Declarations by IA
Declaration Statement by IA
(As per SEBI IA Regulations, 2013)
- Terms & Conditions Agreement Consent
Clients must confirm that they have read and understood the terms, scope, fee structure, risk factors, declarations, disclosures and disclaimers as part of the Investment Advisory Agreement.
- Risk Profiling Consent
Clients must complete and sign the Risk Profiling form, either digitally or physically, to help us determine suitable investment advice aligned with their financial goals and risk appetite.
- Dependent Family Members Declaration
Clients are required to disclose dependent family members whose investments are funded by their income. This declaration must be updated annually or upon change.
- Annual PAN Declaration for Family-Based Advisory
For clients onboarded as a “family unit,” PAN details of all members being considered as a single client must be submitted annually.
- Investment Policy Declaration (Non-Individual Clients)
Non-individual clients must submit their Investment Policy Document or relevant excerpts to facilitate risk profiling and suitability. Advisory services may be withheld if this is not provided.
- Declaration on Fee Structure and Limits
The Investment advisor declare that it shall charge advisory fees only in one of the following SEBI-permitted modes:
Fixed Fee: Not exceeding ₹1,51,000 per client per year
AUA-based Fee: Not exceeding 2.5% per annum of Assets Under Advice
The fee model will be transparently mentioned in the Agreement and client invoices.
- Fee Payment Declaration
Clients must agree to pay advisory fees through traceable banking channels only such as NEFT, RTGS, IMPS, UPI, or account payee cheques. Cash payments are not accepted.
- Explicit Consent for Trade Execution (If Applicable)
Where implementation services are offered:
Clients must provide explicit written consent for trade execution.
This can be given through Aadhaar e-sign (via DigiLocker), timestamped email, or in-person confirmation, as per SEBI Regulation 19(1)(d).
- Acknowledgment of Non-SEBI Products/Services
We do not provide advisory services on products outside SEBI’s jurisdiction (e.g., real estate, insurance, and cryptocurrencies). Clients must acknowledge that grievances related to such products cannot be raised under SEBI’s redressal mechanism. - No Assured Returns Declaration
Clients must acknowledge that investment advice is provided on a best-effort basis and does not guarantee assured returns. All investments carry market risk.
- Grievance Redressal Awareness
Clients are informed about the process to raise grievances:
First with SR Alpha Investment Advisor via designated contact methods.
If unresolved within 30 days, they can escalate via SEBI’s SCORES portal:
- Execution of Agreement
The Investment Advisor shall not render any investment advice or charge any fee until the client has signed the Investment Advisory Agreement.
- No Fund/Asset Handling
The Investment Advisor shall not manage client funds or securities. The only consideration The Investment Advisor receive is fee-based, as per the advisory agreement.
- No Assured Returns
The Investment Advisor shall not guarantee or imply assured, fixed, minimum, or risk-free returns. All investment advice is provided based on suitability and market risk assessment.
- No Power of Attorney (PoA)
The Investment Advisor shall not seek any PoA, trading authority, or account implementation access from the client. Execution of advice shall remain solely under the client’s control.
- Disclosure of Conflicts of Interest
The Investment Advisor shall disclose all conflicts of interest as and when they arise, in writing or through official communication channels.
- No Benefit from Client Investments
The Investment Advisor shall not derive any direct or indirect benefit (commission, referral, and brokerage) from any securities, assets, or investments transacted by the client based on our advice.
- Arms-Length Declaration
The Investment Advisor maintain an arms-length relationship between our investment advisory services and any other business activity (if applicable), in accordance with regulatory requirements.
- Regulatory Eligibility
The Investment Advisor declare full compliance with all eligibility conditions, including qualification, certification, Experience norms, Capital adequacy and deposit requirements (if applicable) and audit requirements, under the SEBI Investment Advisers Regulations.
- Code of Conduct Compliance
The Investment Advisor adhere to the Code of Conduct as specified in Schedule III of the SEBI (Investment Advisers) Regulations, 2013, ensuring fiduciary responsibility, transparency, confidentiality, Integrity and fairness.
- No Distribution Services
The Investment Advisor shall not provide any distribution services, nor receive commissions from product issuers.
- No Cross-Distribution or Cross-Advisory – Group Entities
No distribution services shall be provided to advisory clients by the IA or group entities.
No advisory services shall be provided to distribution clients of the group.
- Adviser’s Liability Disclaimer (Regulatory Limitation of Role)
The client understands that the Investment Adviser is not liable for losses incurred due to market volatility, third-party execution, or macroeconomic risks.
- Data Privacy & Confidentiality Statement
The client’s personal and financial information will be maintained in strict confidence and used solely for providing advisory services, as per applicable data protection regulations.
- Record Retention Consent
The client consents to the adviser maintaining records of communication, risk profiling, advice, and other documentation for a minimum of five years.
- Communication Preference (Mode of Advice Delivery)
Advisory services will be delivered via email, secure platforms as mutually agreed.
- No Free Trial or Preview Services
The Investment Advisor declare that it do not offer free trials, sample portfolios, or preview calls of investment advice, in full compliance with SEBI’s advisory norms.
- Disclosure on AI Usage (If Applicable)
Where any Artificial Intelligence (AI) or automation tool is used to support advice generation:
- Clients are informed at onboarding
- The role of AI is limited to support functions
- Human review and compliance are ensured
- Client data is treated with strict confidentiality
(As per SEBI Circular – Effective April 30, 2025)
- Website & Disclosure Requirements
The Investment Advisor declare that our website contains:
- SEBI Registration Details
- Registered & Branch Office Addresses
- Investor Charter
- Complaint Status (monthly updates)
- Contact & grievance redressal details
- MITC, Risk Profiling disclosures, and more
- Disclosure for Accredited Investors (If Applicable)
The Investment Advisor declare that if any client is categorized as an Accredited Investor.
- We may offer bilateral terms (within permitted flexibility).
- All such terms will be clearly documented and mutually agreed upon.
- Other Declarations
The Investment Advisor will act with honestly, fairly and in the best interests of its clients and in the integrity of the market.
- The Investment Advisor have and employ effectively appropriate resources and procedures which are needed for the efficient performance of its business activities.
- The Investment Advisor will take prior approval from the Board, in case of change in control of its entity.
- Furnish to the Board, information and reports as may be specified by the Board from time to time.
- Not act on its own account, knowingly to sell securities or investment products to or purchase securities or investment product from its client.
- Eligibility Criteria
We declare that we continue to satisfy the eligibility criteria prescribed by SEBI under the Investment Advisers Regulations, Including:
- Educational qualifications
- Certification(NISM Level 1&2)
- Experience norms
- Capital adequacy and deposit requirements(if applicable)
- No distribution by family members-Individual IA
We declare that none of our Family Members shall engage in the distribution of financial products to clients advised by us.