Key Interpretations under Industry Standards Note on Regulation 30 of the LODR Regulations
The Industry Standards Note on Regulation 30 of the LODR Regulations provides detailed interpretations for various terms and their applicability. The following table presents a clear understanding of the major interpretations:
1. Expected Impact in Terms of Value
Occurrence of Event/Trigger Point
Interpretation
Within 60 days of a Quarter
Expected impact in the four ensuing quarters (including the quarter in which the event occurs)
Not within 60 days of a Quarter
Expected impact in the four ensuing quarters
2. PPR Test (Probable, Possible, Remote)
Outcome of the Event (Above Materiality Threshold)
Interpretation
P (Probable) or P (Possible)
Disclosure may be provided
R (Remote)
Disclosure may not be required
3. Disclosure on Indemnity and Insurance Claims
Threshold
Interpretation
Nil
May disclose details of indemnity and insurance claims which could mitigate the expected impact, if any
4. Last Audited Consolidated Financial Statements
Threshold
Interpretation
Nil
Annual audited consolidated financial statements
5. Significant Market Reaction
Threshold
Interpretation
Nil
To be assessed against scrip price
6. Litigations or Disputes with Similar Question of Law or Factual Matrix
Likelihood
Interpretation
Similar Outcome Likely
Cumulative effect should be considered for disclosure
7. Receipt of Show Cause Notice
Source
Interpretation
Generally
Does not trigger disclosure
Regulatory, Statutory, Enforcement Authority
Disclosure as per Para A(20) of Part A of Schedule III
8. Timeline for Disclosure
Scenario
Justification for Delay
Force Majeure
Delay may be justified
Prima Facie Assessment
Reasonable time for completion may be considered
Subsidiary, Director, KMP, Senior Management, Promoter Related Events
Delay may be explained during disclosure
9. Resignation of Director
Trigger Point
Timeline for Disclosure
Date of Resignation comes to effect
Within 24 hours
10. Investor Meet
Scenario
Timeline
Urgent Matters
Requirement of two working days’ notice may be dispensed with
Enforcement Directorate and Central Bureau of Investigation are considered enforcement authorities
This structured interpretation will help companies ensure compliance with Regulation 30 of the LODR Regulations by providing clarity on when disclosures are necessary and how they should be approached.
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