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Fast-forwarding Public & Private InvIT Listings – Commodities/Derivatives/Stock Exchanges

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The Securities and Exchange Board of India (SEBI) via their
circulars dated April 28, 2022 (Public InvIT Circular) and June 24,
2022 (Private InvIT Circular), have trimmed down the timelines for
listing the units of an infrastructure investment trust (InvIT)
pursuant to a public and private offering, respectively, to 6
working days.

Prior to these circulars and pursuant to the SEBI InvIT
Regulations, 2014, an InvIT was required to list its publicly and
privately offered units within 12 working days and 30 working days,
respectively, from the date of the offer closure. Thereafter, SEBI
through the two circulars has endeavoured to provide a streamlined
shortened mechanism for ensuring that the investors (amongst
others) see the light at the end of the tunnel, i.e. the listing of
an InvIT’s units, much sooner.

Contours of a Public & Private InvIT listing



These developments will indeed require some coordination amongst
the stock exchanges and various intermediaries in order to ensure
that public as well as private InvITs are listed within 6 working
days from date of the offer closure. Consequently, we believe, that
SEBI had mandated this framework for public and private listed
InvITs, opening on or after June 1, 2022 and August 1, 2022,

This can also be seen as a smart move by the Indian regulator in
order to sync the timelines for listing a public or a private InvIT
with the listing of equity shares offered via a public offering,
both of which are monitored in SEBI by their distinct

Moreover, from a commercial perspective, this is indeed a
positive direction from SEBI to bolster its efforts in further
making InvITs an attractive fund-raising avenue in India for select
set of investors, especially during continuous volatility and
uncertainty stemming from domestic and global factors. It may be
worthwhile to recall that in case of equity public offerings in
India (IPOs), SEBI has been shrinking down on the timelines for IPO
listings from 22 working days to 12 working days and currently at 6
working days.

We anticipate that sometime in the future, the Indian securities
markets regulator will also inch towards reducing these timelines
to 3 working days to increase efficiency and maximize seamless
listing of a public and a private InvIT in India.

The content of this article is intended to provide a general
guide to the subject matter. Specialist advice should be sought
about your specific circumstances.

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