Should you invest in multi-asset allocation funds?

Rather than focus on what a multi-asset alloction does, it is vital for you to know what difference the fund can make to your portfolio allocation and returns. If you don’t, you only end up adding funds to your portfolio without making any meaningful difference.

Whenever the returns of any category tops equity fund returns, investor interest in such a category goes up. It’s the turn of multi-asset allocation funds now. And going by the number of queries we have received, we know many of you want to know whether to invest in this category.  The queries have revolved around the following:

multi-asset allocation funds
  1. Why we have not rated the multi-asset category
  2. Why we do not have a buy/hold/sell call on these funds in our review tool
  3. Whether the new funds from Motilal or Nippon are options to consider

I will quickly respond to these questions first but go on to substantiate the same through the limited performance and portfolio data that we have.

  1. Most of the funds in the multi-asset allocation category do not have a track record. They are either new or shifted to this category (from an entirely different mandate) when SEBI introduced new categories effective June 2018. For example, SBI Magnum MIP Floater became SBI Multi Asset. HDFC Multiple Yield re-categorized itself as HDFC Multi Asset. ICICI Pru Dynamic became ICICI Pru Multi Asset and so on. This was not just a change in name but a change in mandate – in terms of adding gold and changing individual asset allocation limits. Hence, most of them do not even have a rolling 3-year return record for us to test them quantitatively. We do not rate funds without a minimum 3-year record in equity and hybrid categories.
  2. For the same reason, we do not have an opinion on these funds.
  3. We think NFOs, unless unique or showcase tremendous promise, can be avoided or watched for performance. There need be no rush to invest in them. In the case of Nippon or Motilal Oswal, the addition of international equity differentiates them from the rest and yet, there is nothing too unique that cannot be achieved through your own portfolio diversification.

What you may not know about multi-asset allocation funds

#1Taxation status could be equity or debt

Not all multi-asset allocation funds have a minimum 65% equity as mandate. Of the 11 multi asset funds (2 of which are either recent or an NFO), only 5 (Axis, HDFC, ICICI Pru, Tata and UTI) have stated that they will hold a minimum 65% in equity.

The rest, as it should rightfully be, can go far lesser in equity. That essentially means that you may not get equity taxation in some of the multi-asset funds. Many of you are unaware of this and as far as our interactions with you go, most of you are very ‘sensitive’ to taxation and are reluctant to handle a long-term product with equity but with debt-like tax status.

There are also about at least 5 FoFs from Franklin, IDFC, Quantum, Aditya Birla Sun Life, and HSBC which have an option to use gold. Of these, Franklin and Quantum are the ones that steadily use all 3 asset classes. Here again, as FoFs their tax status irrespective of how much equity they hold, will be that of debt.

#2 A multi-asset allocation fund may not necessarily be diversified

In their urge to capture equity returns adequately and maintain equity tax status, some of the multi asset funds do try to hold higher equities. For example, Axis Triple Advantage has its mandate to invest at least 65% in equities and hence always seeks to maintain it. As a result, its average gold holding is lower than say SBI Multi Asset, which has held far lower equity. This means that the fund is not actually changing allocations much based on market cycles and that it then becomes very close to an equity-oriented hybrid fund in terms of performance.

So, if you believed that your fund will dynamically shift between asset classes to contain falls or capture upside, that may not happen. Likewise, other than Franklin and Quantum Fund of Fund, the other fund of funds that have the option of taking exposure to gold, have hardly done so.

#3 Holding a multi-asset fund may hardly diversify your portfolio

A multi asset fund is unlikely to meaningfully diversify your portfolio unless it accounts for a majority of your portfolio. For example, if a multi-asset fund, on an average held 15% to gold, and this fund accounts for say 15% of your portfolio, your gold allocation is 2.25%! You are hardly hedging your portfolio with gold if that was your idea nor will dynamic asset shifts within this fund make any meaningful contribution to your returns.

This is an important point that most of you miss. Rather than focus on what the fund does, it is vital for you to know what difference the fund can make to your portfolio allocation and returns. If you don’t, you only end up adding funds to your portfolio without making any meaningful difference.

Added to this, it is important to know that you don’t achieve style diversification (growth or value, focused or diversified, large or midcap) by holding such hybrid funds.

How multi-asset allocation funds fare

While multi-asset funds do not have much of a track record, we thought we could still show data comparing similar investments that you may have in your portfolio. Please note that it is pointless for us to compare longer periods of returns as most of these funds were not multi-asset funds earlier.

For this purpose, we studied the average holding of equity, debt and gold holding in these funds over the past year. On an average, this came to 58% equity, 27% debt and cash and 15% in gold. We simply tried to replicate this with 3 funds – A Nifty index fund (UTI Nifty Index), gold mutual funds india (we took the ETF from Quantum given its longer record than the FoF and lower cost) and a banking & PSU debt (Axis) from our recommended list.

We took the rolling 1-year return since June 2018 to date. We did not want to compare returns before June 2018, when multi-asset allocation funds had vastly different attributes.

You will see a steady outperformance of the asset allocated portfolio compared with the average returns of multi-asset funds. Of course, there are 2 limitations to this analysis: data points are insufficient and second with newer multi-asset funds having international mandate, they might behave differently.

We also looked at 3-year rolling returns for at least 2 funds that we know had a steady allocation to all 3 assets and ran the multi asset mandate well before the SEBI category came in. The data for that, with our portfolio of 60:25:15 in equity/debt/gold gave the following:

The Franklin fund fell by the wayside as its debt holding has one of the closed debt funds. But even the Axis fund comparison suggests that an asset allocated portfolio would have delivered higher.

Needless to say, rebalancing, if done regularly to your own asset-allocated portfolio, would have yielded even better. To compare the post-tax returns here would not be correct since your asset allocation to debt and gold will not be the same if you simply invested in the multi-asset fund – whether with a 15/20/25 percent allocation. The idea here is to see fund performance alone and, on this count, the performance thus far has not been too inspiring.

This is one primary reason why we feel, based on current data, your own asset allocated portfolio can deliver better.

Where they stand with other hybrid categories

We also compared multi-asset funds with other relevant hybrid categories. Here too, given the limited record that multi-asset allocation funds have, we took the rolling 1-year returns from June 2018 to August 2020. The performance looks like this:

It is noteworthy that a chunk of the above period was volatile and hence any high-equity allocation would have suffered more.

The above data suggests a few things:

  • Both conservative hybrid and equity savings do a good job of containing volatility better, with hybrid conservative also delivering better average returns.
  • Multi-asset allocation funds are not very different from balance advantage/dynamic asset allocation as far as their performance go. Their volatility is similar and so is the average return. The presently higher returns compared to the balanced advantage category are primarily on account of gold.
  • While the above period may be too short to compare them with aggressive hybrid, for the long haul clearly aggressive hybrid scores, the near-term volatility notwithstanding.

What are we trying to say through the above data? You should be clear in your objective of what you want your fund to achieve in your portfolio. For example, if you had a dynamic allocation fund, then there may be little need to add a multi-asset fund, as things stand. Or for that matter, if you had a gold fund, besides separate allocation to debt and equity, not much is achieved by adding 10% or even 20% to a multi-asset fund.

Summary

In summary, if the above article comes across as being too negative about multi-asset funds at this juncture, we have our reasons:

  • One, data thus far suggests that you can do well with your own asset allocation and may not even need any dynamic asset managing fund if you can rebalance. Please read our article on rebalancing here.
  • Two, we see this as a category that AMCs took to, only because SEBI introduced it as a category. And that would mean adding one more scheme to an AMC’s basket. A new category allows garnering more AUM from a business perspective.
  • Three, we have seen funds jump from entirely different categories to multi asset or even close the category after having created a fund. We already gave examples of such changed categories earlier. Another example would be Edelweiss Prudent Advantage fund, a diversified equity fund that became Edelweiss Multi Asset Allocation fund after SEBI’s new categorization. In July 2019, the same fund became Edelweiss Aggressive Hybrid fund.

So what is the takeaway?

  • We are not undermining the importance of asset allocation. But we would like you to question yourself as to whether it is best served with a multi-asset fund or kept simple with good funds from each asset class put together – providing you the flexibility to change one if it is not doing well for you and preventing any concentration to a single fund. You could look at our Prime Funds to build your own asset-allocated portfolios or pick one from our ready-to-use portfolios.
  • We think only few fund houses are serious about providing a hybrid product that is of value to investors rather than being an additional scheme to garner AUM.

We do find some individual funds – like Quantum or SBI promising. We will continue to watch this space and will rate the category once track record is achieved.

Even so, you must ask yourself – ‘what value does this fund add to my portfolio’, rather than be lured by returns or the fanciness of the theme.  

More like this

22 thoughts on “Should you invest in multi-asset allocation funds?”

  1. emailsubcriptions9

    Isn’t ICICI Prudential Multi Asset fund an old one and has performed well with good returns over more than a decade – any particular reason of not having used in your comparisons and analysis and also not mentioning about it?

    1. Hello Sir, We have very muh mentioned about the fund – that ICICI pru Dynamic asset (which was not multi asset then) became multi asset post SEBI’s new category in 2018. Hence it did not have sufficient record as a multi-asset (less than 23 years) when the article was written). We took the ones that were multi asset since their inception for illustrative purpose. ICICI 5-year performance etc will be irrelevant. We have included multi asset in our rating and MF review tool. You an check the fund there. thanks, Vidya

  2. Dear Vidya
    I have been investing in aggressive hybrid funds of HDFC & ICICI for past many years now, and I am really disappointed with their returns, and their downside protection. While I agree with the eye-opening points you have raised about multi-asset funds, would it make sense to shift from these aggressive-hybrid funds to multi-asset funds, so that there is better downside protection (due to gold, reit, etc) ?

    1. You can have a mix of equity, debt and gold as seprate funds instead. More flexibility and option to choose the best in class in each! thanks, Vidya

  3. Thanks for this very important analysis. Can you clarify if the funds considered for rolling returns were direct or regular plans? And in your opinion would that make a difference? I have this question especially after seeing the other piece on expense ratios where there’s 1%-point difference between regular and direct multi asset funds.

    On a side note, I have been curious about all-weather portfolios popularised by the likes of Ray Dalio, which are also multi asset portfolio though with only 30% in equities, 40% long-term gilt, 15% short or medium duration bonds and 15% gold. I tested them using basic tools on VR. Returns were better (about 11% consistently over any duration) and volatility also appeared lower (March 2020 drawdown less than 10%) than multi asset funds. It would be great if you guys can do an analysis of such a portfolio with standard deviation and rolling returns which is hard to do with tools available to amateurs.

    On yet another side note, conservative hybrid funds seem really good option for consistent returns.. why are they not popular? Aggressive hybrids seem very pointless – if I have to wait 5 years or more for returns then I might as well go 80% equity or 100% into a largecap-dominated elss or multicap (old definition).

    1. Data is for direct. No it hardly makes any difference. The illustration we have given is a all-weather index portfolio. quality funds will better that. Hybrid conservative are not only expensive but mask credit risk and this came to light in the late 2018 and 2019 credit risk fallout. thanks, Vidya

  4. This will be avg return and for conservative investors only,if you are thinking of risky buy better returns then defineately equity funds only..i feel next couple of years active fund gonna shine as it can generate alpha better than passive fund but if you are modest risk taker then can eye on low beta passive equity index fund..multi asset return gonna be in line with fd in long run as per me..
    Dont opt any multi asset..always returns are averaged because if gold high equity will be down n when gold falls stocks shine… Strategically can opt for short to medium term on calculative basis..with a caution

  5. If some one wants to allocate a single multi-asset fund to goal, so that he doesnt need more asset classes and rebalancing process nil. Please let us what is the disadvantages of keeping single multi-asset fund for one goal.

    At the same time if we go by Single Nifty index fund + Liquid fund, Is any issue related to too much concentration on single AMC/Fund. Just curious to understand Is it harmful to use single Fund per goal

    1. We have stated the disadvantages – one, concentration in an active fund. Two, this class has so far underperformed an asset allocated portfolio by a good proportion. Three, no style mix to ensure you have some style performing at all times. Four, you are assuming the equity and debt will be managed well by a single fund.
      When you follow an index, where is the question of active management? If there is no active management, there is risk of underperformance. There will be lack of styles but that is ok and that is the conscious call of passive investing. Liquid fund – can have 1-2 to avoid any outlier scenario. I think we have discussed this with you more than a few times 🙂 Vidya

  6. Sunil Hareendran

    I see this in the following light :-
    Covid-19 has thrown up many questions about asset allocation, and as investors we rethink our portfolios will have to weigh up whether exposure to multi assets will protect, or erode, wealth. Current analysis with historical data to be looked into from that perspective as well ?

    1. Sir, The key takeaway is in point 3 and I am reproducing it here:
      Holding a multi-asset fund may hardly diversify your portfolio
      A multi asset fund is unlikely to meaningfully diversify your portfolio unless it accounts for a majority of your portfolio. For example, if a multi-asset fund, on an average held 15% to gold, and this fund accounts for say 15% of your portfolio, your gold allocation is 2.25%! You are hardly hedging your portfolio with gold if that was your idea nor will dynamic asset shifts within this fund make any meaningful contribution to your returns.

      This is an important point that most of you miss. Rather than focus on what the fund does, it is vital for you to know what difference the fund can make to your portfolio allocation and returns. If you don’t, you only end up adding funds to your portfolio without making any meaningful difference.

      Added to this, it is important to know that you don’t achieve style diversification (growth or value, focused or diversified, large or midcap) by holding such hybrid funds.

  7. Hi,

    Excellent article. If one looks at FD beating returns with modest capital gains then only one fund comes to mind i.e Quantum Multi Asset Fund. The fund is truly balanced as exposure is capped at Equity 40%, bond 40% and Gold 20% unlike other Balanced Funds which have equity upto 65% and hence fell more in the recent crash. True its taxed like a debt fund but if held over 3 years and internal rebalancing (being pass through) at very low cost I think this fund cannot be compared to peers and should be viewed stand alone one of a kind for conservative investors/ retirees.
    Thanks

    1. Hello Vidya,
      I am thinking of investing a fair part of my DEBT portfolio in the MO Multi asset fund in a staggered manner. As the back testing of this fund by the fund house suggests it will give more or less steady high single digit returns with less volatility. This fund will invest more in debt compared to the other balanced/ multi asset funds which have 65% or more in Indian equities. Asset allocation between Indian equity and debt will be rule based by MOVI .
      10% in S&P 500 index which is a solid US large cap Index and 10% in Gold ETF is a good combo. Each asset class will do well or poorly in different market cycles. The YTM in debt funds and bank FD rates have dipped sharply, this type of fund may come handy to some extent for part of the debt portion of the portfolio.

      I know it is contrary to your article, but my personal experience is otherwise. People are generally very skeptical when a new product is introduced and write it off quickly with some data points. It happened when Benchmark MF came out with Gold, Nifty and Junior Nifty ETF’s in mid 2000’s. Same was the case when MO Nasdaq 100 ETF was launched around 2012. Every magazine and financial experts in those days wrote it off. I kept investing in all these 4 products. It gave me a good experience all these years. After 15 years people are slowly accepting these as a good products. In fact you are having a webinar about these ETF shortly. Same I feel will be the case will be with MO Multi asset type of products. It is easier to talk about asset re-balancing etc in theory, but in reality it is very difficult and rarely happens. Honestly I find it very difficult. The drop and gain happen quickly and is volatile like the current last 4-5 months. There is always a hesitation to sell one asset class or sometimes not having time to do all the necessary course correction. Asset re-balancing may also have Income Tax implication and we will end up paying unnecessary LTCG or STCG tax which is again leakage of profits earned in other asset class . The other option is topping up money in the asset class which has fallen down, adding capital may or may not be possible at the given time. In these type of MF’s asset allocation will rule based, without human emotion and since MF is pass through vehicle it will have no impact of Income Tax to the individual. Looking at the above I will be more inclined to invest in it.

      1. Hello Sir, When Benchmark came, I too invested in ALL their ETFs 🙂 But it is not the NFO that made me money…it is the investing/averaging through the years 🙂 When NAsdaq 100 came, we were (in our earlier role) among the first to give it when it become a fund of fund (the ETF suffered from terribly low liqudiity) . So the problem is not about the NFO alone. it is about how unique it is and what value it adds to your portfolio. Please ask yourself by holding 15 or 20% of your portfolio in a multi asset fund, what dynamic allocation really happens to your portfolio? (I have given the example in the article) And if you hold 50% isn’t that excessive concentration to an active fund? (it is ok with index) Second, why should we be obsessed with ‘dynamically managing’ and timing, really? We have explained in our rebalancing article (linked in this article too), that all you need to look at is your own portfolio. if a 60:40 has become 70:30, you shift back. And please remember, in reality such rebalancing need will arise only once in 2-5 years, depending on market rallies. Otherwise, there is little need to dynamically manage your portfolio like a fund. SO there really is no tax inefficiency there. These are needs that are ‘created’ when it really is not a need 🙂 The data we shared shows that multi-asset with all that shifting hasn’t yielded desired results. How can back tested data be trusted when you an cange the methodology to suit the outcome? 🙂 Nobody, really nobody is adept at timing the market and that is why it doesn’t pay off for most people 🙂 You stated very good products like BEnchmark ETFs and a great gateway to the high growth Nasdaq but we should also distinuish between those value adds and seeming value adds (call them gimmics) right? 🙂 Having worked with the industry closely, it is not too difficult to know the difference 🙂 Time will tell of course and we have acknowledged that there couol be 1 or 2 promising ones but there is no rush to participate through NFO, in our limited view 🙂 If you want to remove the human bias, there are simple index funds. And remember, only asset allocation is rule based in multi asset. Stock and debt instrument pick is far from rule based.

        As for investing your ‘debt’ portfolio in this fund, I have no doubt this fund will be singificantly higher in its volatility (we have also shown you the Std Dev in our data of simialr funds) and I am not sure it is a substitute for debt at all.
        thanks, Vidya

        1. Hello Vidya,

          Thank you very much for your detailed reply. I do not want to comment any further and prolong it. From my analysis and experience the MO Multi asset fund will do well in the long haul. It will not be block buster fund but it will give decent debt fund plus returns. Other funds can’t say as they will have 50-65% Indian equities and will behave more like the other hybrid funds. Let us revisit this after 3 years!!

          1. Hello Sir, you are free to have your style of investing. I think my point that having 15-20% allocation to a single fund won’t achieve any diversification or asset allocation in a portfolio was not clear. Also, the idea of using debt is to hedge. When a multi-asset has equity and international equity – it cannot be ‘equivalent’ to debt in a portfolio. That was the only point I tried to make. As for performance etc, the fund has to necessarily deliver higher than debt as its overall allocation to equity (domestic plus intl.) is quite high 🙂 To each unto their strategies 🙂 regards, Vidya

  8. Dear Vidya

    Perfect answers to all the possible queries.

    Sharing my personal experience to add just one point. For a long time in my investment journey, (the erstwhile) Balanced funds made the core of my portfolio – till the time I realized I was getting the worst of both worlds. The equity portion of the leading balanced funds was managed worse than the average equity funds – and the debt portion did not even dish out returns matching liquid funds. In the laziness of letting someone else do the re-balancing and asset allocation for you, one tends to get complacent on what actually is going on with the equity or debt portions of the hybrid funds. All the nuances of MF investing including ‘Investing style in Equity’ and ‘Credit/ Duration risk in Debt’ goes completely beyond the investors control or choice.

    Even today I fail to find a single hybrid fund whose Equity portion is managed as well as any of the top 5 Multicap/ LargeCap equity funds – OR whose debt portion is managed as well as the top 5 debt funds across the spectrum.

    I can safely extrapolate my thought process to the multi-asset funds as a good 70-80 % would still be ‘debt+equity’. The balance would be (a) Gold – which just gets it head out of the water once in a few years and then goes back to sleep (b) International equity- well you have much better options to have that exposure through MO Nasdaq-100 or PPFAS.

    Regards
    Raspreet

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  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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