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SEBI / Portfolio Managers

Discretionary PMS vs Non-Discretionary PMS — Which Suits Which Investor

A comprehensive comparison of Discretionary and Non-Discretionary PMS to help investors determine which suits their investment style and preferences.

25 Jul 20263 min read

Portfolio Management Services can be structured in different ways. This article compares Discretionary and Non-Discretionary PMS to help investors choose the right approach.

What is Discretionary PMS?

Definition

In Discretionary PMS, the portfolio manager makes all investment decisions on your behalf based on the agreed strategy and risk profile. The portfolio manager has complete autonomy to make investment decisions on behalf of the investor.

Key Characteristics

  • Full Autonomy: Manager makes all investment decisions
  • No Permission Required: They do not need to call you for permission before every trade
  • Strategy-Based: They buy and sell based on the strategy you agreed upon
  • Independent Management: The manager independently manages your portfolio

Suitability

Discretionary PMS is ideal for investors seeking expert-led management. It is suitable for:

  • Investors who trust the manager's expertise
  • Investors with limited time to monitor investments
  • Investors who want professional management without active involvement
  • Investors who prefer a hands-off approach

What is Non-Discretionary PMS?

Definition

In Non-Discretionary PMS, the portfolio manager provides recommendations, but the final decision to buy or sell rests with the investors themselves.

Key Characteristics

  • Recommendations Only: Manager provides advice and recommendations only
  • Client Decision: Final decision rests with the client
  • Active Involvement: Client must approve each transaction
  • No Discretion: Manager cannot make decisions without client approval

Suitability

Non-Discretionary PMS is suitable for:

  • Investors who want to retain control over decisions
  • Investors who have the time and expertise to evaluate recommendations
  • Investors who want professional advice but want to make final decisions
  • Investors who are actively involved in their investment management

Detailed Comparison

AspectDiscretionary PMSNon-Discretionary PMS
Decision MakerPortfolio ManagerClient
Manager's RoleMakes decisionsProvides recommendations
Client's RoleSets guidelinesMakes final decisions
Approval RequiredNo for individual tradesYes for each transaction
Time CommitmentLowHigh
Control LevelLowHigh
Expertise RequiredLow (client)High (client)

Which Suits Which Investor?

Discretionary PMS Suits:

  1. Busy Professionals: Who don't have time to monitor investments
  2. Trust-Based Investors: Who trust the manager's expertise
  3. Hands-Off Investors: Who prefer a hands-off approach
  4. Sophisticated Investors: Who understand the strategy but don't want to execute
  5. Long-Term Investors: Who have a long-term investment horizon

Non-Discretionary PMS Suits:

  1. Active Investors: Who want to stay involved in decisions
  2. Control-Oriented Investors: Who want to retain control
  3. Knowledgeable Investors: Who have the expertise to evaluate recommendations
  4. Short-Term Investors: Who may want to make quick decisions
  5. High-Net-Worth Individuals: Who have the resources to actively manage

Regulatory Considerations

Discretionary PMS

  • Higher regulatory oversight
  • More compliance requirements
  • Liability of client limited to investment
  • Must maintain client-level segregation

Non-Discretionary PMS

  • Lower regulatory oversight
  • Client makes final decisions
  • Manager provides recommendations only
  • Client retains control over portfolio

Expert Legal Guidance

Anuj Desai & Associates provides expert legal advisory services on PMS structuring and compliance. Our securities law experts help investors choose the right PMS type and ensure regulatory compliance. Contact us for guidance on PMS structuring and other regulatory matters.


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