2026-04-30
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The Pakistan Credit Rating Agency (PACRA) issued this framework to standardize the assignment of independent management quality ratings for conventional and digital investment advisors. The methodology prioritizes qualitative assessments of ownership, governance, management effectiveness, investment risk, and customer relationships, while incorporating financial risk as a quantitative benchmark. By evaluating operational capabilities, digital infrastructure, and peer-relative positioning, the framework distinguishes advisory management quality from traditional credit obligations to ensure accurate risk profiling.
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Analyst Contacts
Momin Farooque momin.farooque@pacra.com
October 2024
The Pakistan Credit Rating Agency
Investment Advisor Rating
Assessment Framework
Table of Contents
Introduction....................................................2
Profile .............................................................3
Ownership......................................................3
Governance....................................................5
Management ..................................................6
Investment Risk Management........................8
Customer Relationship ..................................9
Financial Risk ...............................................10
Summary
This methodology outlines PACRA’s approach to assigning investment advisory rating. Investment Advisor Rating is an independent opinion on the relative management quality, customer service, and potential vulnerability to operational and investment challenges, of an investment advisor. When rating investment advisors, PACRA’s approach is more skewed towards qualitative factors, including i) Ownership, ii) Governance, iii) Management, iv) Investment Process, and v) Customer Relationship, while vi) Financial Risk is employed as the quantitative factor. PACRA also compares the standing of the investment advisor with peers in its relative universe. It is pertinent to note that the Investment Advisory Rating is a management quality rating and does not reflect the investment advisor’s ability to meet its financial obligations. Analyst Contacts:
Muhammad Hamza Tahir hamza.tahir@pacra.com
+92 42 3586 9504
The Pakistan Credit Rating Agency:
Head Office
FB 1 Awami Complex
Usman Block, New Garden Town
Lahore
Phone: +92 42 3586 9504
Karachi Office
PNSC Building, 3rd Floor
M.T. Khan Road, Lalazar
Karachi
Phone: +92 21 3563 2601
Page | 2 April 2026
Investment Advisor Rating
Assessment Framework
Introduction
Scope
Investment Advisory Rating is a management quality rating to provide users with an independent opinion on the relative management quality, customer service, and potential vulnerability to operational and investment challenges, of conventional and digital investment advisors. It is important to understand that Investment Advisor Rating differs fundamentally from the traditional credit rating, which refers to an entity/issuer’s ability to meet its financial obligations. Overview Investment advisors (hereon referred to as “IAs”) are non-banking financial companies and are incorporated as public limited companies. The Non-Banking Finance Companies (Establishment and Regulation) Rules, 2003, define the scope of activities of an IA as “services provided for, managing discretionary or non-discretionary portfolios for both individual and institutional clients and include the business of advising others as to the value of securities or as to the advisability of investing in, purchasing or selling of securities, for remuneration”. Unlike asset managers, IAs do not directly manage clients’/investors’ funds. As per circular number 25 of 2024, Asset management companies can also provide investment advisor services. Digital Investment Advisors SECP, through its notification (S.R.O. 603(I)/2022), in 2022, has provided details of regulatory requirements for digital IAs. This methodology applies to digital IAs as well. For evaluation purposes, all factors that are considered for conventional IAs, will also be evaluated for digital IAs. In addition to that, PACRA will be incorporating specific regulatory requirements for digital IAs like minimum equity requirements and others. PACRA will look at the digital infrastructure, technological tools, front-end and back-end capabilities, customer interface, and other systems in place to assess the overall capabilities and expertise of digital IAs. Regulatory Landscape IAs are regulated primarily by the Securities and Exchange Commission of Pakistan (SECP). The regulatory framework for IAs is less stringent than other NBFCs, including asset managers. The key regulations governing the activities of IAs include: Non-Banking Finance Companies (Establishment and Regulation) Rules, 2003, and Non-Banking Finance Companies and Notified Entities Regulations, 2008. Together, these lay out the scope of activities permissible to an IA, a broad code of conduct to be observed by the companies and their employees, and minimum requirements of necessary disclosures, policies and procedures, systems, and other areas. Given the nature of its operations, an IA is exposed to multiple risks including i) absence of a robust control framework to ensure true and fair deliverance of responsibilities to investors, ii) inadequacy of risk management infrastructure, iii) weak investment oversight, and iv) poor customer relationship management. Quality Framework Rating PACRA’s rating framework for IAs focuses predominantly on qualitative factors. These
are essential for gaining a holistic view of all factors impacting an entity on a standalone basis and within its operating environment. Herein,
Page | 3 April 2026
Investment Advisor Rating
Assessment Framework
PACRA looks at: i) Profile, ii) Ownership, iii) Governance, iv) Management, v) Investment Risk Management, and vi) Customer Relationship. Meanwhile, to ensure the element of objectivity in its assessment, PACRA incorporates vii) Financial Risk, as a quantitative factor. PACRA achieves a clearer perspective on the relative positioning of an IA by comparing it to peers. Profile Background PACRA reviews the background of the IA to understand its evolution from where it started to where it currently stands. We analyze how and through what means the entity has achieved the desired expansion. PACRA looks at the progress of the entity from its historical past. The entity's progress helps PACRA determine the entity's ability to successfully realize its strategy. The significant factor here for PACRA is to assess whether the entity has achieved the desired expansion through organic growth or acquisitions. Meanwhile, the source of funding for desired growth is also critical. PACRA considers IA’s experience in the industry and views favorably IAs that have gained several years’ track record, navigating through market cycles, developing sound processes, and a well-nurtured expertise to offer IA services. Operations PACRA looks at the scope of an IA’s operations i.e., whether it only offers investment advisory services or if it is also engaged in investment management. If an IA is only involved in investment advisory, the scale and complexity of its operations are likely to be different compared to an IA that provides investment management services only. The scope of PACRA’s assessment changes accordingly. The scale of operations is also assessed by looking at the IA’s market share, and, if applicable, Assets Under Management (AUM), as well as growth/reduction therein, over time. This also depicts the standing of the IA amongst peers. Ownership Ownership Structure The assessment of ownership begins by looking at the legal status of the IA. PACRA conducts an in-depth study of the shareholding mix of the IA to disentangle the structure of ownership. Key factors that are considered for this purpose, inter-alia, include: i) shareholding structure which includes whether the individual(s) own the entity directly or indirectly, ii) foreign or local shareholders, iii) whether the entity is owned by a single group or through a combination of entities and individuals, and iv) whether it is part of a group or a standalone entity. All these deliberations are done to identify the person at the last mile. Rating Criteria Profile Ownership Governance Management Investment & Portfolio Management Customer Relationship Financial Risk
Page | 4 April 2026
Investment Advisor Rating
Assessment Framework
Stability
To analyze the stability of ownership, a particularly important factor to be taken into account is succession planning. An integral part of our background analytical work is an attempt to assess whether, and under the right of succession, the entity’s prospects would be supported and by whom. This is particularly relevant in the case of family-owned businesses and joint ventures, whose failures could have a contagious effect on the sustainability of the entity. Stable ownership with clarity in succession, perhaps major stakes residing with one family or group, is considered positive for ratings. On the contrary, high free float (in case of listed concerns) leads to the risk of takeover and may anchor lower ratings. Business Acumen PACRA gauges the sponsors’ business acumen. Having a strong business acumen set has been critical for sustainable success. PACRA analyzes business acumen through two primary areas: i) industry-specific working knowledge, and ii) strategic thinking capability. Meanwhile, a deep and applicable understanding of the system is critical to determine how a business achieves its goals and objectives. The scope includes the assessment and understanding of how the sponsors of the entity deliberate over and successfully make the right business decisions. In the case of digital IA, PACRA evaluates the owner’s experience in digital services to ascertain their ability to provide strategic guidance. This is especially critical in the case of newly formed digital IAs. Financial Strength PACRA analyzes the ability and willingness of the major shareholders to support the entity whether it is conventional or digital, both continuingly, and support in times of crisis. While the stipulated minimum capital requirement for IAs is lower compared to other regulated financial services providers, PACRA recognizes the IA may need additional support to sustain operations, particularly during the initial years of operations, while the IA builds its client base. While analyzing financial strength, PACRA gives due importance to: i) behavior of the major shareholders to provide timely and comprehensive support in times of need in the past, ii) prospective view of key shareholders, in case such need arises, iii) other businesses of sponsors, and iv) the level of commitment of the major shareholder with the entity in providing capital support. In case of no explicit commitment, PACRA attempts to form a view on the availability of likely support. Support, in this context, refers strictly to financial support, rather than operational support.
Table 1. Information Required on Ownership
Page | 5 April 2026
Investment Advisor Rating
Assessment Framework
Page | 6 April 2026
Investment Advisor Rating
Assessment Framework investment, risk management, segregation of duties and information barriers between various functions of the IA, and safeguarding the flow of sensitive information within the company by establishing firewalls as necessary.
Table 2. Information Required on Governance
Page | 7 April 2026
Investment Advisor Rating
Assessment Framework
Management Effectiveness
Optimum discretionary portfolio management requires adequate technological resources, whether internal, provided by the parent company or affiliate, and/or an external third party (e.g., vendors). High integration of technology into management systems is highly desirable and PACRA places high value on MIS and considers such MIS superior which are generated directly from the system. Another key measure of management effectiveness is its track record of delivering on past projections and sticking to strategies. Control Environment An analysis of the overall control environment of the IA helps in identifying the procedures, control centers, and reporting lines, to manage conflicts of interest, meet fiduciary responsibility, and verify the accuracy of financial and accounting information prepared for stakeholders. This analysis would assess the strength of the overall compliance and control environment beyond regulatory requirements. Adherence to Board policies as well as well-documented and comprehensive policies at the management level, including pricing policies, policies on handling discretionary vs. non-discretionary mandates, and establishment of SOPs related to client vetting and KYC are viewed as positive factors for the rating. Maximum transparency regarding trading and dealing practices and compliance with applicable regulations also provide valuable insight into the monitoring and control environment. Appropriate measures should be in place to ensure that all transactions/trades are conducted in the best interests of investors. With regulatory requirements being relatively less stringent for IAs, self-regulation gains prominence. Thus, the IA’s compliance function would be evaluated on an enterprise-wide basis. More value would be given to a compliance function integrated into the system of the company. In the case of digital IA, the reliability of digital infrastructure is critical. Therefore, for digital IAs, PACRA pays more attention to core software deployed, frontend and back-end applications, vendor details for software services, user interface and channels used by the customers, in-house development capabilities, system back-up, and business continuity plan, and measures taken for data security. Similarly, risk management mechanisms and controls established are examined. entities and is relatively challenging to benchmark, and hence, mitigate. This risk is important in the case of digital IAs since dependence on key individuals is usually high. PACRA attempts to identify the extent to which an entity is dependent on the expertise of such individual(s) and to ensure policies exist for succession/redundancy to limit the adverse impact of such a person unexpectedly leaving, on the entity. MIS: System generated – real-time based – MIS reports add more efficiency in decision making whether related to operational, financial, or strategic issues. PACRA evaluates the quality and frequency of the MIS reports used by the management team to
ascertain that decision-making within the entity is information-based. Operational Risk: Operational risk is the risk of loss resulting from inadequate or failed internal processes, people, and systems or from external events. An analysis of the company’s Disaster Recovery (DR) procedures, infrastructure security, and monitoring of third-party activities helps to determine the viability of the operational
Page | 8 April 2026
Investment Advisor Rating
Assessment Framework
Table 3. Information Required on Management
Page | 9 April 2026
Investment Advisor Rating
Assessment Framework
Risk Management Function
PACRA looks at the risk monitoring and control framework of an IA. Apart from the extent of independence of the risk function, PACRA looks at the policies, procedures, strategy, and accountability at each level. Coverage and appropriateness of risk indicators are analyzed, including pre-defined explicit and meaningful limits on exposure to certain sectors, clients, or products. Meanwhile, reconciliation between expected and actual risk levels analysis of discrepancies and corrections is considered equally important. PACRA looks for the use of appropriate analytical tools and techniques to aid scenario analysis, stress-testing, and fair valuation of securities where market values are unknown. Reporting systems and investment in technology, which support frequent reporting of risk-related information to management is important. PACRA looks at the reports generated in this regard and reviews their content, quality, and comprehensiveness. Investment Risk Management The nature and scope of risk management in IAs can vary, depending on the range of services offered by the IA. This could be just investment advisory to the management of discretionary and non-discretionary client portfolios. Where an IA is managing discretionary and/or non-discretionary client portfolios, investment risk management permeates the entire investment process and consists of two pillars: macroeconomic risks and portfolio risks. PACRA assesses the steps being taken and the systems in place (including MIS) to monitor/mitigate these under three main categories:
i) credit risk, ii) liquidity risk, and iii) market risk.
Table 4. Information Required on Investment Risk Management
Page | 10 April 2026
Investment Advisor Rating
Assessment Framework
A formal mechanism to solicit feedback from clients and handle complaints must also be in place. Nature and number of complaints received is an important indicator to measure the quality of services provided and resultant client satisfaction. PACRA also looks at the IA’s client attrition over time on a standalone basis and comparison of the same to industry peers, as a yardstick to judge the quality and effectiveness of investor services. Extent of Automation/Integration For an IA whether conventional or digital, to be able to service clients efficiently, the systems’ backbone needs to be robust. The systems deployed need to be capable of capturing, processing, and reporting all transactions of all clients with a zero or near-zero error rate. PACRA's evaluation of the infrastructure framework consists of an assessment of the infrastructure deployed, the extent of automation and integration, the type and number of errors encountered, access policies to the computer systems and data, and the quality of reports generated by the MIS. Further, adequate systems infrastructure including connectivity, communication networks, back-up procedures, and disaster recovery to ensure uninterrupted operations are viewed positively by PACRA. Investor Reporting Much of the information provided to investors is communicated through regular reporting, which PACRA examines in light of its comprehensiveness, clarity, consistency, accuracy, and timing. This capacity to adapt reports to meet varied investors’ requirements is also examined. Beyond mere reporting, PACRA believes that all IAs should offer performance presentations and performance attribution reports to their clients on a widespread and timely basis. The agency, therefore, looks at the accuracy of performance attribution and consistency with the investment process. PACRA also reviews the resources and procedures used in the production of reports, particularly for front-office independence and data accuracy. For digital IAs, PACRA evaluates the frequency and mode of information provided to clients, its accuracy, and its effectiveness.
Table 5. Information Required on Customer Relationship
Page | 11 April 2026
Investment Advisor Rating
Assessment Framework
Financial Performance
PACRA looks at the financial position of the IA to assess financial performance and sustainability. Several aspects of the company’s income statement are considered, including growth/stability of the core revenue stream (i.e., management fees), other sources of income, expense trends, and overall profitability level. Leveraging levels are assessed relative to industry norms. The minimum equity requirement of PKR 30mln by the regulator (as per SECP Non-Banking Finance Companies and Notified Entities Regulations, 2008) is ensured and return on equity is analyzed in conjunction with peer to make a view as to the shareholders’ satisfaction with the investment. Performance Against Benchmark PACRA evaluates the tools and mechanisms set in place by the IA to gauge its performance. The benchmark(s) specified by the IA to measure its performance are reviewed and the proximity of actual performance to targets is assessed. Herein, the existence of tracking mechanisms that measure performance in various areas relative to predefined objective and measurable benchmarks is viewed favorably. For IAs involved in investment management, the performance of discretionary and non-discretionary portfolios is evaluated separately. In the case of discretionary portfolios, investor objectives, constraints, and preferences determine the range of portfolio management strategies and the degree of adherence to these overshadows actual performance. Meanwhile, for non-discretionary portfolios, returns are measured against an appropriate benchmark portfolio. Achieving competitive investment results contributes positively to the standing of the IA.
Table 6. Information Required on Performance
Investment Advisor Rating
Scale
Investment Advisor Rating
An independent opinion on the quality of management, customer service, and investment process. Scale Long-Term Rating AM1 (ia) Very high quality of management, customer service, and investment process AM2++ (ia) AM2+ (ia) AM2 (ia) High quality of management, customer service, and investment process AM3++ (ia) AM3+ (ia) AM3 (ia) Good Quality of management, customer service, and investment process AM4++ (ia) AM4+ (ia) AM4 (ia) Adequate quality of management, customer service, and investment process AM5 (ia) Weak quality of management, customer service, and investment process Rating Modifiers | Rating Actions Outlook (Stable, Positive, Negative, Developing) Indicates the potential and direction of a rating over the intermediate term in response to trends in economic and/or fundamental business / financial conditions. It is not necessarily a precursor to a rating change. ‘Stable’ outlook means a rating is not likely to change. ‘Positive’ means it may be raised. ‘Negative’ means it may be lowered. Where the trends have conflicting elements, the outlook may be described as ‘Developing’. Rating Watch Alerts to the possibility of a rating change subsequent to, or, in anticipation of some material identifiable event with indeterminable rating implications. But it does not mean that a rating change is inevitable. A watch should be resolved within foreseeable future, but may continue if underlying circumstances are not settled. Rating watch may accompany rating outlook of the respective opinion. Suspension It is not possible to update an opinion due to lack of requisite information. Opinion should be resumed in foreseeable future. However, if this does not happen within six (6) months, the rating should be considered withdrawn. Withdrawn A rating is withdrawn on a) termination of rating mandate, b) the debt instrument is redeemed, c) the rating remains suspended for six months, d) the entity/issuer defaults., or/and e) PACRA finds it impractical to surveil the opinion due to lack of requisite information. Harmonization A change in rating due to revision in applicable methodology or underlying scale. Surveillance. Surveillance on a publicly disseminated rating opinion is carried out on an ongoing basis till it is formally suspended or withdrawn. A comprehensive surveillance of rating opinion is carried out at least once every six months. However, a rating opinion may be reviewed in the intervening period if it is necessitated by any material happening. Rating actions may include "maintain", "upgrade", or "downgrade". Disclaimer: PACRA has used due care in preparation of this document. Our information has been obtained from sources we consider to be reliable but its accuracy or completeness is not guaranteed. PACRA shall owe no liability whatsoever to any loss or damage caused by or resulting from any error in such information. Contents of PACRA documents may be used, with due care and in the right context, with credit to PACRA. Our reports and ratings
constitute opinions, not recommendations to buy or to sell
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Source: The Pakistan Credit Rating Agency — original document · Summary generated with machine assistance and reviewed before publication; the authoritative text is the regulator's original document. How RegAlert works
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