Statutory Disclosures

1. Registration & Identity

Investors may verify the SEBI registration status of the Adviser at any time on www.sebi.gov.in → Intermediaries → Investment Adviser → search by registration number INA000021331.

2. Fee Structure

Finwiser operates on the Fixed Fee mode permitted under Regulation 15A of the SEBI (Investment Advisers) Regulations, 2013. Fees are disclosed below and specified in detail in the Investment Advisory Agreement executed with each client.

2.1 Annual Cap

The total annual fee per Client Family shall not exceed the cap prescribed by SEBI under the IA Regulations — currently ₹1,51,000 per annum per family of clients for the Fixed Fee mode. Finwiser's fee levels are well below this cap.

2.2 Payment Channels

Fees are payable exclusively to the declared bank account of the Investment Adviser through the following electronic channels:

• UPI to the declared Finwiser UPI handle
• Net banking / IMPS / NEFT / RTGS to the declared account
• Card or subscription payment via the in-app payment gateway

2.3 Refund & Termination

• The one-time Advisory Unlock fee (₹49) is non-refundable once the personalised advisory report has been delivered, except as required under Applicable Law or where the report is not delivered or is materially defective.
• The ongoing advisory subscription (₹199/month) may be cancelled at any time; no further charges apply from the next billing cycle.
• Pro-rata refunds for the current billing period are not provided unless required under Applicable Law.

2.4 Fee-Mode Lock-In

Per Regulation 15A(2) of the SEBI (Investment Advisers) Regulations, 2013, once a fee mode has been opted for (Fixed Fee or AUA-based), the Investment Adviser cannot change the mode for at least 12 months from the date of opting. Finwiser is currently in Fixed Fee mode; the next eligible date to consider a mode change is on or after 04 November 2026 (being 12 months from SEBI registration on 04-Nov-2025). Any mode change, if effected in the future, will be disclosed here and communicated to existing clients in advance.

2.5 Changes to Fee Amounts

Any change in the fee structure or amounts will be communicated to clients by at least 21 calendar days' prior written notice (email). Revised fees take effect only upon the client's continued subscription after such notification; a client who does not wish to continue at revised fees may terminate at no further charge.

3. Conflict of Interest Disclosure

In compliance with Regulations 15, 15A, and 22 of the SEBI (Investment Advisers) Regulations, 2013, Finwiser makes the following disclosures:

• The Investment Adviser does not receive any commission, trail fee, referral fee, or indirect consideration from any mutual fund AMC, broker, insurance company, bank, NBFC, product manufacturer, or other intermediary in respect of products on which advice is rendered.
• The Investment Adviser does not distribute mutual fund units, insurance products, or any other financial products; no ARN, IRDA agency, or similar licence is held.
• The Investment Adviser does not engage in any other SEBI-regulated activity (such as Research Analyst, Portfolio Manager, Stock Broker) that could create a conflict.
• Fees are received only from the client being advised, in accordance with Regulation 15(2) of the IA Regulations.
• The Investment Adviser does not have any material pecuniary relationship with issuers of securities that could reasonably be expected to impair the advice given.
• Immediate relatives of the Investment Adviser (spouse, parents, children, siblings, as defined under SEBI regulations and the Companies Act, 2013) have no commercial relationship with any mutual fund AMC, insurance company, NBFC, broker, or other product manufacturer/distributor on whose products advice is rendered. Related-party arrangements with Finwiser Technologies LLP (the platform operator) are limited to platform-service provision and are disclosed separately under the entity structure; they do not create a conflict on advisory output, since the LLP does not distribute products and does not share in advisory fees.
• Any future arrangement that could potentially create a conflict will be disclosed to clients in advance, and clients will be informed of their options.

4. Execution & Distribution Services

Finwiser does not provide execution or distribution services. Specifically:

• Finwiser does not place, route, or execute any buy / sell / switch order on behalf of the client.
• Finwiser does not hold securities, cash, or any other client asset on custody.
• Finwiser does not act as a distributor of mutual funds, insurance, NPS, or any other product.
• All execution decisions remain with the client, who may execute through any platform of their choice. Finwiser may provide educational information about Direct Plans and reputable execution platforms, but does not endorse or benefit from any specific execution channel.

In line with Regulation 22 of the IA Regulations, the Investment Adviser maintains arm's-length separation between advice (regulated) and execution (not offered). This separation eliminates any incentive to recommend products based on execution revenue.

5. Risk Profiling & Suitability Assessment

In compliance with Regulations 16 and 17 of the SEBI (Investment Advisers) Regulations, 2013, Finwiser follows a documented Risk Profiling and Suitability Assessment process:

5.1 Risk Profiling

• Every client completes a structured risk profiling questionnaire before any advice is rendered.
• The questionnaire assesses: age, income stability, dependents, investment horizon, knowledge / experience, attitude to loss, and reaction to market scenarios.
• A written Risk Profile report is generated and shared with the client; the client confirms the report before proceeding.
• Risk profiles are reviewed at least annually and on the occurrence of material life events (marriage, children, job change, significant income change).

5.2 Risk Profiling Methodology (Overview)

Summary of the scoring and mapping methodology used (detailed Standard Operating Procedure is maintained internally and available on request to the Grievance Redressal Officer):

1. Inputs — 7 core questions + 2 contextual questions: age (drives risk-capacity: time to retirement, earning years remaining), investment horizon, income stability and sources, dependents and obligations, investment knowledge / experience, loss tolerance (quantified through scenario simulation), reaction to a simulated market drawdown, plus two contextual questions on liquidity needs and existing debt burden.
2. Scoring: each response maps to a numeric score; weighted-sum produces a composite risk score normalised to 0–100.
3. Category mapping (composite score → category): 0–25 Conservative, 26–50 Moderate, 51–75 Aggressive, 76–100 Very Aggressive.
4. Asset-allocation bands (category → indicative bands):
   • Conservative: Debt / Fixed Income 70–90%, Equity 10–25%, Others 0–5%.
   • Moderate: Debt 40–60%, Equity 30–55%, Others 0–10%.
   • Aggressive: Debt 20–35%, Equity 55–75%, Others 0–10%.
   • Very Aggressive: Debt 10–25%, Equity 70–85%, Others 0–10%.
5. Exception protocol: where a client's self-assessed risk appetite differs from the computed category, the deviation is documented in writing, the client is explicitly warned of the suitability implication, and a confirmation is obtained before any deviating advice is rendered.
6. Glide path: goal-linked allocations are de-risked automatically as the goal deadline approaches, with equity exposure reduced approximately 8% per year within 7 years of the target date, subject to a floor equal to the lower end of the target category's asset-allocation band (so equity is never reduced below the category minimum).

The complete methodology document (including question bank, scoring matrix, and exception-handling workflow) is maintained under Regulation 19 record-keeping and will be furnished on request or to any regulator / auditor as required.

5.3 Suitability Assessment

• Every recommendation is assessed for suitability against the client's risk profile, financial situation, and stated goals.
• Unsuitable products are not recommended. Where a client insists on a product that is unsuitable to their profile, the Adviser records this exception in writing.
• Asset allocation ranges are derived from the risk profile and goal horizon; recommendations stay within these ranges or, where they deviate, the deviation is explained in writing.

5.4 Record Keeping

Per Regulation 19 of the IA Regulations, Finwiser retains the following records for a minimum of five years:

• KYC records of all clients;
• Rationale of advice along with communication of advice;
• Risk profile and suitability assessment documentation;
• Investment Advisory Agreement, fees charged, and the advice register.

6. Investment Advisory Agreement & MITC

An executed Investment Advisory Agreement (IAA) is a pre-condition for the rendering of any advice. The agreement includes:

• Scope of services and exclusions;
• Fee structure and payment mode;
• Risk profile and suitability framework;
• Conflict-of-interest disclosures;
• Grievance redressal and escalation mechanism;
• Termination rights and consequences;
• Governing law and dispute resolution.

The Most Important Terms & Conditions (MITC) — a one-page summary of the IAA — is provided along with the full agreement and highlights the key commitments both parties are making.

Read the full Investment Advisory Agreement and MITC.

7. Regulatory Bodies & Grievance Redressal

For Finwiser's internal grievance mechanism, see the Investor Charter — Grievance Redressal section and the Monthly Complaints Status page.

8. Cautionary Notes for Investors

• Investment in securities is subject to market risk. Past performance is not indicative of future returns. Read all scheme-related documents carefully before investing.
• No guaranteed returns. Finwiser does not promise or imply any minimum or assured return on any investment. Any such claim made by a third party in the name of Finwiser should be reported to Finwiser and to SEBI immediately.
• Advice only, no execution. Finwiser provides advice; the responsibility to execute, hold, or sell remains with the client.
• Beware of impersonation. Finwiser communicates only through its official email domains (finwiser.org) and the registered mobile number disclosed above. The Adviser will never ask for OTPs, banking passwords, UPI PINs, or payments to personal accounts.
• Verify before engaging. Always verify SEBI registration at sebi.gov.in before paying advisory fees to any party.
• Tax implications. Investment decisions may have tax implications. Finwiser may point out general tax considerations; for definitive tax advice, clients are encouraged to consult a qualified tax professional.

9. Annual Compliance Audit

In compliance with Regulation 19(3) of the SEBI (Investment Advisers) Regulations, 2013, the Investment Adviser is required to conduct an annual audit of compliance with the Regulations by an independent member of the Institute of Chartered Accountants of India (ICAI), the Institute of Company Secretaries of India (ICSI), or the Institute of Cost Accountants of India (ICAI–CMA).

Audit observations, remedial actions, and any qualifications will be disclosed on this page in line with SEBI's transparency framework, once the first annual audit is complete. This page will be updated immediately upon receipt of the audit report.