Portfolio managers must comply with specific website display requirements regarding their registered name and brand name. This article explains the rules and compliance obligations.
The Regulatory Requirement
Name Display Rule
The portfolio manager shall mention its registration number contained in the certificate of registration in all the correspondence with SEBI, other authorities, Stock Exchanges and the clients of the portfolio manager.
Website Display
The following must be prominently displayed on the portfolio manager's website:
- Name of the portfolio manager as registered with SEBI
- Complete registered office address
- SEBI registration number
- Logo/brand name/trade name
- CIN, if applicable
Brand Name vs SEBI-Registered Name
Brand Name
A brand name is the trading name or brand under which the portfolio manager operates. This may be different from the legal name.
SEBI-Registered Name
The SEBI-registered name is the legal name under which the portfolio manager is registered with SEBI. This is the name on the certificate of registration.
Display Requirements
Both names may be displayed, but the SEBI-registered name must be clearly identifiable.
Social Media Display
Proposed Requirements
SEBI has proposed that AMCs, RIAs, and PMS/AIF players prominently display their registered name and registration number on the home page of their social media profiles.
Purpose
The requirement aims to curb fraud on social media platforms and enhance transparency.
Compliance Requirements
Website
The portfolio manager's website must display:
- Registered name
- SEBI registration number
- Registered office address
- Logo/brand name (if different from registered name)
Marketing Materials
All marketing materials must display:
- Registered name
- SEBI registration number
- Registered office address
Correspondence
All correspondence must mention:
- Registration number
- Registered name
Consequences of Non-Compliance
Regulatory Action
Failure to properly display the registered name and registration number can result in:
- Enforcement action by SEBI
- Monetary penalties
- Suspension or cancellation of registration
Investor Confusion
Improper display can lead to investor confusion and potential fraud.
Expert Legal Guidance
Anuj Desai & Associates provides expert legal advisory services on PMS website disclosure compliance. Our securities law experts help portfolio managers ensure proper display of registered names, registration numbers, and other required information. Contact us for guidance on website disclosure and other regulatory matters.