Risk profiler & investment plan RP-2026-0142 Draft
- 1Client contextupcoming
- 2Risk questionnaireupcoming
- 3Profile & mappingupcoming
- 4IPS proposal draftupcoming
- 5Sign & activateupcoming
| Asset class | Recommended % | Policy range | Advisor override | Corpus allocation | Notes |
|---|---|---|---|---|---|
| Total | 100% | 100% | ₹4,20,00,000 |
| Asset class | Current % | Recommended % | Delta | Rupee shift | Action |
|---|---|---|---|---|---|
| Equity — large-cap | 38% | 25% | -13% | -₹54.6 L | Trim Reliance + HDFC Bank; re-deploy to Debt |
| Equity — mid+small | 18% | 15% | -3% | -₹12.6 L | Partial redemption of mid-cap fund |
| Debt — short | 8% | 20% | +12% | +₹50.4 L | Fresh allocation · liquid + ultra-short duration |
| Debt — medium/long | 4% | 15% | +11% | +₹46.2 L | Gilt fund + banking & PSU debt fund |
| Hybrid | 12% | 10% | -2% | -₹8.4 L | Hold existing HDFC Hybrid Equity |
| Gold + Silver | 6% | 5% | -1% | -₹4.2 L | Retain SGB 2029 |
| International | 0% | 5% | +5% | +₹21.0 L | Fresh · MO Nasdaq 100 FoF + MSCI World feeder |
| Cash | 14% | 5% | -9% | -₹37.8 L | Deploy over 4-6 weeks · staggered STP |
Investment Policy Statement
§ 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:
| Section | Max | Scored | Reading |
|---|---|---|---|
| A · Financial capacity | 25 | 18 | Strong income, adequate emergency cover, dependents drag capacity mildly |
| B · Loss tolerance & behavioural risk | 30 | 20 | Comfortable up to -20% drawdown; would hold, not redeem |
| C · Time horizon & liquidity | 20 | 14 | 12-yr horizon, limited near-term liquidity needs beyond emergency fund |
| D · Knowledge & experience | 25 | 16 | Familiar with equity, MF, bonds; limited exposure to F&O, PMS, AIF |
| Total | 100 | 68 | Moderate (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 class | Target % | Policy range | Rupee allocation |
|---|---|---|---|
| Equity — large-cap | 25% | 20-35% | ₹1,05,00,000 |
| Equity — mid+small-cap | 15% | 10-20% | ₹63,00,000 |
| Debt — short duration | 20% | 15-30% | ₹84,00,000 |
| Debt — medium/long duration | 15% | 10-20% | ₹63,00,000 |
| Hybrid (aggressive/dynamic) | 10% | 5-15% | ₹42,00,000 |
| Gold + Silver | 5% | 5-15% | ₹21,00,000 |
| International equity | 5% | 0-10% | ₹21,00,000 |
| Cash / liquid | 5% | 5-15% | ₹21,00,000 |
| Total | 100% | — | ₹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 / scheme | Asset class | Route | Weight | Amount |
|---|---|---|---|---|---|
| 1 | ICICI Prudential Bluechip Fund — Direct Growth | Equity — large-cap | Fresh · Lumpsum | 12% | ₹50,40,000 |
| 2 | HDFC Top 100 Fund — Direct Growth | Equity — large-cap | Retain existing | 8% | ₹33,60,000 |
| 3 | Nippon India ETF Nifty 50 BeES | Equity — large-cap | Fresh · STP 12w | 5% | ₹21,00,000 |
| 4 | Parag Parikh Flexi Cap Fund — Direct Growth | Equity — mid+small | Retain + top-up | 9% | ₹37,80,000 |
| 5 | Kotak Emerging Equity Fund — Direct Growth | Equity — mid+small | Fresh · STP 12w | 6% | ₹25,20,000 |
| 6 | ICICI Prudential Short Term Fund — Direct Growth | Debt — short | Fresh · Lumpsum | 10% | ₹42,00,000 |
| 7 | HDFC Ultra Short Term Fund — Direct Growth | Debt — short | Fresh · Lumpsum | 10% | ₹42,00,000 |
| 8 | SBI Magnum Gilt Fund — Direct Growth | Debt — medium/long | Fresh · Lumpsum | 8% | ₹33,60,000 |
| 9 | Bandhan Banking & PSU Debt — Direct Growth | Debt — medium/long | Fresh · Lumpsum | 7% | ₹29,40,000 |
| 10 | HDFC Hybrid Equity Fund — Direct Growth | Hybrid | Retain existing | 10% | ₹42,00,000 |
| 11 | Sovereign Gold Bond 2029 (existing holding) | Precious metals | Retain | 3% | ₹12,60,000 |
| 12 | Nippon India Silver ETF | Precious metals | Fresh · Lumpsum | 2% | ₹8,40,000 |
| 13 | Motilal Oswal Nasdaq 100 FoF | International | Fresh · STP 12w | 3% | ₹12,60,000 |
| 14 | Franklin India Feeder MSCI World Fund | International | Fresh · STP 12w | 2% | ₹8,40,000 |
| 15 | Nippon India Liquid Fund — Direct Growth | Cash / liquid | Working reserve | 5% | ₹21,00,000 |
| Total · 15 instruments | 100% | ₹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.
§ 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.
| When | Event | By |
|---|---|---|
| 20-Aug 15:20 | IPS document sealed · v0.9 → v1.0 · hash sha256:9f4c…8a12 | Aarti K. |
| 20-Aug 15:22 | E-sign request sent · Aadhaar OTP via SignDesk · txn SDK-2026-84422 | System |
| 20-Aug 15:22 | SMS + email delivered · +91 98204 12456 · aditya.vakil@example.in | System |
| 20-Aug 15:24 | Client opened the document (5 min read) | System |
| Awaiting | Client Aadhaar OTP · request expires 22-Aug 15:22 IST | — |
| Awaiting | Distributor counter-sign · Aarti Kulkarni | — |
| Awaiting | Witness counter-sign · Nishant Menon | — |
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.