Question map
Which of the following is issued by registered foreign portfolio investors to overseas investors who want to be part of the Indian stock market without registering themselves directly?
Explanation
Participatory Notes (P-notes) can be issued by foreign portfolio investors (FPIs) registered with Sebi, and allow overseas investors, hedge funds and other foreign institutions to invest in Indian markets without directly registering[1] with Sebi. A Participatory Note (PN) is a derivative instrument issued in foreign jurisdictions, by a Foreign Institutional Investor (FII) / its sub-accounts or one of its associates, against underlying Indian securities.[2] P-Notes are generally issued by a registered FPI to its clients/investors who wish to participate in Indian capital markets but do not want to be registered themselves in the markets directly.[3] PNs are popular among foreign investors since they allow these investors to earn returns on investment in the Indian market without undergoing the significant cost and time implications of directly investing in India.[2] The other options—Certificate of Deposit, Commercial Paper, and Promissory Note—are different financial instruments not used for this specific purpose of providing unregistered overseas investors access to Indian stock markets.
Sources- [1] https://www.livemint.com/Money/Vn1BmjR7VGxWiZ8nu0IDmM/Outstanding-investments-via-Pnotes-at-7year-high.html
- [2] https://dor.gov.in/sites/default/files/inline-documents/FinalBlackMoney.pdf
- [3] https://www.livemint.com/market/budget-2023-govt-allows-ifsc-units-to-issue-p-notes-to-overseas-investors-here-s-what-it-means-151675930669397.html
PROVENANCE & STUDY PATTERN
Full viewThis is a classic 'Static Economy' concept often mistaken for current affairs. While P-Notes appear in news cycles regarding black money, their definition is a foundational element of the External Sector/Capital Markets syllabus. It is a highly fair question; missing this indicates a gap in core Foreign Investment concepts.
This question can be broken into the following sub-statements. Tap a statement sentence to jump into its detailed analysis.
- Statement 1: Do registered foreign portfolio investors issue Participatory Notes to overseas investors to provide exposure to the Indian stock market without the overseas investors registering directly?
- Statement 2: Do registered foreign portfolio investors issue Certificates of Deposit to overseas investors to provide exposure to the Indian stock market without the overseas investors registering directly?
- Statement 3: Do registered foreign portfolio investors issue Commercial Paper to overseas investors to provide exposure to the Indian stock market without the overseas investors registering directly?
- Statement 4: Do registered foreign portfolio investors issue Promissory Notes to overseas investors to provide exposure to the Indian stock market without the overseas investors registering directly?
- Explicitly states P-notes can be issued by FPIs registered with SEBI.
- Says P-notes allow overseas investors to invest without directly registering with SEBI, matching the claim.
- Identifies FIIs and registered brokers as issuers of participatory notes.
- States the system allows unregistered overseas investors to buy Indian shares without registering in India.
- Defines a Participatory Note as an instrument issued by an FII or its associates against underlying Indian securities.
- Explains PNs allow foreign investors to earn returns in the Indian market without the time/cost of direct investment (i.e., without registering directly).
Gives a direct-styled exam item that links 'registered foreign portfolio investors' with issuing something to overseas investors who want exposure without registering — the correct option listed is 'Participatory Note'.
A student could treat this as an authoritative classroom formulation and check regulatory descriptions of Participatory Notes and FPI activities to confirm operational details.
States that foreign institutional/portfolio investors must be registered with SEBI to buy/sell on Indian exchanges.
Combine this rule with the idea that intermediaries (registered FPIs) can act on behalf of non-registered overseas investors to infer why P-Notes might be issued by registered FPIs.
Defines Foreign Portfolio Investors (FPIs) as institutions incorporated outside India and registered with SEBI.
Use this definition to reason that FPIs are the regulated entities through which foreign participation occurs, so instruments issued by FPIs (like P-Notes) plausibly provide that access.
Explains ADR/GDR as intermediary depository instruments that allow overseas investors to gain exposure without direct listing — an analogous pattern of using intermediaries to access foreign securities.
Use the ADR/GDR analogy plus knowledge of international investment practice to see P-Notes as a similar intermediary device for foreign investors to access Indian stocks.
- Explicitly states that FPIs (foreign portfolio investors) can issue P-notes.
- Says P-notes allow overseas investors to invest in Indian markets without directly registering with SEBI.
- Shows that registered FPIs use offshore instruments to provide exposure to overseas investors — but mentions P-notes, not Certificates of Deposit.
- States that brokers and foreign institutional investors registered with SEBI issue participatory notes to investors in other countries.
- Explains that this system allows unregistered overseas investors to buy Indian shares without registering in India.
- Supports the general mechanism (FPIs issuing offshore instruments) but refers to participatory notes, not Certificates of Deposit.
- Defines a Participatory Note (PN) as a derivative instrument issued by an FII or its associates against underlying Indian securities.
- Notes PNs let foreign investors earn returns on Indian market investments without the cost and time of direct investing.
- Again confirms FPIs/FIIs use P-notes/PNs (offshore derivatives) to give overseas exposure, not Certificates of Deposit.
This MCQ explicitly asks which instrument is issued by registered foreign portfolio investors to overseas investors who want exposure without registering themselves, listing 'Certificate of Deposit' and 'Participatory Note' as options.
A student could use this to focus research on which of the listed instruments (CD vs participatory note) is commonly used for non‑resident exposures and then check authoritative SEBI guidance or definitions.
Explains the general mechanism where an overseas depository (ADRs/GDRs) issues a security representing underlying domestic shares to foreign investors — an example of intermediated exposure.
Compare this known intermediated model (ADRs/GDRs) with the idea of FPIs issuing other intermediated instruments (like CDs or P‑notes) to assess plausibility.
Defines Foreign Portfolio Investors as institutions incorporated outside India and notes that FPIs are registered with SEBI.
Use this to check whether registered FPIs have the authority or precedent to issue instruments to overseas investors on behalf of Indian market exposure.
States that Foreign Portfolio Investment generally happens through the secondary market, implying intermediated trading and instruments are part of FPI activity.
A student could infer that if FPIs operate in secondary markets, they might use intermediating instruments (investigate which specific instruments are used for offshore client exposure).
Notes foreign institutional investors must register with SEBI to buy/sell on Indian exchanges, highlighting regulatory control over foreign access to Indian markets.
Combine this with the MCQ (snippet 1) to investigate whether regulation permits registered FPIs to create pass‑through instruments for unregistered overseas investors.
- Explicitly states that P-notes can be issued by foreign portfolio investors (FPIs) registered with SEBI.
- Says these P-notes allow overseas investors to invest in Indian markets without directly registering with SEBI, which matches the 'exposure without direct registration' part of the statement.
- Says brokers and foreign institutional investors registered with SEBI issue participatory notes and invest on behalf of foreign investors.
- Makes clear that participatory notes allow unregistered overseas investors to buy Indian shares without registering in India.
- Defines a Participatory Note (PN) as a derivative instrument issued by a Foreign Institutional Investor (FII) against underlying Indian securities.
- States PNs are popular because they allow foreign investors to earn returns in the Indian market without the cost and time of direct investment (i.e., without registering).
The exercise question explicitly asks which instrument is issued by registered foreign portfolio investors to overseas investors who want exposure without registering themselves — implying such an arrangement exists and is associated with a specific instrument.
A student could check which option (e.g., Participatory Note vs Commercial Paper) is standardly cited in textbooks or SEBI guidance as the instrument used to give unregistered overseas investors market exposure.
States that foreign institutional investors must register with SEBI and that they operate through portfolio investment schemes, establishing that intermediaries (registered FIIs/FPIs) are the regulated entities in cross-border portfolio flows.
Use this rule to reason that any device allowing unregistered overseas investors exposure would likely be provided via a registered intermediary (FPI/FII) and then verify which instruments SEBI permits intermediaries to issue.
Notes FIIs are regulated by SEBI and are active in financial markets, supporting the idea that registered foreign entities are the channel for foreign investment into Indian securities.
Combine with item 1 to investigate SEBI rules on what registered FIIs/FPIs are allowed to issue to overseas clients (e.g., PNs) versus whether they can issue Commercial Paper for this purpose.
Describes ADR/GDRs as instruments created by an overseas depository to let foreign investors hold shares of Indian companies without direct listing — an example where intermediaries create instruments to provide indirect exposure.
Use this analogy to consider whether Commercial Paper could serve a similar intermediary role, and then look up whether CPs are structured or regulated to provide equity-market exposure to overseas investors.
Defines FPIs and notes they can invest in government and corporate bonds and be treated as debt, highlighting that foreign portfolio investors engage in both equity and debt instruments under regulatory distinctions.
A student could use this to distinguish debt instruments (like Commercial Paper) from equity-exposure instruments (like Participatory Notes) and then check whether CPs are used to give equity-market exposure.
- Explicitly states P-notes can be issued by foreign portfolio investors (FPIs) registered with SEBI.
- Says these P-notes allow overseas investors and institutions to invest in Indian markets without directly registering with SEBI.
- Directly matches the statement's claim about providing exposure without overseas investors registering.
- Describes that brokers and foreign institutional investors registered with SEBI issue participatory notes and invest on behalf of foreign investors.
- States the system allows unregistered overseas investors to buy Indian shares without registering in India, matching the 'without direct registration' part of the statement.
- Clearly states P-Notes are generally issued by a registered FPI to clients who wish to participate in Indian capital markets.
- Specifically notes these clients do not want to be registered themselves in the markets directly, supporting the 'without registering directly' aspect.
The textbook question explicitly lists 'Promissory Note' and 'Participatory Note' as options for instruments issued to overseas investors who don't register directly, indicating these instruments are considered in this context.
A student could recall that one of these options is likely correct and then check external sources (SEBI guidance) or class notes to see which instrument is actually used (e.g., participatory notes vs promissory notes).
States that foreign institutional investors must register with SEBI to buy/sell on Indian exchanges, implying there exist alternative routes/instruments for non-registered overseas investors to gain exposure.
Combine this with knowledge that intermediated products exist to bypass direct registration to infer such instruments (like P‑notes) serve that role and then check whether promissory notes are among them.
Describes ADR/GDR as an instrument where overseas depository banks issue securities representing domestic shares so investors need not list directly—shows precedent of intermediary instruments providing indirect exposure.
Use the ADR/GDR analogy to reason that India may have other intermediary instruments (e.g., P‑notes) rather than promissory notes, and then verify which instrument is used for portfolio/secondary market exposure.
Defines Foreign Portfolio Investors (FPIs) as registered entities with SEBI, highlighting that the regulatory regime distinguishes registered FPIs from other non‑registered overseas investors.
A student could infer that mechanisms exist to let non‑registered investors access markets through registered FPIs (so check whether registered FPIs legally issue promissory notes or another instrument).
Notes IFSC units and India-INX allow foreign listing/transactions treating IFSC as foreign territory—another example of structural alternatives to direct onshore registration.
Combine this with map/knowledge of financial centres to explore whether such off‑shore/IFSC routes are used instead of simple promissory notes for overseas exposure, guiding targeted verification.
- [THE VERDICT]: Sitter. Covered in every standard Economy textbook (Vivek Singh, Singhania, Mrunal) under 'Foreign Investment Models'.
- [THE CONCEPTUAL TRIGGER]: The 'External Sector' module, specifically the sub-topic of 'Routes of Foreign Entry' (FDI vs FPI vs Offshore Routes).
- [THE HORIZONTAL EXPANSION]: Memorize the 'Cross-Border Instrument Matrix': ADR/GDR (Indian equity abroad), IDR (Foreign equity in India), Masala Bonds (Rupee debt abroad), and P-Notes (Derivatives for unregistered investors). Also, the '10% Rule' distinguishing FPI from FDI.
- [THE STRATEGIC METACOGNITION]: When studying regulations (like SEBI registration), always ask: 'What is the workaround for those who don't want to comply?' P-Notes are the specific workaround for anonymity/non-registration. The exam tests the *mechanism* of the exception.
FPIs are foreign institutions that must obtain registration/licence from SEBI to invest in Indian capital markets.
High-yield for UPSC: regulation of foreign investment and market entry rules are frequently tested. Mastering FPI registration clarifies how cross-border portfolio flows are regulated, links to balance of payments and capital account questions, and helps answer regulatory/compliance type MCQs and mains-level questions on capital inflows.
- Indian Economy, Nitin Singhania .(ed 2nd 2021-22) > Chapter 16: Balance of Payments > a. Foreign Institutional Investment (FII) > p. 478
- Indian Economy, Vivek Singh (7th ed. 2023-24) > Chapter 2: Money and Banking- Part I > 2.23 Foreign Investment > p. 98
Foreign institutional investors access India's primary and secondary capital markets through the Portfolio Investment Scheme (PIS).
Important for UPSC because distinguishing the technical routes for foreign investment (PIS vs other routes) is central to questions on inflow mechanisms, RBI/SEBI roles and capital controls. Knowing PIS enables precise answers on permitted channels and reporting requirements.
- Indian Economy, Nitin Singhania .(ed 2nd 2021-22) > Chapter 16: Balance of Payments > a. Foreign Institutional Investment (FII) > p. 478
FDI typically implies lasting interest and active involvement; FPI usually means minority stakes and transactions in secondary markets.
High-yield comparative concept: many questions ask to differentiate types of foreign investment. Understanding FDI vs FPI links to topics on industrial policy, foreign exchange management, and impacts on corporate control, enabling both objective and descriptive answers in prelims and mains.
- Indian Economy, Vivek Singh (7th ed. 2023-24) > Chapter 2: Money and Banking- Part I > 2.23 Foreign Investment > p. 99
- Indian Economy, Vivek Singh (7th ed. 2023-24) > Chapter 2: Money and Banking- Part I > 2.23 Foreign Investment > p. 97
FPIs must obtain SEBI registration/licence to invest in Indian capital markets, which determines whether foreign investors invest directly or through intermediaries.
High-yield: questions frequently ask which agencies regulate foreign capital and the registration requirements for foreign investors. Mastering this links to topics on capital controls, balance of payments, and permissible routes for foreign investment; it enables answering questions on investor classification and regulatory permissions.
- Indian Economy, Vivek Singh (7th ed. 2023-24) > Chapter 2: Money and Banking- Part I > 2.23 Foreign Investment > p. 98
- Indian Economy, Nitin Singhania .(ed 2nd 2021-22) > Chapter 16: Balance of Payments > a. Foreign Institutional Investment (FII) > p. 477
- Indian Economy, Nitin Singhania .(ed 2nd 2021-22) > Chapter 16: Balance of Payments > a. Foreign Institutional Investment (FII) > p. 478
FDI involves long-term capital and control, whereas FPI is portfolio investment (typically minority stakes) in securities — a key distinction when assessing instruments and investor behaviour.
High-yield: UPSC often tests distinctions between FDI and FPI across economy and international finance. Knowing this clarifies which instruments and routes (primary vs secondary markets, control vs portfolio exposure) apply and connects to questions on capital flows and regulation.
- Indian Economy, Vivek Singh (7th ed. 2023-24) > Chapter 2: Money and Banking- Part I > 2.23 Foreign Investment > p. 99
- Indian Economy, Vivek Singh (7th ed. 2023-24) > Chapter 2: Money and Banking- Part I > 2.23 Foreign Investment > p. 97
ADRs/GDRs let overseas investors gain exposure to foreign companies via depository instruments issued by overseas depository banks, providing an indirect investment route without direct local listing or registration.
High-yield: understanding depository receipts is useful for questions on how global investors access domestic equities, cross-border listing mechanisms, and the role of custodian/depository banks. It helps answer items on alternative instruments for foreign participation.
- Indian Economy, Vivek Singh (7th ed. 2023-24) > Chapter 2: Money and Banking- Part I > 2.23 Foreign Investment > p. 100
Foreign Portfolio Investors and Foreign Institutional Investors must obtain registration or approval from SEBI to participate in Indian capital markets.
High-yield for UPSC: questions often probe regulatory entry conditions for foreign investors and implications for capital flows. Mastering this clarifies which routes require direct registration and links to topics on capital account management and financial regulation.
- Indian Economy, Vivek Singh (7th ed. 2023-24) > Chapter 2: Money and Banking- Part I > 2.23 Foreign Investment > p. 98
- Indian Economy, Nitin Singhania .(ed 2nd 2021-22) > Chapter 16: Balance of Payments > a. Foreign Institutional Investment (FII) > p. 477
Indian Depository Receipts (IDRs). Since UPSC has tested P-Notes (foreigners accessing India) and ADRs/GDRs (Indians accessing foreign capital), the logical next step is IDRs (Foreign companies raising funds from Indian investors, e.g., Standard Chartered). Also, watch for 'Variable Capital Companies' (VCC) in GIFT City.
Linguistic Logic: 'Certificate of Deposit' and 'Commercial Paper' are standard Money Market (Debt) instruments used by banks/corporates for short-term liquidity *within* a domestic economy. 'Promissory Note' is a generic legal term. 'Participatory Note' is the only option that implies a derivative relationship—'participating' in the returns of a stock without being the actual owner (registrant).
GS-3 (Internal Security & Money Laundering): P-Notes are frequently cited in the context of 'Round Tripping' (black money leaving India and returning as white FPI investment). This links a dry Capital Market definition to the SIT on Black Money and PMLA (Prevention of Money Laundering Act) debates.