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Published on 2 July 2025

SEBI Allows Liquid Mutual Funds as Deposit Options for Advisers and Analysts

SEBI’s Mutual Fund Move: A Simpler, Smarter Compliance Route for Investment Advisers and Research Analysts

If you're an Investment Adviser (IA) or Research Analyst (RA) in India, here's some regulatory news that might finally make your life a little easier. In a welcome shift, SEBI has approved the use of liquid and overnight mutual fund units as a valid alternative to bank fixed deposits (FDs) for meeting mandatory deposit requirements.

It might sound like a small procedural tweak—but for the thousands of professionals navigating India’s advisory and research ecosystem, it’s a change that brings real relief.

What’s the Old Problem?

Let’s be honest—complying with SEBI’s deposit mandate hasn’t been easy. Up until now, IAs and RAs had to park their deposit as a bank fixed deposit, lien-marked in favour of SEBI or its designated supervisory body. In theory, this offered the regulator security.

But in practice? It created more problems than it solved.

Different banks, different rules: Some bank branches demanded extra documentation, others had never even heard of lien-marking for SEBI compliance. The result? Endless back-and-forth, missed deadlines, and frustrated professionals.

Tedious paperwork: Opening and lien-marking a bank FD still feels like a 2005 process in 2025—offline, opaque, and painfully slow.

So, What’s SEBI Done Differently Now?

In a reform approved at its June 2025 board meeting, SEBI has added a new, modern alternative: You can now use units of liquid mutual funds or overnight funds—lien-marked in SEBI’s favour—to meet your deposit obligations.

Here’s what makes this such a practical fix:

Digital, Demat-Ready Compliance

These mutual fund units can be held in Statement of Account (SoA) or demat form. That means no running around to bank branches, no piles of physical paperwork, and no chasing branch managers. The entire process can be done digitally—and tracked in real time.

Safe, Liquid, Low-Volatility Instruments

Liquid and overnight funds are not high-risk. They offer stable returns, daily liquidity, and low market volatility—exactly the kind of vehicle you’d want for regulatory deposits. SEBI’s move reflects that modern reality.

Annual Check-Ins, Not Constant Hassles

SEBI will review the value of these mutual fund deposits once a year. If the value falls short—due to either market movement or an increase in client numbers—you simply top it up with additional units. No panic. No penalty. Just a straightforward adjustment.

One-Year Lien Minimum

To ensure security, the mutual fund units must be lien-marked for at least one year. This still gives SEBI full control, while letting professionals meet compliance in a much more flexible and digitally-native way.

How Did This Change Come About?

Back in May 2025, SEBI floated a consultation paper—and the response from the advisory industry was overwhelmingly positive.

Industry feedback pointed to:

  • Operational difficulties with bank FDs
  • Digital compatibility of mutual fund units
  • The equal security they provide, since the lien sits with SEBI or the ASB
  • A smoother on-ramp for new entrants trying to set up shop

SEBI clearly listened—and acted.

This Isn’t a Standalone Reform

This move is part of a broader trend in how SEBI is modernising compliance for financial professionals. Over the past year, the regulator has:

  • Dropped the post-grad requirement (now a graduate degree is enough)
  • Scrapped the prior experience clause
  • Switched from net worth to deposit-based models
  • Allowed advance fee collection for up to 12 months

The message is clear: SEBI wants to reduce friction, lower the entry barrier, and build a larger, more diverse base of regulated IAs and RAs—without compromising investor protection.

A Quick Example

Let’s say you’re a new Investment Adviser starting out with fewer than 150 clients. Under SEBI norms, you need to maintain a ₹5 lakh deposit. Now, instead of locking this amount in a bank FD, you can invest it in a liquid mutual fund, mark a lien in SEBI’s favour, and go fully digital from day one.

No bank branch visits. No offline headaches. Full compliance, with more financial flexibility.

Final Word: A Win-Win for the Ecosystem

SEBI’s move to accept liquid and overnight mutual fund units as security deposits is more than a procedural fix—it’s a smart, low-risk step toward digital-first compliance. It keeps investor protection intact while making it easier for good professionals to enter and stay in the market.

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