Context:
The Securities and Exchange Board of India (SEBI), in its consultation paper released on July 7, 2025, has proposed allowing Asset Management Companies (AMCs) to manage non-broad-based pooled investment vehicles, such as family offices and certain offshore funds.
Family office funds
Family office funds are investment vehicles established to manage the wealth of a single family or multiple families, offering a range of services beyond traditional investment management, such as estate planning, tax advisory, and philanthropy. These funds can be structured as single-family offices (SFOs) or multi-family offices (MFOs), catering to the specific needs and goals of their respective client base.
What Are Non-Broad-Based Funds?
These are defined as investment pools:
- With fewer than 20 investors, or
- Where a single investor holds more than 25% of the corpus.
Current Regulation vs. Proposed Change
- Current: AMCs are only allowed to manage broad-based funds and require a separate Portfolio Management Services (PMS) license to manage non-broad-based funds.
- Proposed: AMCs could offer segregated mandates to manage non-broad-based funds under their existing MF license, without needing a PMS license, subject to strict compliance checks and firewalls.
Key Highlights of SEBI’s Proposal
- Expands AMC Scope: Allows AMCs to manage high-value segregated accounts like family offices and select offshore vehicles.
- Eliminates Need for PMS License: Removes dual compliance burden for AMCs.
- New Revenue Stream: Opens a lucrative segment of the market for mutual funds—particularly from ultra-HNIs and global investors.
- Firewalls and Checks:
- Caps on differential fees between MF and private mandates.
- Separate resource allocations.
- Conflict-of-interest protocols.
Implications and Strategic Considerations
- For AMCs:
- Gain access to ultra-HNI segments and offshore vehicles.
- Must build internal controls and reporting systems to manage custom mandates.
- For PMS Providers:
- Face erosion of exclusivity, especially in high-value accounts.
- Opportunity to differentiate through bespoke services, active management, and fiduciary advisory models.
- For SEBI:
- Must ensure regulatory parity, investor protection, and compliance enforcement to avoid arbitrage.
