Portfolio Management Services

Structured Compliance Oversight

We assist portfolio managers in meeting ongoing regulatory obligations and reporting requirements.

Coverage Includes:

• Periodic SEBI reporting and disclosures
• Net worth monitoring & capital adequacy checks
• Review of compliance with client agreement terms
• Code of conduct adherence
• Maintenance of statutory records and registers
• Review of advertisement and marketing communications

Outcome:
Continuous regulatory alignment and reduced compliance exposure.

Risk-Based Review of Portfolio Management Framework

Our internal audit evaluates regulatory adherence, operational discipline, and investor protection mechanisms.

Regulatory Compliance Review

• Adherence to SEBI (Portfolio Managers) Regulations and circulars
• Review of periodic compliance certifications
• Monitoring of regulatory disclosures

Client-Level Controls

• KYC verification & CKYC/KRA compliance
• Risk profiling and suitability assessment
• Client agreement review
• Segregation of discretionary / non-discretionary mandates

Investment Process & Mandate Adherence

• Review of documented investment process
• Portfolio construction methodology
• Monitoring of client-specific mandate limits
• Exposure and concentration monitoring

Trade Execution & Operational Controls

• Broker empanelment framework
• Trade execution & allocation controls
• Settlement and reconciliation process
• Prevention of front-running and conflict controls

Fees, Charges & Reporting

• Verification of fee calculation methodology
• Performance reporting review
• Disclosure of expenses and charges
• Review of periodic client portfolio statements

Grievance Redressal Mechanism

• Investor grievance handling process
• Escalation and resolution timelines
• Documentation and reporting controls

Deliverables:

• Structured internal audit report
• Risk-based observations
• Process gap identification
• Actionable remediation roadmap

Outcome:
Strengthened governance and improved investor transparency.

Review & Update of Disclosure Document as Mandated by SEBI

Portfolio Managers are required to maintain and update a Disclosure Document containing material information about the PMS business.

We assist in conducting an annual review to ensure accuracy, completeness, and regulatory alignment.

Scope Includes:

• Review of business activities and services offered
• Update of fee structure and charging methodology
• Review of investment approach & risk factors
• Disclosure of disciplinary history (if any)
• Review of conflict of interest disclosures
• Update of key personnel information
• Verification of material changes requiring disclosure

Deliverables:

• Updated Disclosure Document
• Compliance confirmation checklist
• Advisory on material change disclosures

Outcome:
Transparent and regulator-aligned disclosure framework.

SEBI Inspection Readiness & Response Assistance

We assist portfolio managers in preparing for and responding to regulatory inspections and information requests.

Services Include:

• Pre-inspection compliance review
• Documentation collation and structuring
• Drafting responses to regulatory queries
• Assistance in compliance clarification
• Post-inspection remediation advisory

Outcome:
Structured regulatory response management and reduced operational disruption.