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SEBI / Research Analysts

Model Portfolio – Risk Disclosures and Audit Requirements

A comprehensive guide on risk disclosures and audit requirements for model portfolios.

25 Jul 20264 min read

Model portfolios must include risk disclosures and be subject to audit requirements. This ensures clients understand the risks and that compliance is verified. This article provides a comprehensive technical analysis of these requirements.

Regulatory Basis

The requirements for risk disclosures and audit are specified in Annexure-A of the Master Circular for Research Analysts.

Risk Disclosures

1. Clear Mention

Requirement: Model portfolio risk should be clearly mentioned in model portfolio report.

What to Include:

  • Market risk.
  • Sector risk.
  • Company-specific risk.
  • Liquidity risk.
  • Concentration risk.
  • Any other relevant risks.

2. Types of Risks

Risk TypeDescription
Market RiskRisk of loss due to market movements
Sector RiskRisk of loss due to sector-specific factors
Company-Specific RiskRisk of loss due to company-specific factors
Liquidity RiskRisk of not being able to sell securities
Concentration RiskRisk of over-concentration in certain securities
Currency RiskRisk of currency fluctuations (for international investments)
Interest Rate RiskRisk of interest rate changes
Inflation RiskRisk of inflation eroding returns

3. Risk Assessment

AspectDescription
Risk LevelLow, Moderate, High
Risk FactorsSpecific factors contributing to risk
Risk MitigationHow risks are managed

Sample Risk Disclosure

"Risk Factors:

The India Large Cap Growth Portfolio is subject to the following risks:

1. Market Risk: The portfolio is subject to market risk, which is the risk of loss due to adverse market movements. The portfolio's value may decline due to market volatility.

2. Sector Risk: The portfolio has significant exposure to the banking and IT sectors. Sector-specific factors may impact portfolio performance.

3. Company-Specific Risk: The portfolio is concentrated in a limited number of companies. Company-specific factors may impact portfolio performance.

4. Liquidity Risk: Some securities in the portfolio may have limited liquidity, which may impact the ability to sell securities at desired prices.

5. Concentration Risk: The portfolio has concentration in certain securities. This may increase volatility.

Risk Level: Moderate

Risk Mitigation: Risks are managed through diversification, periodic review, and rebalancing. The portfolio is reviewed quarterly and rebalanced as needed."

Audit Requirements

1. Applicability

Requirement: Compliance with audit requirement under Regulation 25(3) of the RA Regulations shall also cover compliance with obligations set out under the model portfolio guidelines.

2. What the Audit Covers

AspectDescription
MethodologyIs the methodology followed?
LabellingIs the portfolio true to label?
Investment HorizonIs the horizon specified?
Review FrequencyIs the review frequency followed?
RebalancingIs rebalancing communicated?
BenchmarkingIs benchmarking appropriate?
Risk DisclosuresAre risk disclosures included?
DisclosuresAre all required disclosures included?

3. Audit Process

StepDescription
1Review model portfolio documentation
2Verify compliance with guidelines
3Identify any non-compliance
4Report findings
5Recommend corrective actions

Common Compliance Gaps

1. No Risk Disclosure

Some RAs do not include risk disclosures in model portfolio reports.

Solution: Include comprehensive risk disclosures.

2. Incomplete Risk Disclosure

Some RAs include incomplete risk disclosures.

Solution: Include all relevant risks.

3. Not Covering Model Portfolio in Audit

Some RAs do not cover model portfolio compliance in the audit.

Solution: Ensure audit covers model portfolio compliance.

4. Not Addressing Audit Findings

Some RAs do not address audit findings.

Solution: Address all audit findings promptly.

Conclusion and How Anuj Desai & Associates Can Help

Risk disclosures and audit requirements ensure model portfolios are transparent and compliant.

Anuj Desai & Associates offers specialized services to help RAs comply with model portfolio risk and audit requirements:

  • Review of risk disclosures.
  • Guidance on audit coverage.
  • Compliance audit and advisory.

Contact us today to ensure your model portfolio risk disclosures and audit comply with SEBI requirements. Our team will review your portfolios and provide a tailored compliance roadmap.


Disclaimer: This article is for informational purposes only and does not constitute legal advice. Readers are advised to consult qualified professionals for legal and compliance matters. Anuj Desai & Associates is a SEBI compliance consulting firm based in India.


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