CIRCULAR
SEBI/HO/IMD/IMD-PoD-1/P/CIR/2024/32 May 02, 2024
To
All Portfolio Managers
Association of Portfolio Managers in India (APMI)
Madam/ Sir,
Sub: Facilitating collective oversight of distributors for Portfolio Management
Services (PMS) through APMI
1. Regulation 23 (11) of SEBI (Portfolio Managers) Regulations, 2020, inter-alia
states that the portfolio manager shall ensure that any person or entity involved in
the distribution of its services is carrying out the distribution activities in compliance
with the SEBI (Portfolio Managers) Regulations, 2020 and circulars issued
thereunder from time to time.
2. Additionally, Portfolio Managers are required to ensure that distributors abide by
the Code of Conduct as specified in Annexure 2B to the Master Circular dated
March 20, 2023 for Portfolio Managers.
3. In order to simplify and ease compliances, a working group was constituted to
review the present regulatory framework under SEBI (Portfolio Managers)
Regulations, 2020 and recommend measures to promote ease of doing business.
Based on the recommendations of the working group, a public consultation was
carried out.
4. Pursuant to the above, in order to facilitate collective oversight of PMS distributors
at the industry level, it has been decided that any person or entity involved in the
distribution of portfolio management services shall obtain registration with APMI.
Portfolio Managers shall ensure that any person or entity engaged in the
distribution of its services has obtained registration with APMI, in accordance with
the criteria laid down by APMI.
5. This circular shall come into effect from January 01, 2025. APMI shall issue the
criteria for registration of distributors by July 01, 2024.
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6. This circular is issued in exercise of the powers conferred under Section 11(1) of
the Securities and Exchange Board of India Act, 1992 read with Regulation 43 of
SEBI (Portfolio Managers) Regulations, 2020, to protect the interest of investors in
securities and to promote the development of, and to regulate the securities
market.
7. This circular is available at www.sebi.gov.in under the link “Legal ->Circulars”.
Yours faithfully,
Peter Mardi
Deputy General Manager
+91-22-26449233
peterm@sebi.gov.in
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