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SEBI / Portfolio Managers

Investment Approach Disclosure — What Every Portfolio Manager Must Specify Upfront

A comprehensive guide to investment approach disclosure requirements for Portfolio Managers, including what must be specified upfront and compliance obligations.

25 Jul 20263 min read

Investment approach disclosure is a critical compliance requirement for portfolio managers. This article explains what must be specified upfront and the regulatory obligations.

What is an Investment Approach?

Definition

An Investment Approach is the documented investment philosophy adopted by the portfolio manager while managing the client's funds in order to achieve client's investment objectives.

Purpose

The investment approach provides:

  • Clarity on how the portfolio will be managed
  • Basis for client evaluation
  • Framework for performance measurement
  • Transparency in investment decisions

What Must Be Specified

Mandatory Contents

Any description of investment approach must include:

  1. Investment objective: What the approach aims to achieve
  2. Description of types of securities: Equity, debt, listed, unlisted, convertible instruments
  3. Basis of selection: How securities are selected
  4. Allocation: Allocation across types of securities
  5. Appropriate benchmark: Benchmark to compare performance and basis for choice
  6. Indicative tenure: Investment horizon
  7. Risks: Risks associated with the investment approach
  8. Other salient features: Any other relevant information

Strategy Tagging

Each Investment Approach must be tagged to one broad Strategy:

  • Equity
  • Debt
  • Hybrid
  • Multi-Asset

Benchmark Selection

For each Strategy, the portfolio manager must select one benchmark from those prescribed.

Uniform Nomenclature

Requirement

The information about investment approaches offered by portfolio managers shall be uniform across all types of:

  • Regulatory reporting
  • Client reporting
  • Disclosure document
  • Marketing materials
  • Any other document referring to services offered

Rationale

Uniform nomenclature ensures:

  • Consistent understanding by clients
  • Easy comparison across portfolio managers
  • Regulatory oversight
  • Transparency

Disclosure Document

Static Section

The investment approach must be disclosed in the static section of the Disclosure Document.

Dynamic Section

Any changes to the investment approach must be disclosed in the dynamic section.

Update Requirements

Material changes in the investment approach must be:

  • Disclosed to clients
  • Updated in the Disclosure Document
  • Filed with SEBI within 7 working days

Performance Disclosure

Performance Reporting

Portfolio manager must disclose relative performance of its investment approach in all marketing material where performance is presented.

Performance Components

The disclosure must include:

  • Performance relative to selected benchmark
  • Performance relative to other portfolio managers within the selected Strategy

Aggregated Performance

Aggregated performance statistics of all investors in an investment approach may be used for performance reporting.

Prohibited Activities

Cherry-Picking

The performance of one or more cherry-picked investor(s) cannot be mentioned or implied in performance reporting.

Model Portfolio Returns

Model portfolio returns cannot be disclosed.

Expert Legal Guidance

Anuj Desai & Associates provides expert legal advisory services on investment approach disclosure compliance for portfolio managers. Our securities law experts help clients define compliant investment approaches, draft disclosure documents, and ensure regulatory compliance. Contact us for guidance on investment approach disclosure and other regulatory matters.


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