FME Regulatory Intelligence, Learning & Practice · IFSCA (Fund Management) Regulations, 2025
Back to Practical scenarios
Practical scenario · Ch III-A

Pre-first-close deployment

Scenario 10 of 28 · Reg 22

The facts

A VC scheme has drawn down commitments but has not yet reached first close. The treasury team proposes parking the money in a mix of unlisted debt and equity to earn a return.

The question

Is that permitted?

Choose an answer to see the verdict and the approach.

Scenarios are for learning. They apply the provision named to simplified facts. Real situations need a review of the full provision and your own facts.

Prashant Kumar

Meet the expert

CS Prashant Kumar

Company Secretary & Compliance Officer
Global Horizons Capital Advisors (IFSC) Private Limited — an IFSCA-licensed investment banker

13+ years of experienceFCS Fellow member, ICSIAuthor Audit Under Fire

Published in The Chartered Accountant (Jun 2025, Jan 2025, Mar 2024) and Chartered Secretary (Aug 2023)

Prashant Kumar is a seasoned Company Secretary and corporate governance strategist with more than 13 years of experience advising large corporates, promoter-led groups and global businesses on compliance, regulatory risk and board governance. In GIFT IFSC, the IFSCA regime is his day job rather than a research topic.