Quarterly review – changes to Prime Funds and Prime ETFs

Prime Funds is our list of recommendations in equity, debt, and hybrid mutual funds that are worth investing in. Prime Funds narrows down your choices from the thousands of funds that there are into a concise list of funds that span different styles. Prime Funds are selected based on performance, portfolios, and investment strategies. 

In this review, we have made several additions and removals from our Prime list. We request you to carefully go through the report to stay updated.

Quarterly review – changes to Prime Funds and Prime ETFs

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About Prime Funds

Prime Funds is our list of best mutual funds across the equity, debt, and hybrid categories. We use Prime Ratings, our fund ratings, as a first filter. We then apply qualitative analysis to arrive at our fund recommendations. Prime Funds is an enduring list of funds that you can use at any time. You will always find a fund to meet any goal you’re looking to meet.

Different categories: Prime Funds are separated into buckets, based on risk level in equity & hybrid funds and timeframe in debt funds. Each of these draws from different SEBI-defined categories. We have classified them in a more user-friendly way than using the several dozens of SEBI categories. We do not go only by Prime Ratings but look at other factors as well to narrow the list and make the choices easy for you.

Different styles: In Prime Funds, we’ve aimed at providing funds that follow different strategies for you to mix styles and diversify your portfolio with ease. The ‘Why this fund’ for each Prime Fund will brief its strategy, why we picked it, and how to use it in your portfolio.

Direct plans: We have specifically given the direct plans in Prime Funds. If you wish to know whether it is ok for you to use the regular plan of the fund, check our Portfolio Review Pro tool periodically to know if you are with expensive regular plans.

Quarterly review: Our aim in reviewing the Prime Funds list every quarter is to ensure that we don’t miss any good opportunities that are coming up and we are not holding on to funds that are slipping. When we remove funds from the Prime Funds list, we tell you exactly what to do if you have invested in these funds. Funds we remove do not immediately call for a sell – it is just that they have slipped in performance marginally or there are better alternatives now. Unless our review tool says such funds are a ‘sell’, you can hold them (refer to our article on when to sell funds)

Using Prime Funds: You don’t need to hold every Prime Fund nor add any new fund we introduce to the list. Unless it fits your overall portfolio/strategy, or there is something lacking, there is little need for you to go on adding funds. Our idea of covering them in detail through some of our weekly calls is to let you know the strategy, style, and suitability in different portfolios. It is not a specific call to buy right away, unless we mention that it is a ‘tactical’ or ‘timing’ call. If you need to build a portfolio using Prime Funds, use our Build Your Own portfolio tool to make this easy for you.

Equity Funds

Even as fears of a recession or a soft landing in the US remained high and crude threatened to push India’s deficit, the stock market closed the quarter ending September on a positive note. Though the Nifty 50 managed only sedate gains of under 3%, the Midcap 150 and Smallcap 250 indices showed no sign of relenting with returns of 13 and 17% respectively for the 3 months ending September 2023. 

The sharp rally in the mid and small-cap segment has no doubt caused concerns over the sustainability of the rally as many pockets in this market cap segment begin to look overvalued. In this context, we have made some changes to Prime Funds, to bring in more moderate risk funds that one can ride. Overall, we are approaching equity with some caution. Our fund changes are in line with this sentiment.

Equity – Moderate (Active)

We have brought in 2 funds in this segment considering that we prefer to add more large-cap oriented or diversified funds at this point than new additions in the mid and small-cap space.

You might be surprised that we have added HDFC Flexicap. After prolonged underperformance and years of receiving low ratings in our research, this fund has steadily climbed the ranks. A shuffle in management and also change in fund managers has forced us to take a closer look at the funds in this AMC.

With value strategies picking up, this value-biased fund began to outperform on a rolling 1-year return basis from early 2021 (a year after the March 2020 correction). However, given that this fund had a very volatile history, we did not pick it on initial signs of outperformance. It now appears that it has managed to sustain such performance. Also, with a higher-than-average holding in large cap stocks compared with peers, the fund is well-placed to contain downsides in a falling market. 

While long-term returns  still point to a history of underperformance, we believe the shuffle in the top management and change in fund manager since mid-2022 may have brought in some change in fund management style. To that extent, we will need to assess this fund based on its present performance rather than the past. The fund’s present overweight position in sectors with reasonable valuation such as IT, healthcare and energy also provide comfort in the present market. 

If you are adding this fund, do not let it form a large chunk of your portfolio. You can use it along with index funds that you may hold or with growth style funds. Investments are best done through SIPs.

We also added ICICI Prudential Focused Equity. This fund too has a large-cap orientation except that it has a more concentrated holding in stocks given its focused strategy. The fund has managed to pick high-growth sectors in a timely manner resulting in significant outperformance over both benchmark and peers in the focused category. The fund’s downside ratio suggests that it has also managed to fall less during declines. This feat is particularly difficult to achieve in a focused fund. The large-cap orientation may be helping such downside containment. 

As a focused fund, this fund should not account for a chunk of your portfolio. A focused approach may sometimes fail in some market conditions and will therefore need periodic review. This fund can complement any of the other value-oriented or contra funds in this category, given its growth tilt. Investments are best done through SIPs.

There are two other funds that we wish to take note of in this Prime Funds set – Mirae Asset Large Cap and Canara Robeco Flexicap. In our June quarter review,  we mentioned that Mirae Asset Large Cap was once again slipping after a recovery in the March quarter. But the fund now appears to have stabilised itself and steadily gained ground over benchmark since the end of July 23. While its high weight to HDFC Bank, due to the HDFC-HDFC Bank merger may continue to weigh a bit, the improvement in the IT sector, where it holds an overweight position, may be cementing its recovery.

Canara Robeco Flexicap, on the other hand appeared to be recovering well up to June 2023 but has once again marginally slipped below benchmark returns (rolling 1-year basis). It is worth noting that our comparison in this category is with the Nifty 500. With the fund holding higher large-cap stocks than most peers. When compared with the Nifty 100 index, it is just about keeping pace. We will keep watch over this growth-biased fund.

Equity – Aggressive (Active)

We started rating Franklin funds (after we stopped coverage for over 2 years) from July 2022. When we stopped coverage of Franklin funds, we took a call on their equity funds primarily based on performance. However, we have still kept an eye on the schemes’ performances. 

There has been a marked improvement in some of the equity schemes from the AMC since we started rating them again. While we stand by our stance on the extremely poor way in which the AMC dealt with its debt fund crisis, we have kept an open mind when it comes to performance of equity. Do note that issues of liquidity do not arise in most equity funds, and the AMC has also weathered the confidence crisis in its equity funds.

With this background (for those who know the history of the events in the AMC), we are adding Franklin India Opportunities fund to our Prime list. This go-anywhere fund (classified as thematic under SEBI category) started seeing underperformance since December 2021 and the same started widening as more value-oriented funds did a better job in the market. 

However, since April-May 2022, the fund has made several changes to its portfolio – be it going significantly overweight on capital goods and underweight on financials or reducing IT over 2022 and gradually increasing it now. These changes appear to have held the fund in good stead and aided returns. Its rolling 1-year outperformance over the Nifty 500 TRI is now about 13 percentage points. While the fund’s market cap orientation is similar to a multicap fund, its significant outperformance places it closer to midcap funds in terms of return profile. The fund can therefore be a substitute for those not wanting to directly handle the volatility of midcaps.

Do note that this is still a thematic fund and any wrong sector calls can impact performance significantly. Ensure that this fund is not the core of your portfolio. In terms of market cap this fund is a lot more aggressive than other ‘opportunities fund’, in Prime Funds, from ICICI Pru. While there is very low overlap between the two, we do not recommend holding both given the high risk profile of both the funds. We may also decide to remove this fund from our recommendation if the market turns too volatile.

In this Prime Funds set, we are removing PGIM India Midcap Opportunities. The fund’s portfolio remains a high quality one but unfortunately it becomes necessary for mid and smallcap funds to capture a strong rally well. In this regard, the fund’s portfolio lagged peers significantly. Close to a third of the stocks in its portfolio have underperformed the Nifty Midcap 150 TRI. And where there was outperformance, it appears that the fund booked profits a bit prematurely, not capturing the rally well.

For example, in stocks such as Gokaldas Exports and Stove Kraft, it exited the stocks in early 2023 and missed out on the rally in the next 6 months. On the other hand, in stocks such as Schaeffler India and Clean Science and Technologies it has seen underperformance after it accumulated. It did get the right calls in stocks such as Dixon Technologies.

While this does not mean that the fund’s portfolio lacks quality, what is concerning is the high margin of underperformance. Such margin is typically never easy for funds to close in and outperform. Hence, we are concerned about the opportunity loss in such funds. We will watch performance and are moving the fund to a hold. You can continue to hold investments already made, but avoid fresh investments/SIPs and you can stop existing SIPs running as well.

Do note that the mid-cap category as a whole has been struggling to beat the Midcap 150 index. This could be because of the broad based rally in the segment, even as funds stick to select stocks.  So, at this juncture, we would prefer a midcap index fund for continuing any SIPs you earlier had in PGIM Midcap Opportunities. Lump sum investments are not recommended, even in the index fund, at this point.

As mentioned in our earlier quarterly review, we have been watching the performance of PGIM Flexicap. While underperformance is not stark, we are more keenly watching whether the new CIO Vinay Paharia is able to cement the fund’s performance. We will alert you if there is any deterioration. Investments can be continued for now.

Hybrid funds

These funds have come more into play following the change in taxation of debt funds in April this year. Multi-asset funds especially have markedly shifted into using derivatives to retain favourable taxation. Given this pervasive use of derivatives across the hybrid categories except aggressive and conservative hybrid, it is essential to look at relative equity risk among funds even within a category.

We have earlier added to the Hybrid - Low-Risk set for those looking to replace part of their debt portfolio with these funds. In this quarter, we are adding to the Hybrid - Moderate risk set.

Hybrid Equity – Moderate Risk

In this Prime Funds set, we are adding HDFC Balanced Advantage. This fund, though being in the balanced advantage category, does not use derivatives to hedge equity risk. This makes HDFC Balanced Advantage more like an aggressive hybrid fund, blending 65-70% equity with debt. This, along with the higher volatility and lesser ability to contain downsides than the balanced advantage category, is the reason the fund is classified under the Moderate Risk Prime Funds bucket.

HDFC Balanced Advantage has seen returns pick up strongly over the past several quarters; this improvement has pushed returns above the average for the aggressive hybrid category. Performance is also better than HDFC Hybrid Equity, the fund house’s actual aggressive hybrid fund. Its consistency in beating the Nifty 50 Hybrid Composite Debt 65-35 index in the longer-term 3 year periods has therefore steadily improved over the past year, and is now at levels similar to some of the top aggressive hybrid funds.

The fund can be used as a lower-risk way to invest in equity for timeframes of at least 3 years or more. It is not a substitute for debt funds, nor does it sport the same risk profile as balanced advantage peers (it has a higher risk profile).

Debt funds

Debt funds have emerged from the low-return phase they had been in with returns and yields climbing across the board. The Reserve Bank has held rates unchanged since February, after a series of rapid rate hikes and domestic inflation cooling off. However, the rate cut cycle has not kicked off yet, and the steady rate scenario may persist for a while, given the US Fed’s hawkish stance and spiking US bond yields.

There may be tactical opportunities to play in debt funds (which we have issued multiple times over the past year😊). But in your debt portfolio, it is still best to continue to remain invested in funds you hold, stick to your timeframe when adding funds for fresh investments, and if you have a long-term timeframe, hold funds across maturities (pick from Short Term, Medium Term, and Long Term Prime Funds buckets) to manage any rate cycle.

In this review, the changes we have made to Prime Funds are below.

Debt – Very short term: 3 months to 1.5 years

In this Prime Funds set, we are adding HDFC Low Duration. This fund takes some credit risk of about 7-8% of its portfolio to generate portfolio yields and returns that are higher than other very short-maturity funds. HDFC Low Duration has delivered above-average returns compared to very short-maturity funds, and is consistent in beating the category as well. It can, however, be slightly more volatile. The fund is suitable for timeframes of 3 months and longer and can be held alongside other very short maturity funds that take no credit risk.

We are removing Nippon India Money Market. The fund is a quality performer and has been consistent in delivering above-average returns. We are removing it in order to include funds with higher yields; the fund’s current YTM, compared to the other Prime Funds is on the lower side. These funds are meant for very short-term timeframes – and therefore, for fresh investments, if a better alternative presents itself, going for these would be a smarter move. Please note that we continue to have a Buy call on Nippon India Money Market in general – it is in Prime Funds that we want to specifically include higher-yielding opportunities. If you have invested in the Nippon fund, please continue to stay invested and do not redeem. The fund has had strong yields earlier, when you may have invested, and has still delivered above-average returns.

Debt – Short term: 1.5 years to 3 years

In this Prime Funds set, we are adding ICICI Banking & PSU Debt. We are adding this fund now to capitalise on the potential rally that a rate cut cycle later down the line can bring in, in addition to the existing healthy accrual yields. The fund has also deftly managed its portfolio to snap up different opportunities in floating rate bonds, different maturities, and instruments. The fund is suitable for a 2-3 year timeframe, and is best invested along with a pure short duration fund.

We are removing Axis Short Term from the list. The margin of outperformance in returns between this fund and the category average has been gradually shrinking over the past couple of quarters. While it is still outperforming and portfolio yields are above average, the other funds in the Prime Funds list have shown better performance and yield potential. Please note that we continue to have a Buy call on it; as explained above, we have removed it from Prime Funds in order to include better opportunities and keep the list concise. Continue to hold existing investments already made in Axis Short Term and do not redeem. You can also continue your SIPs in the fund.

Debt – Medium term: 3 to 5 years

In this Prime Funds set, we are removing Kotak Corporate Bond. The margin of outperformance of the fund with the corporate bond and medium duration categories has been shrinking over the past few months. The fund’s current YTM also holds just about the same level as the category average. The Prime Funds list already features the top few corporate bond funds and the Kotak fund’s recent performance does not match up to these. This apart, these other funds in this Prime Funds set all sport different portfolio maturities spanning both short and medium terms. This offers a good variety in choices even without the Kotak fund.

Hold all existing investments made in this fund, and do not redeem. Fresh investments can be made in other funds in this set and SIPs, if any, can also be diverted to fresh funds.

Debt – Long term: Above 5 years

In this Prime Funds set, we are removing Edelweiss Banking & PSU Debt. We had added this fund as a tactical play in the September 2022 quarter review, and to add diversity to funds in this set. The factors working in the fund’s favour were its long maturity and roll-down strategy that can offer both capital appreciation opportunities as the rate cycle turns and accrual through its other bond holdings. The fund’s performance, especially given the period earlier when yields briefly dropped, has not been quite up to the mark of other funds with a similar strategy and long maturity funds. While the fund does offer differentiation in long term portfolios, its current bout of underperformance gives us pause.

Continue to hold existing investments made in the fund and keep a watch on performance. Should interest rates eventually start to fall, the fund can see higher returns and you can use this opportunity to exit on good gains. Stop SIPs in the fund and divert it instead to the gilt/constant maturity funds in this set or from the Debt – Short Term set.

Prime ETFs

Prime ETFs is our list of recommended ETFs in equity, debt, and gold. We look at multiple factors to draw up this list, ranging from short-term and long-term tracking error, expense ratio, trading volumes and usefulness of the index in a portfolio. In this review, we have made only a few changes.

Strategy & Thematic

In this Prime ETFs set, we have made two additions and removed one ETF. The first addition is Nippon India ETF Nifty India Consumption. This ETF tracks the Nifty Consumption index, which comprises 30 stocks along the consumption theme. The weight of individual stocks is capped at 10%. The consumption theme is one that is taking off now with higher-end consumption seeing a firm pick-up and the subdued rural consumption starting to recover. Overall growth in the economy also feeds into the consumption theme. The theme also covers a vast variety of sectors, ranging from FMCG, entertainment, fashion to auto or financial services. As some of these sectors in the theme are  high-growth sectors while a few others are more defensive,  this theme can deliver upside besides containing falls in a down market.

The second addition is Nippon India ETF Nifty Auto. This ETF replaces ICICI Prudential Nifty Auto ETF in this Prime Funds set, which we have now removed. When we had added the ICICI Pru Auto ETF earlier in March, it was a relatively new ETF. Traded volumes were low, but still better than other ETFs tracking the Nifty Auto index and tracking error was well in check. However, volumes for the Nippon India ETF have since surged; the average daily traded value for this ETF for the past 3 months is Rs 1.16 crore compared to the ICICI ETF’s Rs 30 lakh average. While tracking errors for both ETFs are low, we prefer ETFs with higher trading volumes.

Continue to hold all investments made in the ICICI Pru Auto ETF. You can still make additional investments in this ETF if you wish to avoid increasing the number of ETFs you hold; tracking error is still low. Otherwise, use the Nippon India ETF.

As always, please note that thematic funds and ETFs are suitable only for very high-risk investors and cannot form part of your main portfolio. Keep exposure to themes limited to 10-15% of your portfolio.

Check our past quarterly reviews made in 2023 here:

Changes to Prime Funds and ETFs for the quarter ending June 2023

Changes to Prime Funds and ETFs for the quarter ending March 2023

Changes to Prime Funds and ETFs for the quarter ending December 2022

Disclosures & Disclaimers

More like this

16 thoughts on “Quarterly review – changes to Prime Funds and Prime ETFs”

  1. Should I need to mindful about number of funds holding?

    Following Prime funds recommendations, I started investing in Mirae Asset Emerging Bluechip(G) (large and mid-cap) and PGIM India Midcap Opp Fund(G) (mid-cap) but now both the fund have become “hold”. In my portfolio, I don’t have any other fund targetting mid-cap sector.

    If I add SIP in new mid-cap fund (from Prime fund recommendations), I will be overshooting optimum number of funds in my portfolio as per your Portfolio review tool.

    My questions:
    1. Should I sell one of above two funds before starting SIP in new mid-cap fund?
    2. Should I need to worry about number of funds holding? I am also thinking that if I don’t control this, number of funds will increase over the time – bit confused here between “hold” call vs “number of funds” vs “no mid-cap fund in my portfolio”

    1. Ideally, yes, you need to be mindful. However, it’s fine to temporarily have a higher number of funds.

      You can increase SIP in existing aggressive funds if you hold already – since Mirae is a large-and-mid while PGIM is pure midcap, redirecting SIP to any mid-cap oriented fund will suffice. You do not need to necessarily add another fund. You can add if you don’t have aggressive funds. In this case, you can switch the PGIM/Mirae investment to the new fund even if the call is ‘hold’ in order to keep fund list short (you can wait until the 12-month period is crossed, for tax efficiency).

      Else, you can simply hold the higher number of funds and consolidate later – the fund performance can improve and you can then restart fresh investments in it. Your portfolio size may also grow by then which would accommodate a higher number of funds. – thanks, Bhavana

  2. Naga Chokkanathan

    Thanks a lot for this detailed article. Love it!

    No change in Passive recommendations? Or those changes (if any) are covered elsewhere?

    1. No change in the Passive fund recommendations. If there are, it will always be covered in these quarterly review updates, since it forms part of Prime Funds. – thanks, Bhavana

  3. in the current MF review, I see Edelweiss recently listed IPO fund is now a Sell. the fund has outperformed bse 500 for all tenures with a decent margin too – 3m,6m, 1,3,5 yrs too (https://www.valueresearchonline.com/funds/35234/edelweiss-recently-listed-ipo-fund-direct-plan/#performance). the fund does hold volatile stocks (risk parametrs https://www.valueresearchonline.com/funds/35234/edelweiss-recently-listed-ipo-fund-direct-plan/#risk), but then its the nature of the fund objective. do reconfirm the sell Call on this? Also, do suggest switching from this fund to Franklin Technology or Nippon Consumption is a good idea. thank you.

    1. The Edelweiss fund is almost entirely mid and small cap. So it is not surprising that recent returns are strong. But in terms of consistency – compared to both the Nifty 500 and other mid-and-smallcap heavy funds, the Edelweiss fund does not fare well. It’s also extremely volatile. Market sentiment is also a big factor in performance of IPOs and any adverse sentiment can wipe out gains. Unless you’re very keen on IPOs and want to skip the problem of getting allotment in IPOs & spreading risk of IPO, there’s no reason to hold the fund. – thanks, Bhavana

      1. Sure, noted. How about switching it to Franklin Technology or Nippon Consumption at current levels?

        1. That depends on your risk appetite and portfolio – whether you have other thematic funds, whether you already have a high mid/smallcap allocation which would increase your portfolio risk. Switching between the Edelweiss fund and these thematic funds is not a like-for-like shift. If you have low to no allocation to theme/sector funds, and you want to include them, you can add the two funds. Both are in our recommendation list. – thanks, Bhavana

  4. nikhil.abhyankar

    I use Nippon India Money Market and Axis liquid for my emergency funds. Should I prefer Axis liquid now if I want to top up?

    1. No, you can still invest in Nippon India Money Market if you want to top up. As explained in the review above, the reason we removed it is because there were funds that offered better yields which we wanted to include in Prime Funds instead. The Nippon fund remains a good performer, and we continue to have a Buy on it. – thanks, Bhavana

  5. Hi, amongst the three low duration funds listed in the Debt – Very short term: 3 months to 1.5 years category, how would you order them in terms of risk and suitability for a conservative investor with a holding period of around 6 months.

  6. Hi Bhavana,

    Am holding Canara Robeco flexi cap fund. Shall i switch to HDFC Flexi cap? Please advise.

    Thanks,

    1. Canara Flexicap is fine to continue with; it remains both in Prime Funds and as a Buy. – thanks, Bhavana

  7. Does the Nifty ETF Consumption and Auto Funds have Direct Plans? Or do they have only Regular Plans?

    1. ETFs do not have the concept of direct/regular since they are exchange-traded. So you need to invest in these only through your broker – thanks, Bhavana

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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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