Services & FAQ - Congruence Advisers

Equity Advisory service

This is NOT a multibagger stock advisory service, one should see this as an equity portfolio offering that

Offers a differentiated portfolio construct
Can deliver across market cycles
Has low overlap with the NIFTY 50
Offers optimized expense compared to mutual funds

Do read the FAQ section below for more details

Please read the Investor Charter before subscribing

Please see the status of complaints below

Write to us at info@congruenceadvisers.com for any queries

Investor Grievances & Status of Complaints

Dear Investor,

In case of any grievance/complaint against the Investment Adviser, please send an email to info@congruenceadvisers.com

In case you are not satisfied with the response, you can lodge your grievances with SEBI at http://scores.gov.in or you may write to any of the offices of SEBI. For any queries, feedback or assistance please contact SEBI Office or Toll free helpline at 1 800 22 7575/1 800 266 7575

Subscribe to our Equity Advisory Service

FAQ - Equity Advisory Service

Please reach us at info@congruenceadvisers.com if you cannot find an answer to your question.

How does the equity advisory engagement work?

We construct the portfolio, communicate the same at regular intervals and you invest accordingly. We charge you an annual advisory fee for this that is non-refundable. Please note that giving views on stocks outside of our coverage universe is outside the scope of engagement.

You perform the transactions through any online trading account of your choice. Your portfolio is completely under your control all the time, we do not manage your funds. We are fee only advisers.

You will need to commit some time (a few transactions a month at the maximum) to execute the transactions. Else, this model may not add value to you.

What documentation do we need from you to begin the engagement?

A T&C document as per SEBI guidelines and a simple risk profile that you need to fill up, sign and digitally send to us.

Since you will be making the transactions yourself, routine KYC updates with your broker as and when applicable. We have no role to play in this process.

What is the annual advisory fee?

We will charge you an annual fee of INR 20,000 + applicable taxes. We will be raising the invoice for this only after the documentation is mutually signed as per SEBI guidelines.

If you can construct a portfolio of INR 12+ lakh based on what we suggest by the end of the first year, that works out to an expense ratio of 1.6% of the corpus. Pretty much what any equity mutual fund with a differentiated portfolio would charge you. Bigger the corpus you can invest, lower will be your expense ratio.

Does one need an active investing approach? Why not passive funds?

A pertinent question, one can make well-reasoned arguments favoring either side. Our take on this is very simple – unless the portfolio is differentiated, refrain from paying 2% fee to active managers, instead reduce expenses by investing in index funds and ETF’s. Our suggestion is to stick to passive funds for large cap investing, active investing should be for differentiated portfolios that focus on businesses outside the NIFTY 50. This is the very game we are good at.

Are we value investors or growth investors?

If only things were that simple. We are more inclined towards investing in growth companies that meet our criteria where we do not have to overpay. We do not follow the “quality at any price” philosophy. What we do is well captured in the Investment Process section.

What kind of return can investors expect?

Our objective is to outperform the S&P BSE 500 by 4-5% p.a. over the investment horizon (3-5 years). Please note that there are no guaranteed returns on offer, the equity market is a fickle beast that can reward you well if you can play the game right.

We have a bigger focus on managing risks than on managing returns. This way we endeavor to smoothen out the investing experience and focus on durability rather than on generating multi-bagger returns. There has been no shortage of stocks in our portfolio that have turned out to be multi-baggers but that was never the sole objective we started out with.

Good things take time to build, so do good portfolios. Please don’t expect earth shattering returns within a short span of time. It is very difficult to separate luck from skill in the short term.

How should one go about building the portfolio after subscribing?

We will send you a detailed FAQ note on this process. This is why we started with a limited set of like-minded investors and fine-tuned the approach before launching this service online.

How many stock recommendations can one expect in a year?

Wrong question, we build a durable equity portfolio for you; we do not recommend stocks. The offering is the equity portfolio and not individual stock recommendations.

We are not a tactical stock recommendation service where we commit to a specific number of stock ideas every year. We want investors to sign up if they are looking for a professional who can build an equity portfolio that can perform well across market cycles rather than chasing the elusive multibagger all the time.

What communication can you expect?

You should expect to receive communication on your registered email on the following lines

FAQ document on how to go about deploying capital
Portfolio Plan – List of stocks, allocation, recommended price range
Investment Rationale – Summary of what makes each of the stocks a good buy
Quarterly Earnings Summary – Published every 3 months
Market Commentary – On an average once in 45 days based on market conditions
ADD/PRUNE/EXIT calls – Based on market conditions

Can you lose money?

Yes, you can. There is no guarantee of positive returns in equity investing. However, if you stay the course (3-5 years) and execute well enough based on our portfolio plan, the possibility of losing money becomes very low. The risk of investing in equities goes down as the holding period goes up, we hope this is common knowledge by now.

All good. How do I subscribe?

Please express your interest by clicking on the Subscribe to Advisory Service button at the top of this page. It will ask you for your name and email address.

We will reach out to you with the necessary documentation and details on the on boarding process.

Investor Charter for Investment Adviser (IA)

As directed by SEBI circular for IA’s in December 2021

A. Vision and Mission Statements for investors

Vision

Invest with knowledge & safety.

Mission

Every investor should be able to invest in right investment products based on their

needs, manage and monitor them to meet their goals, access reports and enjoy

financial wellness.

B. Details of business transacted by the Investment Adviser with respect to the

investors

To enter into an agreement with the client providing all details including fee details,
aspect of Conflict of interest disclosure and maintaining confidentiality of
information.
To do a proper and unbiased risk – profiling and suitability assessment of the
client.
To obtain registration with Know Your Client Registration Agency (KRA) and
Central Know Your Customer Registry (CKYC).
To conduct audit annually.
To disclose the status of complaints in its website.
To disclose the name, proprietor name, type of registration, registration number,
validity, complete address with telephone numbers and associated SEBI
regional/local Office details in its website.
To employ only qualified and certified employees.
To deal with clients only from official number
To maintain records of interactions, with all clients including prospective clients (prior to onboarding), where any conversation related to advice has taken place.

C. Details of services provided to investors (No Indicative Timelines)

Onboarding of Clients

Sharing of agreement copy
Completing KYC of clients

Disclosure to Clients

To provide full disclosure about its business, affiliations, compensation in
the agreement.
To not access client’s accounts or holdings for offering advice.
To disclose the risk profile to the client.
To provide investment advice to the client based on the risk-profiling of the clients and suitability of the client.

D. Details of grievance redressal mechanism and how to access it

In case of any grievance / complaint, an investor should approach the concerned Investment Adviser and shall ensure that the grievance is resolved within 30 days.
If the investor’s complaint is not redressed satisfactorily, one may lodge a complaint with SEBI on SEBI’s ‘SCORES’ portal which is a centralized web based complaints redressal system. SEBI takes up the complaints registered via SCORES with the concerned intermediary for timely redressal. SCORES facilitates tracking the status of the complaint. Investors may access SCORES website here https://scores.gov.in/scores/Welcome.html
With regard to physical complaints, investors may send their complaints to: Office of Investor Assistance and Education, Securities and Exchange Board of India, SEBI Bhavan, Plot No. C4-A, ‘G’ Block, Bandra-Kurla Complex, Bandra (E), Mumbai – 400 051.

E. Expectations from the investors (Responsibilities of investors)

Do’s

i. Always deal with SEBI registered Investment Advisers.

ii. Ensure that the Investment Adviser has a valid registration certificate.

iii. Check for SEBI registration number. Please refer to the list of all SEBI registered Investment Advisers which is available on SEBI website in the following link:

https://www.sebi.gov.in/sebiweb/other/OtherAction.do?doRecognisedFpi=yes&intm

Id=13)

iv. Pay only advisory fees to your Investment Adviser. Make payments of advisory

fees through banking channels only and maintain duly signed receipts

mentioning the details of your payments.

v. Always ask for your risk profiling before accepting investment advice. Insist that

Investment Adviser provides advisory strictly on the basis of your risk profiling and

take into account available investment alternatives.

vi. Ask all relevant questions and clear your doubts with your Investment

Adviser before acting on advice.

vii. Assess the risk–return profile of the investment as well as the

liquidity and safety aspects before making investments.

viii. Insist on getting the terms and conditions in writing duly signed and stamped.

Read these terms and conditions carefully particularly regarding advisory fees,

advisory plans, category of recommendations etc. before dealing with any

Investment Adviser.

ix. Be vigilant in your transactions.

x. Approach the appropriate authorities for redressal of your doubts / grievances.

xi. Inform SEBI about Investment Advisers offering assured or guaranteed returns.

 Don’ts

xii. Don’t fall for stock tips offered under the pretext of investment advice.

xiii. Do not provide funds for investment to the Investment Adviser.

xiv. Don’t fall for the promise of indicative or exorbitant or assured returns by the

Investment Advisers. Don’t let greed overcome rational investment decisions.

xv. Don’t fall prey to luring advertisements or market rumors.

xvi. Avoid doing transactions only on the basis of phone calls or messages from

any Investment adviser or its representatives.

xvii. Don’t take decisions just because of repeated messages and calls by Investment

Advisers.

xviii. Do not fall prey to limited period discount or other incentive, gifts, etc. offered by

Investment advisers.

xix. Don’t rush into making investments that do not match your risk taking

appetite and investment goals.

xx. Do not share login credential and password of your trading and demat accounts

with the Investment Adviser.