SEBI and APMI have established comprehensive performance reporting requirements for portfolio managers. This article explains the filing obligations, timelines, and compliance requirements.
Monthly Reporting to APMI and SEBI
Dual Submission Requirement
Portfolio Managers shall submit the monthly reports to APMI in addition to SEBI within 7 working days from the end of each month.
Purpose of APMI Reporting
APMI shall make available the monthly reports of the Portfolio Managers on APMI website in an intuitive and user-friendly manner facilitating ease of comparison so as to provide access to portfolio level, investment approach level, portfolio manager level and industry level information to all the stakeholders.
Relative Performance Disclosure
APMI shall make available relative performance of each investment approach within the strategy to concerned portfolio manager and also disclose the same on its website.
Performance Audit Requirements
Annual Performance Audit
After SEBI's recent tightening of norms, PMS players are required to conduct a performance audit annually.
Submission Timeline
Portfolio managers must submit a report within 60 days after the end of a financial year.
Audit Standards
SEBI and APMI collaboratively established performance audit standards for portfolio management services providers, effective from October 1, 2023.
Firm-Level Performance Data
The firm-level performance data of Portfolio Managers shall be audited annually. Confirmation of compliance shall be reported to SEBI within sixty days of end of each financial year. The said report to SEBI shall be certified by the Directors/Partners of the Portfolio Manager or by person(s) authorized by the Board of Directors/Partners of the Portfolio Manager.
Half-Yearly Periodic Reports
Reporting Periods
Periodic reports must be submitted for half-yearly periods ending September 30 and March 31.
Submission Deadlines
| Reporting Period | Submission Deadline |
|---|---|
| September 30 | October 30 |
| March 31 | April 30 |
Report Contents
The half-yearly report must include:
- General Information
- Net worth statement
- Details of settled and pending disputes
- Indictment or involvement in any economic offence
- List of corporate clients
- Performance of Portfolio Manager in comparison to relevant benchmark indices
- Enclosures including auditor's certificate
Annual Compliance Audit
Audit Completion
Annual compliance audit must be completed within six months from end of financial year.
Audit Report Submission
Submit compliance audit report to RAASB/SEBI within a period of one month from the date of the audit report but not later than October 31st of each year for the previous financial year.
Publication Requirements
- Publish status of compliance audit report on website
- Publish adverse findings of audit, if any, along with action taken
- Provide compliance audit report to clients
Expert Legal Guidance
Anuj Desai & Associates provides expert legal advisory services on PMS performance reporting and audit compliance. Our securities law experts help portfolio managers prepare compliant reports, meet filing deadlines, and ensure regulatory compliance. Contact us for guidance on performance reporting and other regulatory matters.