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SEBI / Portfolio Managers

Client Acquisition for Portfolio Managers — What's Compliant Under Solicitation Rules

A comprehensive guide to client acquisition for Portfolio Managers, explaining what is compliant under SEBI solicitation rules.

25 Jul 20264 min read

Client acquisition is essential for growing a portfolio management practice, but SEBI imposes significant restrictions on how portfolio managers can solicit clients. This article explains what is compliant under solicitation rules.

The Regulatory Framework

Advertisement Code

The SEBI Advertisement Code applies to all forms of communications, issued by or on behalf of a portfolio manager, that may influence investment decisions of any investor or prospective investor.

Key Restrictions

  • No false or misleading statements
  • No assured returns
  • No superlative terms
  • No unfair comparisons
  • No misleading testimonials
  • No unsubstantiated performance claims

Compliant Client Acquisition Strategies

Educational Content Marketing

Educational content is a powerful and compliant client acquisition tool:

  • Blog articles on investment concepts
  • Educational webinars
  • White papers
  • General market reports
  • Educational videos

Compliance Checklist:

  • Ensure all content is educational, not promotional
  • Include required disclaimers
  • Avoid specific recommendations in marketing content
  • Include SEBI registration information

Thought Leadership

Establishing thought leadership attracts clients:

  • Publishing industry insights
  • Expert commentary on market conditions
  • Media appearances (with proper disclosures)
  • Speaking at conferences and seminars
  • Publication in industry journals

Compliance Checklist:

  • Disclose registration status
  • Disclose financial interests
  • Include required disclaimers
  • Maintain records of appearances

Professional Networking

Professional networking can generate compliant leads:

  • Attending industry events
  • Joining professional associations
  • Networking with other professionals
  • Collaborating with complementary professionals

Compliance Checklist:

  • Present as SEBI-registered portfolio manager
  • Provide accurate information
  • Include appropriate disclaimers
  • Maintain professional conduct

Client Events and Webinars

Educational events and webinars are effective acquisition tools:

  • Educational webinars on market topics
  • Educational workshops
  • Educational seminars
  • Client appreciation events

Compliance Checklist:

  • Ensure educational focus
  • Include required disclaimers
  • Do not promise returns
  • Maintain records of events

Referral Programs

Referrals from existing clients can be an effective acquisition channel:

  • Client referrals from satisfied clients
  • Professional network referrals
  • Strategic partnership referrals

Compliance Checklist:

  • Ensure referrals are not incentivized improperly
  • Maintain client confidentiality
  • Include required disclosures
  • Do not provide improper inducements

Prohibited Acquisition Strategies

What Not to Do

  • Cold Calling: Unsolicited cold calling with sales pitches
  • Assured Returns: Promising assured or guaranteed returns
  • Bait and Switch: Advertising free services with hidden fees
  • Misleading Claims: Making false or misleading claims
  • Unfair Comparisons: Comparing with other portfolio managers
  • Social Media Recommendations: Making recommendations without disclosures
  • Inducements: Offering inducements to clients or prospects
  • Gifts and Discounts: Limited period discounts or gifts as acquisition tools
  • Games and Competitions: Games, leagues, schemes, competitions with prize monies

Direct Onboarding

Option for Direct Onboarding

Portfolio managers shall provide an option to clients to be on-boarded directly, without intermediation of persons engaged in distribution services.

Disclosure Requirements

Portfolio managers shall prominently disclose in its Disclosure Documents, marketing material and on its website, about the option for direct on-boarding.

Fee Structure

At the time of on-boarding of clients directly, no charges except statutory charges shall be levied.

Distributor-Led Onboarding

Distributor Registration

Any person or entity involved in the distribution of portfolio management services shall obtain registration with APMI.

Fee Structure

Fees or commission to distributors shall be paid only on trail-basis. Further, any fees or commission paid shall be only from the fees received by Portfolio Managers.

Distributor Compliance

Portfolio managers shall ensure that distributors abide by the Code of Conduct and carry out distribution activities in compliance with PM Regulations.

Expert Legal Guidance

Anuj Desai & Associates provides expert legal advisory services on PMS client acquisition compliance. Our securities law experts help portfolio managers develop compliant acquisition strategies, review marketing materials, and ensure regulatory compliance. Contact us for guidance on client acquisition and other regulatory matters.


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