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SEBI / Portfolio Managers

Model Portfolio in PMS — Definition, Risk Disclosures & Audit Requirements

A comprehensive guide to model portfolios in PMS, including definition, risk disclosures, and audit requirements under SEBI regulations.

25 Jul 20263 min read

Model portfolios are an important aspect of portfolio management services. This article explains what model portfolios are, their risk disclosure requirements, and audit obligations.

What is a Model Portfolio?

Definition

A model portfolio is a basket of securities for which a research report is issued by a research analyst recommending the relevant weightages for one or more securities mentioned therein. In the context of PMS, a model portfolio represents a pre-defined investment strategy or approach.

Key Characteristics

  • Pre-defined investment strategy
  • Specified weightages for securities
  • Based on documented investment philosophy
  • Used as a template for client portfolios

Model Portfolio in PMS

The portfolio manager curates a unique focused portfolio (usually 10-12 stocks) for each client based on the timing and quantum of his/her investments.

Regulatory Framework

Investment Approach

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.

Model Portfolio Restrictions

The portfolio managers in India are not allowed to disclose any model portfolio returns or the performance of one or more cherry-picked portfolios in any communication.

Risk Disclosures

General Risks

Model portfolios are subject to:

  • Market risks
  • Concentration risks
  • Liquidity risks
  • Sector-specific risks

Investment Approach Risks

The investment approach must disclose:

  • Risks associated with the investment approach
  • Risk factors specific to the strategy
  • Market risks applicable to the securities

Disclosure Requirements

Portfolio managers must disclose:

  • The investment approach in the Disclosure Document
  • Risks associated with each investment approach
  • Performance of the investment approach

Audit Requirements

Performance Validation

Model portfolios must undergo performance validation.

Benchmarking

Model portfolios must be benchmarked to relevant indices.

Facts heet

Model portfolios must be accompanied by a detailed factsheet outlining:

  • Methodology
  • Disclosures
  • Investment horizon

Annual Audit

Model portfolio performance must be verified as part of the annual compliance audit.

Compliance Requirements

Uniform Nomenclature

The information about investment approaches offered by portfolio managers shall be uniform across all types of regulatory reporting, client reporting, disclosure document, marketing materials.

Description Requirements

Any description of investment approach must include:

  • Investment objective
  • Description of types of securities
  • Basis of selection of securities
  • Allocation across types of securities
  • Appropriate benchmark
  • Indicative tenure or investment horizon
  • Risks associated

Prohibited Activities

Cherry-Picking

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

Model Portfolio Returns

Model portfolio returns cannot be disclosed in any communication.

Expert Legal Guidance

Anuj Desai & Associates provides expert legal advisory services on model portfolio compliance for portfolio managers. Our securities law experts help clients define compliant investment approaches, disclose risks appropriately, and ensure regulatory compliance. Contact us for guidance on model portfolios and other regulatory matters.


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