PMS empanelment: how to evaluate a manager
The 7-point framework we use before recommending any PMS strategy.
PMS in India has matured into a ₹30+ lakh crore industry with 400+ registered managers. The SEBI minimum is ₹50 lakhs, but the right minimum is much higher — at least 30–50% of your equity allocation, not your entire equity.
Most investors evaluate PMS managers wrong. They look at the last 1–3 year return chart and pick the leader. This is mean-reversion bait — yesterday's chart-topper often becomes tomorrow's laggard.
This guide walks you through the seven dimensions we evaluate before recommending any PMS, including the specific questions to ask in the discovery call. It's the framework we wish we'd had on our first PMS investment.
1. Investment process — is it repeatable or vibes?
The first question: can the manager articulate their investment process in a way that's repeatable, falsifiable, and consistent with what they actually do? Or is it vague (we pick good stocks, we focus on quality)?
Repeatable process: written investment philosophy, clear screening criteria, position sizing rules, sell discipline. You should be able to look at any stock in the portfolio and explain why it's there using their stated framework.
Vibes-based process: the manager's personality is the strategy. Works for some star managers; falls apart when they leave or when their style is out of favour.
- Ask: Walk me through how you decided to buy your top holding. What's your sell discipline for it?
- Ask: How does your process behave in different market regimes? What did it tell you to do in March 2020? Oct 2022?
- Red flag: vague answers, references to instinct, refusal to share written framework.
2. AUM trajectory — growth pattern matters
AUM growth tells a story. Steady, multi-year growth typically indicates a mature, repeatable strategy. Sudden spikes followed by contraction often indicate fund chasing a hot theme or styling.
- Healthy: AUM grew from ₹100 Cr to ₹2,500 Cr over 8 years, steadily.
- Yellow flag: AUM went from ₹500 Cr to ₹5,000 Cr in 18 months. Often the strategy doesn't scale; performance degrades.
- Red flag: AUM peaked 3 years ago and has been declining. Investors are exiting; ask why.
- Ask: What's your strategy capacity? Will you close the fund at a certain AUM?
3. Drawdown behaviour across cycles
How a strategy behaved in 2008, 2018–19 (mid/smallcap correction), March 2020 (Covid crash), 2022 (rates + inflation regime) tells you far more than peak-to-peak returns.
- Did the strategy drop with the market, lose less, or lose more?
- How long did it take to recover to prior peaks?
- Did the manager change style mid-cycle (style drift is a red flag) or stay disciplined?
- Compare strategy drawdowns against Nifty 500 in the same window.
- Ask: Pull out your worst 12-month rolling return in the last 5 years. Explain what happened and what you did.
4. Key-person risk
Does the strategy depend on one Portfolio Manager? What happens if they leave? Are there documented decision-making processes that can survive a PM departure?
- Single-PM funds: returns can be extraordinary, key-person risk is enormous.
- Team-based: more institutional, harder to attribute alpha, but more durable.
- Ask: How long has the lead PM been managing this specific strategy? What's the succession plan?
- Red flag: PM has been on the strategy less than 5 years, or has had multiple strategy changes within the firm.
5. Fee transparency
PMS fees come in three flavours. Make sure you understand the full picture, including any hidden charges (custody, transaction, brokerage, audit, advisory).
- Fixed-only (2-2.5% / year) — simplest. Manager paid regardless of performance.
- Performance-only (20% above hurdle) — rare. Aligns interests but managers prefer hybrid for income stability.
- Hybrid (1-2% + 10-20% above hurdle of 6-10%) — most common. Read carefully; can be expensive in good years.
- Ask for fee illustration: if your strategy returns 15% gross over 3 years, what does my account look like net of all charges?
- Red flag: Refusal to provide written illustrative fee breakdown. Refusal to disclose related-party transaction policies (broker selection, etc.).
6. Concentration discipline
Does the PMS have written position-sizing rules? Or does the manager bet large when conviction is high?
- Healthy: max 8-10% per single position, sector concentration limits, written rebalancing rules.
- Risky: 20%+ single positions, unconstrained sector tilts.
- Both can work — concentrated PMS can deliver outsized alpha but can also drawdown brutally. Match concentration tolerance to your risk profile.
- Ask: What's your max single position size? How do you decide when to trim a winner that's growing into the portfolio?
7. Track record duration and verification
Has the manager managed THIS specific strategy across at least one full market cycle (5-7 years)? SEBI now requires aggregate performance disclosure across all clients — that's the number to compare across managers.
- Less than 5 years: manager hasn't seen one full cycle. Be cautious.
- 5-7 years: includes at least one significant drawdown. Look at how they handled it.
- 7+ years: includes a major drawdown cycle. Returns are more trustworthy.
- Verify aggregate TWRR (Time-Weighted Rate of Return) at strategy level, not cherry-picked client returns.
- Ask: Share the SEBI-format aggregate performance disclosure for the last 7 years.
Pre-investment PMS checklist
- 1Read the Disclosure Document (DD) — not just the executive summary. Fee details, related-party transactions, conflict policies are all in there.
- 2Verify SEBI registration is current. Search at sebi.gov.in/sebiweb/other/OtherAction.do?doRecognised=yes
- 3Get the last 3 years of monthly portfolio statements — look at actual holdings drift over time, not just summary returns.
- 4Talk to 2-3 existing clients (the manager will provide references, but ask through your own network too).
- 5Run the after-tax math, not gross returns. PMS returns are taxed at your slab rate based on holdings turnover.
- 6Verify custodian arrangements — your demat is held at a SEBI-registered custodian, not the PMS firm itself.
- 7Document your investment thesis in writing before transferring funds. Why this manager, this strategy, this allocation. Reference it annually to evaluate the decision.
PMS done well can add 2-4% of alpha over 7+ year periods. PMS done poorly can underperform Nifty 500 net of fees while charging premium prices.
We use this exact framework to evaluate every PMS before recommending to a client. If you'd like a second opinion on a PMS you're considering — or help shortlisting from your specific criteria — book a 30-minute call. We don't take kickbacks from any PMS, so the recommendation is what actually fits your goals.
Ready to apply this to your situation?
The Auris Wealth Planner turns this framework into a personalised plan in 60 seconds. Or book a free 30-minute call with Ashish.
Col Ashish Bhardwaj
Founder of Auris Wealth. Ex-Indian Army (20 years). NISM-certified Investment Adviser. Writes guides like this one for Indian and global investors who want clarity, not products.