FME Regulatory Intelligence, Learning & Practice · IFSCA (Fund Management) Regulations, 2025

Topic C of 6 · 14 terms

Fund products and strategies

What does the fund invest in, and how?

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1 · In one sentence

The portfolio manager decides what to buy and sell for each client, without asking the client before every trade.

2 · Think of it like thisLike telling a driver where you want to end up and letting them choose the route.

4 · A real-world example

A client signs a discretionary agreement; the manager rebalances the portfolio each quarter without seeking approval for each trade.

5 · Why it matters

The client gives up day-to-day control, so the agreement, the Disclosure Document and regular reports matter more.

6 · Don't confuse it with

Discretionary: the manager decides. Non-discretionary: the client decides and the manager carries out the directions.

7 · Regulatory meaning

Reg 16(1), SEBI (Portfolio Managers) Regulations, 2026 (in force from 1 April 2027): the discretionary portfolio manager individually and independently manages each client's funds according to the client's needs, in a manner that does not partake the character of a mutual fund.

8 · Explain it to someone else

Remember it this way: Discretionary = the manager chooses the trades.

Plain-English explanations to aid understanding. Regulatory points cite their source; general finance concepts are explained as commonly used. Not legal or tax advice.

Prashant Kumar

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CS Prashant Kumar

Company Secretary & Compliance Officer
Global Horizons Capital Advisors (IFSC) Private Limited — an IFSCA-licensed investment banker

13+ years of experienceFCS Fellow member, ICSIAuthor Audit Under Fire

Published in The Chartered Accountant (Jun 2025, Jan 2025, Mar 2024) and Chartered Secretary (Aug 2023)

Prashant Kumar is a seasoned Company Secretary and corporate governance strategist with more than 13 years of experience advising large corporates, promoter-led groups and global businesses on compliance, regulatory risk and board governance. In GIFT IFSC, the IFSCA regime is his day job rather than a research topic.