This page contains the mandatory and voluntary disclosures applicable to my PMS distribution practice. Please read it before engaging with any Portfolio Management Service.
1. Distributor status
Ayush Agrawal is an APMI-registered distributor of Portfolio Management Services, registration number APRN09522.
I am a distributor, not an investment advisor. I do not manage portfolios, do not control investment decisions, and do not provide personalised investment advice. My role is to explain, compare and facilitate PMS offerings so you can make an informed decision.
I am currently empanelled with the following SEBI-registered Portfolio Managers:
Negen Capital Services Private Limited — SEBI Reg. INP000005414
Buoyant Capital Private Limited — SEBI Reg. INP000005000
Empanelment with a Portfolio Manager, or inclusion of a PMS / investment approach on this website, should not be construed as an assurance of performance or as being suitable for every investor.
2. Nature of relationship
As a distributor I may:
Help you understand PMS offerings and investment philosophies
Explain and compare characteristics of different approaches
Coordinate meetings with Portfolio Managers
Assist with documentation and onboarding
Help resolve operational queries and understand reports
I do not:
Manage your portfolio
Control investment decisions
Promise or guarantee returns
Represent that PMS eliminates market risk
Believe one strategy is appropriate for everyone
3. Risk disclosures
Market risk: PMS portfolios invest in securities and can decline in value.
Concentration risk: PMS portfolios may hold concentrated positions, increasing volatility.
Liquidity risk: some holdings may be difficult to exit at a desired price or time.
Drawdown risk: meaningful interim declines are a normal part of equity investing.
Style risk: an investment approach can underperform for extended periods.
Past performance does not guarantee future results. Performance data, where shown, is sourced from official Portfolio Manager disclosures / APMI Insights in the SEBI-prescribed format, with the as-on date stated.
4. Fees & commission
I do not charge you a separate fee for distribution services. I may receive a distribution commission from Portfolio Managers when a client onboards through me.
PMS fees are charged by the Portfolio Manager as per its Disclosure Document and may include:
Management fee
Performance fee, subject to hurdle rate and high-water mark
Exit load, if applicable
Brokerage, custody and other expenses
Always read the Portfolio Manager's Disclosure Document and client agreement for the complete, applicable fee schedule before investing.
5. Conflict of interest
I may receive different commission rates from different Portfolio Managers.
Empanelment does not mean endorsement; suitability for you comes first.
I may decline to present a PMS where the process, team, governance, risk or communication does not meet my evaluation standards.
6. Suitability framework
Before introducing any investment approach, I consider, among other things:
Your financial circumstances and investment objectives
Your risk tolerance and ability to bear drawdowns
Your investment horizon and liquidity needs
Your experience with equities and managed products
7. Complaints & escalation
If you have a grievance:
Step 1 — Contact your Relationship Manager
Step 2 — Contact me at ayush@ayushagrawal.in
Step 3 — Contact the Portfolio Manager
Step 4 — Escalate to SEBI SCORES at scores.gov.in
8. Privacy policy
I collect only the information needed to assess suitability and facilitate PMS onboarding — name, contact details, and financial information you choose to share. This information is used solely for the purposes of PMS distribution and communication, is not sold to third parties, and is retained only as long as necessary. You may request access to, correction of, or deletion of your information by writing to ayush@ayushagrawal.in.
9. Terms of use
This website is provided for information and education only. Nothing on this website constitutes investment advice, an offer, or a solicitation. While I strive for accuracy, information may be incomplete or outdated; verify with the Portfolio Manager's official Disclosure Document before investing. Past performance is not indicative of future results.
10. Compliance commitment
As an APRN holder, I submit the Annual Declaration of Self-Certification (DSC) through the APMI distributor portal. I review the content of this website periodically to ensure it remains factual, clear and compliant with applicable SEBI and APMI guidelines.
