SEBI Registered Investment Adviser Regn No. INA1000000000

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Disclosure

Disclosures as per SEBI Investment Advisers Regulations

Issued by: SR Alpha Investment Advisor (The Trading Mitra™) | SEBI RIA No.: INA000000001

1. 📃 Client Agreement Disclosure

We enter into a mandatory Investment Advisory Agreement with each client before offering advice or accepting fees. This agreement outlines:

  • Services offered
  • Fee structure and mode
  • Responsibilities of both parties
  • Terms of termination

Note: We do not begin advisory until this agreement is executed.

2. 📊 Client Risk Profiling & Suitability

We conduct a comprehensive risk profiling and suitability assessment for every client. Clients must:

  • Complete and sign a Risk Profile Form
  • Review the categorization (Low / Moderate / High Risk)
  • Consent to the suitability-based advice before implementation

3. 🔄 Segregation of Advisory & Distribution Activities

As per SEBI regulations:

  • We ensure segregation of advisory and distribution services at the client level
  • We, or any of our family/group entities, do not offer distribution to our advisory clients

4. 💰 Fee Structure Disclosure

We offer two SEBI-permitted fee models:

  • Fixed Fee: Capped at ₹1,25,000 per client per annum
  • AUA-based Fee: Capped at 2.5% of assets under advice annually Clients are clearly informed of the chosen model in the advisory agreement.
Additional Fee Conditions:
  • Fee can be charged quarterly in advance (maximum 2 quarters at a time).
  • In case of premature termination, the unutilized portion is refunded after retaining a breakage fee (max 1 quarter’s fee).
  • Fee is charged per client or per family, as defined under SEBI regulations.
  • Change of fee model is allowed only after 12 months from onboarding or last change.

This ensures transparency, fairness, and full regulatory compliance in how we charge and disclose fees.

Fee Structure Disclosure:

We offer two SEBI-approved fee models. Clients must select one model at the time of onboarding, which is clearly documented in the Investment Advisory Agreement:

  • Fixed Fee : Up to ₹1,25,000 per annum per client or family, across all services
  • AUA-Based Fee : Up to 2.5% per annum of Assets Under Advice (AUA), with supporting proof.
Fee Model Change & Mixing – SEBI Guidelines

Under Regulation 15A and SEBI Circulars (esp. 2020/182), the following rules apply:

  • A client must select only one fee model:
    • Either Fixed Fee, or
    • AUA-Based Fee
  • Mixing of both models is strictly not allowed for the same client or family.
  • Change of fee model (e.g., switching from Fixed to AUA or vice versa) is allowed only after 12 months from:
      • The client’s onboarding date, or
      • The last fee model change date

5. 🧠 Disclosure on Use of Artificial Intelligence (AI)

As part of our research and reporting process, SR Alpha Investment Advisor may utilize Artificial Intelligence (AI)-based tools or algorithms to assist in data analysis, pattern recognition, or report generation.

Regulatory-Compliant AI Usage Guidelines:
  • AI is used only as a support tool and does not replace human judgment in investment advice.
  • All investment recommendations are approved by qualified human advisors, in compliance with SEBI’s suitability and fiduciary standards.
  • No AI-based tool is authorized to interact directly with clients or make autonomous investment decisions.
  • Client data processed by AI systems is managed in accordance with applicable data protection and confidentiality norms.
  • Clients are informed during onboarding if AI tools form part of their advisory process.
Compliance Reference:

This disclosure complies with SEBI’s expectations on technology-assisted advisory processes, including standards for accountability, transparency, and human oversight (per IA Regulations and regulatory advisories up to 2025).

6. 📄 MITC – Most Important Terms & Conditions

We provide clients with a standardized MITC document at the time of onboarding. It includes:

  • Fee limits and mode
  • Market risk and return variability
  • No-assured-return clause
  • Grievance escalation mechanism (including SCORES portal)

7. 📈 Disclosure of Investor Charter

As mandated, we prominently publish the SEBI Investor Charter on our website.
If the client cannot access this online, we provide it through email or WhatsApp.

8. 📌 Monthly Complaint Disclosure

We publish a monthly investor complaint status in SEBI’s prescribed format on our website homepage.

9. 🔄 Disclosure of Other Business Activities

(Aligned with Regulation 15(11) and Regulation 2(pb) of SEBI IA Regulations, 2013)

Primary Activity:

SR Alpha Investment Advisor operates as a full-time SEBI-registered Investment Adviser (RIA) under Registration No. INA00000XXX.

Other Activities Undertaken:

In addition to investment advisory, we also undertake the following activities:

  • Educational Programs: We conduct stock market training and financial awareness sessions. These are strictly non-advisory, do not involve any specific stock recommendations or portfolio advice, and are delivered independently from our advisory function.
  • Tax and Financial Support Services: We assist clients with income tax return filing, loan/subsidy documentation, and related professional compliance support. These services:
  1. Do not involve securities market advice,
  2. Do not involve management of client funds, and
  3. Are distinct and segregated from our advisory operations.
Segregation & Compliance Measures:
  • These activities are conducted via separate operational teams, invoices, and client records.
  • We maintain clear segregation at both operational and client-service levels.
  • These disclosures are made in full alignment with Regulation 15(11) and Regulation 2(pb) of the SEBI IA Regulations.
  • The independence, objectivity, and fiduciary duty of our investment advisory services remain unaffected by these activities.

10. 📰 Advertisement Code Compliance

We comply with SEBI’s Advertisement Code. We ensure that:

  • No misleading performance claims are made
  • All disclaimers are prominently disclosed
  • No offer of free trials, assured returns, or guaranteed profits is made

11. 🌐 Website Information Disclosure

Our website (The Trading Mitra™) contains:

  • SEBI Registration No.
  • Registered and Branch Office addresses
  • Contact information
  • Details of Compliance Officer (if applicable)
  • Disclosures, Investor Charter, MITC, Complaint Data

12. 🚫 Non-SEBI Products/Services Disclosure

We do not offer advice on products outside SEBI’s purview such as:

  • Real estate
  • Insurance
  • Unregulated crypto assets Clients must acknowledge that grievances for such products cannot be raised with SEBI.

13. 📋 Annual Compliance Audit Disclosure

We undergo an annual compliance audit by a SEBI-recognized auditor.

  • Any adverse observations are disclosed to clients along with corrective actions
  • Audit report is available to clients upon request

14. 🗂 Half-Yearly Reporting to SEBI

We submit bi-annual regulatory filings in the prescribed IAASB format, covering:

  • Number of clients
  • Complaints received/resolved
  • Fees collected
  • Other disclosures

15. 🔁 Change in Control Disclosure

Any proposed change in control of the IA is:

  • Disclosed to SEBI in advance
  • Accompanied by declarations from the acquiring party
  • Shared transparently with clients if it affects service continuity

16. ⚠️ Grievance Redressal Disclosure

Clients can raise concerns via:

📩 Email – sralphainvestmentadvisers@gmail.com
Contact Form on Website
WhatsApp-9422906376,9579001565

Unresolved complaints within 30 days can be escalated to:
🛡 SCORES Portal: https://scores.sebi.gov.in
📬 SEBI Office: Plot No. C4-A, G-Block, BKC, Bandra (E), Mumbai – 400051

17. 🏛 Disclosure for Accredited Investors (If Applicable)

Where the client is classified as an Accredited Investor, bilateral terms for fees and service delivery may differ and are disclosed transparently during onboarding.

Who Can Be an Accredited Investor?

Individual:

  • Income ≥ ₹2 crore annually OR
  • Net worth ≥ ₹7.5 crore, with at least ₹3.75 crore in financial assets

✅ HUFs, Family Trusts, Sole Proprietorships:

  • Same income/net worth thresholds as individuals

Body Corporates, Trusts, LLPs, AIFs, PMS clients, etc.:

  • Net worth ≥ ₹50 crore

Foreign Investors (FPI, FVCI, etc.):

  • Must meet eligibility as notified by SEBI

🛡 How Accreditation Works:

  1. Apply to a SEBI-recognized Accreditation Agency
  2. Receive a Certificate of Accreditation valid for 1 year
  3. Can access customized investment products or bilaterally negotiated terms (e.g., fees for IA services)

For Accredited Investors, the RIA:

    • Is exempt from standard fee caps (e.g., ₹1.25 lakh/year or 2.5% AUA)
    • Can enter custom agreements
  • Must disclose Accredited status and record such classification properly during onboarding

18. 🗃 Record Maintenance Disclosure

We maintain complete records of:

  • Client communications
  • Risk profiling
  • Agreements signed

These are stored for a minimum of 5 years or until dispute resolution.

19. ❌ Prohibition of Free Trials & Assured Returns

We do not provide free trials, demo services, or assured/guaranteed return offers under any circumstances.
Such actions are strictly prohibited under SEBI norms.

20. ⚖️ Conflicts of Interest Disclosure

We declare that:

  • Any potential or actual conflict of interest will be disclosed to the client in writing
  • We maintain independence from group entities or relatives in our advisory

21. 🔏 No Power of Attorney (PoA) Declaration

We do not seek or accept PoA or any trade authorization from clients.
Implementation (if applicable) is done only post explicit, documented consent.

22. 🏷 Brand Name and Identity Disclosure

“The Trading Mitra™” is the brand under which SR Alpha Investment Advisor operates.
Clients are clearly informed about:

  • The name under which advisory is registered with SEBI
  • The use of this trade name in communication, agreements, and websites

23. 🏦 Deposit Requirement Disclosure (NEW)

In compliance with SEBI norms (w.e.f. 2025):

  • IAs must maintain a deposit for investor protection
  • For up to 150 clients, this amount is ₹1,00,000
  • This requirement enhances operational accountability and risk coverage

Note: We do not begin advisory until this agreement is executed.