Fund & Product Selection Policy

Per AMFI DDQ Section 2.6 | AMFI Master Circular | SEBI Guidelines on Suitability & Conflict of Interest

Gaurav Singhvi | 143128 | Initial Reg: 11-Mar-2018 | Valid Until: 09-Mar-2029 | Effective: July 2026

Purpose of This Policy This Fund & Product Selection Policy describes the framework used by Gaurav Singhvi (143128) to select, recommend, and review financial products for investors. This policy is prepared in accordance with AMFI DDQ Section 2.6, AMFI Master Circular January 2026, and applicable SEBI guidelines on investor suitability and conflict of interest management. We are committed to recommending only those products that are genuinely suitable for each investor based on their individual profile.

⚠️ Core Principle — Suitability Above All Every product recommendation made by Gaurav Singhvi is based SOLELY on the investor's risk profile, financial goals, investment horizon, and financial capacity. Commission rates, incentives, or commercial considerations from AMCs or product manufacturers have NO influence on our recommendations. Investor suitability is non-negotiable.

1. Our 4-Step Product Selection Process

Investor Profiling

Structured risk assessment to understand goals, horizon, income, liabilities, and risk tolerance

Product Mapping

Match investor profile to suitable product categories using SEBI Riskometer and asset allocation framework

Scheme Evaluation

Evaluate specific schemes using quantitative and qualitative criteria — performance, costs, AMC reputation

Recommendation & Review

Present suitable options. Final decision always with investor. Periodic review at least annually.

2. Investor Risk Profiling

Before recommending any product, Gaurav Singhvi conducts a structured investor risk profiling exercise covering:

Age & Life Stage — Investment horizon typically decreases as investors approach retirement
Income & Surplus — Monthly investable surplus after expenses and emergency fund allocation
Existing Liabilities — Home loan, personal loan, education loan EMIs affecting investable capacity
Financial Goals — Short-term (less than 3 years), medium-term (3-7 years), long-term (7+ years)
Risk Tolerance — Emotional and financial capacity to absorb temporary portfolio losses
Investment Experience — First-time investor vs experienced investor — affects product complexity
Tax Bracket — Relevant for recommending tax-efficient investment options like ELSS
Liquidity Needs — Emergency fund adequacy, upcoming financial commitments in next 3 years

3. Risk Profile Categories & Product Suitability Matrix

Risk Profile	Suitable Fund Categories	Suitable Products	Avoid	Recommended Horizon
🟢 Conservative Low risk tolerance, capital preservation priority	Liquid, Overnight, Ultra Short Duration, Money Market, Short Duration Debt, Conservative Hybrid	Debt MFs, Liquid MFs, Term Insurance, Endowment	Small Cap, Sector/Thematic, Long Duration Debt, High Yield Credit, PMS	Less than 3 years
🟡 Moderate Moderate risk, balanced growth	Balanced Advantage, Aggressive Hybrid, Large Cap, Multi Cap, Index Funds, Balanced Hybrid	Hybrid MFs, Large Cap MFs, Index Funds, Term + Health Insurance	Small Cap (primary), Sector Funds (primary), Long Duration Debt	3 to 7 years
🔴 Aggressive High risk tolerance, wealth creation focus	Flexi Cap, Mid Cap, Small Cap, ELSS, Thematic, Sectoral, International Funds	Diversified Equity MFs, ELSS, PMS (Min Rs.50L)	Liquid/Overnight for long-term goals, Capital Protection schemes	7+ years

Note: This matrix is indicative. Actual recommendations depend on the individual investor's complete profile. A Moderate investor may hold some Aggressive products for long-term goals and vice versa, based on goal-based allocation.

4. Scheme Evaluation Criteria

Once the appropriate category is identified, Gaurav Singhvi evaluates specific schemes using the following criteria:

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Performance Track Record

3-year and 5-year returns vs benchmark and category average. Consistency of outperformance across market cycles.

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Fund Manager Quality

Fund manager's experience, track record across market cycles, stability (low turnover), and investment philosophy.

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AMC Reputation & Stability

AMC's AUM size, years of operation, parent company stability, regulatory compliance history, and overall franchise strength.

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Expense Ratio (TER)

Total Expense Ratio compared to category average. Lower TER (all else equal) means better net returns for investors.

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Risk-Adjusted Returns

Sharpe Ratio, Sortino Ratio, Standard Deviation — evaluating how much return is generated per unit of risk taken.

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Liquidity & Portfolio Quality

Portfolio concentration, liquidity of underlying securities, credit quality (for debt), sector/stock concentration risks.

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Fund Size (AUM)

Adequate AUM to ensure liquidity and operational efficiency. Avoid very small funds with closure risk and very large funds in mid/small cap categories.

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Investment Style Consistency

Does the fund follow its stated investment mandate? Style drift (e.g. large cap fund buying small caps) is a red flag.

5. Conflict of Interest Policy

Our Formal Declaration — No Commission-Driven Recommendations Gaurav Singhvi formally declares that:

✓ Commission rates received from AMCs have NO influence on fund recommendations
✓ We do not maintain any formal or informal "preferred AMC" list for commercial reasons
✓ We do not participate in AMC-sponsored holidays, trips, or gifts that create conflict of interest
✓ We do not receive any incentives, rebates, or benefits beyond the standard trail commission disclosed on our website
✓ Scheme recommendations are documented with rationale before presentation to investors
✓ We do not switch investors between schemes to generate additional commission (churning)
✓ Direct Plans are always disclosed as an alternative, even though we do not facilitate them

Practices We Strictly Prohibit (Conflict of Interest):

Recommending schemes based on higher commission rates or incentives
Churning — unnecessary switching of investor portfolios to generate commissions
Accepting non-cash benefits, gifts above regulatory limits, or sponsored trips from AMCs
Recommending close-ended NFOs or illiquid products without full risk disclosure
Recommending products outside investor risk profile without written unsuitability declaration

6. Unsuitability Declaration Process

If an investor wishes to invest in a product that does not match their assessed risk profile, Gaurav Singhvi follows this process:

Step 1 — Inform: Gaurav Singhvi will clearly communicate in writing that the chosen product is outside the investor's risk profile
Step 2 — Explain Risks: A detailed explanation of the specific risks of the product — volatility, liquidity, downside potential
Step 3 — Formal Declaration: Investor must sign a formal Unsuitability Declaration acknowledging the risk mismatch
Step 4 — Process Transaction: Only after receiving the signed declaration will the transaction be processed
Step 5 — Record Keeping: Unsuitability declarations are maintained for a minimum of 8 years as part of client records

7. Portfolio Review Policy

Annual Review: Gaurav Singhvi conducts a comprehensive portfolio review with every investor at least once a year
Triggered Review: Additional reviews are initiated when there is a material change in investor's financial situation, goals, or life stage
Market Event Review: During significant market events (15%+ correction or rally), investors are proactively communicated with
Fund Change Review: When a recommended scheme undergoes fundamental changes (fund manager change, mandate change, merger), investors are informed and alternatives reviewed
Rebalancing: Portfolio rebalancing is recommended when actual asset allocation deviates significantly (more than 10%) from target allocation

8. Product-Specific Selection Policies

Insurance Products

Insurance need analysis conducted before any insurance recommendation — Human Life Value (HLV) method used for life cover calculation
Term insurance is always the primary recommendation for life cover — investment-linked products recommended only for specific needs
Health insurance coverage adequacy reviewed against medical inflation and family health history
Insurance is the subject matter of solicitation. Policy documents shared before purchase decision

Portfolio Management Services (PMS)

PMS recommended ONLY for investors with investable surplus above Rs. 50 Lakhs in this specific asset class
Only Aggressive risk profile investors with minimum 5-year horizon are considered for PMS
PMS manager track record, strategy, fee structure (fixed + performance fees) evaluated before recommendation
Concentration risk, liquidity risk, and manager risk specifically disclosed before PMS investment

9. Record Keeping & Compliance

All investor risk profiles, financial goal discussions, and recommendation rationale are documented and maintained
Records retained for minimum 8 years as per SEBI and AMFI requirements
All unsuitability declarations maintained as permanent client records
This Fund Selection Policy is reviewed and updated at least annually or when there are regulatory changes
Policy is available for inspection by AMFI, SEBI, or any regulatory authority on request

Formal Declaration by Gaurav Singhvi I, Gaurav Singhvi (Proprietor), on behalf of Gaurav Singhvi (143128), hereby declare that this Fund & Product Selection Policy represents our genuine commitment to investor-first recommendations. This policy is followed in letter and spirit in all our client interactions. Any deviation from this policy can be reported to AMFI at igrc@amfiindia.com or to SEBI SCORES at scores.sebi.gov.in.

Contact for policy queries:
Gaurav Singhvi | Proprietor | gauravsinghvimf@gmail.com | 9904336060 | www.cfpgauravsinghvi.com

Regulatory Reference: AMFI DDQ Section 2.6 | AMFI Master Circular January 2026 | SEBI Master Circular for Mutual Funds | SEBI Circular on Suitability Assessment

Effective Date: July 2026 | Last Updated: July 2026 | Gaurav Singhvi | 143128 | Reviewed annually

Fund Selection Policy