After changing “Name of entity / person / intermediary/ Organization*”and “Advisor Name” with your name and “ARN-xxxxxx” with your ARN No.
Email this draft to:
sebiria@sebi.gov.in
Before 23rd Jan. 2018
Copy from following line till end of the letter.
SUB: Feedback on Consultation Paper (Investment Advisers) Regulations, 2013 Jan 02, 2018
Dear sir \ Madam
I have gone through your RIA Consultation Paper and found it is the best move to protect the Investor’s interest as an advisor I have noticed, even though every aspect is kept in mind to protect investor, something is left which may hurts and not good from Investor’s angle which I want to highlight and hope that it will be implemented in the final draft of the paper
By referring all the points I would like to suggest on the consultation paper
| Name of entity / person / intermediary/ Organization* | |||
| Sr. No. | Pertains to Point No | Suggestions | Rationale |
| 1 | 1 | Most welcome one more step towards balanced format of consultation paper. | |
| 2 | 2 | I will suggest one step ahead to ensure that there is no cross connection between RIAs for that all the immediate relatives will be in same category either in RIAs or MFDs
Best move is to allow only direct plans for RIAs then there will not be any conflict or loss on investor side |
I found 1 Problem
Problem 1] There is a possibility of creating a cartel by RIAs that my relative will provide execution to your advisory services and vis a versa |
| 3 | 3 | In addition one more thing is required that Risk Profiling should be made mandatory to stop mis-selling for Banks, NBFCs, Body Corporates, LLPs . | I found 1 Problem
Problem 1] There is a possibility of mis-selling if the products are sold to a person without risk profiling. There are so many cases registered that retired persons were offered single premium policies. |
| 4 | 4 | Welcome this decision | |
| 5 | 5 | If SEBI wants to ensure “appropriateness’ of products to the client”
1] MFDs risk profiling must be mandatory 2] Should be allowed to do basic goal based planning. Otherwise there are so many chances of knowingly or unknowingly mis-selling. MFDs. should not be allowed to make comprehensive financial planning. Disclosures & other things like are ok |
I Found 2 roblems
Problem 1] MFDs are not allowed to do Risk Profiling then how MFDs can decide “appropriateness’ of products to the client”.
Proble 2] Only Risk Profiling is not sufficient for deciding “appropriateness’ of products to the client”. Because some schemes are suitable for one goal may not suitable for another goal. |
Thanking You
Advisor Name
ARN-xxxxxx
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