Annual Disclosure under Reg 8(3) of SAST

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CS Ekta

Company Secretary

230 Points Posted on 14 April 2010

Dear All,

Reg 8(2) provides of SEBI (SAST) provides that the promoter or every person having control over a company have to give annual disclosure of his shareholding.

Kindly confirm that the term "Promoter" will also cover "Promoters Group" i.e. do the persons falling under promoters' group also need to give the disclosure?

Replies (3)

Ankur Garg

Company Secretary and Compliance Officer

75761 Points Posted on 14 April 2010

On a safer side I’d suggest you to consider promoter group also for the purpose of regulation 8(3). However the same is not desired specifically. But the true motive of these kinds of regulations is to include promoter group along with other powerful parties.

Further am following the same practice and you are free to follow your own practice.

Best Regards

CS Ekta

Company Secretary

230 Points Posted on 14 April 2010

Hi Ankur,

lets consider that the persons in the promoter group also falls under the category of person acting in concert..

The promoters will be required to give disclosure of the PAC holdings. That way the shareholdings of the promoters group get also covered for the purpose of Reg 8(3).

Considering this only the promoters will give the disclosure under Reg 8(2) both in respect of his holdings and the person acting in concert with him

What do you suggest?