IND SEBI Portfolio Managers Disclosure


On May 2, IND SEBI issued measures on ease of doing business.


  • IND SEBI issued circular for Portfolio managers - facilitating ease in digital on-boarding process for clients and enhancing transparency through disclosures.
  • Follows IND SEBI Mar. 2023 master circular for portfolio managers, see #166824.
  • Disclosures
  • Working group reviewed current regulatory framework in SEBI (portfolio managers) regulations, 2020; recommended measures to promote ease of doing business.
  • IND SEBI mandates portfolio managers to ensure clients fully understand fee structures before onboarding, including modifications to agreement process.
  • By allowing for digital signatures, typed confirmations, ensuring clarity, transparency.
  • Portfolio managers must provide a fee calculation tool to all clients highlighting various fee options with multi-year fee calculations and adherence to high watermark principle.
  • Additional fee disclosures introduced; performance fees must be accompanied by detailed illustrations of various scenarios, ensuring clients have clear understanding.
  • Furthermore, periodic reports must include an annexure detailing fee calculations.
  • Terms & Conditions
  • IND SEBI also introduced the most important terms and conditions (MITC) document to simplify critical aspects of the portfolio manager-client relationship.
  • The MITC document must be acknowledged by the client; portfolio manager must ensure compliance with for new clients on-boarded on or after Oct. 1, 2024.
  • For existing clients, the MITC shall be informed to the clients via email or any other suitable mode of communication (which can be preserved) by Jan. 1, 2025.
  • Effectiveness
  • Provisions applicable from Oct. 1, 2024.

Regulators IND SEBI
Entity Types IA; Inv Co
Reference Cir SEBI/HO/IMD/IMD-PoD-1/P/CIR/2024/35, 5/2/2024
Functions Client Money; Compliance; Operations; Reporting; Technology; Treasury
Countries India
Category
State
Products Fund Mgt; Mutual Funds; Securities
Regions AP
Rule Type Final
Rule Date 5/2/2024
Effective Date 10/1/2024
Rule Id 210879
Linked to Rule :166824
Reg. Last Update 5/2/2024
Report Section International

Last substantive update on 05/07/2024