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Secondary SGL

The SGL facility an RBI-eligible entity offers to route its own constituents' government securities holdings, keeping separate sub-accounts for each investor while RBI sees only the consolidated balance.

In plain language

Not every investor in government securities is eligible to open an account directly with RBI. Something has to stand between them and RBI's own books. That something is Secondary SGL.

An entity that already qualifies for a Primary SGL account with RBI can also offer Secondary SGL to its own clients — the constituent investors who cannot open a Primary SGL account themselves.

How it works

From Chapter 11, section 11.4: there are two SGL facility types. Primary SGL is opened directly with RBI, used only for the account holder's own investments, and open only to entities meeting RBI's eligibility criteria. Secondary SGL routes the investments of clients who are not eligible to open a Primary SGL account directly. Any entity permitted to open a Primary SGL account may also offer Secondary SGL.

The Secondary SGL provider keeps a separate sub-account for each investor in its own books. Its Secondary SGL account with RBI, however, shows only the consolidated balance of all its account holders together — RBI does not see the individual investor-wise split. Depositories in India are separately permitted to maintain Constituent SGL accounts of investors through DPs, built on the same underlying idea.

A worked example

A public sector bank holds a Primary SGL account directly with RBI for its own treasury investments. It also offers Secondary SGL facility to 40 corporate clients who are not eligible for Primary SGL accounts themselves, keeping a separate sub-account for each of the 40 clients showing their individual G-Sec holdings.

RBI's own books, however, show only one consolidated Secondary SGL balance for the bank — say, Rs 120 crore in total across all 40 clients. RBI has no visibility into how that Rs 120 crore splits between the 40 individual constituents; only the bank's own records show that.

Why NISM asks about it

Chapter 11, section 11.4, introduces Primary and Secondary SGL together. Expect a question distinguishing Primary SGL (own investments only) from Secondary SGL (routes constituents' investments), and the fact that RBI sees only the consolidated Secondary SGL figure.

Common exam traps

  • Primary SGL is for the account holder's own investments only; Secondary SGL exists specifically to route constituents' investments.
  • RBI's books show only the consolidated Secondary SGL balance — the investor-wise split lives only in the Secondary SGL provider's own records.
  • Eligibility for Primary SGL is a precondition to also offering Secondary SGL, not an alternative to it.

Check yourself

  1. 1.An entity offers a Secondary SGL facility to investors who are not eligible for a Primary SGL account. How are the holdings maintained?

    1. a)Each investor gets his own SGL account directly with RBI
    2. b)The entity uses its Primary SGL account for both its own investments and its clients' holdings, with no sub-accounts
    3. c)The entity keeps a separate sub-account for each investor in its books, and the Secondary SGL account with RBI shows the consolidated balance of all account holders
    4. d)The investors' holdings are shown on physical certificates issued by the entity
    Show the answer

    Answer: (c) The entity keeps a separate sub-account for each investor in its books, and the Secondary SGL account with RBI shows the consolidated balance of all account holders

    The workbook: "Secondary SGL facility is to be used to keep accounts of the constituent investors. In other words, Secondary SGL is used to route investments of clients who are not eligible to directly open Primary SGL accounts. The entity which offers Secondary SGL facility, has to keep sub-accounts for each investor separately in its books; Secondary SGL account with RBI will show the consolidated balances of all account holders."

    • A describes a Primary SGL account, which is opened with the RBI directly, and only by entities meeting RBI's eligibility criteria.
    • B mixes the two. Primary SGL facility can be used only for own investments of the account holder. Client holdings go through the Secondary SGL.
    • D — SGL is the book-entry form, which is the alternative to physical certificates.

    An entity permitted to open a Primary SGL account may avail of the Secondary SGL facility as well. The depositories maintain Constituent SGL accounts of investors through their DPs.

  2. 2.A Primary SGL facility can be used for which purpose?

    1. a)Only for own investments of the account holder
    2. b)Only for holding securities of constituent investors
    3. c)For both own investments and constituent investors' holdings
    4. d)Only for securities pending rematerialisation
    Show the answer

    Answer: (a) Only for own investments of the account holder

    Primary SGL facility can be used only for own investments of the account holder. The account is opened with the RBI directly, and only entities which fulfil all the eligibility criteria prescribed by RBI are permitted to open a Primary SGL account.

    Option B describes Secondary SGL: any entity which is permitted to open a Primary SGL account may avail of Secondary SGL facility as well. However, Secondary SGL facility is to be used to keep accounts of the constituent investors — routing the investments of clients who are not eligible to directly open Primary SGL accounts.

    Option C is wrong because that is exactly the separation the two-tier structure exists to enforce. And the record-keeping follows from it: the entity which offers Secondary SGL facility has to keep sub-accounts for each investor separately in its books; the Secondary SGL account with RBI will show the consolidated balances of all account holders.

Where this is taught

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