SEBI Disclosures - Avinash Luthria, Hourly-Fee Financial Planner & SEBI RIA

Disclaimer:

Registration granted by SEBI, membership of BSE Administration and Supervision Limited (BASL) and certification from National Institute of Securities Markets (NISM) in no way guarantee performance of the Investment Adviser 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
I do not provide any investment advice during the introductory audio call i.e. any informal introductory discussion during the introductory audio call is not investment advice
Due to SEBI’s Advertisement Code for Investment Advisers, any Investment Advice that the Investment Adviser sends to the Client is only for consumption by the Client and such material should not be redistributed

SEBI Complaint Data to be displayed by Investment Advisers:

Data for the previous month

Sr. No.	Received from	Pending at the end of last month	Received	Resolved	Total Pending	Pending complaints > 3months	Average Resolution time (in days)	Reason
1	Directly from Investors	0	0	0	0	0	N/A	N/A
2	SEBI (SCORES)	0	0	0	0	0	N/A	N/A
3	Other Sources (if any)	0	0	0	0	0	N/A	N/A
	Grand Total	0	0	0	0	0	N/A	N/A

Trend of monthly disposal of complaints

Sr. No.	Month	Carried forward from previous month	Received	Resolved	Pending	Reason
1	Month before the previous month	0	0	0	0	N/A
2	Previous month	0	0	0	0	N/A
	Grand Total	0	0	0	0	N/A

Trend of annual disposal of complaints

Sr. No.	Year	Carried forward from previous year	Received	Resolved	Pending	Reason
1	FY2021-2022	0	0	0	0	N/A
2	FY2022-2023	0	0	0	0	N/A
3	FY2023-2024	0	0	0	0	N/A
4	FY2024-2025	0	0	0	0	N/A
5	FY2025-2026	0	0	0	0	N/A
	Grand Total	0	0	0	0	N/A

Compliance Audit Status:

Sr. No.	Financial Year	Compliance Audit Status	Remarks, if any
1	FY2020-2021	Conducted	N/A
2	FY2021-2022	Conducted	N/A
3	FY2022-2023	Conducted	N/A
4	FY2023-2024	Conducted	N/A

SEBI requirement on information to be provided:

Complete name of Investment Adviser: Avinash Khatoo Luthria
Type of Registration: Individual
Registration number: INA200011125
Validity of registration: Perpetual starting from Jul 12, 2018
Correspondence Address: C 1203 The Gardens, No 9 Magadi Road Near Binny Mill Circle, Bangalore - 560023, Karnataka
Correspondence Email address: avinash@fiduciaries.in (Note: In case of any complaint by a client, the complaint should be sent to this email address)
Phone Number only for statutory purposes: +919538950469 (Note: This phone number is provided only for statutory purposes and is not for business enquiries by potential clients and others; Please use the email address for business enquiries; For regulatory reasons only, if you are unable to send an email, only in that case, send a WhatsApp message on this number and provide a few business days to check the WhatsApp message)
Corresponding SEBI regional/local office address: 2nd Floor, Jeevan Mangal Building, No.4, Residency Road, Bengaluru - 560025, Karnataka
Link to SEBI's SCORES website and mobile app on Android
SEBI's Online Dispute Resolution (ODR): ODR website and information about ODR

SEBI requirement on Grievance Redressal / Escalation Matrix :

Details of designation	Contact Person Name	Address	Contact No.	Email-ID	Working hours	Remarks
Customer Care	Avinash Khatoo Luthria	C 1203 The Gardens, No 9 Magadi Road Near Binny Mill Circle, Bangalore - 560023, Karnataka	+919538950469	avinash@fiduciaries.in	9am to 7pm (Monday to Friday; except public holidays)	Since I am an Individual IA without team members and I may be busy on a call with a client, hence it is much faster to reach me over Email else then WhatsApp messages rather than via an unscheduled call
Head of Customer Care	Avinash Khatoo Luthria	C 1203 The Gardens, No 9 Magadi Road Near Binny Mill Circle, Bangalore - 560023, Karnataka	+919538950469	avinash@fiduciaries.in	9am to 7pm (Monday to Friday; except public holidays)	Since I am an Individual IA without team members and I may be busy on a call with a client, hence it is much faster to reach me over Email else then WhatsApp messages rather than via an unscheduled call
Compliance Officer	Avinash Khatoo Luthria	C 1203 The Gardens, No 9 Magadi Road Near Binny Mill Circle, Bangalore - 560023, Karnataka	+919538950469	avinash@fiduciaries.in	9am to 7pm (Monday to Friday; except public holidays)	Since I am an Individual IA without team members and I may be busy on a call with a client, hence it is much faster to reach me over Email else then WhatsApp messages rather than via an unscheduled call
CEO	Avinash Khatoo Luthria	C 1203 The Gardens, No 9 Magadi Road Near Binny Mill Circle, Bangalore - 560023, Karnataka	+919538950469	avinash@fiduciaries.in	9am to 7pm (Monday to Friday; except public holidays)	Since I am an Individual IA without team members and I may be busy on a call with a client, hence it is much faster to reach me over Email else then WhatsApp messages rather than via an unscheduled call
Principal Officer	Avinash Khatoo Luthria	C 1203 The Gardens, No 9 Magadi Road Near Binny Mill Circle, Bangalore - 560023, Karnataka	+919538950469	avinash@fiduciaries.in	9am to 7pm (Monday to Friday; except public holidays)	Since I am an Individual IA without team members and I may be busy on a call with a client, hence it is much faster to reach me over Email else then WhatsApp messages rather than via an unscheduled call

SEBI's Investor Charter in respect of Investment Advisers (IAs)

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
  - i. Always deal with SEBI registered Investment Advisers.
  - ii. Ensure that the Investment Adviser has a valid registration certificate.
  - iii. 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
  - iv. 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.
  - v. Always ask for your risk profiling before accepting investment advice. Insist that Investment Adviser provides advisory strictly on the basis of your risk profiling and take into account available investment alternatives.
  - vi. Ask all relevant questions and clear your doubts with your Investment Adviser before acting on advice.
  - vii. Assess the risk–return profile of the investment as well as the liquidity and safety aspects before making investments.
  - viii. 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.
  - ix. Be vigilant in your transactions.
  - x. Approach the appropriate authorities for redressal of your doubts / grievances.
  - xi. Inform SEBI about Investment Advisers offering assured or guaranteed returns.
  - xii. Always be aware that you have the right to exit the service of an Investment Adviser
  - xiii. Always be aware that you have the right to seek clarifications and clear guidance on advice
  - xiv. Always be aware that you have the right to provide feedback to the Investment Adviser in respect of services received.
  - xv. 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
  - i. Don’t fall for stock tips offered under the pretext of investment advice.
  - ii. Do not provide funds for investment to the Investment Adviser.
  - iii. 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.
  - iv. Don’t fall prey to luring advertisements or market rumors.
  - v. Avoid doing transactions only on the basis of phone calls or messages from any Investment adviser or its representatives.
  - vi. Don’t take decisions just because of repeated messages and calls by Investment Advisers.
  - vii. Do not fall prey to limited period discount or other incentive, gifts, etc. offered by Investment advisers.
  - viii. Don’t rush into making investments that do not match your risk taking appetite and investment goals.
  - ix. Do not share login credential and password of your trading, demat or bank accounts with the Investment Adviser.

SEBI has made it mandatory for Investment Advisers to display the two SEBI images below:

Additional information that Investment Advisers are required to mention on their website

Investors may report unsolicited Stock Tip/Recommendation in Stocks and Equity Derivatives (Derivative Contracts) ONLY via the details available at this link
- Additionally, Press Releases by BSE are available at this link

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