Description

SEBI adjudication order against Landmark Opportunity Fund and its officials for alleged violations of AIF regulations including breach of concentration limits.

Summary

SEBI has issued an adjudication order against Landmark Opportunity Fund (Category II AIF), its manager Landmark Capital Advisors Private Limited, and key managerial personnel Mr. Ashish Joshi for alleged violations of AIF regulations. The violations include breach of concentration limits and non-compliance with code of conduct provisions during the examination period from April 1, 2022 to March 31, 2023.

Key Points

  • Landmark Opportunity Fund is a Category II AIF registered with SEBI (Registration No. IN/AIF2/13-14/0068)
  • The fund launched Landmark Return Multiplier Fund with corpus of Rs. 82.89 crores and 67 investors
  • PPM Audit Report for FY 2022-23 highlighted adverse observations on breach of concentration limits
  • Three entities charged: the AIF, its manager, and key managerial personnel
  • Violations relate to AIF Regulations 15(1)(c), 20(1), 20(2), and 20(5) and code of conduct provisions
  • Fund is a close-ended scheme with tenure ending March 31, 2026

Regulatory Changes

No new regulatory changes introduced. This is an enforcement action under existing AIF Regulations, 2012.

Compliance Requirements

  • AIFs must adhere to concentration limits as specified in regulations
  • Compliance with code of conduct provisions in Fourth Schedule of AIF Regulations
  • Regular audit and reporting requirements for AIFs
  • Key managerial personnel accountability for regulatory compliance

Important Dates

  • Examination period: April 1, 2022 to March 31, 2023
  • Fund initial close: August 31, 2018
  • Fund final close: March 31, 2021
  • Fund end date: March 31, 2026
  • Current adjudicating officer appointed: April 21, 2025

Impact Assessment

This enforcement action reinforces SEBI’s focus on AIF compliance, particularly concentration limit adherence. It serves as a reminder for fund managers and key personnel about their regulatory obligations. The action may impact the fund’s operations and investor confidence, while setting a precedent for similar violations in the AIF industry.

Impact Justification

Enforcement action against AIF for regulatory violations, relevant for fund management industry compliance