Portfolio Management Services (PMS) — Disclosure

Per SEBI (Portfolio Managers) Regulations 2020 | APMI Guidelines | Mandatory Disclosure for PMS Distribution

Gaurav Singhvi | 143128 | APMI APRN: APRN08183 | Valid Until: 09-Mar-2029 | Last Updated: July 2026

About This Disclosure Gaurav Singhvi (143128) is empanelled as a distributor with the Portfolio Management Service providers listed on this page. This disclosure is made in accordance with SEBI (Portfolio Managers) Regulations 2020, APMI guidelines, and AMFI Master Circular. Investors are strongly advised to read the complete Disclosure Document of each PMS manager before making any investment decision.

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

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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.

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Non-Discretionary PMS

Portfolio Manager recommends investments but investor approves each transaction. Investor retains decision-making authority.

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Advisory PMS

Portfolio Manager only provides advice — execution is done by the investor themselves. Least common form.

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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?

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Eligible Investors

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Not Suitable For

Investors with less than Rs. 50 Lakhs investable surplus | Conservative risk profile investors | Investors needing high liquidity | First-time equity investors

⚠️ SEBI Mandatory Minimum — Rs. 50 Lakhs As per SEBI (Portfolio Managers) Regulations 2020, the minimum investment amount in any PMS is Rs. 50 Lakhs (Rupees Fifty Lakhs) per investor per Portfolio Manager. This minimum is set by SEBI to ensure only sophisticated investors with adequate financial capacity participate in PMS.

4. Key Risks in PMS — Please Read Carefully

Risk Disclosure — Mandatory per SEBI (Portfolio Managers) Regulations 2020

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.

Important: Unlike Mutual Funds where TER is included in NAV, PMS fees are charged separately and directly reduce your portfolio value. Always ask for the complete fee schedule before investing. Request the Disclosure Document which contains the full fee structure.

6. Gaurav Singhvi's Role as PMS Distributor

Gaurav Singhvi 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 Gaurav Singhvi
Gaurav Singhvi holds APMI APRN registration (APRN08183) as required for PMS distribution
Gaurav Singhvi 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 Gaurav Singhvi at gauravsinghvimf@gmail.com or 9904336060

7. PMS Managers Empanelled with Gaurav Singhvi

The following SEBI-registered Portfolio Managers are currently empanelled with Gaurav Singhvi. Investors can invest in their strategies through Gaurav Singhvi.

Add PMS companies from the left panel

Verify PMS registration at sebi.gov.in → Registered Entities → Portfolio Managers. Always request and read the PMS Disclosure Document before investing.

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

🔍 Verify PMS Registrations — Official Portals

Verify every PMS manager and distributor using these official government portals before investing.

SEBI — PMS Managers

sebi.gov.in → Portfolio Managers ↗

Verify SEBI registration, Disclosure Document, and compliance status of PMS managers

APMI — PMS Distributors

apmiindia.org ↗

Verify APMI APRN registration of PMS distributors including Gaurav Singhvi

SEBI SCORES — Grievances

scores.sebi.gov.in ↗

Lodge complaint against PMS manager or distributor if unresolved at firm level

SMART ODR — Dispute Resolution

smartodr.in ↗

Online dispute resolution for PMS-related investor disputes

Contact Gaurav Singhvi for PMS QueriesFor any queries regarding PMS investments, strategies, fee structures, or to schedule a detailed discussion, contact us at gauravsinghvimf@gmail.com or 9904336060. We will provide complete information and the PMS Disclosure Document free of charge before any investment commitment.