TaxTMI 
TaxTMI 
Circular for Portfolio Managers
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....tfolio Managers Regulation 24 (3A) of PMS Regulations inter-alia provides that the Portfolio Manager shall ensure compliance with the prudential limits on investment as may be specified by the Board. Accordingly, the Portfolio Managers shall ensure the following: i. Portfolio Manager shall invest up to a maximum of 30 percent of their client's portfolio (as a percentage of the client's assets under management) in the securities of their own associates/related parties. Further, the Portfolio Manager shall ensure compliance with the following limits: Security Limit for investment in single associate/related party (as percentage of client's AUM) Limit for investment across multiple associates/related parties (as percentage of client's AUM) Equity 15% 25% Debt and hybrid securities 15% 25% Equity + Debt + Hybrid securities 30% ii. The aforementioned limits shall be applicable only to direct investments by Portfolio Managers in equity and debt/hybrid securities of their own associates/related parties and not to any investments in the Mutual Funds. iii. Hybrid securities includes units of Real Estate Investment Trusts (....
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....nt of passive breach of the specified investment limits, (i.e., occurrence of instances not arising out of omission and/or commission of portfolio manager), a rebalancing of the portfolio shall be completed by Portfolio Managers within a period of 90 days from the date of such breach. Notwithstanding the same, the client may give an informed, prior positive consent to the Portfolio Manager for waiver from the rebalancing of the portfolio to rectify any passive breach of the investment limits. viii. Such requirement of rebalancing in the event of a passive breach of investment limits shall be suitably disclosed in the consent form mentioned at para 2(B)(i) above and any waiver from the same shall also be obtained in the same document. ix. In accordance with Regulation 27 (1) of the PMS Regulations, Portfolio Managers shall maintain records and documents pertaining to: a) Prior positive consent or dissent, as the case may be. b) Instances of the passive breach of investment limits, if any. c) Steps taken, if any to rectify the passive breach of investments limits. d) Waiver obtained from the client regarding rebalancing in the eve....
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.... Transaction wise Details Transaction date Buy/sell Quantity Gross transaction value (INR in crores) Net transaction value (INR in crores) ii. Security wise Sr. No. Issuer name Type of security ISIN Security wise Details Investment amount (cost of investment) as on last day of the previous quarter (INR in crores) Value of investments as on last day of the previous quarter (INR in crores) percentage of client's AUM as on last day of the previous quarter (INR in crores) percentage of PM's AUM as on last day of the previous quarter (INR in crores) iii. Details regarding passive breach of investment limits: Sr. No. Details of passive breach Date of passive breach Details of steps taken, if any, to rectify the passive breach of limits Date of rectification Whether rectified within 90 days  ....
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.... c) The circular shall come into effect from September 20, 2022 and the requirements at para 2(D)(II) above shall come into effect from the quarter ending September 2022. 4. This circular is issued in exercise of powers conferred under Section 11(1) of the Securities and Exchange Board of India Act, 1992 read with Regulation 43 of the SEBI (Portfolio Managers) Regulations, 2020, to protect the interests of the investors in securities market and to promote the development of, and to regulate the securities market. 5. The circular is available on SEBI website at www.sebi.gov.in under the categories "Info for - Portfolio Managers" and "Legal framework - Circulars". Yours faithfully, Manaswini Mahapatra General Manager +91-22-26449375 [email protected] Annexure: A Format of obtaining the consent from the client 1. This document is for obtaining the consent/dissent for investment by Portfolio Manager in its associates/related parties. 2. As per SEBI (Portfolio Managers) Regulations, 2020, the limits applicable for investment in the securities of associates/related parties of Portfolio Manager are as under: Security Limit f....