Fund & Product Selection Policy
Per AMFI DDQ Section 2.6 | AMFI Master Circular | SEBI Guidelines on Suitability &
Conflict of Interest
Fintopia Financial Services | ARN-115652 | Initial Reg: 20-Sep-2025 | Valid Until:
19-Sep-2028 | Effective: July 2026
Purpose of This Policy
This Fund & Product Selection Policy describes the framework used by Fintopia Financial
Services (ARN-115652) 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 Fintopia Financial Services 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, Fintopia Financial Services 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, Term Insurance, Endowment |
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, Term + Health Insurance |
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, SIF (Min Rs.10L) |
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, Fintopia Financial Services 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
Fintopia Financial Services 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, Fintopia Financial Services follows this process:
- Step 1 — Inform: Fintopia Financial Services 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: Fintopia Financial Services 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. Product-Specific Selection Policies
Insurance Products
- Insurance need analysis conducted before any insurance recommendation — Human Life Value (HLV)
method used for life cover calculation
- Term insurance is always the primary recommendation for life cover — investment-linked products
recommended only for specific needs
- Health insurance coverage adequacy reviewed against medical inflation and family health
history
- Insurance is the subject matter of solicitation. Policy documents shared before purchase
decision
Specialised Investment Funds (SIF)
- SIF recommended ONLY for investors with minimum Rs. 10 Lakhs available for this specific
investment
- SIF is positioned between MF and PMS — suitable for sophisticated investors seeking higher
risk-adjusted returns
- Higher risk profile, strategy complexity, and limited track record (new asset class)
specifically disclosed
9. 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 Fintopia Financial Services
I, Soumen Bose (Founder & Proprietor), on behalf of Fintopia Financial
Services (ARN-115652), 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:
Soumen Bose | Founder & Proprietor | support@fintopiafinserv.com | +91 90881 00727 |
www.fintopiafinserv.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 | Fintopia Financial Services |
ARN-115652 | Reviewed annually
