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Should you use balanced advantage funds for generating retirement income?

What are retirement portfolios made of? At a minimum, a retirement portfolio should contain a debt component for stability and to draw periodic income from, an equity component to allow the portfolio to grow and keep up with inflation, and importantly a rebalancing plan to optimise growth and stability. (we are not talking about physical assets here).

If this is the need, what if we use a balanced advantage fund, which invests in both debt and equity, and the fund manager takes care of asset allocation as well? Does that reduce your job to just coming up with a withdrawal plan? And are there any hidden risks in going with this seemingly ready-made solution?
In this article,let’s look into how a full-fledged retirement income generation plan from a balanced advantage fund stands against one from a managed equity and debt portfolio.

Portfolio 1: Balanced advantage fund

Balanced advantage funds, as an official mutual fund category, came into existence after SEBI’s classification of mutual funds in 2018. A typical balanced advantage fund has an effective equity exposure anywhere between 30% to 80% based on the fund manager’s perception of whether equity is overvalued or undervalued. It is important to note that each fund house will have different metrics to assess this.

Now, this category is officially in place only for the past 6 years. But we need longer data to assess the feasibility of balanced advantage funds as a retirement product. Therefore, we picked a fund that chose to be a balanced advantage fund even before SEBI’s category came into being, making it a pioneer in this category. We are talking of ICICI Pru Balanced Advantage (which was first launched as ICICI Pru Equity and Derivatives Fund) For the period we have chosen, from January 5, 2007, to July 5, 2024, the fund has given a CAGR of 11.49%.

Portfolio 2: Separate equity and debt funds

For this portfolio, we have selected funds with similarly long track records from the same fund house. The equity fund chosen is the ICICI Prudential Value Discovery Fund, and the debt fund is the ICICI Prudential Short Term Fund. We have used different asset allocations, which will be explained in the Analysis section below.

For the period from January 5, 2007, to July 5, 2024, the ICICI Prudential Value Discovery Fund delivered a CAGR of 17.04%. The ICICI Prudential Short Term Fund has achieved a CAGR of 8.19% for the same period.

Rebalancing plan

In an asset-allocated portfolio, rebalancing is done to take profit from inflated assets or to add to an asset that is available cheaply. This can be done on a rule-based approach, such as once a year, if the asset allocation has moved in either direction by a certain threshold, bringing it back to the original allocation. For example, in a 60-40 Equity-Debt portfolio, if equity goes up to 65% or above, you would sell part of the equity and buy debt to bring the total allocation back to 60-40. Similarly, if equity drops to 55% or below, you would sell part of the debt and buy equity.


However, since our two-fund retirement portfolio is quite minimalistic, we cannot allow selling debt to buy equity, as the debt fund is what we are counting on to meet future monthly withdrawals. (In an advanced retirement portfolio, there can be separate components to take care of periodic withdrawals and debt as part of the long-term portfolio to carry out rebalancing.) Hence, in our two-fund portfolio, rebalancing is done only if equity gets inflated. Redemption of equity is done when the equity asset allocation goes up by more than 5% from the original allocation, and this will be invested into debt.

Analysis

For our analysis, we started with an initial capital of Rs. 1 crore and tested initial annual withdrawal rates of 4%, 5%, and 6%. In each case, we applied an annual increment of 6% to the withdrawal amount to adjust for inflation, as typically done in retirement portfolios.
For example, with an initial annual withdrawal of 4% per year, the monthly withdrawal would be Rs. 33,333 (4% of Rs. 1 crore / 12).


In the second year, the monthly withdrawal would be Rs. 35,333 (106% of Rs. 33,333).
In the third year, it would be Rs. 37,453 (106% of Rs. 35,333). And so on.
The monthly withdrawal at the end of the period would be Rs. 89,759.
Please note that taxes have not been accounted for in this analysis.

Portfolio transactions

For Portfolio 1, the initial capital of Rs. 1 crore was invested in the ICICI Prudential Balanced Advantage Fund on January 5, 2007. Withdrawals began from the same fund starting from January 5, 2007, lasting till July 5, 2024.


For Portfolio 2, we considered two different asset allocations: a 50:50 equity:debt and a 30:70 equity:debt ratio. The initial capital of Rs. 1 crore was allocated to the ICICI Prudential Value Discovery Fund and ICICI Prudential Short Term Fund according to the chosen asset allocation. Monthly withdrawals were initiated from the ICICI Prudential Short Term Fund starting from January 5, 2007, to July 5, 2024.


Every January 5th, the portfolio’s asset allocation was reviewed. If the equity portion had increased by 5 percentage points or more from the initial allocation, it was rebalanced by redeeming from equity and reinvesting into debt to maintain the original allocation.

Here is how the results stands:

Metrics for evaluation

  • Balance Capital: The remaining amount in the portfolio after all withdrawals have been made.
  • Balance Capital Growth Rate: The annual growth rate of balance capital, after all the withdrawals in this period.If this rate keeps up with inflation (assumed at 6% in this analysis), the portfolio is likely to sustain future income generation. For example, in the case of Portfolio 1 (Balanced advantage fund) at an initial annual withdrawal rate of 6%, we started with Rs.1 crore and ended with Rs.1.57 crore. For a period of 17.5 years, that is a growth of 2.63% per annum.
  • Final Withdrawal: The annual withdrawal rate in the last month under observation based on the balance capital. For example, in the case of Portfolio 1 (Balanced advantage fund) at an initial annual withdrawal rate of 6%, the final redemption is Rs.1.35 lakh, the remaining capital is Rs.1.57 crore. This is 0.855% per month or 10.26% per year.
  • Withdrawal Risk: The percentage of observations throughout the income generation period (17.5 years in this analysis) where the annual withdrawal rate exceeded the initial withdrawal rate. For example, in the case of Portfolio 1 (Balanced advantage fund) at an initial annual withdrawal rate of 6%, out of the 211 months when a withdrawal was done, only 11 times the withdrawal was below 6% (annual rate) of the remaining capital. At 200 months, the withdrawal amount was above 6% (annual rate) of the remaining capital, resulting in a withdrawal risk of 94.8% (200/211).

Among the metrics, one needs to make the distinction between final withdrawal rate and withdrawal risk. Withdrawal risk points to the stress the portfolio underwent in generating retirement income during the period under observation. The lower the value, the less the risk. Final withdrawal rate points to future risk. A higher final withdrawal rate compared to the initial withdrawal rate indicates capital erosion in the portfolio, risking future income generation.

Findings

Case: 4% withdrawal

All three portfolios comfortably sustained the 4% initial withdrawal rate, as evidenced by the growth in remaining capital above the 6% annual increment in withdrawals. The final withdrawal rates were lower than the initial rate set for all portfolios. However, when examining withdrawal risk, the Balanced Advantage fund portfolio exhibited a higher risk (41.7%) compared to the asset-allocated portfolios.

Case: 5% withdrawal

In this case, the Balanced Advantage fund portfolio appears stretched in its ability to provide retirement income. The remaining capital grew below the rate of increase in withdrawals, and the final withdrawal rate exceeds the initial 5% withdrawal rate. The withdrawal risk is very high at 94.3%, indicating high stress in the portfolio to generate income in the period.

In the asset-allocated portfolios, the 30:70 Equity:Debt portfolio managed to maintain its sustainability for retirement income withdrawals. Its capital grew at nearly 6%, and the final withdrawal rate was slightly below the initial rate. However, with a withdrawal risk of 56.87%, there was notable stress in meeting income needs during the period.

Meanwhile, the 50:50 Equity:Debt portfolio has comfortably managed to withstand the withdrawals.

Case: 6% withdrawal

In this case, both the Balanced Advantage fund portfolio and the 30:70 Equity:Debt portfolio faced stress due to higher withdrawals. However, the Balanced Advantage Fund portfolio experienced more stress than the 30:70 Equity:Debt portfolio, as evidenced by a final withdrawal rate 2.5% higher than the latter. Additionally, the withdrawal risk of the Balanced Advantage fund portfolio was over 10 percentage points higher than that of the 30:70 Equity:Debt portfolio.

Meanwhile, the 50:50 Equity:Debt portfolio managed to withstand the higher withdrawals in this scenario as well, although its performance was not as strong as in the 5% withdrawal case.

It is interesting to note that the asset allocated portfolios fared better than the Balanced Advantage fund portfolio, even the one with just 30% Equity allocation. If we look at the weighted average return of a 30:70 ICICI Prudential Value Discovery Fund:ICICI Prudential Short term fund for the period of analysis, we get 10.85%, which is less than the 11.49% the ICICI Prudential Balanced Advantage Fund has generated. To see what worked in favour of the asset allocated portfolios, we looked further at the portfolio rebalancing for various withdrawal cases. The below are the years in which the portfolio was rebalanced, or redemption from Equity was carried out to add to Debt.

In general, in the two equity and debt portfolios we have given, withdrawals are from debt. But since they undergo rebalancing, given below are years when Equity was redeemed as part of rebalancing in the asset allocated portfolio.

There are some interesting observations here. 

  • Even an asset allocated equity debt plan can cause stress to the portfolio by way of high withdrawals. Take the case of 6% withdrawal for the 30:70 equity:debt portfolio -  it saw a final withdrawal of 7.7% and in 83% of the instances the withdrawal was higher than the initial rate of 6%. Not a good thing. But here is the big positive. A rule based asset allocation strategy prevented redemption of equity at crucial points like beginning of 2009, during the global financial crisis, beginning of 2012, Eurozone crisis, beginning of 2017, post demonetisation, when equity markets were under stress. All these points were followed by a market rally, although to be known only in hindsight.The fact that withdrawals were from debt prevented unnecessary tampering of equity, allowing it to once again settle and grow. In any managed portfolio, periods when equity is available cheap is when we should avoid redeeming from equity and if possible, add to equity. 
  • In a balanced advantage portfolio too, it is likely that a fund manager will increase equity at this point and rightfully so (though we don’t have portfolio data for the older periods). However, if an investor has mandated a withdrawal from this fund, more equity will inadvertently be redeemed at this point, not allowing the same to be added/deployed (in equity). This has likely caused the balanced advantage fund portfolio to underperform 30:70 Equity:Debt asset allocated portfolio, despite having higher equity allocation, generating high internal returns, and having a fund manager oversight to assign equity and debt. 

Simply put, not withdrawing from equity, when the market is low has allowed the equity:debt portfolios to outperform the balanced advantage fund. That leaves these portfolios with higher corpus for future income generation. 

If you wish to do more analysis on this, by tweaking asset allocation, withdrawal rates etc; please use the spreadsheet below:

Conclusion

Here are the takeaways from this analysis:

  • In a robust retirement plan, it is essential to implement checks and balances to avoid redeeming equity during unfavourable market conditions. Opting for a balanced advantage fund portfolio forfeits this flexibility available to portfolios with separate equity and debt components.
  •  Our analysis reveals that a rule-based withdrawal and reallocation strategy can potentially extend the lifespan of your retirement portfolio with lower risk compared to a simplistic portfolio solely reliant on balanced advantage funds.

When it comes to critical goals like retirement planning, it's crucial to develop a comprehensive plan that considers personal circumstances and market uncertainties. Consider seeking assistance from financial planners, where necessary, to ensure your plan is well-suited to meet your long-term financial objectives.

We have also separately written about the shortcomings of using balanced advantage funds for SWP (Systematic Withdrawal Plans) in an earlier article, Should you use balanced advantage funds for SWPs? - PrimeInvestor.

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Bipin Ramachandran

Research analyst, PrimeInvestor
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38 thoughts on “Should you use balanced advantage funds for generating retirement income?”

  1. chitskuhu12

    Dear Bipin,

    Thank you for this insightful article. I have a general query. In all these scenarios , the balance corpus at the end of the period increased to a significant value.
    In an actual retirement scenario, my objective is to live comfortably plus ensure that i do not run out of money in the following 20 years or so. So , i am looking at a strategy where i can withdraw more ( and live better) rather than look at how much i have ended up saving at the end of the period. Your thoughts will be helpful if i am naive here. Also, does your excel have parameters to tweak and check scenarios ? TIA.

    1. Bipin Ramachandran

      Hello,

      This analysis is about withdrawing more as time passess. We’ve used 6% as the ‘yearly increment’ in withdrawals. The balance corpus is after doing withdrawals with increments. About this being increased – this is used to analyse how the portfolio stands after 17.5 years (the period of analysis) to take care of future withdrawals. While increasing the balance corpus itself is not the primary objective of a retirement portfolio, prolonging income generation with higher withdrawals is. This depends on the corpus growing even after withdrawals, especially in the initial period of retirement income generation. If someone is looking for a shorter period of income generation, they can make higher withdrawals and/or increase the withdrawal amount by a higher percentage.

      Some of the parameters in the Excel file can be tweaked. These are highlighted in green.

      Thanks

  2. dwarak73

    Excellent analysis, this gives a clear planning strategy for retirement planning…I will think on these lines and have a similar portfolio for retirement

    1. Bipin Ramachandran

      Thank you!
      Please keep in mind that this is a minimalistic analysis meant to explain some of the core concepts of retirement income generation. Please consider personal circumstances, taxation etc when you design your retirement portfolio. Seek help from financial planners, where necessary.

  3. nrkamath5-2

    Hi Bibin,
    It was a great blog and a superb analysis. Was wondering since BAF returns are better than pure debt, would if be worthwhile to invest say 1/3 or 1/2 the amount intended for debt portion in a balanced advantage fund , do the SWP from debt part only. During rebalancing during favourable conditions, move from BAF to debt and from pure equity to BAF.

    1. Bipin Ramachandran

      Hello,

      This strategy should work logically. However, you may want to compare it against an equity-to-debt move only to see whether there are benefits and if it is worth the additional management involved.

      Thanks

  4. Pandurangan Narasimhan

    Thanks for the article. Detailed.
    My option on balanced advantaged fund during retirement OR as 2nd trough of emergency funds (1st being liquid/short-term debt funds) would be: Secure your 3 year day-to-day run expense corpus in these funds and do SWP from there. If index does get low, use a %ge of these funds (% depends on your risk palette) into selected equity funds. With debt funds being taxed at higher tax levels, this could be a viable way forward?

    Ofcourse this can hold good for most hybrid funds, but balanced hybrid being less volatile with equity taxation. Chose the right balanced fund though, which is not aggressive (One such e.g., DSP Dynamic Fund).

  5. contact-2

    Nicely explained Sir, Why can’t we plan for Aggressive Equity Hybrid funds for this SWP, instead of going for separate 50:50 or 30:70. What are the pros and cons in setting up SWP with Aggressive Equity Hybrid Funds as this also will not require any rebalancing as this is being done by the Fund Manager.

    1. Bipin Ramachandran

      Hello,

      The key takeaway from the exercise is that unless equity and debt are separated, you’ll be forced to withdraw from equity, even when it is unfavorable to do so. This increases the risk of income generation. This principle also applies to aggressive hybrid funds.

      Thanks

      1. sweetykumari090204

        does this mean that the withdrawn units would be in same ratio (50:50 or 30:70) as the allocation in the fund (BAF) ? how can you be sure of that ?

        1. Bipin Ramachandran

          No, it doesn’t mean that. Let’s look at an oversimplified example:

          Portfolio 1: a hybrid fund with 50:50 equity: debt allocation
          Portfolio 2: Separate equity and debt funds with 50:50 allocation

          Equity markets goes down 20% from Jan 1 to Jul 1, recovers part of the losses and close the year with 5% losses from Jan 1
          Debt markets goes up 3% from Jan 1 to Jul 1, ends the year with 6% gain from Jan 1

          Let’s say an equity fund mirroring the equity markets has NAVs as below:

          Jan 1: Rs.10
          Jul 1: Rs.8
          Dec 31: Rs.9.5

          Similarly, the Debt fund’s NAVs will be:

          Jan 1: Rs.10
          Jul 1: Rs.10.3
          Dec 31: Rs.10.6

          The hybrid fund’s NAV, assuming it gives average of the equity and debt for both the periods Jan 1 – Jul 1 and Jan 1 – Dec 31:

          Jan 1: Rs.10
          Jul 1: Rs.9.15
          Dec 31: Rs.10.05

          We invest Rs.1 lakh in both the portfolios; plan is to redeem Rs.10,000 once a year at Jul 1st. The portfolio 2 will be rebalanced on Dec 31.

          Portfolio 1:

          Jan 1 purchase:
          Amount: Rs.1 lakh
          Hybrid fund NAV: Rs.10
          Hybrid fund units purchased: 10,000

          Jul 1 redemption:
          Amount: Rs.10,000
          Hybrid fund NAV: Rs.9.15
          Portfolio value before redemption: Rs.91,500
          Hybrid fund units redeemed: 1,092.896
          Hybrid fund units balance: 8,907.104
          Portfolio1 value after redemption: Rs.81,500

          Dec 31
          Hybrid fund NAV: Rs.10.05
          Portfolio 1 balance: Rs.89,516

          Portfolio 2:

          Jan 1 purchase:
          Equity: purchase amount: Rs.50,000
          Equity fund NAV: Rs.10
          Equity fund units purchased: 5,000

          Debt: purchase amount: Rs.50,000
          Debt fund NAV: Rs.10
          Debt fund units purchased: 5,000

          Jul 1 redemption (redemption happens only from debt fund:
          Amount: Rs.10,000
          Debt fund NAV: Rs.10.3
          Debt fund value before redemption: Rs.51,500
          Debt fund units redeemed: 970.874
          Debt fund units balance: 4,029.126
          Debt fund value after redemption: Rs.41,500

          Equity fund NAV: Rs.8
          Equity fund balance: Rs.40,000

          Total portfolio 2 balance: Rs.81,500

          Dec 31
          Equity fund NAV: Rs.9.5
          Equity fund units: 5000
          Equity fund balance: Rs.47,500
          Debt fund NAV: Rs.10.6
          Debt fund units: 4,029.126
          Debt fund balance: Rs.42,709

          Rebalance:
          Equity redemption: Rs.2,395.5
          Equity fund units redeemed: 252.158
          Equity fund units balance: 4,747.842
          Debt investment: Rs.2,395.5
          Debt fund units invested: 225.991
          Debt fund units balance: 4255.117

          Equity fund value: Rs.45,105
          Debt fund value: Rs.45,104

          Portfolio 2 balance: Rs.90,209

          Here both the portfolios have maintained 50:50 allocation at the year beginning and year end, also did the same amount of withdrawals at the same date, yet portfolio 2 ended up having slightly higher value than portfolio 1, because it avoided redeeming equity when equity markets were down 20%; this is not possible with the hybrid fund as when we redeem from it, we ended up redeeming equity as part of it at an unfavourable time.

          1. Pandu

            Nice example. Didn’t think from this perspective. Still the difference is not significant.
            Believe that, (1) if you account for tax factor for debt funds (2) If Rebalancing is not done every year, but done only when Equity goes down significantly for e.g., 15% or more (which may happen once in 3 years avg?) — SWP from balanced/hyrbid funds may work out better?
            Your thoughts, Mr.Bipin?
            Thanks

          2. Bipin Ramachandran

            Hello Sir,

            Regarding tax: The issue is that tax can vary significantly depending on personal circumstances. For example, if a retiree with no other income has a debt fund that is sitting at a 100% gain, for a monthly income generation of up to Rs. 1.17 lakhs from this debt fund, there will not be any capital gains tax applicable, as the gains will be below Rs. 7 lakh, which is tax-free with rebates.

            If the debt fund is sitting at a 50% gain, the threshold for monthly income for tax to be applicable is Rs. 1.75 lakhs.

            Please note that if this is for a retirement plan in the future, the tax rates and slabs at that point will be applicable. If we look at trends, both the threshold for paying tax and the rates of tax are coming down for slab tax.

            On the other hand, if another person with multiple income streams uses an income portfolio to generate more income, they will likely pay more tax.

            I don’t understand the second point about doing rebalancing when equity is down significantly. Please note that in this analysis, a rebalancing in favor of equity is not done because that would deplete the debt balance for periodic income generation.

  6. Raghav

    Thanks for this, very insightful. can you pl plot monthly Equity/Debt ratio of ICICI pru balanced advantage fund for this period….hope that data is available. I’m still not clear why balanced adv fund performed poorly compared to other two cases. does this mean that balanced fund on average had less than 30% equity for this entire period?

    1. Bipin Ramachandran

      Hello Sir,

      I am afraid we do not have data on the monthly equity allocation of the fund for such a long period. It is unlikely that the average equity allocation of the fund for the entire period was less than 30%.

      As explained in the article, in our view, this happened because, with periodic withdrawals enabled, there is no option to preserve equity assets when the markets are down, which is possible with a separate equity fund.

      Thank you.

  7. dipakdpj

    A very good analysis.
    Do you have a curated list of financial planners who can be of help?
    He should be able to analyze individual portfolio in similarly lucid fashion suggest changes?
    Fee paid financial planner who will not invest for investing through him.

    1. Bipin Ramachandran

      Hello,

      Thanks! While we do not have a curated list of financial planners, we can share contact details of potential contacts. You may then inquire if they are able to provide the services you are looking for.

      Please write to us at [email protected]

      Thank you.

  8. Kiran

    I think this does not take taxation into account. Moving from Debt to equity and vice versa is way more tax inefficient compared to the other option

    1. Bipin Ramachandran

      Hello,

      You are correct; this analysis does not account for taxation. As explained in the reply of another comment, doing a generic analysis of retirement income with taxation is hard as the impact on tax can vary a lot based on the corpus and individual’s financial situation.

      Thanks

  9. Gopalakrishnan CS

    Bipin very good analysis – How about HDFC Balanced Advantage or Edelweiss Balanced advantage fund.
    The convenience of a single hybrid fund with equity fund is very valid.
    I feel if we include taxation balanced advantage fund will stand out 🙂

    1. Bipin Ramachandran

      Hello Sir,

      Thank you! Regarding using other balanced advantage funds, both HDFC’s and Edelweiss’s funds do not have a long track record of being dynamically managed hybrid funds.

      Regarding taxation, yes, it will make a difference. However, it will be very specific to the corpus, as both equity and debt taxation have elements that will be determined by the quantum of capital gains, which in turn depends on the corpus; and also on any other income the investor has. In a nutshell, this can be very specific for each individual. For example, capital gains on debt funds are taxed at the slab rate. If we assume a person is generating retirement income from the portfolio and does not have any other source of income, it means debt capital gains up to Rs. 7 lakh are tax-free (general taxation relief including rebate, available for everyone under the new tax regime). If the debt fund is sitting on a 100% gain, this means a redemption of Rs. 14 lakh from the debt fund in a year will be required for the debt capital gains tax to be applicable. If the debt fund is sitting on a 50% gain, the debt redemption threshold will be Rs. 21 lakh in a year.

      Another point to note is that over 10 years or more, this Rs. 7 lakh limit will likely be revised upwards, adding another complication of including tax in the analysis for a very long period.

      Thanks

  10. karthiksekhar1988

    Bipin ji, one of the best best analysis which Team PI has come up with.. Superb. It has really given me a very good perspective and clarity when it comes to choosing my retirement portfolio.

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This website www.primeinvestor.in (“Website”) is owned and operated by PrimeInvestor Financial Research Pvt. Ltd. (“RA”), a SEBI-registered Research Analyst with Registration No. INH200008653.

Through the Website, the RA allows clients to access research recommendations, research reports, and model portfolios, along with tools, personal finance products, and articles, on the payment of a subscription fee (“Research Services”). The terms ‘RA’ or ‘us’ or ‘we’ refer to PrimeInvestor Financial Research Pvt Ltd (SEBI RA Registration No INH200008653) who are the owners of this Website and offering the Research Services. The term ‘you’ and ‘client’ refers to the subscriber of the Services on the Website. The RA provides the Research Services subject to the notices, terms, and conditions set forth in these Terms. By accepting these Terms when you subscribe to the Research Services, you provide your consent to abide by these Terms.

Most Important Terms and Conditions (MITC)

[Forming part of the Terms and Conditions for providing research services]

  1. These terms and conditions, and consent thereon are for the research services provided by the Research Analyst (RA) and RA cannot execute/carry out any trade (purchase/sell transaction) on behalf of the client. Thus, the clients are advised not to permit RA to execute any trade on their behalf.
  2. The fee charged by RA to the client will be subject to the maximum amount prescribed by SEBI/ Research Analyst Administration and Supervisory Body (RAASB) from time to time (applicable only for Individual and HUF Clients).
    Note:
    • SEBI's current cap on fee is Rs 1,51,000/- per annum per family of client for all research services of the RA.
    • The fee limit does not include statutory charges.
    • The fee limits do not apply to a non-individual client / accredited investor.
  3. RA may charge fees in advance if agreed by the client. Such advance shall not exceed the period stipulated by SEBI; presently it is one quarter. In case of pre-mature termination of the RA services by either the client or the RA, the client shall be entitled to seek refund of proportionate fees only for the unexpired period.
  4. Fees to RA may be paid by the client through any of the specified modes like cheque, online bank transfer, UPI, etc. Cash payment is not allowed. Optionally the client can make payments through Centralized Fee Collection Mechanism (CeFCoM) managed by BSE Limited (i.e. currently recognized RAASB).
  5. The RA is required to abide by the applicable regulations/ circulars/ directions specified by SEBI and RAASB from time to time in relation to disclosure and mitigation of any actual or potential conflict of interest. The RA will endeavor to promptly inform the client of any conflict of interest that may affect the services being rendered to the client.
  6. Any assured/guaranteed/fixed returns schemes or any other schemes of similar nature are prohibited by law. No scheme of this nature shall be offered to the client by the RA.
  7. The RA cannot guarantee returns, profits, accuracy, or risk-free investments from the use of the RA's research services. All opinions, projections, estimates of the RA are based on the analysis of available data under certain assumptions as of the date of preparation/publication of research report.
  8. Any investment made based on recommendations in research reports are subject to market risks, and recommendations do not provide any assurance of returns. There is no recourse to claim any losses incurred on the investments made based on the recommendations in the research report. Any reliance placed on the research report provided by the RA shall be as per the client's own judgement and assessment of the conclusions contained in the research report.
  9. The SEBI registration, Enlistment with RAASB, and NISM certification do not guarantee the performance of the RA or assure any returns to the client.
  10. For any grievances,
    • Step 1: the client should first contact the RA using the details on its website or following contact details:
      Customer care: [email protected]
      Grievance officer: [email protected], ATTN: Srikanth Meenakshi
      Compliance officer: [email protected], ATTN.: Bhavana Acharya
      Principal officer: [email protected], ATTN.: Vidya Bala
    • Step 2: If the resolution is unsatisfactory, the client can also lodge grievances through SEBI's SCORES platform at www.scores.sebi.gov.in
    • Step 3: The client may also consider the Online Dispute Resolution (ODR) through the Smart ODR portal at https://smartodr.in
  11. Clients are required to keep contact details, including email id and mobile number/s updated with the RA at all times.
  12. The RA shall never ask for the client’s login credentials and OTPs for the client’s Trading Account, Demat Account, and Bank Account. Never share such information with anyone including RA.

By browsing, viewing, using the Website and subscribing to the Research Services provided therein you consent to and agree to comply with these Terms and Conditions of subscription (“Terms”).

The RA reserves the right to change or modify the Website, the contents thereof and these Terms at any time. All modifications to these Terms & Conditions will be posted on the Website and will become effective immediately upon such posting. Changes once made will be communicated to the client. Continued use of the Website shall be construed as acceptance of the revisions to the Terms by conduct.

The following terms and conditions include but are not limited to minimum mandatory terms and conditions to clients as stipulated by SEBI.

1. Availing the research services

By accepting delivery of the research service, the client confirms that he/she has elected to subscribe to the research service of the RA at his/her sole discretion. The RA confirms that Research Services shall be rendered in accordance with the applicable provisions of the SEBI RA Regulations.

2. Obligations on RA

The RA shall be bound by the SEBI Act and all the applicable rules and regulations of SEBI, including the RA Regulations and relevant notifications of Government, as may be in force, from time to time.

3. Client Information and KYC

The client shall furnish all such details in full as may be required by the RA in its standard form with supporting details, if required, as may be made mandatory by Research Analyst Administration and Supervisory Body(RAASB)/SEBI from time to time. RA shall collect, store, upload and check KYC records of the clients with KYC Registration Agency (KRA) as specified by SEBI from time to time.

4. Standard Terms of Service

The consent of client shall be taken on the following understanding:

“I / We have read and understood the terms and conditions applicable to a research analyst as defined under regulation 2(1)(u) of the SEBI (Research Analyst) Regulations, 2014, including the fee structure.

I/We are subscribing to the research services for our own benefits and consumption, and any reliance placed on the research report provided by research analyst shall be as per our own judgement and assessment of the conclusions contained in the research report.

I/We understand that –

  1. Any investment made based on the recommendations in the research report are subject to market risk.
  2. Recommendations in the research report do not provide any assurance of returns.
  3. There is no recourse to claim any losses incurred on the investments made based on the recommendations in the research report.”

The declaration of the RA is as follows:

  1. We are duly registered with SEBI as an RA pursuant to the SEBI (Research Analysts) Regulations, 2014 and our registration details are: registration no SEBI INH200008653, with registration date 19th August, 2021
  2. We have the registration and qualifications required to render the services contemplated under the RA Regulations, and the same are valid and subsisting;
  3. Research analyst services provided by us do not conflict with or violate any provision of law, rule or regulation, contract, or other instrument to which it is a party or to which any of its property is or may be subject;
  4. The maximum fee that may be charged by the RA is ₹1.51 lakhs per annum per family of client. Our current fee structure, the term and duration of our subscription for our Research Services, can be viewed on our website here: https://primeinvestor.in/prime-pricing
  5. The recommendations provided by us as part of the Research Services do not provide any assurance of returns.

5. Consideration and mode of payment

The client shall duly pay to the RA the agreed fees for the services that RA renders to the client and statutory charges, as applicable. Such fees and statutory charges shall be payable through the specified manner and mode(s)/ mechanism(s).

The payment of fees shall be through a mode that shows traceability of funds. Such modes include but are not limited to credit cards/debit cards/ UPI/ net banking or any other mode specified by SEBI from time to time. However, the fees shall not be in cash.

6. Risk factors

  1. Investments are subject to market risk. Investing or trading in financial products involves risk. Past performance of the recommendation is not an indication of future returns. Past performance of the RA is not an indicator of future performance. Past performance of the security is not an indication of future returns.
  2. There are no assurances or guarantees that the objectives of any investment in financial products will be achieved.
  3. The names of financial products mentioned herein do not in any manner indicate their prospects or returns. The performance in the equity may be adversely affected by the performance of individual companies, changes in the market place and industry specific and macro-economic factors.
  4. The performance of the investments/ products recommended by the RA are subject to a wide range of risks, including but not limited to: performance of the respective companies, changes in equity and debt market conditions, micro and macro factors and forces affecting equity and debt markets, general levels of interest rates and interest rate risk, credit risk, liquidity risk, reinvestment risk, economic slowdown, volatility & illiquidity of the stocks, risks associated with trading volumes, liquidity and settlement systems in equity and debt markets and/or such other circumstance beyond the control of the RA or any of its Associates.
  5. Other risk factors include that may affect the performance of the investments/ products recommended by the RA include but are not limited to economic policies, changes of Government and its policies, acts of God, acts of war, civil disturbance, sovereign action and /or such other acts/ circumstance beyond the control of the RA or any of its Associates.
  6. The recommendations provided by the RA as part of its Research Services may not be suitable to all categories of investors.
  7. The client should read all scheme and security related documents carefully before investing.
  8. Returns and performance figures mentioned in the research report represent past performance and should not be constituted to be future returns or guaranteed returns.

7. Conflict of interest

The RA shall adhere to the applicable regulations/ circulars/directions specified by SEBI from time to time in relation to disclosure and mitigation of any actual or potential conflict of interest. Registration granted by SEBI and certification from NISM in no way guarantee performance of the intermediary or provide any assurance of returns to investors. Investment in securities market are subject to market risks. Read all the related documents carefully before investing.

General disclosures: PrimeInvestor Financial Research Pvt Ltd (with brand name PrimeInvestor) is an independent research entity offering research services on personal finance products to customers. We are a SEBI registered Research Analyst (Registration: INH200008653). PrimeInvestor Financial Research Pvt. Ltd., its employees, directors or agents, do not have any material adverse disciplinary history as on the date of publication of this report.

Restrictions on trading: To ensure no conflict of interest, the RA declares as follows:

  1. Personal trading activities of the individuals employed as research analysts shall be monitored, recorded and subject to a formal approval by the directors or compliance officer of PrimeInvestor Financial Research Private Limited.
  2. Research analysts employed by PrimeInvestor Financial Research Private Limited or their associates or relatives shall not:
    • Deal/ trade in stocks recommended/ tracked by the research analyst within 30 days before and five days after the publication of a research report;
    • Deal/ trade in securities that the research analyst reviews in a manner contrary to the given recommendation;
    • Purchase or receive securities of the issuer before the issuer's initial public offering, if the issuer is principally engaged in the same types of business as companies that the research analyst follows or recommends.

Disclosures with respect to Research and Recommendations Services:

  1. The RA or its directors or any of its officer/employee does not trade in securities which are subject matter of recommendation.
  2. The RA, or any of its officers, directors, employees, or subsidiaries have not received any compensation/ benefits whether monetary or in kind, from the AMC, company, government, bank or any other product manufacturer or third party, whose products are the subject of its Research Services or investment information.
  3. The Research Analysts who have prepared the research reports that form part of the Research Services (“Research Analyst”) certify that all of the views expressed in the research report accurately reflect their views about the subject company or subject security.
  4. The RA or directors or employees or Research Analyst certify that no part of their compensation was, is, or will be directly or indirectly related to the specific recommendation(s) or view(s) in this report.
  5. The Research Analyst has not served as director, officer or employee in the subject company, AMC or insurance company of the mutual fund or insurance policy that is the subject of this report, or company whose bonds, NCDs, fixed deposits or other savings products that is the subject of this report.
  6. The Research Analyst or their relatives do not have any known direct or indirect material conflict of interest including long/short positions in the subject company.
  7. The Research Analyst may hold investments in the stocks, mutual fund schemes, bonds, fixed deposits, insurance policies, or other products that are the subject of the recommendations provided as part of the Research Services. The Research Analyst certifies that they will not act in a manner contrary to their views on these securities except in the event of significant news or event or change in personal financial circumstances and without formal approval from the directors of PrimeInvestor Financial Research Pvt. Ltd. or the compliance officer.
  8. There are no actual or potential conflicts of interest arising from any connection to or association with any issuer of products/ securities, including any material information or facts that might compromise its objectivity or independence in the carrying on of the Research Services. Such conflict of interest shall be disclosed to the client as and when they arise.
  9. The RA or its directors or its employee or its associates have not managed or co-managed the public offering of any company. The RA or its directors or its employee or its associates have not received any compensation for investment banking or merchant banking of brokerage services from the subject company. The RA or its directors or its employee or its associates have not received any compensation for products or services other than above from the subject company. The RA or its directors or its employee or its associates have not received any compensation or other benefits from the Subject Company or 3rd party in connection with the research report/ recommendation.
  10. The subject company of its research recommendations was not a client of the RA or its directors or its employee or its associates during twelve months preceding the date of recommendation services provided.
  11. The RA or its directors or its employee or its associates has not served as an officer, director or employee of the subject company. Research Analysts has not been engaged in market making activity of the subject company.

PrimeInvestor Financial Research Pvt. Ltd., its Associates, the Research Analysts or their relatives holds ownership of 1% or more, in respect of the said issuer company(ies)? – NO

8. Termination of service and refund of fees:

The RA may terminate or suspend rendering of Research Services to the client in the following circumstances:

  1. On account of suspension/cancellation of registration of RA by SEBI. In case of suspension of certificate of registration of the RA for more than 60 (sixty) days or cancellation of the RA registration, RA shall refund the fees, on a pro rata basis for the period from the effective date of cancellation/ suspension to end of the client’s subscription period.
  2. The RA voluntarily chooses to terminate its Research Service. In the event of such termination of the Research Service, the RA shall refund the fees, on a pro rata basis for the period from the date of such termination of research service to end of the client’s subscription period.

9. Grievance redressal and dispute resolution:

Any grievance related to:

  1. nonreceipt of research report, or
  2. missing pages or inability to download the entire report, or
  3. any other deficiency in the research services provided by RA

shall be escalated promptly by the client to the person/employee designated by RA, in this behalf as under:

Name: Bhavana Acharya
Designation: Director & Compliance Officer, PrimeInvestor Financial Research Pvt Ltd
Email: [email protected]

The RA shall be responsible to resolve grievances within 7 (seven) business working days or such timelines as may be specified by SEBI under the RA Regulations.

RA shall redress grievances of the client in a timely and transparent manner. Any dispute between the RA and his client may be resolved through arbitration or through any other modes or mechanism as specified by SEBI from time to time.

If the client is not satisfied with the response of the RA, he/she can lodge his/her grievances with SEBI at scores.sebi.gov.in. Alternatively, the client may also write to any of the offices of SEBI. For any queries, feedback or assistance, please contact SEBI Office on Toll Free Helpline at 1800 22 7575 / 1800 266 7575

Details on grievances are available on the Website as follows: https://primeinvestor.in/ra-grievance/

10. Additional clauses:

Scope of the Research Service: The Research Services will be limited to providing independent research recommendation and shall not be involved in any advisory or portfolio allocation services. The Research Services are not meant to be tailor-made or customized solutions that specifically apply to each client based on his/her risk profile.

The RA never guarantees the returns on the recommendation provided. Investor shall take note that investment/trading in stocks/Index or other securities is always subject to market risk. Past performance is never a guarantee of same future results. The RA shall not be responsible for any loss to the Investors.

This service is not directed for access or use by anyone in a country, especially the USA, Canada or the European Union countries, where such use or access is unlawful or which may subject PrimeInvestor Financial Research Pvt Ltd or its affiliates to any registration or licensing requirement.

The Research Service, including recommendations, research reports, updates, and other information will be accessible through the RA’s website https://primeinvestor.in only. Such recommendations and updates will not be provided over phone calls.

Fees: Our current fee structure, the term and duration of our subscription for our Research Service, can be viewed on our website: https://primeinvestor.in/prime-pricing. Eligibility for any discounts is ascertained at the time the client subscribes. Any such discount and its tenure shall be at the discretion of the RA.

Subscription and access to content services fall under the purview of Goods and Services Tax (GST) as per the current indirect taxation policy, Government of India. Unless otherwise indicated, prices stated on our website are exclusive of applicable GST, any applicable value added tax (VAT) or other sales taxes. We are a business-to-consumer (B2C) service provider and we do not commit to provide any input tax credit on GST charged on subscription to our Research Service.

We may change the Subscription Fees and charges then in effect, or add new fees or charges which will take effect at the end of the client’s subscription period, by giving notice in advance and an opportunity to cancel renewal of the subscription.

Subscription Access & Renewal: Subscription to the Website commences immediately on the realisation of payment of the Subscription Fees. Subscriptions are set to be renewed automatically at the end of the subscription period.

Unless the client notifies us before the end of his/her subscription period, or the client cancels the auto-renewal mandate within the period specified by law, that the client does not wish to renew his/her subscription, the client’s subscription will renew for the period defined by the client’s subscription plan. We will charge the subscription using the same payment method that you previously used.

Although the client may notify to us his/her intention to his/her subscription, such notice will only take effect at the end of his/her then current subscription period, and he/she will not receive a refund other than as set out under Clause 8 in these Terms.

The client may notify us of his/her wish to cancel his/her subscription by sending an email to [email protected]. The client must provide at least 5 business days advance notice for this to be implemented.

Refunds: There can be no cancellation and refund of subscription fee paid once the subscription is active, other than as stated in Clause 8 of these Terms. If the client is entitled to a refund as specified under Clause 8 of these Terms, the RA will credit that refund to the card or other payment method used by the client to submit payment, unless it has expired - in which case the RA will contact the client to proceed with the refund. If we do issue a refund or credit due to circumstances outside the obligations specified under Clause 8, we are under no obligation to issue the same or a similar refund in the future.

General disclaimers: The recommendations made herein in the Research Services are expression of views and/or opinions and should not be deemed or construed to be advice for the purpose of purchase or sale of any security, nor a solicitation or offering on any investment/ trading opportunity on behalf of the company, AMC, insurance company, or issuer of security referred to herein.

The content and research reports generated by the RA does not constitute or is not intended to constitute an offer to buy or sell, or a solicitation to an offer to buy or sell financial products, units or securities.

The information/ opinion/ views mentioned in research reports or by the RA are not meant to serve as a professional guide to the client or recipients of this Report. The research report, recommendation, or any other content published by the RA do not assure or guarantee any minimum or fixed returns to the client or recipients of the reports/ recommendations/ content.

Use of this information is at the client’s own risk. The client must make his/ her own investment decisions based on his/her specific investment objective and financial position and using such independent advisors as he/she believes necessary. The services rendered by the RA are on a best-effort basis. All information in the content or research report of the RA is provided on an as is basis. Information is believed to be reliable but the RA does not warrant its completeness or accuracy and expressly disclaim all warranties and conditions of any kind, whether express or implied.

While due care has been taken to ensure that the disclosures, information, and opinions given are fair and reasonable, PrimeInvestor Financial Research Pvt Ltd and/or none of its officers, directors, partners, employees, agents, subsidiaries, affiliates or business associates shall be liable for any direct, indirect, special, incidental, consequential, punitive or exemplary damages, including lost profits arising in any way whatsoever from the information/ opinions/ views contained in the research report and recommendations that form part of the Research Service, and/or mails, social media or notifications issued by PrimeInvestor Financial Research Pvt Ltd or any other agency appointed/authorised by PrimeInvestor Financial Research Pvt Ltd. Returns and performance figures mentioned in the research report represent past performance and should not be constituted to be future returns or guaranteed returns.

Any agreements, transactions or other arrangements made between the client and any third party named on (or linked to from) the Website are at your own responsibility and entered into at your own risk. Any information that you receive via the Website, whether or not it is classified as “real time”, may have stopped being current by the time it reaches you. Market price information may be rounded up/down and therefore may not be entirely accurate.

The purpose of these disclosures is to provide essential information about the Research Services in a manner to assist and enable the prospective client/client in making an informed decision for engaging in Research Services before onboarding.

History, present business and background: PrimeInvestor Financial Research Private Limited is registered with SEBI as Research Analyst with registration no. INH200008653. The Research Analyst got its registration on August 19, 2021 and is engaged in offering research and recommendation services.

Disciplinary history: There are no pending material litigations or legal proceedings against the Research Analyst. As on date, no penalties / directions have been issued by SEBI under the SEBI Act or Regulations made thereunder against the Research Analyst relating to Research Analyst services.

Details of the RA's associates: No associates.

Usage of Website Content: This Website is controlled and operated by the RA. All material, including research reports, recommendations, portfolios, ratings, lists of financial products, illustrations, statements, opinions, views, photographs, products, images, artwork, designs, text, graphics, logos, button icons, images, audio and video clips and software (collectively, “Content”) are protected by copyrights, trademarks and other intellectual property rights that are owned and controlled by the RA or by other parties that have licensed their material to us.

Except where otherwise agreed in writing with the RA, material on the Website is solely for the client’s personal, non-commercial use. Except as provided below, the client must not copy, reproduce, republish, upload, post, transmit or distribute such material in any way, including by e-mail or other electronic means and whether directly or indirectly and the client must not assist any other person to do so.

Without the prior written consent of the RA, modification of the materials, use of the materials on any other web site or networked computer environment or use of the materials for any purpose other than personal, non-commercial use is a violation of the copyrights, trademarks and other proprietary rights, and is prohibited. Any use for which the client receives any remuneration, whether in money or otherwise, is a commercial use for the purposes of these Terms.

The client may occasionally distribute a copy of a research report, or a portion of the same, from the Website in non-electronic form to a few individuals without charge, provided the client includes all copyright and other proprietary rights notices in the same form in which the notices appear, original source attribution, and the phrase “Used with permission from PrimeInvestor Financial Research Pvt. Ltd.”

While the client may occasionally download and store research reports or information from the Website for his/her personal use, he/she may not otherwise provide others with access to the same. The foregoing does not apply to any sharing functionality we provide through the Website that expressly allows the client to share Content or links to Content with others. In addition, the client may not use Content he/she has downloaded for personal use to develop or operate an automated trading system or for data or text mining.

The client agrees not to rearrange or modify the Content available through the Website. The client agrees not to display, post, frame, or scrape the Content for use on another website, app, blog, product or service, except as otherwise expressly permitted by these Terms. You agree not to create any derivative work based on or containing the research products and Content. The framing or scraping of or in-line linking to the Services or any Content contained thereon and/or the use of webcrawler, spidering or other automated means to access, copy, index, process and/or store any Content made available on or through the Services other than as expressly authorized by us is prohibited.

The client further agrees to abide by exclusionary protocols (e.g., Robots.txt, Automated Content Access Protocol (ACAP), etc.) that may be used in connection with the Research Services. The client may not access parts of the Research Services to which he/she is not authorized, or attempt to circumvent any restrictions imposed on your use or access of the Services.

As a general rule, the client may not use the Content, including without limitation, any Content made available through one of our RSS Feeds, in any commercial product or service, without our express written consent.

The client may not create apps, extensions, or other products and services that use our Content without our permission. The client may not aggregate or otherwise use our Content in a manner that could reasonably serve as a substitute for a subscription to the Website.

The client may not access or view the Services with the use of any scripts, extensions, or programs that alter the way the Services are displayed, rendered, or transmitted to you without our written consent.

The client agrees not to use the Services for any unlawful purpose. We reserve the right to terminate or restrict the client's access to the Website if, in our opinion, the client's use of the Services may violate any laws, regulations or rulings, infringe upon another person's rights or violate these Terms.

Prohibited content: The Website includes comments sections, blogs and other interactive features that allow interaction among clients and between clients and the RA. We call the information posted by or contributed by users “Contributed Content.” In the course of availing of the Research Services or uploading any post or comment on the Website, the client shall not post any Contributed Content that (i) contains nude, semi-nude, sexually suggestive photos, (ii) tends or is likely to abuse, harass, threaten, impersonate or intimidate other users of the Website and/or Research Services, (iii) is lascivious or appeals to the prurient interest or if its effect is such as to tend to deprave and corrupt persons who are likely to use or have access to the Website and/or Services, or (iv) otherwise violates, is prohibited or restricted by applicable law, rule or regulation, is offensive or illegal or violates the rights of, harms or threatens the safety of other users of the Website and/or Services (collectively “Prohibited Content”).

We reserve the right to cease to provide the client with the Research Services or access to the Website, or terminate your subscription, with immediate effect and without notice and liability, for violating these Terms, applicable law, rules or regulations and reserves the right to remove Prohibited Content which is in violation of these Terms, or is otherwise abusive, illegal or disruptive. The determination of whether any content constitutes Prohibited Content, violates these Terms, or is otherwise abusive illegal or disruptive, is subject to the sole determination of the Firm.

Changes to Research Services: We are constantly endeavouring to improve the quality of Research Services provided to our clients. Due to this, the form and nature of the Research Services provided may change from time to time without any prior notice to the client. We reserve the right to introduce and initiate new features, functionalities, components to the Website and/or Research Services and/or change, alter, modify, or discontinue existing ones without any prior notice to the client.

Warranty and liability disclaimer: The Website, Research Services, and all the materials and services, included on or otherwise made available to the client through this Website is provided by the RA on an “as is” and “as available” basis without any representation or warranties, express or implied except otherwise specified in writing. Without prejudice to the foregoing paragraph, the RA does not warrant that:

  • This Website and/or Research Services will be constantly available, or available at all;
  • The information on this Website or provided through the Research Services is complete, true, accurate or not misleading; or
  • The quality of any products, services, information, or other material that you obtain through the Website or Services will meet your expectations.

The RA, to the fullest extent permitted by law, disclaims all warranties, whether express or implied, including the warranty of merchantability, fitness for particular purpose and non-infringement. The RA makes no warranties about the accuracy, reliability, completeness, or timeliness of the Website, Research Services, Content, Contributed Content, Services, software, text, graphics and links.

The RA does not warrant that this Website, Research Services, information, content, materials, or any other material included on or otherwise made available to you through this Website, their servers, or electronic communication sent by the RA are free of viruses or other harmful components.

Nothing on this Website constitutes, or is meant to constitute, advice of any kind.

Indemnification: The client:

  1. Represents, warrants and covenants that no materials of any kind provided by him/her will:
    1. Violate, plagiarise, or infringe upon the rights of any third party, including copyright, trademark, privacy or other personal or proprietary rights; or
    2. Contain libellous, Prohibited Content or other unlawful material;
  2. Hereby agree to indemnify, defend and hold harmless the RA and all of the RA’s officers, directors, owners, agents, customers/clients, information providers, affiliates, licensors and licensees (collectively, the “Indemnified Parties”) from and against any and all liability and costs, including, without limitation, reasonable advocate’s fees, incurred by the Indemnified Parties in connection with any claim arising out of any breach by the client of these Terms or the foregoing representations, warranties and covenants. The client shall cooperate as fully as reasonably required in the defence of any such claim. The RA reserves the right, at its own expense, to assume the exclusive defence and control of any matter subject to indemnification by the client.

Applicable law: This Website, including the Content and Contributed Content and information contained herein, and the provision of Research Services shall be governed by the Securities and Exchange Board of India, laws of the Republic of India and the courts of Chennai, India which shall retain exclusive jurisdiction to entertain any proceedings in relation to any disputes arising out of the same. As such, the laws of India shall govern any transaction completed using this Website.

Information gathered and tracked: Information submitted or collected on the Website or pursuant to the use of the Services is stored in a database. Specifically, we store the username, name, e-mail address, contact number, as submitted or collected on our Website or through the provision of the Research Services. We may use such information to send out occasional promotional materials, including alerts on new Services available, or other promotional and marketing material relating to our clients and customers.

In accordance with the Information Technology Act 2000, the name and the details of the Grievance Officer at PrimeInvestor is provided below:

Mr. Srikanth Meenakshi
PrimeInvestor Financial Research Pvt. Ltd., Registered office: 659, 4th Avenue, D-Sector, Anna Nagar Western Extension, Chennai 600 101.
Email: [email protected]

11. Mandatory notice:

Clients shall be requested to go through Do’s and Don’ts while dealing with RA as specified in SEBI master circular no. SEBI/HO/MIRSD-POD-1/P/CIR/2024/49 dated May 21, 2024 or as may be specified by SEBI from time to time.

12. Optional Centralised Fee Collection Mechanism:

SEBI has operationalized a centralized fee collection mechanism for IA and RA. Under this mechanism, clients shall pay fees to IAs/RAs through a designated platform/portal administered by a recognized Administration and Supervision body. This is an optional mechanism for the registered entities. At this time, PrimeInvestor has opted out of this fee collection mechanism. Therefore, all subscription payments for the Research Services will be through the modes as specified in Clause 5 of these Terms.

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