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SEBI Registered Investment Adviser

Application Process: step by step


guide
This is a detailed step by step guide to the SEBI Registered Investment Adviser
Application Process under SEBI(Investment Advisers) Regulations 2013. It will help
anyone with the necessary qualifications (see below) to apply for SEBI RIA certification.
This post is authored by Swapnil Kendhe a successful SEBI RIA. His website
is vivektaru.
One of the first fee-only RIAs Melvin Joseph had earlier explained How to become a
Registered Investment Adviser (RIA) in India. The current post is a sequel.

Introduction
SEBI came up with Investment Advisers Regulation in 2013 that segregated commission
selling from investment advice. As per this regulation, no person can work as an
investment adviser unless he is registered as an investment adviser with SEBI; and a
registered adviser cannot receive remuneration or compensation in any form from any
person other than the client being advised. This essentially means that an investment
adviser must work on a fee-only model of advisory in India.
This regulation was heavily criticized by the adviser community which was mostly
working on commission based advisory model till then. Many people thought that fee-
only advisory cannot work in India because investors won’t pay for advice upfront to the
adviser. But slowly this model began getting talked about over social media and
elsewhere and many investors started seeking advice from fee-only advisers. It turned
out that investors are willing to pay a fee for an unbiased advice even in India. Some of
the early entrants into this model became successful and that started attracting more
and more people to it. Today not only advisers but many DIY investors are thinking of
leaving their jobs to become SEBI RIA.

Pros and cons of becoming a SEBI Registered Investment Adviser


The fee-only model removes inherent biases of commission-based advice and investors
can be better served with this model, but it is tougher to execute compared to the
commission-based model. It demands a higher degree of competence on part of an
adviser compared to what he/she can get away with in commission-based advice. Not all
fee-only advisers attract business either. Online business is skewed towards some
established advisers and a few others who have better online visibility. Successful fee-
only advisers are earning more than most people think they earn, while many others are
struggling to get a steady flow of business.
Selling is an inseparable part of the advisory business, be it commission based or fee-
only. Fee-only advice is a product that needs to be sold. You either have to figure out
ways to attract online business or you have to sell it offline. Getting included in freefincal
list of fee-only advisers doesn’t automatically generate business. If you think that you
can become a successful RIA because you have good knowledge of personal finance
and investing, you are probably approaching it from the wrong direction. The primary
thing that determines the success of an RIA is how well he can sell himself as a fee-only
adviser. Expertise comes distant second from a pure revenue point of view. So, think
hard before taking the plunge.
If you have made up your mind to become a SEBI RIA, this article can help you with the
registration process.

Eligibility for registration as an investment adviser in India


Following minimum qualifications are required to become an investment adviser in India.
1. A professional qualification or postgraduate degree or postgraduate diploma in
finance, accountancy, business management, commerce, economics, capital market,
banking, insurance or actuarial science.
or You should be a graduate in any discipline with an experience of at least five years
in activities relating to advice in financial products or securities or fund or asset or
portfolio management.
2. A certification on financial planning or fund or asset or portfolio management or
investment advisory services from (a) NISM or (b) from any other organization or
institution including Financial Planning Standards Board India (FPSB) or any
recognized stock exchange in India provided that such certification is accredited by
NISM.
In simple words, a postgraduate in finance-related topics or a graduate in any discipline
with 5 years’ experience in the financial sector can pass following 2 examinations by
National Institute of Securities Markets (NISM) and apply to SEBI for registration as an
Investment Adviser.
1. NISM – Series-X-A: Investment Adviser (Level-1) Certification Examination
2. NISM- Series – X-B: Investment Adviser (Level-2) Certification Examination
If you are a Certified Financial Planner (CFP), you need not pass these 2 examinations.
(An MBA from any branch with zero relevant experience can become an RIA by passing
two NISM exams. Likewise, an insurance agent with 5 years’ experience in insurance
selling also qualifies to become an RIA if he has a graduate degree in any discipline.)
Documents required
1. Proof of Identity
2. Proof of address
3. Proof of qualification (Degree certificates, NISM exam certificates or CFP certificate)
4. Experience Certificate in case of graduates (e.g. Insurance agency license, MF ARN
card etc.)
5. CIBIL Score
6. Net worth certificate from a Chartered Accountant (Minimum net worth requirement is
rupees one lakh for individuals or partnership firm.)
7. Income Tax Returns for the last 3 years
8. Various declarations.
Registration process
The registration process is completely online. There are three steps in the registration
process.
1. Getting access to the SEBI Intermediary portal by paying the initial registration fee of
₹5000.
2. Filling RIA registration form on SEBI intermediary portal and uploading relevant
documents.
3. Paying registration fee of ₹10,000 after the application is approved by SEBI.

Step 1: SEBI Registered Investment Adviser Application Process


Getting access to SEBI Intermediary portfolio
Go to https://siportal.sebi.gov.in/intermediary/index.html
Click on Self-Registration

Fill in the application details and click on proceed.


Step 2: Payment
Payment can be made by internet banking or debit card. Click on payment mode ‘Online’
and then click on ‘proceed to pay’. It will direct you to the payment gateway.

After payment is made, you will receive following mail from SEBI
Step 3: Acknowledgement email

Step 4: Activation link email


It takes a few days to get SEBI Intermediary portal login ID and portal activation link.

Step 5: Submit Application


The application is to be submitted within 14 days of receiving login id and portal
activation link mail, failing which self-registration expires and application fee is not
refunded.
On login to SEBI intermediary portal, following home page appears.
Click on Investment Adviser and navigate to the registration

This opens Investment Adviser registration form A. There are 7 sections in the
application form as mentioned below.

Section 1: General Information


This consist of general information like name, registered office address (residential
address can be given in case of individual applicants), correspondence address,
address of principal place of business, details of the contact person, details of
registration if applicant is registered with SEBI, RBI, IRDA or PFRDA in any capacity e.g.
insurance agency license number with its start and end date etc.
In addition to this you have to write about your present and past activities majorly related
to investment and personal finance; like MF AMCs you are empanelled with, your MF
AUM, insurance companies you are associated with and other relevant activities.

Section 2. Details of applicant


In this section you have to upload self-certified copies of identity proof, address proof,
supporting documents in respect of qualification, supporting documents in respect of
experience like AMFI registration card, insurance agency license etc., NISM investment
adviser exam certificates or CFP certificate, 3 years Income tax return and the copy of
net worth certificate from a chartered accountant. Here is a sample of net worth
certificate.

Section 3. Business Plan


In this section, you have to upload a pdf copy of your proposed business plan that
includes the advisory model you will work on e.g. financial planning, stock advisory etc.,
pricing of the advisory services, number of clients you are targeting to acquire and tools
and resources you will use to execute the business plan. Here is a sample business
plan.
In addition to the business plan, you also have to mention the type of products or
securities on which investment advice is proposed to be rendered. Here is a sample.
You also have to upload pdf document mentioning the process you will follow for risk
profiling of clients and for assessing the suitability of advice. Here is a sample

Section 4. Details of infrastructure


In this section, you have to give details of office space, office equipment, furniture and
fixtures, communication facilities and softwares or online tools you will use for
undertaking investment advisory services.
In addition to this, you have to upload documentary evidence of the office space. You
can prepare a document with pictures of your office space along with an electricity bill or
rental agreement in case of a rented office. This is what I had submitted for documentary
evidence of office space.
You also have to upload the declaration of necessary infrastructure to effectively
discharge the activities of Investment Adviser. Here is the sample of this declaration.

You can upload scanned copies of self-signed declaration if you do not have digital
signature. Up to 2mb file can be uploaded.

Section 5. Execution services


This section is relevant for body corporates who propose to offer distribution or
execution services to its clients through a subsidy or separate identifiable department or
division. Independent applicants have to upload a declaration that they will not carry out
any distribution and execution services post-grant of registration of investment adviser
by SEBI. Here is a sample of this declaration.
Section 6. Other information/ declarations
In this section you have to upload CIBIL report, declaration that the applicant is fit and
proper persons based on the criteria as specified in Schedule II of the SEBI
(Intermediaries) Regulations, 2008 and the declaration that the applicant shall not obtain
any consideration by way of remuneration or compensation or any other form
whatsoever, from any person other than the client being advised, in respect of the
underlying products or securities for which advice is provided to the client. Here are
samples of these two declarations.
Section 7. Declaration statement
In this section you have to upload pdf copies of declarations that you currently comply
with the certification and qualification requirements under section 7 of SEBI (Investment
Advisers) Regulation, 2013 and the declaration that you shall ensure that you will
comply with the certification and qualification requirements under section 7 of SEBI
(Investment Advisers) Regulation, 2013, 2013 at all times. Here are samples of these
two declarations.

You then have to tick following declaration statements and submit the application.
1. I/We hereby agree and declare that the information supplied in the application,
including the attachment sheets, is complete and true.
AND I/ we further agree that, I/we shall notify the Securities and Exchange Board of
India immediately any change in the information provided in the application.
2. I/ We further agree that I/ we shall comply with, and be bound by the Securities and
Exchange Board of India Act, 1992, and the Securities and Exchange Board of India
(Investment Advisers) Regulations, 2013, guidelines/instructions as may be issued by
the Securities and Exchange Board of India from time to time.
3. I/ We further agree that as a condition of registration, I/ we shall abide by such
operational instructions/directives as may be issued by the Securities and Exchange
Board of India from time to time.
Step 6: Registration Acknowledgement & Submission to SEBI Office
After submitting the application form on SEBI portal, you will receive following mail with a
pdf copy of the application form you submitted on the portal.

You have to take a print of the application form attached in the mail, sign it and submit or
courier it to SEBI office along with self-attested documents and declarations you
uploaded on SEBI portal.

Step 7: Initial approval & Payment


It usually takes 15 to 20 days to get first response from SEBI after the application is
submitted on SEBI portal. You are asked to fulfil deficiencies if any in the application. If
there are no flaws in the application, the first response from SEBI is to inform you that
your registration is approved.
You have to pay the registration fee of ₹10,000 on SEBI portal after registration is
approved. RIA certificate is issued within 2 to 3 working days of paying the registration
fee.

Step 8: Final approval and receipt of RIA certificate

Scanned copy of RIA certificate is mailed to you and a hard copy is couriered to your
address immediately after RIA certificate is issued.
Please join me in thanking Swapnil Kendhe for this exhaustive guide detailing the SEBI
Registered Investment Adviser Application Process. Here is more information about
Swapnil

About the author


Regular readers may be aware that Swapnil’s website is vivektaru and is part of the
freefincal list of Fee-only Financial Planners and Fee-only India: a movement to serve
investors and advisors. His successful transition from mutual fund distributor to SEBI
RIA has been documented here: Fee-only advisor journey: Swapnil Kendhe’s successful
transition into a SEBI RIA This is his guest post at freefincal: Are you a conservative
investor? Here is how you can grow your money smartly

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