SEBI Informal Guidance in the matter of Innovative Tech Park Limited

Innovative Tech Park Limited requested for informal guidance from SEBI, seeking clarification inter alia with respect to interpretation of Regulation 78(6) of the erstwhile SEBI (Issue of Capital and Disclosure Requirements) Regulations, 2009 (‘Old ICDR Regulations’), for the purpose of calculating the lock-in period, where convertible securities (in this case, warrants) are not listed on any recognized stock exchange. SEBI was of the view that in case of an issue of convertible securities allotted on preferential basis which are not listed on any stock exchange, the entire pre-preferential holding is required to be locked-in from the ‘relevant date’ upto a period of six months from the date of allotment of the securities, instead of the date of trading approval (which is relevant for listed securities only) and the relevant date in such a case would be calculated from 30 days prior to the date of the shareholders approval in accordance with Regulation 71 of the Old ICDR Regulations.