Harsh Roongta On What It Takes To Become A Registered Investment Advisor | New SEBI Rules Explained

Summary

The video discusses the recent consultation paper by SEBI on Registered Investment Advisers (RIAs) in India, aiming to ease the process of becoming an RA and increase their numbers. Harsh Jain, an RA, explains the benefits of becoming an RA, including the fee model and client satisfaction. He outlines the current regulations and proposed changes, such as the removal of net worth requirements and experience, making it easier to become an RA. Harsh also discusses the life of an RA, including regulatory compliances, fee structures, and the importance of cybersecurity and PMLA compliance. He addresses gaps in the consultation paper and encourages those interested in the profession to engage with ARYA, emphasizing it as a satisfying career.

Takeaways

• 📈 The Securities and Exchange Board of India (SEBI) has issued a consultation paper to ease the process of becoming a Registered Investment Adviser (RIA) and increase their numbers in India.
• 💼 Currently, there are approximately 995 RIAs serving a population of 1.4 billion, indicating a low number of RIAs relative to the population size.
• 🏫 To become an RIA, one must have a postgraduate degree in specific subjects like finance, accountancy, or economics, and pass certain NISM exams.
• 💼 The consultation paper proposes to remove the postgraduate requirement and reduce the net worth requirement, making it easier for individuals and corporates to become RIAs.
• 💼 The RIA profession is seen as more transparent and client-focused compared to traditional mutual fund distribution, where commissions can create conflicts of interest.
• 🔑 The consultation paper suggests that RIAs will be allowed to offer both advisory and distribution services, provided they are not offered to the same client.
• 📝 RIAs are subject to stringent compliance standards, including maintaining a client register, conducting risk assessments, and signing engagement letters outlining terms and conditions.
• 💻 The process of becoming an RIA has become more streamlined, with SEBI's application processing times typically around 30 days.
• 💼 The Association of Registered Investment Advisors (ARIA) provides support and guidance to budding RIAs, including clinics to answer questions about the application process.
• 💼 The fee structure for RIAs is regulated, with options for fixed fees or asset-based fees, and the consultation paper proposes more flexibility in fee structures.
• 🔒 RIAs must also comply with cybersecurity regulations and maintain records as per the Prevention of Money Laundering Act (PMLA).

Q & A

What is the current number of registered investment advisers (RIAs) in India?

As of the discussion, there are approximately 995 registered RIAs in India.

What is the purpose of SEBI's consultation paper on RIAs?

The consultation paper aims to ease the process of becoming an RA and increase the number of RIAs in India.

Why did the guest speaker choose to become a Registered Investment Adviser (RIA)?

The speaker became an RIA to provide transparent services to clients, charging fees directly from them and avoiding conflicts of interest that arise from earning commissions.

What are the current educational requirements to become an RA in India?

Currently, one must have a postgraduate degree in specific subjects like Finance, Accountancy, Economics, etc., to become an RA.

What changes are proposed in the consultation paper regarding the net worth requirements for individuals and corporates?

The consultation paper proposes to remove the net worth requirements, which are currently 1 lakh for individuals and 5 lakhs for corporates.

What is the significance of the removal of the net worth requirement for corporates?

The removal of the net worth requirement for corporates allows easier corporatization and reduces the barrier to entry for those wanting to offer investment advisory services.

How long does it typically take for SEBI to process an RA registration application?

Under the current regulations, it typically takes about 30 days for SEBI to process an RA registration application.

What is the role of the Association of Registered Investment Advisers (ARIA)?

ARIA is a Section 8 not-for-profit company formed to promote investor interests by elevating the standards of the investment advisory profession. It provides support and guidance to budding RAs.

What are the regulatory compliances that an RA has to adhere to in a typical year?

An RA must maintain a client register, provide suitable advice based on the client's risk profile and goals, and undergo a compliance audit at the end of the year.

How are fees typically charged by RAs and what are the regulatory limits?

Fees can be charged either as a fixed fee capped at 1 lakh 125,000 or as a percentage of assets under advice, capped at 2.5%. Switching between fee structures requires a minimum of 12 months between changes.

What are the implications of the consultation paper's proposals on the scope of services an RA can provide?

The consultation paper proposes restrictions on the scope of services, particularly concerning products not regulated by SEBI or other Indian regulators, which could limit the comprehensive financial planning RAs can offer.

Outlines

00:00

📈 Introduction to Registered Investment Advisers (RIAs) in India

The script begins with a discussion on the recent consultation paper released by SEBI (Securities and Exchange Board of India) concerning Registered Investment Advisers (RIAs) or RAAs. The paper aims to simplify the process of becoming an RA and increase their numbers in India, which currently stands at 995 for a population of 1.4 billion. The guest, Har Runa, an RA himself, explains his transition from a mutual fund distributor to an RA, emphasizing the importance of fee-only models for transparency and the professional satisfaction it brings. He also touches on the benefits of the RA model from a client's perspective, including the growing demand for direct plans and the potential for corporatization and offering a range of services if the consultation paper is accepted.

05:00

🏫 Becoming a Registered Investment Adviser (RIA)

The second paragraph delves into the current regulations for becoming an RA in India, which include having a postgraduate degree in finance or related fields, passing specific NISM exams, and meeting a net worth requirement. The consultation paper proposes to eliminate the postgraduate requirement and the net worth criterion, which would significantly lower the barriers to entry. Har Runa also mentions the need for experience in finance, which the paper suggests removing. Additionally, he discusses the process of applying for registration with SEBI and the time it typically takes, as well as the support provided by the Association of Registered Investment Advisers (ARIA) for budding RAs.

10:02

📚 Life of an RA: Regulatory Compliances

This section outlines the regulatory compliances that RAs must adhere to in a typical year. These include maintaining a client register with detailed information and investment advice, undergoing a compliance audit, and having a grievance procedure in place. The RA must also ensure that any advice given is suitable for the client's risk profile, resources, and goals. The script also mentions the need for RAs to have a Letter of Engagement that outlines the terms and conditions of the service, including the fee structure, which must be clearly stated and cannot be changed within the same year under current regulations.

15:03

💼 Practical Aspects and Fee Structures for RAs

The fourth paragraph discusses the practical aspects of being an RA, such as assisting clients with execution without charging for it, and the fee structures that RAs can adopt. RAs can charge a fixed fee or a fee based on assets under advice, with specific caps in place. The consultation paper proposes more flexibility in switching between fee structures. Har Runa also mentions the need for RAs to conduct a compliance audit at the end of the year, file compliance reports, and maintain transparency on their websites regarding grievance procedures and complaint statuses.

20:03

🔒 Cyber Security and PMLA Compliance for RAs

This section highlights the additional compliances RAs must adhere to, such as cyber security awareness programs and maintaining records as per the Prevention of Money-Laundering Act (PMLA). RAs are required to report suspicious transactions to the Financial Intelligence Unit and ensure data storage complies with regulations. The script also addresses the ambiguity in the consultation paper regarding advice on products not regulated by SEBI or other Indian regulators and the challenges this poses for RAs in providing comprehensive financial planning.

25:03

📖 Addressing Gaps and Positive Aspects of the Consultation Paper

The final paragraph addresses gaps in the consultation paper, such as the restriction on the scope of advice RAs can provide and the treatment of trading call providers. Har Runa emphasizes the positive aspects of the paper, including relaxations on qualifications, experience, and net worth requirements, and the simplification of corporatization. He also discusses the need for clarifications on various points and the hope that SEBI will address these issues. The script concludes with a call to action for those interested in becoming RAs and a reminder that the profession can be satisfying and is not as difficult as it may seem.

Keywords

💡Sebi

Sebi refers to the Securities and Exchange Board of India, which is the regulator for securities markets in India. In the video, Sebi is discussed in the context of issuing a consultation paper aimed at easing the process and increasing the number of Registered Investment Advisers (RIAs) in India.

💡Registered Investment Advisers (RIAs)

Registered Investment Advisers, or RIAs, are individuals or firms that provide professional investment advice for a fee. The video discusses the current low numbers of RIAs in India and the potential for growth following Sebi's consultation paper.

💡Consultation Paper

A consultation paper is a document issued by a regulatory authority like Sebi to seek public input on proposed changes to regulations. The video discusses the consultation paper's aim to ease the process of becoming an RIA and increase their numbers in India.

💡Mutual Fund Distributors

Mutual Fund Distributors are entities that sell mutual fund products and often earn commissions on the funds they recommend. The video contrasts them with RIAs, who typically recommend direct plans and do not take commissions, instead charging a fee for their advice.

💡Fee Model

The fee model refers to a system where an adviser charges a fee for their services, as opposed to earning commissions on products sold. The video discusses the speaker's transition from a commission-based model to a fee-only model, which is more transparent and aligns the adviser's interests with the client's.

💡Net Worth Requirement

Net worth requirement refers to the minimum amount of money or assets an individual or corporation must have to qualify for a particular license or registration. The video discusses how the consultation paper proposes to remove the net worth requirement for corporates, making it easier to become an RIA.

💡NISM Exams

NISM stands for National Institute of Securities Markets, which conducts exams for various financial market certifications. In the video, passing the NISM exams (specifically 10A and 10B) is mentioned as a requirement to become an RIA.

💡Compliance

Compliance in the context of the video refers to the adherence to rules and regulations set by Sebi for RIAs. The video discusses various compliance requirements RIAs must meet, such as maintaining client records, conducting suitability assessments, and undergoing annual compliance audits.

💡Corporatization

Corporatization in this context refers to the process of structuring a business as a corporation. The video mentions that the consultation paper aims to make corporatization easier for RIAs by removing net worth requirements.

💡Assets Under Advice (AUA)

Assets Under Advice (AUA) refers to the total value of the assets for which an RIA provides investment advice. The video discusses how RIAs can charge fees based on AUA, with a maximum cap of 2.5%.

💡Cyber Security Compliance

Cyber security compliance refers to the set of regulations and practices that require financial institutions to protect sensitive data from cyber threats. The video mentions that RIAs must comply with cyber security regulations, including conducting awareness programs and maintaining records as per the Prevention of Money Laundering Act (PMLA).

Highlights

Sebi's consultation paper aims to ease the process of becoming a Registered Investment Adviser (RIA) and increase their numbers in India.

Currently, there are only 995 registered RIAs for a population of 1.4 billion in India.

The speaker, an RA himself, discusses the reasons for becoming an RA, including the shift from commission-based to fee-based models.

Mutual fund Distributors take commissions on funds recommended, whereas RIAs recommend direct plans without commissions.

The professional satisfaction of being transparent about fees and earnings is a key motivator for becoming an RA.

Clients are increasingly seeking direct plans due to social media and media influence, making it essential for professionals to offer this option.

To become an RA, one must have a postgraduate degree in specific subjects, pass certain exams, and meet net worth requirements.

The consultation paper proposes removing the postgraduate requirement and net worth for corporates, making it easier to become an RA.

The application process for RA registration with Sebi has become more streamlined, taking about 30 days.

The Association of Registered Investment Advisors (ARIA) supports new RAs with clinics and guidance on the application process.

RIAs must maintain a client register, conduct KYC, risk profiling, and sign a letter of engagement outlining terms and conditions.

RIAs cannot charge for execution and must provide suitable advice based on the client's risk profile and goals.

RIAs are subject to compliance audits and must report any shortcomings and take necessary actions.

RIAs must display compliance reports and grievance procedures on their websites or communicate them to clients.

Fees for RIAs are regulated, with options for fixed fees or asset-based fees, and new regulations allow more flexibility.

RIAs must comply with cybersecurity regulations and report suspicious transactions under the PMLA.

The consultation paper has addressed several issues, including qualifications, experience, and net worth requirements, but some gaps remain.

The paper proposes that trading call providers who give advice on a one-to-one basis can be RIAs, but this may need further clarification.

ARIA and the speaker advocate for a more flexible approach to RIA regulations to better serve clients and clarify the scope of services.

The speaker reassures potential RAs that the profession is satisfying and not as difficult as it may seem, encouraging those interested to pursue it.

Transcripts

[Music]

as many of you would have noticed sebi

has come out with a big consultation

paper on registered investment advisers

or

raas uh the idea is to ease the process

of becoming an RA and to increase the

number of raas in India which currently

is wul low um there are about 900 or so

registered r 995 995 to be precise in a

population of 140 crores so to decode

what's happening with uh the whole R uh

regulation scenario we have U har Runa

who is himself an RA and he will take us

through the wise the house and the what

might bees of of the profession so har

thank you so much for joining us thank

you n for having me here shall we start

with the why why should anyone become an

R

so why should you become an raia let me

answer that from two sides one I will

answer why did I become an raia I think

like most people when I got into this

side of the profession I I had this nice

little cozy

Ria I would charge for advice and then I

would get Commission on the mutual funds

much before it became compulsory I had

switched to the fee completely the fee

model and among other things one thing

that helped me do so was sorry hush just

to break this down for our viewers so

there are mutual fund Distributors who

take a commission on whatever funds that

they recommending and there are Ras who

only recommend direct plans so they

can't take any commissions so typically

they either charge a fixed flat fee or

they might take a percentage which is

upfront disclos to you go it has to be

disclosed because the client will be

paying it so I was talking about why I

became an

from being an RA plus a distributor uh

and that was because of many things but

basically I I had this very close friend

of mine who was also a client uh and I

waved the fees for him because he was a

friend uh and I just made the commission

which

wasn't much very high and you know uh I

realized over time as I the relationship

of the professional relationship

progressed that he thought he was doing

me a favor okay because he was giving me

business and on which I was earning

commission and I thought I was doing him

a favor because I was not charging him a

fees uh and you know I said no this is

not right my service is to the client

okay and therefore I must take the money

from the client he must know what he is

paying what am I earning from him I

myself done the distribution there's

absolutely no uh nothing wrong with

distribution it just gave me more

satisfaction to be an

raia let me now answer from the client's

perspective I think each of the mutual

fund Distributors today knows that as

their clients go up the curve given the

social media noise given all the media

noise that is there clients are going to

ask for direct plans clients are going

to ask for these services having that

option even if you don't believe in it

having that option I think is a must for

any serious professional who's not doing

this part time and today assuming the

consultation paper goes through and we

will talk about that a little later

corporatization will become very easy

the the net worth requirements are being

removed and that means your ability to

do both not with the same client but

being able to offer both

Services is going to be there for the

asking and I would say that every

serious

distributor professional should look at

this option very very seriously yeah

yeah so next uh let's talk about how to

become an raia um so first of all I'm

going to go through the list and if I

miss something harsh correct me so you

need to have a uh so first we'll discuss

the current regulation and then what has

been proposed So currently you need to

have a postgraduate degree in specific

subjects like Finance accountancy

economics Etc uh you need to pass the

10A and 10B nism

exams and uh you need to have for

individuals a net worth of uh 1 lakh

it's very little whatever it is some

small net worth and for corporates 50

lakhs 5 lakhs which was a big

deterent um and if the consultation

paper is accepted then the

postgraduation requirement goes away you

can be uh a graduate but in specific

areas like finance accountancy and so on

um you uh also need to still pass the NM

108 10B

exam um and the net worth also goes away

so especially for corporates that's a

big big deal because you suddenly go

from needing to have 50 lakhs of of net

worth all the way down to uh I mean it

whatever it takes to float a corporate

because net worth requirement will be

done away I think the one thing you

missed nil was experience oh yes sorry

sorry currently yes you need to have 5

years of experience in finance which

will go away with the consultation paper

um in terms of net worth although that

will not be required you still have to

deposit a sum of money with the stock

exchange so I think up to 1,000 clients

it's 5 lakhs and more than 1,000 is 10

lakhs so it's still much much lower than

the current 50 lakh figure and that's

for your raia clients yeah so I mean if

as a corporate if you're doing both this

deposit amount is required for raia

clients if you have less than 150 raia

clients then the figure is 1 lakh yeah

yeah um once you have all of these

things in place you have to apply to

sebi for registration typically how long

does it take for sebi to process and

application so I think things used to be

a little different I think now things

are pretty much uh more streamlined uh

of course once the new consultancy a new

consultant paper becomes effective it

might take a little time to settle down

but already when people are applying

under the existing regulations things

have become much faster typically it

would take about 30 days I would advise

people who are listening to this that we

do what we are what we when I say we I'm

talking of the association of registered

investment advisors which is a Section 8

not for profit company uh which uh you

know we have uh formed to promote

investor interests by elevating the

standards of the investment advisory

profession if you are an raia you can

become a member ra Arya holds what we

call Ara CL raia clinics uh where buding

Ras we sort of take them through the

process among them is a process to

answer questions on about applications

and how often are these clinics held so

right now they are held on demand okay

we're very very happy to if if you have

sufficient demand from your readers we

very happy to Fantastic so viewers if

you're interested in knowing more and

engaging directly with the association

uh you can reach out to Arya on ar.org

which is

ar.org doin sorry which is the website

or to harsh on his personal handles or

to me and I'll forward any requests to

ARA absolutely um so harsh now let's

talk about the life of an raia uh in a

typical year what are the regulatory

compliances that you have to

do so I think again uh people will think

and probably rightly so that the

compliance standards on RIS are far more

stringent than say they are on uh other

professions or Distributors definitely

it is much more stringent uh but if I

break it that down for you uh one

Whatever advice you give whatever

clients you have you need to maintain a

client register it can be the good old

register where each client their details

uh uh their kyc details every investment

advice that you gave them needs to be

there in a register okay it can be

electronic as well I I frankly don't

know a single raia who maintains it in

the register so everybody is electronic

there are softwares out there the most

common software is the Microsoft Office

uh product uh in fact H if he could take

a step back and you know I come to you

as a client what do you have to do as an

ra to onboard me like what what steps

does that

involve so before we can take on a

client we have to do a

kyc uh we have to do a you

know a a risk profile we have to sign a

letter of

Engagement okay uh which outlines all

the terms and conditions and there are

certain responsibilities that an

has towards the client and certain

rights of the client that have to be

compulsorily mentioned yeah uh that have

to be there in the letter of Engagement

some of them like the fee structure Etc

have to be in the first page so I mean

it's a very laid down

regulated uh service and I think that is

good both for the ra and for the client

as well uh so that has to to be done uh

once that is done uh then there are

practical things these are regulatory

things then there are practical things

that each client each raia will do

depending on what they will do for the

client if I'm going to do mutual funds

maybe I will open an account with a

platform sure if there are Ras who do

Equity advice they may you know open a

dmat account open ask the client to open

or they may use the client's existing

dmat account Etc so there could be

non-regulatory things and the regulatory

things is what I told you about so just

to clarify on the non regulatory things

the execution as it is called RIS are

not allowed to charge on that right

absolutely we we we can assist clients

with the execution we cannot make money

from the execution right right okay so

we discussed uh the register and the at

the time of onboarding the fact that

there has to your risk assessment and uh

the agreement has to be signed um what

else needs to be done in a year from

from an raia's point of view so

obviously any advice needs to be

suitable based on the risk profile of

the clients based on the resources based

on his goals you need whatever advice

you are giving needs to be suitable and

that suitability needs to be captured it

is uh I mean whatever it needs to be

documented and be aail ailable for a

compliance audit uh so that is ongoing

right uh at the end of the year there is

a compliance audit that needs to be done

this is done by a CA or by so if if you

are a non- individual and subject to

statutory audit uh it had to be done by

your auditor earlier uh now I think they

are under the Consulting consultation

paper I think it can be done by any

chartered accountant right

uh it it has to be done if it if it

requires if it points out certain

shortcomings then an uh action taken

report also needs to be adopted by the

uh Board of the company Etc and that

needs to be filed with BC ASL earlier

now with Bombay Stock Exchange which is

the first line regulator for Ras uh also

Al uh you need to file the compliance

report status on your website you also

on your website need to show what is the

grievance procedure there are certain

things that uh you need to show on your

website what is the complaint status how

many complaints have come on scores so

there is again a set of things and if

you don't have a website how do you show

this then you have to send it to the

client okay youve send an email to the

client okay okay uh um but in today's

day and world I think almost everybody

has a a website

yeah okay um in terms of fees typically

how are fees charged how often are fees

charged so the uh the fee structure is

regulated uh you could charge fee under

two kinds of mechanism uh either you

charge a fixed fee that is maximum

capped at 1 lakh

125,000 or you could charge a fee based

on the assets under advice that is

maximum 2 and a

half% you cannot switch from one to the

other under existing regulations if you

have charged a fixed fee then before you

switch see uh uh you know uh investment

advisory relationship is a long-term

relationship typically so you cannot

switch from a fixed fee to variable or

variable to fixed within a year minimum

12 months have to go by that is the

existing

regulations the under the proposed

regulations it's far more flexible exact

shape I think we will know

as but you can switch for sure under the

new regulations yes and you can only

charge up to two quarters of Advance

what you could charge in advance is uh

two quarters yes

right um so there are many technical

points with this nail which I think are

a little bit too much for a okay I'll

just I'll just go into two more the idea

is to give people the reality and the

checklist that it involves uh without

scaring anyone so uh just two more

things one is that the cyber security uh

compliance has to be done could you

elaborate on that so there is a I mean

you have to do an awareness this is not

a sebbi regulation as such it's a

certain it's a regulation from May the

ministry of electronics electronics and

you know goes through all the Regulators

all regulated entities have to go

through that cyber awareness programs

Etc uh again uh this may sound very you

also have to give a software as a

service if you're using any software as

a service then every 6 months there is a

certain certificate uh that you have to

uh provide again that's a and and who

provides the certificate I mean how do

you get it you provide it's

self-certification it's self-

certification I you have to take it from

your service provider and provide to se

to se so that the data is being stored

in not to SEI to BC right uh to that the

data is being stored

in right right and the other thing is uh

you also have to maintain records as per

the pmla like how how does that

compliance come in

so I mean uh obviously like any other

regulated entity you are required to

report any suspicious

transactions uh to the

FIU uh anything and and that's a there's

a definition given there I don't claim

to be an expert on pmla

uh pmla I mean you have to do the those

things but I think typically the way we

would do things is that there is a list

that you have against which whenever a

new client comes or even all your

existing client you scrub them

periodically against that list to see

that none of the prescribed individuals

or entities are in your Client List

right right that is one thing and now

these are available as software okay uh

that is one thing uh that you do

suspicious transactions uh you have to

report to the financial intellig unit

okay any big one we have missed apart

from the list that we just went through

uh not really and what I really want to

add Neil is that people should not get

scared no no I that's not my intention

at all and you know Arya is there we are

a very close-knit

Community uh we have a compliance

calendar the community is very active

and we learn from each other and we

support uh each other and finally in

terms of gaps in the current

consultation papers so one big gap that

mint has also written about is this

ambiguity around um products which are

not regulated by sebi or any other

Indian regulator so sebi has created

essentially three categories of products

one which are under sebi like mutual

funds and stocks R can advise on that no

problem charge fees and so on then there

are products which are under other

Indian Regulators like irda or pfrda

where the ra can provide advice uh but

they have to give clients a disclaimer

that they cannot approach sebi for any

grievance

redressal um and then there is the third

category products which is quite

important to financial planning things

like Wills tax overseas Securities where

sebi has in the consultation paper said

that that advice can only be delivered

by a separate entity why is this a

problem hsh why not have a separate

entity um

and you know how does this affect the

work of an

RA so I can give you plenty of examples

I mean comprehensive Financial see from

a client's perspective a client does not

respect regulatory boundaries client

cannot be expected to know this is se's

remit this is ird's remit this is pfrda

remit this is nobody's remit okay or

this is the Indian laws remit and this

is the intern interational laws remit uh

so when a client comes to you and I can

give you many examples okay uh for

example you've saved up for mutual funds

for your daughter's

education you now want to know that is

it okay to take an education loan rather

than liquidate right corre and if it is

okay give me the working okay so that's

tax planning yeah if that working shows

that it is okay to take an educ loan

then help me get the education loan now

that's that's not regulated helping

people to get a loan and getting paid

for it is not regulated it's not

regulated by RBI then you know I mean so

you know for a client for me to tell a

client that sorry I can't advise you

this is tax planning I'm not allowed to

do tax planning or sorry I can't help

you get the loan because this is not

allowed or you go to a separate entity

or it is under even different brand I

think that does not work that confusing

it's very very confusing I'm so very

clearly the regulator has shown great

willingness it has been in a very

consultative uh status and position I

mean we have had good dialogues with

them I'm very comfortable and confident

that they will agree to sort of look at

and find a solution they also have a

issue right they have an issue that if

people complained about these Services

they won't be able to help because they

don't know about those services and I

think that's a very genuine concern for

that our position from uh you know as as

an as an raia is that just like what

they have proposed for a part-time ra

where who would be an educationist of

influencer whose core activity is

unregulated okay they have been asked in

the consultation paper to give a

disclaimer saying that if there is a

complaint regarding that you cannot come

to sebi he saying let's have a SE

different dis same

dispensation for the full-time r as well

okay okay any other issues with the the

consultation

paper so before we come to the issues I

want to point to the great things that

the consultation paper has said because

otherwise it looks like we're just

cribbing cribbing cripping okay I mean

look at the relaxations that they have

done uh whether it is uh qualifications

whether it is uh experience they have

done away with uh the net worth

compulsory corporatization has just

become it's been relaxed also and

corporatization itself has been made so

easy because of removal of uh net worth

requirements okay uh so I mean there are

plenty of good things that are there in

the paper among the misses one was this

scope being restricted a second big Miss

uh is uh this uh you know uh type of uh

uh people who provide trading calls or

trading call providers as we call them

now trading call providers somebody who

gives a call saying Buy sell Futures

options things like that now those are

typically very very security

oriented providing in the consultation

paper that if they are doing it one to

one they can be an raia and if they are

doing it one to many there will be an RA

I think anything that is based on

security an RA is a research analyst

which is a separate license from ra ra

correct so anything if the advice is

based on security how can it be one to

one it will have to be one to it will be

the same whether it comes to this person

so they should be in the ra regulations

they should not be in the IIA

regulations let me put it this way and

anything else I would say those are so

on the Fe there are lots of

clarifications required on a lot of

other things I would not call them a

Miss I reasonably sure they will agree

to those clarifications I think there's

one thing that I would bring up uh

especially relevant for a lot of mfds

disputer who want to become Ras that um

or or Ras who most clients already have

regular plans with mfds or banks that if

an R is telling you that get out of this

scheme put money in that scheme then

they should be allowed to charge a fee

on the distributed AUM as well right

which they are not getting the

distribution commission for somebody

else is getting the commission for

that's definitely on your list right so

this is a clarification I think and this

is something we have sought and I'm I

mean we hope that we will get that

clarification yeah all right uh har

thank you so much hopefully people

watching this uh will some of them

approach you approach Arya and we'll

have an uptick in the numbers I just

want to end this with saying the great

support that you know you personally and

you know live Min has provided to the

profession and to those who are watching

I can say this is a very satisfying

profession do do not go by what you have

heard okay it is never as difficult as

it is said it is never as easy as you

think fair enough thank you har thank

you

[Applause]