Portfolio managers must disclose complaint data on their websites on a monthly basis. This article explains the format and compliance requirements.
The Regulatory Mandate
Legal Basis
All Portfolio Managers on a monthly basis shall disclose on their websites, the data pertaining to all complaints including SCORES complaints received by them in the specified format.
Timeline
The information shall be made available by 07th of the succeeding month.
Purpose
The complaint data disclosure aims to:
- Enhance transparency in the Investor Grievance Redressal Mechanism
- Provide visibility into complaint handling
- Enable investors to assess complaint resolution performance
- Promote accountability
Complaint Data Format
Monthly Data
Data for the month ending [Month, Year]
| Sr. No. | Received from | Pending at the end of last month | Received | Resolved* | Total Pending# | Pending complaints > 3 months | Average Resolution time^ (in days) |
|---|---|---|---|---|---|---|---|
| 1 | Directly from Investors | ||||||
| 2 | SEBI (SCORES) | ||||||
| 3 | Other Sources (if any) | ||||||
| Grand Total |
*Inclusive of complaints of previous months resolved in the current month. #Inclusive of complaints pending as on the last day of the month. ^Average Resolution time is the sum total of time taken to resolve each complaint in days, in the current month divided by total number of complaints resolved in the current month.
Trend of Monthly Disposal
| Sr. No. | Month | Carried forward from previous month | Received | Resolved* | Pending# |
|---|---|---|---|---|---|
| 1 | April, YYYY | ||||
| 2 | May, YYYY | ||||
| 3 | June, YYYY | ||||
| 4 | ... | ||||
| 5 | March, YYYY | ||||
| Grand Total |
*Inclusive of complaints of previous months resolved in the current month. #Inclusive of complaints pending as on the last day of the month.
Trend of Annual Disposal
| SN | Year | Carried forward from previous year | Received | Resolved** | Pending## |
|---|---|---|---|---|---|
| 1 | 2018-19 | ||||
| 2 | 2019-20 | ||||
| 3 | 2020-21 | ||||
| Grand Total |
**Inclusive of complaints of previous years resolved in the current year. ##Inclusive of complaints pending as on the last day of the year.
Display Requirements
Website
The complaint data must be displayed on the portfolio manager's website:
- In a prominent location
- In the specified format
- Updated monthly by the 7th of the succeeding month
Mobile Apps
The complaint data should also be displayed on mobile apps.
Link/Option
Portfolio managers are advised to display link/option on their websites and mobile apps so as to enable their clients to lodge complaint with them directly.
SCORES Link
Additionally, link to SCORES website and the link to download the SCORES mobile app may also be provided by the Portfolio Managers on their websites.
What Must Be Included
All Complaints
The disclosure must include:
- Complaints received directly from investors
- Complaints received through SCORES
- Complaints from other sources
Resolution Status
The disclosure must show:
- Complaints pending at the beginning of the month
- Complaints received during the month
- Complaints resolved during the month
- Complaints pending at the end of the month
Ageing
The disclosure must show:
- Complaints pending for more than 3 months
Resolution Time
The disclosure must show:
- Average resolution time in days
Expert Legal Guidance
Anuj Desai & Associates provides expert legal advisory services on complaint data disclosure compliance for portfolio managers. Our securities law experts help clients implement compliant disclosure processes, prepare accurate data, and ensure regulatory compliance. Contact us for guidance on complaint data disclosure and other regulatory matters.