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SEBI / Portfolio Managers

AI/ML Tools in Portfolio Management — SEBI's "Extent of Use" Disclosure Requirement

A comprehensive guide to SEBI's "extent of use" disclosure requirement for AI/ML tools in portfolio management.

25 Jul 20263 min read

SEBI has introduced disclosure requirements for the use of AI and ML tools in portfolio management. This article explains the "extent of use" disclosure requirement and compliance obligations.

The Regulatory Framework

Disclosure Requirement

SEBI has proposed that market participants disclose their use of AI and ML tools in operations like algorithmic trading, asset management, portfolio management, and advisory services.

Purpose

The disclosure requirement aims to:

  • Ensure transparency in the use of AI/ML tools
  • Enable investors to make informed decisions
  • Protect investor and stakeholder rights
  • Ensure accountability

What Must Be Disclosed

Extent of Use

Portfolio managers must disclose the extent of use of AI/ML tools in servicing clients. This includes:

  • How AI/ML tools are used
  • The scope of their application
  • The frequency of use

Risks and Limitations

Disclosures should include information on:

  • Risks associated with AI/ML tools
  • Limitations of the tools
  • Accuracy results
  • Data quality

Fees

Disclosure of fees related to AI/ML tools.

Compliance Requirements

Senior Management Oversight

Market participants using AI and ML will need to designate senior management with technical expertise to oversee the performance and control of these tools.

Liability

Investment advisers would solely be responsible for the advice irrespective of the use of AI tools. Portfolio managers remain fully liable for decisions made using AI/ML tools.

Data Privacy

Portfolio managers will also be responsible for safeguarding privacy of client data.

Existing Laws

The use of AI and ML tools must comply with existing laws.

Risk Management

Technology Risk

AI/ML tools introduce technology risks that must be managed.

Data Risk

AI/ML tools rely on data quality. Poor data quality can lead to poor decisions.

Operational Risk

AI/ML tools can create operational risks if not properly managed.

Compliance Risk

AI/ML tools must comply with all regulatory requirements.

Best Practices

Documentation

Document the use of AI/ML tools, including:

  • Purpose and scope
  • Methodology
  • Data sources
  • Validation

Testing

Regularly test AI/ML tools for accuracy and reliability.

Monitoring

Continuously monitor AI/ML tool performance.

Review

Regularly review AI/ML tool use and update disclosures.

Consequences of Non-Compliance

Regulatory Action

Failure to disclose AI/ML tool use can result in enforcement action by SEBI.

Investor Harm

Undisclosed AI/ML tool use can harm investor interests.

Expert Legal Guidance

Anuj Desai & Associates provides expert legal advisory services on AI/ML disclosure compliance for portfolio managers. Our securities law experts help clients implement compliant AI/ML use, prepare disclosures, and ensure regulatory compliance. Contact us for guidance on AI/ML disclosure and other regulatory matters.


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