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Response to SEBI's Consultation Paper on Pre-Filing Offer Document in case of IPO
Response to SEBI's Consultation Paper on Pre-Filing Offer Document in case of IPO

June 27, 2022

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On June 6, 2022, NASSCOM made a submission to Securities Exchange Board of India (SEBI) in response to the Consulation Paper on Pre-Filing of Offer Document in case of an Initial Public Offering (IPO). In our submission, we welcomed the introduction of an alternate mechanism for regulatory review of offer document by permitting a confidential pre-filing of offer document. We noted that this will give the necessary protection to issuing companies contemplating an IPO from the disclosure of business sensitive information to competitors, without the certainty that the IPO would be executed.

Further, our submission sought clarity on whether SEBI would notify the issuer company to file the final Red Herring Prospectus (RHP), after taking note of the changes to the draft prospectus:

  • If yes, we recommended that a time should be specified within which SEBI shall take note of the changes and notify the issuer company to file for the final RHP.
  • If no, we recommended that it should be clarified that the issuer company can file the final RHP as soon as the draft proespectus has been submitted to SEBI.

We highlgihted that the timing of the public issueis a critical aspect for companies going for an IPO. Any uncertainty in the process and delayscan have multiple impacts, for example, change in market conditions, redundancy of the feedback from potential institutional investorsetc. These can in turn impactthe pricing and estimating the issue size. Therefore, for each step of the process, need for SEBI approvals and timelines should be clearly specified.

For more information, kindly write to garima@nasscom.in


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Garima Prakash
Manager, Public Policy and Government Affairs

Reach out to me for all things policy about e-commerce, international trade, export controls, start-ups and fintech

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