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

A portfolio manager that only gives investment advice on a client's portfolio, without executing or holding the securities.

2 · Think of it like thisLike a navigator who reads the map while you drive.

4 · A real-world example

A portfolio manager recommends a model portfolio to a family office, which places the trades itself.

5 · Why it matters

Because it does not manage or administer securities, an advisory-only portfolio manager does not need a custodian.

6 · Don't confuse it with

Advisory: advice only. Non-discretionary: the manager also executes the client's directions.

7 · Regulatory meaning

Reg 19, SEBI (Portfolio Managers) Regulations, 2026 (in force from 1 April 2027): every portfolio manager must appoint a custodian for the securities managed or administered by it, unless it provides only advisory services.

8 · Explain it to someone else

Remember it this way: Advisory PMS = advice, not execution.

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

Meet the expert

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.