29k Investment Advisers Private Limited (29k) is committed to assisting you meet your financial goals. 29k provides you with the access to investments in a way that best suits your needs. We believe that the foundation of a dynamic relationship between our Investment Advisers and Clients is a comprehensive understanding of the mutual expectations of both parties.

This disclosure aims to help you with understanding your relationship with 29k, the services we offer, the features of your account and how it operates; and our responsibilities to you. You may as well refer to the sample investment advisory services agreement here.

'You' 'Your' in this section refers to the prospects, and clients.

Your input through the “Know Your Client” (CKYC) information you provide in the Client Questionnaire is essential to ensuring we meet your expectations.

1. Investment Advisory Services Responsibilities

  • a. Client Responsibilities

You shall be responsible for all the investment decisions made, irrespective of the fact whether you have relied on the advice of your Investment Adviser. You are also responsible for providing accurate and up-to-date KYC information. It is also your responsibility to review all product disclosure documents, including prospectuses and Investment report that we provide concerning the investments you make in your account at 29k. You should review all transaction confirmations and account statements carefully and immediately report errors, omissions, questions, or concerns to your Investment Adviser.

  • b. Investment Adviser's Responsibilities

Your Investment Adviser is responsible for providing suitable and unbiased investment recommendations to you that meet the standard of care expected of a trained investment professional based on the KYC information that you provide to us. You are responsible for making all investment decisions in your account.

29k feels strongly that it is essential for you to completely understand the steps you have taken in the investment process and to ask your Investment Adviser to clarify any items that you do not completely understand.

Registration granted by SEBI, membership of BASL and certification from NISM in no way guarantee performance of the intermediary or provide any assurance of returns to investors.

Investment in securities market are subject to market risks. Read all the related documents carefully before investing.

2. Investment Advisory Fees


Advisory fees specified under the regulations and relevant circulars issued there under,

Sr. No.

Mode of charging fees

Limits under the IA regulations


Assets under Advice


not exceeding 2.5 percent of AUA per annum per Client


Fixed Fee

not exceeding INR 1,25,000 per annum per Client


Performance Fees

Only an accredited investor can subscribe to this mode

The above table is for information purposes only and reflects the modes of charging fees permitted under the Regulations.

The billing is quarterly. The fee details will be elaborated on in the investment advisory services agreement.

3. How we determine what investments are suitable for you

Before we provide you with any investment recommendations, we will need to ascertain if our recommendations are suitable for you and are in line with the information you provided. It is imperative that the KYC information (financial and non-financial) documented in our records is kept up-to-date and accurate. We understand that individuals maybe concerned about sharing some of this information; however, without all the material facts we may not be able to make suitable assessments that properly reflect your actual circumstances.

The suitability factors that guide us in our decision as to an investment’s suitability include what we understand to be your current:

i) Financial Status: What financial assets (deposits, investments) and liabilities (debt, mortgage) you have and the sources and amount of your income – we will consider the size of any transaction compared to the overall value of your net financial assets (assets minus liabilities).

ii) Investment Knowledge: Whether you consider yourself, or we understand you, to be a novice at investing, have some knowledge, or feel you understand some of the new more complex financial

iii) Investment Objectives: What you tell us are your specific financial goals; this will assist us in determining how to balance the desire to keep your money safe (not lose principal), earn income, and increase your capital through growth in the market value of your

iv) Time Horizon: When you expect to need your financial assets, for example, to buy a house, pay for education or enter retirement – In retirement, this may also include consideration of tax requirements to withdraw minimum

v) Risk Tolerance: Whether, even if you have many years to earn and save, you feel comfortable with the possibility of losing money in your It is crucial that you do not overestimate your appetite for risk when informing us of your risk tolerance; the information you provide us with is crucial when we assess the suitability of any investments you make.

vi) Investment portfolio composition and risk level: How the purchase or sale of particular securities affects holdings in your overall account(s) in terms of allocation of holdings between debt, equity and other classes, and the riskiness of the assets held as captured by your investment policy Your risk profile is critical. Some of the above    factors are relatively easily answered while some are more complex, particularly your risk tolerance. The combination of these factors that makeup your profile will help us suggest the allocation of your holdings.

4. Commission

Mutual fund managers usually charge a management fee and charge transaction costs and other expenses to the fund, which reduces fund performance. The amount of these fees and expenses as a percentage of the fund’s net asset value from time to time is often referred to as the fund’s management expense ratio, or MER. In addition, mutual fund managers, out of their fees, may pay trailing commissions to your mutual fund distributor. Trail commission is calculated as a percentage of the net assets attributable to the Units sold by the distributor. The commission payable is calculated on the daily balances and paid out periodically to the distributor as per the agreement entered into with AMC. The trail commission is normally paid by the AMC on a quarterly basis or monthly basis. As per the SEBI circular No. SEBI/IMD/CIR No. 4/ 168230/09 dated June 30 2009, the below link provides the brokerage report including details of the scheme wise disclosure of commission/ brokerage paid to 29k Investment Advisers Private Limited, due to the company’s association with the various empanelled fund houses. The company may receive mutual fund commissions from clients who have opted for distribution services

5. Dispute Resolution

All complaints or grievances can be forwarded to complaints@29kadvisers.com and the responsible 29k team member will ensure to take necessary fair steps and actions to address all complaints received.
The formation, interpretation and performance of this Agreement and any disputes arising out of it or in the event of failure to settle the dispute by mutual negotiations, it may be resolved by arbitration in accordance with provisions of The Arbitration and Conciliation Act, 1996, or any statutory modification or re-enactment thereof for the time being in force. Such Arbitration proceedings shall be held at Bangalore and the language of Arbitration will be English. The matter shall be referred to an arbitrator as selected by mutually by both the parties. The cost of arbitration will be borne as decided by the arbitrator. The award of the arbitrator will final and binding on both the parties.

SEBI has set up an online complaints redressal system SCORES for easy retrieval and tracking of complaints by investors. 29k will receive and redress the complaints lodged against it in accordance with the procedures prescribed by SEBI. However, it would be advisable that you may initially take up the grievance for redressal with the respective 29k team.

SMART ODR is the regulator’s attempt to combine online conciliation and online arbitration for resolution of disputes in the securities market. You can access the master circular on Online Resolution of Disputes in the Indian Securities Market here. SMART ODR can be accessed through the link SMARTODR.

To get in touch with our compliance officer, you can reach out to compliance@29kadvisers.com. If you have any grievances, feel free to address them in your message. Alternatively, you can also contact our compliance officer through our boardline at 9019110110.

6. Important Information

SEBI RIA Registration Number: INA200000365
Registration Type: Corporate
Address: #390, 7th Main, 9th Cross, Jayanagar II Block, Bengaluru-560011 (Address is under updation in SEBI website)
Phone Number: +91 90191 10110
Principal Officer: Mr. Prashanth Prabhu, Email ID: prashanth@29kadvisers.com
Nodal SEBI office Address: 2nd Floor, Jeevan Mangal Building, No.4, Residency Road, Bengaluru - 560025, Karnataka

7. Investor Charter

The Securities Exchange Board of India (hereinafter the ‘SEBI’) has recommended that we promote active client participation for a mutually successful relationship. Regulatory guidance (Securities and Exchange Board Of India (Investment Advisers) Regulations, 2013: General Obligations And Responsibilities) has formulated an investor charter to provide transparent, equitable and reliable markets with timely and accurate information dissemination for investors. It also aims to provide the highest standards of investor education, investor awareness and investor protection and timely services.

8. Investment Advisory Compliance Audit

Disclosure with respect to compliance with Annual compliance audit requirement under Regulation 19(3) of SECURITIES AND EXCHANGE BOARD OF INDIA (INVESTMENT ADVISERS) REGULATIONS, 2013 for last and current financial year are as under:

Sr. No.

Financial Year

Compliance Audit

Remarks, If any


FY 20 - 21



FY 21 - 22



FY 22 - 23


9. Annual Returns

MGT 7 Financial Year 2020-21
MGT 7 Financial Year 2021-22
MGT 7 Financial Year 2022-23