To, 18th April 2020

Shri. Ajay Bhushan Pandey Finance Secretary Government of Ministry of Finance, North Block. - 110001

Subject: Representation from IVCA regarding difficulties in executing and stamping documents during the Lockdown

Dear Sir,

I am writing to you on behalf of the members of the Indian Venture Capital Association which has over 170 + members from the Indian Alternative Investment Fund ecosystem. The lockdown in India has been extended till May 3rd, 2020 in order to arrest the spread of COVID-19 in India. These are unprecedented times and they demand such unprecedented measures to mitigate the risks.

During this lockdown, we’re facing a practical difficulty in the stamping of various documents, agreements and certificates such as shareholders’ agreements, security subscription agreements, indemnity agreements, share certificates, LLP agreements, trust indentures, loan agreement, working capital agreements, etc. Such stamping is mandatory under the Indian Stamps Act, 1899 and other statutes under various state governments. These documents are crucial to the continuity of business and deferring them will cause severe hardship to those affected. This also extends to the need to get documents notarised physically for submission to various government bodies and regulators.

Another difficulty faced is the need to physically attest and sign every page of these documents, which has become impractical due to the current lockdown.

We appeal to you to make the following announcements for immediate relief to businesses to ensure business continuity:

1. All documents executed between March 25th, 2020 up to the end of the lockdown per state, the stamping, franking or notarising of the documents may be done within a period of 60 days from the end of the lockdown per state, without any adjudication, penalty or interest

2. Waiver of the need to have documents such as financial statements, loan agreements, and other such agreements physically executed and initialled so long as an email from the registered email of the executor is provided for a digitally signed version of said agreements. They may be executed physically within a period of 60 days from the end of the lockdown per state, without any penalties, interest or other fines

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806, 8th Floor Akash Deep Building 26A, Barakhamba Road Connaught Place, New Delhi-110001 +91 11 49876992, [email protected] CIN: U74900DL2010NPL198236, www.ivca.in This will give great comfort to the industry to continue business during the lockdown and ease a great practical difficulty faced by Indian businesses.

We’re fully supportive of the measures undertaken by the in fighting COVID-19 and remain committed to assisting all efforts for the same.

Thanking you, Respectfully,

Rajat Tandon President, IVCA

Cc: Soniya Tolani, IVCA – (+91) 7023854835 Cc: Yogesh Arora, IVCA – (+91) 95400 84999

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806, 8th Floor Akash Deep Building 26A, Barakhamba Road Connaught Place, New Delhi-110001 +91 11 49876992, [email protected] CIN: U74900DL2010NPL198236, www.ivca.in