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

Topic D of 6 · 17 terms

Money and investor economics

Who puts money in, who gets paid, and when?

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1 · In one sentence

Keeping each client's securities and money separate from the portfolio manager's own and from other clients'.

2 · Think of it like thisLike separate lockers in a bank: each key opens only one person's box.

4 · A real-world example

Each client's shares are in that client's own account, and client money sits in a separate account with a scheduled commercial bank.

5 · Why it matters

If the portfolio manager runs into trouble, each client's assets remain identifiable as that client's.

6 · Don't confuse it with

In a pooled fund, investors own units of the fund; in PMS, each client directly owns their own securities.

7 · Regulatory meaning

Reg 16(8), (9), SEBI (Portfolio Managers) Regulations, 2026 (in force from 1 April 2027): the portfolio manager segregates each client's holding of securities in separate accounts and keeps the funds of all clients in a separate account maintained with a scheduled commercial bank.

8 · Explain it to someone else

Remember it this way: Segregation = one client, one locker.

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.