The particulars given in this Disclosure Document have
been prepared in accordance with SEBI (Investment Advisers) Regulations, 2013.
The purpose of the Document is to provide essential information about the Investment Advisory
Services in a manner to assist and enable the perspective client/client in making an informed
decision for engaging Investment Advisor before investing.
For the purpose of this Disclosure Document, Investment Adviser is Dhruvin J
Bhanushali
1) Descriptions about Dhruvin J Bhanushali:
2) History, Present business and Background
Dhruvin J Bhanushali was originally incorporated as
Dhruvin J Bhanushali on 22nd day of September, 2019. Dhruvin J Bhanushali is registered with
SEBI as an Investment Advisor with Registration No. INA000019017. The focus of Dhruvin J
Bhanushali is to provide investment advice to the clients.
In the capacity as advisers Dhruvin J
Bhanushali aligns its interests with those of the client and seeks to provide the best suited advice
based on clients risk profile. Dhruvin J Bhanushali first tries to understand the client's return
expectations, risk taking ability & goals, which in turn helps to arrive at an asset allocation
suitable for the client. Dhruvin J Bhanushali conducts frequent portfolio reviews and suggests any
corrective action/s if required.
1) Terms & conditions for advisory services:-Dhruvin J Bhanushali
will provide Advisory Services which shall be in the nature of investment advice, and may include
buying and selling the securities for an agreed fee structure and which may be for a definite period
of time and which may vary / change from time to time, entirely at the Client’s risk. The detailed
terms and conditions are as per the agreement executed between client and Dhruvin J Bhanushali.
2) Disciplinary history:- Dhruvin J Bhanushali (Prop: Grow Fortuna
was served with a show cause notice on 30th August 2023 by the regulator SEBI for the procedural gap
in the inspection carried out by BSE Administration & Supervision Limited (BASL) on 12th December
2022 of the records & books of accounts of the Advisor and subsequently passed a final order on 15th
September 2023 with a monetary penalty of Rs.4 lakh and advised us ‘maintain proper KYC records of
the clients and to maintain the fixed fee limits as per the regulations of IA, which the IA complied
with thereafter since September 2022 only.
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Details as per the final Adjudication order being passed dated 15/09/2023 bearing Order ref
no. ORDER/NH/KL/2023-24/29268 .
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Affiliations with other intermediaries:- Dhruvin J Bhanushali Currently Dhruvin J Bhanushali
provides Investment advisory services only.
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Disclosures with respect to receipt of any consideration by way of remuneration or
compensation or in any other form whatsoever, received or receivable by Dhruvin J Bhanushali
or any of its associates or subsidiaries(if any) for any distribution or execution services
in respect of the products or securities for which the investment advice is provided to the
client:
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Dhruvin J Bhanushali do not have any distribution or execution arrangement with the issuers
of the securities, that Dhruvin J Bhanushali advises on. The fellow subsidiaries(if any) of
Dhruvin J Bhanushali may receive distribution commission/referral fee or similar income in
respect of the product or securities for which investment advice is provided to the client
by Dhruvin J Bhanushali. The indicative commissions received by fellow subsidiaries (if any)
are available on the website.
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Disclosure of consideration by way of remuneration or compensation or in any form whatsoever
with respect to recommending the services of a stock broker or other intermediary to a
client:
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Dhruvin J Bhanushali does not recommend services of any stock broker or intermediary to a
client. Dhruvin J Bhanushali does not have any commission sharing agreement with any
intermediary for recommending the services either as a stock broker or as other
intermediary.
Disclosures with respect to Dhruvin J Bhanushali own holding
position in financial products / securities:
Although Dhruvin J Bhanushali is registered as an Investment advisor with SEBI, it is
not actively engaged into any proprietary trading. It does not invest in any financial products /
securities. However Dhruvin J Bhanushali may/not have positions in various mutual funds/liquid
products.
Actual or potential conflicts of interest
arising from any connection to or association with any issuer of products/ securities, including any
material information or facts that might compromise its objectivity or independence in the carrying
on of investment advisory services:
Dhruvin J Bhanushali is a separate legal entity which has an independent activity of
providing the Investment Advisory services. These services shall be provided by Dhruvin J Bhanushali
by maintaining an arm’s length relationship with its fellow subsidiaries (if any) which might engage
in stock broking, depository, research, portfolio management and distribution of mutual funds and
third party products. Appropriate Chinese walls are also maintained in the manner as expected under
SEBI IA Regulations.
Disclosure of all material facts relating to the
key features of the products or securities, particularly, performance track record, warnings,
disclaimers etc.
Clients are requested to go through the detailed key features, performance
track record of the product, or security including warnings, disclaimers etc. before
investing as and when provided by the Investment Advisor. Such product materials may also be
available to www.sebi.gov.in or www.nseindia.com or www.bseindia.com.
Drawing client’s attention to warnings,
disclaimers in documents, advertising materials relating to investment products.
Dhruvin J Bhanushali and the Advisers of Dhruvin J Bhanushali who
provide the investment advice on behalf of the concern to the clients, shall draw the client’s attention
to the warnings, disclaimers in documents, advertising materials relating to an investment product/s
which he/she/they is/are recommending to the client/s.
Standard Risk Factors as perceived by Investment Adviser:
1)Investments in equities and derivatives are subject to market risks and there is no assurance or
guarantee that the objective of the investment / products will be achieved.
2) The past performance does not indicate its future performance. There is no assurance that past
performances will be repeated. Investors are not being offered any guaranteed or indicative returns.
3) The performance of the investments/products may be affected by changes in Government policies,
general levels of interest rates and risks associated with trading volumes, liquidity and settlement
systems in equity and debt markets.
4) Investments in the products which the Clients have opted are subject to wide range of risks which
inter alia also include but not limited to economic slowdown, volatility & illiquidity of the stocks,
poor corporate performance, economic policies, changes of Government and its policies, acts of God, acts
of war, civil disturbance, sovereign action and /or such other acts/ circumstance beyond the control of
Dhruvin J Bhanushali or any of its fellow subsidiaries.
5) The names of the products/nature of investments do not in any manner indicate their prospects or
returns. The performance in the equity products may be adversely affected by the performance of
individual companies, changes in the market place and industry specific and macro-economic factors.
6) Investments in debt instruments and other fixed income securities are subject to default risk,
liquidity risk and interest rate risk. Interest rate risk results from changes in demand and supply for
money and other macroeconomic factors and creates price changes in the value of the debt instruments.
Consequently, the NAV of the portfolio may be subject to the fluctuation.
7) Investments in debt instruments are subject to reinvestment risks as interest rates prevailing on
interest amount or maturity due dates may differ from the original coupon of the bond, which might
result in the proceeds being invested at a lower rate.
8)Engaging in securities lending is subject to risks related to fluctuations in collateral value /
settlement/ liquidity/counter party.
9)The product may use derivatives instruments like index futures, stock futures and options contracts,
warrants, convertible securities, swap agreements or any other derivative instruments. Usage of
derivatives will expose portfolio to certain risk inherent to such derivatives.
10) The use of derivative requires a high degree of skill, diligence and expertise. Thus, derivatives
are highly leveraged instruments. Small price movement in the underlying security could have a large
impact on their value. Other risks in using derivatives include the risk of mis-pricing or improper
valuation of derivatives and the inability of derivatives to correlate perfectly with underlying assets,
rates and indices.
11)The Investment Advisor may, considering the overall level of risk of the portfolio, advice for
investment in lower rated/unrated securities offering higher yield. This may increase the risk of the
portfolio. Such investments shall be subject to the scope of investments as laid down in the Agreement.
General Risks: We trust that, before executing on the advice of the Investment Adviser, our Relationship
Manager at Dhruvin J Bhanushali has provided you with all the information about the products, risk
factors etc. and you have gone through all the relevant information about the product being advised and
have sought requisite clarification about the same.
Dhruvin J Bhanushali shall maintain complete confidentiality of all information provided by the client/s
and shall not disclose any such information, without your prior consent except if such disclosure is
required to be made in compliance with any applicable law or regulatory direction. Dhruvin J Bhanushali
will obtain information pertaining to your orders/transactions/portfolio/funds availability/securities
availability etc. from the individual Client to enable us to provide you with informed and appropriate
advice.
Investors Services: The detail of investor relation officer who shall attend to the investor queries
and complaints is mentioned below:
Name of the person: Dhruvin J Bhanushali
Address: C/O Jagdish Bhanushali 1102 C-Wing Olive Building, Dindayal Upadhyay Marg,
Neptune CHS Beside Croma, Mumbai , Mulund West ,Mumbai Suburban, Maharashtra, 40080
+91 99309 06921 growfortuna@gmail.com
In case of any grievances the investors may email to grievance@growfortuna.com
