background

Fund Selection Policy

AMFI DDQ SECTION 2.6 | SUITABILITY FRAMEWORK

Fund & Product Selection Policy

Objective, Fiduciary & Investor-Centric Scheme Evaluation Guidelines
ARN-367223 Valid Until: 04-AUG-2029 Zero Commission Bias
Purpose & Regulatory Mandate This Fund & Product Selection Policy outlines the structured, objective framework used by FINWISDOM FINANCIAL SERVICES PVT LTD (ARN-367223) to evaluate, select, recommend, and periodically review financial products. Prepared in strict accordance with AMFI Due Diligence Questionnaire (DDQ) Section 2.6, the AMFI Master Circular (January 2026), and SEBI guidelines on investor suitability and conflict-of-interest prevention, our recommendations are driven solely by investor suitability.
Core Commitment — Non-Negotiable Suitability: Every product recommendation is based EXCLUSIVELY on the investor's documented risk profile, financial objectives, investment horizon, and surplus cash flows. Distributor payout rates, volume tiers, or AMC incentives have ZERO bearing on product selection.

1. Our 4-Step Product Selection Process

01

Investor Profiling

Comprehensive risk profiling analyzing financial capacity, goal timelines, net cash flow, and psychological loss tolerance.

02

Category Mapping

Aligning the investor's profile to SEBI-defined asset classes and Riskometer tiers to determine optimal asset allocation.

03

Scheme Evaluation

Multi-factor screening across 8 quantitative and qualitative criteria (rolling returns, Sharpe, expense ratio, AMC stability).

04

Fulfillment & Review

Presenting shortlisted options with SID/KIM. Final investment choice is always the investor's. Annual review mandated.

2. Multi-Dimensional Investor Risk Profiling

Before proposing any financial scheme, FINWISDOM conducts an in-depth risk evaluation across 8 crucial financial dimensions:

Age & Life Stage

Investment horizons, dependent obligations, and risk capacity naturally shift across career and retirement phases.

Income & Surplus

Net monthly disposable cash surplus after mandatory lifestyle expenses, debt obligations, and emergency fund buffers.

Existing Debt / EMIs

Fixed liabilities (home loans, education loans, personal debts) affecting liquidity and financial stress thresholds.

Financial Goal Horizon

Short-term (<3 yrs), medium-term (3–7 yrs), and long-term (7+ yrs) objectives with targeted maturity dates.

Risk Tolerance

Psychological comfort and balance sheet capacity to endure short-to-medium term market volatility and drawdowns.

Market Experience

Investor familiarity with market cycles, past asset exposure, and product sophistication (first-time vs experienced).

Tax Bracket

Evaluating marginal tax slabs to optimize post-tax returns through Section 80C ELSS or debt/equity taxation rules.

Liquidity & Emergency Needs

Ensuring 6–12 months of contingency liquid reserves before committing capital to long-term lock-in products.

3. Risk Categories & Product Suitability Matrix

Risk Profile Suitable Fund Categories Recommended Products Categories to Avoid Recommended Horizon
🟢 Conservative
Capital preservation priority
Liquid, Overnight, Ultra Short Duration, Money Market, Short Duration Debt, Conservative Hybrid Debt Mutual Funds, Liquid Funds, Term Insurance Small Cap, Sectoral/Thematic, PMS, Credit Risk < 3 Years
🟡 Moderate
Balanced growth & income
Balanced Advantage (BAF), Aggressive Hybrid, Large Cap, Multi Cap, Nifty 50 Index Funds Hybrid Mutual Funds, Large Cap MFs, Index Funds, Health Insurance Small Cap (Primary), Thematic/Sector Funds, Long Duration Debt 3 – 7 Years
🔴 Aggressive
Long-term wealth compounding
Flexi Cap, Mid Cap, Small Cap, ELSS (Tax Saving), Thematic, International Funds Diversified Equity MFs, ELSS, SIF (Min ₹10L), PMS (Min ₹50L), AIF (Min ₹1Cr) Overnight/Liquid for long-term compounding, capital protection plans 7+ Years

4. 8-Point Scheme Evaluation Framework

Rolling Returns Track Record

Consistent 3, 5, and 7-year rolling returns against benchmark indices across bull, bear, and consolidation market phases.

Fund Manager Competence

Managerial tenure, investment philosophy adherence, and historical track record across market downturns.

AMC Stability & Governance

Institutional pedigree, total AUM size, risk management systems, fiduciary culture, and regulatory compliance record.

Total Expense Ratio (TER)

Competitive management expense relative to peers. A lower TER directly enhances the investor's compounded net yield.

Risk-Adjusted Ratios

Sharpe Ratio, Sortino Ratio, Standard Deviation, and Downside Capture ratios to measure returns generated per unit of risk.

Liquidity & Portfolio Quality

Underlying asset liquidity, low stock/sector concentration, top 10 holding ratios, and credit quality (AAA/Sovereign for debt).

Optimal Fund Size (AUM)

Balanced fund scale ensuring sufficient liquidity while preventing scale-drag in mid-cap and small-cap segments.

Mandate & Style Discipline

Strict adherence to scheme mandate without style drift (e.g. large-cap funds making unmandated mid/small-cap allocations).

5. Conflict of Interest Management Policy

Fiduciary Independence Declaration FINWISDOM FINANCIAL SERVICES PVT LTD formally confirms that:
  • Distributor trail commission rates received from AMCs have ZERO influence on scheme recommendations
  • We maintain no "preferred AMC" lists based on commercial payouts or sponsorship arrangements
  • We strictly reject all sponsored trips, luxury gifts, or contest incentives from fund houses
  • Portfolio churning (unwarranted switching to generate commissions) is strictly prohibited
  • Investors are always informed about Direct Plans as an alternative, though we distribute Regular Plans

Practices We Strictly Prohibit

  • Recommending schemes solely driven by distributor commission rates or incentives
  • Portfolio churning — unnecessary switching of investments to generate fresh trail or transaction fees
  • Accepting non-cash benefits, sponsored foreign travel, or gifts from Asset Management Companies
  • Recommending complex, high-risk closed-ended NFOs without exhaustive risk profiling
  • Recommending products outside the investor's risk profile without an executed Unsuitability Declaration

6. Unsuitability Declaration Process

When an investor explicitly requests a product that does not align with their assessed risk profile, FINWISDOM enforces the following statutory 5-step protocol:

1
Written Risk Mismatch Advisory

We provide formal written communication explaining why the chosen scheme deviates from the assessed risk profile.

2
Detailed Downside & Volatility Disclosure

Thorough documentation of potential capital drawdowns, liquidity lock-ins, and downside volatility risks.

3
Formal Unsuitability Declaration

The investor must execute a signed Unsuitability Declaration acknowledging full awareness of the product risk mismatch.

4
Execution on Investor's Sole Mandate

Transaction is processed only after the declaration is fully signed and archived in the compliance register.

5
8-Year Mandatory Record Preservation

All unsuitability records and client acknowledgments are retained securely for a statutory minimum of 8 years.

7. Product-Specific Selection & Advisory Guidelines

Protection

Insurance Products

  • Human Life Value (HLV) calculation conducted before recommending life cover
  • Pure term insurance is prioritized for life risk protection
  • Health cover limits evaluated against medical inflation and family history
  • Corporate agency distribution only — risk is underwritten by the respective insurer
Min ₹10 Lakhs

Specialised Investment Funds (SIF)

  • Offered exclusively to sophisticated investors with minimum ₹10 Lakhs surplus
  • Positioned between Mutual Funds and PMS for specialized thematic strategies
  • Strategy complexity and track record limitations disclosed in detail
  • Allocation capped as a tactical satellite component of overall wealth
Min ₹50 Lakhs

Portfolio Management Services (PMS)

  • Statutory minimum ticket size of ₹50 Lakhs per SEBI regulations
  • Suitable solely for Aggressive risk profiles with 5+ year horizons
  • Comprehensive evaluation of manager track record and performance fee hurdles
  • Concentration and illiquidity risks explicitly documented
Min ₹1 Crore

Alternative Investment Funds (AIF)

  • Statutory minimum ticket size of ₹1 Crore for accredited investors
  • Category I, II, III lock-in rules, drawdown structures, and tax pass-through explained
  • Capital call commitments and illiquidity strictly evaluated
  • Suitable strictly as a private equity / venture diversification tool

Formal Declaration — Product Selection Policy

ARN-367223

I, Devansh S Mehta (Director), on behalf of FINWISDOM FINANCIAL SERVICES PVT LTD (ARN-367223), hereby formally declare that this Fund & Product Selection Policy represents our unconditional commitment to objective, suitability-first advisory. Any breach of this policy may be reported directly to AMFI at igrc@amfiindia.com or SEBI SCORES at scores.sebi.gov.in ↗.

Devansh S Mehta

Director
FINWISDOM FINANCIAL SERVICES PVT LTD
AMFI ARN-367223 | CIN: U66190MH2026PTC472887

Registered Office

1203 Ajmera Sikhova Off LBS MARG, Lane Opp. Damodar Park, Ghatkopar West, Mumbai 400086
Phone: 9920217997 | Email: devansh@finwisdom.co.in

Effective Date: August 2026 | Last Updated: August 2026 | FINWISDOM FINANCIAL SERVICES PVT LTD | AMFI ARN-367223 | Reviewed Annually