Disclosures
1. Introduction:
All mutual fund distributors must pass an examination conducted by the National Institute of Securities Markets (NISM). Thereafter, they register with the Association of Mutual Funds in India (AMFI) and obtain an AMFI Registration Number (ARN). We fulfill both these requirements. The AMFI distributor code of this firm is ARN-165114. Date of Initial AMFI Registration – 5th August 2019; ARN valid till – 1st January 2025.
When investing in mutual funds, you have two options. You can invest directly with the mutual fund or proceed through a distributor. Investing directly with mutual funds is less expensive. However, you will receive neither advice nor services from us if you choose the direct option.
2. AMFI Code of Conduct for Distributors of Mutual Funds:
We are bound by a code of conduct prescribed by AMFI, which is displayed on the notice board of our office. You are entitled to demand photocopies of this code of conduct or ask for the code of conduct to be emailed to you absolutely free of charge. This code of conduct can also be accessed on the AMFI website (www.amfiindia.com) and the websites of individual mutual funds. You are strongly urged to familiarise yourself with the said code of conduct and form an opinion about whether we are adhering to the same.
3.Important documentation pertaining to mutual fund investment plans advised by us for you, or chosen by you:
Comprehensive documentation about specific mutual fund investment plans is available on the websites of all mutual funds. The most comprehensive document is the Scheme Information Document (SID). Next is the Statement of Additional Information (SAI). The SID mainly contains information about mutual fund schemes. The SAI primarily contains information about the mutual fund, its asset management company, its trustees, sponsors, etc. The SID should be read together with the SAI and not in isolation, because the SAI is part of the SID. The Key Information Memorandum (KIM) is essentially a summary of the SID and SAI. As per SEBI regulations, every application form is to be accompanied by the KIM. We reiterate that the SID, SAI and KIM of all mutual fund investment plans that we distribute are available at on the websites of mutual funds free of cost. Furthermore, these are amended from time to time and addendums thereto are also available on the websites of the mutual funds and through our office.
We recommend that all mutual fund investors make the effort to go through these important documents and other useful publications such as reports and ‘fact sheets’ published by all mutual funds regularly.
4. Risk, Risk Management, Past Performance and Investor Education:
All investments, including mutual fund investments, are fraught with risk. This is the first and most important point that you as a mutual fund investor must understand and accept.
Second, risk is of two types – risk that cannot be managed (for example betting, gambling and games of pure chance) and risk that can be managed. The risk in equity and mutual fund investments can very definitely be managed. This is achieved by employing time-tested risk management tools which can control and significantly reduce risk. Some of these risk management tools are diversification, asset allocation, the setting of investment time horizons, systematic investment and regular reviews.
Third, past performance of any mutual fund investment plans is neither a predictor nor a guarantor of future returns. No one can predict future returns. By investing wisely however, you can increase the probability that you will obtain optimum returns and manage risk.
Fourth, educating yourself about investment is important. You should ask us as many questions as you want till you understand the products you are investing in and the reasons for zeroing down on those.
5. Disclosure about commissions earned by us on your investments:
We do not charge advisory fees or transaction fees to any of our investors for mutual fund investments. We do receive commissions from mutual funds on investments routed through us. Details about such commissions are contained in “brokerage structure” documents supplied to us at regular intervals by mutual funds with whom we are associated. These have been put up on our website www.addingwell.in.
You can be aware of commissions in the form of trail and other commissions received by us for the different schemes of various mutual funds from which schemes recommended to you are chosen. You can also obtain printouts/photocopies of these reports or have them emailed to you free of charge. Finally, commissions paid to us appear in the consolidated account statements (CAS) that are couriered or emailed to all mutual fund investments at stipulated intervals. We make it very clear that under no circumstances will we rebate or pass back commissions to investors.
6. Complaints and investor grievance redressal:
If you have any grievances against our firm, please address the same to us either in person or by telephone or in writing, including by email. You may direct your complaints about mutual fund investments to:
Mr. Umesh Rajgarhia, Founder
We try our best to redress grievances within two working days. Do not hesitate to revert to us if any grievance is not redressed within a week. Apart from grievances, your suggestions and feedback are also always welcome.
7. Disclosure about the firm’s own activities and investments and measures to avoid conflicts of interest:
The principal activity of this firm is to provide personal investment services to individual investors. The main areas of the firm’s operations are mutual funds and other managed investment products. We may also distribute capital gains exemption bonds and tax-free government or PSU bonds subject to their availability and suitability to investors, and also depending upon whether the regulatory environment allows us to do so.
The firm/founder also makes investments of its own, mainly in equity shares and mutual funds. Whether in mutual funds or stocks, the investment strategies and investment avenues chosen by the firm are similar as the ones recommended to its clients. Clients have the right to verify this. Incorrect advice by us will affect our investments as much as yours.
Thus, we attempt to establish a commonality of interest, while eliminating conflicts of interest in this area. The firm’s investment program comprises of long-term, buy-and-hold strategies, with no element of speculation, churning or short-termism whatsoever. Our own investing program ensures that the discussions with clients is based on, not just our extensive reading, but also practical experience, and therefore carries credibility.
We do not accept any costly gifts from mutual funds or other financial institutions. We also do not participate in business augmentation contests which such organisations come out with from time to time. If we recommend an investment plan or mutual fund, it is solely because we believe it addresses a financial need of the investor to whom it is recommended. Finally, the firm does not have any sales staff. We solicit business by referrals only.
8. We are not SEBI registered investment advisers:
Basic and broad general advice to investors is given in some of our writings and more with an objective to initiate discussions with clients/prospects rather than work as investment advice. We do not do detailed financial planning or offer detailed and comprehensive investment advice to individual clients. Only advice incidental to our primary activities is given.
For Adding Well,
Umesh Rajgarhia, Founder.