Circular for Portfolio Managers

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..... nagers to not hold the securities belonging to the portfolio account, in its own name on behalf of its clients either by virtue of contract with clients or otherwise. Further, circular IMD/DOF I/PMS/Cir- 4/2009 dated June 23, 2009 specifies conditions subject to which a Portfolio Manager may keep and maintain the funds of all clients in a separate bank account which inter-alia includes clear segregation of each client s fund through proper and clear maintenance of back office records. 3. In furtherance to the above, it is specified as under: 3.1. Portfolio Managers shall put in place a written down policy ( policy ), in compliance with the PMS Regulations and circulars issued thereunder, which inter-alia detail the specific activiti .....

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..... lients are treated in a fair and equitable manner and ensure compliance with the following: 4.1. Requirements with respect to investments in all instruments: a) Portfolio Managers shall constitute a dealing team (DT) which shall be responsible for order placement and execution of all orders in accordance with the aforesaid policies of the Portfolio Manager. DT may include the Principal Officer or the person appointed in terms of Regulation 7(2) (e) of PMS Regulations . b) Portfolio Managers shall ensure that DT is suitably staffed and comply with the following: i. All conversations of DT shall be only through the dedicated recorded telephone lines or through emails from authorized email ids. ii. Mobile phones or any ot .....

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..... execution and trade allocation. 6. Implementation Schedule: 6.1. Based on APMI s (Association of Portfolio Managers in India) deliberations with the stakeholders, it has been decided that the provisions of this Circular shall be applicable with effect from April 01, 2023. 6.2. APMI shall endeavour to ensure that all Portfolio Managers adhere to the activity wise timelines given at Annexure A so as to ensure compliance with para 6.1 above. 6.3. Portfolio Managers and APMI shall take necessary steps for implementing the circular, including putting required processes and systems in place to ensure compliance with the provisions of this circular. 6.4. APMI shall furnish progress in implementation of provisions of this circula .....

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