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Performance Benchmarking and Reporting of Performance by Portfolio Managers

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..... olio Managers. 2. In order to help investors in assessing the performance of a Portfolio Manager, the applicable requirements related to performance reporting and benchmarking by Portfolio Managers has been reviewed as under: Performance Benchmarking 2.1. An investment approach ( IA ) is the documented investment philosophy to be adopted by the Portfolio Managers while managing the client funds in order to achieve client s investment objectives. Now, in addition to IA, an additional layer of broadly defined investment themes called Strategies shall be adopted by Portfolio Managers. These broad Strategies shall be Equity , Debt , Hybrid and Multi Asset . 2.2. Each IA shall be tagged to one and only one Strate .....

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..... of Securities by Portfolio Managers 2.7. APMI shall prescribe standardized valuation norms for Portfolio Managers same as the corresponding norms applicable to the Mutual Funds. Valuation of the portfolio debt and money market securities by portfolio managers shall be carried out in accordance with these standardized valuation norms prescribed by APMI. 2.8. APMI shall empanel valuation agencies for the purpose of providing security level prices to Portfolio Managers. Portfolio Managers shall mandatorily use valuation services obtained only from one or more of such empanelled valuation agencies for the purpose of valuation of debt and money market securities in portfolios managed by them. The ultimate responsibility for fair val .....

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..... investor(s) However, aggregated performance statistics of all investors in an IA may be used by a Portfolio Manager for aggregated performance reporting. 2.12. Formats placed at Annexure 1 of this Circular shall replace format at Section E Performance Data in Annexure-A of SEBI Circular no. SEBI/HO/IMD/DF1/CIR/P/2021/02 dated January 8, 2021 . 2.13. Portfolio Manager shall disclose relative performance of its investment approach in all the marketing material where performance of the concerned investment approach is being presented. Such disclosure of relative performance shall, at minimum, include the following: 2.13.1. Performance relative to the selected benchmark 2.13.2. Performance relative to other P .....

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..... nt Fund Trusts), Employee State Insurance Corporation, Postal Life Insurance, etc. 3.3.2. The non-individual Investors are regulated by RBI, IRDA PFRDA for whom specific valuation and/or benchmarking norms have been specified by the concerned regulator(s). subject to verification of compliance with the above conditions in the annual audit under Regulation 30 of the PM Regulations. 3.4. Portfolio Managers shall not advertise/ publish/ mention to any entity other than those belonging to the investor category to which said IA is offered the returns of the IAs where exception as above has been exercised. Portfolio Managers may, however, include the assets managed in such IAs in their total AUM when communicating publicly as .....

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..... ion Strategy 1 IA 1 Benchmark 1 IA 2 Benchmark 2 .....

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..... Benchmark 1 Table 2 Name of the Portfolio Manager Portfolio Turnover Ratio Investment Approach 1 month 1 year IA 1 IA 2 IA 3 IA 4 .....

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