NISM Series XIX-B · Chapter 7: Category III AIF Investment Strategies and Due Diligence Process
L1 · FoundationFoundation — The four equity-market strategies
How a Category III AIF states its investment strategy and why a capital commitment is indirect consent to it; the Long-only strategy with its hedging through index put options and the Fund FGH example; the Long-short strategy, the 130/30 and 120/20 structures, and why net market exposure equals 100 per cent; the Market-neutral strategy with the Fund PQC beta computation showing weighted average betas of zero and why the index options left the portfolio beta only close to zero; Directional and Short-bias strategies with Fund LMN and Fund TGR, and how Dedicated-Long and Dedicated-Short differ from Long-short; and the two-times NAV leverage restriction that binds them all.
22 min read · Worth 8% of the paper · Written from pages 240–266 of the official NISM workbook · Updated 18 September 2026
How a Category III AIF actually positions itself
1. What "investment strategy" means here
⚠️ "Category III AIFs may take LEVERAGE, SHORT POSITIONS AND DERIVATIVE POSITIONS, in order to GENERATE ABSOLUTE RETURNS FOR INVESTORS OVER THE MEDIUM AND LONG TERM. Hence, THESE FUNDS GENERALLY DO NOT INVEST FOR THE PURPOSE OF INTRA-DAY TRADING."
⚠️ "Speculative investments in equities MAY BE MADE, IF THE INVESTMENT MANAGER CAN PREDICT SHORT-TERM PROFIT GENERATION FOR THE FUND."
That last sentence carries real weight. It is why a change of strategy later needs a two-thirds vote by value — the original consent was given by subscribing, and a change withdraws the basis of it.
2. Long-only Equity Strategy
⚠️ "Investment managers make stock selection using a TOP-DOWN OR BOTTOM-UP FUNDAMENTAL APPROACH, with an aim to invest in companies having PREDICTABLE, SCALABLE AND QUALITY BUSINESS MODELS", analysing "HISTORICAL DATA... OF DIVIDEND PAY-OUTS, RETURN ON CAPITAL EMPLOYED AND OTHER IMPORTANT FINANCIAL PARAMETERS."
2.1 Hedging within a long-only strategy
⚠️ "In order to protect the fund against losses, a prudent investment manager MAY TAKE A 'HEDGING POSITION' TO MINIMIZE THE MARKET RISK DUE TO DECREASE IN VALUE OF A STOCK. Hedging positions can be taken by TAKING OPPOSITE POSITIONS, i.e. A SELL POSITION, IN A FUTURES OR OPTIONS CONTRACT... A sell position can be taken through A 'SHORT' POSITION IN A FUTURES CONTRACT OR BY BUYING A 'PUT' OPTION."
2.2 Fund FGH — the worked example
⚠️ Long positions as on 1 April 2023:
| Stock | ⚠️ Quantity | ⚠️ Market Price | ⚠️ Total Value |
|---|---|---|---|
| ⚠️ Company A (large-cap) | ⚠️ 1,00,000 | ⚠️ Rs 320 | ⚠️ Rs 3,20,00,000 |
| ⚠️ Company B (large-cap) | ⚠️ 10,00,000 | ⚠️ Rs 50 | ⚠️ Rs 5,00,00,000 |
| ⚠️ Company C (large-cap) | ⚠️ 3,00,000 | ⚠️ Rs 250 | ⚠️ Rs 7,50,00,000 |
| ⚠️ Company D (large-cap) | ⚠️ 4,00,000 | ⚠️ Rs 500 | ⚠️ Rs 20,00,00,000 |
| ⚠️ Company E (mid-cap) | ⚠️ 1,00,000 | ⚠️ Rs 500 | ⚠️ Rs 5,00,00,000 |
| ⚠️ Company F (mid-cap) | ⚠️ 1,00,000 | ⚠️ Rs 930 | ⚠️ Rs 9,30,00,000 |
⚠️ Hedge: NIFTY50 Put Options bought — strike 9,000.00 · lot size 450 contracts · 150 lots · price Rs 500.00 · total exposure Rs 3,37,50,000, expiry 31 December 2023.
⚠️ "Futures and Options in a broad-based market index such as NIFTY50 or S&P BSE SENSEX CAN PARTIALLY HEDGE the inherent market risk. OPTIONS CAN PROVE TO BE MORE EFFICIENT AS COMPARED TO FUTURES, FOR THE PURPOSE OF HEDGING. The most suitable hedging strategy can be to BUY A PUT OPTION ON THE NIFTY50 OR S&P BSE SENSEX... AND KEEP ROLLING THE OPTION CONTRACTS FORWARD."
3. Long-Short Equity Strategy
⚠️ "The short positions are usually undertaken by INVESTING THROUGH THE OPTIONS AND FUTURES CONTRACTS on the underlying assets."
⚠️ The contrast with Long-only: "the investment manager CAN TAKE A SHORT POSITION IN STOCKS, EVEN AT THE TIME OF INVESTMENTS IN STOCKS. This provides GREATER FLEXIBILITY... AND CAN CREATE A NATURAL HEDGE against total market risk... This is possible if BOTH SHORT POSITIONS AND LONG POSITIONS ARE TAKEN IN STOCKS WHICH HAVE THE SAME CHARACTERISTICS OR IN THE SAME INDUSTRY."
3.1 Fund TCR — the worked example
| Stock | ⚠️ Exposure | ⚠️ Quantity | ⚠️ Price | ⚠️ Total Value |
|---|---|---|---|---|
| ⚠️ Company B (large-cap) | ⚠️ Buy | ⚠️ 10,00,000 | ⚠️ Rs 50 | ⚠️ Rs 5,00,00,000 |
| ⚠️ Company C (large-cap) | ⚠️ Sell | ⚠️ 3,00,000 | ⚠️ Rs 250 | ⚠️ Rs 7,50,00,000 |
| ⚠️ Company D (large-cap) | ⚠️ Buy | ⚠️ 4,00,000 | ⚠️ Rs 500 | ⚠️ Rs 20,00,00,000 |
| ⚠️ Company E (mid-cap) | ⚠️ Buy | ⚠️ 1,00,000 | ⚠️ Rs 500 | ⚠️ Rs 5,00,00,000 |
| ⚠️ Company F (mid-cap) | ⚠️ Sell | ⚠️ 1,00,000 | ⚠️ Rs 930 | ⚠️ Rs 9,30,00,000 |
⚠️ Plus NIFTY50 Put Options bought — strike 9,000.00, 50 lots of 450, price Rs 500.00, total exposure Rs 1,12,50,000.
Note why. The buy is Rs 5 crore and the sell Rs 9.30 crore, in different companies. A long and a short of unequal size in unequal names is not a hedge — it is two separate bets that happen to point in opposite directions.
4. Market-Neutral Strategy
⚠️ The cost of neutrality: "the investment manager HAS LOW FLEXIBILITY TO TRADE FREELY IN VARIOUS STOCKS, BY MARKET-CAPITALIZATION, INDUSTRY OR SECTOR."
4.1 Fund PQC — the beta computation
| Stock | ⚠️ Exposure | ⚠️ Quantity | ⚠️ Beta | ⚠️ Price | ⚠️ Total Value |
|---|---|---|---|---|---|
| ⚠️ Company B | ⚠️ Buy | ⚠️ 10,00,000 | ⚠️ 0.40 | ⚠️ Rs 50 | ⚠️ Rs 5,00,00,000 |
| ⚠️ Company C | ⚠️ Buy | ⚠️ 2,00,000 | ⚠️ 2.00 | ⚠️ Rs 250 | ⚠️ Rs 5,00,00,000 |
| ⚠️ Company D | ⚠️ Sell | ⚠️ 2,00,000 | ⚠️ 1.20 | ⚠️ Rs 500 | ⚠️ (Rs 10,00,00,000) |
| ⚠️ Large-cap net exposure | ⚠️ 0.00 | ||||
| ⚠️ Company E | ⚠️ Buy | ⚠️ 1,00,000 | ⚠️ 1.50 | ⚠️ Rs 500 | ⚠️ Rs 5,00,00,000 |
| ⚠️ Company F | ⚠️ Sell | ⚠️ 1,00,000 | ⚠️ 1.50 | ⚠️ Rs 500 | ⚠️ (Rs 5,00,00,000) |
| ⚠️ Mid-cap net exposure | ⚠️ 0.00 |
⚠️ The weighted average beta:
| Stock | ⚠️ Beta [A] | ⚠️ Value | ⚠️ Weight [B] | ⚠️ Weighted Beta [A×B] |
|---|---|---|---|---|
| ⚠️ Company B | ⚠️ 0.40 | ⚠️ Rs 5,00,00,000 | ⚠️ 0.25 | ⚠️ 0.10 |
| ⚠️ Company C | ⚠️ 2.00 | ⚠️ Rs 5,00,00,000 | ⚠️ 0.25 | ⚠️ 0.50 |
| ⚠️ Company D | ⚠️ 1.20 | ⚠️ (Rs 10,00,00,000) | ⚠️ 0.50 | ⚠️ (0.60) |
| ⚠️ Large-cap total | ⚠️ NIL | ⚠️ 0.00 | ||
| ⚠️ Company E | ⚠️ 1.50 | ⚠️ Rs 5,00,00,000 | ⚠️ 0.50 | ⚠️ 0.75 |
| ⚠️ Company F | ⚠️ 1.50 | ⚠️ (Rs 5,00,00,000) | ⚠️ 0.50 | ⚠️ (0.75) |
| ⚠️ Mid-cap total | ⚠️ NIL | ⚠️ 0.00 |
⚠️ "Weights are computed by DIVIDING THE INVESTMENT IN THE COMPANY, BY THE TOTAL INVESTMENTS IN THE SECTOR-SPECIFIC STOCKS."
4.2 Why the beta is not exactly zero
⚠️ The fund also held a NIFTY50 CALL at strike 10,000 (30 lots of 750) and a NIFTY50 PUT at strike 9,500 (50 lots of 450), both expiring 31 December 2023 — "TOTAL EXPOSURE TAKEN IN TERMS OF NUMBER OF CONTRACTS IS THE SAME IN CALL OPTIONS AND PUT OPTIONS, i.e. 22,500 CONTRACTS."
⚠️ And the risk that neutrality does not remove: "the exposures in individual stocks BEAR RISK, UNRELATED TO THE MARKET RISK. THIS IS ALSO KNOWN AS UNSYSTEMATIC RISK. The individual price movements of each stock CAN SIGNIFICANTLY CHANGE THE PORTFOLIO MIX, AS THE INVESTMENT MANAGER WILL AGAIN NEED TO BRING THE PORTFOLIO BETA TO ZERO."
5. Directional and Short-bias Strategies
⚠️ The four distinctions:
| Comparison | ⚠️ Difference |
|---|---|
| ⚠️ Short-bias vs Long-only | ⚠️ "the fund maintains A NET LONG EXPOSURE IN A LONG-ONLY STRATEGY AND NET SHORT EXPOSURE IN A SHORT-BIAS STRATEGY" |
| ⚠️ Short-bias vs Long-short | ⚠️ "in a Long-short Strategy, the investment manager MAY MAINTAIN A NET LONG OR A NET SHORT EXPOSURE, as compared to THE NET SHORT EXPOSURE TO BE MAINTAINED IN A SHORT-BIAS STRATEGY" |
| ⚠️ The 130/30 fund | ⚠️ "In a typical '130/30' long-short strategy, THE INVESTMENT MANAGER MAINTAINS A NET LONG POSITION, UP TO 100 PERCENT OF THE TOTAL INVESTABLE FUNDS" |
| ⚠️ Dedicated-Long vs Long-short | ⚠️ "The investment manager MAY TAKE BOTH LONG AND SHORT POSITIONS IN THE LONG-SHORT STRATEGY, AS COMPARED TO EXCLUSIVELY TAKING LONG POSITIONS IN A DEDICATED-LONG STRATEGY" |
⚠️ "A Directional Strategy and a Short-bias Strategy MAY BE VOLATILE AND RISKY, DURING MAJOR MACRO-ECONOMIC UPTURNS AS WELL AS DOWNTURNS, depending on the net exposure."
5.1 Fund LMN and Fund TGR
⚠️ Fund LMN — large-cap: Company C Buy Rs 5,00,00,000, Company D Sell (Rs 10,00,00,000), net (Rs 5,00,00,000). Mid-cap: Company E Buy Rs 5,00,00,000, Company F Sell (Rs 7,50,00,000), net (Rs 2,50,00,000).
⚠️ Fund TGR — large-cap: Company H Buy Rs 35,00,00,000, Company I Buy Rs 30,00,00,000, net Rs 65,00,00,000; plus NIFTY50 CALL options at strikes 10,000 (30 lots) and 9,500 (50 lots).
Note the giveaway. Fund TGR bought calls, not puts. A long-only fund that hedges buys puts; a dedicated-long directional fund that is betting on the market buys calls. The instrument tells you the intention.
Think of it like this
The farmer who buys crop insurance but still grows the crop
A cotton farmer in Vidarbha plants his whole field with cotton. He is long cotton and nothing else. But he also pays a premium for a crop insurance policy that pays out if the harvest fails.
He has not sold his cotton. He has not planted anything he expects to fail. He has simply bought protection.
That is a long-only Category III AIF buying NIFTY50 put options. "The most suitable hedging strategy can be to BUY A PUT OPTION ON THE NIFTY50 OR S&P BSE SENSEX... AND KEEP ROLLING THE OPTION CONTRACTS FORWARD."
And like insurance, it must be renewed and must match what it covers: "the hedging positions, type of contracts and indices used SHOULD BE CHANGED ON A REGULAR BASIS, TO REPLICATE THE CHARACTERISTICS OF THE INVESTMENTS IN THE FUND PORTFOLIO."
A policy covering wheat does not protect a cotton crop.
The 130/30 shopkeeper
A cloth merchant has Rs 100 of his own money. He buys Rs 130 of stock, funding the extra Rs 30 by taking goods on approval from a supplier and selling them immediately — goods he will have to return later at whatever the price then is.
His own exposure to the cloth market is still Rs 100, not Rs 130. That is what a 130/30 fund does: "the investment manager takes 130 PERCENT LONG POSITIONS AND 30 PERCENT SHORT POSITIONS, AS A PERCENTAGE OF THE TOTAL INVESTABLE FUNDS. THIS ENSURES THAT THE NET EXPOSURE TO THE MARKET IS EQUAL TO 100 PERCENT."
He has not increased his market bet. He has increased his number of opinions — 130 rupees of "this will rise" and 30 rupees of "this will fall", within the same Rs 100 of net risk.
That is the whole appeal, and the whole danger. More opinions means more chances to be right, and more chances to be wrong.
The see-saw with two children of the same weight
Two children of exactly equal weight sit at exactly equal distances on a see-saw. It is level. If both of them jump slightly, it stays level.
That is a market-neutral portfolio: "managers TAKE EQUAL AMOUNT OF LONG AND SHORT EXPOSURES IN EQUITIES", so the beta is zero, or close to zero.
But watch what happens if one child eats a big lunch. The balance is lost, and someone must move. Exactly so: "the individual price movements of each stock CAN SIGNIFICANTLY CHANGE THE PORTFOLIO MIX, AS THE INVESTMENT MANAGER WILL AGAIN NEED TO BRING THE PORTFOLIO BETA TO ZERO."
And a level see-saw is not a safe see-saw. "A ZERO BETA DOES NOT ENSURE THAT THE STRATEGY IS NOT VOLATILE OR RISKY." Both children can still fall off.
The umbrella with a hole in the middle
Fund PQC bought a NIFTY50 call at 10,000 and a NIFTY50 put at 9,500. Above 10,000, the call protects; below 9,500, the put protects.
Between 9,500 and 10,000 — nothing. "The Fund has NEUTRALIZED THE EXPOSURE TO NIFTY50, FOR ANY VALUE ABOVE 10,000 OR ANY VALUE BELOW 9,500. However, THE FUND WILL BE EXPOSED TO MARKET RISK, IF THE NIFTY50 VALUE... IS BETWEEN 9500 AND 10000."
It is an umbrella with a hole in the middle. It works in a storm from either direction, and leaves you wet in ordinary rain.
That gap is why "the positions taken in the derivatives contracts are NOT Market-Neutral" — the two strike prices are different, so the two legs do not cancel.
Betting on the horse and on the race being run
In a merger arbitrage, the fund makes two different bets at once.
The first is on the target company: the acquirer must pay a premium over the unaffected share price, because "such Target Company's board of directors is ONLY LIKELY TO APPROVE THE ACQUISITION... IF THE ACQUISITION PRICE IS SIGNIFICANTLY HIGHER THAN THE CURRENT EQUITY SHARE PRICE." So the fund goes long the target, to capture that spread.
The second is on the acquirer, and it is usually a short, for two reasons the workbook names. UNCERTAINTY IN DEAL-COMPLETION — the deal still needs board, regulatory and shareholder approvals, and "if at any stage, the deal is not approved or is delayed, there is a high risk that the deal can fail." And PREMIUM TO TARGET COMPANY — "if the premium to be paid... is OVER-VALUED, there is an inherent risk that THE EQUITY SHARE PRICE OF THE ACQUIRING COMPANY WILL FALL."
Betting the horse will win is one thing. Betting the race will actually be run is another.
The wholesale rate for the first customer at the shop
A new sweet shop sells its first day's stock cheap to a caterer who takes a large quantity and takes the risk of an untested shop. Later customers pay the counter price.
That is a Pre-IPO placement. "Pre-IPO shares are offered to institutional investors AT A DISCOUNT TO THE ISSUE PRICE of equity securities in the IPO, DUE TO SUFFICIENTLY LARGE AMOUNT OF INVESTMENTS MADE AND RISK TAKEN BY SUCH INSTITUTIONAL INVESTORS."
Fund PPI bought 2,50,000 shares at Rs 120 when the IPO price was Rs 130 — a discount of Rs 10 a share, or 7.70 per cent, for a 16.67 per cent stake.
But the caterer cannot resell the sweets the same evening. "The shares held by the Fund are SUBJECT TO LOCK-IN for a period as prescribed by SEBI (ICDR) Regulations FROM THE DATE OF LISTING OF SHARES PURSUANT TO THE IPO."
Cheaper, but not free to move.
Key terms in this chapter
- 130/30 Fund
- A long-short fund holding 130 per cent long positions and 30 per cent short positions as a percentage of total investable funds, so that net market exposure equals 100 per cent. The 120/20 variant works identically.
- Acquiring Company
- In a merger or acquisition, the company buying the shares of another company. It typically pays a premium over the target's unaffected share price to win board approval.
- Activist Strategy
- A strategy making a significant investment in an investee company to benefit from a material corporate event, large enough to participate in the management process, taking a private equity and long-term oriented approach.
- Borrowing Fee
- The fee a fund incurs to borrow securities in order to take short positions or make a short sale. It is an additional cost, alongside the dividends foregone on shares held short.
- Business Continuity Plan
- A documented plan setting out the course of action following material key-person events or natural disasters, accompanied by disaster recovery plans covering trade execution technology and client data.
- Convergence Trade
- A relative-value trade purchasing relatively under-valued bonds and selling relatively over-valued bonds, as LTCM did in European, Japanese and USA sovereign bond markets. The tiny spreads involved required very high leverage.
- Conversion Ratio
- The number of equity shares issuable for each convertible security on exercise. It is fairly priced when the market value of the shares receivable equals the face value of the bond.
- Convertible Arbitrage Strategy
- A long-short strategy taking a long position in a company's convertible securities and a simultaneous short position in its equity shares, to profit from mispricing of the conversion ratio independent of stock price movements.
- Convertible Security
- A hybrid debt instrument or preference share giving its holder the option to convert into equity shares at a pre-determined date and conversion ratio based on a pre-determined equity price.
- Dedicated-Long Strategy
- A strategy taking long positions exclusively, unlike a long-short strategy where the manager may take both. A dedicated-short strategy correspondingly takes only sell positions.
- Directional Strategy
- A strategy taking either a net long or a net short position based on a call on the direction of the overall market. It is the opposite of market-neutral, since the manager does not aim at a portfolio beta of zero.
- Event-driven Strategy
- A strategy taking positions in the equities or derivatives of one target company following a material corporate event such as debt restructuring, a merger, an acquisition, a spin-off or a change in management.
- Global-Macro Strategy
- A strategy taking long and short positions across currencies, fixed income securities, equities, commodities, real assets and interest rate derivatives, selecting on macro-economic trends rather than company fundamentals, across multiple markets and geographies.
- Hedging Position
- An opposite, sell-side position taken to minimise market risk from a fall in the value of a stock — a short futures position or a bought put option on an underlying with similar characteristics to the portfolio holding.
- International Financial Services Centre (IFSC)
- A centre governed by the SEBI (International Financial Services Centre) Guidelines, 2015, such as Gujarat International Finance Tec-City. A Category III AIF based there may delegate the investment management and advisory function to a third-party investment advisor.
- Investment Due Diligence
- The process by which institutional investors analyse the financial performance and influencing factors of a Category III AIF, to verify the expected return and risk factors stated in the PPM and to identify red flags before committing capital.
- Key-Person Risk
- The risk that an adverse event such as the death, insanity, incapacity or immovability of the investment manager will significantly hamper the fund's operations, tested through on-site meetings with the whole team.
- Long-only Equity Strategy
- A strategy taking only buy positions in selected stocks at the time of investment, aiming at absolute returns over the medium to long term with a strong emphasis on capital preservation. Hedging is permitted through short futures or bought put options.
- Long-Short Equity Strategy
- A strategy going long under-priced stocks and short over-priced ones relative to the manager's fair valuation, with the aim of taking advantage of undervalued and overvalued opportunities.
- Long Term Capital Management (LTCM)
- The US fund founded by John Meriwether of Salomon Brothers that ran convergence trades in sovereign bond markets. By 1998 it held USD 5 billion of equity against over USD 125 billion of borrowings, a leverage ratio of 30:1, and collapsed after the Russian sovereign default, requiring a bailout of USD 3.65 billion.
- Maker-Checker Control
- A basic internal control, verified in due diligence alongside access controls, under which one person initiates and another verifies transactions or entries involving confidential client data.
- Manager Selection Process
- The screening and selection process by which an AIF appoints its investment manager. An informal process may indicate the fund is privately managed by the sponsor and manager without aligning investors' interests.
- Market-Neutral Strategy
- A strategy taking equal long and short exposures so the fund has net zero or neutral exposure to a sector, industry or market-capitalisation, giving a beta of zero or close to zero, with the aim of minimising systematic risk.
- Merger Arbitrage Strategy
- An event-driven strategy taking a long position in the target company's shares and a short or long position in the acquiring company's shares, to profit from the spread created by the acquisition premium and the conversion ratio.
- Pre-IPO Placement
- The process of allotting pre-IPO shares to certain institutional investors just before the date of the investee company's IPO.
- Pre-IPO Shares
- Shares with unique identification numbers issued to employees or institutional investors, including Category III AIFs, before shares are offered to the general public in an IPO, at a discount to the issue price and subject to a minimum lock-in from listing.
- Red Flag
- Any internal or external factor identified during screening that may materially impact the stated risk-return objective of an investment.
- Short-bias Strategy
- A type of directional strategy in which the manager takes both long and short positions but maintains a net short exposure to the broad market.
- Special Situations Strategy
- Another name for the activist strategy, covering a fund taking or increasing a stake in a company undergoing NCLT proceedings that is likely to be acquired by a larger company in the same industry.
- Target Company
- In a merger or acquisition, the company selling its shares or being merged into the acquiring company.
- Unsystematic Risk
- The risk borne by exposures in individual stocks that is unrelated to market risk. It survives market neutrality and forces the manager to rebalance as individual prices move.
Check you have understood it
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Create a free accountOriginal explanatory writing based on the official NISM workbook for Series XIX-B, which is published and copyrighted by NISM. Check figures against the current edition at nism.ac.in.