Investor Charter: Portfolio Management Services

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 PMS industry provides a viable investment avenue for wealth creation by adopting high levels of skill, integrity, transparency and accountability.

• ·Appropriate risk profiling of investors
• ·Providing the Disclosure Document to investors
• ·Executing the PMS agreement
• ·Making investment decisions on behalf of investors under a discretionary mandate, acting on investor instructions under a non-discretionary mandate, or advising investors on their investment decisions

Discretionary and non-discretionary portfolio management

An investor gives their portfolio in any form, whether stocks, cash or a combination. The minimum portfolio size is Rs 50 lakh as required under SEBI regulations, though a higher threshold may be prescribed product-wise. Investment objectives are established to achieve optimal returns against the investor’s risk profile. Under a discretionary mandate, investment decisions rest with the portfolio manager where they are consistent with those objectives. Under a non-discretionary mandate, decisions rest with the investor.

Investment advisory

The client is advised on buy and sell decisions within their overall profile, without back-office responsibility for trade execution, custody of securities or accounting. The portfolio manager acts solely as an advisor, is not responsible for investment or divestment, acts in a fiduciary capacity, and maintains an arm’s length relationship with its other activities.

Client onboarding

• ·Compliance with KYC and anti-money laundering requirements
• ·Franking and signing the Power of Attorney
• ·Opening a demat account and funding it from the investor’s verified bank account, or transferring securities from a verified demat account
• ·Mapping that demat account with the custodian

Ongoing activities

• ·Periodic statements as required under the PMS Regulations 2020 and subsequent SEBI notifications and circulars
• ·An audited account statement annually, containing everything required under the PMS Regulations

Fees, closure and grievances

Fees and expenses are charged and disclosed in accordance with the PMS Regulations. On termination by either party, securities and funds are transferred to the investor’s verified bank and demat accounts. Investor queries, service requests and grievances are addressed in a time bound manner on an ongoing basis.

Account opening

• ·PMS account including demat, resident individuals: 7 days from receipt of all requisite documents, subject to review for accuracy and completeness
• ·PMS account including demat, non-individual clients: 14 days from receipt of all requisite documents
• ·PMS account including demat, bank and trading accounts, non-resident clients: 14 days from receipt of all requisite documents
• ·Uploading the PMS account to KRA and CKYC: 10 days from account opening

Nomination

• ·Registration of nominee: alongside account opening, so the same turnaround applies
• ·Modification of nominee: 10 days from receipt of the requisite form

At the time of signing the agreement

The following form part of the account opening form and disclosure document: SEBI registration number, type of account whether discretionary or non-discretionary, what each account type entails and the powers exercisable by the portfolio manager, conditions of termination, fees and modes of payment, transactions permitted under the Power of Attorney, explanation of investment risks, indicative tenure of investments, and any restrictions the investor places on the portfolio manager.

Ongoing disclosures

• ·Copy of the executed PMS agreement: within 3 days of client request
• ·Copy of the Power of Attorney: within 3 days of client request
• ·Name and demat account number of the custodian: within 3 days of PMS and demat account opening
• ·Details of bank accounts holding client funds: within 3 days of PMS and demat account opening
• ·Funds and securities balance statements: quarterly, or on request
• ·Details of eligible funds and portfolio transactions: not later than quarterly, or on request
• ·Settlement of client funds and securities by the custodian, in the prescribed format: not later than quarterly
• ·Audited reports to clients: annually
• ·Total assets under management: disclosed monthly to SEBI. Latest net worth disclosed in the Disclosure Document whenever there is a material change
• ·Related party transactions and conflicts of interest: disclosed in the Disclosure Document, available on this website at all times
• ·Latest Disclosure Document: provided before account opening and available on this website at all times
• ·Redressal of investor grievances: within 30 days, subject to receiving all information required to resolve the complaint

All timelines above are in clear working days.

• ·Every PMS provider must register on SEBI SCORES, the centralised online complaint resolution system, through which a complainant can raise a grievance and track its status at scores.sebi.gov.in
• ·The name, address and telephone number of the investor relations officer who attends to investor queries and complaints are set out in the PMS Disclosure Document
• ·The grievance redressal and dispute mechanism is set out in the Disclosure Document
• ·Investors may approach SEBI directly. On receipt of a complaint SEBI takes the matter up with the PMS provider and follows up
• ·Complaints may be sent to the Office of Investor Assistance and Education, Securities and Exchange Board of India, SEBI Bhavan, Plot No. C4-A, G Block, Bandra Kurla Complex, Bandra East, Mumbai 400051

• ·Check the registration status of the intermediary on the SEBI website before availing services
• ·Submit KYC documents and the application form promptly, signed in the appropriate places and with the required supporting documents
• ·Read the terms and conditions of the agreement carefully before signing
• ·Study the Disclosure Documents thoroughly to understand the risks the investment entails
• ·Answer the risk questionnaire accurately and sincerely, so the risk profile is properly assessed
• ·Study the quarterly statements, which set out the portfolio’s absolute and relative performance, its constituents and its risk profile
• ·Provide the full negative list of securities as part of freeze instructions when entering the agreement, and promptly thereafter for any changes
• ·Inform us of any change to KYC documents or personal details, with the required proof