Alternative

Investment
Funds
-A regulatory perspective

Financial Advisory Lab at:

Mumbai

| Thane | Baroda

www.shbathiya.com

This research paper on Alternate Investment Funds (AIF) is prepared and compiled by the
members of Financial Advisory Lab at S. H. Bathiya & Associates for knowledge
dissemination and learning to the Firm members and its clients. This research paper
provides general information and guidance on AIF which aims in creating a structure where
regulatory framework is available for all shades of private pool of capital or investment
vehicle so that such funds are channelized in the desired space in a regulated manner
without posing systematic risk. The research paper should be read in conjunction with the
Disclaimer as forming a part of this research paper. For any further details and clarification
on the research paper:
Write us at fal@shbathiya.com or
Call us at 022 4355 8000 / 4275 8000
Date of research paper: 21st September, 2012
Research Team:
Mr. Jatin A. Thakkar
Mr. Ankit Davda
Mr. Kunal Jhaveri
Mr. Jatin N. Thakkar
Mr. Hitesh Sharma
Ms. Shraddha Mehta
Mentor Partners:
Mr. Umesh Lakhani
Mr. Anand Bathiya

Alternate Investment Funds

Contents
INTRODUCTION

SALIENT FEATURES

REGISTRATION PROCESS

SPONSOR & MANAGER

INVESTMENT CONDITIONS AND RESTRICTIONS

GENERAL OBLIGATIONS

12

CONFLICT OF INTEREST

12

TRANSPARENCY

12

VALUATION

13

MAINTENANCE OF RECORDS
WINDING UP

13

14

TAX PASS THROUGH FOR AIFS

CONCLUSION

15

15

ABBREVIATIONS & DISCLAIMER:

15

Alternate Investment Funds

 INTRODUCTION
An investment fund is an organisation, entity or firm that pools funds from a large
number of small investors. By aggregating the funds of retail investors into a
specific investment, in line with the objectives of the investors, an investment
company gives individual investors access to a wider range of securities and also
achieving economies of scale by bringing down the trading cost. Private bankers,
trust managers or other advisers often direct some or all of the assets of their
clients towards fund investments.
With a view to extending the perimeter of regulation to unregulated funds and
ensuring systemic stability, increasing market efficiency, encouraging formation of
new capital and protecting the interest of investors, the Securities & Exchange
Board of India (SEBI or Board) approved proposal to frame SEBI (Alternative
Investment Funds) Regulations, 2012 and on May 21, 2012, notified the SEBI
(Alternative Investment Funds) Regulations, 2012 (AIF Regulations). The AIF
Regulations would be a replacement to the SEBI (Venture Capital Funds)
Regulations, 1996 (VCF Regulations)
SEBI issued the AIF Regulations in order to create a structure where regulatory
framework is available for all shades of private pool of capital or investment
vehicles so as to channelize and better regulate the funds where institutions or HNIs
invest. The need for the framework arises in order to detect fraud, unfair trade
practices and minimize conflicts of interest through disclosures, incentive
structures, reporting requirements and legal agreements.

SALIENT FEATURES
Scope of the Regulations and applicability to existing funds
All funds whether operating as Private Equity Funds, Real Estate Funds, Hedge
Funds, Venture Capital Funds, Pooled vehicles, etc. must register with SEBI under
the AIF Regulations.
The VCF Regulations shall be repealed. However, existing VCFs shall continue to be
regulated by the VCF Regulations till the existing fund or scheme managed by the
fund is wound up. Existing VCFs, however, shall not raise any fresh funds. Such
VCFs may also seek re-registration under AIF regulations subject to approval of
66.67% of their investors by value.
Existing funds not registered under the VCF Regulations will not be allowed to float
any new scheme without registration under AIF Regulations.
Existing funds not registered under the VCF Regulations which seek registration but
are not able to comply with all provisions of AIF Regulations may seek exemption
from the SEBI from strict compliance with the AIF Regulations.
There is no minimum exemption based on the number of investors which means
even if money is held on behalf of two or more persons, to be invested, that will
amount to AIF.

Alternate Investment Funds

Similarly, there is no exemption with respect to the size of investment, which means
that irrespective of how small a fund is, it will still require to follow the AIF
Regulations.
B. Categories of funds
The AIF Regulations seek to cover all types of funds broadly under 3 categories. An
application can be made to SEBI for registration as an AIF under one of the following
3 categories:Category I AIF: AIFs with positive spill-over effects on the economy, for which
certain incentives or concessions might be considered by SEBI or GOI or other
regulators in India; and which shall include VCFs, SME Funds, Social Venture Funds
and Infrastructure Funds. It includes those AIFs that invest in sectors which are
considered socially and economically relevant for the country.
Category II AIF: This forms the residual category, funds which cannot be classified
either as Category I or III will be classified as Category II.

Category III AIF: It covers AIFs including hedge funds that are considered to have
negative externalities such as worsening systemic risk through leverage or complex
trading strategies. The regulatory restrictions and conditions are more stringent for
this category of AIF.
C. Other salient features
AIF Regulations will be applicable to all pooled investment vehicles other than
Mutual Funds, Collective Investment Schemes, Family Trusts, ESOP Trusts, Employee
Welfare Trusts, and holding companies, funds managed by Asset Reconstruction
Companies, Securitisation Trust or any such pool of funds which are directly
regulated by any other regulator in India. In that sense, the AIF Regulations are the
residuary regulations which can possibly apply to large number of funding vehicles.
Category I and II AIFs shall be close-ended and shall have a minimum
tenure of 3 years. However, Category III AIF may either be close-ended or
open-ended.
Schemes may be launched under an AIF subject to filing of Information
Memorandum (IM) with the SEBI along with applicable fees.
Units of close ended schemes of AIF may be listed on stock exchange subject to a
minimum tradable lot of Rs. One Crore. However, AIF shall not raise funds through
stock exchange mechanism.
AIFs shall not be permitted to invest more than 25% of the investible funds in one
Investee Company. Further, AIFs shall not invest in associate companies except if it
obtains requisite approval from the investors.

Alternate Investment Funds

All AIFs shall have Qualified Institutional Buyer (QIB) status as per SEBI
(Issue of Capital and Disclosure Requirements) Regulations, 2009.
AIF Regulations provide for transparency and disclosures and mechanism for
avoidance of conflict of interest.
AIFs shall provide, on an annual basis, the investors with financial information of
portfolio companies as also material risks and how these are managed.
SEBI shall have right to inspect or investigate the AIFs and to issue necessary
directions.

Key Comparison between VCF Regulations & AIF Regulations: In terms of

Investment Conditions and Restrictions regulations

VCF Regulations
AIF Regulations

Minimum Investment per Investor

5 lakh Rupees
1 Crore Rupees

Minimum Corpus of Fund

venture capital fund
Each scheme launched or fund set up by
a VCF shall have firm commitment from
the investors for contribution of an
amount of at least 5 crores Rupees
before the start of operations by the

Each scheme of the AIF shall have

corpus of at least 20 crore Rupees;

Minimum investment for Employees or Directors of the manager of the

fund

No such provision
20 Lakh Rupees

Minimum investment for manager of the fund

For Category I and II:

Lower of a) 5 Crore Rupees or b) 2.5% of

No such provision
Corpus

For Category III:

Lower of a) 10 Crore Rupees or b) 5% of Corpus

Maximum Number of Investors per Scheme

No such provision
1000 Investors

Ceiling on Investment in one Investee Company

25% of Corpus
For Category I and II: 25% of Corpus

For Category III: 10% of Corpus

Alternate Investment Funds

Investment in Associate

An AIF can invest in associates subject

to
A VCF is not allowed to invest in its Associate
approval of 75% of investors by value of their

investment.

Additional Conditions for AIF

a) Co-investment in an investee company by a

Manager or Sponsor shall not be on terms

more favourable than those offered to the AIF;

No such provision
b) Un-invested portion of the corpus may be

invested in liquid mutual funds or bank

deposits or other liquid assets of higher quality

such as Treasury bills, CBLOs, etc.

till

deployment of funds as per objective.

Key Definitions:
Change in definition of Venture Capital Fund:

As defined in VCF Regulations:

Venture Capital Fund means a fund established in the form of a trust or a
company including a body corporate and registered under these regulation which
has a dedicated pool of capital;
raised in a manner specified in the regulations; and
invests in accordance with the regulations;
As defined in AIF Regulations:
Venture Capital Fund means an AIF which invests primarily in unlisted
securities of start-ups, emerging or early-stage venture capital undertakings mainly
involved in new products, new services, technology or intellectual property right
based activities or a new business model;
Additional definitions in AIF regulations:

Alternative Investment Fund means any fund established or incorporated in

India in the form of a trust or a company or a limited liability partnership or a body
corporate whichis a privately pooled investment vehicle which collects funds from investors,
whether Indian or foreign, for investing it in accordance with a defined investment
policy for the benefit of its investors; and

Alternate Investment Funds

is not covered under the Securities and Exchange Board of India (Mutual Funds)
Regulations, 1996, Securities and Exchange Board of India (Collective Investment
Schemes) Regulations, 1999 or any other regulations of the Board to regulate fund
management activities.
Corpus means the total amount of funds committed by investors to the
Alternative Investment Fund by way of a written contract or any such document as
on a particular date.
Social Venture means a trust, society or company or venture capital
undertaking or limited liability partnership formed with the purpose of promoting
social welfare or solving social problems or providing social benefits and includes,Public charitable trust registered with Charity Commissioner;
Societies registered for charitable purposes or for promotion of science, literature,
or fine arts;
Company registered under Section 25 of the Companies Act, 1956;
Micro finance institutions.

Sponsor means any person or persons who set up the AIF and includes promoter
in case of a company and designated partner in case of a limited liability
partnership.

REGISTRATION PROCESS
All AIFs are required to mandatorily obtain Certificate of registration from SEBI to act
as AIF.
Transitory provisions: Time period of 6 months allowed for all existing funds such
as Private Equity Funds, Real Estate Funds, Hedge Funds, etc. to register with SEBI
under the AIFs Regulations. SEBI has discretion to extend this period by another 6
months in special cases.
All the existing funds falling within the definition of AIF and not registered with SEBI:
cannot raise fresh monies other than commitment already made till the
registration is granted;
cannot float any new scheme without registration under AIF Regulations.
However, existing schemes floated by such funds before 21 May 2012, shall be
allowed to continue to be governed till maturity by the contractual terms, except
that no rollover / extension or raising of any fresh funds shall be allowed; and

Alternate Investment Funds

- seeking registration with SEBI but are not able to comply with all provisions of AIF
Regulations may seek exemption from SEBI from strict compliance with the AIFs
Regulations.
Existing SEBI registered VCFs:
continue to be regulated by the VCF Regulations till the existing fund or scheme
managed by the fund is wound up;
cannot increase the targeted corpus of the fund or scheme as it stands on 21 May
2012;
cannot launch any new scheme after 21 May 2012; and
may seek re-registration under AIF Regulations subject to approval of 2/3 of their
investors by value. The SEBI VCF Regulations are repealed w.e.f. 21 May 2012.
The certificate of registration, once granted, shall be valid till the concerned AIF is
wound up.

SPONSOR & MANAGER

Manager as defined in the AIF Regulations means any person or entity who is
appointed by the Alternative Investment Fund to manage its investments by
whatever name called and may also be same as the sponsor of the Fund.
Following are some of the key aspects with respect to role / function of Sponsor &
Manager under the AIFs Regulations:

Sponsor or Manager shall have the continuing interest in AIF at least of the
following amount in the form of investment in AIF and such interest shall not be
through waiver of management fees:
For Category I and II AIF
For Category III AIF
Lower of:
Lower of:
2.5% of the corpus or INR 50
5% of the corpus or INR 100
million
million
Sponsor or Manager shall disclose their investment in the AIF to the investors of AIF.
Sponsor or Manager shall appoint a custodian registered with SEBI for safekeeping
of securities if the corpus of AIF is more than INR 5 billion. However, for Category III
AIF, irrespective of the size of the corpus, appointment of custodian is mandatory.
Sponsor and Manager of AIF shall act in a fiduciary capacity towards its investors
and shall disclose to the investors, all conflicts of interests as and when they arise
or seem likely to arise.

Alternate Investment Funds

Any fees ascribed to the Sponsor or Manager and any fees charged to AIF or any
investee company by an associate of the Sponsor or Manager shall be disclosed
periodically to the investor.

INVESTMENT CONDITIONS AND RESTRICTIONS

Fund Raising Mechanism:
General Conditions:
AIF may raise funds subject to following conditions:
Funds may be raised from Indian as well as foreign investors including NRIs
through issue of units
AIF may form various schemes to raise funds and such schemes shall have
minimum corpus of Rupees 20 crores
Minimum amount of investment from an investor should be at least Rs. 1 crore
Exception: Minimum amount to be Rs. 25 lakhs instead of Rs. 1 crore in case of
investment by employees or directors of AIF or of Manager of the AIF
Manager or Sponsor to have continuing interest in the AIF of at least 2.5% of the
corpus or Rs. 5 crore whichever is less and such interest should be in the form of
direct investment by subscribing to units of the AIF and should not be through
waiver of management fees
Exception: In case of Category III AIF, continuing interest should be at least 5% of
the corpus of Rs. 10 Crore viz. doubles the normal requirements.
Maximum investors for each scheme is restricted to 1000; alternatively an AIF may
have more than 1000 investors if it has more than one scheme
Funds can be raised only through private placement basis from domestic as well as
international investors however no public issues allowed. This draws a borderline
between AIF CIS and MF which can invite public subscriptions.
Fund Raising Procedure:
As mentioned earlier, AIF may raise funds by launching various schemes
For each scheme, AIF needs to file placement memorandum or information
memorandum (IM) with SEBI at least 30 days prior to launching the scheme along
with requisite fees
Exception: No fees to be paid for launching first scheme.

Alternate Investment Funds

IM should contain all material information about the AIF and the Manager and should
contain minimum disclosures as provided in Regulation 11(2) to help investors to take
informed investment decision.
SEBI may give comments on IM within 30 days of filing and AIF shall be duty bound to
incorporate such comments in IM prior to launch of scheme.
Tenure and Listing:
Category wise tenure and listing requirements of funds or schemes are as follows:
Particulars
AIF

Category I
Category II
Category III

Close Ended/
Close Ended only
Close Ended only
Open or Close Ended
Open Ended

Tenure
Minimum 3 years
Minimum 3 years
No Restriction

Listing

may be listed subject

may be listed subject
Close ended schemes

to minimum tradable
to minimum tradable
can be
listed
subject

lot of Rs. 1 Crore

lot of Rs. 1 Crore
to minimum
tradable

lot of Rs. 1 Crore

Buy-back of
Not allowed
Not allowed
Allowed
for
Open
Units

ended funds

Note:
Category I and II AIF shall determine the tenure of fund/scheme at the time of application
for launch of fund subject to minimum of 3 years as stated above. Hence maximum tenure
not defined.
Extension of tenure of close ended funds allowed if approved by the unit holders holding
2/3rd of the value of total investments in AIF.
If extension of tenure not approved, then AIF shall fully liquidate the fund within 1 year of
expiration of the fund tenure or extended tenure.
B. Investment by AIFs:
1. General Conditions:
AIF may invest raised funds subject to the following general conditions:

Investment in securities of companies incorporated outside India permitted subject to

guidelines/conditions specified by RBI and SEBI.
Investment in a Company by a Manager or Sponsor shall not be on favourable terms than
those offered to AIF.

Alternate Investment Funds

10

Maximum investment in an investee company shall be restricted to 25% of the corpus in

case of Category I and II AIF AND in case of Category III AIF it is 10% of the corpus.
Investment in associates not allowed.
Exception: Possible if such investment decision is approved by 75% of the unit
holders in terms of value of their investment in AIF.
Till deployment as per investment objective, the un-invested portion of the corpus may be
invested in liquid mutual funds or bank deposits or other liquid assets of higher quality.
AIF may act as Nominated Investor in case of SME companies public offerings whereby it
can enter into an agreement with merchant bankers to subscribe to the issue in case of
under-subscription.
Such other conditions as the SEBI may prescribe from time to time.
Specific conditions for each Category of AIF:
In addition to general conditions (as mentioned above) applicable to all categories of AIF,
there are some specific conditions which are detailed below:
Particulars

AIF

Category I

Category II

Category III

Primary
Investee companies,
Unlisted
investee
Securities of
listed
Investments
venture
capital
companies

or unlisted investee

undertaking etc.

companies
or

derivatives
or

complex
or

structured products
Investment in other
Can invest in units of
Can invest
in
units
Can
invest in
units
AIF
Category
I
AIF
of
of Category I and II
of Category I and II

same sub-category
AIF

AIF

Borrowing/Leverage
Shall
not
borrow
Same as Category I
Can
borrow
or

funds
or
engage
in

engage in leverage

leverage
except
for
However,
it
may
subject to

meeting
temporary
engage in
hedging
- consent from the

funding

subject
to
investors and

requirements for
guidelines
specified
- maximum limit, as

- not more than 30

by SEBI.

may be specified by

days, and

SEBI

- on not more than 4

occasions
in
a year

Specified details to

and

be disclosed to the

- not more than 10%

investors and SEBI

of the corpus

Note:

Alternate Investment Funds

11

Investee Company means any company, special purpose vehicle or limited

liability partnership or body corporate in which an AIF makes an investment.
Under Category I AIF, there are 4 sub-category funds viz. 1) Venture Capital
Funds 2) SME Fund 3) Social Venture Fund and 4) Infrastructure Fund and for
each category there are certain investment conditions and restrictions intended to
serve the objective which each funds nomenclature denotes.

GENERAL OBLIGATIONS
AIFs to regularly review policies and procedures and their implementation to ensure
continued appropriateness.
The Sponsor or Manager of AIF shall appoint a custodian registered with the Board
for safekeeping of securities if the corpus of the AIF is more than Rs 500 crore
(Category III AIF shall appoint such custodian irrespective of the size of corpus)
All AIF shall inform the Board in case of any change in the Sponsor,
Manager or designated partners or any other material change.
Prior approval of the Board to be obtained in case of change in control of
the AIF, Sponsor or Manager.
Books of accounts of AIF shall be audited annually by a qualified auditor.

CONFLICT OF INTEREST
The Sponsor and Manager shall act in a fiduciary capacity and shall disclose all
conflicts of interests to the investors.
Manager shall establish and implement written policies and procedures to identify,
monitor and appropriately mitigate conflicts of interest.
Managers and Sponsors shall abide by high level principles on avoidance of conflicts
of interest with associated persons, as may be specified by the Board from time to
time.

TRANSPARENCY
AIFs shall ensure transparency and disclosure of information to investors on the
following:
Periodical disclosure of financial, risk management, operational, portfolio, and
transactional information regarding fund investments.
Any fees ascribed to the Manager or Sponsor; and any fees charged to the
AIF or any investee company by an associate of the Manager or Sponsor.
Any inquiries / legal actions by legal or regulatory bodies in any jurisdiction

Alternate Investment Funds

12

Any material liability arising during the AIFs tenure.

Any breach of a provision of the placement memorandum or agreement
made with the investor or any other fund documents.
Change in control of the Sponsor or Manager or Investee Company
Reports to investors at least on an annual basis, within 180 days from the year end,
including the following information, as may be applicable:
Financial information of investee companies
Material risks and how they are managed which may include concentration risk at
fund level; foreign exchange risk at fund level; leverage risk at fund and investee
company levels; realization risk (i.e. change in exit environment) at fund and
investee company levels; strategy risk (i.e. change in or divergence from business
strategy) at investee company level; reputation risk at investee company level;
extra-financial risks, including environmental, social and corporate governance
risks, at fund and investee company level.
Category III AIF shall provide quarterly reports to investors in respect of the above
information within 60 days of end of the quarter:
Any significant change in the key investment team
Information for systemic risk purposes (including the identification, analysis and
mitigation of systemic risks) to be provided when required by the Board.

VALUATION
AIF shall provide to investors a description of its valuation procedure and of the
methodology for valuing assets.
Category I and Category II AIFs shall undertake valuation of their investments, at
least once in every six months; by an independent valuer (such period may be
enhanced to one year on approval of at least 75% of the investors by value of their
investment in AIF.)
Category III AIFs shall ensure that calculation of the net asset value (NAV) is
independent from the fund management function and such NAV shall be disclosed
to the investors on quarterly basis for close ended Funds and on monthly basis for
open ended funds.

MAINTENANCE OF RECORDS
the assets under the scheme/fund;
valuation policies and practices;
investment strategies;
particulars of investors and their contribution;

Alternate Investment Funds

13

Rationale for investments made.

These records shall be maintained for a period of 5 years after the winding up of the
fund.

WINDING UP
A. An AIF set up as a trust shall be wound up:
B.
when the tenure of the AIF or all schemes launched by AIF, is over; or
if it is the opinion of the trustees or the trustee company, as the case may be, that
the AIF be wound up in the interests of investors in the units; or
if 75% of the investors by value of their investment in AIF pass a resolution at a
meeting of unit holders that the AIF be wound up; or
if the Board so directs in the interests of investors.
An AIF set up as a LLP shall be wound up in accordance with the provisions of The
Limited Liability Partnership Act, 2008 on occurrence of events mentioned above in
(1)
(a) or (c) or (d)
AIF set up as a company shall be wound up in accordance with the provisions of the
Companies Act, 1956 (1 of 1956).
AIF set up as a body corporate shall be wound up in accordance with the
provisions of the statute under which it is constituted.
The trustees or trustee company or the Board of Directors or designated partners of
AIF, as the case maybe, shall intimate the Board and investors of the circumstances
leading to the winding up.
On and from the date of such intimation no further investments shall be
made on behalf of AIF.
Within 1 year from the date of intimation the assets shall be liquidated, and the
proceeds accruing to investors shall be distributed to them after satisfying all
liabilities.
Subject to the conditions, if any, contained in the placement memorandum or
contribution agreement or subscription agreement, as the case may be, in specie
distribution of assets of AIF, shall be made at any time, including on winding up as
per the preference of investors, after obtaining approval of at least 75% of the
investors by value of their investment in AIF.
Upon winding up of AIF, the certificate of registration shall be surrendered to the
Board.

Alternate Investment Funds

14

 TAX PASS THROUGH FOR AIFS

The SEBI press release states that SEBI will work with the central
government to obtain pass through treatment for AIFs for tax purposes.
This is an interesting proposal because under the existing income tax
laws, only VCFs registered with SEBI are eligible for this tax treatment.
However, as per explanation under Regulation 3 (4) (a), only Category I
funds shall be treated as venture capital funds for the purpose of Section
10 (23FB) of the Income-tax Act, 1961. Therefore, if the central
government agrees to provide tax pass through treatment to all AIFs,
which will be a very encouraging move and would further facilitate fund
investments in general.
The AIF Regulations now seemingly curtail that benefit and limit it only to
Category I AIFs. If there is significant delay in passing the necessary
amendments to the Income Tax Act to effect pass through status for all
AIFs (and similar kind of thing has happened before with LLPs, for
example, when it took more than a year to get clarity on the tax status of
LLPs), that could adversely affect investment strategies and structuring of
AIFs in the interim.

CONCLUSION
India as a nation has been a witness to plenty of varied investment schemes in
different shades of grey. The AIF Regulations are a step in the right direction as they
bring transparency around the issue of regulation of private pools of capital that are
raised locally for deployment by various types of investment funds. It will help in
monitoring the unregulated funds; encourage formation of new capital and investor
protection. It will enable several variety of funds that were not possible in the past
like social capital funds, real estate funds, hedge funds etc. AIF Regulations possess
several features like investment strategy, disclosure of periodic information to
investors, valuation procedure, audit of fund, dispute resolution, winding up of funds
etc. These comprehensive Regulations would surely bring greater clarity to the
market and the investors and its comprehensive nature will bring several
investment entities under the watchdog that were hitherto unregulated by SEBI.
Also, the investments in AIF can be used as a tool to reduce investment risk through
diversification thereby helping the investors in the market. The classification
between the three categories is also a socially-desirable change.

ABBREVIATIONS & DISCLAIMER:

Sr. No.
Abbreviations

1
AIF
Alternative Investment Funds

2
AIFs Regulations
SEBI (Alternative Investment Funds) Regulations, 2012

3
INR
Indian Rupees

4
LLP
Limited Liability Partnership

5
CIS Scheme
SEBI (Collective Investment Scheme), Regulations 1999
Alternate Investment Funds

15

6
ESOP
Employee Stock Option Plan
7
SME
Small, Micro and Medium Enterprise
8
QIB
Qualified Institutional Buyers
9
CBLO
Collaterized Borrowing and Lending Obligation
10
NAV
Net Asset Value
11
NRI
Non Resident Indian
12
VCF
Venture Capital Fund
13
VCF Regulations
SEBI (Venture Capital Funds) Regulations, 1996
14
SEBI
Securities & Exchange Board of India

15
HNIs
High Net-worth Individuals/Investors
16
GoI
Government of India
17
MF
Mutual Fund

Alternate Investment Funds

16

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Alternate Investment Funds

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