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Guidelines for Portfolio Managers

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..... and Charges 3. In partial modification to Cir. /IMD/DF/13/2010 dated October 05, 2010 on Regulation of Fees and Charges, the following is mandated: (i) As provided in Regulation 22 (11) of the PMS Regulations , no upfront fees shall be charged by the Portfolio Managers, either directly or indirectly, to the clients. (ii) Brokerage at actuals shall be charged to clients as expense. (iii) Operating expenses excluding brokerage, over and above the fees charged for Portfolio Management Service, shall not exceed 0.50% per annum of the client s average daily Assets under Management (AUM). (iv) In case client portfolio is redeemed in part or full, the exit load charged shall be as under: a) In the first year of investment, .....

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..... document, marketing materials and any such document which refer to services offered by Portfolio Managers. 8. Any description of investment approach provided by Portfolio Managers shall, inter-alia, include: (i) investment objective (ii) description of types of securities e.g. equity or debt, listed or unlisted, convertible instruments, etc. (iii) basis of selection of such types of securities as part of the investment approach (iv) allocation of portfolio across types of securities (v) appropriate benchmark to compare performance and basis for choice of benchmark (vi) indicative tenure or investment horizon (vii) risks associated with the investment approach (viii) other salient features, if any. D. Periodic .....

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..... anagers 13. Further to Regulation 22 (4)(e) of PMS Regulations , it is clarified that the Portfolio Managers shall: (i) Consider all cash holdings and investments in liquid funds, for calculation of performance. (ii) Report performance data net of all fees and all expenses (including taxes). (iii) Clearly disclose any change in investment approach that may impact the performance of client portfolio, in the marketing material. (iv) Ensure that performance reported in all marketing material and website of the Portfolio Manager is the same as that reported to SEBI. (v) Ensure that the aggregate performance of the Portfolio Manager (firm-level performance) reported in any document shall be same as the combined performance .....

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..... ers. (iii) Ensure that prospective clients are informed about the fees or commission to be earned by the distributors for on-boarding them to specific investment approaches. (iv) Ensure that distributors abide by the Code of Conduct as specified in Annexure C. (v) Have mechanism to independently verify the compliance of its distributors with the Code of Conduct. (vi) Ensure that, within 15 days from the end of every financial year, a self-certification is also received from distributors with regard to compliance with Code of conduct. H. Applicability 17. The provisions of this Circular shall be applicable with effect from May 01, 2020. 18. This circular is issued in exercise of powers conferred under Section 11(1) o .....

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