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Portfolio Review Automation: SEBI PM Compliance + AML/CFT + DPDP Matrix

"It instantly generated a table contrasting the performance across different portfolios as well as highlighting the best quarter and the growth over time. Suit was also able to generate the debt‑equity ratio within the portfolio."

Sunil Nahar

Founder, Common Wealth Advisors

A page of SEBI’s CSCRF, Annexure-A, “Vulnerability Assessment Findings Details”, behind the title “SEBI Compliance for Portfolio Managers”, the client’s line “[jhana.ai] instantly made a table contrasting performance across portfolios, the best quarter & debt-equity ratios.”, and the tags “<15 mins”, “CA/Fin. Data”, and “.xlsx AI”.

Headnote

Fragmented portfolio documents (FD statements, PF passbooks, brokerage reports) converted into instant, source-linked analytics tables. Debt-equity ratios, quarterly performance, and best-quarter highlights extracted in minutes with full regulatory compliance trail.

How to Run Portfolio Reviews on Suit

Running a portfolio review on jhana Suit takes three steps. Each conclusion is one click away from the underlying source page.

01

Upload Documents As-Is

Upload PDFs and spreadsheets: FD statements, PF passbooks, insurance policies, brokerage reports. Suit parses tables, dates, and securities/allocations automatically.

02

Automatic Extraction & Tabulation

The system extracts portfolio values, dates, and allocations. Tabulate builds comparative tables by portfolio and quarter, computes deltas, and surfaces the best quarter automatically.

03

Source-Linked Notes & Ratios

Every figure is anchored to page and paragraph with a traceable link. Debt-equity ratios, growth over time, and top-performing quarters.

Feature: Notes

Inline date recognition and portfolio mapping with page-linked citations

Feature: Tabulate

Per-portfolio grid showing: quarter, value, delta, growth %, debt-equity ratio, best quarter highlight

Feature: Preview

Verify against the original document with synchronized highlighting; click any footnote to jump to source

Opening frame of the film: the jhana mark beside “v1.5 Launch, October 2025”, above the line “Founded at Harvard in 2022. Made in India.”Play from Vimeo 2:08

Wealth management teams face fragmented artifacts (FD statements, PF passbooks, insurance policies, brokerage reports), making on-call consolidation slow and error-prone. Regulatory exposure arises across multiple dimensions: client reporting, record-keeping, AML/KYC traceability, and cyber security.

1. SEBI (Portfolio Managers) Regulatory Duties

Portfolio managers must maintain client-wise accounts, furnish periodic reports (not exceeding six months), preserve records for minimum five years, and submit to inspections.

Reg. 17, 19, 21 • SEBI (Portfolio Managers) Regulations

"Every portfolio manager shall keep and maintain… records in support of every investment transaction… [and] preserve the books of account and other records… for a minimum period of five years."

2. Personal Data and Security

Section 43A • IT Act, 2000

"Where a body corporate… is negligent in implementing and maintaining reasonable security practices… [and] causes wrongful loss… such body corporate shall be liable to pay damages by way of compensation."

Section 8(5)-(6) • DPDP Act, 2023

"A Data Fiduciary shall… protect personal data… by taking reasonable security safeguards… [and] in the event of a personal data breach… give the Board and each affected Data Principal, intimation…"

Key Supreme Court Authorities

The following judgments establish the evidentiary framework for electronic records, critical for any AI-generated portfolio analysis that may be produced in proceedings.

Anvar P.V. v. P.K. Basheer

(2014) 10 SCC 473 • Supreme Court of India (2014)

65A/65B is the special code for electronic records. Any electronic record sought to be admitted must comply with Section 65B.

Arjun Panditrao Khotkar v. Kailash Kushanrao Gorantyal

(2020) 7 SCC 1 • Supreme Court of India (2020)

65B certificate is mandatory unless the original device/primary electronic record is produced. Clarifies exceptions for when the device is not under the party's control.

Privacy Proportionality
K.S. Puttaswamy (Aadhaar-5J.), (2019) 1 SCC 1, establishes privacy and data-protection proportionality: purpose limitation, necessity, safeguards, retention limits, and informational self-determination.

Regulatory Compliance Mapping

The source-linked workflow maps directly to regulatory obligations:

  • SEBI Reg. 21 client reporting: Completeness and clarity in composition, transactions, cash balance, and risk disclosures
  • SEBI Reg. 17/19 record-keeping: Structured, searchable preservation for ≥5 years
  • Master Circular audit-readiness: Performance benchmarking and firm-level audit consistency
  • AML/KYC trails: Evidence of origin, completeness, and monitoring
Before vs After: Compliance and Audit Posture
AreaLegacy ProcessAI-Powered (jhana)
Client ReportingManual collation; inconsistenciesAutomated quarterly tables, deltas, best quarter
Record-keepingScattered filesSource-linked entries; page/para anchors
Performance AuditAd hoc spreadsheetsConsistent firm-level metrics; audit-ready
AML/KYCFragmented evidenceTraceable document lineage and checks
Data ProtectionUndefined retentionRetention tagging; security safeguards

Key Takeaway

Immediate, on-call clarity: Growth over time, top-performing quarters, and current debt-equity ratios, delivered with source-linked citations that satisfy SEBI reporting requirements, support AML/CFT audit trails, and produce 65B-compliant electronic evidence.


References

[1]

SEBI (Portfolio Managers) Regulations. Reg. 17, 19, 21: record-keeping, client reporting

[2]

Digital Personal Data Protection Act, 2023. Security safeguards, accuracy, breach intimation (s.8)

[3]

IT Act, 2000 Section 43A. Reasonable security practices; compensation for negligence

[4]

Anvar P.V. v. P.K. Basheer (2014). Section 65B is the special code for electronic records

[5]

Arjun Panditrao Khotkar (2020). 65B certificate mandatory unless original device produced