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The Original CHAUKIDAAR ,“TAKEOVER WATCHMAN” since 2007. CA. Arun Goenka* hands-on experience in the share market* deep knowledge of laws and account*one of the early players, pioneered an investment strategy in TAKEOVERS*The WIRC - of The Institute of Chartered Accountants of India, has honoured him with the ‘Recognition of CAs in Social Service’. * often invited by National business news; electronic and print media, for his views on SEBI related matters. * history of red-flagging 100+ cases to SEBI* contributes by giving inputs in drafting amendments to the regulation* Some of the suggestions reflected in subsequent regulatory changes: (a). In takeover of Cairn 3,750 Crores non-compete fees waived off and ultimately Removal of Non-compete fee in 2011 (b) November 2009 amending Regulation 11 (1). (c)Listing agreement baring promoters from voting on related party. (d) Disclosure of past performance by merchant bankers in case of IPO (e) SAST 2011 regulation 10(1)(h), (f) Counter Offer in case of Delisting (g) Interest payment to all in case of delays in Open Offers(05.06.20).

Wednesday, June 17, 2020

Shareholding pattern- disclosure should be made more relevant


Text of letter written to SEBI on  May 10, 2020 , Date of posting on the blog June 17, 2020
Suggestion for making the disclosure of shareholding pattern more relevant

Currently, the shareholding is disclosed as per  SEBI Circular No. CIR/CFD/CMD/13/2015 November 30, 2015. Table III - Statement showing shareholding pattern of the Public shareholder; Individuals – at point 3(a) states :
i. Individual shareholders holding nominal share capital up to Rs. 2 lakhs.
ii. Individual shareholders holding nominal share capital in excess of Rs. 2 lakhs

This has become absolutely irrelevant and serves no purpose. The market price of shares are really relevant. In case of TCS 2 lacs nominal value of shares will be valued at Rs. 37.8 Crores, in case of Nestle or Eicher motors etc. it will be around 3 crs. This certainly is not the intention.  It serves no purpose. The obvious objective is to find the number of small investors. In the Buy back regulation you have specified 2 lakhs worth of holding as on the record date will be categorised as small shareholders. The same definition should be extended here. A very small change is required to be done urgently.

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