies offered under that SIF.
Basu clarified that Sebi frames the rule around “investment strategies” under an SIF rather than “schemes”. Each strategy has its own NAV and works much like a scheme, but with wider tools (short positions, derivatives).
Basu explained this with an example. If an AMC offers a Hybrid Long-Short and an Equity Long-Short strategy, an investor can invest ₹ 6 lakh in one and ₹ 4 lakh in the other. Since the combined investment is ₹ 10 lakh under the same PAN and AMC, the investor meets the threshold.
“However, ₹ 5 lakh invested in an SIF of AMC A and ₹ 5 lakh in an SIF of AMC B would not qualify. The ₹ 10 lakh threshold is calculated separately for each AMC,” he added.
“Only SIF investments count. Regular mutual fund holdings with the same AMC are excluded, even if the investor holds crores there. Someone with ₹ 50 lakh in regular schemes and ₹ 8 lakh in SIF strategies does not meet the threshold,” Basu explained.
According to Agrawal, Sebi-accredited investors are exempt from the ₹ 10 lakh minimum investment requirement.
Basu added that mandatory investments made by an AMC on behalf of its designated employees under the “skin-in-the-game” requirement are also exempt.
All three are permitted, subject to one binding condition. The aggregate SIF investment at the PAN level must stay at or above ₹ 10 lakh through these transactions, Basu noted.
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