Question 1

Who is a Portfolio Manager?

Accepted Answer

A portfolio manager is a body corporate, which, pursuant to a contract with a client, advises or directs or undertakes on behalf of the client (whether as a discretionary portfolio manager or otherwise) the management or administration of a portfolio of securities or goods or funds of the client.

Question 2

What is the minimum value of funds or securities that can be accepted by the portfolio managerfrom the client while opening the PMS account?

Accepted Answer

The portfolio manager is required to accept minimum INR 50 Lacs or securities having a minimum worth of INR 50 Lacs from the client.

Question 3

Who are the eligible investors that can avail Portfolio Management Service?

Accepted Answer

Resident Individuals
Non-Resident Indians (NRI)
Proprietary inv
Body Corporates (Private / Public)
Hindu Undivided Families (HUF)
Registered Trusts
Partnership Firms or any other eligible investor

Question 4

What is the difference between discretionary portfolio management service and non discretionary portfolio management service?

Accepted Answer

In discretionary portfolio management service, the portfolio manager individually and independently manages the funds and securities of each client in accordance with the needs of the client. Under the non-discretionary portfolio management service, the portfolio manager manages the funds in accordance with the directions of the client.

Question 5

What fees can a Portfolio Manager charge from its clients for the service rendered by him?

Accepted Answer

SEBI (Portfolio Managers) Regulations, 2020 provide that the portfolio manager shall charge a fee as per the agreement with the client for rendering portfolio management services. The fee so charged may be a fixed amount or a performance-based fee or a combination of both. However, no upfront fees shall be charged by the portfolio manager directly or indirectly to the clients.  The agreement between the portfolio manager and the client shall, inter-alia, also include the quantum and the manner of fees payable by the client for each activity for which service is rendered by the portfolio manager directly or indirectly.

Question 6

What are the various securities in which the Portfolio Manager may invest in a clients' funds?

Accepted Answer

Under Discretionary Portfolio Management Service (DPMS), Portfolio Managers shall invest funds of his clients in the securities listed or traded on a recognized stock exchange, money market instruments, units of Mutual Funds through direct plan and other securities as specified by Board from time to time. Under Non-Discretionary Portfolio Management Service (NDPMS), Portfolio Managers may invest up to 25% of the AUM of a client in unlisted securities, in addition to the securities permitted for discretionary portfolio management. “Unlisted securities” for investment by Portfolio Managers shall include units of Alternative Investment Funds (AIFs), Real Estate Investment Trusts (REITs), Infrastructure Investment Trusts (InvITs), debt securities, shares, warrants, etc. which are not listed on any recognized stock exchanges in India.

Question 7

On what basis is the performance of the Portfolio Manager calculated?

Accepted Answer

The performance of a discretionary portfolio manager is calculated using time weighted rate of return (TWRR) method for the immediately preceding three years or period of operation, whichever is lesser. SEBI Circular No. SEBI/HO/IMD/DF1/CIR/P/2020/26 dated February 13, 2020, interalia, provides information on reporting of performance by Portfolio Managers and also a client reporting format which includes information on the performance of the client account, portfolio manager and the appropriate benchmark.

Question 8

Does SEBI approve the disclosure document of the Portfolio Manager?

Accepted Answer

No. SEBI also does not certify the accuracy or adequacy of the contents of the Disclosure Document.

Question 9

Can a Portfolio Manager impose a lock-in on the investor?

Accepted Answer

Portfolio managers cannot impose a lock-in on the investment of their clients. However, a portfolio manager can charge applicable exit fees from the client for early exit, as laid down in the agreement subject to provision of SEBI Circular No. SEBI/HO/IMD/DF1/CIR/P/2020/26.

Question 10

Can a Portfolio Manager offer indicative or guaranteed returns?

Accepted Answer

No.

Question 11

Does SEBI approve any of the services offered by portfolio managers?

Accepted Answer

No. SEBI does not approve any of the services offered by the Portfolio Manager. An investor has to invest in the services based on the terms and conditions laid out in the disclosure document and the agreement between the portfolio manager and the investor.

Question 12

Where can an investor look out for information on portfolio managers?

Accepted Answer

Investors can log on to the website of SEBI www.sebi.gov.in for information on SEBI regulations and circulars pertaining to portfolio managers. Addresses of the registered portfolio managers are also available on the SEBI website. Information on monthly reports submitted by Portfolio Managers to SEBI can be accessed at https://www.sebi.gov.in/sebiweb/other/OtherAction.do?doPmr=yes.

Question 13

Is Partial withdrawal of Portfolio permitted, for the existing clients of Portfolio Managers?

Accepted Answer

The client may withdraw partial amounts from his portfolio, in accordance with the terms of the agreement between the client and the Portfolio Manager. However, the value of investment in the portfolio after such withdrawal shall not be less than the applicable minimum investment amount.

Question 14

What are the rules governing services of a Portfolio Manager?

Accepted Answer

The services of a Portfolio Manager are governed by the agreement between the portfolio manager and the investor. The agreement should cover the minimum details as specified in the SEBI Portfolio Manager Regulations. However, additional requirements can be specified by the Portfolio Manager in the agreement with the client. Hence, an investor is advised to read the agreement carefully before signing it.

Question 15

What is the disclosure mechanism of the portfolio managers to their clients?

Accepted Answer

The portfolio manager provides to the client the Disclosure Document prior to entering into an agreement with the client.   The Disclosure Document contains the quantum and manner of payment of fees payable by the client for each activity, portfolio risks, complete disclosures in respect of transactions with related parties, the performance of the portfolio manager and the audited financial statements of the portfolio manager for the immediately preceding three years.

Question 16

What is the frequency of the updates to clients from the Portfolio Managers?

Accepted Answer

The reports are shared on a monthly basis on the registered email addresses of the clients

Question 17

What kind of reports can the client expect from the portfolio manager?

Accepted Answer

The portfolio manager shall furnish periodically a report to the client, as per the agreement, but not exceeding a period of three months and such report shall contain the following details, namely: - 
(a) the composition and the value of the portfolio, description of securities and goods, number of securities, value of each security held in the portfolio, units of goods, value of goods, cash balance and aggregate value of the portfolio as on the date of report; 
(b) transactions undertaken during the period of report including date of transaction and details of purchases and sales; 
(c) beneficial interest received during that period in the form of interest, dividend, bonus shares, rights shares, etc; 
(d) expenses incurred in managing the portfolio of the client; 
(e) details of risk foreseen by the portfolio manager and the risk relating to the securities recommended by the portfolio manager for investment or disinvestment; 
(f) default in payment of coupons or any other default in payments in the underlying debt security and downgrading to default rating by the rating agencies, if any; 
(g) details of commission paid to distributor(s) for the particular client.

Question 18

Where can an investor file their complaints?

Accepted Answer

Investors would find the name, address and telephone number of the investor relation officer of the portfolio manager (who attends to the investor queries and complaints) in the Disclosure Document. The grievance redressal and dispute mechanism is also mentioned in the Disclosure Document. In case of non redressal of the complaint by the Portfolio Manager, investors can approach SEBI for redressal of their complaints. Investors may lodge their complaints through SCORES (SEBI Complaints Redress System - https://scores.gov.in/scores/Welcome.html ) or by sending their complaints on the address given below -
Office of Investor Assistance and Education, 
Securities and Exchange Board of India, 
SEBI Bhavan II Plot No. C7, ‘G’ Block, 
Bandra-Kurla Complex, Bandra (E), 
Mumbai - 400 051

FREQUENTLY ASKED QUESTIONS