SEBI CIRCULAR SEBI/HO/IMD/IMD-I POD-1/P/CIR/2024/105 DATED AUG 07, 2024
Specialised Investment Funds (SIF) Disclosures
New Asset Class Framework, Strategy Mechanics & Statutory Risk Disclosures
New Asset Class (2024)
Min. ₹10 Lakhs
Long-Short & Derivatives
ARN-367223
MANDATORY STATUTORY RISK WARNING — SIF IS A NEW, COMPLEX ASSET CLASS
Specialised Investment Funds (SIF) are a new SEBI-introduced asset class (August 2024) positioned between Mutual Funds and PMS with a mandatory minimum investment of ₹10 Lakhs (Rupees Ten Lakhs) per transaction. SIF permits complex strategies including Long-Short Equity, Inverse ETFs, and Derivative leverage not permitted in regular Mutual Funds. SIF carries significantly higher risk and has a limited historical track record. Please read the Scheme Information Document (SID) carefully before investing.
About This Statutory SIF Disclosure
FINWISDOM FINANCIAL SERVICES PVT LTD (ARN-367223) is empanelled as an AMFI-registered distributor to offer Specialised Investment Fund (SIF) strategies. This disclosure is published in accordance with the SEBI Circular dated August 7, 2024 and AMFI guidelines to ensure investors fully understand the strategy mechanics, minimum ticket thresholds, short-selling risks, and suitability criteria governing this emerging asset class.
1. What is a Specialised Investment Fund (SIF)?
A Specialised Investment Fund (SIF) is a new regulatory asset class introduced by SEBI in August 2024, designed to bridge the product gap between traditional Mutual Funds (low ticket, long-only) and Portfolio Management Services (₹50 Lakhs minimum). SIF enables sophisticated retail and affluent investors to access institutional-grade strategies within a pooled, well-regulated framework.
New Asset Class (2024)
Introduced under SEBI Master Circular dated August 7, 2024 to curb unregistered tip providers and offer regulated alpha.
₹10 Lakhs Minimum
Mandatory minimum ticket size of ₹10 Lakhs per investor per transaction (subsequent in multiples of ₹1 Lakh).
Long-Short & Derivatives
Authorised to take unhedged short positions and utilize derivative leverage beyond traditional mutual fund limits.
AMC Infrastructure
Offered directly by established AMFI-registered Asset Management Companies (AMCs) with pooled unit ownership.
SEBI Riskometer
Mandatory monthly SEBI Riskometer tagging and dynamic portfolio disclosure for investor transparency.
Strict Governance
Regulated under the SEBI (Mutual Funds) Regulations, 1996 with separate risk management safeguards.
2. Where SIF Fits in the Indian Investment Hierarchy
Mutual Funds (Retail)
Min. ₹500 SIP | Long-Only Strategies
Diversified long-only equity and debt funds. Broad retail participation with daily liquidity and strict derivative hedging caps.
SIF (Affluent / Sophisticated)
Min. ₹10 Lakhs | Long-Short & Inverse
Bridges the gap between MFs and PMS. Pooled units with complex alpha, short-selling, and tactical derivatives.
PMS (High Net Worth)
Min. ₹50 Lakhs | Direct Demat Ownership
Customized, segregated Demat portfolios holding 15–30 concentrated stocks with discretionary mandate.
AIF (Ultra HNI)
Min. ₹1 Crore | 3–7 Yr Illiquid Lock-in
Privately pooled unlisted equity, private credit, and venture capital for sophisticated institutions and family offices.
3. Permitted SIF Strategy Types
Long-Short Equity
Takes long positions in undervalued stocks while shorting overvalued companies to generate market-neutral alpha.
Inverse & Bear Hedging
Strategies designed to deliver positive payoffs during market downturns via inverse index positions or short derivatives.
Derivatives-Heavy Alpha
Utilizes complex multi-leg futures and options structures to capitalize on volatility spikes and arbitrage spreads.
Sectoral Long-Short
Long on anticipated outperforming sectors and short on lagging sectors within a systematic pairwise model.
Structured Credit
Invests in higher-yielding debt instruments and structured corporate notes not eligible in traditional debt MFs.
Multi-Asset Quantitative
Systematic computer-driven allocation shifting dynamically between equities, debt, gold, and derivatives.
4. Investor Eligibility & Suitability Framework
Eligible & Suitable Investors
- Affluent Individuals & High Net Worth Investors (HNIs)
- Resident Indians, NRIs, HUFs, Corporates & Trusts
- Minimum ₹10 Lakhs investable surplus per transaction
- Documented 'High' or 'Very High' risk profile
- Investment time horizon of 3 to 5+ years
- Investors seeking hedging or absolute returns during corrections
NOT Suitable For
- Retail investors with investable surplus under ₹10 Lakhs
- Conservative, Moderate, or Capital Preservation investors
- First-time mutual fund investors unfamiliar with derivatives
- Funds required for emergency reserves or near-term liquidity
- Investors expecting steady or linear return trajectories
5. SIF vs Mutual Fund vs PMS vs AIF Comparison
| Feature / Metric |
Mutual Fund |
SIF (New Asset Class) |
PMS |
AIF |
| Minimum Investment |
₹500 |
₹10 Lakhs |
₹50 Lakhs |
₹1 Crore |
| Strategy Style |
Long-Only / Simple |
Long-Short & Inverse |
Concentrated Direct |
Private Equity / Hedge |
| Asset Ownership |
Units in pooled fund |
Units in pooled fund |
Direct Demat stocks |
Units in private trust |
| Short Selling Permitted |
No |
Yes (Regulated) |
Yes |
Yes |
| Derivatives Leverage |
Hedging only |
Active / Enhanced Alpha |
Allowed |
Allowed (Cat III) |
| SEBI Riskometer |
Mandatory |
Mandatory |
Not Applicable |
Not Applicable |
| Historical Track Record |
Long (30+ Years) |
New (2024 Launch) |
Medium (15+ Years) |
Medium (12+ Years) |
| Governing Document |
SID / KIM |
SIF SID / KIM |
Disclosure Document |
Private Placement Memo |
6. Key Risk Disclosures — Per SEBI SIF Framework
New Product Track Record
As SIF is a brand new asset class launched in 2024, strategies lack extensive historical track records across multi-year market cycles.
Short-Selling Risk
Unhedged short positions can generate losses if the underlying security rallies significantly against the manager's thesis.
Derivative Leverage Drag
Futures and options introduce time-decay costs (theta), margin volatility, and potential roll-over drag during choppy markets.
Counterparty Risk
Over-the-counter and exchange-traded derivative contracts carry clearing corporation and counterparty settlement exposures.
Strategy Complexity
Sophisticated multi-strategy models are difficult for non-institutional investors to monitor without ongoing professional guidance.
Market Volatility
Net Asset Value (NAV) can experience significant fluctuation during unexpected macroeconomic or regulatory regime shifts.
7. Official Regulatory Framework & Circulars
SEBI SIF Master Circular
SEBI/HO/IMD/IMD-I POD-1/P/CIR/2024/105 dated August 7, 2024 formally introducing the New Asset Class framework.
SEBI Circular Aug 2024 ↗
AMFI SIF Guidelines
AMFI Master Circular 2026 establishing distributor qualification standards and operational onboarding guidelines.
AMFI SIF Guidelines ↗
SEBI SCORES Portal
Centralized platform to lodge and track complaints against SEBI-registered SIF asset managers and distributors.
scores.sebi.gov.in ↗
SMART ODR Platform
Online conciliation and arbitration platform for rapid dispute resolution in the Indian securities market.
smartodr.in ↗
8. Pre-Investment SIF Checklist for Investors
- Read the complete Scheme Information Document (SID) and Key Information Memorandum (KIM) of the SIF strategy
- Verify the AMFI SIF distributor registration credentials at amfiindia.com
- Confirm your risk profile is documented as 'High' or 'Very High' prior to order processing
- Ensure the ₹10 Lakhs minimum is allocated from long-term investable surplus — not emergency funds
- Understand the underlying mechanics — Long-Short, Inverse, or Derivatives exposure limits
- Verify that any exit load or lock-in terms do not conflict with your capital liquidity needs
- Maintain SIF as a tactical allocation (max 10%–15%) alongside core mutual fund portfolios
9. FINWISDOM's Role as SIF Distributor
FINWISDOM FINANCIAL SERVICES PVT LTD (ARN-367223) acts strictly as an AMFI-registered distributor for Specialised Investment Fund offerings. Asset management and portfolio trading decisions are executed independently by the respective SEBI-registered Asset Management Companies (AMCs). FINWISDOM receives distributor trail remuneration from the AMC as part of the scheme's statutory Total Expense Ratio (TER).
Request SIF Strategy Documents & SIDs
SIF is a new and sophisticated asset class. For detailed strategy breakdowns, scheme offer documents (SID), or to schedule a consultation before committing capital:
Devansh S Mehta | Director & GRO
FINWISDOM FINANCIAL SERVICES PVT LTD (ARN-367223)
Email:
devansh@finwisdom.co.in | Phone:
9920217997 |
Grievance Portal ↗
Effective: August 2026 | Last Updated: August 2026 | FINWISDOM FINANCIAL SERVICES PVT LTD | ARN-367223 | Regulatory basis: SEBI Circular SEBI/HO/IMD/IMD-I POD-1/P/CIR/2024/105 dated Aug 07, 2024