DEPUTY GENERAL MANAGER ALTERNATIVE INVESTMENT FUND AND FOREIGN PORTFOLIO INVESTOR DEPARTMENT DIVISION OF POLI… — THE SECURITIES AND EXCHANGE BOARD OF INDIA ACT, 1992

DEPUTY GENERAL MANAGER ALTERNATIVE INVESTMENT FUND AND FOREIGN PORTFOLIO INVESTOR DEPARTMENT DIVISION OF POLICY AND DEVELOPMENT SEBI/HO/AFD/PoD/OW/2023/50721 December 15 , 2023 ASKWA Multi Opportunities Fund [SEBI Registration No. IN/AIF3/20-21/0829] ASK Wealth Advisors Private Limited Birla Aurora, 16 Level, Office Floor 9, Dr. Annie Besant Road, Worli, Mumbai - 400030 Dear Sir, KIND ATTN: Mr. Amit Gupta Sub: Request for Informal Guidance by way of interpretative letter under the provisions of Securities and Exchange Board of India (Informal Guidance) Scheme 2003 relating to Regulation 18 of Securities and Exchange Board of India (Alternative Investment Funds) Regulations, 2012 Ref: Your letters dated September 10, 2023 and letter dated November 30, 2023 from Amicorp Trustees (India) Private Limited In the context of your letter under reference , you have , inter alia, a, stated that ASKWA Multi Opportunities Fund ( " the Fund " ) is a SEBI registered Category III Alternative Investment Fund ( " AIF " ) bearing registration no. IN/AIF3/20-21/0829 and have sought an interpretive letter under the Securities and Exchange Board of India (Informal Guidance) Scheme 2003 from SEBI in respect of permissibility to make investments in the units of Exchange Traded Fund ( " ETF " ) for earning regular income by the Fund. 2. Our Comments The submissions made in your letter have been considered and without necessarily agreeing with your analysis, our view on the issues raised in your letter are as under: 2.1. In terms of Regulation 18 of the Securities and Exchange Board of India (Alternative Investment Funds) Regulations, 2012 ("AIF Regulations"), Category III AIFs may , inter alia , - invest in securities of listed or unlisted investee companies, derivatives, units of other AIFs o