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Aditya Vakil · RP-2026-0142
  1. 1Client contextupcoming
  2. 2Risk questionnaireupcoming
  3. 3Profile & mappingupcoming
  4. 4IPS proposal draftupcoming
  5. 5Sign & activateupcoming
1
Client context
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Fields marked with · are AMFI / SEBI (MF Distribution) suitability-record inputs
Client
Prospect / client details Prefilled from client record where available
Objective & horizon
12 yrs
Draft auto-saved. Suitability record retained 7 years per AMFI / SEBI (MF Distribution) Regulations 2013.
2
Risk questionnaire
SEBI-style suitability & risk-tolerance assessment
20 questions · 4 sections · save-and-resume enabled
Progress
3 / 20 answered · running score 42
Section A · Financial capacity 5 questions · max 25 pts
Section B · Loss tolerance & behavioural risk 6 questions · max 30 pts
Section C · Time horizon & liquidity needs 4 questions · max 20 pts
Section D · Knowledge & investment experience 5 questions · max 25 pts
Complete all 20 questions to compute the risk-profile score and unlock model-portfolio mapping.
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Profile & mapping
Risk score, band and model-portfolio allocation
Score computed deterministically · band bounds locked in firm's IPS policy v2.4
68
out of 100
Moderate
Willing to accept short-term volatility for medium-to-long-term growth. Comfort with equity majority provided debt/hybrid ballast is in place. Tolerates drawdowns up to ~20% without redemption pressure.
Section A · capacity
18 / 25
Section B · loss tolerance
20 / 30
Section C · horizon
14 / 20
Section D · knowledge
16 / 25
Model bands score ranges per firm IPS policy v2.4 · the mapped band is highlighted
Conservative
0 - 40
Capital preservation · low volatility
Moderate-Conservative
41 - 55
Debt-tilted balanced · small equity satellite
Moderate
56 - 70
Equity majority with debt / hybrid ballast
Moderate-Aggressive
71 - 85
Equity-tilted · mid/small + international
Aggressive
86 - 100
Growth-first · tolerates 30%+ drawdowns
Recommended asset allocation · Moderate Mapped from firm's model portfolio · policy v2.4 · reviewed 2026-Q2View methodology →
Asset class Recommended % Policy range Advisor override Corpus allocation Notes
Total 100% 100% ₹4,20,00,000
Compare with existing portfolio Aditya Vakil · disclosed holdings ₹3.4 CrLook-through detail →
Asset class Current % Recommended % Delta Rupee shift Action
Equity — large-cap38%25%-13%-₹54.6 LTrim Reliance + HDFC Bank; re-deploy to Debt
Equity — mid+small18%15%-3%-₹12.6 LPartial redemption of mid-cap fund
Debt — short8%20%+12%+₹50.4 LFresh allocation · liquid + ultra-short duration
Debt — medium/long4%15%+11%+₹46.2 LGilt fund + banking & PSU debt fund
Hybrid12%10%-2%-₹8.4 LHold existing HDFC Hybrid Equity
Gold + Silver6%5%-1%-₹4.2 LRetain SGB 2029
International0%5%+5%+₹21.0 LFresh · MO Nasdaq 100 FoF + MSCI World feeder
Cash14%5%-9%-₹37.8 LDeploy over 4-6 weeks · staggered STP
Advisor may nudge percentages within policy range. Deviations beyond range require reasoned override and reviewer sign-off.
4
IPS proposal draft
Investment Policy Statement · ready for review
v0.9 · draft · not signed · use Edit on a section to change it in place
WC
Kulkarni Wealth Distributors LLPAMFI / SEBI (MF Distribution) · ARN-118472

Investment Policy Statement

Prepared for Mr. Aditya Rajesh Vakil · resident individual
Ref · RP-2026-0142 / IPS-v0.9
Prepared · 20-Aug-2026
Prepared by · Aarti Kulkarni, Principal WM
Reviewed by · Nishant Menon, Associate
Compliance · Priya Nair
This Investment Policy Statement records the client's suitability profile and the distribution relationship's investment framework, in accordance with SEBI (Mutual Funds) Regulations and the AMFI Code of Conduct.

§ 1 Executive summary

Mr. Aditya Vakil (age 52, resident individual, PAN ABCPV1234K) has engaged Kulkarni Wealth Distributors LLP as AMFI-registered mutual-fund distributor under a distribution mandate. His primary objective is retirement corpus generation over a 12-year horizon with an investable base of ₹4,20,00,000, supplemented by a monthly investable surplus of ₹1,25,000.

The suitability questionnaire (Section 3 below) scores him at 68 / 100, placing him in the Moderate risk-profile band. The corresponding model portfolio (Section 5) targets a blended equity weight of 40%, debt weight of 35%, hybrid 10%, precious metals 5%, international 5% and cash reserve 5%. This IPS commits both parties to a quarterly review discipline, a ±5% drift-alert threshold and an annual re-profiling exercise.

Nothing is billed to the client. The distributor earns AMC trail commission on regular-plan schemes held by the client, disclosed in Section 7. All conflicts of interest are disclosed in Section 8. The client acknowledges that past performance is not indicative of future returns and that market-linked instruments carry the risk of principal loss.

§ 2 Client profile

Full legal name
Mr. Aditya Rajesh Vakil
Date of birth · age
18-Jun-1974 · 52 years
PAN
ABCPV1234K
Aadhaar (masked)
XXXX-XXXX-8842
Residency
Resident individual · India · Mumbai
Occupation
Salaried — Chief Financial Officer, Reliance Retail
Gross annual income
₹50 lakh - 1 crore band
Existing net-worth
₹5 - 15 crore band · self-declared
Dependents
2 (son 16 yrs · daughter 12 yrs)
Emergency fund
₹36 lakh (approx. 12 months household expense) in liquid MF + savings
Life insurance
Term cover ₹4 Cr · HDFC Life · in force to 2044
Health insurance
Family floater ₹25 lakh · Max Bupa · plus employer cover ₹10 lakh
Primary objective
Retirement corpus at age 62 (target 2036) · secondary goals: children's higher education (2028-2032), Alibaug house maintenance reserve
Investable corpus (day 1)
₹4,20,00,000
Monthly surplus
₹1,25,000 · to be deployed via SIP / STP
Time horizon
12 years to primary objective (retirement)
Existing advisor
Kotak Wealth (transactional) · to be gradually consolidated
Referred by
Mr. Neel Shah (client, Shah family)

§ 3 Risk assessment

The client completed the firm's 20-question SEBI-style risk-profile questionnaire on 20-Aug-2026. The scoring rubric (0-5 points per question, 100-point maximum) is set out in Appendix B. The section-wise breakdown is:

SectionMaxScoredReading
A · Financial capacity2518Strong income, adequate emergency cover, dependents drag capacity mildly
B · Loss tolerance & behavioural risk3020Comfortable up to -20% drawdown; would hold, not redeem
C · Time horizon & liquidity201412-yr horizon, limited near-term liquidity needs beyond emergency fund
D · Knowledge & experience2516Familiar with equity, MF, bonds; limited exposure to F&O, PMS, AIF
Total10068Moderate (band 56 - 70)

Band description. A Moderate investor is willing to accept short-term market volatility in return for medium-to-long-term capital growth. Typical drawdown tolerance is up to 20%, with a stated intention to hold through market cycles rather than redeem. The band is suitable for a diversified equity-majority portfolio with a meaningful debt ballast and modest allocations to precious metals and international equity for correlation reduction.

The client's profile will be re-assessed annually or on the occurrence of a material change in circumstances (income, dependents, health, employment, marital status, inheritance). Interim requests to change risk profile require a fresh questionnaire and a reasoned override under Section 4.

§ 4 Investment policy

Objective statement
Grow the invested corpus at a real (post-inflation, post-tax) return of 6 - 8% p.a. over rolling 5-year windows, with capital preservation as the overriding secondary objective.
Return benchmark
Composite: 55% Nifty 500 TRI + 35% CRISIL Composite Bond Index + 5% MCX Gold + 5% MSCI World INR
Risk tolerance
Drawdown up to 20% at portfolio level acceptable without corrective action. Beyond 20%, a joint review call is triggered.
Rebalance rule
Drift alert fires when any asset-class weight deviates by more than ±5 percentage points from the target set in Section 5. Advisor evaluates within 5 working days and either rebalances or documents a hold decision.
Liquidity policy
Minimum 5% cash / liquid MF reserve at all times. Additional 6-month household-expense buffer maintained outside this IPS scope.
Investment universe
SEBI-registered mutual funds (equity, debt, hybrid, gold, silver, international feeder), listed equities on NSE / BSE, Sovereign Gold Bonds, listed corporate bonds (AA and above), and Category II AIFs (subject to separate suitability). PMS, unlisted equity and derivatives excluded.
Concentration limits
Single stock ≤ 8% · single fund ≤ 15% · single sector ≤ 25% · single AMC across funds ≤ 30%
Prohibited instruments
Structured products with capital-loss features, penny stocks, derivatives (F&O), unlisted / unrated debt, cryptocurrency, and any instrument outside the SEBI regulatory perimeter.
ESG / thematic tilt
None specified. Client open to a review after 12 months.
Tax approach
Prefer LTCG-eligible harvesting windows · use ₹1.25 lakh LTCG exemption on equity annually · avoid short-term equity churn where possible · debt gains taxed at slab rate per Finance Act 2023.

§ 5 Recommended asset allocation

The recommended asset-class weights below are derived from the firm's Moderate model portfolio (policy v2.4, reviewed Q2 2026) and mapped to the client's ₹4,20,00,000 investable corpus.

Asset classTarget %Policy rangeRupee allocation
Equity — large-cap25%20-35%₹1,05,00,000
Equity — mid+small-cap15%10-20%₹63,00,000
Debt — short duration20%15-30%₹84,00,000
Debt — medium/long duration15%10-20%₹63,00,000
Hybrid (aggressive/dynamic)10%5-15%₹42,00,000
Gold + Silver5%5-15%₹21,00,000
International equity5%0-10%₹21,00,000
Cash / liquid5%5-15%₹21,00,000
Total100%—₹4,20,00,000

§ 6 Proposed portfolio · scheme-level

The scheme selections below implement the Section 5 allocation using SEBI-registered mutual funds and instruments already on the firm's approved list. Direct-plan / growth-option is preferred throughout.

#Instrument / schemeAsset classRouteWeightAmount
1ICICI Prudential Bluechip Fund — Direct GrowthEquity — large-capFresh · Lumpsum12%₹50,40,000
2HDFC Top 100 Fund — Direct GrowthEquity — large-capRetain existing8%₹33,60,000
3Nippon India ETF Nifty 50 BeESEquity — large-capFresh · STP 12w5%₹21,00,000
4Parag Parikh Flexi Cap Fund — Direct GrowthEquity — mid+smallRetain + top-up9%₹37,80,000
5Kotak Emerging Equity Fund — Direct GrowthEquity — mid+smallFresh · STP 12w6%₹25,20,000
6ICICI Prudential Short Term Fund — Direct GrowthDebt — shortFresh · Lumpsum10%₹42,00,000
7HDFC Ultra Short Term Fund — Direct GrowthDebt — shortFresh · Lumpsum10%₹42,00,000
8SBI Magnum Gilt Fund — Direct GrowthDebt — medium/longFresh · Lumpsum8%₹33,60,000
9Bandhan Banking & PSU Debt — Direct GrowthDebt — medium/longFresh · Lumpsum7%₹29,40,000
10HDFC Hybrid Equity Fund — Direct GrowthHybridRetain existing10%₹42,00,000
11Sovereign Gold Bond 2029 (existing holding)Precious metalsRetain3%₹12,60,000
12Nippon India Silver ETFPrecious metalsFresh · Lumpsum2%₹8,40,000
13Motilal Oswal Nasdaq 100 FoFInternationalFresh · STP 12w3%₹12,60,000
14Franklin India Feeder MSCI World FundInternationalFresh · STP 12w2%₹8,40,000
15Nippon India Liquid Fund — Direct GrowthCash / liquidWorking reserve5%₹21,00,000
Total · 15 instruments100%₹4,20,00,000

Deployment schedule: lumpsum entries execute within 5 working days of activation. STP-routed equity entries (Nifty 50 BeES, Kotak Emerging Equity, Nasdaq 100 FoF, MSCI World feeder) stagger over 12 weekly instalments starting the first Monday post-sign-off, drawn from Nippon India Liquid Fund. Monthly SIP of ₹1,25,000 routes 60% to equity (large + mid) and 40% to short-duration debt from month 2 onwards.

§ 7 Commercial disclosure

Distributor revenue model
AMC trail commission on regular-plan schemes · earned monthly on average daily AUM · paid by the AMC to the distributor · nothing billed to the client
Typical trail bands (informational)
Regular-plan equity ~50-80 bps p.a. · debt ~20-40 bps · hybrid ~40-60 bps · direct plans + SGB + direct equity: nil
Upfront on-boarding fee
Nil · no charge for onboarding, IPS drafting, or ongoing service
Other consideration
The distributor does not accept referral fees, sub-brokerage from third parties, or upfront commissions outside AMFI-permitted trail structures
Third-party charges (borne by client, paid to third parties — not to the distributor)
Fund-house expense ratios (per SID) · demat AMC to depository participant (Zerodha, ~₹300 p.a.) · STT / stamp duty / GST on transactions
Trail statement
Annual trail-commission statement available on request · itemised per scheme · reconciled against AMC WBR
Termination
Either party may terminate the distribution relationship on 30 days' written notice · no exit charge from the distributor

§ 8 Regulatory disclosures

AMFI mutual-fund distributor registration. Kulkarni Wealth Distributors LLP is registered with AMFI as a mutual-fund distributor · ARN ARN-118472 · valid to 31-Mar-2029 · Principal Officer: Ms. Aarti Kulkarni. Conduct is governed by SEBI (Mutual Funds) Regulations and the AMFI Code of Conduct.

Conflict of interest. The distributor earns AMC trail commission on regular-plan schemes recommended and held by the client, per each AMC's published rate card. Typical trail bands are disclosed in Section 7. The distributor does not accept upfront commissions, referral fees, or any consideration from the client. Product recommendations are made on the basis of the client's risk profile and IPS objectives, not on commission economics.

Past performance disclaimer. Past performance of the recommended schemes or of the composite benchmark is not indicative of future returns. All market-linked instruments carry the risk of principal loss. The recommended asset allocation is a policy target and not a guarantee of future portfolio outcomes. Tax implications depend on the client's individual tax position and prevailing law and may change without notice.

Grievance redressal. Complaints may be raised with the Compliance Officer (compliance@wealthcockpit.example.in). Unresolved complaints may be escalated to SEBI's SCORES portal (scores.sebi.gov.in) or to the Online Dispute Resolution mechanism at smartodr.in.

Data protection. Personal information collected in the course of this engagement is processed under the Digital Personal Data Protection Act, 2023. The client's consent to processing (purpose, retention, sharing) is recorded separately in the DPDP consent register attached in Appendix D. Retention: 7 years from the date of engagement termination.

§ 9 Review discipline

Quarterly review
Portfolio statement + rebalance recommendation + tax utilisation update · 45-minute call within 15 days of quarter-end
Annual review
Full IPS refresh · fresh risk questionnaire · goals re-visit · fee-model review · in-person meeting preferred
Drift-alert response
±5 pp deviation from target → advisor acknowledges within 2 working days · rebalance decision within 5 working days · outcome logged in audit trail
Ad-hoc reviews
Triggered by material change in client circumstances, market drawdown > 15% peak-to-trough, or regulatory change materially affecting the portfolio
Reporting deliverables
Quarterly statement (Investwell format) · annual capital-gains report (Schedule CG rollup) · monthly SIP execution log · on-demand look-through concentration report
Meeting log
Every review call, notes are captured, signed off and retained in the client's DD folder for 7 years

§ 10 Signatures

By signing below, both parties confirm that this Investment Policy Statement accurately reflects the client's risk profile, financial circumstances and objectives as on the date of signing, and that the distribution relationship is governed by the SEBI (Mutual Funds) Regulations and the AMFI Code of Conduct and the terms set out above.

Client
Mr. Aditya Rajesh Vakil
PAN ABCPV1234K · Aadhaar OTP e-sign
Signed on ____________________
Distributor · Principal Officer
Ms. Aarti Kulkarni
Kulkarni Wealth Distributors LLP · ARN-118472
Signed on ____________________
Witness
Mr. Nishant Menon
Associate Wealth Manager
Signed on ____________________

§ 11 Appendices

Appendix A · Full questionnaire responses. A verbatim record of all 20 questions and the client's selected option is retained. The responses are the primary evidence supporting the risk-band assignment in Section 3 and are re-visited at every annual review.

Appendix B · Scoring methodology. Each question carries options weighted 0 to 5 points. The composite score maps to five bands: Conservative (0-40), Moderate-Conservative (41-55), Moderate (56-70), Moderate-Aggressive (71-85), Aggressive (86-100). Ties resolve to the lower band per firm's prudence policy.

Appendix C · Model portfolio methodology. The firm's five model portfolios are constructed using long-run capital-market assumptions reviewed annually by the Investment Committee. Sector, single-name and AMC concentration limits are hard-coded and enforced at proposal generation. The next scheduled review of model assumptions is Q4 2026.

Appendix D · DPDP consent register. Signed consent capturing purpose (mutual-fund distribution), retention (7 years), sharing (regulators, auditors, RTAs on need-to-know), and the client's rights under the Digital Personal Data Protection Act, 2023.

Appendix E · KYC docket. PAN, Aadhaar (masked), address proof, income proof, bank proof, and photograph — verified via the firm's KYC utility on 18-Aug-2026. Full docket retained in the DD folder.

Cover · 1 of 12
v0.9 draft · autosaved 2 minutes ago · once signed, this document is immutable and its hash is written to the audit chain.
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Sign & activate
E-signature and reference-model activation
Once signed, the IPS becomes the reference model for drift-alert monitoring
Signature pathway picks the e-sign engine and evidence stored in the DD folder
Aadhaar OTP eSign. One-time password to the client's registered mobile. Standard for online onboarding under SEBI (IA/MFD) e-sign guidelines. Signed IPS is sealed with a SignDesk-issued audit trail.
◷
Awaiting client signature
Aadhaar OTP e-sign via SignDesk · sent 20-Aug-2026 15:22 IST to +91 98204 12456
WhenEventBy
20-Aug 15:20IPS document sealed · v0.9 → v1.0 · hash sha256:9f4c…8a12Aarti K.
20-Aug 15:22E-sign request sent · Aadhaar OTP via SignDesk · txn SDK-2026-84422System
20-Aug 15:22SMS + email delivered · +91 98204 12456 · aditya.vakil@example.inSystem
20-Aug 15:24Client opened the document (5 min read)System
AwaitingClient Aadhaar OTP · request expires 22-Aug 15:22 IST—
AwaitingDistributor counter-sign · Aarti Kulkarni—
AwaitingWitness counter-sign · Nishant Menon—
Signed IPS is retained for 7 years per SEBI (MF Distribution) record-retention rule. Client, distributor and witness signatures + Aadhaar / DSC evidence are archived to the DD folder.
Activate as reference model portfolio

Once the IPS is fully signed, the recommended allocation in Section 5 becomes the reference model against which the client's live portfolio is monitored. Drift alerts fire on the thresholds set below.

Use signed IPS as drift-alert referenceDrift alerts on Aditya Vakil's live portfolio will be generated against the Section 5 target allocation
Asset-class drift thresholdAlert when any class deviates by more than this from target
Concentration alertsFire on single-name > 8%, single-fund > 15%, sector > 25%
Quarterly review reminderSchedule the first review call for Nov-2026
Annual re-profile reminderSchedule a fresh questionnaire for 20-Aug-2027
Signed IPS + activation writes an immutable AuditEvent (kind: ips.activated) to the client's audit stream with the document hash.