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Investment approach

Also written IA · Investment approaches

A broad outlay of the securities and permissible instruments a portfolio manager will invest in for a client, set out in the PMS agreement and tagged to exactly one strategy.

In plain language

A PMS is not one product. A single portfolio manager may run a large-cap equity approach, a mid-cap approach, a debt approach and a multi-asset approach — each with its own universe of securities, its own style and its own track record.

Each of those is an investment approach. The SEBI (Portfolio Managers) Regulations, 2020 define it as a broad outlay of the type of securities and permissible instruments to be invested in by the portfolio manager for the customer, taking into account factors specific to clients and securities. Chapter 9 adds a plainer description: the documented investment philosophy the portfolio manager adopts while managing client funds to achieve the client's investment objectives.

For a PMS distributor it is the unit of sale. Clients do not invest "in a portfolio manager"; they invest in one or more of its investment approaches.

How it works

It is a regulatory requirement in the agreement. The PMS agreement must include the investment approach, areas of investment and any restrictions the client places on investing in a particular company or industry, plus the type of instruments and proportion of exposure (Chapter 7, section 7.5.1; Chapter 8, section 8.3.4; Chapter 9, section 9.3.4). The account opening form records the investment approach and portfolio construction choice opted for.

Strategies and benchmarks (Chapter 9, section 9.3.8).

  • SEBI added a layer of broad themes called strategies: equity, debt, hybrid and multi-asset.
  • Each investment approach is tagged to one and only one strategy, at the portfolio manager's discretion.
  • APMI prescribes a maximum of three benchmarks for each strategy; the portfolio manager selects one of them for each investment approach.
  • The Board of the portfolio manager is responsible for appropriate selection of strategy and benchmark.
  • Tagging can be changed only after offering subscribers an option to exit without exit load. The track record before the change cannot be used for performance reporting, and the change is verified in the annual audit under Regulation 30.

Performance reporting (Chapter 8, section 8.8). When advertising an investment approach's performance, the portfolio manager presents its TWRR with the trailing return of the selected benchmark. When reporting to an investor, it presents the investor's XIRR for each approach, with the minimum, maximum and median XIRR across all investors in that approach.

A worked example

The portfolio manager and client are illustrative; the rules are the workbook's.

A portfolio manager offers three investment approaches:

Investment approachStrategy tagBenchmark (one of APMI's up to three)
Large-Cap QualityEquityNIFTY 50
Short-Duration IncomeDebtA bond index with similar maturity and credit profile
Balanced AllocationHybridA hybrid index

Ananya invests ₹60 lakh in Large-Cap Quality. Her agreement records the approach, the instruments and exposure proportions, and her restriction: no tobacco companies.

Two years later the Board decides Large-Cap Quality now belongs under multi-asset. Before changing the tag, the portfolio manager must offer Ananya and every other subscriber an exit without exit load. If she stays, the approach's pre-change track record can no longer be shown in its performance reports — and the change, with its justification, is checked in the annual audit.

Her quarterly report shows her own XIRR, the approach's TWRR, the benchmark's trailing return, and the min/max/median XIRR of all investors in the approach, with the disclaimer that her result may differ because of the timing of her cash flows and her portfolio's restrictions.

Why NISM asks about it

One of the most connected terms in the paper: Chapter 7 (Role of Portfolio Managers, 10%), Chapter 8 (Operational Aspects, 13%) and Chapter 9 (Portfolio Management Process, 15%). Chapter 7's sample question gives the definition and asks you to name it — investment approach, against distractors "investment statement", "investment strategy" and "investment risk profile". The PMS distributor code of conduct in Chapter 12 requires distributors to be fully conversant with investment approaches and to disclose distribution commissions for each.

Common exam traps

  • Investment approach is not the same as strategy. Strategy is the broad tag (equity, debt, hybrid, multi-asset); the approach sits beneath it.
  • One approach, one strategy. Chapter 9 also contains a garbled sentence saying a portfolio manager "may tag more than one Investment strategy to an investment approach", but the same sentence ends "each investment approach must be tagged to only one strategy". Go with one.
  • APMI prescribes up to three benchmarks per strategy; the portfolio manager picks one per approach.
  • Changing a tag requires a no-exit-load exit option first, and the old track record cannot be used.
  • TWRR is for the approach; XIRR is for the individual investor.
  • "Investment policy statement" is a different document — the investor's roadmap, not the manager's product definition.

Check yourself

  1. 1.An ________ is a broad outlay of the type of securities and permissible instruments to be invested in by the portfolio manager for the customer, considering factors specific to clients and securities.

    1. a)investment approach
    2. b)investment statement
    3. c)investment strategy
    4. d)investment risk profile
    Show the answer

    Answer: (a) investment approach

    This is the workbook's definition of an investment approach. It forms part of the client agreement and defines the universe of securities.

    "Investment strategy" is the closest distractor but is not the defined term. A risk profile describes the investor, not the securities.

  2. 2.In the account opening form format under the Portfolio Managers Regulations, 2020, details such as risk tolerance, investment horizon and withdrawal choice fall under which part?

    1. a)General information about the client
    2. b)Investment approach and portfolio construction choice
    3. c)Investment profile of the client
    4. d)Introducer details
    Show the answer

    Answer: (c) Investment profile of the client

    The form has three blocks. Investment profile of the client covers “Experience, Risk Tolerance, Investment Horizon, Investment Objective, Withdrawal Choice etc.”

    General information is name, mailing addresses, photograph, PAN, driving licence, occupation, introducer details and income details — so introducer details are only one item within general information. The investment approach and portfolio construction choice block records which approach the client has opted for, not the client's own risk profile.

  3. 3.Farida joins a PMS by transferring listed shares worth ₹52 lakh on the on-boarding date. Which statement is correct?

    1. a)The portfolio manager must hold the shares unchanged for at least one year
    2. b)The shares must first be sold by Farida and the cash brought in
    3. c)The portfolio manager may sell all or part of the shares to meet her investment objectives within the investment approach
    4. d)The shares count only at 50% of their value towards the minimum investment
    Show the answer

    Answer: (c) The portfolio manager may sell all or part of the shares to meet her investment objectives within the investment approach

    Investment can be “in cash or in securities or a combination of the two worth minimum Rs. 50 lacs”, with the valuation of the securities on the on-boarding date meeting the regulatory criteria. Then: “The portfolio manager may execute the sale of all or part of such securities to meet the investment objectives of the client within the investment approach.”

    There is no lock-in on transferred shares, no need for Farida to sell them first, and no haircut — the workbook values them on the on-boarding date. At ₹52 lakh she meets the ₹50 lakh floor.

Where this is taught

Free preparation for NISM Series XXI-A

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