Quarterly review – changes to recommendations in Prime Funds & Prime ETFs

Prime Funds narrows the choice of the thousands of funds out there in the market into a list of 50-60 funds that you can pick from to invest. This quarter we have made some additions to gain from the renewed strength that the equity market is exhibiting, the recession fears in the US notwithstanding. There are some additions in the debt space as well, as yields moved up. We have removed some funds that were bigger laggards and are observing the slip in performance in a few others. If you are new to Prime Funds, we urge you to read the contents in the table below to know how to use them to your advantage. Otherwise, use the Table of Contents below to navigate to the section you are keen on.

Quarterly review – changes to recommendations in Prime Funds & Prime ETFs

About Prime Funds

New to PrimeInvestor? This is what you need to know 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 and you will find a fund that meets 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 MF Review Tool (not our Ratings). If the review specifies ‘buy through direct,’ it means that the expense ratio differential is high under the regular plan for that fund. You will be better off using the direct plan in such cases. You can also check the expense ratio differential using our expense ratio tool.

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.

Equity funds

The equity markets had yet another tepid quarter with intermittent corrections. But the quarter ending September 2022 did manage a decent 6% gain, thanks to a strong comeback in consumer and pharma stocks in September. Besides, the strong rally in capital goods and engineering also helped sector/thematic funds in this space. Sector/theme based Prime Funds from this space therefore gained well. 
The changes we made this quarter are discussed below. We also alert you to some of the poor performers – you need not act on these until we explicitly give a call.

Equity Moderate – Active

Funds in this category had a tough time primarily because of the underperformance of the IT sector. Most large-cap and flexi cap funds have equal or overweight exposure to IT, given that the sector commands a sizeable weight in all large-cap indices, next to the banking & financial sector. Hence, it did not come as a surprise when we saw a few of our funds in this segment underperforming. 

However, we had to take a decision on funds that saw more pronounced underperformance or where the deterioration was visible from previous quarters. Axis Bluechip was one such fund. 

Axis Bluechip’s underperformance can be traced to hits in IT stocks such as Infosys and TCS (although exposure has reduced) or financial stocks such as Bajaj Finance (relief rally in the past 3 months notwithstanding, the stock saw a volatile year on the back of elevated valuations) and HDFC Bank. The fund’s focused portfolio approach impacted performance. 

While we took note of this in our last quarter review, we find the margin of underperformance to be increasingly high. The proportion of its outperformance over the index on a rolling 1-year return basis also deteriorated to 45%. While funds such as Mirae Asset Largecap are also struggling, their outperformance still stood at a decent 61%. 

We are adopting a hold strategy on Axis Bluechip. You can stop any fresh SIP investments in the fund and hold existing investments for now. 

We have instead added ICICI Pru Value Discovery. This is not an early pick, since value as a strategy has been gaining ground post the 2020 market correction and the fund has been delivering well for a while now. Nevertheless, we do think there is room for value to deliver currently as the undervalued and contrarian sectors such as healthcare, energy, and, importantly, pockets of undervalued financial stocks are best played through such funds. The fund can also provide some hedge in this volatile market. 

ICICI Pru Value Discovery fund has delivered positive returns in the past 1 year when large-cap indices have struggled to remain in the green. While we have 2 other contra funds in our list, note these points: one, the contra funds in our list have some exposure to growth stocks and are therefore not pure value. Two, ICICI Pru Value Discovery has only about a third (portfolio weight) overlap with each of those funds, thus complementing them. 

That said, it is better not to go overboard on value with your portfolio as value is known to go through long periods of underperformance. ICICI Pru Value Discovery for instance has just surpassed its benchmark over a 5-year period, having underperformed for over 2 years. 

Overall, in the Equity Moderate category, we find an increasing need for you to hold market-cap weighted index funds to ensure that your portfolio stays with the market. Select large and flexicap funds do continue to beat indices – but that they are unable to do so on a steady state points to the fact that index investing is gaining ground. Having some part of your large cap/moderate risk portfolio in large-cap index funds may become necessary to keep returns in tune with the market. You will find passive index funds in Prime Funds, which we have classified separately.

Equity Aggressive – Active

We added Nippon India Multicap in this category. This multi-cap fund can help you take adequate exposure to mid and small-cap segments if you do not want the direct risks from the latter segments. Active sector calls and playing a mix of growth and value has ensured that this fund has steadily climbed the ranks in performance. Earlier called Reliance Equity Opportunities, this fund has picked up in recent times, playing both the secular consumer spending story as well as the more cyclical story from capex spending in the country. The fund has comfortably managed to beat its peers and benchmark in the past few quarters and also competes well with funds from the large and midcap category. 

Please note that the fund’s rating stands at ‘2’. This low rating is because the fund has limited record as a multi-cap fund (a new category under SEBI) and was in a different category with more bias for large caps earlier. On the other hand, some of its peers were already holding higher exposure of mid and small-cap stocks before the new category came into being and therefore sported higher returns. In short, the rating is more backward looking and you may ignore it until a track record is built. Since this fund’s performance pick up is relatively recent, ensure that it is not core of your portfolio, if you decide to hold it. 

We have removed Invesco India Midcap. You can continue to hold the fund and just stop fresh investments and SIPs for now. While we always found the fund’s portfolio to be a sound one, the market moves in 2022 has seen many midcap funds struggling to beat the index. The fund’s outperformance on a rolling 1-year return basis dipped from 62% as of June 2022 to 55% as of September 2022. After our experience with DSP Midcap, we do think that midcap funds that lose out too long can find the comeback quite hard as peers take over quickly. 

Hence, while the underperformance of Invesco India Midcap is not bad at all, we are being a bit cautious on this front and also since there are sufficient mid and small caps available in Prime Funds to play the risky segment. We will watch performance and if there is a bounce back, we may reinstate it as it is a fund that contains downsides well. 

Overall, only a handful of midcap funds managed to beat their benchmarks in recent months, even as small caps did a far better job. This can be partly attributed to more selling pressure in the midcap space (possible FPI pull out) than it the small-cap space over the last 2 quarters. Hence, you will need to be patient and continue your SIPs in this segment. 

In the Equity Aggressive – Active category, we would like to highlight the following observations. No action is needed on these points:

  • We have moved PGIM Flexicap from the Equity Moderate category to Equity Aggressive, in line with the higher mid-cap exposure it sports. Make sure you do not have high weight to this fund if you are a low to moderate risk investor. The fund continues to sport good performance.
  • We are taking note of the sharp underperformance of UTI Flexicap in the past 3 months as the result of the rout in IT stocks. It holds at least 4 percentage points more in IT sector, compared with Flexicap peers. As a result, the hit was harder. Besides, exposure to stocks as Bajaj Finance and HDFC Bank had pulled down performance earlier this year. We are watching the fund’s performance and are not too concerned about its ability to bounce back, given the sound portfolio. The fund still scores over peers on a rolling 1-year and 3-year metrics. We will alert you if our thesis does not hold. You can continue investments in the fund. 
  • We are taking note of some underperformance in the seemingly invincible Mirae Asset Emerging Bluechip. This, too, can be attributed to the mid-cap rout (more than small cap), perhaps triggered by profit booking. In general, many funds in this category have struggled to beat the benchmark Nifty LargeMid 250. This is one of the reasons why we have introduced an index fund mirroring this index. We will watch for performance closely. No action is needed at present.

Equity Aggressive – Passive

In this category, we have added Edelweiss Nifty Large Midcap 250 index fund. This fund tracks the Nifty Large Midcap 250 index representing both the large-cap and the mid-cap universe. The Large Midcap 250 index is a good middle-ground for those looking to add a higher-returning option in their portfolios without going for a pure midcap fund. The index scores well in performance against the more aggressive Nifty Multicap 50:25:25 index along with lower volatility.

However, against the other broad-market index – the Nifty 500 – the LargeMidcap 250 index is similar in performance. Motilal Oswal Nifty 500 Index Fund also features in this Prime Funds category. Therefore, avoid holding both these index funds in the same portfolio.

The Edelweiss Nifty LargeMidcap 250 is a new fund, having been launched only in December 2021. We have a very limited history to go by to judge tracking error. However, it also is the only fund that tracks the Nifty Large Midcap 250 index, so we have gone with it. Bear in mind that the fund might see higher tracking error, if we go by the tracking error of the other mid-cap and Nifty 500 index funds.

Equity – Tax Saver

In this review, we have added Parag Parikh Tax Saver. This fund has just crossed the 3-year minimum cut-off we maintain in order to rate equity funds. While its track record is brief, the fund has shown the capacity to deliver above-average returns. The fund beats the Nifty 500 index about 75% of the time on a rolling 1-year return basis over the past 4-year period. This is far better than even older ELSS funds. 3-year returns have so far held above the Nifty 500 index. This apart, the fund is adept at containing downsides and sports below-average volatility.

This comes from its strategy of maintaining higher cash positions when required. The fund has gone even up to 20% in cash in earlier months, when markets were uncertain or overheated. The fund follows a stock-specific value-based approach and maintains a compact portfolio with top stocks having heavier weights. In its strategy, the fund differs from most other ELSS funds which tend to be far more aggressive.

However, Parag Parikh Tax Saver does have a marked portfolio overlap with Parag Parikh Flexicap. If you hold the latter fund in your portfolio, it would be better to go with the other Prime Funds from the Tax Saver category.

Hybrid funds

We have made no changes in our hybrid fund recommendations. However, we would like to make some observations about aggressive hybrid funds, which we include in the Hybrid – Moderate Prime Funds category.

Hybrid – Moderate

This category comprises funds from the aggressive hybrid category, and those balanced advantage funds that are not too conservative in their hedging strategies. Both categories have seen quite a few new funds and these funds have not really seen a low-returning market phase or prolonged correction which older funds have. While our rating criteria makes some provisions for funds with shorter track records, the lack of a low-returning period has helped some of the newer funds score well on ratings.

Mirae Asset Hybrid, part of Prime Funds, has therefore seen its ratings slip now to 3.5. The fund’s 1-year returns against the Nifty 50’s hybrid index had also slipped, which has had an impact on its rating. However, in recent times, the fund’s returns have moved back higher. It has delivered against the category average as well. It remains a lower-volatile performer with above-average risk adjusted returns. We are watching this fund’s performance and will make any changes if necessary. The other funds in this Prime Funds category continue to record strong performance.

Debt funds

Debt funds have seen portfolio yields finally move higher across the board over the past few months, reflecting the higher interest rate scenario. Longer-maturity funds remain low-returning as rising rates impact bond prices. However, we have been highlighting different pockets of attractive yields, from target maturity funds to g-secs to t-bills. We’ll continue to do so, which you can use to supplement your debt portfolio.

A lot of factors are set to influence where rates go from here. We recently discussed these in our report on where to park short-term money. If you have a short-term timeframe, you can use a mix of debt funds and other options as mentioned above. For longer-term portfolios, the best way to navigate the current rate scenario is to use a mix of short-term and medium/long-term funds.

Debt – very short term

In this category, we have added Kotak Low Duration. This was a fund that was always a good performer but came with very high credit risks. However, the fund has gradually pared its exposure to low-rated papers and holding in below AA+ papers is about 6%. The fund has still managed to keep its returns and portfolio yields above average. The fund deftly juggles allocations between CPs, CDs, treasury bills and short-term bonds. It also takes tactical calls on g-secs to make returns off bond price rallies. For this reason, the fund is more volatile than peers in very short term periods such as 1 week. The fund can be used by any investor to invest short-term money, or as part of an emergency portfolio, or to run SWPs.

Debt – Short term

In this review, we have removed IDFC Banking & PSU Debt. At this point, we’d prefer to go with short duration funds with a wider investment mandate, which have managed to increase portfolio yields. The IDFC fund’s portfolio yields have been below average for a few quarters now, though average returns are still better than the category.

For investments already made, continue to hold for the intended timeframe. For any SIPs, you can stop the SIP and restart the same in funds in the Debt - Very Short Term category or from the Debt – Short Term category depending on your timeframe.

Debt – Long term

In the long-term category, the options available have typically been limited. This earlier explanation on the different categories that fit a long-term timeframe will explain more. This quarter, we have added Edelweiss Banking & PSU Debt fund to introduce diversity in this category. This fund invests in debt issued by banks and PSUs, besides SDLs and g-secs. The fund has a long maturity of close to 7 years currently. 

The fund, however, follows a roll-down strategy which means that maturity will gradually reduce over the years. This works well for longer-term periods, as it can see returns shine when the rate cycle eventually turns lower down the line. Its current portfolio yields are well above both peer average and the corporate bond category. The fund has steadily delivered returns above its peers and short-maturity funds as well.

The fund suits any investor with a horizon of at least 5 years. You can hold this fund along with other short-term funds and corporate bond funds for a diversified debt portfolio.

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.

Moderate risk

In this category, we have added SBI S&P BSE Sensex ETF and removed the HDFC S&P BSE Sensex ETF. The SBI fund has improved on its tracking error and is now better on this count than the HDFC ETF. Its trading volumes have also improved and are above that of HDFC. You can hold all investments made in the HDFC Sensex ETF; if you do not wish to increase the number of ETFs you hold and the marginally higher tracking error does not concern you, you can continue with the HDFC ETF for fresh investments as well. Else, make any fresh investments in the SBI ETF.

Themes & strategies

In this Prime ETF category, we have added Mirae Asset S&P 500 Top 50 ETF. This ETF tracks the S&P 500 Top 50 index, an international index that houses the top 50 stocks from the S&P 500 index by free-float market capitalisation. The S&P 500 itself comprises the 500 largest stocks in the US by market capitalisation.

This index is a good replacement for the S&P 500 index as it contains a good part of the S&P 500’s weight. In terms of performance, the two indices are closely correlated and share similar trends. The index is less volatile than the other US bellwether Nasdaq 100. It offers a different option to invest in the US markets; with the RBI restrictions on funds investing internationally, most of the available options track only the Nasdaq 100 index. In our view, for investing in US markets, passive is a better choice than active funds.

The Mirae S&P Top 50 ETF has seen reasonable volumes, though tracking error has been high during the months when the RBI restrictions were in place. The ETF can form part of 5+ year portfolios. Cap international exposure to 10-15% of your portfolio.

You can see the updated Prime Funds list here.

You can see the updated Prime ETFs list here.

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19 thoughts on “Quarterly review – changes to recommendations in Prime Funds & Prime ETFs”

  1. I had probably missed this but when did the Axis Banking and PSU fund get removed? IDFC is a tad worse performer than the Axis one in this category? Again, I will be in short term and it is the gabbar tax for a 3% return, making it as good as zero return….I had subscribed to Prime investor and I religiously follow the prime fund changes but these changes in debt funds and their non-performance is just killing me

    1. It remains a hold. We wrote about it in January (after Dec 21 review). Here it is: https://www.primeinvestor.in/quarterly-review-changes-to-prime-funds/ We have written earlier that one should look beyond MFs in these testing times https://www.primeinvestor.in/all-your-debt-fund-doubts-answered/ If you have susbcribed to Primeinvestor then Prime deposits and Prime bonds (for growth subscribers) are the other options. The last 2 years, debt has tested everyone’s patience – whether deposit holders or MF holders. I am afraid that it is what it is.
      However, yields have improved now and stands at an average 6.7% for short duration and banking & PSU. And SDLs and G Sec options we keep coming up with offer decent yields for long-term. Treasury bills on RBI Direct retail platform too is better than debt funds for the present.
      Vidya

  2. Hi Team PI….

    With moderate risk capability, I am planning to create a 60% equity & 40% debt portfolio for period of 7 years using your listed Prime Funds.

    My question pertains to debt part of the portfolio. I plan to use 3 funds in debt portfolio. Considering my moderate risk capabilities, what should be the Average maturity of my debt portfolio?

    Regards

    Jatin

    1. Spread 40% between very short and short and rest to medium alone or medium and long term debt funds in our list. Keep max of 20% in long term if you choose long term. Portfolio maturity will average around 5-6 max. Vidya

  3. Hello Team Primeinvestor,
    Is not the FOF of mirae asset s&p 500 top 50 etf a better alternative as you can do systematic investing and also the expense ratio of FOF (direct mode) is much lower than the ETF.

    1. You can certainly do for convenience. Nothing wrong. Expense ratio of ETF is inbuilt in FoF NAV. So it is not necessarily lower. The comparison is difficult as one needs to consider demat as well as brokerage to do the cost comparison. Vidya

  4. Hello Team Primeinvestor,
    During your last quartely review you had removed ICICI Prudential Commodities fund from prime funds and it was said that we can hold the existing investment in the fund and now in the latest MF review tool in prime recommendation section you are just not having any opinion whether to buy, hold or sell for this fund. It is very confusing, please clarify.

    1. We issued a book profits call (not a sell call) when we took it out from Prime Funds and hence made it no opinion like all other sector funds. We will however update it to make it clear. If you hold after taking away profits, it is fine.

  5. Hi Thanks for the update.A few queries
    1.Is Parag Parikh Tax Saver allowed to hold U.S.equity,What is its current exposure to U.S.equty?
    2.Is there any SnP index fund accepting fresh investment?
    3.Debt funds like money market yields have gone up but returns are yet to kick in.When do you see the returns coming?

    1. 1. No
      2. Mirae S&P 500 top 50
      3. Hopefully in a year’s time, in line with their maturity if rates don’t continue to go up.

  6. Thanks for the Detailed review & update here. It will be better if the target persona and the mode of investment for which changes needed are also attached.

    Since you are doing quarterly review and making changes in the Funds, If we do the stop and start based on this every quarter, wont we end up with lot of funds ? Since some of the timelines are longer(like 7 to 10 years), is this relevant and required?

    1. We give the suitability of each fund, i.e., the kind of investor for whom the fund will fit. Funds can be invested through SIPs or lumpsums based on your choice. Where we feel a particular method of investment will work better, we explicitly state that. You do not have to hold every fund we have in the list, nor do you need to invest in every fund we add – so you won’t be holding to many funds, and we do not make a lot of changes in our fund recommendations. Most have been in place from the start of our recommendations. In a lot of cases, we give holds and not exits, so there is not a lot of churn. Therefore, please pick based on your portfolio timeframe, risk, and fund strategies. Periodic review is necessary even if you have a long term timeframe as prolonged underperformance will mean sub-par returns for you despite holding for years. – thanks, Bhavana

  7. Thank you for the periodic relook at the Prime Funds list.

    On debt MFs, a good few of the schemes have a passive roll down strategy – case in point IDFC Banking & PSU Debt. I gather that this scheme will roll towards maturity by March 2023 and hence the Fund Manager may move reallocate towards the 3 year segment from Jan 2023 onwards. Hence, the challenge remains to be updated on each of these debt MFs strategy whenever a record is being made.

  8. Chaitanya Rayabharam

    Hi Team,

    Had one question about the reason that, when there is a hold suggestion, it is suggested to leave the corpus accumulated as it is and not move it to a new fund, especially since the recommendation is that new SIP’s be started in another fund. If the direction is that new fund will do better than old fund, isnt it prudent to move the current accumulated corpus into the new fund as well.

    Leaving so many funds without shifting might lead to portfolio clutter at some point of time.

    Can you please explain your thoughts on this.

    Regards
    Chaitanya

    1. Your observation is right. It is a question of paying STCG on such funds. When performance is terrible we give an exit. When it is middling, we try not to cause tax outflow. You can do so if you indeed have too many funds once they cross a year so that your taxation is less. Vidya

    2. It’s not necessary to immediately shift existing investments – the ‘hold’ fund could well recover as we have seen in many cases. The shift of new investments in the new fund is to prevent opportunity loss and to minimize the impact of underperformance. This apart, you would be paying taxes each time you move from one fund to another. So unless necessary, we don’t give an immediate exit call. We watch performance and then change the call to exit if there is further deterioration. ‘Hold’ funds can also be used when rebalancing a portfolio. – thanks, Bhavana

    3. It’s not necessary to immediately shift existing investments – the ‘hold’ fund could well recover as we have seen in many cases. The shift of new investments in the new fund is to prevent opportunity loss and to minimize the impact of underperformance. This apart, you would be paying taxes each time you move from one fund to another. So unless necessary, we don’t give an immediate exit call. We watch performance and then change the call to exit if there is further deterioration. ‘Hold’ funds can also be used when rebalancing a portfolio. – thanks, Bhavana

      1. if we need to shift, would you recommend a one time shift or do you suggest STP there if the corpus is considerable?

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

The declaration of the RA is as follows:

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

5. Consideration and mode of payment

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

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

6. Risk factors

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

7. Conflict of interest

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

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

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

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

Disclosures with respect to Research and Recommendations Services:

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

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

8. Termination of service and refund of fees:

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

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

9. Grievance redressal and dispute resolution:

Any grievance related to:

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

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

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

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

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

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

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

10. Additional clauses:

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

Details of the RA's associates: No associates.

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

Indemnification: The client:

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

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

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

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

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

11. Mandatory notice:

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

12. Optional Centralised Fee Collection Mechanism:

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

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