DEPUTY GENERAL MANAGER — 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/2023/38073 September 13, 2023 Mr. Vineet Bagri CEO and Fund Manager, Prajana Advisors Private Limited, Investment Manager of Athena Alternative Investments Fund , 1101, Naman Centre, BKC, Bandra (East), Mumbai - 400051 Dear Sir, 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 ( " AIF Regulations") Ref: Your letter dated July 13, 2023 In the context of your letter under reference , you have , inter alia, a, stated that Athena Alternative Investments Trust is a SEBI registered Category III Alternative Investment Fund ( " AIF " ) bearing registration no. IN/AIF3/22-23/1166 and have sought an interpretive letter under the Securities and Exchange Board of India (Informal Guidance) Scheme 2003 from SEBI on the following query: Whether a Cat III AIF can invest in Mutual Funds on a permanent basis as a part of the multi asset portfolio? 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 AIF Regulations, Cat III AIFs may , inter alia , - invest in securities of listed or unlisted investee companies, derivatives, units of other AIFs or complex or structured products. deal in goods received in delivery against physical settlement of commodity derivatives. buy or sell credit default swaps in terms of the conditions as may be specified by the Boar