THE STOTRAM MONEYMART (ARN-347083)
AMFI-Registered Mutual Fund & SIF Distributor

Objective

The objective of this policy is to ensure investor-first, consistent, and auditable mutual fund recommendations in line with the SEBI Master Circular for Mutual Funds, AMFI Code of Conduct for MFDs, and AMFI Due Diligence Questionnaire (DDQ) requirements. THE STOTRAM MONEYMART aims to select suitable products, disclose associated risks and costs transparently, and maintain documentary evidence of all recommendations.

Scope

This policy applies to all partners, EUIN holders, and authorized representatives of THE STOTRAM MONEYMART who recommend or distribute mutual fund schemes (Equity, Hybrid, Debt, Liquid, ELSS, ETFs, Index Funds, and SIF-linked products), prepare product notes or portfolio reviews, or engage with investors for mutual fund transactions.

Core Principles

1. Compliance-First: Only SEBI-registered AMCs and SEBI-approved schemes are used for transactions via recognized platforms (NSE NMF II, BSE STAR MF, MFU, or AMC/RTA portals) with mandatory EUIN capture.
2. Evidence-Based: Scheme recommendations are supported by peer analysis, rolling performance review, and risk-adjusted metrics.
3. Transparency: Trail-only commissions are disclosed. No assured or indicative returns are communicated to any investor at any time.
4. Suitability: Each recommendation aligns with the investor’s documented risk profile and investment goal horizon.
5. Documentation: Every recommendation is supported by a written rationale, maintained with client records as per regulatory retention requirements.

Fund Selection Criteria

a) Eligibility:

Only SEBI-registered AMCs and purchase-enabled schemes. Minimum 3-year track record unless specifically justified for new category launches or NFOs.

b) Screening Parameters:

• Category consistency and rolling 3-year performance relative to peer group.
• Risk-adjusted returns above category median.
• Standard deviation within acceptable range for the category.
• AUM threshold of minimum Rs. 500 Cr for open-ended schemes (with documented exceptions for niche or thematic categories).
• Portfolio quality checks including diversification, credit profile (AA- and above for debt funds), and liquidity.

c) Exclusion Criteria:

Funds under SEBI or AMFI observation, restricted, suspended for fresh transactions, or with any regulatory advisory pending are automatically excluded from the recommendation universe.

Suitability Assessment

Before recommending any mutual fund scheme, we conduct a risk profiling assessment of the investor covering investment objectives, time horizon, risk tolerance, existing portfolio composition, and financial circumstances.

For execution-only transactions where the investor’s choice differs from the assessed risk profile, a written unsuitability warning is provided and the investor’s acknowledgment is obtained before executing the transaction.

Portfolio Review

Existing client portfolios are reviewed periodically (at least annually) to assess alignment with the investor’s current risk profile and investment goals. Any rebalancing recommendations are documented and communicated to the investor.