SEBI Master Circular — the sections that shape AIF fund administration
SEBI's Master Circular for Alternative Investment Funds consolidates the operating expectations regulators place on managers, trustees and — by extension — fund administrators. Below is a practitioner-oriented tour of the sections that most directly influence day-to-day AIF fund administration.
Note: This summary is educational and reflects the industry's current reading of the SEBI Master Circular for AIFs. It is not legal advice; consult your compliance counsel and refer to the latest SEBI text at sebi.gov.in for authoritative wording.
Valuation and NAV
The Master Circular re-affirms the requirement for independent valuation of unlisted securities and a documented valuation policy at the fund level. For a fund administrator, this cascades into:
Freezing marks against the valuation policy on the NAV date, not on the reporting date.
Reconciling third-party valuer inputs into the accounting system with a full audit trail.
Escalating stale or missing marks before NAV publish, with maker-checker sign-off.
Modern NAV calculation software for AIF automates most of this — but the responsibility for policy adherence sits with the administrator and the trustee.
PPM disclosures & investor consent
The circular emphasises that any deviation from the Private Placement Memorandum requires investor consent thresholds. For the administrator this means:
Maintaining a version-controlled PPM and side-letter register.
Producing an as-executed commitment schedule reconciled to the subscription agreements.
Flagging fee, waterfall or investment-strategy changes for governance workflow.
Investor reporting
SEBI expects consistent, comparable investor reporting — inflows, outflows, valuation, fees, expenses and performance. A conforming AIF investor servicing software should produce:
Standard capital account statements per LP class.
Periodic performance reports with net IRR, DPI, TVPI and gross MOIC.
An audit-ready trail of every document dispatched and every LP acknowledgement.
Trustee governance & compliance officer
The circular reiterates the trustee's oversight role and the requirement for a designated compliance officer. Administrators typically:
Maintain a compliance calendar of trustee-board and SEBI filings.
Prepare the pack for trustee approval — NAV, distributions, capital calls, side-pockets.
Support the compliance officer's periodic risk & control reviews.
Where AIFLedger fits
AIFLedger is a purpose-built SEBI AIF compliance software that codifies the Master Circular's operational expectations — maker-checker journals, dual-signature NAV publish, versioned PPM library, per-investor consent tracking, and a fund-admin console designed for Indian AIF categories.