This is with reference to our Notice No. 20200104-1 dated January 04, 2020, 20210824-12 dated August 24, 2021 & 20210929-15 dated September 29, 2021 with respect to Uniform Implementation of KYC requirements.
As per recent GOI notification on Prevention of Money-laundering (Maintenance of Records) Amendment Rules, 2023, there are changes in UBO and NPO requirements.
All Companies or Trusts/Societies must submit the fresh UBO declaration as per the format shared by RTAs to confirm that new UBO information is refreshed and updated in MF/RTA database accordingly. As informed by the RTAs,
- New UBO declaration form should be submitted fresh by all Companies/Trusts/Societies even if there is no change in UBO details as some of the values are made mandatory for various other reporting and due diligence requirements in RTA systems.
- For new folio creation, new UBO declaration is mandatory. For all the existing investors – Optional but request to submit the updated form.
- NPO declaration mandatory for all financial transactions in new and existing folios.
- wherever the UBO ownership does not fall as per the prescribed threshold mentioned in the attached Annexure IV, Senior Managing Official (SMO) details are also to be provided.
In view of the above and as per the confirmation received from RTA/AMCs, the below mentioned additional details are added in the existing FATCA/UBO format, in manual, bulk and API formats :
- UBO_EXCH
- UBO_ISIN
- UBO_REL_LI
- UBO_Categ
- UBO_PEP_FL
- UBO_Email
- UBO_SMO_De
- NPO_FORM
- NPO_DCL
- NPO_RGNO
Apart from the NPO declaration provided in the FATCA entry, members are also required to provide the NPO Declaration form along with the UBO declaration form wherever applicable. NPO Declaration shall form part of the UBO Declaration, and no separate upload is required.
For existing UCCs registered in the below mentioned tax status, members are requested to provide the revised FATCA details alongwith the UBO Declaration form.
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Tax Status
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PAN 4th Character
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AOP
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T
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SOCIETY
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T
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TRUST
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T
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For existing UCCs which are registered in tax status other than the ones mentioned above, NPO Declaration flag shall be updated as ‘N’ by default.
Members are requested to provide the revised FATCA and UBO Declaration with respect to changes mentioned above to avoid any rejection.
Detailed process note and the go live date shall be shared separately.
All members using third party vendor solutions and/or in-house developed trading application are hereby requested to take note of the above and arrange to initiate necessary development at their end.
For any query on the BSE StAR MF platform, you can reach us through our service centre on 022-45720450 & 022-45720650 on business days between 8.00 a.m. to 7.00 p.m. You can also raise your queries on our CRS portal:- https://bsecrs.bseindia.com
Please find attached the following :
Annexure I – Fatca Bulk Upload Structure
Annexure II – UBO Declaration Form
Annexure III – NPO Declaration Form
Annexure IV – FAQs received from RTAs
Ketan Jantre Zeeta Eustace
Chief General Manager – Mutual Funds Dy. General Manager – Mutual Funds
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