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.