Tuesday, Dec 2, 2025
In a SEBI-registered PMS, your securities are always held in demat accounts in your own name with an approved custodian/DP, while your funds sit in designated bank accounts (pool/PIS/NRE/NRO) linked to the PMS structure, not in the PMS provider’s personal bank account. The exact bank-account setup differs for resident and NRI clients, but legal ownership of securities remains with you in both cases.
● Shares and other listed securities are held in a demat account opened specifically for the PMS with a custodian or depository participant (e.g., a large bank), with the demat in your name and PAN, and assets segregated client-wise as required by SEBI.
● Cash you transfer to the PMS typically goes into a PMS pool bank account maintained by the portfolio manager with a scheduled commercial bank, separate from the manager’s own funds and used only for client investments and related credits/debits.
● For NRIs, a dedicated NRE or NRO bank account (and often PIS-designated where applicable) is opened solely for PMS investments; the PMS and its banking partner use this account structure to route your funds in and out as per FEMA/RBI rules.
● Your equity and other securities are again held in a custodian demat account tagged to you (often with the same bank acting as custodian), with your holdings recorded separately from other PMS clients and from the PMS provider’s proprietary assets.
● SEBI regulations mandate that portfolio managers segregate each client’s funds and securities from their own and maintain separate client-wise accounts, whether the client is resident or NRI.
● Portfolio managers may maintain a combined bank account for all clients’ funds, but it must be a distinct “clients’ funds” account with proper records of all client-wise credits, debits, dividends, interest, and corporate action benefits.
|
Aspect |
Resident PMS client |
NRI PMS client |
|
Where shares are held |
Client-specific demat with custodian/DP in your name. |
Client-specific demat with custodian/DP in your name. |
|
Where cash is held |
PMS pool/clients’ bank account with scheduled bank. |
NRE/NRO (often PIS) account plus PMS clients’ bank account as per setup. |
|
Legal owner of securities |
Always the client (you), not the PMS. |
Always the client (you), not the PMS. |