SEBI Update: Regulator proposes detailed disclosures regarding Analyst Meets, Investor Meets and Conference Call and maintenance of its records

• Primary Advisory Market Committee (PMAC) of SEBI in its meeting held  in July, 2020 discussed the report prepared by its sub-group on disclosures pertaining to analyst meets, investor meets and conference calls. 

• SEBI in its latest meeting held in November, 2020 discussed above report. It is pertinent to note that the sub-group comprised of 10 industry veterans as members and headed by Shri Keki Mistry (Vice-chairman and CEO of HDFC Limited).

• The Report proposed following sweeping amendments in disclosures, by listed entity, relating to analyst meets, investor meets and conference calls, which can be classified into two broad categories, as follows:

1. Disclosure on Immediate Basis i.e. compliances Post-earnings conference call/ Quarterly Call and Maintenance of Records:

• After the post-earnings conference call/quarterly call, audio/video recordings of the same shall upload on its website and file with respective stock exchanges immediately, before the next trading day or within twenty-four hours from the occurrence of event or information (whichever is earlier), as required under the Reg. 30 of SEBI Listing Regulations, 2015.

• Listed companies shall within five working days of such call, upload written transcripts on its website and file with respective stock exchanges. Written transcripts of such call shall be available for a period of atleast eight years on its website, in addition to the details disseminated on respective stock exchanges. 

• Listed companies, on its discretion, allowed to decide whether such calls open to everyone to attend or limit to existing shareholders. 

     2. Disclosure on Quarterly basis and Maintenance of Records:

• Listed companies shall disclose no. of one-to-one meetings with select investors in its quarterly Corporate Governance Report submitted to stock exchanges along with affirmation that no Unpublished Price Sensitive Information was shared by any official of the company in such meetings. 

• It shall maintain a record of all such one-to-one meetings, for a period of atleast eight years.

• However, it was recommended  that  the  aforementioned amendments should be  made applicable in a phased manner. In addition, requirements shall be initially recommendatory for a period of 1 year and mandatory thereafter for all listed companies.

∆ SEBI sought public comments or the views of various stakeholders, in the following format as prescribed in document: 

- Name of the person/ entity

- Sr. no. 

- Recommendation in the report to which the comment pertains 

- Comment 

- Rationale for the comment Revisions to the recommendations, if any

- Public comment or views of stakeholders in above format may be sent by email to consultationcmd2@sebi.gov.in or by post to the address latest by December 21, 2020: 

General Manager, Compliance and Monitoring Division – II, 

Corporation Finance Department, SEBI Bhavan, Plot No. C4-A, "G" Block, 

Bandra Kurla Complex, Bandra (East), Mumbai - 400051

SEBI Consultation Paper