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How do I start an investment fund, like a hedge fund or VC fund, in India?

Any Indian fund that pools other people's money to invest privately must register with SEBI as an Alternative Investment Fund: a VC or angel fund is Category I, a private equity or debt fund Category II, and a hedge fund or any fund that borrows to invest Category III. Each scheme needs a minimum corpus of Rs 20 crore, each investor must put in at least Rs 1 crore (Rs 25 lakh for the fund's own employees and directors), and the sponsor or manager must keep the lower of 2.5% of the corpus or Rs 5 crore in the fund. You set it up as a trust with a manager company, file a private placement memorandum and apply on SEBI's intermediary portal. A fund raising mostly from overseas often sets up in GIFT City under IFSCA instead. Managing individual portfolios is a separate SEBI licence, and a quant firm trading only its own capital needs no fund licence. The hard part is a track record that makes people trust you with Rs 1 crore each, so many start with an angel fund or syndicate.

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SEBI's own announcement of the rules every private fund in India is registered under: three categories of Alternative Investment Fund, a minimum investment of Rs 1 crore per investor and a minimum corpus of Rs 20 crore.

SEBI notifies SEBI (Alternative Investment Funds) Regulations, 2012

From sebi.gov.in by Securities and Exchange Board of India Press release

  • A VC or angel fund registers as Category I, a PE or debt fund as Category II, a hedge fund as Category III.
  • No AIF may take less than Rs 1 crore from an investor.
  • Pooling other people's money to invest without SEBI registration is not allowed.
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A law firm's question-by-question guide to forming a fund under SEBI's AIF rules: the categories, Rs 20 crore minimum corpus per scheme, Rs 1 crore minimum per investor (Rs 25 lakh for employees and directors), the manager's continuing interest of the lower of 2.5% or Rs 5 crore, trust structures, compliance, and the GIFT City option.

PE and VC fund formation in India: AIF legal FAQ guide

From ksandk.com by King Stubb & Kasiva Guide

  • VC funds usually register as Category I; hedge funds and PIPE funds as Category III.
  • The sponsor or manager must keep the lower of 2.5% of corpus or Rs 5 crore in the fund.
  • Consider GIFT City IFSC if your investors are mostly overseas.
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Where an Alternative Investment Fund, portfolio manager or investment adviser applies to SEBI for registration and files afterwards.

SEBI intermediary registration portal

From siportal.sebi.gov.in by Securities and Exchange Board of India Official portal

  • Register here before you take a rupee of anyone else's money.
  • Keep your private placement memorandum ready; SEBI reviews it with the application.
  • Use the same portal for ongoing filings once registered.
Open siportal.sebi.gov.in →
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SEBI's own data on commitments raised and investments made by AIFs, by category. It shows the scale of the market a new fund manager is entering.

Alternative Investment Funds: statistics (SEBI)

From sebi.gov.in by Securities and Exchange Board of India Data

  • See how much each category raises before you pick yours.
  • Track commitments against investments made to judge how fast funds deploy.
  • Use it in your pitch to anchor investors.
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The regulator for GIFT City's international financial services centre, which registers fund management entities and funds aimed largely at overseas investors.

International Financial Services Centres Authority (IFSCA)

From ifsca.gov.in by IFSCA Official site

  • Look at a GIFT City fund if most of your money will come from abroad.
  • Fund managers in GIFT City register with IFSCA, not SEBI.
  • Read IFSCA's fund management regulations before choosing between the two.
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