Fund & Product Selection Policy
Per AMFI DDQ Section 2.6 | AMFI Master Circular | SEBI Guidelines on Suitability
& Conflict of Interest
Aangi Investments | ARN-85723 | Initial Reg: 18-May-2024 | Valid Until:
19-May-2028 | Effective: July 2026
Purpose of This Policy
This Fund & Product Selection Policy describes the framework used by Aangi
Investments (ARN-85723) to select, recommend, and review financial products for
investors. This policy is prepared in accordance with AMFI DDQ Section 2.6, AMFI Master Circular
January 2026, and applicable SEBI guidelines on investor suitability and conflict of interest
management. We are committed to recommending only those products that are genuinely suitable for
each investor based on their individual profile.
⚠️ Core Principle — Suitability Above All
Every product recommendation made by Aangi Investments is based SOLELY on the investor's risk
profile, financial goals, investment horizon, and financial capacity. Commission rates,
incentives, or commercial considerations from AMCs or product manufacturers have NO influence on
our recommendations. Investor suitability is non-negotiable.
1. Our 4-Step Product Selection Process
01
Investor Profiling
Structured risk assessment to understand goals, horizon, income, liabilities, and risk
tolerance
02
Product Mapping
Match investor profile to suitable product categories using SEBI Riskometer and asset
allocation framework
03
Scheme Evaluation
Evaluate specific schemes using quantitative and qualitative criteria — performance,
costs, AMC reputation
04
Recommendation & Review
Present suitable options. Final decision always with investor. Periodic review at least
annually.
2. Investor Risk Profiling
Before recommending any product, Aangi Investments conducts a structured investor risk
profiling exercise covering:
- Age & Life Stage — Investment horizon typically decreases as investors
approach retirement
- Income & Surplus — Monthly investable surplus after expenses and
emergency fund allocation
- Existing Liabilities — Home loan, personal loan, education loan EMIs
affecting investable capacity
- Financial Goals — Short-term (less than 3 years), medium-term (3-7 years),
long-term (7+ years)
- Risk Tolerance — Emotional and financial capacity to absorb temporary
portfolio losses
- Investment Experience — First-time investor vs experienced investor —
affects product complexity
- Tax Bracket — Relevant for recommending tax-efficient investment options
like ELSS
- Liquidity Needs — Emergency fund adequacy, upcoming financial commitments
in next 3 years
3. Risk Profile Categories & Product Suitability Matrix
| Risk Profile |
Suitable Fund Categories |
Suitable Products |
Avoid |
Recommended Horizon |
🟢 Conservative Low risk tolerance, capital preservation priority
|
Liquid, Overnight, Ultra Short Duration, Money Market, Short Duration Debt, Conservative
Hybrid
|
Debt MFs, Liquid MFs |
Small Cap, Sector/Thematic, Long Duration Debt, High Yield Credit |
Less than 3 years |
🟡 Moderate Moderate risk, balanced growth |
Balanced Advantage, Aggressive Hybrid, Large Cap, Multi Cap, Index Funds, Balanced
Hybrid
|
Hybrid MFs, Large Cap MFs, Index Funds |
Small Cap (primary), Sector Funds (primary), Long Duration Debt |
3 to 7 years |
🔴 Aggressive High risk tolerance, wealth creation focus
|
Flexi Cap, Mid Cap, Small Cap, ELSS, Thematic, Sectoral, International Funds |
Diversified Equity MFs, ELSS |
Liquid/Overnight for long-term goals, Capital Protection schemes |
7+ years |
Note: This matrix is indicative. Actual recommendations depend on
the individual investor's complete profile. A Moderate investor may hold some Aggressive
products for long-term goals and vice versa, based on goal-based allocation.
4. Scheme Evaluation Criteria
Once the appropriate category is identified, Aangi Investments evaluates specific
schemes using the following criteria:
📈
Performance Track Record
3-year and 5-year returns vs benchmark and category average. Consistency of
outperformance across market cycles.
👨💼
Fund Manager Quality
Fund manager's experience, track record across market cycles, stability (low turnover),
and investment philosophy.
🏢
AMC Reputation & Stability
AMC's AUM size, years of operation, parent company stability, regulatory compliance
history, and overall franchise strength.
💰
Expense Ratio (TER)
Total Expense Ratio compared to category average. Lower TER (all else equal) means better
net returns for investors.
📊
Risk-Adjusted Returns
Sharpe Ratio, Sortino Ratio, Standard Deviation — evaluating how much return is generated
per unit of risk taken.
💧
Liquidity & Portfolio Quality
Portfolio concentration, liquidity of underlying securities, credit quality (for debt),
sector/stock concentration risks.
📏
Fund Size (AUM)
Adequate AUM to ensure liquidity and operational efficiency. Avoid very small funds with
closure risk and very large funds in mid/small cap categories.
🎯
Investment Style Consistency
Does the fund follow its stated investment mandate? Style drift (e.g. large cap fund
buying small caps) is a red flag.
5. Conflict of Interest Policy
Our Formal Declaration — No Commission-Driven
Recommendations
Aangi Investments formally declares that:
✓ Commission rates received from AMCs have NO influence on fund
recommendations
✓ We do not maintain any formal or informal "preferred AMC" list for commercial
reasons
✓ We do not participate in AMC-sponsored holidays, trips, or gifts that create conflict
of interest
✓ We do not receive any incentives, rebates, or benefits beyond the standard trail
commission disclosed on our website
✓ Scheme recommendations are documented with rationale before presentation to
investors
✓ We do not switch investors between schemes to generate additional commission (churning)
✓ Direct Plans are always disclosed as an alternative, even though we do not facilitate
them
Practices We Strictly Prohibit (Conflict of Interest):
- Recommending schemes based on higher commission rates or incentives
- Churning — unnecessary switching of investor portfolios to generate commissions
- Accepting non-cash benefits, gifts above regulatory limits, or sponsored trips from
AMCs
- Recommending close-ended NFOs or illiquid products without full risk disclosure
- Recommending products outside investor risk profile without written unsuitability
declaration
6. Unsuitability Declaration Process
If an investor wishes to invest in a product that does not match their assessed risk
profile, Aangi Investments follows this process:
- Step 1 — Inform: Aangi Investments will clearly communicate in writing that
the chosen product is outside the investor's risk profile
- Step 2 — Explain Risks: A detailed explanation of the specific risks of the
product — volatility, liquidity, downside potential
- Step 3 — Formal Declaration: Investor must sign a formal Unsuitability
Declaration acknowledging the risk mismatch
- Step 4 — Process Transaction: Only after receiving the signed declaration
will the transaction be processed
- Step 5 — Record Keeping: Unsuitability declarations are maintained for a
minimum of 8 years as part of client records
7. Portfolio Review Policy
- Annual Review: Aangi Investments conducts a comprehensive portfolio review
with every investor at least once a year
- Triggered Review: Additional reviews are initiated when there is a material
change in investor's financial situation, goals, or life stage
- Market Event Review: During significant market events (15%+ correction or
rally), investors are proactively communicated with
- Fund Change Review: When a recommended scheme undergoes fundamental changes
(fund manager change, mandate change, merger), investors are informed and alternatives
reviewed
- Rebalancing: Portfolio rebalancing is recommended when actual asset
allocation deviates significantly (more than 10%) from target allocation
8. Record Keeping & Compliance
- All investor risk profiles, financial goal discussions, and recommendation rationale are
documented and maintained
- Records retained for minimum 8 years as per SEBI and AMFI requirements
- All unsuitability declarations maintained as permanent client records
- This Fund Selection Policy is reviewed and updated at least annually or when there are
regulatory changes
- Policy is available for inspection by AMFI, SEBI, or any regulatory authority on request
Formal Declaration by Aangi Investments
I, Maitrik Sanghavi (Proprietor), on behalf of Aangi
Investments (ARN-85723), hereby declare that this Fund & Product Selection
Policy represents our genuine commitment to investor-first recommendations. This policy is
followed in letter and spirit in all our client interactions. Any deviation from this policy can
be reported to AMFI at igrc@amfiindia.com or to SEBI SCORES at scores.sebi.gov.in.
Contact for policy queries:
Maitrik Sanghavi | Proprietor | aangiinvestments@gmail.com | +91 99246 55449 |
www.aangiinvestments.com
Regulatory Reference: AMFI DDQ Section 2.6 | AMFI Master Circular
January 2026 | SEBI Master Circular for Mutual Funds | SEBI Circular on Suitability Assessment
Effective Date: July 2026 | Last Updated: July 2026 | Aangi Investments | ARN-85723
| Reviewed annually