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Circular for Portfolio Managers

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..... ent to PMS Regulations shall come into force on the thirtieth day from the date of their publication in the Official Gazette. 2. Pursuant to the above, the Portfolio Managers shall ensure compliance with the following: A. Limits on investment in securities of associates / related parties of Portfolio Managers Regulation 24 (3A) of PMS Regulations inter-alia provides that the Portfolio Manager shall ensure compliance with the prudential limits on investment as may be specified by the Board. Accordingly, the Portfolio Managers shall ensure the following: i. 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 assoc .....

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..... . ii. 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 para 2 (A) (i) above. iii. The text and figures of the consent form shall be prominently highlighted and not be below size 12 font. iv. For new clients, the aforementioned consent shall be obtained at the time of entering into agreement, in terms of Regulation 22 (1) of PMS Regulations (i.e., at the time of onboarding of a new client). v. For existin .....

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..... l also be obtained in the same document. ix. In accordance with Regulation 27 (1) of the PMS Regulations, Portfolio Managers shall maintain records and documents pertaining to: a) Prior positive consent or dissent, as the case may be. b) Instances of the passive breach of investment limits, if any. c) Steps taken, if any to rectify the passive breach of investments limits. d) Waiver obtained from the client regarding rebalancing in the event of a passive breach of investment limits. C. Minimum credit rating of securities for investments by Portfolio Managers Regulation 24 (3C) of PMS Regulations provides that Portfolio Managers shall not be allowed to invest clients' funds in unrated securities of their related parties or thei .....

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..... Details of instances of passive breach of investment limits, if any, and steps taken to rectify the same. iii. Details of credit ratings of investments in debt and hybrid securities. b) Accordingly, the format for client reporting as provided in Annexure B of aforesaid Circular dated February 13, 2020 has been revised to include the following tables as a separate head under clause E. Investments in the securities of associates/related parties of Portfolio Manager: i. Transaction wise Sr. No. Issuer name Type of security ISIN Transaction wise Details Transaction date Buy/sell Quantity Gross transaction value (INR in crores) Net transaction value (INR in crores) ii. Security wise Sr. No. Issuer name Type of secur .....

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..... any Name of the associate/related party Investment amount (cost of investment) as on last day of the previous calendar quarter (INR in crores) Value of investment as on last day of the previous calendar quarter (INR in crores) percentage of total AUM as on last day of the previous calendar quarter ii. Portfolio Managers shall ensure that any material changes in the above information is updated in the Disclosure Document and uploaded on their respective websites within 7 days. 3. Applicability a) The requirements as specified at para 2 above and in Regulations 22 (1A), 22(4) (da) & (db), 24 (3A) to 3(E) of PMS Regulations shall not be applicable for advisory portfolio management services, co-investment portfolio management serv .....

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..... ient 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 .....

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