Active funds vs Index funds

The answer is no. There will definitely be more space for index investing in your portfolio but that doesn’t mean you can ignore active funds.  We’ll show you some numbers on Indian active funds’ ability to beat the indices currently.

In recent years, a series of events have led to increased awareness of index funds:

  • The regulator increasingly pushing manufacturers to reduce costs and encouraging investors to opt for low cost products
  • Significant increase in global inflows in ETFs
  • Select stocks in the Indian markets moving to newer heights, naturally pushing indices up but having little to no impact on the wealth of those who held certain categories of active equity funds.

This article won’t get into the above trends. Instead, we will look at the performance of mutual funds in recent years vis-à-vis indices to make the case for why active investing is still needed.

A few notes on what we did:

  • We avoided very long periods for the simple reason that much water has flowed post 2008. Pre-2008, you could throw a dart and be reasonably sure the fund you picked outperformed the index. Active investing beat indices comfortably over 15-20-year periods and the returns of very dated periods skews the averages.
  • Therefore, we kept to a maximum of 10 years. So, 3 years returns were rolled daily for 5 years (that makes it a total 8-year period) and 5-year returns were rolled daily for 5 years (so a total of 10 years from 2009). This period is also important as mutual funds did not have it easy both regulatorily and otherwise in many ways.
  • For the said 3- and 5-year periods, daily averages of fund return in each category were taken and compared with the indices we benchmarked them against.
  • We clubbed the large & mid, focused and multicap categories (called diversified in this article) as there isn’t must difference in their investing styles. Also, much of these historical returns were pre-SEBI categorization (2018) when they all had similar market-cap styles. We kept value, dividend yield and contra separate to compare them with their appropriate benchmarks.
  • We considered regular plans, as direct plans do not have full data for the period considered. Also, the idea is to see how funds perform with full expense loaded in them.
Active vs index funds screenshot 
Active funds vs index funds 

What the averages mask

The two tables above don’t paint active funds in a bad light except in a couple of cases. But looking at just averages can be misleading even though we’ve avoided taking longer periods where returns were high. Therefore, let’s look at the details category-wise.

Largecaps may be losing the plot

The large-cap fund category’s 5-year average return has been underperforming the Nifty 100 TRI by an average 0.4% annualized since June 2018 (when the underperformance trend started). This gets more acute over 1 and 3-year periods. The next check we did was whether large-cap funds are at least containing downsides better. Downside capture ratio tells whether funds fall less than the index, when indices fall. Our rolling 1-month (over 3 years) data tells that only half the universe of large-cap funds did better than the index.

Next, we tried to see if there are at least enough winning funds that you can pick. Unfortunately, just 1 in 4 funds manage to beat the Nifty 100 TRI over 3- and 5-year time frames. That means the odds are against your hitting upon right fund to beat the benchmark.

Verdict:  There is a growing case for substituting large-cap funds with other options. Please read our article on this changing trend and what to do: https://www.primeinvestor.in/2019/11/08/large-cap-funds-are-losing-the-appeal/.

PrimeInvestor will have investible ETFs and index funds other than the commonplace Nifty 50 to play this space better in our Prime list of recommendations. We will also highlight the few superior large cap funds in this space.

Diversified funds for all seasons

This category beat the benchmark by 2.1 percentage points on an average for 3-year periods. However, the 3-year returns since June 2018 has been marginally underperforming the index, though it is not as pronounced as large caps. It is also clear that fund managers are staying away from ‘expensive quality’ or limiting weights to them. This is one reason for their recent underperformance.

But there isn’t a dearth of funds to outplay the index, unlike the large-cap space. 1 in 2 funds beat the index two-thirds of the time on a rolling 3-year basis. Better still, on a rolling 5-year basis, 2 in 3 funds beat the index over 80% of the time. This clearly establishes that there is a clear case for active investing in this category.

Not just that, the category’s record in delivering consistently superior returns is also high. For example, 79% of the time, they delivered returns above 12% on a 5-year rolling basis. The Nifty 500 TRI delivered such returns just 60% of the time.

The third positive feature is that the category provides various styles of investing. Choosing differentiated styles will ensure that one or the other of your funds will be outperforming in different cycles. For example, a value conscious diversified fund from a small but well-known fund management house with a dash of international exposure combined with a growth strategy from a nimble AMC or a momentum play from a lesser known fund house can balance your portfolio better than one market-cap based index.

On the index front in this space, as things stand today, there is just one index fund on the Nifty 500 index and one ETF on the S&P BSE 500. The Nifty 500/ BSE 500 are not to be confused with the structure of the S&P 500, which is a US market index and sports a far better mix of sectors and stocks (Here’s our review of the Motilal Oswal S&P 500 index fund).

Our sense is that filtered versions of the Nifty 500 (factor-based) may kick in soon. But it is clear that fund houses do all the factor-based investing possible in the active segment of this category and there is enough variety and funds to choose from.

Verdict: There is a very clear case for active investing in this space. This segment can also be a substitute for large caps given the ability of many funds in this space to contain downsides and deliver returns.

Midcaps still manage

The3-year returns in this category beat the benchmark comfortably. By their very structure (an index is purely into midcaps while a fund can have small proportion in large caps or cash), their ability to contain downsides has ensured outperformance.

However, there is a stark divergence in the performance of the universe in recent times, like large caps. Post SEBI’s categorization in 2018, mid-cap funds may have seen a change in their investment universe, wherein what AMCs considered as midcaps became small caps (as defined by SEBI). But the bigger issue is that the midcap rally until 2017 left some of these funds with burgeoning assets that had to be effectively deployed. And if initial signs are anything, some of the funds with larger AUMs are showing signs of strain. This essentially means it is not easy picking funds in this category.

In the index space, while funds comfortably beat Midcap 100, new and emerging indices such as Midcap 150 provide stiff competition. But the index may be suitable only for very aggressive investors.

Verdict: The bottom line here is that, for a long-term portfolio, an active fund from this category or from small caps is a must to provide kicker to your portfolio. But choosing the right fund will not be as easy as it is in the diversified fund category.

Small caps cannot be swapped

This is one category where the fund manager’s skills show up. We don’t think there will be any indices any time soon to replace this. Whether it is the Nifty Smallcap 100 or the tougher Nifty Smallcap 250, small-cap funds score every time.

9 out of 14 funds in this category beat the benchmark over 80% of the times when returns were rolled for 3-year periods.

And while index supporters might say that this category contains downsides better only because they do not hold 100% small-caps, we think that is why investors need to go to a fund manager in the first place. For an investor to take cash calls or to shift market caps and incur capital gains to do so deftly, in the Indian context (cost and tax), is simply not efficient nor feasible.

Verdict: You need active small-cap funds to build wealth. There appears no substitute at this stage for this.

Value, waiting to be picked

Apart from showing the numbers, I do not wish to get into a debate on value vs quality in the Indian context and whether value funds are underperforming, as we will digress. While value traps may be harder to overcome in indices than active fund styles, it is heartening to know that value strategies, especially if combined with other factors, can deliver. More about it when we talk about recent index funds, emerging indices and possible ETFs in this space.

What these numbers tell us

We have put out just a couple of the many factors that we look at when we compare funds with indices during our rating and recommendation cycles. They key takeaways from our numbers are this:

  • While the number of funds underperforming the benchmark is worrisome in large caps, in all other cases, there are enough options that makes active investing worthwhile. In fact, the above averages would be higher save for a few funds that account for probably less than 2 percent of the AUM.
  • However, with a larger universe of funds, it is not going to be easy for investors to spot the funds that are improving or the funds that are going down. Read our article on https://www.primeinvestor.in/2019/10/31/is-buy-and-hold-a-sound-strategy-for-mfs/
  • It has and will be more challenging for retail investors, especially those who have been confidently picking their own funds to mix funds with right strategies to deliver.
  • Understanding of individual fund strategies and how they play will be crucial to picking good funds.

In this regard, it is important for investors looking at big names in the MF space or index supporters criticising the big names (the only ones they know) – to look deeper, as the landscape has changed. It is important to spot smaller, nimble, less flashy names that have quietly been doing their job with élan.

Investors have a choice between doing or seeking quality research and advice or simply calling active funds as ‘sour grapes’. But for those who do, here’s a sample of what good active funds can deliver just over a 5-year period, if you are a SIP investor:

File could not be opened. Check the file's permissions to make sure it's readable by your server.

Returns as of Oct. 31, 2019

Postscript

While we mentioned some reasons for the increasing interest in index funds, it is also partly to do with the poor advice (sometimes mis-selling) that some investors have experienced. This can be a very valid reason to decide to simply hug the market than take active calls that go wrong. However, it is not necessary that you stay away from good opportunities to build wealth.

At PrimeInvestor, we consider both passive and active strategies. The present team has been engaging in talks with fund houses about the need to have more low-cost semi-active products for the past 2 years. The team has back tested many of the factor indices in India and tried various combinations on what works in the Indian context.

We are now again sharing and understanding strategies with fund houses that see a need to build passive or semi-active strategies for the long term. Our overall objective is to see how optimally an investor can build wealth, without losing out on good options – active or passive. It need not be either or. And as things stand today, it is certainly not ‘all passive’.

Index Talk in India

In the last 2 years of regulatory changes both with respect to cost structure and investment framework, we see some extreme views on investing and advisory.

  • Anybody who advocates active investing is seen to be after money or commission.
  • Anybody who provides free advice or calculations must always be right.
  • Recommending index investing is a must to establish one’s moral status or values

I will stop with saying the above views are a bit myopic if not dangerous.

There is also this belief that fund returns look alike with time, so one might as well go with low cost. Going with index funds is not at all wrong and is a strategy by itself but the reasoning that is often presented is not true. Quality funds can make a difference to your wealth as can be seen in the SIP table in this article.

Unfortunately, many investors who read the index bibles and advocate it, fail to see the pitfalls that Indian investors are confronted with in the Indian market (in contrast with what’s seen in the US market). Here are some:

  • Index funds are not always low on cost save for the Nifty 50. The cost of Next50 or an equal weight index is closer to the 1% mark. Besides, investors are often unaware that the tracking error in these funds can be significant and that there are some abnormally high cost index funds.
  • Worse still, ETFs (other than the Nifty, Junior Nifty and select Bank ETFs) suffer from poor liquidity and their market prices and NAVs are totally out of sync.
  • There are very limited options today for ETFs or index funds to replace the varied strategies that funds use or the varied categories that SEBI has prescribed. ETFs such as low volatility or Value exist without being useful due to poor liquidity. Others such as equal weight pale in comparison to performance of their active counterparts.
  • When global advisors (or NRIs investing in India using overseas vehicles) talk of index-based investing in Indian markets, they only see major indices such as the MSCI India indices. Those indices are much more deftly managed, and many are filtered on several factors including low volatility, quality or value. These do deliver well and exhibit lower volatility in some cases. Unfortunately, the Indian regulator permits only indices associated with our stock exchanges to be publicly available for investing.

Yes, you can seek to invest in the varied, exciting indices in other markets. But for a normal retail investor in India, it is not yet that easy to tap the global market. Save for a Nasdaq 100 ETF and FoF or Hangseng, there aren’t any funds/ETFs that you can invest in, through the local fund route; unless you get directly into such ETFs through select brokerages. It may not also be affordable for a typical Rs 5000-10,000 per month retail SIP investor. That global investing is treated as debt investing for tax purposes in India, can also be a big put off for many ‘tax conscious’ investors.

Hold On

You are being redirected to another page,
it may take a few seconds.
Login to your account
OR

Become a PrimeInvestor!

Get stock & mutual fund recommendations

Start registration

Start registration

OR
user icon
user icon
user icon

Terms & Conditions

A copy of the T&C has been sent to your email.

Last modified on February 18, 2025

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.

Enter the OTP sent to (Edit)
By doing this you agree to our terms & conditions
Didn't receive OTP? Resend

Have an account?
Login To Your Account
OR
Don’t have an account ? Register for free