Format of ‘Disclosure Document’ for Portfolio Managers
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Disclosure Document format updated: portfolio managers must segregate static/dynamic pages, certify changed pages and file updates promptly.
The circular prescribes a simplified template for the Disclosure Document for Portfolio Managers, replacing Schedule V, and requires a two-part document with a Static Section (enduring disclosures including definitions, services, risk factors, taxation, accounting and valuation policies) and a Dynamic Section (client representation, financial and performance data, audit observations, related-party investments). Each parameter must start on a fresh page; only pages with changes require certification by an independent chartered accountant and the principal officer and must be highlighted to clients, updated on the manager's website and filed with the Board within seven working days of change.