TaxTMI 
TaxTMI 
TaxTMI 
Master Circular for Portfolio Managers
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....07, 2024, the guidelines/directions contained in the circulars listed out in the Appendix to that Master Circular were rescinded. In addition, with the issuance of this Master Circular, the guidelines/directions contained in the circulars listed out in Sr. Nos. 37-39 of the Appendix, to the extent they relate to the Portfolio Managers, shall stand rescinded.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. The extant Master Circular is also updated to bring about consistency with respect to usage of the terms "Para", "Paragraph" and "Clause" to refer to particular paragraphs of the Master Circular. To ensure consistency, the term "Paragraph/(s)" is used at all places, wherever such references are made. F. Notwithstanding such rescission, F.1. anything done or any action taken or purported to have been done or taken under the rescinded circulars, including registrat....
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.... 2. OPERATING GUIDELINES 19 2.1. Guidelines for advertisement by Portfolio Managers 19 2.2. Maintenance of Clients' Funds in a separate Bank Account by Portfolio Managers. 19 2.3. Direct on-boarding of clients by Portfolio Managers 20 2.4. Supervision of Distributors 21 2.4A. Collective oversight of distributors through APMI 22 2.5. Clarification on minimum investment amount by clients and schemes 22 2.6. Written down policies by Portfolio Manager 23 2.7. Fair and equitable treatment of all clients 24 2.8. Cyber Security and Cyber Resilience framework for Portfolio Managers 26 2.9. Valuation of Securities by Portfolio Managers 26 3. INVESTMENTS BY PORTFOLIO MANAGERS 28 3.1. Transaction in Corporate Bonds through Request for Quote platform by Portfolio Management Services (PMS) 28 3.2. Investment in Derivatives 29 3.3. Participation of Portfolio Managers in Commodity Derivatives Market in India 30 3.4 Limits on investment in securities of associates/ related parties of Portfolio Managers 32 3.5 Prior consent of the client regard....
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....lient 153 Annexure 7A Format of Complaint data to be displayed by the Portfolio Managers. 160 APPENDIX: LIST OF CIRCULARS RESCINDED 162 POLICY RELATED LETTERS/EMAILS ISSUED BY SEBІ. 168 1 Performance benchmarking of Portfolio Managers 168 2. Reply to your queries raised for the matter pertaining to Performance Benchmarking of Portfolio Managers 171 3. Formats for annual submissions by Portfolio Managers- Proposal on the Formats 174 4. Clarification regarding paragraphs 2.6 and 2.7 of SEBI Master Circular for Portfolio Managers 180 5. Provision for Submission of Compliance Reports of PMS through the SEВІ Intermediary Portal 182 6. Entities/Persons/Whatsapp/Telegram groups impersonating as Registered Portfolio Managers 190 7. Selection of Secondary Benchmarking for PMS. 191 8. Offsite monitoring of qualitative compliance aspects through Compliance Monitoring Module (CMM) for Portfolio Managers. 194 1. REGISTRATION AND POST-REGIS TRATION ACTIVITY 1.1. Application procedure for registration as Portfolio Manager ^[1] 1.1.1. All entities desirous to be register....
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....oup Entities^[5] 1.3.1. SEBI may consider grant of certificate to an applicant, notwithstanding that another entity in the same group has been previously granted registration by SEBI, if the following conditions are fulfilled: 1.3.1.1. The entities are incorporated as separate legal entities. 1.3.1.2. The entities have independent Board of Directors. Explanation: Independent Board of Directors for this purpose means that common directors should not be in majority in both the Boards. 1.3.1.3. There is arm's length relationship with reference to their operations. 1.3.1.4. The key personnel and infrastructure are independently available for each entity. 1.3.1.5. Each entity has independent regulatory control and supervisory mechanism. 1.3.2. It is also clarified that whenever as per the above policy, two entities in the same 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....
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..... The prior approval granted by SEBI shall be valid for a period of six months from the date of such approval. 1.5.1.3. Applications for fresh registration pursuant to change in control shall be made to SEBI within six months from the date of prior approval. 1.5.1.4. ^[9][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. However, for the clients under co- investment portfolio management services, the Portfolio Manager shall ensure compliance with the second proviso of Regulation 22 (2) of PMS Regulations.] 1.5.1.5. In matters which involves scheme(s) of arrangement which needs sanction of the National Company Law Tribunal ("NCLT") in terms of the provisions of the Companies Act, 2013, the Portfolio Managers shall ensure the following: 1.5.1.5.1. The ap....
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....ute 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 are principal officers or employees having decision making authority related to fund management as on the date of this notification obtain the certification by passing the NISM-Series-XXI-B: Portfolio Managers Certification Examination within two years from the date^[13] of the notification: Provided that a Portfolio Manager, who engages or employs any such associated person who is a principal officer or an employee having decision making authority related to fund management, after the date^[14] of the Gazette Notification No. SEBI/LAD-NRO/GN/2021/49, shall ensure that such person obtains certification by passing the NISM- Series-XXI-B: Portfolio Managers Certification Examination within one year from the date of their employment. 1.7.2. For distributors of Portfolio Managers ....
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....1. The PM Regulations^[20] states that "the portfolio manager shall segregate each client's funds and portfolio of securities and keep them separately from his own funds and securities and be responsible for safekeeping of clients' funds and securities." 2.2.2. With regard to the above, it is clarified that Portfolio Managers may keep the funds of all clients in a separate bank account maintained by the Portfolio Managers subject to the following conditions: 2.2.2.1. There shall be a clear segregation of each client's fund through proper and clear maintenance of back office records, 2.2.2.2. Portfolio Managers shall not use the funds of one client for another client, 2.2.2.3. Portfolio Managers shall also maintain an accounting system containing separate client-wise data for their funds and provide statement to clients for such accounts at least on monthly basis, 2.2.2.4. Portfolio Managers shall reconcile the client-wise funds with the funds in the aforesaid bank account on daily basis. 2.2.3. With respect to investment in short term Liquid Mutual Funds by Portfolio Managers, it is clarified that pending investment ....
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.....5. Clarification on minimum investment amount by clients and schemes^[27] 2.5.1. The Portfolio Managers shall ensure the following: 2.5.1.1. To ensure compliance with the PM Regulations, the first single lump- sum investment amount received as funds or securities from clients should not be less than Rs.50 Lakh^[28]. 2.5.1.2. Portfolio Managers shall not organize investment portfolios as 'Schemes' akin to Mutual Fund Schemes while marketing their services to clients. 2.6. Written down policies by Portfolio Manager^[29] 2.6.1. Portfolio Managers shall put in place a written down policy ("policy"), in compliance with the PM Regulations and circulars issued thereunder, which inter-alia detail the specific activities, role and responsibilities of various teams engaged in fund management, dealing, compliance, risk management, back-office, etc., with regard to management of client funds and securities including the order placement, execution of order, trade allocation amongst clients and other related matters. 2.6.2. Portfolio Managers shall also put in place a specific policy, in compliance with the PM Regulations and circulars iss....
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.... employees as defined in the aforementioned policies of the Portfolio Manager. 2.7.2.2.5. There shall be no sharing of information through any mode, except for trade execution under the approved policies of the Portfolio Manager. 2.7.3. For equity, equity-related instruments and Mutual Funds units^[31] 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 ....
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....gh RFQ in OTO mode. However, any transaction entered by Portfolio Managers in CBs in OTM mode which gets executed with another Portfolio Managers, shall be counted in OTM mode. 3.1.1.4. Portfolio Managers are permitted to accept the Contract Note from the stock brokers for transactions carried out in OTO and OTM modes of RFQ. 3.1.2. Portfolio Managers shall ensure that at least 10% (by value) of their secondary market trades in CBs in current month and immediate preceding two months are executed by placing / seeking quotes through OTO or OTM mode of RFQ. For example, for the month of May 2022, the secondary market trades executed in CBs in the months of March 2022, April 2022 and May 2022 shall be considered for the purpose of aforesaid calculation. 3.2. Investment in Derivatives^[35] 3.2.1. Portfolio Managers are permitted to invest in derivatives, including transactions for the purpose of hedging and portfolio rebalancing, through recognized stock exchanges. 3.2.2. Portfolio Managers can invest in derivatives on the terms specified in the Portfolio Management Agreement. The Agreement should contain complete details pertaining to the manner a....
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....ty Derivatives on their behalf. 3.3.2.4. Portfolio Managers shall provide adequate disclosures in the Disclosure Document as well as the agreement with the client pertaining to their participation in the Exchange Traded Commodity Derivatives, including but not limited to the risk factors, margin requirements, position limits, prior experience of the Portfolio Manager in Exchange Traded Commodity Derivatives, valuation of goods, etc. 3.3.2.5. In case dealing in commodity derivatives lead to delivery of physical goods, there is a possibility that, the Portfolio Manager remains in possession of the physical commodity. In such cases, the goods need to be disposed off at the earliest, within the timelines as agreed upon between the client and the Portfolio Manager. The responsibility of liquidating the physical goods shall be with the Portfolio Manager. 3.3.2.6. Since Foreign Portfolio Investors ("FPIs") are allowed to participate in the Exchange Traded Commodity Derivatives market, subject to conditions specified by SEBI; Portfolio Managers shall, while onboarding FPIs as clients and executing transactions in Exchange Traded Commodity Derivatives market, ensu....
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.... shall obtain a one-time prior positive consent of client in the format specified at Annexure 3A (consent form), as a part of the agreement mandated under Regulation 22(1) of the PM Regulations. 3.5.2. The consent form shall have an option to indicate dissent, in case the client does not want to undertake any investment in the securities of associates/related parties of respective Portfolio Manager. The client shall also have an option to specify a limit on investments in the securities of 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....
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....ect to investments in debt and hybrid securities, the Portfolio Managers shall ensure compliance with the following: 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:^[42] 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 portfolio management services, co-investment portfolio management services and for client categories who in turn ....
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....ding 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 levy of all applicable charges on a sample portfolio of Rs.50 lacs^[47] over a period of one year. The fees and charges shall be shown for 3 scenarios viz. when the portfolio value increases by 20%, decreases by 20% or remains unchanged. An illustration of the same is enclosed as Annexure 4A of this Master Circular 4.3.2. [For new clients, on-boarded on or after October 01, 2024, whenever performance fees is charged to such client, the annexure for fees and charges to the PMS-client agreement, shall also contain the following additional fee illustrations: • One year and multi-year fee illustrations that cover different scenarios viz. increase in the portfolio value by a certain percentage, decrease in the portfolio value by a certain percentage and when the portfolio value remains unchanged. The said illustrations shall also suitably incorporate the high watermark principle. The standard formats for the above fee illustrations have been prescribed by APMI, in consultatio....
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....ect benchmark indices in line with paragraph 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 their management perception on the performance of their schemes.]^[55] 4.5.2.4. The Boards of portfolio managers may review the performance of the funds managed by them for each client separately in their meetings and should take corrective action wherever necessary. They may also compare the performance of the portfolios with benchmarks. 4.5.3. In relation to performance of the portfolio manager, it is also clarified that the Portfolio Managers shall:^[56] 4.5.3.1. Consider all cash holdings and investments in liquid funds, for calculation of performance. 4.5.3.2. Report performance data net of all fees and all expenses (including taxes). 4.5.3.3. Clearly disclose any change in investment approach that may impact the performance of client portfolio, in the marketing material. 4.5.3.4. Ensure that performance reported in all marketing material and website of the Portfolio Manager is....
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....o Manager may tag more than one IA to a Strategy, but each IA must be tagged to only one Strategy. 4.6A.3. APMI shall prescribe a maximum of three benchmarks for each Strategy. These benchmarks shall reflect the core philosophy of the Strategy. While tagging an IA to a particular Strategy, the Portfolio Manager shall select one benchmark 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 Regulations^[60]. 4.6A.6 The changes in Strategy and/ or benchmark shall be recorded with proper justification and shall....
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....rmediaries Portal within 7 working days of the end of each month^[67] and there is no requirement of sending hard copy of the said report to SEBI. 5.1.3. In the said report data pertaining to Assets under Management ("AUM") of the portfolio manager as on the last calendar day 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 5.1.5. In terms of the PM Regulations^[68], Compliance Officer of the portfolio managers shall also be responsible for ensuring compliance with this Master Circular. 5.2. Submission of compliance reports by Portfolio Manager^[69] 5.2.1. With effect from Financial Year 2019-20, Portfolio Managers are required to submit the following information to SEBI:^[70] 5.2.1.1. A ce....
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.... [calendar]^[74] 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 clients' portfolios managed (i.e. clients of both discretionary and non-discretionary portfolio management services) for the purpose of audit of firm-level performance data. 5.3.3. Standard Terms of Reference by APMI: 5.3.3.1. In order to have uniformity, APMI, in consultation with SEBI, shall specify standardised Terms of Reference ('ToR') for aforesaid audit of firm-level performance data. 5.3.3.2. The standard ToR shall inter-alia include requirement for Portfolio Managers to consider clients' portfolios under all services for the purpose of audit of firm-level performance data. Performance of advisory clients may be excluded only if performance of such clients, either individually or cumulatively, is not reported or published in any marketing material or website. 5.3.3.3. The standard ToR specified by APMI (available on ....
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.... 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 be communicated by the Board from time to time. 5.4.7. Portfolio Managers who are exclusively co-investment managers, shall not be required to submit the offsite inspection data. 5.4.8. Portfolio Managers are not required to submit data with respect to funds managed by them for EPFO and other similar government mandates.]^[80] 5.5. Reporting to clients by Portfolio Managers 5.5.1. Portfolio Managers shall furnish a report in the format provided at Annexure 5D^[81] of this Master Circular, to their clients on a quarterly basis^[82] which inter-alia includes the following^[83]: 5.5.1.1. Details of investment of client's funds in the securities of associates/related parties of the Portfolio Manager. 5.5.1.2. Details of instances of passive breach of investment limits, if any, and steps taken to rectify the same. 5.5.1.3. Details of credit ratings of investments in debt and hybrid securities. 5.5.1.4. [Details of f....
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....r the Regulations^[86]. 5.6.6. Portfolio Managers shall also submit the monthly reports to APMI in addition to SEBI within 7 working days from the end of each month. APMI shall make available the monthly reports of the Portfolio Managers on APMI website in an intuitive and user-friendly manner facilitating ease of comparison so as to provide access to portfolio level, investment approach level, portfolio manager level and industry level information to all the stakeholders. APMI shall also make available relative performance of each investment approach within the strategy to concerned portfolio manager and also disclose the same on its website. 5.6.7. The above provisions under paragraphs 5.6.1 to 5.6.6 shall be applicable to any entity reporting/ publishing/ advertising performance of any Investment Approach of any Portfolio Manager. 5.6.8. Portfolio of investors/clients of portfolio manager shall not be covered under provisions 2.9, 4.6.1A, 4.6A, 5.6, if, 5.6.8.1. Investors are governed by separate statutes like Provident Funds (Employees' Provident Fund Organization, Coal Mines Provident Fund Organization, Exempted Provident Fund Trusts), E....
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....to the non- associates providing the same service. 6.1.3.5. The provisions with respect to fees and charges shall not be applicable to Co-investment services^[92]. 6.1.3.6. Profit/ performance shall be computed on the basis of high water mark principle over the life of the investment, for charging of performance / profit sharing fee. High Water Mark Principle: High Water Mark shall be the highest value that the portfolio/account has reached. Value of the portfolio for computation of high watermark shall be taken to be the value on the date when performance fees are 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 performanc....
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....12. 6.1.6. Maximum Liability^[97] 6.1.6.1. The PM Regulations^[98] provide that the agreement between the portfolio manager and the client shall, inter alia, contain, in case of a discretionary portfolio manager, a condition that the liability of a client shall not exceed his investment with the portfolio manager. 6.1.6.2. Portfolio managers shall strictly comply with the aforesaid Regulation. 7. GRIEVANCE REDRESSAL 7.1. Dispute Resolution^[99] 7.1.1. The PM Regulations^[100] 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 websites^[101] 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 t....
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.... 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 Worklist" on the home page of SEBI Intermediary Portal. h. Inside the mail, there will be a link "Enter Fee Details" through which the applicant has to enter the fee details and save it. i. Once the details relating to fees are entered and saved, it must be adjusted against the outstanding amount as per the instructions given in the "blue question mark" on the top right hand corner of the page. j. Once the fees are adjusted, the fee details must be saved and then submitted, by clicking the "Submit" button in the e-mail, to SEBI for final approval. Online Process for Updation of Information a. There can be any change in information that a registered Portfolio Managers can undergo during its operations. b. Apart from sending the physical copy of such changes in information to SEBI, the same should be updated on the SEBI Intermediary ....
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....nguage and the inclusion of excessive details which may detract the investors should be avoided. 1.6. The advertisement shall not contain information, the accuracy of which is to any extent dependent on assumptions. 1.7. The advertisement shall not contain any promise or guarantee of assured/fixed return to the investors, either directly or indirectly. 1.8. The advertisement shall not compare one Portfolio Manager with another, implicitly or explicitly, unless the comparison is fair and all information relevant to the comparison is included in the advertisement. 2. OBSERVANCE OF CODE OF ADVERTISEMENT 2.1. Every Portfolio Manager shall strictly observe the Code of Advertisement set out in paragraph 1 given above. Any breach of the Code would be construed as breach of Code of conduct set out in Schedule III to the Securities and Exchange Board of India (Portfolio Managers) Regulations, 2020. Annexure 2B: Code of Conduct for Distributors of Portfolio Management Services 1. The Code of Conduct, as provided hereunder, shall be applicable to all persons involved in the distribution of Portfoliz Management Services. 2. All distributors shall....
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..... Make comparisons, if any, only with the similar and comparable products along with complete facts. xvii. Not indulge in any manipulative, fraudulent or deceptive practices or spread rumours with a view to make personal gain. xviii. Hold valid Certification, as specified by SEBI, at all times. **** Annexure 3A: 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 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% 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 pres....
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.....50 lacs^[104] over b. Period: 1 year c. Hurdle Rate: 10% of amount invested d. Brokerage/ DP charges/ transaction charges: Weighted Average of such charges (as a percentage of assets under management) levied in the past 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 50,00,000^[105] Less: Any other fees (please enumerate) XX 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 60,00,000 Less: Brokerage/DP charges/any other similar charges (e.g. 2% of Rs.50,00,000) 1,00,000 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 - ....
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....tal contributed (4.00%) Note: The frequency of charging various fees may be specified for every type of fees in the illustration 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 Investor (non- discretionary) or advising investors regarding their investment decisions (advisory), as the case may be. C. Details of services provided ....
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....ns 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, if any, on an ongoing basis. Timelines of the services provided to investors are as follows: Sr. No. Service / Activity Timeline 1 Opening of PMS account (including demat account) for residents. 7 days from receipt of all requisite documents from the client, subject to review of the documents for accuracy and completeness by portfolio manager and allied third party service providers as may be applicable. 2 Opening of PMS account (including demat account) for n....
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....rtfolio manager. At the time of client signing the agreement; this information should be a part of the account opening form. 13 Copy of executed PMS agreement sent to client. Within 3 days of client request. 14 Frequency of disclosures of available eligible funds. All details regarding client portfolios should be shared quarterly (point 26). 15 Issuance of funds and securities balance statements held by client. This data should be shared on a quarterly basis or upon client request. 16 Intimation of name and demat account number of custodian for PMS account. Within 3 days of PMS and demat account opening. 17 Conditions of termination of contract. At the time of client signing the agreement; this information should be a part of the account opening form. 18 Intimation regarding PMS fees and modes of payment or frequency of deduction. At the time of client signing the agreement; this information should be a part of the account opening form. 19 POA taken copy providing to client. Within 3 days of client request. 20 Intimation to client about what all transactions can portfolio manager do using PoA. At the time of....
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....t resolution system through which the complainant can take up his grievance against the PMS provider and subsequently view its status. (https://scores.gov.in/scores/Welcome.html) b. The details such as the name, address and telephone number of the investor relations officer of the PMS provider who attends to the investor queries and complaint should be provided in the PMS Disclosure document. c. The grievance redressal and dispute mechanism should be mentioned in the Disclosure Document. d. Investors can approach SEBI for redressal of their complaints. On receipt of complaints, SEBI takes up the matter with the concerned PMS provider and follows up with them. e. Investors may send their complaints to: Office of Investor Assistance and Education, Securities and Exchange Board of India, SEBI Bhavan. Plot No. C4-A, 'G' Block, Bandra-Kurla Complex, Bandra (E), Mumbai - 400 051. E. Expectations from the investors (Responsibilities of investors) • Check registration status of the intermediary from SEBI website before availing services. • Submission of KYC documents and application form in a timely manner with signat....
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....bsp; B. Break-up of assets under management of the Portfolio Manager Investment Approach Assets Under Management as on last day of the month (in INR crores) Equity Plain Debt Structured Debt Derivatives Mutual Funds Others Total Listed Unlisted Listed Unlisted Listed Unlisted Equity Commodity Others Approach 1 Approach 2 --- Approach N. Total C. Funds Inflow/ Outflow Investment Approach Funds Inflow/Outf....
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....; IA 5 Benchmark 3 IA 6 Benchmark 1 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 Management (AUM) as on last day of the month ....
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....s 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 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 ....
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....E > STRING Y Maximum length allowed: 100 Name of Compliance Officer 9 < PO_NISM_CERTIFICATE_NO > < /PO_NISM_CER TIFICATE_NO > STRING N Maximum length allowed: 20 Principal Officer's NISM Certificate Number 10 < PO_NISM_CERTIFIC_DATE > < /PO_NISM_CERTI FIC DATE > DATE N YYYY-MM-DD Date of NISM certificate 11 < FIU_REG_NO > < /FIU_REG_NO > STRING N Maximum length allowed: 20 FIU Reg Number 12 < KRA REG_NO > < /KRA_REG_NO > STRING N Maximum length allowed: 20 Institution code issued by KRA In case of registration with multiple KRA agencies, provide any one KRA agency registration number 13 < CERSAI_REG_NO > < /CERSAI_REG_NO > STRING N Maximum length allowed: 20 Institution code issued by CERSAI 14 < SCORE_REG_NO > < /SCORE_REG_NO > STRING Y Maximum length allowed: 20 SEBI SCORES registration number 15 < WEBLINK >< /WEBLINK > STRING N Maximum length allowed: 500 Website of the Portfolio Manager 16 < FO_SYSTEM_NAME >< /FO_SYSTEM_NAME > STRING N Maximum length allowed: 100 Name of Front Office Trading System 17 < BO_SYSTEM_N....
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....t. Provide Unique Client Code, if folio no. not maintained. This value cannot be NULL, if CLIENT_BOID is not NULL. 3 < CLIENT_PAN > < /CLIENT_PAN > STRING Y Length allowed: 10 Client PAN 4 < CLIENT_BOID > < /CLIENT_BOID > STRING N Length allowed: 16 BOID of the client. For investors having investments only in MF Units in SOA format, BOID may not be provided. 5 < CLIENT_CATEGORY > < /CLIENT_CATEGORY > STRING Y Individual Resident Individual Non Resident HUF Corporate Resident Corporate Non- Resident Association of Persons Body of Individuals Partnership Firm Limited Liability Partnership Trust FPI other 5 < CLIENT_SUB_CATEGORY > < /CLIENT_SUB _CATEGORY > STRING Y General Accredited Large Value Accredited Co-investment Eligible Investment Fund Not Applicable 7 < SERVICE_CATEGORY > < /SERVICE_CATEGORY > STRING Y Discretionary Non-Discretionary Advisory 8 < CLIENT_FIRST_NAME > < /CLIENT_FIRST_NAME > STRING Y Maximum length allowed: 100 9 < CLIENT_MIDDLE_NAME > < /CLIENT_MIDDLE_NAME > STRING N Maximum length allowed: 35 10....
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....d: 10 27 < NOMINEE_3_NAME > < /NOMINEE_3_NAME > STRING N Maximum length allowed: 100 28 < NOMINEE_3_PAN_NO > < /NOMINEE_3_PAN_NO > STRING N Length allowed: 10 29 < FIRST_HOLDER_GENDER > < /FIRST_HOLDE R_GENDER > STRING N Male Female Other NA 30 < FIRST_HOLDER_DOB > DATE N YYYY-MM-DD Date of Birth of First holder For non-individuals, date of incorporation will be captured wherever available 31 < FIRST_HOLDER_NATIONALITY > < /FIRST_HOLDER_NATIONALITY > STRING N Maximum length allowed: 40 Nationality of First holder 32 < FIRST_HOLDER_OCCUPATION > < /FIRST_HOLDER_OCCUPATION > STRING N Maximum length allowed: 100 Occupation of First Holder 33 < DATE_OF_PMS_ACCOUNT_ACTIVATION > < /DATE_OF_PMS_ACCOUNT_ACTIVATION > DATE N YYYY-MM-DD PMS Account Activation date 34 < IS_ACCOUNT_ACTIVE > < /IS_ACCOUNT_ACTIVE > BOOL Y true false Active Account - True Inactive Account - False Examples of inactive accounts: * UCC created but funds not received. * Full Redemption request received, but full and final settlem....
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....nique code for each investor based on agreement and holding nature (i.e. single/joint/etc.) 2. < CLIENT_FOLIO_NO > < /CLIENT_FOLIO_NO > STRING Y Maximum length allowed: 20 Folio no. of the client. Provide Unique Client Code, if folio no. not maintained. 3. < AGREEMENT_DATE > < /AGREEMENT_DATE > DATE Y YYYY-MM-DD Date of agreement 4. < INVESTMENT_APPROACH > < /INVESTMENT_APPROACH > STRING N Maximum length allowed: 50 Name of Investment Approach 5. < INVESTMENT_STRATEGY > < /INVESTMENT_STRATEGY > STRING Y Equity Debt Hybrid Multi 6. < BENCHMARK > < /BENCHMARK > STRING Y Maximum length allowed: 50 BENCHMARK INDEX selected by PM for the strategy. Benchmark Index names to be given exactly as provided by the index provider 7. < CLIENT_BOID > < /CLIENT_BOID > STRING N Length allowed: 16 BOID of the client. For investors having investments only in MF Units in SOA format, BOID may not be provided. 8. < CUSTODIAN_REG_NO > < /CUSTODIAN_REG_NO > STRING N Maximum length allowed: 20 SEBI Registration Number of Custodian. Mandatory for Discretionary/Non- Discretiona....
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....IVE > < /IS_CONSENT_INVST_IN_COMMODITY_DERIVATIVE > BOOL Y TRUE FALSE Consent for investment in Commodity Derivatives 20. < PERCENTAGE_DERIVATIVE_CONSENT > < /PER_CENTAGE_DERIVATIVE_CONSENT > FLOAT Y DECIMAL(5,2) Percent of AUM which can be invested in derivatives 21. < IS_CONSENT_LENDING > < /IS_CONSENT_LENDING > BOOL Y TRUE FALSE Consent for lending of securities. 22. < CLIENT_CUSTODIAN_CODE > < /CLIENT_CUSTODIAN_CODE > STRING Y Maximum length allowed: 20 Custodian code of the client 23. < PM_DISTRIBUTOR_NAME > < /PM_DISTRIBUTOR_NAME > STRING N Maximum length allowed: 100 Name of the Distributor 24. < PM_DISTRIBUTOR_PAN > < Is_Valid_PAN > < /Is_Valid_PAN > < /PM_DISTRIBUTOR_PAN > STRING N Length allowed: 10 PAN of the Distributor 25. < PERFORMANCE_FEE_DESCRIPTION > < /PERFORMANCE_FEE_DESCRIPTION > STRING Y Maximum length allowed: 100 Mode of charging performance fees in description 26. < PERCENTAGE_PERFORMANCE_FEE > < /PERCENTAGE_PERFORMANCE_FEE > FLOAT Y DECIMAL(5,2) Performance fees percentage 4. PMS_Inspection_Client_Folio_AUM ....
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....nth of Report for this XML File 5.2. Client_Cap_Transactions [< 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 Sr. No. Tag Data Type Mandatory Allowed Character Comments 1 < UNIQUE_CLIENT_CODE > < /UNIQUE_CLIENT_CODE > STRING Y Maximum length allowed: 20 Unique client code 2 < CLIENT_FOLIO_NO > < /CLIENT_FOLIO_NO > STRING Y Maximum length allowed: 20 Folio no. of the client. Provide Unique Client Code, if folio no. not maintained. 3 < TRANSACTION TYPE > < /TRANSACTION_TYPE > STRING Y Initial Inflow Top Up Partial Redemption Full Redemption Interest/Divid end Pay-in Interest/Divid end Pay-out Tax Liability (TDS or IT for NRI) Switch-in Switch-out * Please see note below. All redemption transactions after receipt of account closure/ deactivation/ transmission date shall be tagged as Full Redemption, even if the proceeds a....
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..../ACCRUAL_DATE > DATE Y YYYY-MM-DD Date of the expense charged 2 < UNIQUE_CLIENT_CODE > < /UNIQUE_CLIENT_CODE > STRING Y Maximum length allowed: 20 Unique client code 3 < CLIENT_FOLIO_NO > < /CLIENT_FOLIO_NO > STRING Y Maximum length allowed: 20 Folio Number of the client. Provide Unique Client Code, if folio no. not maintained 4 < EXPENSE_TYPE > < /EXPENSE_TYPE > STRING Y PMS Fees Operating Fees Statutory Levies 5 < EXPENSE_SUB_TYPE > < /EXPENSE_SUB_TYPE > 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 Statutory Levies 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) In case of Statutory Levies: Statutory Levies 6 < EXPENSE_VALUE > < /EXPENSE_VALUE >....
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....E > < /SECURITY_NAME > STRING N Maximum length allowed: 100 Name of the security 8 < SECURITY_ISIN > < /SECURITY_ISIN > STRING N Length allowed: 12 ISIN of security. For derivatives, provide ISIN of underlying security. 9 < SECURITY_CODE > < /SECURITY_CODE > STRING N Maximum length allowed: 20 Internal code of the security for which there is no ISIN. 10 < IS_SECURITY_ASSOCIATED > < /IS_SECURITY_ASSOCIATED > BOOL Y TRUE FALSE If security is of associate/ related party 11 < IS SECURITY_LISTED > < /IS_SECURITY_LISTED > BOOL Y TRUE FALSE If security is listed 12 < SECURITY_RATING > < /SECURITY_RATING > STRING N REFER ANNEXURE-A Security rating mandatory in case of Debt/ Hybrid securities 13 < RATING_AGENCY > < /RATING_AGENCY > STRING N REFER ANNEXURE-B Rating agency mandatory for debt / hybrid securities 14 < QUANTITY > < /QUANTITY > FLOAT N DECIMAL(30,6) Quantity 15 < UNIT_PRICE > < /UNIT_PRICE > FLOAT N DECIMAL(30,6) Market Price or valuation price of the security in INR 16 < MARKET_VALUE > < /MARKET_VALUE > FLOAT N ....
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....Mandatory Allowed Character Comments 1 < LOGIN_ID > < /LOGIN_ID > INT Y >0 Login ID of the PMS 2 < YEAR > < year > < /year > < /YEAR > STRING Y 20XX to 21XX Year of Report for this XML File 3 < MONTH > < month > < /MO NTH > STRING Y January February March April May June July August September October November December Month of Report for this XML File 9.2. PMS_PoolAcc [< PMS_PoolAcc > < /PMS_PoolAcc >] - None or more occurrences allowed Important Note: Kindly ensure that each of the POOL_BOID should be uniquely identified in this report. No two entries for same POOL_BOID should be present. Sr. No. Tag Data Type Mandatory Allowed Character Comments 1 < POOL_DP_ID > < /POOL_DP_ID > STRING Y Maximum length allowed: 20 Pool DP ID 2 < POOL_DP_NAME > < /POOL_DP_NAME > STRING Y Maximum length allowed: 100 Pool Name of DP 3 < POOL_NAME> STRING Y Maximum length allowed: 100 Pool Account title 4 < POOL_BOID > < /POOL_BOID > STRING Y Length allowed: 1....
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....s XML File 3 < MONTH > < month > < /MONTH > STRING Y January February March April May June July August September October November December Month of Report for this XML File 11.2. PMS_Trade_data [< PMS_Trade_data > < /PMS_Trade_data >] - None or more occurrences allowed Sr. No. Tag Data Type Mandatory Allowed Character Comments 1 < TRADE_DATE > < /TRADE_DATE > DATE Y YYYY-MM-DD format Trade date of the security Trade date should belong to the month for which the report is submitted. 2 < SETTLEMENT_DATE > < /SETTLEMENT_DATE > DATE Y YYYY-MM-DD format Settlement date of the security 3 < UNIQUE_REF_NO > < /UNIQUE_REF_NO > STRING Y Maximum length allowed: 40 Unique identifier for particular transaction 4 < BOID > < /BOID > STRING N Allowed Length = 16 BOID of the Pool or Client Account. 5 < CLIENT_ID > < /CLIENT_ID > STRING N Maximum length allowed: 40 Client ID of the trading account 6 < POOL_FLAG > < /POOL_FLAG > Numeric Y 1 - Pool Account 2- Client Account Wh....
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.... For Equity quantity traded 2. For Equity Futures and Options the units traded i.e. Lot size * No. of Lots 3. For Debt, actual Quantity considering the FV as per the Information Memorandum (IM). In case partial redemption has happened by reducing the Quantity, then provide reduced Quantity. 18 < FACE_VALUE > < /FACE_VALUE > DECIMAL(20,4) N 20 digits with 4 decimal Kindly leave blank wherever not applicable 19 < TRANSACTION_PRICE > < /TRANSACTION_PRICE > DECIMAL(20,6) Y 20 digits with 6 decimal 1. In case of Debt securities, provide clean price i.e. excluding accrued interest component. 2. For Equity Options, the premium paid/received (Premium in absolute terms viz. without negative or positive sign shall be given) 3. For Equity Futures, the price of one unit 20 < ACCRUED_INTEREST > < /ACCRUED_INTEREST > DECIMAL(20,4) N 20 digits with 4 decimal Accrued Interest for debt securities 21 < TRANSACTION_VALUE > < /TRANSACTION_VALUE > DECIMAL(20,4) Y 20 digits with 4 decimal 1. For Equity Options, Transaction_Value = Quantity * Premium 2.For Equity Futures, Transaction_Value = Quantity/unit * Transact....
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....of the PMS 2 < YEAR > < year > < /year > < /YEAR > STRING Y 20XX to 21XX Year of Report for this XML File 3 < MONTH > < month> < /MONTH > STRING Y January February March April May June July August September October November December Month of Report for this XML File 12.2. PMS_Fm_Dealer_Dtls [< PMS_Fm_Dealer_Dtls > < /PMS_Fm_Dealer_Dtls >] - One or more occurrences allowed Sr. No. Tag Data Type Mandatory Allowed Character Comments 1 < KEY_EMPLOYEE_NAME > < /KEY_EMPLOYEE_NAME > STRING Y Maximum length allowed: 100 2 < DESIGNATION > < /DESIGNATION > STRING Y Allowed Character: Fund Manager Dealer 3 < EMPLOYEE_PAN > < /EMPLOYEE_PAN > STRING Y Allowed Length: 10 Should follow PAN syntax 4 < APPOINTMENT_DATE > < /APPOINTMENT_DATE > DATE Y YYYY-MM-DD Date of Appointment in the Designation 5 < CESSATION_DATE > < /CESSATION DATE > DATE N YYYY-MM-DD Date of cessation from the Designation Date of cessation should belong to the month of the....
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....ient_Cap_Transactions. 4 3.1. Transaction in Corporate Bonds through Request for Quote platform by Portfolio Management Services (PMS) PMS_Inspection_Trade_Data. 5 3.2.2 Portfolio Managers can invest in derivatives on the terms specified in the Portfolio Management Agreement. PMS_Inspection_Client_Folio_Master. 6 3.2.3 The total exposure of the portfolio client in derivatives should not exceed his portfolio funds placed with the Portfolio Manager PMS_Inspection_Client_Folio_AUM, PMS_Inspection_Client_Holding_Master. 7 3.3.2. 3 Portfolio Managers may participate in Exchange Traded Commodity Derivatives after entering into an agreement with the clients. PMS_Inspection_Client_Folio_Master. 8 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 securities of their own associates/related parties. PMS_Inspection_Client_Folio_Master, PMS_Inspection_Client_Folio_AUM, PMS_Inspection_PM_Associated_Security_Details, PMS_Inspection_Client_Holding_Master. 9 3.6.2 Portfolio Managers offering discretiona....
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.... on quarter end) % of 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 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 ....
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....nbsp; Commodities A: B: Other Assets Cash & Cash Equivalent Total Note: (i) Portfolio Managers offering Co-investment services, may provide details as applicable, for assets permitted to be managed by them E. Other Important Information • With regard to client portfolio, deviations from investment approach, if any • With regard to debt securities, details of any delay in coupon payments, if any • With regard to debt securities, details of default, if any • With regard to portfolio allocation in equity and commodity derivatives, details of funds and securities held as collateral, if any. • Details of Other assets outstanding to be received in Clients account for more than 3 months from the due date Nature of Asset Outstanding amount (In Rs.) a. Coupon Payments b. Divid....
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....d Total ^ Average Resolution time is the sum total of time taken to resolve each complaint in days, in the current month divided by total number of complaints resolved in the current month. Trend of monthly disposal of complaints Sr. No. Month Carried forward from previous month Received Resolved* Pending# 1 April, YYYY 2 May, YYYY 3 June, YYYY 4 5 March, YYYY Grand Total *Inclusive of complaints of previous months resolved in the current month. #Inclusive of complaints pending as on the last day of the month Trend of annual disposal of complaints SN Year Carried forward from previous year Received Resolved ** Pending## 1 2018-19 2 2019-20 3 2020-21 &n....
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....nt amount by clients, performance of portfolio and schemes Cir. /IMD/DF/16/2010 19. July 16, 2012 Deployment of client funds in liquid mutual fund Cir. /IMD/DF-1/16/2012 20. May 22, 2019 Participation of Portfolio Managers in Commodity Derivatives Market in India SEBI/HO/IMD/DF1/CIR/P/2019/066 21. 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 I....
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....rcular') specifying various measures on performance benchmarking by portfolio managers, asset valuation and performance reporting practices. 1.2. In order to operationalize various measures specified in the aforesaid Circular, APMI is advised to: 1.2.1. Prescribe a maximum of three benchmarks for each Strategy as prescribed in Paragraph 2.3 of the Circular (reference: paragraph 4.6A.3 of this Master Circular). An indicative list of Benchmarks is enclosed as Annexure-A for your perusal. 1.2.2. 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 Paragraph 2.7 of the Circular (reference: paragraph 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 Paragraph 2.8 of the Circular (reference: paragraph 2.9.2 of this Master Circular). Portfolio Managers shall mandatorily use valuation services obtai....
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....marks for each prescribed Strategy SI. Strategy Benchmark 1 Benchmark 2 Benchmark 3 1 Equity NIFTY 500 Index S&P BSE 500 Index MSEI SX40 Index 2 Debt NIFTY Medium to Long Duration Debt Index AA+/AA 33%, AA- 17%, A+/A/A- - 50% - 2 - 2.5 duration CRISIL Composite Bond Fund Index 3 Hybrid NIFTY 50 Hybrid Composite debt 50:50 Index 50% BSE 500 Index and 50% S&P BSE Arbitrage Rate Index CRISIL Hybrid 50+50 Moderate Index 4 Multi Asset 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% Annexure - B: Format for Performance Report Card Quartile Analysis of {Name of IA} within {Name of Strategy} Strategy Period No. of IAs IA TWRR (%) Benchmar k/ 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 Seco....
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....rity on 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 1. Whether a link can be provided w.r.t peer performance ....
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....ines 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 Portfolio Manager and report of the same has been submitted to the Board of the Portfolio Manager? 7. Whether Portfolio Manager has exercised due diligence in all its operational activities This certificate is issued in accordance with requirement of Paragraph 5.2.2 of the SEBI Master Circular for Portfolio Managers dated March 20, 2023 For PMS _______ (______) Name of the Principal Officer Date: 1.1.2. Certificate of compliance with PMS Regulations and Circulars (To be subm....
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....n 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. 8. Attached/submitted the audit report on firm-level performance data to SEBI This certificate is issued in accordance with requirement of Paragraph 5.3.1 of the Master Circular for Portfolio Managers dated March 20, 2023 read with Clause 4 of Circular SEBI/HO/IMD/IMD-POD-1/P/CIR/2023/133 dated August 02, 2023. For PMS________ (______) Director/ Partner of PMS Date: 1.1.4. Certificate of compliance with Net worth requirements (To be submitted within 6 months of end of Financial Year) Certificate of compliance with Net worth requirements under the SEBI (Portfolio Managers) Regulations, 2020 This is to certify that the Portfolio Manager bearing SEBI Registration number has fulfilled the Net worth requirements as stipulated under the SEBI (Portfolio Managers) Regulations, 2020 as on March 31, 20XX. Amount in INR Paid up equity capital Add: Free Reserves (excluding reserves created out of revaluation) Less: Aggregate value of....
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....d the threshold of INR 1000 crores of AUM after April 01, 2023 but before the date of this letter, shall ensure compliance with the paragraph 2.7.3 of the Master Circular by June 30, 2024. 4.1.4.2. Portfolio Managers, who would cross the threshold of INR 1000 crores of AUM after the date of this letter, shall ensure compliance with the paragraph 2.7.3 of the Master Circular within 6 months from the end of the month in which the AUM crosses the threshold of INR 1000 crores. 4.1.4.3. The AUM for this purpose shall be the total AUM for discretionary and non-discretionary services reported at the end of the month on SEBI/APMI Portal. 4.1.4.4. Once the compliance requirement becomes applicable, the same shall continue to remain applicable. 4.2. APMI is advised to issue appropriate communication to all Portfolio Managers to this effect. 5. Provision for Submission of Compliance Reports of PMS through the SEBI Intermediary Portal Reference: SEBI Email dated April 29, 2024 Addressed to: APMI 5.1. Portfolio Managers to submit the reports as mentioned in the trail email, online through the SEBI Intermediary Portal (SI Portal) at https://siportal.sebi....
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....pital adequacy requirements, if any, for each activity undertaken by it under the relevant Regulations. 2.2.3. "Net worth" means the aggregate value of paid up equity capital plus free reserves (excluding reserves created out of revaluation) reduced by the aggregate value of accumulated losses and deferred expenditure not written off, including miscellaneous expenses not written off. 2.2.4. In terms of paragraph 5.2.1.1 of the Master Circular for Portfolio Managers issued on March 20, 2023, Portfolio Managers are required to submit to SEBI, a certificate from the qualified Chartered Accountant certifying the net-worth as on March 31, every year based on audited account within 6 months from the end of Financial Year. 2.3 Certificate of compliance with Regulations 2.3.1. In terms of paragraph 5.2.1.2 of the Master Circular for Portfolio Managers issued on March 20, 2023, Portfolio Managers are required to submit to SEBI, a certificate of compliance with PM Regulations and circulars issued thereunder, duly signed by the Principal Officer, within 60 days of end of each financial year. 2.3.2. Further, details of non-compliance along with the corrective actions, if any,....
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....he investors and claiming to provide investment advisory services by camouflaging themselves as SEBI registered Portfolio Managers / entities associated with SEBI registered Portfolio Managers. 6.2. In view of the proliferation of such activities on social media, which are dubious in nature and not in the interest of investors, who intend to avail Portfolio Management Services, APMI is advised to communicate the following to its SEBI registered Portfolio Managers: 6.2.1. Portfolio Managers shall be vigilant and regularly monitor social media to identify the entities / groups which camouflage themselves as registered Portfolio Managers or misuse the names of concerned Portfolio Managers to lure the investors for investments. 6.2.2. Based on this continuous monitoring of such entities, concerned Portfolio Manager should promptly take appropriate actions including issuing a press release / public notice, filing FIR etc. to ensure that such entities / groups are prevented from misusing names of such Portfolio Manager. 7. Selection of Secondary Benchmarking for PMS. Reference: SEBI letter no. SEBI/HO/IMD/IMD-POD-2/P/OW/2024/31192/1 dated October 03, 2024 Ad....
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....7. APMI shall not display the secondary benchmark's performance on its website. Only the primary benchmark's performance will be displayed. 7.1.1.8. Once selected, the Portfolio Manager must show, in all communication to customers or the public where past performance is tabulated or charted, the performance of the secondary benchmark in the same manner as the primary benchmark. 7.2. APMI is advised to communicate the above to all PMs Annexure A List of Secondary Benchmark (Based on AUM as on August 31, 2024) Sr. No. Index 1 NIFTY 50 2 Nifty Midcap 150 3 NIFTY Liquid Index A-I 4 Nifty Large Midcap 250 5 Nifty Smallcap 250 Index 6 Nifty 100 7 NIFTY 50 Arbitrage 8 S&P BSE Sensex 9 CRISIL Liquid Debt A-I Index 10 CRISIL Hybrid 35+65 - Aggressive Index 11 NIFTY 500 Multicap 50:25:25 12 S&P BSE 100 13 CRISIL Money Market A-I Index 14 NIFTY Corporate Bond Index A-Il 15 NIFTY Low Duration Debt Index A-I 16 S&P BSE 250 Small Cap 17 NIFTY Money Market Index A-I 18 NIFTY Short Duration Debt Index A-Il 19 CRISIL Liquid Overnight Index 20 Nifty ....
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....ised independent CA certificate certifying the contents of DD. Wherever there is no change, the Portfolio Manager can indicate no change from previous submission. 8.3.3. Upload of supporting documents: With respect to 26 compliance parameters, Principal Officer will be required to submit a signed declaration in the format finalized by APMI every quarter (Annexure A). For other compliance parameters, PMs will have to upload supporting documents based on Annexure B. Wherever, documents/declarations are dependent on audit report, the same can be submitted based on latest available audit report as on end of the respective quarter. 8.3.4. Applicable timelines: Principal officer will be required to submit their responses within one month from end of reporting period starting from Q1 of FY 2025-26. Accordingly, first such submission shall be made by PMs for period April-June 2025 by July 31, 2025. 8.4. In view of above, APMI is advised to circulate these Guidelines to all Portfolio Managers promptly, and the Portfolio Managers shall be advised to place these Guidelines before their Board/Partners, and comply with the said Guidelines as per the timelines stipulated in ....
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....ct or indirect benefit out of the client's funds or securities. 15. We have not lent the securities held on behalf of the clients to a third person except as provided under the regulations. 16. Money or securities accepted by us are invested or managed in terms of the agreement between us and the client. 17. We have an alert based system in place to monitor compliance with the prudential limits on investments. 18. We have not invested the clients' funds in the portfolio managed or administered by another portfolio manager. 19. We have not invested client's fund based on the advice of any other entity. 20. We confirm ordinarily purchasing or selling of securities separately for each client and in the event of aggregation of purchases or sales for economy of scale, inter se allocation is done on a pro rata basis and at weighted average price of the day's transactions. 21. We have segregated each clients' funds and portfolio of securities from his/her own funds and securities and are responsible for safekeeping of clients' funds and securities. 22. We have provided audited portfolio accounts to all ....
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..../a dvisory/observation issued to the PM in the previous quarter. - For others, the PM will select the dropdown as "No" 5 Whether the Portfolio Manager, its principal officer, its director, promoter, partners and key management persons by whatever name called are fit and proper persons based on the criteria specified in Schedule Il of the SEBI (Intermediaries) Regulations, 2008. Yes/No Common Declaration 6 Whether any disciplinary action was taken against the entities as mentioned in Regulation 7(2)(f) in the current quarter. If yes, provide details. Yes/No Common Declaration 7 Whether the agreements entered with clients in the current quarter are compliant with regulatory requirements including but not limited to Regulations 22(1) and 22(2)? Compliant/ Compliant (No Change)/ Non-compliant/ Partially compliant/Not Applicable Common Declaration 8 Whether consent was obtained from all clients onboarded in this quarter by the Portfolio Manager for investment in associates/related entities? If not, reasons thereof and number of such clients. Yes/No - PM's will upload the report defining the status of the consent obtained from the cl....
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....SEBI in timely manner? Compliant/ Compliant (No Change)/ Non-compliant/ Partially compliant/Not Applicable Common Declaration 16 1. Whether the funds of discretionary clients are managed individually and independently by the Portfolio Manager without partaking the character of a Mutual Fund? 2. Whether the Portfolio Manager followed all directions of its non- discretionary clients with respect to fund management. Compliant/ Compliant (No Change)/ Non-compliant/ Partially compliant/Not Applicable Common Declaration 17 Whether the portfolio manager has acted in a fiduciary capacity with regard to the client's funds. Compliant/ Compliant (No Change)/ Non-compliant/ Partially compliant/Not Applicable Common Declaration 18 Whether the portfolio manager keeps the funds of all clients in a separate account maintained in a Scheduled Commercial Bank? Yes/No Common Declaration 19 Whether the portfolio manager transacts in securities within the limitation placed by the client himself with regard to dealing in securities under the provisions of the Reserve Bank of India Act, 1934 (2 of 1934). Yes/No Common Declaration 20 Whethe....
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....ll the client highlighting the details as per Regulation 31(1). If not, reasons thereof and number of such clients. Compliant/ Compliant (No Change)/ Non-compliant/ Partially compliant/Not Applicable Common Declaration 31 Whether all clients whose contracts were terminated in the current quarter were provided with statement of account Regulation 31(3). If not, reasons thereof and number of such clients. Compliant/ Compliant (No Change)/ Non-compliant/Partially compliant/Not Applicable Common Declaration 32 Whether all related party/associates transactions were carried out in compliance with regulatory provision? Compliant/ Compliant (No Change)/ Non-compliant/ Partially compliant/Not Applicable Common Declaration 33 Whether Portfolio Manager has dispatched/sent physical copy of periodic report to clients as required under Regulation 31(1) of SEBI(PMS) Regulations, 2020 in instances of failure/rejections/returned undelivered emails regarding the same? Yes/No Common Declaration 34 Whether the investor grievance redressal and dispute resolution procedure is in line with regulatory provisions of SEBI? Is there was any delay provide detail....
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....securities v. Account Opening Procedure vi. Issuance and collection of cheques to/from clients. vii. Controls in place to prevent acceptance/issuance of funds/securities from other than clients. viii. Suspicious transaction monitoring and reporting ix. Freezing of funds, financial assets or economic resources or related services Compliant/ Compliant (No Change)/ Non-compliant/ Partially compliant/Not Applicable - The PM will upload the AML policy once - For the rest of the quarters, if there is any change, the PM will upload the revised one 38 Please explain in detail the policy, process/procedure undertaken by you with respect to dealing with the following: a. Account opening procedure / On-boarding of clients b. Fees and charges c. Risk / investment profiling d. Investment Approach e. Performance of the Portfolio Manager f. Investment of clients' fund and management of clients' securities. g. Maintenance of books of accounts, records etc. as per Regulation 27 & 29. h. Advisory Services provided i. Conflict of interest j. Kno....
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.... September 7, 2021 [18] RPM circular No.1(93-94) dated October 20, 1993 [19] IMD/DOF I/PMS/Cir- 4/2009 dated June 23, 2009 [20] Regulation 24 (14) of the SEBI (Portfolio Managers) Regulations, 2020 [21] Regulation 24 (14) of the SEBI (Portfolio Managers) Regulations, 2020 [22] SEBI/HO/IMD/DF1/CIR/P/2020/26 dated February 13, 2020 [23] SEBI/HO/IMD/IMD-I/DOF1/P/CIR/2021/0000000679 dated December 10, 2021 [24] SEBI/HO/IMD/DF1/CIR/P/2020/26 dated February 13, 2020 [25] Updated vide Master Circular for Portfolio Managers dated July 16, 2025 [26] SEBI/HO/IMD/IMD-PoD-1/CIR/2024/32 dated May 02, 2024 [27] Cir. /IMD/DF/16/2010 dated November 02, 2010 [28] Gazette notification No. LAD-NRO/GN/2011-12/37/3689 read with Regulations 23(2) of SEBI (Portfolio Managers) Regulations, 2020 [29] 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 [30] SEBI/HO/IMD/IMD-I DOF1/P/CIR/2022/133 dated September 30, 2022 [31] SEBI/HO/IMD/IMD-I DOF1/P/CIR/2022/133 dated September 30, 2022 [32] Inserted by SEBI Circular No. SEBI/HO/ITD-1/ITD_CSC_EXT/P/CIR/....
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....being managed by the portfolio managers on discretionary basis in comparison with the rise or fall in the markets, portfolio managers shall disclose the performance of benchmark indices in the periodical reports to be furnished to the client in terms of the PM Regulations i.e. Regulation 31 of the SEBI (Portfolio Managers) Regulations, 2020." [55] Modified in line with SEBI Circular No. SEBI/HO/IMD/IMD-PoD-2/P/CIR/2022/172 dated December 16, 2022. Priorto modification, paragraphs 4.5.2.2 & 4.5.2.3 read as under: "4.5.2.2. The portfolio managers may select any of the indices available, e.g. BSE (Sensitive) index, S&P CNX Nifty, BSE 100, BSE 200 or S&P CNX 500, depending on the investment objective and portfolio of the client. These benchmark indices may be decided by the portfolio managers and any change at a later date shall be recorded and justified with specific reasons thereof. 4.5.2.3. As the purpose of introducing benchmarks is to indicate the performance of the portfolios vis-à-vis markets to the investors, the portfolio managers may give performance of more than one index if they so desire. Also, they have the option to give their management perce....
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....io Management services offered by Portfolio Manager and SEBI/HO/IMD/IMD-PoD-1/P/CIR/2024/35 dated May 02, 2024 [82] SEBI/HO/IMD/DF1/CIR/P/2020/26 dated February 13, 2020 [83] SEBI Circular No. SEBI/HO/IMD/IMD-I/DOF1/P/CIR/2022/112 dated August 26, 2022 [84] SEBI/HO/IMD/IMD-POD-1/P/CIR/2024/35 dated May 02, 2024 [85] Inserted by SEBI Circular No. SEBI/HO/IMD/IMD-PoD-2/P/CIR/2022/172 dated December 16, 2022, SEBI/HO/IMD/IMD-PoD-2/P/OW/2022/62571/1 dated December 16, 2022, SEBI/HO/IMD/POD-II/P/OW/2023/12814/1 dated March 29, 2023 [86] Regulation 30 of the SEBI (Portfolio Managers) Regulations, 2020 [87] Regulation 22 read with Schedule IV of the SEBI (Portfolio Managers) Regulations, 2020 [88] SEBI Cir. /IMD/DF/13/2010 dated October 5, 2010 [89] SEBI/HO/IMD/DF1/CIR/P/2020/26 dated February 13, 2020 [90] Regulation 22 (11) of the SEBI (Portfolio Managers) Regulations, 2020 [91] SEBI/HO/IMD/DF1/CIR/P/2020/26 dated February 13, 2020 [92] SEBI/HO/IMD/IMD-I/DOF1/P/CIR/2021/0000000679 dated December 10, 2021 [93] SEBI/HO/IMD/IMD-POD-1/P/CIR/2024/35 dated May 02, 2024 [94] SEBI/HO/IMD/DF1/CIR/P/2020/26 dated February ....
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....079 :Event Type - GET FEES Application for - Pay Renewal Fass of Pallavi as Portfolio Managers Application No - 517089 :Event Type - GET FEES Document 2 o %uatsiportal.sebi.gov.in/intermediary/reportModule.html IS O VEN = 4 Welcome Pallavi Logout à¤à¤¾à¤°à¤¤à¥€à¤¯ पà¥à¤°à¤¤à¤¿à¤à¥‚ति और विनिमय बोरà¥à¤¡ Securities and Exchange Board of India Last Legin Detail Fririny Apr 26 2024 | 12:07:20 Tuesday Apr 02 2024 | 02:15:44 Portfolio Managers Report Module Report Module Name of the Applicant: Pallavi Role: Portfolio Managers Registration No .: INP000464208 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 Document 3 % uatsiportal.sebi.gov.in/intermediary/reportModuleUpload.html S O VPN Welcome Pallavi Logout à¤à¤¾à¤°à....
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....tificate of Net Worth Select File Upload Document 6 % uatsiportalsebi.gov.in/intermediary/reportModule.html Q CIOA S O VPN = Welcome Pallavi Logout à¤à¤¾à¤°à¤¤à¥€à¤¯ पà¥à¤°à¤¤à¤¿à¤à¥‚ति और विनिमय बोरà¥à¤¡ Securities and Exchange Board of India Last Login Details: Friday Ap 25 2224 | 12:07.20 Tum udny Ap: 02 2026 | 02:05:44 Portfolio Managers Report Module Report Module Name of the Applicant: Pallavi Role: Portfolio Managers Registration Start Date: 22/01/2023 Registration No .: INP000464208 Proceed to Upload View Uploads Available Downloads PMS Offate Data - Client Expense PMS Ofshe Data - Client Folio AUM PMS Ofale Data - Client Folio Master PMS Ofiste Data - Client Holding PMS Offsite Data - Client Master PMS Offate Data - PM Expense PMS Offsite Data - PM Master PMS Ofiste Data - PM Pool Account Master PMS Offsite Data - PM Pool Account Holding Document 7 uatsiportal.sebi.gov.in/intermediary/reportModuleViewUploads.html COA O VPN Welcome Pallavi Lo....