Investment in Derivatives in PMS
This sub‑topic explains how Portfolio Management Services (PMS) can invest in derivatives, the regulatory framework governing such investments, and the calculations required to stay within SEBI limits. Understanding these concepts is crucial for answering exam questions on permissible instruments, exposure limits, and valuation methods. The content links the theory of derivatives with practical PMS operations, helping learners apply knowledge in real‑world scenarios.
Learning Objectives
- 1Define derivatives and identify the types permitted for PMS.
- 2Explain why PMS use derivatives and the benefits they provide.
- 3Describe SEBI regulations, including exposure limits and reporting requirements.
- 4Perform basic calculations for gross/net derivative exposure and mark‑to‑market profit/loss.
What are Derivatives?
A derivative is a financial contract whose value is derived from an underlying asset such as equities, indices, commodities, currencies or interest rates. The contract obligates the parties to buy, sell or exchange the underlying at a future date, at a price agreed today.
Common derivative instruments include futures, options and swaps. Futures are standardized contracts traded on exchanges, options give the right but not the obligation to transact, and swaps are over‑the‑counter (OTC) agreements to exchange cash flows.
In the context of PMS, derivatives are used as tools for hedging, leveraging, or enhancing returns, but they must be employed within the regulatory limits set by SEBI. The exam often tests the definition, types, and the basic mechanics of these contracts.
Why PMS Use Derivatives
Derivatives enable PMS to manage portfolio risk efficiently. By taking opposite positions in derivatives, a PMS can hedge against adverse price movements of the underlying securities, protecting client capital during market volatility.
Leverage is another advantage. A modest margin requirement allows the PMS to gain exposure larger than the cash invested, potentially boosting returns when the market moves in the anticipated direction. However, leverage also magnifies losses, which is why exposure limits are strictly monitored.
Derivatives also facilitate tactical asset allocation. For example, a PMS can use index futures to quickly adjust market exposure without buying or selling the constituent stocks, saving transaction costs and time. Exam questions frequently ask for the purpose of using derivatives, so remember the three pillars: hedging, leverage, and tactical allocation.
Many candidates mistakenly think SEBI bans all derivatives for PMS. In reality, derivatives are allowed but only specific instruments and exposure limits apply. Always choose the option that mentions permissible derivatives with SEBI‑defined limits.
Regulatory Framework for Derivatives in PMS
The SEBI (Portfolio Management Services) Regulations, 2020 govern the use of derivatives by PMS. Only listed derivatives that are approved by SEBI can be used – primarily exchange‑traded futures and options on equities, equity indices, currency pairs, and interest‑rate futures. OTC swaps are permissible only if they are cleared through a recognized clearing house and the PMS has obtained explicit client consent.
Before initiating any derivative position, the PMS must obtain a written consent from the client, disclose the risk profile, and ensure that the client’s suitability assessment aligns with the intended strategy. Failure to obtain consent can lead to regulatory action and disqualification.
For the exam, remember that the regulator’s focus is on (i) permissible instruments, (ii) client consent, and (iii) strict exposure monitoring. Questions may present a scenario and ask whether a particular derivative transaction is compliant.
Permitted Derivative Instruments under SEBI PMS Regulations
| Instrument | Underlying Asset | Exchange / Clearing Requirement |
|---|---|---|
| Futures | Equities, Equity Indices, Currency Pairs, Interest‑Rate Futures | Listed on recognized exchange; cleared by exchange clearing house |
| Options | Equities, Equity Indices, Currency Pairs | Listed on recognized exchange; cleared by exchange clearing house |
| Swaps | Interest‑Rate, Currency | OTC but must be cleared through a SEBI‑approved clearing corporation and require client consent |
Exposure Limits
SEBI imposes two key limits on derivative exposure for a PMS portfolio: gross exposure and net exposure. Gross exposure is the sum of the absolute market values of all long and short derivative positions. It may not exceed 200% of the portfolio’s Net Asset Value (NAV).
Net exposure is the difference between the market value of long positions and short positions. This limit cannot be more than 100% of the NAV. These caps ensure that the portfolio does not become overly leveraged and that risk remains within a manageable range.
Exam questions often present a portfolio’s derivative holdings and ask you to calculate whether the gross or net exposure breaches the SEBI limit. Knowing the formulas and the step‑by‑step method is essential.
Where:
MV_i= Market value of the i^{th} derivative position (in rupees)NAV= Net Asset Value of the PMS portfolio (in rupees)n= Total number of derivative positionsWorked Example
Given three positions: MV_1 = 2,00,000 (long), MV_2 = -1,20,000 (short), MV_3 = 80,000 (long) and NAV = 5,00,000: Step 1: Sum of absolute values = |2,00,000| + |‑1,20,000| + |80,000| = 4,00,000 Step 2: Gross Exposure = (4,00,000 / 5,00,000) × 100 = 80% Verification: (4,00,000 ÷ 5,00,000) × 100 = 80%.
Where:
MV_{i}^{\text{long}}= Market value of long derivative positions (in rupees)MV_{j}^{\text{short}}= Market value of short derivative positions (in rupees, taken as positive numbers)NAV= Net Asset Value of the PMS portfolio (in rupees)Worked Example
Using the same positions as above: Long total = 2,00,000 + 80,000 = 2,80,000; Short total = 1,20,000. Step 1: Net Exposure = (2,80,000 – 1,20,000) / 5,00,000 × 100 Step 2: Net Exposure = 1,60,000 / 5,00,000 × 100 = 32% Verification: (1,60,000 ÷ 5,00,000) × 100 = 32%.
Students often subtract short positions when calculating gross exposure. Remember: gross uses absolute values; net subtracts short from long. Confusing the two leads to wrong compliance answers.
Valuation and Mark‑to‑Market (MTM)
Derivatives are marked‑to‑market daily. The profit or loss (P/L) arising from price changes is added to or deducted from the portfolio’s NAV. This MTM adjustment reflects the real‑time economic value of the derivative position.
For futures contracts, the MTM P/L is calculated as the difference between the closing price and the opening (or previous settlement) price, multiplied by the contract size and the number of contracts held. The same principle applies to options, but the intrinsic value and time value components are also considered.
Exam questions may provide opening and closing prices and ask you to compute the MTM impact on NAV. Knowing the formula and the sign convention (positive for profit, negative for loss) is essential.
Where:
C_{close}= Closing price of the futures contract (in rupees)C_{open}= Opening/previous settlement price (in rupees)S= Contract size (units per contract)N= Number of contracts heldWorked Example
A client holds 5 Nifty futures contracts. Each contract size = 75 units. Opening price = 18,200, closing price = 18,500. Step 1: Price difference = 18,500 – 18,200 = 300 Step 2: MTM = 300 × 75 × 5 = 112,500 rupees profit Verification: (18,500‑18,200) × 75 × 5 = 112,500.
Scenario
A PMS holds 10 contracts of Reliance Industries Ltd. futures. Each contract represents 500 shares. The contract was bought at Rs. 2,200 per share. At the end of the trading day, the futures price is Rs. 2,250 per share.
Solution
Step 1: Determine price change per share = 2,250 – 2,200 = 50 rupees. Step 2: Compute MTM per contract = 50 × 500 = 25,000 rupees. Step 3: Total MTM for 10 contracts = 25,000 × 10 = 2,50,000 rupees profit. This amount is added to the portfolio’s NAV for the day. If the price had fallen, the same calculation would produce a negative figure, reducing NAV.
Conclusion
The example illustrates how daily MTM directly influences the NAV of a PMS portfolio, a point frequently tested in scenario‑based questions.
Risk Management Practices
Effective risk management is mandatory for PMS dealing in derivatives. Key practices include setting stop‑loss limits for each contract, monitoring the portfolio’s Value‑at‑Risk (VaR), and conducting periodic stress‑testing to assess the impact of extreme market moves.
SEBI requires PMS to maintain a risk management framework that records the rationale for each derivative trade, the expected payoff profile, and the contingency measures if the market moves against the position. Regular reporting to the regulator and to clients ensures transparency.
Exam items may ask which of the following is NOT a required risk‑management tool for derivative exposure. Remember that while stop‑loss and VaR are mandatory, tools like “margin call alerts” are operational rather than regulatory requirements.
Typical Derivative Exposure Profile in a PMS Portfolio (Illustrative)
Client Suitability and Disclosure
Before allocating client funds to derivatives, a PMS must perform a suitability assessment based on the client’s risk tolerance, investment horizon, and financial goals. The assessment is documented in the client’s KYC file and must be reviewed annually.
Full disclosure of the derivative strategy, potential losses, margin requirements, and the impact on the portfolio’s liquidity must be provided in the PMS agreement. SEBI mandates that the client sign a separate risk‑disclosure annex for derivative exposure.
In the exam, you may encounter a statement asking which document is essential for derivative investment consent. The correct answer is the signed risk‑disclosure annex specific to derivatives.
Scenario
Mr. Sharma, a 45‑year‑old salaried professional, wishes to protect his equity portfolio against a potential market correction. He has a moderate risk tolerance and a 5‑year investment horizon. The PMS proposes using index futures for hedging.
Solution
Step 1: Verify suitability – moderate risk and long horizon satisfy the hedging strategy. Step 2: Obtain written consent and have Mr. Sharma sign the derivative risk‑disclosure annex. Step 3: Calculate the required futures contracts to achieve a 50% hedge of the equity exposure, ensuring that gross exposure stays below the 200% NAV limit. Step 4: Document the rationale, expected hedge ratio, and stop‑loss limits in the risk‑management framework.
Conclusion
The scenario demonstrates the alignment of client suitability, regulatory consent, and exposure calculations – all of which are examined in NISM questions.
⭐Exam Takeaways
- Derivatives are allowed in PMS but only listed futures, options and cleared swaps as per SEBI regulations.
- Gross derivative exposure = (sum of absolute market values ÷ NAV) × 100 and must not exceed 200% of NAV.
- Net derivative exposure = (long market value – short market value ÷ NAV) × 100 and must stay within 100% of NAV.
- Mark‑to‑market profit/loss for futures = (Closing price – Opening price) × Contract size × Number of contracts.
- Client consent via a signed risk‑disclosure annex is mandatory before taking any derivative position.
Practice Questions
8 questions on Investment in Derivatives in PMS
What is a derivative as defined in the PMS study material?
Which derivative instruments are expressly permitted for PMS under SEBI regulations?
A PMS portfolio has three derivative positions with market values: Rs 2,00,000 (long), Rs ‑1,20,000 (short) and Rs 80,000 (long). The NAV is Rs 5,00,000. What is the gross derivative exposure percentage?
Using the same positions as above (long total Rs 2,80,000 and short total Rs 1,20,000) with NAV Rs 5,00,000, what is the net derivative exposure percentage?
A PMS has NAV Rs 6,00,000 and holds three derivative positions: Long futures Rs 3,00,000, Long swaps Rs 2,00,000 and Short options Rs ‑2,00,000. What is the net exposure percentage and does it breach SEBI’s net‑exposure limit?
Which of the following is NOT a regulatory risk‑management tool required by SEBI for derivative exposure in a PMS?
Before allocating client funds to derivatives, which document must a PMS obtain from the client?
What is the maximum gross derivative exposure allowed as a percentage of a PMS portfolio’s NAV under SEBI regulations?
