TaxTMI 
TaxTMI 
Master Circular for Portfolio Managers
X X X X Extracts X X X X
X X X X Extracts X X X X
.... Circular for Portfolio Managers dated March 20, 2023, the guidelines/directions contained in the circulars listed out in the Annexure Z to that Master Circular were rescinded. In addition, with the issuance of this Master Circular, the guidelines/directions contained in the circulars listed out at Sr. Nos.33-36 in the Appendix to this Master Circular, to the extent they relate to the Portfolio Managers, shall stand rescinded. D. With respect to the directions or other guidance issued by SEBI, as specifically applicable to Portfolio Managers, the same shall continue to remain in force in addition to the provisions of any other law for the time being in force. Terms not defined in this Master Circular shall have the same meaning as provided under the relevant Regulations. E. Notwithstanding such rescission, E.1. anything done or any action taken or purported to have been done or taken under the rescinded circulars, including registrations or approvals granted, fees collected, registration suspended or cancelled, any inspection or investigation or enquiry or adjudication commenced or show cause notice issued prior to such rescission, shall be deemed to have been done or take....
X X X X Extracts X X X X
X X X X Extracts X X X X
....receipt of 'Form A', SEBI may seek further information for processing the application. Any information sought by SEBI has to be responded in detail and supported by relevant documents. 1.1.3. The information submitted to SEBI at the time of registration, shall be full and complete in all respects, otherwise it may delay processing of the registration application. 1.1.4. Online process for Fresh Registrations and Updation of Information is given in Annexure 1A of this Master Circular3. 1.2. General Registration Guidelines4 1.2.1. The registration granted to a portfolio manager under Chapter II of the PM Regulations is for the principal office as well as for all the branch offices of the portfolio manager in India. 1 SEBI/RPM CIRCULAR NO.2 (2002-2003) dated January 14, 2003 2 SEBI/HO/MIRSD/MIRSD1/CIR/P/2017/38 dated May 02, 2017 3 Online Process of Portfolio Manager applications dated September 21, 2010 4 RPM circular No.1(93-94) dated October 20, 1993 Page 8 of 175 à¤à¤¾à¤°à¤¤à¥€à¤¯ पà¥à¤°à¤¤à¤¿à¤à¥‚ति और विनिमय बोरà¥à¤¡ Securities and Exchange....
X X X X Extracts X X X X
X X X X Extracts X X X X
....group are granted registration, any action by way of suspension or cancellation of registration taken by SEBI against one entity, may entail action against other entities of the same group, under the Intermediaries Regulations. Explanation: For the purposes of this Master Circular, two entities are considered to be in the same group if: 1.3.2.1. the same person, by himself or in combination with relatives, directly or indirectly exercises control over both the entities or, 1.3.2.2. one is an 'associate company' of another and for this purpose, 'associate company' shall mean 'associate company' as defined under sub-section (6) of section 2 of the Companies Act,2013, or Page 10 of 175 à¤à¤¾à¤°à¤¤à¥€à¤¯ पà¥à¤°à¤¤à¤¿à¤à¥‚ति और विनिमय बोरà¥à¤¡ Securities and Exchange Board of India 1.3.2.3. where one entity directly or indirectly exercises 'control' over the other entity and for this purpose, 'control' as defined under the Regulation 2(1)(e) of the PM Regulations shall be referred. 1.4. Co-investment Portfolio Management Services 1.4.1. 6The Co-....
X X X X Extracts X X X X
X X X X Extracts X X X X
....ement, the portfolio manager shall inform its existing investors/ clients about the proposed 7 SEBI/HO/IMD-I/DOF1/P/CIR/2021/564 dated May 12, 2021 8 SEBI/HO/IMD-1/DOF1/P/CIR/2022/77 dated June 02, 2022 9 Substituted by SEBI Circular No. SEBI/HO/IMD/IMD-PoD-1/P/CIR/2023/8 dated January 10, 2023. Prior to substitution, clause 1.5.1.4 read as under: "Pursuant to grant of prior approval by SEBI, in order to enable existing investors/ clients to take well informed decision regarding their continuance or otherwise with the changed management, the Portfolio Manager shall inform its existing investors/ clients about the proposed change prior to effecting the same and give an option to exit without any exit load, within a period of not less than 30 calendar days, from the date of such communication." Page 12 of 175 à¤à¤¾à¤°à¤¤à¥€à¤¯ पà¥à¤°à¤¤à¤¿à¤à¥‚ति और विनिमय बोरà¥à¤¡ Securities and Exchange Board of India change prior to effecting the same and give an option to exit without any exit load, within a period of not less than 30 calendar days, from the da....
X X X X Extracts X X X X
X X X X Extracts X X X X
....not written off) Less: Minimum Capital Adequacy networth requirement for any other activity undertaken under other SEBI Regulations. Networth 10 SEBI Circular No. IMD/DOF I/PMS/Cir- 5/2009 dated July 31, 2009 Page 14 of 175 à¤à¤¾à¤°à¤¤à¥€à¤¯ पà¥à¤°à¤¤à¤¿à¤à¥‚ति और विनिमय बोरà¥à¤¡ Securities and Exchange Board of India 1.7. Certificate of associated persons in the Securities Markets 1.7.1. For employees of Portfolio Managers11 1.7.1.1. The associated persons functioning as principal officer of a Portfolio Manager or employee(s) of the Portfolio Manager having decision making authority related to fund management, shall obtain certification from the National Institute of Securities Markets by passing the NISM- Series-XXI-B: Portfolio Managers Certification Examination as mentioned in the communiqué No. NISM/ Certification/Series-XXI-B: Portfolio Managers (PM) Certification/2021/01 dated June 15, 2021 issued by the National Institute of Securities Markets. 1.7.1.2. The Portfolio Managers shall ensure that all such associated persons who a....
X X X X Extracts X X X X
X X X X Extracts X X X X
....XI-A: Portfolio Management Services (PMS) Distributors Certification Examination within one year from the date of their employment: 14 SEBI Gazette No. SEBI/LAD-NRO/GN/2021/48 dated September 7, 2021 15 SEBI Gazette No. SEBI/LAD-NRO/GN/2021/48 dated September 7, 2021 16 SEBI Gazette No. SEBI/LAD-NRO/GN/2021/48 dated September 7, 2021 Page 16 of 175 à¤à¤¾à¤°à¤¤à¥€à¤¯ पà¥à¤°à¤¤à¤¿à¤à¥‚ति और विनिमय बोरà¥à¤¡ Securities and Exchange Board of India Provided further that an associated person, who being a distributor of the Portfolio Management Services, has obtained any of the following registration/ certification as on the date of this notification a) a valid AMFI Registration Number (ARN) b) NISM Series-V-A exam certification shall be exempted from the requirement of obtaining certification by passing the NISM-Series-XXI-A: Portfolio Management Services (PMS) Distributors Certification Examination till the validity of the said registration/ certification. Page 17 of 175 à¤à¤¾à¤°à¤¤à¥€à¤¯ पà¥à¤°à¤¤à¤¿à¤....
X X X X Extracts X X X X
X X X X Extracts X X X X
....rding of clients by Portfolio Managers21 2.3.1. Portfolio Managers shall provide an option to clients to be on-boarded directly, without intermediation of persons engaged in distribution services. 2.3.2. Portfolio Managers shall prominently disclose in its Disclosure Documents, marketing material and on its website, about the option for direct on-boarding. 2.3.3. At the time of on-boarding of clients directly, no charges except statutory charges shall be levied. 20 Cir. /IMD/DF-1/16/2012 dated July 16, 2012 21 SEBI/HO/IMD/DF1/CIR/P/2020/26 dated February 13, 2020 Page 19 of 175 à¤à¤¾à¤°à¤¤à¥€à¤¯ पà¥à¤°à¤¤à¤¿à¤à¥‚ति और विनिमय बोरà¥à¤¡ Securities and Exchange Board of India 2.3.4. The above provisions with respect to direct on-boarding of clients shall not be applicable to Co-investment portfolio management services22. 2.4. Supervision of Distributors23 2.4.1. The Portfolio Managers shall: 2.4.1.1. Ensure that any person or entity involved in the distribution of its services is carrying out the distribution activities in compliance with....
X X X X Extracts X X X X
X X X X Extracts X X X X
.... 2020 26 SEBI Circular No. SEBI/HO/IMD/IMD-I DOF1/P/CIR/2022/133 dated September 30, 2022 & refer SEBI Letter No. SEBI/HO/IMD-POD-1/P/OW/2023/50456/1 dated December 27, 2023 Page 21 of 175 à¤à¤¾à¤°à¤¤à¥€à¤¯ पà¥à¤°à¤¤à¤¿à¤à¥‚ति और विनिमय बोरà¥à¤¡ Securities and Exchange Board of India 2.6.2. Portfolio Managers shall also put in place a specific policy, in compliance with the PM Regulations and circulars issued thereunder, which shall inter- alia provide for the following: 2.6.2.1. Specific situations (not generic) wherein the orders shall be placed for each client individually or pooled from trading account of Portfolio Manager. 2.6.2.2. Scenarios / situations in which deviation from the allotment of securities as intended at the time of placement of order would be permissible, if at all. 2.6.2.3. Scenarios, wherein, the Portfolio Manager is required to place certain margins / collaterals in order to execute certain transactions, details on how such margins / collaterals shall be segregated / placed from amongst various clients, without affecting ....
X X X X Extracts X X X X
X X X X Extracts X X X X
....olicies of the Portfolio Manager. 2.7.3. For equity, equity-related instruments and Mutual Funds units 28 2.7.3.1. Portfolio Managers with assets under management of INR 1000 crores or more under discretionary and non-discretionary services, shall have in place an automated system with minimal manual intervention for ensuring effective funds and securities management including order management and allocation of securities to each client. 2.7.3.2. The aforesaid system shall inter-alia clearly capture details with respect to pre-order placement allocation as well as final allocation of trades to clients along with instances of deviation, if any, as mentioned at paragraph 2.6.2.4 above. 2.7.4. Portfolio Managers shall maintain audit trail of all activities related to management of funds and securities of clients including order placement, trade execution and allocation. Further, there shall be time stamping with respect to order placement, order execution and trade allocation. 2.8. Cyber Security and Cyber Resilience framework for Portfolio Managers29 2.8.1. With rapid technological advancement in the securities market, there is a greater need for maintaining robust ....
X X X X Extracts X X X X
X X X X Extracts X X X X
....anaged by them. The ultimate responsibility for fair valuation shall be that of the Portfolio Manager. Page 26 of 175 à¤à¤¾à¤°à¤¤à¥€à¤¯ पà¥à¤°à¤¤à¤¿à¤à¥‚ति और विनिमय बोरà¥à¤¡ Securities and Exchange Board of India 3. INVESTMENTS BY PORTFOLIO MANAGERS 3.1. Transaction in Corporate Bonds through Request for Quote platform by Portfolio Management Services (PMS)31 3.1.1. In order to enhance transparency pertaining to debt investments by Portfolio Managers in Corporate Bonds ("CBs") and to increase liquidity on exchange platform, the following shall be followed by Portfolio Managers: 3.1.1.1. On a monthly basis, Portfolio Managers shall undertake at least 10% of their total secondary market trades by value in CBs in that month by placing/seeking quotes through one-to-one (OTO) or one-to-many (OTM) mode on the Request for Quote platform of stock exchanges (RFQ). 3.1.1.2. In order to ensure compliance with the abovementioned 10 percent requirement, Portfolio Managers shall consider the trades executed by value through OTO or OTM mode of RFQ with resp....
X X X X Extracts X X X X
X X X X Extracts X X X X
....ªà¥à¤°à¤¤à¤¿à¤à¥‚ति और विनिमय बोरà¥à¤¡ Securities and Exchange Board of India management scheme, prior permission from investors in the event of any changes in the manner or terms of usage of derivative contracts etc. 3.2.3. The total exposure of the portfolio client in derivatives should not exceed his portfolio funds placed with the Portfolio Manager and the Portfolio Manager should, in essence, invest and not borrow on behalf of his clients. 3.2.4. It may be noted that investment in derivatives shall be only on the terms mutually agreed between the Portfolio Manager and the client through the portfolio management agreement. In the event of the any violation of the terms of the agreement, the Portfolio Manager shall be responsible. 3.2.5. Portfolio Managers are required to provide necessary disclosures in Disclosure Document in terms of the PM Regulations. 3.3. Participation of Portfolio Managers in Commodity Derivatives Market in India33 3.3.1. Portfolio Managers are permitted to participate in Exchange Traded Commodity Derivatives on behalf of their clients. 3.3....
X X X X Extracts X X X X
X X X X Extracts X X X X
....¾à¤°à¤¤à¥€à¤¯ पà¥à¤°à¤¤à¤¿à¤à¥‚ति और विनिमय बोरà¥à¤¡ Securities and Exchange Board of India Traded Commodity Derivatives market, ensure that all conditions specified by SEBI are complied with. 3.3.2.7. Portfolio Managers shall also provide periodic reports to the clients as per the PM Regulations34 regarding their exposure in Exchange Traded Commodity Derivatives. 3.3.2.8. Portfolio Managers shall report the exposure in Exchange Traded Commodity Derivatives under the heading of 'Commodity Derivatives' in the monthly reports submitted to SEBI. 3.4. Limits on investment in securities of associates/ related parties of Portfolio Managers35 3.4.1. Regulation 24 (3A) of the PM 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: 3.4.2. 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 secu....
X X X X Extracts X X X X
X X X X Extracts X X X X
....°à¤¤à¤¿à¤à¥‚ति और विनिमय बोरà¥à¤¡ Securities and Exchange Board of India associates/related parties of respective Portfolio Manager, below the ceiling specified in paragraph 3.4.2 above. 3.5.3. The text and figures of the consent form shall be prominently highlighted and not be below size 12 font. 3.5.4. For new clients, the aforementioned consent shall be obtained at the time of entering into agreement, in terms of Regulation 22 (1) of the PM Regulations (i.e., at the time of onboarding of a new client). 3.5.5. For existing clients, the aforementioned consent shall be obtained by way of execution of a supplementary agreement with the clients. In cases where the agreements entered with existing clients contain provision for obtaining consent for investments through a specified mode, the same mode can be used for obtaining aforesaid prior consent for investments in the securities of associates/related parties of the Portfolio Manager as well. 3.5.6. Portfolio Manager shall not make any investments in the securities of associates/related parties without the prior consent of the cli....
X X X X Extracts X X X X
X X X X Extracts X X X X
...., 2022 Page 34 of 175 à¤à¤¾à¤°à¤¤à¥€à¤¯ पà¥à¤°à¤¤à¤¿à¤à¥‚ति और विनिमय बोरà¥à¤¡ Securities and Exchange Board of India 3.6.2. Portfolio Managers offering discretionary portfolio management services shall not make any investment in below investment grade securities. 3.6.3. Portfolio Managers offering non-discretionary portfolio management services shall not make any investment in below investment grade listed securities. However, Portfolio Manager may invest up to 10% of the assets under management of such clients in unlisted unrated securities of issuers other than associates/related parties of Portfolio Manager. The said investment in unlisted unrated debt and hybrid securities shall be within the maximum specified limit of 25% for investment in unlisted securities under Regulation 24(4) of the PM Regulations. 3.7. Applicability of above provisions: 38 3.7.1. The requirements as specified at paragraphs 3.4, 3.5 & 3.6 above and in Regulations 22 (1A), 22(4) (da) & (db), 24 (3A) to 3(E) of the PM Regulations shall not be applicable for advisory por....
X X X X Extracts X X X X
X X X X Extracts X X X X
....etion by him. 4.2.3. Therefore, it is advised that Portfolio Managers who have incorporated the said clause or similar clause shall modify it as below :- 39 SEBI/HO/IMD/DF1/CIR/P/2020/26 dated February 13, 2020 40 Regulation 22 (7) of the SEBI (Portfolio Managers) Regulations, 2020 41 SEBI/IMD/CIR No.1/ 70353 /2006 dated June 28, 2006 Page 37 of 175 à¤à¤¾à¤°à¤¤à¥€à¤¯ पà¥à¤°à¤¤à¤¿à¤à¥‚ति और विनिमय बोरà¥à¤¡ Securities and Exchange Board of India 'The portfolio managers' decision (taken in good faith) in deployment of the Clients' account is absolute and final and cannot be called in question or be open to review at time during the currency of the agreement or any time thereafter except on the ground of malafide, fraud, conflict of interest or gross negligence. 4.3. Disclosure of fees and charges42 4.3.1. To ensure transparency and adequate disclosure regarding fees and charges, the client agreement shall contain a separate annexure which shall list all fees and charges payable to the portfolio manager. The said annexure shall contain details of ....
X X X X Extracts X X X X
X X X X Extracts X X X X
..../IMD/DF/16/2010 dated November 02, 2010 47 IMD/PMS/CIR/1/21727/03 dated November 18, 2003 48 Omitted in line with SEBI Circular No. SEBI/HO/IMD/IMD-PoD-2/P/CIR/2022/172 dated December 16, 2022. Prior to omission, clause 4.5.2.1 read as under: "All portfolio managers are required to disclose the performance of their portfolios to their clients, including disclosure of the performance indicators calculated on the basis of 'time weighted rate of return' method taking each individual category of investments for the immediately preceding three years in case of discretionary portfolio managers. In order to make the investors fully aware about how their funds have been Page 39 of 175 à¤à¤¾à¤°à¤¤à¥€à¤¯ पà¥à¤°à¤¤à¤¿à¤à¥‚ति और विनिमय बोरà¥à¤¡ Securities and Exchange Board of India 4.5.2.2. [The portfolio managers may select benchmark indices in line with para 4.6A of this Master Circular. Any change in the benchmark indices at a later date shall be recorded and justified with specific reasons thereof. 4.5.2.3. Portfolio Managers have the option to give the....
X X X X Extracts X X X X
X X X X Extracts X X X X
.... 4.5.3.4. Ensure that performance reported in all marketing material and website of the Portfolio Manager is the same as that reported to SEBI. 4.5.3.5. Ensure that the aggregate performance of the Portfolio Manager (firm- level performance) reported in any document shall be same as the combined performance of all the portfolios managed by the Portfolio Manager. 4.5.3.6. Provide a disclaimer in all marketing material that the performance related information provided therein is not verified by SEBI. 4.6. Nomenclature 'Investment Approach'51 4.6.1. [An investment approach ('IA') is the documented investment philosophy to be adopted by the Portfolio Managers while managing the client funds in order to achieve client's investment objectives.]52 The information about Investment Approaches offered by Portfolio Managers, shall be uniform across all types of regulatory reporting, client reporting, disclosure document, marketing materials and any such document which refer to services offered by Portfolio Managers. 51 SEBI/HO/IMD/DF1/CIR/P/2020/26 dated February 13, 2020 52 Inserted by SEBI Circular No. SEBI/HO/IMD/IMD-PoD-2/P/CIR/2022/172 dated December 16, 2022 Page....
X X X X Extracts X X X X
X X X X Extracts X X X X
....hmark from those prescribed for that Strategy to enable the investor to evaluate relative performance of the Portfolio Managers. 4.6A.4 The Board of the Portfolio Managers shall be responsible for ensuring appropriate selection of Strategy and benchmark for each IA. 4.6A.5 Once an IA is tagged to a Strategy and/or to a benchmark, the tagging shall be changed only after offering an option to subscribers to the IA to exit without any exit load. The performance track record (of the specific IA whose tagging with Strategy/ benchmark was changed) prior to the change shall not be used by the Portfolio Manager for performance reporting. Further, the same shall be verified as part of annual audit under the Regulations54. 4.6A.6 The changes in Strategy and/ or benchmark shall be recorded with proper justification and shall be verified as part of the annual audit under the Regulations55. 4.7. Disclosure of details of related party investments by Portfolio Managers 56 4.7.1. Regulations 22 (4) (da) & (db) of the PM Regulations provides that the Portfolio Manager shall disclose in the Disclosure Document the details of its diversification policy and the details of investment ....
X X X X Extracts X X X X
X X X X Extracts X X X X
....of each month shall be indicated in Rupees in crores. 5.1.4. Procedure to upload monthly report on portal is as follows: 5.1.4.1. Log on to SEBI Portal at https://siportal.sebi.gov.in using the Username and Password provided at the time of Registration/ Renewal as a portfolio manager. 5.1.4.2. Select the portfolio manager tab 5.1.4.3. Select the link: PM Monthly Report 5.1.4.4. Fill the data in the format provided 5.1.4.5. Save the data and then Submit 57 SEBI/IMD/PMS/CIR-3/2009 dated June 11, 2009 58 Revised format as per SEBI circular SEBI/HO/IMD/IMD-I/DOF1/P/CIR/2021/0000000679 dated December 10, 2021 to include details of Co-investment Portfolio Management services offered by Portfolio Manager 59 SEBI/HO/IMD/DF1/CIR/P/2020/26 dated February 13, 2020 Page 45 of 175 à¤à¤¾à¤°à¤¤à¥€à¤¯ पà¥à¤°à¤¤à¤¿à¤à¥‚ति और विनिमय बोरà¥à¤¡ Securities and Exchange Board of India 5.1.5. In terms of the PM Regulations60, Compliance Officer of the portfolio managers shall also be responsible for ensuring compliance with this Master Circular. 5.2. S....
X X X X Extracts X X X X
X X X X Extracts X X X X
....t should reach SEBI within thirty days from the end of the financial year. 5.2.3. Failure to submit reports as mentioned in this master circular shall constitute a default and render the Portfolio Managers liable for action under the Intermediaries Regulations. 5.3. Firm-level performance reporting by Portfolio Managers63 5.3.1. The firm-level performance data of Portfolio Managers shall be audited 63 Inserted by SEBI/HO/IMD/DF1/CIR/P/2020/26 dated February 13, 2020 & SEBI/HO/IMD/IMD-PoD- 1/P/CIR/2023/133 dated August 02, 2023 Page 47 of 175 à¤à¤¾à¤°à¤¤à¥€à¤¯ पà¥à¤°à¤¤à¤¿à¤à¥‚ति और विनिमय बोरà¥à¤¡ Securities and Exchange Board of India annually. Confirmation of compliance with paragraph 4.5.3 of this Master Circular shall be reported to SEBI within sixty days of end of each financial year. The said report to SEBI shall be certified by the Directors/Partners of the Portfolio Manager or by person(s) authorized by the Board of Directors/Partners of the Portfolio Manager. 5.3.2. Accordingly, Portfolio Managers are required to consider all clien....
X X X X Extracts X X X X
X X X X Extracts X X X X
....ient Capital Transactions 6 Client Expense Master 7 PM Holding Master 8 PM Operating Expense Page 49 of 175 à¤à¤¾à¤°à¤¤à¥€à¤¯ पà¥à¤°à¤¤à¤¿à¤à¥‚ति और विनिमय बोरà¥à¤¡ Securities and Exchange Board of India 9 PM Pool Account Master 10 PM Associated Security Details 5.4.2. The data to be submitted by Portfolio Managers in the aforementioned reporting formats is prescribed in Annexure 5B. 5.4.3. Portfolio Managers shall submit data as per the specified formats for all its clients on quarterly basis within 10 days from end of the quarter. Day-wise data shall be furnished for table headings: "Client Folio AUM" and "Client Holding Master". 5.4.4. In their first time reporting, Portfolio Managers shall submit data for all their clients from April 01, 2020 to September 30, 2023. 5.4.5. Details of the requirements prescribed under various clauses of this Master Circular that are covered through the reporting formats, as mentioned in the paragraph 5.4.1 above, are specified in Annexure 5C. 5.4.6. [Any change in the prescribed formats shall ....
X X X X Extracts X X X X
X X X X Extracts X X X X
..../HO/IMD/POD- II/P/OW/2023/12814/1 dated March 29, 2023 Page 51 of 175 à¤à¤¾à¤°à¤¤à¥€à¤¯ पà¥à¤°à¤¤à¤¿à¤à¥‚ति और विनिमय बोरà¥à¤¡ Securities and Exchange Board of India return of the benchmark(s) selected shall also be presented separately. Following disclaimer must accompany this disclosure: "Please note that performance of your portfolio may vary from that of other investors and that generated by the Investment Approach across all investors because of 1) the timing of inflows and outflows of funds; and 2) differences in the portfolio composition because of restrictions and other constraints." 5.6.3. The following shall not be mentioned or implied in performance reporting or in any other communication in any form by the Portfolio Managers: 5.6.3.1. Any other categorization/ classification of IAs, except for the Strategy that they are tagged to. 5.6.3.2. Model Portfolio returns 5.6.3.3. The performance of one or more cherry-picked investor(s) However, aggregated performance statistics of all investors in an IA may be used by a Port....
X X X X Extracts X X X X
X X X X Extracts X X X X
....ूति और विनिमय बोरà¥à¤¡ Securities and Exchange Board of India subject to verification of compliance with the above conditions in the annual audit under Regulation 30 of the PM Regulations. 5.6.9. Portfolio Managers shall not advertise/ publish/ mention to any entity other than those belonging to the investor category to which said Investment Approach is offered the returns of the Investment Approaches where exception as above has been exercised. Portfolio Managers may, however, include the assets managed in such Investment Approaches in their total AUM when communicating publicly as well as in regulatory reporting. 5.6.10. Letters issued to APMI with respect to Performance Benchmarking are enclosed under 'Policy related letters/emails issued by SEBI' Page 54 of 175 à¤à¤¾à¤°à¤¤à¥€à¤¯ पà¥à¤°à¤¤à¤¿à¤à¥‚ति और विनिमय बोरà¥à¤¡ Securities and Exchange Board of India 6. FEES AND CHARGES 6.1. Regulation of Fees and Charges 6.1.1. The inter se relationship between the por....
X X X X Extracts X X X X
X X X X Extracts X X X X
....charged. For the purpose of charging performance fee, the frequency shall not be less than quarterly. The portfolio manager shall charge performance based fee only on increase in portfolio value in excess of the previously achieved high water mark. Illustration: Consider that frequency of charging of performance fees is annual. A client's initial contribution is Rs.50,00,000, which then rises to Rs.60,00,000 in its first year; a performance fee/ profit sharing would be payable on the Rs.10,00,000 return. In the next year the portfolio value drops to Rs.55,00,000 hence no performance fee would be payable. If in the third year the Portfolio rises to Rs.65,00,000, a performance fee/profit sharing would be payable only on the Rs.5,00,000 profit which is portfolio value in excess of the previously achieved high 75 SEBI/HO/IMD/IMD-I/DOF1/P/CIR/2021/0000000679 dated December 10, 2021 Page 56 of 175 à¤à¤¾à¤°à¤¤à¥€à¤¯ पà¥à¤°à¤¤à¤¿à¤à¥‚ति और विनिमय बोरà¥à¤¡ Securities and Exchange Board of India water mark of Rs.60,00,000, rather than on the full return durin....
X X X X Extracts X X X X
X X X X Extracts X X X X
....CIR/2021/693 dated December 21, 2021 79 SEBI Cir. /IMD/DF/13/2010 dated October 5, 2010 80 Regulation 22(2)(m) of the SEBI (Portfolio Managers) Regulations, 2020 Page 58 of 175 à¤à¤¾à¤°à¤¤à¥€à¤¯ पà¥à¤°à¤¤à¤¿à¤à¥‚ति और विनिमय बोरà¥à¤¡ Securities and Exchange Board of India 7. GRIEVANCE REDRESSAL 7.1. Dispute Resolution81 7.1.1. The PM Regulations82 provide for settlement of grievances/disputes and provision for arbitration in the portfolio manager - client agreement. 7.1.2. In case of any dispute regarding fees and charges, the same shall be referred to arbitration for settlement as per the terms of the agreement, under the Arbitration and Conciliation Act, 1996. 7.2. Disclosure of Investor Complaints by Portfolio Managers on their websites83 7.2.1. In order to enhance transparency in the Investor Grievance Redressal Mechanism, all Portfolio Managers on a monthly basis shall disclose on their websites, the data pertaining to all complaints including SCORES complaints received by them in the format mentioned in Annexure 7A of this Master Circ....
X X X X Extracts X X X X
X X X X Extracts X X X X
....lications Online Process for Fresh Registration a. Log-in ID and Password will be generated on receipt of a fresh application for registration as a Portfolio Manager. b. The URL of the SEBI portal, the Log-in ID and Password will be e-mailed to the Compliance Officer or the Principal Officer only. c. On receipt of the Log-in ID and Password the applicant should fill up all the details by clicking "Fresh Registration" under the tab "Portfolio Manager" given on the SEBI Intermediary Portal ("SI Portal"). d. All instructions on how to fill the details under every tab should be read before filling the online form. The same can be accessed by clicking the "Blue Question Mark" on the top right hand corner of every page. e. The details filled under every tab should be saved by clicking on the "Saved Draft" button as soon as a particular tab is completely filled up. f. Once all the details are filled up, the applicant should submit the online application form by clicking the "Final Submit" button. g. After SEBI approval, the applicant will be required to fill the fee details. The same will be sent through a mail which can be accessed by clicking the link "My Worklis....
X X X X Extracts X X X X
X X X X Extracts X X X X
....ntain any statement, promise or forecast which is untrue or misleading. 1.2. An advertisement shall be considered to be misleading if it contains - (i) Statements made about the performance or activities of the Portfolio Manager in the absence of necessary explanatory or qualifying statements, which may give an exaggerated picture of the performance or activities of the Portfolio Manager, than what it really is. (ii) An inaccurate portrayal of the past performance or portrayal in a manner which implies that past gains or income will be repeated in future. 1.3. The advertisement shall not be so designed in content and format or in print as to be likely to be misunderstood, or likely to disguise the significance of any statement. Advertisement shall not contain statements which directly or by implication or by omission mislead the investor. Page 63 of 175 à¤à¤¾à¤°à¤¤à¥€à¤¯ पà¥à¤°à¤¤à¤¿à¤à¥‚ति और विनिमय बोरà¥à¤¡ Securities and Exchange Board of India 1.4. The publicity literature should contain only information, the details of which are contained....
X X X X Extracts X X X X
X X X X Extracts X X X X
....hall never form the basis for recommending Portfolio Management Services. vii. Be fully conversant with the Disclosure Document, Investment Approaches, fees and charges and the terms of agreement to be entered between the client and the Portfolio Manager. viii. Disclose to the clients all material information including the details of distribution commissions for various Investment Approaches. ix. Assist clients in completing Know Your Client ("KYC") and In-Person Verification related procedures. X. Provide full and latest information about investment approaches and also highlight the assumptions made in performance calculations, risk assessments, performance projections etc., if any, for such investment approaches. Page 65 of 175 à¤à¤¾à¤°à¤¤à¥€à¤¯ पà¥à¤°à¤¤à¤¿à¤à¥‚ति और विनिमय बोरà¥à¤¡ Securities and Exchange Board of India xi. Inform the clients about the risks and level of control over the administration of Portfolio associated with the type of Portfolio Management Services offered (i.e. Discretionary, Non-discretionary or Advisory). xii.....
X X X X Extracts X X X X
X X X X Extracts X X X X
.... from the suggested framework, reasons for such deviations should also be provided in the policy document. The policy document should be reviewed by the Board or equivalent body of the Portfolio Manager at least once annually with the view to strengthen and improve its cyber security and cyber resilience framework. 3. The cyber security and cyber resilience policy should include the following process to identify, assess, and manage cyber security risks associated with processes, information, networks, and systems; a. 'Identify' critical IT assets and risks associated with such assets, b. 'Protect' assets by deploying suitable controls, tools, and measures, Page 67 of 175 à¤à¤¾à¤°à¤¤à¥€à¤¯ पà¥à¤°à¤¤à¤¿à¤à¥‚ति और विनिमय बोरà¥à¤¡ Securities and Exchange Board of India c. 'Detect' incidents, anomalies, and attacks through appropriate monitoring tools/processes, d. 'Respond' by taking immediate steps after identification of the incident, anomaly, or attack, e. 'Recover' from incident through incident management, disaster recovery, and business cont....
X X X X Extracts X X X X
X X X X Extracts X X X X
.... 10. Portfolio Managers should define the responsibilities of its employees, outsourced staff, and employees of vendors and other entities, who may have access to or use systems/networks of the Portfolio Managers, towards ensuring the goal of cyber security. Identify 11. Portfolio Manager shall identify and classify critical assets based on their sensitivity and criticality for business operations, services, and data management. The critical assets shall include business-critical systems, internet-facing applications/ systems, systems that contain sensitive data, sensitive personal data, sensitive financial data, Personally Identifiable Information (PII) data, etc. All the ancillary systems used for accessing/ communicating with critical systems either for operations or maintenance shall also be classified as critical assets. The Board or equivalent body of the Portfolio Manager shall approve the list of critical assets. Page 69 of 175 à¤à¤¾à¤°à¤¤à¥€à¤¯ पà¥à¤°à¤¤à¤¿à¤à¥‚ति और विनिमय बोरà¥à¤¡ Securities and Exchange Board of India To this end, Portfo....
X X X X Extracts X X X X
X X X X Extracts X X X X
....rivileged users, periodic review of privileged users' activities, disallowing privileged users from accessing systems logs in which their activities are being captured, strong controls over remote access by privileged users, etc. 19. Account access lock policies after failure attempts should be implemented for all accounts. 20. Employees and outsourced staff such as employees of vendors or service providers, who may be given authorized access to the Portfolio Manager's critical systems, networks, and other computer resources, should be subject to stringent supervision, monitoring, and access restrictions. 21. Two-factor authentication at log-in should be implemented for all users that connect using online/ internet facility. Page 71 of 175 à¤à¤¾à¤°à¤¤à¥€à¤¯ पà¥à¤°à¤¤à¤¿à¤à¥‚ति और विनिमय बोरà¥à¤¡ Securities and Exchange Board of India 22. Portfolio Managers should formulate an Internet access policy to monitor and regulate the use of internet and internet based services such as social media sites, cloud-based internet storage sites, etc. 23. Pr....
X X X X Extracts X X X X
X X X X Extracts X X X X
.... not compromised during the process of exchanging and transferring information with external parties. 32. The information security policy should also cover use of devices such as mobile phone, faxes, photocopiers, scanners, etc. that can be used for capturing and transmission of data. 33. Portfolio Managers should allow only authorized data storage devices through appropriate validation processes. Hardening of Hardware and Software Page 73 of 175 à¤à¤¾à¤°à¤¤à¥€à¤¯ पà¥à¤°à¤¤à¤¿à¤à¥‚ति और विनिमय बोरà¥à¤¡ Securities and Exchange Board of India 34. Only a hardened and vetted hardware / software should be deployed by the Portfolio Managers. During the hardening process, Portfolio Managers should inter-alia ensure that default passwords are replaced with strong passwords and all unnecessary services are removed or disabled in equipments/software. 35. All open ports which are not in use or can potentially be used for exploitation of data should be blocked. Other open ports should be monitored and appropriate measures should be taken to secure the por....
X X X X Extracts X X X X
X X X X Extracts X X X X
....ed organizations for conducting VAPT. The final report on said VAPT shall be submitted to SEBI after approval from Technology Committee of respective Portfolio Manager, within 1 month of completion of VAPT activity. 41. Any gaps or vulnerabilities detected shall be remedied on immediate basis and compliance of closure of findings identified during VAPT shall be submitted to SEBI within 3 months post the submission of final VAPT report. Page 75 of 175 à¤à¤¾à¤°à¤¤à¥€à¤¯ पà¥à¤°à¤¤à¤¿à¤à¥‚ति और विनिमय बोरà¥à¤¡ Securities and Exchange Board of India 42. In addition, Portfolio Managers shall perform vulnerability scanning and conduct penetration testing prior to the commissioning of a new system which is a critical system or part of an existing critical system. Monitoring and Detection 43. Portfolio Managers should establish appropriate security monitoring systems and processes to facilitate continuous monitoring of security events and timely detection of unauthorized or malicious activities, unauthorized changes, unauthorized access and unauthorized c....
X X X X Extracts X X X X
X X X X Extracts X X X X
....ported to CERT-In in accordance with the guidelines/ directions issued by CERT-In from time to time. Additionally, the Portfolio Manager, whose systems have been identified as "protected system" by NCIIPC, shall also report the incident to NCIIPC. The quarterly reports containing information on cyber- attacks, threats, cyber-incidents, and breaches experienced by Portfolio Manager and measures taken to mitigate vulnerabilities, threats and attacks including information on bugs/ vulnerabilities/ threats that may be useful for other Portfolio Managers shall be submitted to SEBI within 15 days from the quarter ended June, September, December and March of every year. Page 77 of 175 à¤à¤¾à¤°à¤¤à¥€à¤¯ पà¥à¤°à¤¤à¤¿à¤à¥‚ति और विनिमय बोरà¥à¤¡ Securities and Exchange Board of India The above information/ reports shall be shared through the dedicated e-mail ids: [email protected] and [email protected] 52. Such details as are felt useful for sharing with other Portfolio Managers in masked and anonymous manner shall be shared using mechanism to b....
X X X X Extracts X X X X
X X X X Extracts X X X X
....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% 3. The client may choose not to invest in the securities of associates/related parties of the Portfolio Manager. Further, the client may choose a limit lower than the limits prescribed at paragraph 2 above. 4. The risks and conflict of interest associated with investment by the Portfolio Manager in the securities of its associates/related parties are as under: Risks: Conflict of Interest: 5. In case the client wants the Portfolio Manager to invest in the securities issued by associated/related parties of Portfolio Manager and provides the consent for Page 80 of 175 à¤à¤¾à¤°à¤¤à¥€à¤¯ पà¥à¤°à¤¤à¤¿à¤à¥‚ति और विनिमय बोरà¥à¤¡ Securities and Exchange Board of India the same, the investments shall be subject to the following limits: Security Limit for investment in single associate/related party ....
X X X X Extracts X X X X
X X X X Extracts X X X X
....st year/ in case of new portfolio managers indicative charges as a percentage of assets under management (e.g. 2%) e. Management fee (e.g. 2%) f. Performance fee (e.g. 20% of profits over hurdle rate) g. The frequency of calculating all fees is annual. Portfolio performance: Gain of 20% Nature of Fees Amount in Rs. Amount in Rs. Capital Contribution 50,00,00086 XX 60,00,000 Less: Any other fees (please enumerate) Assets under Management 50,00,000 Add: Profits on investment during the year @ 20% on assets under management 10,00,000 Gross value of the portfolio at the end of the year 1,00,000 Less: Brokerage/DP charges/any other similar charges (e.g. 2% of Rs.50,00,000) Less: Management Fees (if any) (e.g. 2% of Rs.50,00,000) 1,00,000 Less: Performance fees (if any) (e.g 20% of Rs.5,00,000 - working given below) 1,00,000 XX Less: Any other fees (please enumerate) 84 SEBI Cir. /IMD/DF/13/2010 dated October 5, 2010 85 Clause 3 (v) of SEBI/HO/IMD/DF1/CIR/P/2020/26 dated February 13, 2020 86 Illustration has been suitably updated to consider minimum investment amount of Rs.50 lakh. Page 83 of 175 à¤à¤¾à¤°à¤¤à¥€à¤¯ à....
X X X X Extracts X X X X
X X X X Extracts X X X X
....e: The frequency of charging various fees may be specified for every type of fees in the illustration Page 85 of 175 à¤à¤¾à¤°à¤¤à¥€à¤¯ पà¥à¤°à¤¤à¤¿à¤à¥‚ति और विनिमय बोरà¥à¤¡ Securities and Exchange Board of India Annexure 4B: Format of Investor Charter in Respect of Portfolio Management Services A. Vision and Mission Statements for investors. Vision: To implement diligently researched customised investment strategies which help investors meet their long-term financial goals in a risk appropriate manner. Mission: To ensure that the Portfolio Management Services industry provides a viable investment avenue for wealth creation by adopting high levels of skill, integrity, transparency and accountability. B. Details of business transacted by the organization with respect to the investors. a. appropriate risk profiling of investors b. to provide Disclosure Document to investors c. executing the PMS agreement d. Making investment decisions on behalf of investors (discretionary) or investment decisions taken at the discretion of the ....
X X X X Extracts X X X X
X X X X Extracts X X X X
....ªà¥à¤°à¤¤à¤¿à¤à¥‚ति और विनिमय बोरà¥à¤¡ Securities and Exchange Board of India c. opening demat account and funding of the same from the investor's verified bank account and/or transfer of securities from verified demat account of the investor and d. Mapping the said demat account with Custodian. iv. Ongoing activities a. To provide periodic statements to investors as provided under the PM Regulations 2020 and other SEBI notifications and circulars ("PM Regulations") and b. Providing each client an audited account statement on an annual basis which includes all the details as required under the PM Regulations. v. Fees and Expenses Charging and disclosure of appropriate fees & expenses in accordance with the PM Regulations. vi. Closure and Termination Upon termination of PMS Agreement by either party, the securities and the funds lying in the account of the investor shall be transferred to the verified bank account/ demat account of the investor. vii. Grievance Redressal Addressing in a time bound manner investor's queries, service requests and grievances,....
X X X X Extracts X X X X
X X X X Extracts X X X X
....isclosure document. 8 Disclosure about latest networth of portfolio manager and total AUM. Disclosure of portfolio manager's total AUM - monthly to SEBI Disclosure of latest networth should be done in the disclosure document whenever there are any material changes. 9 Intimation of type of PMS account - discretionary. At the time of client signing the agreement; this information should be a part of the account opening form. 10 Intimation of type of PMS account - non discretionary. At the time of client signing the agreement; this information should be a part of the account opening form. 11 Intimation to client what discretionary account entails and powers that can be exercised by portfolio manager. At the time of client signing the agreement; this information should be a part of the account opening form. Page 90 of 175 à¤à¤¾à¤°à¤¤à¥€à¤¯ पà¥à¤°à¤¤à¤¿à¤à¥‚ति और विनिमय बोरà¥à¤¡ Securities and Exchange Board of India Sr. No. Service / Activity Timeline 12 Intimation to client what nondiscretionary account entails and powers that can be exercised....
X X X X Extracts X X X X
X X X X Extracts X X X X
.... the clients in the prescribed format not later than on a quarterly basis. Page 92 of 175 à¤à¤¾à¤°à¤¤à¥€à¤¯ पà¥à¤°à¤¤à¤¿à¤à¥‚ति और विनिमय बोरà¥à¤¡ Securities and Exchange Board of India Sr. No. Service / Activity Timeline 26 Frequency of intimation of transactions undertaken in portfolio account. Not later than on a quarterly basis or upon clients' request. 27 Intimation regarding conflict of interest in any transaction. The portfolio manager should provide details of related party transactions and conflict of interest in the Disclosure Document which should be available on website of portfolio manager at all times. 28 Timeline for providing disclosure document to investor. The latest disclosure document should be provided to investors prior to account opening and the latest disclosure documents should be available on website of portfolio manager at all times. 29 Intimation to investor about details of bank accounts where client funds are kept. Within 3 days of PMS and demat account 30 Redressal of investor grievances. Within 30 days, subje....
X X X X Extracts X X X X
X X X X Extracts X X X X
....the 'Risk Questionnaire' shall help the PMS provider properly assess the risk profile of the investor. 6. Thorough study of the quarterly statements sent by the PMS provider to the investor intimating him about the portfolio's absolute and relative performance, its constituents and its risk profile. 7. Ensure providing complete details of negative list of securities as part of freeze instructions at the time of entering into PMS agreement and every time thereafter for changes, if any, in a timely manner. 8. To update the PMS provider in case of any change in the KYC documents and personal details and to provide the updated KYC along with the required proof. Page 95 of 175 à¤à¤¾à¤°à¤¤à¥€à¤¯ पà¥à¤°à¤¤à¤¿à¤à¥‚ति और विनिमय बोरà¥à¤¡ Securities and Exchange Board of India Annexure 4C: Format for disclosure of Performance of the Portfolio Manager (As per Regulation 22 (4) (e) of SEBI (Portfolio Managers) Regulations, 2020) Current Year (April 01 - as on date) Year 1 (Financial year) Year 2 (Financial year) Year 3 (Financial year) Portfolio Per....
X X X X Extracts X X X X
X X X X Extracts X X X X
.... based on daily average E. Performance Data87 Table 1 Name of the Portfolio Manager Registration number TWRR Returns (%) Strategy Investment Approach AUM (INR Cr.) 1 Month 3 Months 6 months 1 Year 2 Year 3 Year 4 Year 5 Year Since Inception Strategy 1 IA 1 Benchmark 1 IA 2 Benchmark 2 Strategy 2 IA 3 Benchmark 3 Strategy 3 IA 4 Benchmark 1 IA 5 Benchmark 3 IA 6 Benchmark 1 87 Updated vide SEBI Circular No. SEBI/HO/IMD/IMD-PoD-2/P/CIR/2022/172 dated December 16, 2022 Page 98 of 175 à¤à¤¾à¤°à¤¤à¥€à¤¯ पà¥à¤°à¤¤à¤¿à¤à¥‚ति और विनिमय बोरà¥à¤¡ Securities and Exchange Board of India Table 2 Name of the Portfolio Manager Portfolio Turnover Ratio Investment Approach 1 month 1 year IA 1 IA 2 IA 3 IA 4 IA 5 IA 6 II. Data for Non- Discretionary Services F. Break-up of clients of the Portfolio Manager Particulars Domestic Clients Foreign Clients PF/ EPFO Corporates Non- Corporates Non Residents FPI Others Total No. of unique Clients as on last day of the month Assets under Mana....
X X X X Extracts X X X X
X X X X Extracts X X X X
....s Foreign Clients Total Clients Corporates Non- Corporates Corporates Non Residents Others No. of unique Clients as on last day of the month Value of the Assets for which Co-investment Services are being given (Amount in INR crores) M. Break-up of assets under management of the Portfolio Manager Funds In- flow in the month Funds Out- flow in the month Assets Under Management as on last day of the month (in INR crores) Equity Plain Debt Structured Debt Others Total Note: AUM may be calculated on cost basis or in any manner as may be specified by SEBI Page 101 of 175 à¤à¤¾à¤°à¤¤à¥€à¤¯ पà¥à¤°à¤¤à¤¿à¤à¥‚ति और विनिमय बोरà¥à¤¡ Securities and Exchange Board of India V. Data on Complaints Type of Client Total No. of complaints Pending at the beginning of the month Received during the month Resolved during the month Pending at the end of the month Domestic - PF/ EPFO Domestic Corporates Domestic Non- Corporates Foreign - NR Foreign - FPI Foreign -Others Total Note: Data on investor complaints registered through SC....
X X X X Extracts X X X X
X X X X Extracts X X X X
....तिà¤à¥‚ति और विनिमय बोरà¥à¤¡ Securities and Exchange Board of India # Tag Data Type Mandator y Allowed Character Comments 13 STRING Y Maximum length allowed: 20 SEBI SCORES registration number 14 STRING N Maximum length allowed: 500 Web link for direct on- boarding of client 15 STRING N Maximum length allowed: 100 Name of Front Office Trading System 16 STRING N Maximum length allowed: 100 Name of Back Office Accounting System or Fund accountant 17 DATE N YYYY-MM-DD Date of approval of application for surrender by SEBI 18 FLOAT Y DECIMAL(24,4) Net worth of PM as on March 31 of the preceding financial year in INR. e.g. For report of May-2023, Net worth as on 31-03-2023 has to be provided). Till the time audited Financial Statements are not released, Mandator y Page 105 of 175 à¤à¤¾à¤°à¤¤à¥€à¤¯ पà¥à¤°à¤¤à¤¿à¤à¥‚ति और विनिमय बोरà¥à¤¡ Securities and Exchange Board of India # Tag Data Type Mandator y Allowed Character Comments ....
X X X X Extracts X X X X
X X X X Extracts X X X X
....dia # Tag Data Type Mandator y Allowed Character Comments Large Value Accredited Co-investment Not Applicable 7 STRING Y Discretionary Non-Discretionary Advisory 8 STRING Y Maximum length allowed: 100 9 STRING N Maximum length allowed: 35 10 STRING N Maximum length allowed: 35 11 STRING Y Maximum length allowed: 300 12 STRING N Maximum length allowed: 100 13 STRING N Maximum length allowed: 35 14 INT N Length allowed: 4 to 6 Mandator y Page 109 of 175 à¤à¤¾à¤°à¤¤à¥€à¤¯ पà¥à¤°à¤¤à¤¿à¤à¥‚ति और विनिमय बोरà¥à¤¡ Securities and Exchange Board of India # Tag Data Type Mandator y Allowed Character Comments 15 STRING N Maximum length allowed: 35 16 STRING N Length allowed: 7 to 15 Please specify STD/ISD Codes. Acceptable pattern is as follows: 1st char (optional)-> + or 0 2nd char -> 1 - 9 3rd char onwards -> 0 - 9 Acceptable values are: +123456 1234567 0123456789 Not acceptable: 00123456 +012345678 17 STRING N Maximum length allowed: 100 18 STRING N Maximum length allowed: 150 Second Holder ....
X X X X Extracts X X X X
X X X X Extracts X X X X
.... 35 DATE N YYYY-MM-DD Mandatory for inactive accounts. If account inactive on account of complete withdrawal of funds, the date as mentioned written request has to be mentioned. 36 STRING N Maximum length allowed: 200 Reason for tagging account as inactive. Mandator y Page 113 of 175 à¤à¤¾à¤°à¤¤à¥€à¤¯ पà¥à¤°à¤¤à¤¿à¤à¥‚ति और विनिमय बोरà¥à¤¡ Securities and Exchange Board of India # Tag Data Type Mandator y Allowed Character Comments Reasons may be one of the below: 1. Insufficient funds and client not reachable 2. Demat account opened but no initial fund transfer. 3. Written instruction received for complete redemption of funds. 4. Others - please specify 37 DATE N YYYY-MM-DD The date of full and final settlement shall be reported as Account Closure Date. Mandator y Page 114 of 175 à¤à¤¾à¤°à¤¤à¥€à¤¯ पà¥à¤°à¤¤à¤¿à¤à¥‚ति और विनिमय बोरà¥à¤¡ Securities and Exchange Board of India PMS_Inspection_Client_Foli....
X X X X Extracts X X X X
X X X X Extracts X X X X
....client has given permission for investments in associates/related parties 12 FLOAT N DECIMAL(5,2) Percent of AUM which can be invested by PM in the equity shares of one associate/related party. Only required if value is true in #11. 13 FLOAT N DECIMAL(5,2) Percent of AUM which can be invested by PM in the equity shares of all its associate/related party. Only required if value is true in #11. Mandator y Y Y Page 117 of 175 à¤à¤¾à¤°à¤¤à¥€à¤¯ पà¥à¤°à¤¤à¤¿à¤à¥‚ति और विनिमय बोरà¥à¤¡ Securities and Exchange Board of India # Tag Data Type Mandator y Allowed Character Comments 14 FLOAT N DECIMAL(5,2) Percent of AUM which can be invested by PM in the debt and hybrid securities of one associate/related party. Only required if value is true in #11. 15 FLOAT N DECIMAL(5,2) Percent of AUM which can be invested by PM in the debt and hybrid securities of all its associate/related party. Only required if value is true in #11. 16 FLOAT N DECIMAL(5,2) Percent of AUM which can be invested by PM in the equity, debt and hybrid securities of....
X X X X Extracts X X X X
X X X X Extracts X X X X
.... 4 FLOAT N DECIMAL(24,4) No. of units under the folio if units are maintained by PMS 5 FLOAT Y DECIMAL(24,4) AUM of the folio in INR. For holidays and weekends, provide AUM Mandatory Page 121 of 175 à¤à¤¾à¤°à¤¤à¥€à¤¯ पà¥à¤°à¤¤à¤¿à¤à¥‚ति और विनिमय बोरà¥à¤¡ Securities and Exchange Board of India of preceding working day. Page 122 of 175 à¤à¤¾à¤°à¤¤à¥€à¤¯ पà¥à¤°à¤¤à¤¿à¤à¥‚ति और विनिमय बोरà¥à¤¡ Securities and Exchange Board of India 1.5. PMS_Inspection_Client_Cap_Transactions Client_Cap_Transactions [] - None or more occurrences allowed Important Note: Kindly ensure that each of the UNIQUE_CLIENT_CODE and CLIENT_FOLIO_NO combination entered in this report should exactly match with some entry of UNIQUE_CLIENT_CODE and CLIENT_FOLIO_NO present in the CLIENT_FOLIO_MASTER report # Tag Data Type Mandatory Allowed Character Comments 1 STRING Y Maximum length allowed: 20 Unique client code 2 STRING Y Maxim....
X X X X Extracts X X X X
X X X X Extracts X X X X
....¤° विनिमय बोरà¥à¤¡ Securities and Exchange Board of India # Tag Data Type Mandatory Allowed Character Comments 5 STRING Y Management Fees (fixed) Performance Fees (variable) Exit Load Account Opening Charges (including stamp duty) Audit Fee Bank Charges Fund Accounting Charges Custody Fee Demat Charges Broking Fees Other Miscellaneous Expense In case of PMS Fees, either Management Fees (fixed) or Performance Fees (variable) or Exit Load. In case of Operating Expenses: (Account Opening charges including stamp duty / Audit Fee / Bank charges / Fund Accounting charges / Custody Fee / Demat charges / Broking Fees or other miscellaneous expense) Page 126 of 175 à¤à¤¾à¤°à¤¤à¥€à¤¯ पà¥à¤°à¤¤à¤¿à¤à¥‚ति और विनिमय बोरà¥à¤¡ Securities and Exchange Board of India # Tag Data Type Mandatory Allowed Character Comments 6 FLOAT Y DECIMAL(20,4) Amount of the expense charged in INR Page 127 of 175 à¤à¤¾à¤°à¤¤à¥€à¤¯ पà¥à¤°à¤¤à¤¿à¤à¥‚ति और....
X X X X Extracts X X X X
X X X X Extracts X X X X
.... is listed 12 STRING N REFER ANNEXURE-A Security rating mandatory in case of Debt/ Hybrid securities 13 STRING N REFER ANNEXURE-B Rating agency mandatory for debt / hybrid securities 14 FLOAT N DECIMAL(30,6) Quantity 15 FLOAT N DECIMAL(30,6) Market Price or valuation price of the security in INR 16 FLOAT N DECIMAL(30,6) Market Value of securities in INR Mandator y Y Y Page 130 of 175 à¤à¤¾à¤°à¤¤à¥€à¤¯ पà¥à¤°à¤¤à¤¿à¤à¥‚ति और विनिमय बोरà¥à¤¡ Securities and Exchange Board of India # Tag Data Type Mandator y Allowed Character Comments 17 DATE N YYYY-MM-DD Maturity Date (in case of debt instrument) 18 STRING N Put Call Option Type (Call or Put) Page 131 of 175 à¤à¤¾à¤°à¤¤à¥€à¤¯ पà¥à¤°à¤¤à¤¿à¤à¥‚ति और विनिमय बोरà¥à¤¡ Securities and Exchange Board of India PMS_Inspection_PM_Operating_Expense 1.8. PMS_Expense [ ] - None or more occurrences allowed Important Note: For ease of reporting, for ea....
X X X X Extracts X X X X
X X X X Extracts X X X X
....ich: . the issuer of the security was an associate of the Portfolio Manager (as specified in sub-section (6) of section 2 of the Companies Act, 2013) or, . the issuer of the security was related to Portfolio Manager as per the definition provided in Regulation 2(1)(pa) of the SEBI (Portfolio Managers) Regulations, 2020. # Tag Data Type Mandatory Allowed Character Comments 1 STRING Y Equity Derivatives Investment Type 2 STRING Y Equity Shares Futures Options Asset Type (For Equity: Equity Shares For Derivative: Futures or Options) 3 STRING N Maximum length allowed: 12 ISIN of security. Y Y Page 135 of 175 à¤à¤¾à¤°à¤¤à¥€à¤¯ पà¥à¤°à¤¤à¤¿à¤à¥‚ति और विनिमय बोरà¥à¤¡ Securities and Exchange Board of India 4 STRING N Maximum length allowed: 20 Internal code of the security for which there is no ISIN. 5 DATE Y YYYY-MM-DD Y Page 136 of 175 à¤à¤¾à¤°à¤¤à¥€à¤¯ पà¥à¤°à¤¤à¤¿à¤à¥‚ति और विनिमय बोरà¥à¤¡ Secur....
X X X X Extracts X X X X
X X X X Extracts X X X X
....ortfolio 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. Client Folio Master, Client Folio AUM and Client Holding Master 3.6.2 Portfolio Managers offering discretionary portfolio management services shall not make any investment in below investment grade securities. Client Holding Master 3.6.3 Portfolio Managers offering non-discretionary portfolio management services shall not make any investment in below investment grade listed securities. However, Portfolio Manager may invest up to 10% of the assets under management of such clients in unlisted unrated securities of issuers other than associates/related parties of Portfolio Manager. Client Folio AUM and Client Holding Master Page 139 of 175 à¤à¤¾à¤°à¤¤à¥€à¤¯ पà¥à¤°à¤¤à¤¿à¤à¥‚ति और विनिमय बोरà¥à¤¡ Securities and Exchange Board of India Paragraph No. Requirement Table Reference 6.1.3.3 Operating expenses excluding brokerage, over and above the fees ch....
X X X X Extracts X X X X
X X X X Extracts X X X X
....f Assets Under Management (in Rs) (in Rs) Equity Plain Debt Structured Debt Equity Derivatives Commodity Derivatives Goods Mutual Funds Cash and equivalent Other Assets Total Note: (i) Portfolio Managers offering Co-investment services, may provide details as applicable, for assets permitted to be managed by them. Portfolio Summary Particulars (in Rs) Portfolio Value at the beginning of quarter Portfolio Value at the end of quarter Page 142 of 175 à¤à¤¾à¤°à¤¤à¥€à¤¯ पà¥à¤°à¤¤à¤¿à¤à¥‚ति और विनिमय बोरà¥à¤¡ Securities and Exchange Board of India For the quarter 1. Capital Inflow 2. Capital Outflow 3. Interest Income 4. Dividend Income 5. Other Income 6. Management Fee 7. Performance Fee 8. Expenses at actuals 9. Other expenses 10. Realized Gain/ Loss 11. Unrealized Gain/ Loss Commission paid to Distributor Brokerage paid Note: (i) Portfolio Managers offering Co-investment services, may provide details as applicable C. Performance of Portfolio Disclaimer: Per....
X X X X Extracts X X X X
X X X X Extracts X X X X
....proach, if any 2. With regard to debt securities, details of any delay in coupon payments, if any 3. With regard to debt securities, details of default, if any 4. With regard to portfolio allocation in equity and commodity derivatives, details of funds and securities held as collateral, if any. 5. Details of Other assets outstanding to be received in Clients account for more than 3 months from the due date Page 145 of 175 à¤à¤¾à¤°à¤¤à¥€à¤¯ पà¥à¤°à¤¤à¤¿à¤à¥‚ति और विनिमय बोरà¥à¤¡ Securities and Exchange Board of India Nature of Asset Outstanding amount (In Rs.) a. Coupon Payments b. Dividends c. Others Total 6. Investments in the securities of associates/related parties of Portfolio Manager: a. Transaction wise Sr. No. Issuer name Type of security ISIN Transaction wise Details Transaction Buy/sell Quantity Gross Net date transaction value (INR in crores) transaction value (INR in crores) b. Security wise Sr. No. Issuer Type of ISIN Security wise Details name security Investment Value of percentage percent....
X X X X Extracts X X X X
X X X X Extracts X X X X
....s on the last day of the month Trend of annual disposal of complaints SN Year Carried forward from Received Resolved ** Pending## previous year Page 148 of 175 à¤à¤¾à¤°à¤¤à¥€à¤¯ पà¥à¤°à¤¤à¤¿à¤à¥‚ति और विनिमय बोरà¥à¤¡ Securities and Exchange Board of India 1 2018-19 2 2019-20 3 2020-21 Grand Total ** Inclusive of complaints of previous years resolved in the current year. ## Inclusive of complaints pending as on the last day of the year. Page 149 of 175 à¤à¤¾à¤°à¤¤à¥€à¤¯ पà¥à¤°à¤¤à¤¿à¤à¥‚ति और विनिमय बोरà¥à¤¡ Securities and Exchange Board of India APPENDIX: LIST OF CIRCULARS RESCINDED Sr. No. Date of Circular Subject Circular Ref. No. 1. October 20, 1993 Format of Half Yearly Report and Guidelines for advertisement RPM circular No.1(93-94) 2. September 17, 2002 Clarification for definition of associates RPM CIRCULAR NO.1 (2002- 2003) 3. January 14, 2003 Application procedure for registration/ren....
X X X X Extracts X X X X
X X X X Extracts X X X X
..... February 13, 2020 Guidelines for Portfolio Managers SEBI/HO/IMD/DF1/CIR/P/2020/26 22. March 30, 2020 Relaxation in compliance with requirements pertaining to Portfolio Managers SEBI/HO/IMD/DF1/CIR/P/2020/57 23. September 09, 2020 Operating Guidelines for Portfolio Managers in International Financial Services Centre SEBI/HO/IMD/DF1/CIR/P/2020/169 24. January 08, 2021 Monthly Reporting of Portfolio Managers SEBI/HO/IMD/DF1/CIR/P/2021/02 25. May 12, 2021 Procedure for seeking prior approval for change in control of SEBI registered Portfolio Managers SEBI/HO/IMD/IMD- I/DOF1/P/CIR/2021/564 26. December 09, 2021 Transaction in Corporate Bonds through Request for Quote platform by Portfolio Management Services (PMS) SEBI/HO/IMD/IMD- I/DOF1/P/CIR/2021/678 27. December 10, 2021 Publishing of Investor Charter and disclosure of Investor Complaints by Portfolio Managers on their websites SEBI/HO/IMD/IMD- II_DOF7/P/CIR/2021/681 28. December 10, 2021 Clarification regarding amendment to SEBI (Portfolio Managers) Regulations, 2020 SEBI/HO/IMD/IMD- I/DOF1/P/CIR/2021/0000000679 Page 152 of 175 à¤à¤¾à¤°à¤¤à¥€à¤¯ पà¥à¤°à¤¤à¤¿à¤à....
X X X X Extracts X X X X
X X X X Extracts X X X X
.....2. Coordinate on an ongoing basis (once every quarter at minimum) with AMFI and prescribe standardized valuation norms got debt and money market securities which shall be same as the corresponding norms applicable to mutual funds as required in Para 2.7 of the Circular (reference: para 2.9.1 of this Master Circular). These valuation norms shall be followed by all the portfolio managers. 1.2.3. Empanel valuation agencies for the purpose of providing security level prices to Portfolio Managers as required in Para 2.8 of the Circular (reference: para 2.9.2 of this Master Circular). Portfolio Managers shall mandatorily use valuation services obtained only from one or more of such empaneled valuation agencies for the purpose of valuation of securities in portfolios managed by them. 1.2.4. Put in place necessary systems and resources to enable submission of monthly reporting by the Portfolio Managers as required in Para 2.15 of the Circular (reference: para 5.6.6 of this Master Circular). The templates of performance reporting have been provided in SEBI Circular nos. SEBI/HO/IMD/DF1/CIR/P/2020/26 dated February 13, 2020, SEBI/HO/IMD/DF1/CIR/P/2021/02 dated January 8, 2021 and S....
X X X X Extracts X X X X
X X X X Extracts X X X X
.... Page 155 of 175 à¤à¤¾à¤°à¤¤à¥€à¤¯ पà¥à¤°à¤¤à¤¿à¤à¥‚ति और विनिमय बोरà¥à¤¡ Securities and Exchange Board of India 50% Nifty 500 Index, 20% NIFTY 50 Arbitrage Index, 10% Gold, 10% 50% BSE 500 Index, 20% S&P BSE Arbitrage Rate Index, 10% Gold, 10% Multi Asset 4 Annexure - B: Format for Performance Report Card Quartile Analysis of {Name of IA} within {Name of Strategy} Strategy Period No. of IAs IA TWRR (%) Benchmark/ Index Return (%) IA Quartile TWRR (%)* 1st Quartile 2nd Quartile 3rd Quartile 1 year 50 20.38 48.15 Bottom quartile 70.40 55.88 37.10 2 years 45 9.34 26.58 Bottom Quartile 35.78 27.13 17.81 3 years 40 12.14 19.49 Third Quartile 23.43 18.54 12.13 5 years 35 10.94 10.45 Second Quartile 14.95 8.30 -0.10 7 years 25 11.21 12.18 Second Quartile 13.48 9.36 5.43 10 years 15 13.16 11.83 Top Quartile 13.11 8.87 6.42 * Time weighted rate of returns mentioned in these columns represent the minimum return for each quartile Page 156 of 175 à¤à¤¾à¤°à¤¤à¥€à¤¯ पà¥à¤°à¤¤à¤¿à¤....
X X X X Extracts X X X X
X X X X Extracts X X X X
.... definition of portfolio aggregates and its difference with TWRR. Both represent the same. 3. Clarification needed on whether portfolio of the clients who put negative constraint on stocks due to compliance stock concentration or religious reasons shall be considered for XIRR reporting. The portfolio of all clients needs to be considered while reporting XIRR. 4. Whether old performance to be carry forward after a change in benchmark to build credible and verifiable performance track record or grandfathered. In this regard, you are advised to clarify how it is proposed to represent old performance post transition to a new benchmark. An illustration may be provided in this regard. A certain timeline up to which the old performance may be represented or carried forward may be suggested with sufficient illustration. 5. Clarification regarding return in Table 1 of the Annexure 1 mentioned in the circular shall be different for different IAs of the portfolio manager. This is explicitly covered in the circular and the annexure to the same. SEBI has no further comment to offer. C. Others Page 158 of 175 à¤à¤¾à¤°à¤¤à¥€à¤¯ पà¥à¤°à¤¤à¤¿....
X X X X Extracts X X X X
X X X X Extracts X X X X
....be furnished to the client in terms of the PM Regulations and Circulars Page 160 of 175 à¤à¤¾à¤°à¤¤à¥€à¤¯ पà¥à¤°à¤¤à¤¿à¤à¥‚ति और विनिमय बोरà¥à¤¡ Securities and Exchange Board of India issued thereunder? 2. Whether Board of the Portfolio Manager has reviewed the compliance of regulations in their periodical meetings? 3. Whether there is a system of getting quarterly reports by compliance officer regarding compliance of SEBI Regulations and Guidelines and also that due diligence has been exercised by their officials in their operations and that the interests of investors are protected? 4. Whether Board of the Portfolio Manager has reviewed redressal of investors' grievances? 5. Whether advisory/ caution/ deficiency/ warning letters issued to the Portfolio Managers by SEBI have been placed before the Board of the Portfolio Manager? 6. Whether internal audit of Portfolio Manager has been conducted by a practicing Chartered Accountant ("CA") or Company Secretary ("CS") so as to judge the quality of internal procedures being followed by the Por....
X X X X Extracts X X X X
X X X X Extracts X X X X
....Reported performance data net of all fees and all expenses (including taxes). 3. Clearly disclosed any change in investment approach that may impact the performance of client portfolio, in the marketing material. 4. Ensured that performance reported in all marketing material and website of the Portfolio Manager is the same as that reported to SEBI. 5. Ensured that the aggregate performance of the Portfolio Manager (firm-level performance) reported in any document shall be same as the combined performance of all the portfolios managed by the Portfolio Manager 6. Provided a disclaimer in all marketing material that the performance related information provided therein is not verified by SEBI. 7. Carried out the audit of firm- level performance data in line with standard terms of reference specified by APMI. Page 163 of 175 à¤à¤¾à¤°à¤¤à¥€à¤¯ पà¥à¤°à¤¤à¤¿à¤à¥‚ति और विनिमय बोरà¥à¤¡ Securities and Exchange Board of India 8. Attached/submitted the audit report on firm-level performance data to SEBI. This certificate is issued in accordance with ....
X X X X Extracts X X X X
X X X X Extracts X X X X
.... 2023 (hereinafter referred to as 'Master Circular'). Pursuant to feedback received from APMI, the matter was examined and following is clarified: 4.1.1. Clauses 2.6 and 2.7 of the Master Circular shall be applicable for discretionary and non-discretionary services provided by the Portfolio Manager. 4.1.2. Clause 2.6 of the Master Circular shall be applicable for co-investment portfolio management service provided by Portfolio Manager. Clause 2.7 of the Master Circular shall not be applicable for co-investment portfolio management service provided by Portfolio Manager. 4.1.3. Clauses 2.6 and 2.7 of the Master Circular shall not be applicable for advisory services provided by the Portfolio Manager. 4.1.4. Clause 2.7.3 of the Master Circular inter alia mandated Portfolio Managers with assets under management of INR 1000 crores or more under discretionary and non-discretionary services, to have in place an automated system with minimal manual intervention for ensuring effective funds and securities management. In order to ensure compliance with the said Clause, the following may be specified by APMI: 4.1.4.1. Portfolio Managers, who have crossed the threshold of INR 100....
X X X X Extracts X X X X
X X X X Extracts X X X X
.... Managers (PMS) 1. Facility for uploading of following 4 reports/certificates were enabled in the SI Portal viz. 1.1. PMS Improvement in Corporate Governance Report, 1.2. PMS Certificate of Net Worth, 1.3. PMS Certificate of compliance with Regulations, 1.4. PMS Certificate of Compliance with Performance Reporting Guidelines 2. Brief description of the Reports/ Certificates is as follows: Page 168 of 175 à¤à¤¾à¤°à¤¤à¥€à¤¯ पà¥à¤°à¤¤à¤¿à¤à¥‚ति और विनिमय बोरà¥à¤¡ Securities and Exchange Board of India Sr. No. Reports/Certificates Description (Regulatory requirements to be verified with latest relevant SEBI Regulations, Circulars, etc.) 2.1 Improvement in Corporate Governance Report 2.1.1. In terms of clause 5.2.2. of the Master Circular for Portfolio Managers issued on March 20, 2023, Portfolio Managers shall report to SEBI on compliance with the provisions of the above guidelines while submitting the annual reports. 2.1.2. The report should reach SEBI within thirty days from the end of the financial year. 2.2 Certificate of Net Worth 2....
X X X X Extracts X X X X
X X X X Extracts X X X X
.... 2.4.2. The firm-level performance data of Portfolio Managers shall be audited annually. Confirmation with compliance with paragraph 4.5.3. of the Master Circular for Portfolio Managers issued on March 20, 2023, shall be reported to SEBI within sixty days of end of each financial year. 2.4.3. The said report to SEBI shall be certified by the Directors/Partners of the Portfolio Manager or by person(s) authorized by the Board of Directors/Partners of the Portfolio Manager. 3. PMS can upload the aforementioned reports @ the following path: Portfolio Managers -> Other Reports -> Report Module -> Proceed to Upload -> Select Report Type -> Proceed 4. Details steps to upload the reports are mentioned hereunder: 4.1. Click on Portfolio Managers -> Other Reports -> Report Module Page 170 of 175 à¤à¤¾à¤°à¤¤à¥€à¤¯ पà¥à¤°à¤¤à¤¿à¤à¥‚ति और विनिमय बोरà¥à¤¡ Securities and Exchange Board of India c % uatsiportal.sebi.gov.in/intermediary/Forms.html COA S O VPN = Welcome Pallavi Logout Last Login Details: Friday Apr 26 2024 | 12:07:28 Tuesday....
X X X X Extracts X X X X
X X X X Extracts X X X X
....¯ पà¥à¤°à¤¤à¤¿à¤à¥‚ति और विनिमय बोरà¥à¤¡ Securities and Exchange Board of India C % uatsiportal.sebi.gov.in/intermediary/reportModuleUpload.html O VPN E Welcome Pallavi Logout Last Login Details: Friday Apr 26 2024 | 12:07:28 × Tuesday Apr 02 2024 | 02:16:44 à¤à¤¾à¤°à¤¤à¥€à¤¯ पà¥à¤°à¤¤à¤¿à¤à¥‚ति और विनिमय बोरà¥à¤¡ Securities and Exchange Board of India Friday Apr 26 2024 | 12:07:28 × Tuesday Apr 02 2024 | 02:16:44 Portfolio Managers PMS Offsite Data - Client Expense Re PMS Offsite Data - Client Folio AUM PMS Offsite Data - Client Folio Master U PMS Offsite Data - Client Holding PMS Offsite Data - Client Master PMS Offsite Data - PM Expense PMS Offsite Data - PM Master PMS Offsite Data - PM Pool Account Master PMS Offsite Data - PM Pool Account Holding PMS Improvement in Corporate Governance PMS Certificate of Net Worth PMS Certificate of compliance with Regulations PMS Certificate of Compliance with Performance Rep....
X X X X Extracts X X X X
X X X X Extracts X X X X
....¨à¤¿à¤®à¤¯ बोरà¥à¤¡ Securities and Exchange Board of India Last Login Details: Friday Apr 26 2024 | 12:07:28 Tuesday Apr 02 2024 | 02:16:44 n Portfolio Managers Report Module Report Module Name of the Applicant: Pallavi Registration No .: INP000464208 Role: Portfolio Managers Registration Start Date: 22/01/2023 Proceed to Upload View Uploads Available Downloads PMS Offsite Data - Client Expense PMS Offsite Data - Client Folio AUM PMS Offsite Data - Client Folio Master PMS Offsite Data - Client Holding PMS Offsite Data - Client Master PMS Offsite Data - PM Expense PMS Offsite Data - PM Master PMS Offsite Data - PM Pool Account Master PMS Offsite Data - PM Pool Account Holding 5.2. Select the Report Type, and enter 'Submit Date' Range and click on Search. Page 173 of 175 à¤à¤¾à¤°à¤¤à¥€à¤¯ पà¥à¤°à¤¤à¤¿à¤à¥‚ति और विनिमय बोरà¥à¤¡ Securities and Exchange Board of India c uatsiportal.sebi.gov.in/intermediary/reportModuleViewUploads.html S · VPN = ....