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SEBI / Portfolio Managers

KYC Requirements for PMS Clients — Onboarding Standards Explained

A comprehensive guide to KYC requirements for PMS clients, including onboarding standards, documentation, and compliance obligations for Portfolio Managers.

25 Jul 20263 min read

Know Your Client (KYC) is a fundamental compliance requirement for portfolio managers. This article provides a comprehensive overview of KYC requirements for PMS clients, including onboarding standards and documentation.

The Regulatory Framework

Legal Basis

Portfolio managers are required to comply with KYC requirements under the SEBI (Portfolio Managers) Regulations, 2020 and the Prevention of Money Laundering Act, 2002. KYC is a mandatory process while onboarding a customer on any SEBI registered intermediary.

Objective

The KYC framework aims to:

  • Prevent money laundering and terrorist financing
  • Verify the identity of clients
  • Assess the risk profile of clients
  • Maintain records of client transactions

KYC Documentation

For Individuals

Identity Proof (any one):

  • PAN Card (mandatory)
  • Aadhaar Card
  • Passport
  • Voter ID Card
  • Driving License

Address Proof (any one):

  • Aadhaar Card
  • Passport
  • Voter ID Card
  • Driving License
  • Bank Statement (not older than 3 months)
  • Utility Bill (not older than 3 months)

Additional Documents:

  • Latest six months' bank statement or passbook
  • Photograph

For Non-Individuals

Entity Documents:

  • Certificate of Incorporation
  • Memorandum and Articles of Association (or Partnership Deed)
  • PAN Card of the entity
  • Board Resolution authorizing the investment
  • List of directors/partners with their KYC documents
  • Audited financial statements

Onboarding Process

Step 1: Document Collection

The portfolio manager must collect all required KYC documents from the client. The custodian handles KYC for PMS accounts.

Step 2: Verification

The portfolio manager must verify:

  • PAN, name, address, mobile number, and email id
  • Identity proof documents
  • Address proof documents
  • Financial information

Step 3: KRA Upload

KYC Registration Agencies (KRAs) must verify KYC records within 2 days of receipt of KYC records. KRAs will verify PAN, name, address, mobile number, and email id.

Step 4: Central KYC Registry

KRAs shall upload the verified/validated KYC information onto the system of Central KYC Records Registry (CKYCRR).

Risk Profiling

Mandatory Requirement

SEBI mandates the implementation of mandatory risk profiling for every PMS client. Providers must evaluate each investor's risk profile.

Risk Assessment

The portfolio manager must assess:

  • Investment objectives
  • Risk tolerance
  • Investment experience
  • Financial situation

Documentation

The risk profiling must be documented and maintained as part of the client records.

Digital Onboarding

Digital KYC

Portfolio managers can use digital KYC processes for onboarding clients. This includes:

  • Aadhaar-based e-signature
  • Video KYC
  • Online document submission

Physical Presence

Currently, digital onboarding is partially allowed for NRIs, with major restrictions such as requiring the investor to be physically present in India during the process.

Ongoing KYC Compliance

Periodic Updation

Portfolio managers must:

  • Review KYC records periodically
  • Update KYC records when there are changes
  • Conduct re-KYC as required

Record Maintenance

Portfolio managers must maintain:

  • KYC records for all clients
  • Records of verification
  • Records of periodic reviews

Consequences of Non-Compliance

Regulatory Action

Failure to comply with KYC requirements can result in:

  • Enforcement action by SEBI
  • Monetary penalties
  • Suspension or cancellation of registration

Business Impact

Non-compliance can lead to:

  • Regulatory scrutiny
  • Reputational damage
  • Disruption of business operations

Expert Legal Guidance

Anuj Desai & Associates provides expert legal advisory services on KYC compliance for portfolio managers. Our securities law experts help clients understand KYC requirements, implement onboarding procedures, and maintain compliance. Contact us for guidance on KYC and other regulatory matters.


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