Circular No. SEBI/HO/IMD/DF1/OW/P/2021/3186. Dated 05.02.2021 

The SEBI made it clear in an interpretive letter issued to Sundaram Alternate Assets Limited under the informal guidance scheme that no separate listing is required to provide investment advice to general investors under IA Regulation.  

In addition, a portfolio manager registered under PMS regulation is also exempt from seeking registration as an investment adviser when it provides any random investment advice to its clients. 

In any case, the portfolio manager would be needed to follow general commitments and duties under Chapter III of the IA Regulations, where it renders warning administrations to customers as far as the portfolio the executives understanding endorsed with the customer and portfolio supervisor.