⚠️ Important — Read Before Investing in PMS
Portfolio Management Services (PMS) are high-risk, sophisticated investment products suitable ONLY for investors with a minimum investable surplus of Rs. 50 Lakhs in this asset class and high risk tolerance. PMS is NOT a Mutual Fund. Past performance of any PMS strategy does not guarantee future returns. Please read the PMS Disclosure Document carefully before investing.
Portfolio Management Services (PMS) — Disclosure
Per SEBI (Portfolio Managers) Regulations 2020 | APMI Guidelines | Mandatory Disclosure for PMS Distribution
Bhavin Gunvantray Patel | 176351 | APMI APRN: APRN00517 | Valid Until: 2029-05-10 | Last Updated: September 2026
About This Disclosure
Bhavin Gunvantray Patel (176351) is empanelled as a distributor with the Portfolio Management Service providers listed on this page. This disclosure is made in accordance with SEBI (Portfolio Managers) Regulations 2020, APMI guidelines, and AMFI Master Circular. Investors are strongly advised to read the complete Disclosure Document of each PMS manager before making any investment decision.
1. What is Portfolio Management Services (PMS)?
Portfolio Management Services (PMS) is a customised investment service offered by SEBI-registered Portfolio Managers to high-net-worth individuals (HNIs) and institutions. Unlike Mutual Funds where all investors hold units in a common pool, PMS provides each investor with a dedicated, individual portfolio of stocks, bonds, or other securities managed by a professional Portfolio Manager.
- Customised Portfolio: Each investor gets a separate demat account — investments are personalised to their risk profile and goals
- Direct Ownership: Investor directly owns the underlying securities — unlike MF where they own units
- Professional Management: Managed by SEBI-registered Portfolio Managers with defined strategies
- Higher Flexibility: Portfolio Manager can take concentrated bets — higher potential returns AND higher risk
- Regulatory Body: SEBI regulates PMS under SEBI (Portfolio Managers) Regulations 2020
- Industry Body: APMI (Association of Portfolio Managers in India) — all PMS distributors must hold APMI APRN
2. Types of PMS
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Discretionary PMS
Portfolio Manager takes all investment decisions on behalf of the investor. Investor gives a power of attorney. Most common form of PMS in India.
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Non-Discretionary PMS
Portfolio Manager recommends investments but investor approves each transaction. Investor retains decision-making authority.
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Advisory PMS
Portfolio Manager only provides advice — execution is done by the investor themselves. Least common form.
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Equity PMS
Most popular — focused on listed equity stocks. Strategies include Value, Growth, Momentum, Quality, GARP (Growth at Reasonable Price).
3. Who Can Invest in PMS?
✅
Eligible Investors
Resident Indians | NRIs (with RBI approval) | HUFs | Partnership Firms | Companies | Trusts | Family Offices with minimum Rs. 50 Lakhs available for PMS
❌
Not Suitable For
Investors with less than Rs. 50 Lakhs investable surplus | Conservative risk profile investors | Investors needing high liquidity | First-time equity investors
⚠️ SEBI Mandatory Minimum — Rs. 50 Lakhs
As per SEBI (Portfolio Managers) Regulations 2020, the minimum investment amount in any PMS is Rs. 50 Lakhs (Rupees Fifty Lakhs) per investor per Portfolio Manager. This minimum is set by SEBI to ensure only sophisticated investors with adequate financial capacity participate in PMS.
4. Key Risks in PMS — Please Read Carefully
Risk Disclosure — Mandatory per SEBI (Portfolio Managers) Regulations 2020
- Market Risk: PMS portfolios are subject to market fluctuations — portfolio value can fall significantly during bear markets
- Concentration Risk: PMS portfolios are typically concentrated (15-30 stocks) — higher impact from individual stock failures vs diversified MF
- Liquidity Risk: Some PMS strategies invest in mid/small cap or illiquid stocks — redemption may take longer than Mutual Funds
- Strategy Risk: PMS performance depends heavily on the Portfolio Manager's skill and market conditions — no guarantee of outperformance
- Benchmark Risk: PMS may significantly underperform its benchmark index in certain market conditions
- Manager Risk: Fund manager change can significantly impact portfolio performance and strategy continuity
- Cost Risk: PMS fees (management fee + performance fee) are higher than Mutual Fund TER — costs impact net returns
- Regulatory Risk: Changes in SEBI regulations, tax laws, or market structure can impact PMS strategy performance
5. PMS Fee Structure — Understanding the Costs
| Fee Type | Description & Typical Range |
| Management Fee (Fixed) | Annual fee charged on AUM regardless of performance. Typically 1% to 2.5% per annum. Charged quarterly or monthly. |
| Performance Fee | Fee charged on profits above a hurdle rate. Typically 10% to 20% of gains above hurdle. Hurdle rate typically 8% to 10% per annum. |
| Exit Load / Lock-in | Some PMS have exit loads if redeemed before 1-3 years. Ranges from 1% to 3% in early years. Some have no exit load. |
| Custodian / Demat Charges | Annual demat account maintenance and custodian charges. Typically Rs. 1,000 to Rs. 5,000 per annum. |
| Brokerage / Transaction Cost | Charged on each buy/sell transaction. Typically 0.1% to 0.5% per transaction. Varies by PMS manager. |
| GST | 18% GST applicable on management fee and performance fee. Per AMFI BPG 123/2025-26, GST is over and above the fee. |
Important: Unlike Mutual Funds where TER is included in NAV, PMS fees are charged separately and directly reduce your portfolio value. Always ask for the complete fee schedule before investing. Request the Disclosure Document which contains the full fee structure.
6. Bhavin Gunvantray Patel's Role as PMS Distributor
- Bhavin Gunvantray Patel acts as a distributor of PMS — we are NOT the Portfolio Manager
- All investment decisions in PMS are taken by the respective SEBI-registered Portfolio Manager — not by Bhavin Gunvantray Patel
- Bhavin Gunvantray Patel holds APMI APRN registration (APRN00517) as required for PMS distribution
- Bhavin Gunvantray Patel receives a referral fee / distribution fee from PMS managers — disclosed separately
- PMS recommendations are made only after thorough investor risk profiling and suitability assessment
- PMS is recommended ONLY to Aggressive risk profile investors with minimum 5-year investment horizon
- All PMS-related queries and grievances should first be addressed to Bhavin Gunvantray Patel at bhavin.patel2021@outlook.com or 9909392007
7. PMS Managers Empanelled with Bhavin Gunvantray Patel
The following SEBI-registered Portfolio Managers are currently empanelled with Bhavin Gunvantray Patel. Investors can invest in their strategies through Bhavin Gunvantray Patel.
| PMS Company | SEBI Reg. No. | Strategy | Min. Investment |
| ICICI PRUDENTIAL ASSET MANAGMENT |
PMSD2521 |
— |
Rs. 50 Lakhs |
| 360One WEALTH |
BHAVINPTL |
— |
Rs. 50 Lakhs |
Verify PMS registration at sebi.gov.in → Registered Entities → Portfolio Managers. Always request and read the PMS Disclosure Document before investing.
8. Before Investing in PMS — Your Checklist
- ✅ Read the complete Disclosure Document of the PMS manager — mandatory per SEBI regulations
- ✅ Verify SEBI registration of the Portfolio Manager at sebi.gov.in
- ✅ Understand the fee structure completely — management fee, performance fee, exit load, and GST
- ✅ Review the PMS strategy's 3-year and 5-year track record vs benchmark
- ✅ Understand the investment mandate — what the strategy invests in, concentration level
- ✅ Confirm the fund manager's track record and continuity
- ✅ Ensure Rs. 50 Lakhs minimum is from investable surplus — not your emergency fund or short-term money
- ✅ Sign the PMS Agreement and Power of Attorney only after fully understanding the terms
- ✅ Keep your other investments (MF, FD) diversified — PMS should be a part, not all, of your portfolio
🔍 Verify PMS Registrations — Official Portals
Verify every PMS manager and distributor using these official government portals before investing.
SEBI — PMS Managers
Verify SEBI registration, Disclosure Document, and compliance status of PMS managers
APMI — PMS Distributors
Verify APMI APRN registration of PMS distributors including Bhavin Gunvantray Patel
SEBI SCORES — Grievances
Lodge complaint against PMS manager or distributor if unresolved at firm level
SMART ODR — Dispute Resolution
Online dispute resolution for PMS-related investor disputes
Contact Bhavin Gunvantray Patel for PMS QueriesFor any queries regarding PMS investments, strategies, fee structures, or to schedule a detailed discussion, contact us at bhavin.patel2021@outlook.com or 9909392007. We will provide complete information and the PMS Disclosure Document free of charge before any investment commitment.
Last Updated: September 2026 | Bhavin Gunvantray Patel | 176351 | APMI: APRN00517 | www.wealthlineinvestments.in | Regulatory basis: SEBI (Portfolio Managers) Regulations 2020