NISM Certifications · NISM-Series-X-A: Investment Adviser (Level 1)
Portfolio Manager: formula sheet
Key formulas
- Discretionary PMS
- Manager decides + manager executes, no per-trade approval
- Manager acts on the client's behalf within the contract and client's objectives.
- Non-discretionary PMS
- Manager decides + client approves each transaction before it is executed
- Prior consent for each deal is the key feature.
- Advisory PMS
- Manager advises + client decides and executes
- The manager does not execute trades for the client.
- PMS vs mutual fund
- PMS = individual client portfolio; mutual fund = pooled units with one NAV
- A PMS client holds securities directly through an individual account.
- Governing document
- Portfolio management agreement between manager and client
- Sets out the type of service, scope, fees and risks.
- Who can be registered
- Portfolio manager = body corporate holding a SEBI certificate of registration
- An individual cannot be registered as a portfolio manager. Watch for options that say individuals can.
- Minimum net worth
- Net worth ≥ ₹5 crore
- Must be maintained at all times. Earlier regulations had a lower figure, so reject older numbers such as ₹2 crore.
- Net worth composition
- Net worth = paid-up capital + free reserves − accumulated losses − deferred revenue expenditure − miscellaneous expenditure not written off − similar items
- Use the regulation's definition. Do not add or exclude items on your own.
- Minimum client investment
- Funds + securities (or either) accepted from a client at onboarding ≥ ₹50 lakh
- The minimum is tested at the time of onboarding. Funds, securities or both can make up the amount.
- Types of PMS
- Discretionary = manager decides | Non-discretionary = client decides
- Identify the type by who takes the investment decision. Investment advisory services are a separate service a portfolio manager may offer, not a third kind of PMS.
- Returns
- No guaranteed returns may be promised
- Any promise or assurance of returns is prohibited. Past performance is not a guarantee.
- Onboarding sequence
- Disclosure document → KYC → Risk profiling → Agreement → Account opening
- A safe order to remember. The disclosure document must reach the client before the agreement is signed.
- Agreement type
- Discretionary | Non-discretionary | Advisory
- The agreement must state which service applies, because it fixes who takes the investment decision.
- Accredited investor
- Meets SEBI criteria + certified by an accreditation agency
- Status comes from certification, not from the investor's own claim.
- Minimum investment
- Check the current SEBI minimum per client for PMS
- Learn the exact current figure and any accredited investor relaxation from the latest NISM workbook. Do not guess.
- Fixed fee
- Fixed fee = AUM × fee rate % (for the period)
- Charged irrespective of performance. Pro-rate if the period is less than a year.
- Performance fee with hard hurdle
- Fee = profit share % × (ending value − (opening value × (1 + hurdle)))
- Charged only if the ending value is above the hurdle value. Otherwise the fee is nil.
- Performance fee with soft hurdle
- Fee = profit share % × total profit, if return ≥ hurdle
- Once the hurdle is cleared, the share applies to the whole profit. Nothing is due if the hurdle is not met.
- Performance fee with high water mark
- Fee = profit share % × (ending value − high water mark), if positive
- The high water mark is the highest value on which a fee was already paid. Nil fee if the value is at or below it.
- Time-weighted rate of return
- TWRR = [(1 + r₁) × (1 + r₂) × … × (1 + rₙ)] − 1
- Each r is the return of a sub-period between cash flows. Chain the sub-periods by multiplying, not adding.
- Types of PMS
- Discretionary = manager decides | Non-discretionary = client consent needed | Advisory = advice only
- Exam questions often ask who takes the investment decision or who executes it.
- Minimum client investment
- ₹50,00,000 per client (funds or securities); relaxed for accredited investors
- Applies under the 2020 Regulations to discretionary and non-discretionary services, across all of the client's portfolios with the manager. It is not a requirement for the advisory service. Do not confuse it with the manager's net worth requirement.
- Minimum net worth of portfolio manager
- ₹5 crore, maintained at all times
- This is a continuing requirement for the manager, needed at registration and afterwards. It is not a client limit.
- Investment approach
- Investment approach = broad outline of securities and instruments + objective
- It is disclosed to clients. A manager may offer more than one.
- Segregation rule
- Manager's own funds ≠ client funds; client A ≠ client B
- Separate bank accounts and separate client-wise records apply.
- Returns rule
- No guarantee or assurance of returns
- Past performance may be shown with disclosures, but future returns cannot be promised.
Quick revision
- PMS means a portfolio manager manages a client's funds or securities under a contract, within SEBI's Portfolio Managers Regulations, 2020.
- Three service types: discretionary, non-discretionary and advisory. The key difference is who takes the investment decision.
- In discretionary PMS, the manager decides and executes on the client's behalf. In non-discretionary, the client's consent is needed for each decision.
- An advisory service gives advice only. The client makes and executes the decisions.
- Portfolio managers need SEBI registration and must meet the net worth and minimum client investment rules in the workbook.
- A written agreement is signed with every client, supported by a disclosure document.
- Fee models are fixed, return-based or hybrid. Know how a hurdle rate affects the performance fee.
- Client money and securities must be kept separate from the manager's own.
- Performance is reported to clients regularly, using the method and frequency in the workbook.
- On a wrong answer in X-A you lose 25% of that question's marks, so skip only when you cannot narrow the options.
Common mistakes
- Saying non-discretionary PMS means the client takes the decision. Fix: The manager still gives the decision. The client only approves it before execution.
- Thinking advisory PMS means the manager executes trades. Fix: In advisory PMS the manager only advises. The client decides and executes.
- Choosing ₹2 crore as the minimum net worth. Fix: For the 2020 regulations, use ₹5 crore. Treat ₹2 crore as an outdated figure.
- Counting only cash towards the ₹50 lakh client minimum. Fix: The minimum can be met in funds, securities or both at onboarding. Add them together and compare with ₹50 lakh.
- Treating the disclosure document and the agreement as the same document. Fix: The disclosure document informs before signing. The agreement is the binding contract.
- Thinking the client can sign first and receive the disclosure document later. Fix: Remember that the client must have the disclosure document before entering the agreement.
- Charging the performance fee on the whole profit under a hard hurdle. Fix: Hard hurdle means the fee is only on the excess over the hurdle. Soft hurdle means the fee is on the whole profit once the hurdle is cleared.
- Charging a performance fee when the value recovers to the old peak but not beyond it. Fix: Compare the ending value with the high water mark. Only the amount above it is chargeable.
- Treating PMS like a mutual fund with pooled units. Fix: Remember that PMS holds securities in the client's own portfolio, while a mutual fund pools money and issues units.
- Mixing up ₹50,00,000 and ₹5 crore. Fix: ₹50,00,000 is the client's minimum investment. ₹5 crore is the manager's minimum net worth.
Exam tips
- Reduce every type to three words: decide, approve, execute. Write them on your rough sheet at the start.
- Watch for scenario questions with no type named. The clue is usually a phrase like 'with the client's prior consent' or 'client places the order'.
- Expect distractors that swap the features of discretionary and non-discretionary PMS. Read both ends of the sentence.
- Under 25% negative marking on NISM-Series-X-A, a wrong answer costs a quarter of the question's marks. Eliminate two options before guessing.
- Study this topic with the SEBI Portfolio Managers Regulations, as questions on the types often blend with agreement and regulatory rules.
- Memorise the two figures: ₹5 crore for the manager's net worth and ₹50 lakh for the client minimum. Many questions are only a number check.
- Check which regulation version a question refers to. The 2020 regulations replaced the 1993 ones, so reject old figures.
- Read options for absolute words such as 'guaranteed', 'any individual' or 'only once'. These are usually wrong.