PMS Disclosure
Portfolio Management Services (PMS) — Disclosure
1. What is Portfolio Management Services (PMS)?
Portfolio Management Services (PMS) is a customised investment service offered by SEBI-registered Portfolio Managers to high-net-worth individuals (HNIs) and institutions. Unlike Mutual Funds where all investors hold units in a common pool, PMS provides each investor with a dedicated, individual portfolio of stocks, bonds, or other securities managed by a professional Portfolio Manager.
- Customised Portfolio: Each investor gets a separate demat account — investments are personalised to their risk profile and goals
- Direct Ownership: Investor directly owns the underlying securities — unlike MF where they own units
- Professional Management: Managed by SEBI-registered Portfolio Managers with defined strategies
- Higher Flexibility: Portfolio Manager can take concentrated bets — higher potential returns AND higher risk
- Regulatory Body: SEBI regulates PMS under SEBI (Portfolio Managers) Regulations 2020
- Industry Body: APMI (Association of Portfolio Managers in India) — all PMS distributors must hold APMI APRN
2. Types of PMS
Discretionary PMS
Portfolio Manager takes all investment decisions on behalf of the investor. Investor gives a power of attorney. Most common form of PMS in India.
Non-Discretionary PMS
Portfolio Manager recommends investments but investor approves each transaction. Investor retains decision-making authority.
Advisory PMS
Portfolio Manager only provides advice — execution is done by the investor themselves. Least common form.
Equity PMS
Most popular — focused on listed equity stocks. Strategies include Value, Growth, Momentum, Quality, GARP (Growth at Reasonable Price).
3. Who Can Invest in PMS?
Eligible Investors
Resident Indians | NRIs (with RBI approval) | HUFs | Partnership Firms | Companies | Trusts | Family Offices with minimum Rs. 50 Lakhs available for PMS
Not Suitable For
Investors with less than Rs. 50 Lakhs investable surplus | Conservative risk profile investors | Investors needing high liquidity | First-time equity investors
4. Key Risks in PMS — Please Read Carefully
- Market Risk: PMS portfolios are subject to market fluctuations — portfolio value can fall significantly during bear markets
- Concentration Risk: PMS portfolios are typically concentrated (15-30 stocks) — higher impact from individual stock failures vs diversified MF
- Liquidity Risk: Some PMS strategies invest in mid/small cap or illiquid stocks — redemption may take longer than Mutual Funds
- Strategy Risk: PMS performance depends heavily on the Portfolio Manager's skill and market conditions — no guarantee of outperformance
- Benchmark Risk: PMS may significantly underperform its benchmark index in certain market conditions
- Manager Risk: Fund manager change can significantly impact portfolio performance and strategy continuity
- Cost Risk: PMS fees (management fee + performance fee) are higher than Mutual Fund TER — costs impact net returns
- Regulatory Risk: Changes in SEBI regulations, tax laws, or market structure can impact PMS strategy performance
5. PMS Fee Structure — Understanding the Costs
| Fee Type | Description & Typical Range |
|---|---|
| Management Fee (Fixed) | Annual fee charged on AUM regardless of performance. Typically 1% to 2.5% per annum. Charged quarterly or monthly. |
| Performance Fee | Fee charged on profits above a hurdle rate. Typically 10% to 20% of gains above hurdle. Hurdle rate typically 8% to 10% per annum. |
| Exit Load / Lock-in | Some PMS have exit loads if redeemed before 1-3 years. Ranges from 1% to 3% in early years. Some have no exit load. |
| Custodian / Demat Charges | Annual demat account maintenance and custodian charges. Typically Rs. 1,000 to Rs. 5,000 per annum. |
| Brokerage / Transaction Cost | Charged on each buy/sell transaction. Typically 0.1% to 0.5% per transaction. Varies by PMS manager. |
| GST | 18% GST applicable on management fee and performance fee. Per AMFI BPG 123/2025-26, GST is over and above the fee. |
6. Niveau Financial Services's Role as PMS Distributor
- Niveau Financial Services acts as a distributor of PMS — we are NOT the Portfolio Manager
- All investment decisions in PMS are taken by the respective SEBI-registered Portfolio Manager — not by Niveau Financial Services
- Niveau Financial Services holds APMI APRN registration (Under renewal process) as required for PMS distribution
- Niveau Financial Services receives a referral fee / distribution fee from PMS managers — disclosed separately
- PMS recommendations are made only after thorough investor risk profiling and suitability assessment
- PMS is recommended ONLY to Aggressive risk profile investors with minimum 5-year investment horizon
- All PMS-related queries and grievances should first be addressed to Niveau Financial Services at Support@niveau.in or 9821298901
7. PMS Managers Empanelled with Niveau Financial Services
The following SEBI-registered Portfolio Managers are currently empanelled with Niveau Financial Services. Investors can invest in their strategies through Niveau Financial Services.
8. Before Investing in PMS — Your Checklist
- ✅ Read the complete Disclosure Document of the PMS manager — mandatory per SEBI regulations
- ✅ Verify SEBI registration of the Portfolio Manager at sebi.gov.in
- ✅ Understand the fee structure completely — management fee, performance fee, exit load, and GST
- ✅ Review the PMS strategy's 3-year and 5-year track record vs benchmark
- ✅ Understand the investment mandate — what the strategy invests in, concentration level
- ✅ Confirm the fund manager's track record and continuity
- ✅ Ensure Rs. 50 Lakhs minimum is from investable surplus — not your emergency fund or short-term money
- ✅ Sign the PMS Agreement and Power of Attorney only after fully understanding the terms
- ✅ Keep your other investments (MF, FD) diversified — PMS should be a part, not all, of your portfolio

