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Temporary borrowing

Also written Temporary borrowing (Category I and II) · Temporary funding requirements · Drawdown-shortfall borrowing

The only fund-level borrowing Category I and II AIFs may do: for temporary funding needs, for no more than 30 days, on no more than 4 occasions a year, and up to 10% of investable funds.

In plain language

Category I and II AIFs are not meant to use borrowed money to boost returns. Their investors carry the risk of unlisted companies already; the regulations do not let the manager add debt on top.

But funds have timing problems. An investment has to be paid for on a date, and the cash from investors may arrive a few days late. Temporary borrowing is the narrow exception for that: short, infrequent and small.

A second, related permission covers one specific timing problem — an investor who has not paid a capital call before a deal closes.

How it works

The general rule (Chapter 17). No leveraging at fund level is permitted for Category I or Category II AIFs, directly or indirectly, except for meeting temporary funding requirements:

LimitFigure
DurationNot more than 30 days
FrequencyNot more than 4 occasions in a year
SizeNot more than 10% of investable funds

Category I AIFs may engage in hedging, including buying credit default swaps, and Category II AIFs may engage in hedging, as SEBI specifies — hedging is not leverage for this purpose.

The drawdown-shortfall permission (SEBI circular of 19 August 2024). To ease business, Category I and II AIFs may also borrow to meet a temporary shortfall in the amount called from investors for making an investment (the "drawdown amount"). Conditions:

  • only in an emergency and as a last recourse;
  • when the investment opportunity is about to close and the drawdown has not arrived before the investment date, despite the manager's best efforts;
  • the cost is charged only to the delaying investor(s);
  • a 30-day cooling-off period between two periods of borrowing, counted from the date of repayment of the previous borrowing.

Exceptions and contrasts.

  • IFSC: these restrictions do not apply to Category I and II AIFs domiciled in an IFSC. They may take leverage if the maximum leverage and its calculation are disclosed in the placement memorandum, investors consent, and the fund has a risk management framework suited to its size, complexity and risk profile.
  • Category III: may take leverage through derivatives or borrowing, up to 2 times NAV, calculated at scheme level. Borrowing at fund level as part of the investment strategy is unique to Category III.

A worked example

Kaveri Growth Fund (illustrative) is a Category II AIF with investable funds of Rs 200 crore. It has agreed to invest Rs 30 crore in a company, with completion on 10 September.

The shortfall. It issues a capital call for Rs 30 crore. By 9 September, investors have paid Rs 22 crore; one investor, Mr Sethi, has not paid his Rs 8 crore despite reminders, and the seller will not extend the date.

Can it borrow?

TestKaveriPasses?
Within the general limit of 10% of investable fundsRs 8 crore vs Rs 20 croreYes
Emergency, last recourse, deal about to closeCompletion 10 SeptemberYes
Manager used best efforts to collectReminders documentedYes

The workbook sets the drawdown-shortfall permission out separately from the general 30-day / 4-occasion / 10% limits; this example stays inside both.

It borrows Rs 8 crore on 10 September and repays it on 30 September, when Mr Sethi pays — 20 days, inside the 30-day limit.

Who pays the interest. At an illustrative 10% a year:

Rs 8,00,00,000 × 10% × 20 ÷ 365 = Rs 4,38,356

The whole amount is charged to Mr Sethi alone, not to the other investors.

The cooling-off. The borrowing was repaid on 30 September, so Kaveri cannot borrow again before 30 October.

Why NISM asks about it

Chapter 17 (Regulatory Framework), section 17.9.2 (Category I) and section 17.9.3 (Category II) carry the 30 days / 4 occasions / 10% rule and the drawdown-shortfall permission; section 17.10.3 sets Category III leverage at 2 times NAV; Chapter 15 notes that fund-level borrowing for strategy is unique to Category III. Expect straight recall of the three limits, a question on who bears the cost of drawdown-shortfall borrowing, and a comparison with Category III leverage.

Common exam traps

  • 30 days, 4 occasions a year, 10% of investable funds — the three numbers are asked together and swapped freely in wrong options.
  • 10% of investable funds, not of corpus and not of NAV.
  • The cost of drawdown-shortfall borrowing falls only on the delaying investor.
  • The 30-day cooling-off runs from repayment, not from the date the earlier loan was taken.
  • Category III is different: leverage up to 2 times NAV is permitted.
  • IFSC-domiciled Category I and II AIFs are outside these limits if they disclose leverage, obtain consent and have a risk framework.
  • Hedging is permitted for Category I and II and is not the same as fund-level leverage.

Where this is taught

Free preparation for NISM Series XIX-C

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