Dealing team
Also written DT · Dealing team (DT) · Dealing Team (DT)
The team a portfolio manager must constitute to place and execute all orders under its written policies, working from a restricted dealing room with recorded lines and full audit trails.
In plain language
A portfolio manager trades for hundreds of clients at once. Whoever places those orders has a great deal of power — to favour one client over another, to trade ahead of clients, or to leak what the portfolio manager is about to buy.
The dealing team is how the regulations contain that power. Portfolio managers must constitute a dealing team that is responsible for order placement and execution of all orders, strictly according to the portfolio manager's written policies. The team works in a controlled dealing room: recorded phone lines, no mobile phones, restricted internet, restricted entry.
For an investor, the dealing team is invisible. Its purpose is that every client is treated in a fair and equitable manner.
How it works
Written policies first (Chapter 8, section 8.2.1). Portfolio managers must have a written policy covering the roles of fund management, dealing, compliance, risk management and back office, including order placement, execution and trade allocation among clients. A specific policy must cover:
- the specific (not generic) situations in which orders are placed per client individually or pooled from the portfolio manager's trading account;
- when deviation from the intended allotment is permissible;
- how margins or collateral are segregated among clients.
Deviations are allowed only on account of exigency, with prior written approval of the Principal Officer and the Compliance Officer and a detailed rationale. The policies must be approved by the Board or equivalent body.
The dealing team's controls (section 8.2.3).
| Control | Rule |
|---|---|
| Composition | May include the Principal Officer or the person appointed under Regulation 7(2)(e) |
| Communication | Only dedicated recorded telephone lines or emails from authorised email ids |
| Devices | No mobile phones or other devices inside the dealing room |
| Internet | Restricted; only for trade execution |
| Access | Only authorised employees defined in the policies |
| Information | No sharing by any mode except for trade execution under approved policies |
Automation threshold. For equity, equity-related instruments and mutual fund units, portfolio managers with AUM of ₹1,000 crore or more under discretionary and non-discretionary services must have an automated system with minimal manual intervention for funds and securities management, including order management and allocation.
Audit trail. All activities — order placement, trade execution and allocation — must have an audit trail with time stamping.
A worked example
Illustrative portfolio manager and trade; the controls and the pricing rule are the workbook's.
A portfolio manager with ₹4,200 crore under discretionary and non-discretionary services — above the ₹1,000 crore threshold — decides to buy a stock for 60 clients.
- The fund manager sends the decision to the dealing team through the order management system — not by a phone call to a dealer's mobile, which is not allowed in the dealing room.
- The policy says a pooled order is used for this situation. The DT places one pooled order for 30,000 shares.
- The order fills in three lots: 12,000 at ₹502, 10,000 at ₹505 and 8,000 at ₹508.
- Chapter 7's rule for aggregated trades applies: allocation pro rata at the weighted average price of the day's transactions. Weighted average = (12,000 × 502 + 10,000 × 505 + 8,000 × 508) ÷ 30,000 = ₹1,51,38,000 ÷ 30,000 = ₹504.60
- Every client receives shares at ₹504.60 in proportion to its intended allocation. No client gets the ₹502 lot at the others' expense.
- The system time-stamps order placement, execution and allocation.
A month later, a client complains that her allocation was cut. The audit trail shows the fill, the allocation and a deviation note signed in advance by the Principal Officer and Compliance Officer, citing a liquidity exigency — exactly what the written policy required.
Why NISM asks about it
Chapter 8 (Operational Aspects of Portfolio Managers, 13% weightage), sections 8.2.1 to 8.2.3, under "Fair and equitable treatment of all clients". Expect questions on the ₹1,000 crore automation threshold, the prohibition on mobile phones in the dealing room, the recorded-lines rule, and who must approve deviations (Principal Officer and Compliance Officer). Chapter 7's weighted-average-price rule for aggregated trades is the natural companion question.
Common exam traps
- Deviations need prior written approval of both the Principal Officer and the Compliance Officer — not just one.
- The automation requirement is for AUM of ₹1,000 crore or more, and it applies to equity, equity-related instruments and mutual fund units.
- AUM for the threshold counts discretionary and non-discretionary services — advisory is not mentioned.
- Recorded lines or authorised email ids only. Personal mobiles are banned inside the dealing room.
- Policies are approved by the Board or equivalent body, not by the dealing team.
- Aggregated trades are allocated pro rata at the weighted average price, with no open position in allocation at day end (Chapter 7).
- Time stamping covers three events: order placement, order execution and trade allocation.
Where this is taught
Free preparation for NISM Series XXI-ARelated terms
- Chinese WallAn enforced separation inside a firm between departments holding confidential price-sensitive information and those dealing with clients, sales or public research.
- APMIThe Association of Portfolio Managers in India — the PMS industry body that prescribes benchmarks and valuation norms, standardises client documents and registers PMS distributors.
- Principal officerThe named individual at a non-individual intermediary who carries personal regulatory responsibility for the advisory business, and who must personally hold the prescribed qualification and NISM certification.
- Compliance OfficerThe separately appointed officer of a merchant banker, listed company or intermediary who monitors compliance with securities law, handles investor grievances, and reports non-compliance to SEBI independently.
- Portfolio managerA body corporate registered with SEBI that, under a contract with a client, advises on or manages that client's securities or funds — discretionary, non-discretionary or advisory.