Investor Charter in respect of Investment Adviser (IA)

Investor Charter – Annexure A

Investor Charter in respect of Manek Financial Advisors Pvt. Ltd.(MFAPL)

A. Vision and Mission Statements for investors

  • Vision – Invest with knowledge & safety.
  • Mission – Every investor should be able to invest in right investment products based on their needs, manage and monitor them to meet their goals, access reports and enjoy financial wellness.

B. Details of business transacted by the Investment Adviser with respect to the investors

  • To enter into an agreement with the client providing all details including fee details, aspects of Conflict of interest disclosure and maintaining confidentiality of information.
  • To do a proper and unbiased risk – profiling and suitability assessment of the client.
  • To conduct audit annually.
  • To disclose the status of complaints on its website.
  • To disclose the name, proprietor name, type of registration, registration number, validity, complete address with telephone numbers and associated SEBI Office details (i.e. Head office/ regional/ local Office) on its website.
  • To employ only qualified and certified employees.
  • To deal with clients only from official number
  • To maintain records of interactions,  with  all  clients  including  prospective  clients  (prior  to onboarding), where any conversation related to advice has taken place.
  • To ensure that all advertisements are in adherence to the provisions of the Advertisement Code for Investment Advisers
  • Not to discriminate  in  terms  of  services provided, among  clients  opting  for  same/similar products/services offered by investment adviser.

C. Details of services provided to investors (No Indicative Timelines)

  • Onboarding of Clients
    – Sharing of agreement copy
    – Completing KYC of clients
  • Disclosure to Clients
    – To provide  full  disclosure  about  its  business,  affiliations,  compensation  in  the agreement.
    – To not access client’s accounts or holdings for offering advice.
    – To disclose the risk profile to the client.
    – To disclose any conflict of interest of the investment advisory activities with any other activities of the investment adviser.
    – To disclose the extent of use of Artificial Intelligence tools in providing investment advisory services.
  • To provide investment  advice  to  the  client  based  on  the  risk-profiling  of  the  clients  and suitability of the client.
  • To treat all advisory clients with honesty and integrity.
  • To make adequate disclosure to the investor of all material facts such as risks, obligations, costs, etc. relating to the products or securities advised by the adviser.
  • To provide clear  guidance  and  adequate  caution  notice  to  clients  when  providing investment advice for dealing in complex and high-risk financial products/services.
  • To ensure confidentiality  of  information  shared  by clients unless  such  information  is required  to  be  provided  in  furtherance  of  discharging  legal  obligations  or a  client has provided specific consent to share such information.
  • To disclose the timelines  for  the  various  services  provided  by  the  investment  adviser  to clients and ensure adherence to the said timelines.

D. Details of grievance redressal mechanism and how to access it

1.Investor can lodge complaint/grievance against Investment Adviser in the following ways:

Mode of filing the complaint with investment adviser

In  case  of  any  grievance  /  complaint,  an  investor  may approach  the  concerned Investment Adviser who shall strive to redress the grievance immediately, but not later than 21 days of the receipt of the grievance.

Mode of filing the complaint on SCORES or with Investment Adviser Administration and Supervisory Body (IAASB)

i) SCORES 2.0 (a web based centralized grievance redressal system of SEBI for facilitating effective grievance redressal in time-bound manner) (https://scores.sebi.gov.in)

Two level review for complaint/grievance against investment adviser:

  • First review done by designated body (IAASB)
  • Second review done by SEBI

ii) Email to designated email ID of IAASB

2. If the Investor is not satisfied with the resolution provided by the Market Participants, then the Investor has the option to file the complaint/ grievance on SMARTODR platform for its resolution through online conciliation or arbitration

3. With regard to physical complaints, investors may send their complaints to:

         Office of Investor Assistance and Education,
Securities and Exchange Board of India,
SEBI Bhavan, Plot No.C4 – A, ‘G’ Block,
Bandra – Kurla Complex, Bandra (E),
Mumbai – 400 051

E. Rights of investors

  • Right to Privacy and Confidentiality
  • Right to Transparent Practices
  • Right to fair and Equitable Treatment
  • Right to Adequate Information
  • Right to Initial and Continuing Disclosure-Right to receive information about all the statutory and regulatory disclosures.
  • Right to Fair & True Advertisement
  • Right to Awareness about Service Parameters and Turnaround Times
  • Right to be informed of the timelines for each service
  • Right to be Heard and Satisfactory Grievance Redressal
  • Right to have timely redressal
  • Right to Suitability of the Financial Products
  • Right to Exit from Financial product or service in accordance with the terms of agreement with the investment adviser
  • Right to receive clear guidance and caution notice when dealing in Complex and High-Risk Financial Products and Services
  • Additional Rights to vulnerable consumers-Right to get access to services in a suitable manner even if differently abled
  • Right to provide feedback on the financial products and services used
  • Right against coercive, unfair, and one-sided clauses in financial agreements

F. Expectations from the investors (Responsibilities of investors)

  • Do’s
  1. Always deal with SEBI registered Investment Advisers.
  2. Ensure that the Investment Adviser has a valid registration certificate.
  3. Check for SEBI registration number. Please  refer  to  the  list  of  all  SEBI  registered  Investment  Advisers  which  is available on SEBI website in the following link: https://www.sebi.gov.in/sebiweb/other/OtherAction.do?doRecognisedFpi=yes&intmId=13
  4. Pay only advisory fees to your Investment Adviser. Make payments of advisory fees through banking  channels  only  and  maintain  duly  signed  receipts  mentioning  the details of your payments.
    You  may  make  payment  of  advisory  fees  through  Centralised  Fee  Collection Mechanism (CeFCoM) of IAASB if investment adviser has opted for the mechanism.
  5. Always ask  for  your  risk  profiling  before  accepting  investment    Insist  that Investment  Adviser  provides  advisory  strictly  on  the  basis  of  your  risk  profiling  and take into account available investment alternatives.
  6. Ask all relevant questions and clear your doubts with your Investment Adviser before acting on advice.
  7. Assess the  risk–return  profile  of  the  investment  as  well  as  the  liquidity  and  safety aspects before making investments.
  8. Insist on getting the terms and conditions in writing duly signed and stamped. Read these terms  and  conditions  carefully  particularly  regarding  advisory  fees,  advisory plans, category of recommendations etc. before dealing with any Investment Adviser.
  9. Be vigilant in your transactions.
  10. Approach the appropriate authorities for redressal of your doubts / grievances.
  11. Inform SEBI about Investment Advisers offering assured or guaranteed returns.
  12. Always be aware that you have the right to exit the service of an Investment Adviser
  13. Always be aware that you have the right to seek clarifications and clear guidance on advice
  14. Always be aware that you have the right to provide feedback to the Investment Adviser in respect of services received.
  15. Always be  aware  that  you  will  not  be  bound  by  any  clause, prescribed  by  the investment adviser, which is contravening any regulatory provisions.
  • Don’ts
  1. Don’t fall for stock tips offered under the pretext of investment advice.
  2. Do not provide funds for investment to the Investment Adviser.
  3. Don’t fall  for  the  promise  of  indicative  or  exorbitant  or  assured  returns  by  the Investment Advisers. Don’t let greed overcome rational investment decisions.
  4. Don’t fall prey to luring advertisements or market rumours.
  5. Avoid doing  transactions  only  on  the  basis  of  phone  calls  or  messages  from  any Investment adviser or its representatives.
  6. Don’t take decisions just because of repeated messages and calls by Investment Advisers.
  7. Do not  fall  prey  to  limited  period  discount  or  other  incentive,  gifts,    offered by Investment advisers.
  8. Don’t rush into making investments that do not match your risk taking appetite and investment goals.
  9. Do not share login credential and password of your trading, demat or bank accounts with the Investment Adviser.