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FINAL RDD TO SEBI - KRChoksey · Partnership firm which started share broking in 1979. The Company is owned by Kisan R. Choksey and his family which includes Ramesh R. Choksey and

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Page 1: FINAL RDD TO SEBI - KRChoksey · Partnership firm which started share broking in 1979. The Company is owned by Kisan R. Choksey and his family which includes Ramesh R. Choksey and
Page 2: FINAL RDD TO SEBI - KRChoksey · Partnership firm which started share broking in 1979. The Company is owned by Kisan R. Choksey and his family which includes Ramesh R. Choksey and

INDEX

Sr. No. Contents Page Nos.

1. Disclaimer 1

2 Definitions 1

3 (i) History, Present Business & Background Of The Portfolio Manager 2

3 (ii) Background Of Promoters & Directors Of The Portfolio Manager 2

3 (iii) Top 10 Group Companies / Firms Of The Portfolio Manager On Turnover Basis 3

3 (iv) Services Offered 3

3 (v) Process and Operations Management of the Portfolio Manager 6

4. Penalties 6

5 (i) Investment Objectives & Policies 6

5 (ii) Policies for Investment in Associates and Group Companies 6

6 Risk Factors 6

7 (i) Client Representations 7

7 (ii) Disclosures On Transaction With Related Parties 8

8 Financial Performance Of The Portfolio Manager 9

9 Portfolio Manager Performance 10

10 Nature Of Expenses 12

11 Taxation 12

12 Accounting Policies 13

13 Investors Services 13

Page 3: FINAL RDD TO SEBI - KRChoksey · Partnership firm which started share broking in 1979. The Company is owned by Kisan R. Choksey and his family which includes Ramesh R. Choksey and

1

DECLARATIONS:

1. The Document has been filed with the Board along with the certificate in the prescribed format in

terms of Regulation 14 of the SEBI (Portfolio Managers) Regulations, 1993.

2. The purpose of the Document is to provide essential information about the portfolio services in a

manner to assist and enable the investors in making an informed decision for engaging a Portfolio

Manager.

3. This disclosure document contains the necessary information about the Portfolio Manager

required by an investor before investing, and the investor may also be advised to retain the

document for future reference.

4. All the intermediaries involved in the PMS are registered with SEBI as on the date of the

document.

5. The name, phone number, e-mail address of the Principal Officer so designated by the portfolio

manager is Mr. Rajiv Kisan Choksey, Tel: 91 22 66535000 / 9820080806, Email:

[email protected].

1) DISCLAIMER CLAUSE:

This document has been prepared in accordance with the SEBI (Portfolio Managers) Regulation, 1993 and is filed

with SEBI. This Document has neither been approved nor disapproved by SEBI nor has SEBI certified the

accuracy or adequacy of the contents of Document. The contents of this material do not seek to market

performance of Kisan Ratilal Choksey Shares & Securities Private Limited (hereinafter referred to as

“KRChoksey”) as a Portfolio Manager nor seeks to convey the performance/influence the opinions of investors.

This document is not for public distribution and has been furnished to you solely for your information and may

not be reproduced or redistributed to any other person. The manner of circulation and distribution of this

document may be restricted by law or regulation in certain countries and may not be circulated /distributed in

those countries without obtaining requisite approvals. Persons into whose possession this document may come

are required to inform themselves of, and to observe, such restrictions. This material is for the personal

information of the authorized recipient, and we are not soliciting any action based upon it. This report is not to be

construed as an offer to sell or the solicitation of an offer to buy any security in any jurisdiction where such an

offer or solicitation would be illegal. No person associated with KRChoksey is obligated to call or initiate contact

with you for the purposes of elaborating or following up on the information contained in this document. While we

endeavor to update on reasonable basis the information discussed in this material, there may be regulatory,

compliance, or other reasons that prevent us from doing so.

2) DEFINITIONS:

1. "Act" means the Securities and Exchange Board of India, Act 1992 (15 of 1992);

2. "Principal Officer" means an employee of the portfolio manager who has been designated as such by

the portfolio manager.

3. "Portfolio Manager " means any person who pursuant to a contract or arrangement with a client,

advises or directs or undertakes on behalf of the client (whether as a discretionary portfolio manager or

otherwise) the management or administration of a portfolio of securities or the funds of the client, as the

case may be and in the context of this document “KRCPMS”.

4. "Discretionary Portfolio Manager" means a portfolio manager who exercises or may, under a contract

relating to portfolio management, exercise any degree of discretion as to the investments or management

of the portfolio of securities or the funds of the client, as the case may be;

Page 4: FINAL RDD TO SEBI - KRChoksey · Partnership firm which started share broking in 1979. The Company is owned by Kisan R. Choksey and his family which includes Ramesh R. Choksey and

2

5. “Non-Discretionary Portfolio Manager” means a portfolio manager who exercises or may under a

contract relating to portfolio management, shall manage the funds in accordance with the directions of

the client.

6. "Regulations" means the Securities and Exchange Board of India (Portfolio Managers) Regulations,

1993.

DESCRIPTION:

3 (i) HISTORY, PRESENT BUSINESS & BACKGROUND OF THE PORTFOLIO MANAGER:

The Company, KISAN RATILAL CHOKSEY SHARES & SECURITIES PRIVATE LIMITED was

incorporated on 23rd

June, 1997 in the state of Maharashtra. The company commence the business of share

broking on corporatization of Mumbai Stock Exchange Membership Card of KRC&CO. Partnership firm which

started share broking in 1979. The Company is owned by Kisan R. Choksey and his family which includes

Ramesh R. Choksey and their family members. The Company is the Corporate Member of Bombay Stock

Exchange Ltd. (BSE), National Stock Exchange of India (NSE) and MCX Stock Exchange (MCX-SX).

Prior to Corporatization, the partnership firm was in the stock broking and investment related services for 19

years. Registered Office of the Company is at 1102, Stock Exchange Tower, Dalal Street, Mumbai – 400 001 &

Corporate Office is at Abhishek, C 5 & 6, 5th Floor, Dalia Industrial Estate, Link Road, Andheri (West),

Mumbai – 400 058 and has channel partners at 165 different locations across India.

The promoters of the Company, Choksey family holds vast experience in the field of capital market. Shri Kisan

Ratilal Choksey was the Trustee of the Mumbai Stock Exchange prior to Corporatisation. Even prior to the

corporatization of the Mumbai Stock Exchange Card, the Choksey family held membership of Bombay Stock

Exchange Ltd. (BSE) for decades. The group also has interest in Life Insurance & General Insurance business as

agents through its Corporate Associate KRC Insurance Advisors Pvt. Ltd.

3 (ii) BACKGROUND OF PROMOTERS & DIRECTORS OF THE PORTFOLIO MANAGER:

Name Qualification Experience

KISAN RATILAL CHOKSEY B.Com More than 40 years in the field of broking, investment, financial services and Advisory broking.

RAMESH RATILAL CHOKSEY Inter Science More than 40 years in the field of broking, investment, financial services and Advisory broking.

DEVEN RAMESH CHOKSEY B.Com. More than 20 years in the field of broking, investment, financial services and Advisory broking.

RAJIV KISAN CHOKSEY B. Com. More than 15 years in the field of broking.

Page 5: FINAL RDD TO SEBI - KRChoksey · Partnership firm which started share broking in 1979. The Company is owned by Kisan R. Choksey and his family which includes Ramesh R. Choksey and

3

3 (iii) TOP 10 GROUP COMPANIES/ FIRMS OF THE PORTFOLIO MANAGER ON TURNOVER BASIS.

Name of the Company

Address Phone Numbers

Type of Activities Handled

Ownership Details

Total Income for the F.Y. 2015-16

Nature of Interest of Promoter/ Director

Nature of Interest of Applicant Company

KRC Insurance Advisors Pvt. Ltd.

1102, Stock Exchange Tower Dalal St., Mumbai 400 001 66338050

Insurance Advisory and Agency Services

98.4% owned by KR Choksey Investment Managers Pvt.Ltd./ Choksey Family

58.02 (Lakhs)

Promoter / Director – Mr. Kisan R.Choksey, Ramesh R.Choksey, Deven R. Choksey

Nil

Kisan Ratilal Choksey & Co. (Registered Partnership Firm)

1102, Stock Exchange Tower Dalal St., Mumbai 400 001 66338050

Trading And Investments

100% owned by Choksey Family (partners)

175.92 (Lakhs)

Mr Deven Choksey, Mr Het D. Choksey , Naina and Ramesh Choksey Family Trust , Mr Ramesh Choksey , Mr Kisan Choksey , Mona Choksey , Ankita Choksey & Mr Rajiv Choksey are the partners of the firm.

Nil

K. R. Choksey Commodity Brokers Pvt.LTd.

1102, Stock Exchange Tower Dalal St., Mumbai 400 001 56338050

Trading & Investment in Commodities Exchange

98.50% owned by KR Choksey Investment Managers Pvt.Ltd./ Choksey Family

18.30 (Lakhs)

Promotor / Director – Mr. Kisan R.Choksey, Ramesh R.Choksey, Deven R. Choksey

Nil

K. R. Choksey Investment Manager .Pvt Ltd.

1102, Stock Exchange Tower Dalal St., Mumbai 400 001 56338050

Investment Management

98.01% owned by Kisan Ratilal Choksey & Co./Choksey Family

42.80 (Lakhs)

Promoter / Director – Mr. Kisan R.Choksey, Ramesh R.Choksey, Deven R. Choksey

Nil

Padmesh Tradelink Pvt. Ltd.

1102, Stock Exchange Tower Dalal St., Mumbai 400 001 56338050

Financing activity

96 % owned by KR Choksey Investment Managers Pvt.Ltd./ Choksey Family

160.19 (Lakhs)

Promoter / Director – Mr. Kisan R.Choksey, Ramesh R.Choksey, Deven R. Choksey

Nil

K R Choksey Realty LLP

1102, Stock Exchange Tower Dalal St., Mumbai 400 001 56338050

Realty Sector

100% owned by Choksey Family (Partners)

1.20 (Lakhs)

Mr. Deven Choksey Mr. Ramesh Choksey, Mr. Kisan Choksey, Mr.Rajiv K.Choksey, Mr. Het Deven Choksey, Kisan Ratilal Choksey SHARES & SECURITIES Pvt Ltd. are the partners of the firm

Nil

Page 6: FINAL RDD TO SEBI - KRChoksey · Partnership firm which started share broking in 1979. The Company is owned by Kisan R. Choksey and his family which includes Ramesh R. Choksey and

4

3 (IV) DETAILS OF SERVICES OFFERED:

We offer the following services:

(I) DISCRETIONARY - PORTFOLIO MANAGEMENT (DPM).

In this product funds will be managed by KRCPMS, on behalf of its clients on discretionary basis. It

shall be the endeavor of KRCPMS to maximize returns for its clients, in consonance with the client

risk profile. Here funds will be predominantly invested in Equities. However, the Portfolio Manager

may invest funds in debts, government securities, derivative instruments, units of mutual funds,

money market instruments, Exchange Traded Fund as per the risk profile of the customer,

depending upon the circumstances and the needs of time.

Client will offered the following options under DPM:

KRChoksey – Diversified Equity

Investment Objective

The investment objective would be to generate long term capital growth from an actively

managed portfolio of equity and equity related instrument primarily in the large-cap stocks.

Investment Strategy

The stock selection would focus predominantly on large-cap stocks which would deliver stable

returns over a period of time at a lower volatility. KRChoksey will pursue a top-down

investment approach, identifying initially industries/sectors that would do well over the

investment horizon and then identifying investment candidates within the same. The fund

managers will have the discretion to have a marginal exposure to mid-cap and small-cap ideas,

although it may predominantly (80-90%) invest in large-cap stocks.

The Fund manager at his/her discretions hedge the portfolio of the clients in derivatives market

not exceeding the amount of fund invested & as permitted in SEBI(Portfolio manager)

amendment regulation 2003 dated 5th

Feb 2003.

The fund manager at his/her discretion invests the surplus fund (kept aside for investment) in

money market investment till such time the surplus funds are invested.

KRChoksey – Emerging Cap

Investment Objective

The investment objective would be to generate long term capital growth from an actively

managed portfolio of equity and equity related instrument primarily in the mid-cap stocks.

Investment Strategy

The stock selection would focus predominantly on mid-cap and small-cap stock which has the

potential to deliver superior risk adjusted returns. KRChoksey will pursue a bottom-up

investment approach seeking to identify promising investment ideas. Mid-cap stocks are

susceptible to higher volatility and higher risks as compared to large-cap stocks and this risk

will be mitigated by ensuring ample diversification across a spectrum of mid-cap stocks.

The Fund manager at his/her Discretions hedge the portfolio of the clients in derivatives market

not exceeding the amount of fund invested & as permitted in SEBI(Portfolio manager)

amendment regulation 2003 dated 5th

Feb 2003.

The fund manager his/her Discretion invest the surplus fund (kept aside for investment) in

money market investment till such time the surplus funds are invested.

Page 7: FINAL RDD TO SEBI - KRChoksey · Partnership firm which started share broking in 1979. The Company is owned by Kisan R. Choksey and his family which includes Ramesh R. Choksey and

5

KRChoksey – Flexicap

Investment Objective

The investment objective would be to generate long-term capital growth from an actively

managed portfolio of equity and equity related instrument for resident and non resident clients

Investment Strategy

The stock selection would focus on companies having excellent business formation; track

record and sound dividend pay out. We will pursue a bottoms-up investment approach seeking

to identify promising investment ideas. The flexi cap approach would help us invest in stocks of

different capitalization segments and get the benefits of risk diversification.

The Fund manager at his/her Discretions hedge the portfolio of the clients in derivatives market

not exceeding the amount of fund invested & as permitted in SEBI(Portfolio manager)

amendment regulation 2003 dated 5th

Feb 2003.

The fund manager his/her Discretion invest the surplus fund (kept aside for investment) in

money market investment till such time the surplus funds are invested.

KRChoksey - Short Term

Investment Objective

The objective will be to generate short-term capital growth from an actively managed portfolio

of equity and equity related instruments.

Investment Strategy

The stock /index selection would focus on liquid counters which have the potential to deliver

superior risk adjusted returns. KRChoksey will pursue a combination of technical and

quantitative techniques in order to identify the oversold/ overbought shares/ indices. The

strategy is usually contrarian in nature, however sticks to the basic principles of investing – buy

low, sell high.

The Fund manager at his/her Discretions hedge the portfolio of the clients in derivatives market

not exceeding the amount of fund invested & as permitted in SEBI(Portfolio manager)

amendment regulation 2003 dated 5th

Feb 2003.

The fund manager his/her Discretion invest the surplus fund (kept aside for investment) in

money market investment till such time the surplus funds are invested.

KRChoksey Vision Infrastructure

Investment Objective

The investment objective would be to generate long term capital growth from a passive

managed portfolio of equity and equity related instrument primarily in the mid-cap stocks.

Investment Strategy

The stock selection would focus predominantly on mid-cap stock which has the potential to

deliver superior risk adjusted returns in Infrastructure space. KRChoksey will pursue a bottom-

up investment approach seeking to identify promising investment ideas. Mid-cap stocks are

susceptible to higher volatility and higher risks as compared to large-cap stocks and this risk

will be mitigated by ensuring ample diversification across a spectrum of mid-cap stocks.

The Fund manager at his/her Discretions hedge the portfolio of the clients in derivatives market

not exceeding the amount of fund invested & as permitted in SEBI(Portfolio manager)

amendment regulation 2003 dated 5th Feb 2003.

The fund manager his/her Discretion invest the surplus fund (kept aside for investment) in

money market investment till such time the surplus funds are invested

Page 8: FINAL RDD TO SEBI - KRChoksey · Partnership firm which started share broking in 1979. The Company is owned by Kisan R. Choksey and his family which includes Ramesh R. Choksey and

6

KRChoksey Vision Structured Product - Series I

Investment Objective

The investment objective to provide capital protection with fixed return by investing in Secured

Redeemable Non- Convertible Debenture (Debentures listed on the BSE WDM segment) and

participation in Nifty after a certain hurdle rate.

Investment Strategy

Investment in debentures which will be secured partly by way of creation of charge on

immovable property and partly by way of hypothecation / floating charge on the current assets

and / or receivables and / or other movable tangible and / or intangible assets and/or any other

asset of the issuer and / or its affiliates subject to the satisfaction of the debenture trustee.

(II) NON-DISCRETIONARY PORTFOLIO MANAGEMENT (NDPM)

The funds will be under the control of the PMS client and the Portfolio Manager shall try to

maximize the return for its clients by providing advisory services to the PMS Client. The buy/sale/

hold decision will be taken by the client and the return on these investments will largely depend on

the acceptance of advisory services and implementation thereof, by the client.

3(V) PROCESS AND OPERATIONS MANAGEMENT OF THE PORTFOLIO MANAGER:

Under the DPM Service, the discretion to make investment decisions lies with the Portfolio Manager. The

process of funds management by the Portfolio Manager is as under:

i. Enter into Portfolio Management Agreement with the clients; at this stage the client is given a

choice of the fee structure viz. Fixed Percentage/Performance Linked/combination of both.

ii. The PMS client will have to open broking account, bank account, with the bank chosen and

Demat account with the Depository participant and the said accounts shall be managed by

KRCPMS under Power of Attorney.

iii. In case of Non-resident clients, the Client will have to open separate bank account. The

Custodial services will be offered by Depository Participant. The Portfolio Manager shall

manage then accounts under Power of Attorney.

iv. A monthly unaudited statement listing the client’s funds position and the performance of the

Fund will be sent to the client.

v. An annual audited statement listing the client’s funds position and the performance of the Fund

will be sent to the client.

vi. As per the SEBI guideline dated August 11, 2008 we have discontinued managing on the pool

basis with effect from 11 Feb 2009. KRCPMS shall get the transactions of all Clients executed

through the Non-Pool based system , where the order will be placed either on Individual Client

basis or on the Pool based but the bank accounts and the DP accounts of Customers are

maintained separately thereby ensuring the trail and individual identification of shares and

Funds of each client .

Page 9: FINAL RDD TO SEBI - KRChoksey · Partnership firm which started share broking in 1979. The Company is owned by Kisan R. Choksey and his family which includes Ramesh R. Choksey and

7

4) PENALTIES:

i.) All cases of penalties imposed by the Board or the directions issued by the Board under the Act or Rules or

Regulations made there under.

Penalty levied by Securities Exchange Board of India for non settlement of client’s account during 20011-12 of Rs. 35 lakhs, has been paid within the stipiulated time.

ii.) The nature of the penalty/direction.

For non settlement of clients account as per the consent.

iii.) Penalties imposed for any economic offence and/ or for violation of any securities laws.

No penalties other than as stated above have been imposed against us.

iv.) Any pending material litigation / legal proceedings against the Portfolio Manager / key personnel with

separate disclosure regarding pending criminal cases, if any.

Nil

v.) Any deficiency in the systems and operations of the Portfolio Manager observed by the Board or any

regulatory agency. –

No such observation raised by SEBI during the disclosure period. (October 2015 to March 2016)

vi.) Any enquiry/ adjudication proceedings initiated by the Board against the Portfolio Manager or its directors,

principal officer or employee or any person directly or indirectly connected with the Portfolio Manager or

its directors, principal officer or employee, under the Act or Rules or Regulations made thereunder.

Same as mentioned above

5) (I) INVESTMENT OBJECTIVE AND POLICIES:

Our objective is primarily to:

1. Preserve Capital and

2. Achieve better returns than the appropriate benchmarks.

We invest in well – researched stocks and follow a bottom up approach for stock selection. We also have a strong

focus on asset allocation. We believe that markets are fairly volatile and this volatility requires a dynamic

approach to funds management. We understand that client needs are different and hence we try and customize our

services to the needs of our clients. We constantly conduct an unbiased review of client portfolios and inculcate a

high level of sell discipline in our portfolio management approach. We maintain the highest level of

confidentiality and transparency in all our transactions and we provide clients with comprehensive reports that

include holding statements, performance statements, capital gains statements, sauda summary and broker reports.

5) (II) POLICIES FOR INVESTMENT IN ASSOCIATES AND GROUP COMPANIES:

KRCPMS will not invest funds of its clients in any company, which is associated with Kisan Ratilal Choksey

Shares & Securities Pvt. Limited or any of its group companies, directly or indirectly.

6) RISK FACTORS

1. Securities investments are subject to market risk and there is no assurance or guarantee that the

objectives of the product will be achieved.

2. Past performance of the portfolio manager does not indicate the future performance of the portfolio

manager.

Page 10: FINAL RDD TO SEBI - KRChoksey · Partnership firm which started share broking in 1979. The Company is owned by Kisan R. Choksey and his family which includes Ramesh R. Choksey and

8

3. Various factors which impact the value of the Portfolio Investment include, but are not limited to,

fluctuations in the equity markets, prevailing political and economic environment, changes in

government policy, factors specific to the issuer of the securities, tax laws, liquidity of the underlying

instruments, settlement periods, trading volumes etc. Investment decision made by the Portfolio

Manager may not always be profitable.

7) (I) CLIENT REPRESENTATION:

KRChoksey commenced PMS services from 1st April, 2005. The details as on 31stMarch 2016 are given below:

(Upto 31st December 2008 KRCPMS was managed on Pool basis which has been discontinued as per the SEBI

guideline is now being managed on individual basis.)

Category of clients Diversified Equity Emerging Cap Vision Structured Product

Discretionary No. of

clients

Funds

managed

(Corpus)

(Rs. Cr.)

No. of

clients

Funds

managed

(Corpus)

(Rs. Cr.)

No. of

clients

Funds managed

(Corpus)

(Rs. Cr.)

Associates/group

companies Nil Nil Nil Nil Nil Nil

Others 08 6.78 15 16.75 Nil Nil

Category of clients Flexi-cap Vision Infrastructure Short Term

Discretionary No. of

clients

Funds

managed

(Corpus)

(Rs. Cr.)

No. of

clients

Funds

managed

(Corpus)

(Rs. Cr.)

No. of

clients

Funds managed

(Corpus)

(Rs. Cr.)

Associates/group

companies Nil Nil Nil Nil Nil Nil

Others 11 16.19 Nil Nil Nil Nil

Category of clients Diversified Equity Emerging Cap Vision Structured Product

Non-Discretionary No. of

clients

Funds

managed

(Corpus)

(Rs. Cr.)

No. of

clients

Funds

managed

(Corpus)

(Rs. Cr.)

No. of

clients

Funds managed

(Corpus)

(Rs. Cr.)

Associates/group

companies Nil Nil Nil Nil Nil Nil

Others Nil Nil Nil Nil Nil Nil

Category of clients Flexi-cap Vision Infrastructure Short Term

Non-Discretionary No. of

clients

Funds

managed

(Corpus)

(Rs. Cr.)

No. of

clients

Funds

managed

(Corpus)

(Rs. Cr.)

No. of

clients

Funds managed

(Corpus)

(Rs. Cr.)

Associates/group

companies Nil Nil Nil Nil Nil Nil

Others 41 38.09 Nil Nil Nil Nil

Page 11: FINAL RDD TO SEBI - KRChoksey · Partnership firm which started share broking in 1979. The Company is owned by Kisan R. Choksey and his family which includes Ramesh R. Choksey and

9

7(ii) DISCLOSURES ON TRANSACTION WITH RELATED PARTIES:

a) Names of related parties and description of Relationship.

Sr. No. Nature of Relationship and Name of related Parties

1 Enterprise over which Key Management Personnel exercise significant influence.

Kisan Ratilal Choksey & Co.

KRC Insurance Advisors Pvt. Ltd

K. R. Choksey Investment Managers Pvt. Ltd

K. R. Choksey Commodity Brokers Pvt. Ltd.

Ratilal K. Choksey Charitable Trust

K R Choksey Realty LLP

HET CHOKSEY ADVISORS LLP

Padmesh Tradelink Private Ltd.

2 Key Management Personnel (Directors / Partners)

Shri. Kisan Ratilal Choksey

Shri. Ramesh Ratilal Choksey

Shri. Deven Ramesh Choksey

Shri. Rajiv Kisan Choksey

Page 12: FINAL RDD TO SEBI - KRChoksey · Partnership firm which started share broking in 1979. The Company is owned by Kisan R. Choksey and his family which includes Ramesh R. Choksey and

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b) Details of Transactions with related parties. (audited)

Sr. No.

Name of Related Party Nature of Transaction Balance as on 1st April,

2015

Debit Credit Balance as on 31st March,

2016

1 KISAN RATILAL CHOKSEY & CO.

Rent* -

1,500,000

-

-

Deposit for premises 44,500,000

- 18,000,000

62,500,000

Share Trading Account 5,570

3,435,547

3,439,766

1,351

Loans given/Repayment Received -

32,000,000

32,000,000

-

2 K. R. Choksey Investment Managers Pvt. Ltd.

Management Service Fees* -

1,619,300

-

-

3 K. R. Choksey Commodity Brokers Pvt. Ltd.

Lease rent of car* -

347,106

-

-

Research Expense* -

650,000

-

-

4 KRC INSURANCE ADVISORS LTD

Interest on Unsecured Loan* -

8,438 -

-

Share Trading Account -

89,281 89,281

-

5 Padmesh Tradelink Private Ltd.

Share Trading Account -

174,196

-

174,196

Interest on secured Loan* -

135,051

-

-

Loan secured against shares -

- 20,000,000

20,000,000

6 K R Choksey Realty LLP Rent* -

120,000

-

-

Partners' Current A/c 9,838,750

- 850,000

10,688,750

7 HET CHOKSEY ADVISORS LLP Management Service Fees* -

100,000

-

-

8 Kisan Ratilal Choksey Remuneration* -

450,000 -

-

9 Ramesh Ratilal Choksey Seating Fees* -

720,000 -

-

10 Deven Ramesh Choksey Remuneration* -

187,500 -

-

11 Rajiv Kisan Choksey Remuneration* -

1,350,000 -

-

Page 13: FINAL RDD TO SEBI - KRChoksey · Partnership firm which started share broking in 1979. The Company is owned by Kisan R. Choksey and his family which includes Ramesh R. Choksey and

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* * These items are pertains to the Profit & Loss accoun t and therefore accordingly debited or credited in Profit

and Loss Account for the expenses incurred or income earned respectively

8) FINANCIAL PERFORMANCE OF THE PORTFOLIO MANAGER:

Kisan Ratilal Choksey Shares & Securities Private Limited has a net worth of Rs. 4063.96 and has a Profit

before Tax of Rs. 34.15 Lacs (Profit) based on audited figures from the Balance Sheet and Profit/ Loss as on

31st March 2016.

9) PORTFOLIO MANAGEMENT PERFORMANCE OF THE PORTFOLIO MANAGER FOR THE

LAST THREE YEARS, AND IN CASE OF DISCRETIONARY PORTFOLIO MANAGER

DISCLOSURE OF PERFORMANCE INDICATORS CALCULATED USING WEIGHTED AVERAGE

METHOD IN TERMS OF REGULATION 14 OF THE SEBI (PORTFOLIO MANAGERS)

REGULATIONS, 1993:

KRCPMS commenced PMS services since 1st April, 2005. The details as on 30th

September 2015 are given

below. (As on 31st December 2008 KRCPMS were managed on scheme basis which has been discontinued as

per the SEBI guideline dated 11th

August, 2008 with effect from 11th

February, 2009)

Performance of Portfolio Manager including Discretionary & Non Discretionary Portfolio:

Returns are calculated as per Weighted Average Method (XIRR)

(Figures in %)

Period KRC PMS SENSEX Nifty S&P CNX500

18.07.05 to 31.03.06 30.36 54.75 54.80 49.19

01.04.06 to 31.12.06 12.95 24.63 19.76 17.17

01.01.07 to 31.08.07 10.31 11.42 12.69 12.76

01.08.07 to 30.11.07 21.39 26.38 29.10 31.17

01.12.07 to 31.03.08 -23.24 -18.74 -17.36 -20.76

01.04.08 to 30.06.08 -11.58 -13.82 -14.53 -16.13

01.07.08 to 31.12.08 -40.58 -28.55 -26.98 -28.56

01.01.09 to 30.06.09 40.26 49.67 44.46 50.51

01.07.09 to 31.12.09 20.61 20.41 21.13 24.69

01.01.10 to 30.06.10 4.77 1.09 1.87 1.82

01.07.10 to 31.12.10 3.23 15.96 15.58 11.91

01.01.11 to 31.03.11 -10.47 -5.31 -5.02 -6.48

01.04. 11 to 30.09.11 -21.40 -15.30 -15.20 -13.90

01.10. 11 to 31.03. 12 7.09 5.67 7.00 5.93

01.04. 12 to 30.09.12 -3.44 7.36 7.23 6.21

01.10. 12 to 31.03.13 -10.07 0.76 0.02 -0.93

01.04. 13 to 30.09.13 -1.83 2.96 1.00 -1.00

01.10. 13 to 31.03.14 28.65 15.59 16.97 19.04

01.04. 14 to 30.09.14 39.04 19.36 19.20 23.45

01.10. 14 to 31.03.15 6.61 5.06 6.69 8.86

01.04. 15 to 30.09.15 -1.99 -6.47 -6.41 -4.76

01.10. 15 to 31.03.16 -10.41 -3.41 -2.84 -3.70

01.04. 16 to 30.09.16 18.76 9.37 10.07 14.09

Performance of Discretionary PMS:

Returns are calculated as per Weighted Average Method (XIRR)

(Figures in %)

Product Period KRC

PMS SENSEX Nifty

S&P

CNX500

Diversified Equity

16.09.05 to 31.03.06 27.44 37.80 37.66 34.15

01.04-06 to 31.12.06 8.11 23.00 17.60 14.48

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01.01.07 to 31.08.07 17.19 16.60 17.20 17.66

01.08.07 to 30.11.07 25.19 26.31 29.03 31.17

01.12.07 to 31.03.08 -24.05 -19.30 -18.03 -21.45

01.04.08 to 30.06.08 -13.75 -13.89 -14.60 -16.23

01.07.08 to 31.12.08 -39.16 -28.29 -26.76 -28.32

01.01.09 to 30.06.09 41.40 50.38 45.16 51.33

01.07.09 to 31.12.09 17.30 20.50 21.20 24.71

01.01.10 to 30.06.10 4.69 -0.15 0.61 0.28

01.07.10 to 31.12.10 5.12 15.81 15.41 11.72

01.01. 11 to 31.03.11 -13.73 -5.31 -5.03 -6.49

01.04. 11 to 30.09.11 -20.60 -15.70 -15.60 -14.30

01.10. 11 to 31.03. 12 5.48 5.78 7.13 6.10

01.04. 12 to 30.09.12 -3.04 7.38 7.26 6.22

01.10. 12 to 31.03.13 -2.92 1.89 1.26 0.93

01.04. 13 to 30.09.13 -4.71 3.41 1.55 -0.39

01.10. 13 to 31.03.14 28.67 15.55 16.93 19.00

01.04. 14 to 30.09.14 42.25 19.62 19.43 23.98

01.10. 14 to 31.03.15 -6.04 -1.13 0.27 3.07

01.04. 15 to 30.09.15 -4.23 -8.13 -7.99 -6.25

01.10. 15 to 31.03.16 -0.97 -3.24 -2.77 -3.03

01.04. 16 to 30.09.16 17.07 6.96 8.19 11.79

Emerging Cap

18.07.05 to 31.03.06 29.67 55.43 55.52 49.78

01.04.06 to 31.12.06 12.36 24.75 19.93 17.37

01.01.07 to 31.08.07 10.27 10.60 12.10 12.16

01.08.07 to 30.11.07 20.64 26.61 29.61 31.35

01.12.07 to 31.03.08 -22.44 -18.26 -16.86 -20.12

01.04.08 to 30.06.08 -10.08 -13.59 -14.33 -15.91

01.07.08 to 31.12.08 -40.32 -28.29 -26.70 -28.28

01.01.09 to 30.06.09 40.41 50.26 45.08 51.13

01.07.09 to 31.12.09 22.22 20.3 21.02 24.59

01.01.10 to 30.06.10 5.66 1.22 2.02 1.98

01.07.10 to 31.12.10 2.39 15.95 15.57 11.99

01.01. 11 to 31.03.11 -9.96 -5.50 -5.21 -6.66

01.04. 11 to 30.09.11 -20.40 -15.50 -15.30 -14.10

01.10. 11 to 31.03. 12 7.92 5.73 7.07 6.02

01.04. 12 to 30.09.12 -3.22 7.40 7.27 6.24

01.10. 12 to 31.03.13 -10.64 0.53 -0.23 -1.33

01.04. 13 to 30.09.13 1.04 2.71 0.71 -1.35

01.10. 13 to 31.03.14 28.41 15.62 17.00 19.06

01.04. 14 to 30.09.14 42.76 19.49 19.31 23.55

01.10. 14 to 31.03.15 9.36 5.56 7.20 9.32

01.04. 15 to 30.09.15 0.97 -6.34 -6.30 -4.67

01.10. 15 to 31.03.16 -8.51 -3.33 -2.89 -3.19

01.04. 16 to 30.09.16 19.16 9.96 11.28 14.61

Flexi Cap 01.08.05 to 31.12.06 13.24 28.23 26.01 28.73

01.01.07 to 31.08.07 9.41 21.79 20.53 19.94

01.08.07 to 30.11.07 31.47 26.40 29.09 31.20

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01.12.07 to 31.03.08 -23.44 -19.71 -18.30 -22.05

01.04.08 to 30.06.08 -13.94 -14.70 -15.29 -16.97

01.07.08 to 31.12.08 -40.61 -29.54 -27.99 -29.62

01.01.09 to 30.06.09 39.75 48.49 43.03 49.22

01.07.09 to 31.12.09 18.85 20.65 21.36 24.89

01.01.10 to 30.06.10 3.10 1.44 2.21 2.25

01.07.10 to 31.12.10 3.89 16.04 15.64 11.84

01.01. 11 to 31.03.11 -10.13 -5.04 -4.76 -6.23

01.04. 11 to 30.09.11 -23.20 -14.80 -14.70 -13.40

01.10. 11 to 31.03. 12 6.46 5.52 6.83 5.72

01.04. 12 to 30.09.12 -3.98 7.28 7.15 6.15

01.10. 12 to 31.03.13 -15.25 0.55 -0.19 -1.20

01.04. 13 to 30.09.13 -6.18 3.10 1.16 -0.82

01.10. 13 to 31.03.14 29.14 15.54 16.92 19.00

01.04. 14 to 30.09.14 30.64 19.06 18.94 23.15

01.10. 14 to 31.03.15 3.05 5.01 6.65 8.82

01.04. 15 to 30.09.15 -6.95 -6.24 -6.18 -4.54

01.10. 15 to 31.03.16 -12.83 -3.48 -2.81 -4.14

01.04. 16 to 30.09.16 18.76 9.38 10.72 14.11

Short term

07.11.07 to 30.11.07 31.47 26.40 29.09 31.20

01.12.07 to 31.03.08 -33.60 -24.25 -23.25 -28.89

01.04.08 to 30.06.08 -22.00 -13.90 -14.62 -16.24

01.07.08 to 31.12.08 -53.15 -28.39 -26.82 -28.41

01.01.09 to 30.06.09 31.85 35.95 33.47 36.62

01.07.09 to 31.12.09 3.33 20.67 21.37 25.09

01.01.10 to 30.06.10 -0.89 -2.16 -1.25 -1.12

01.07.10 to 31.12.10 7.73 14.58 14.44 12.09

01.01. 11 to 31.03.11 -4.66 -5.19 -4. 90 -6.37

01.04. 11 to 30.09.11 -10.00 -5.30 -5.30 -3.60

01.10. 11 to 31.03. 12 CLOSED

Vision Infrastructure 01.04. 11 to 30.09.11 -21.11 -11.20 -11.20 -11.00

01.10. 11 to 31.03. 12 -0.36 5.67 7.00 5.96

01.04. 12 to 30.09.12 -8.51 7.80 7.69 6.68

01.10. 12 to 31.03.13 -18.46 0.39 -0.36 -1.46

01.04. 13 to 30.09.13 -21.09 3.47 1.46 -0.69

01.10. 13 to 31.03.14 30.72 15.27 16.75 18.44

01.04. 14 to 30.09.14 CLOSED

Note: The Portfolio Manager has also launched various Series under the KRChoksey Vision Structured

Products. The Portfolio Products under the different Series have different tenures and the returns will

be known only on maturity and hence are not provided above.

10) NATURE OF EXPENSES:

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1. Investment management and advisory fees: Investment management and advisory fees are charged on the

basis of portfolio value on quarterly basis.

2. Custodian fee: At present, custodian fees are charged to clients as the custodian has Custody of client’s

portfolio. As we have moved towards Non-Pool based execution the back office operation of the

services has been outsourced to the custodian/third party KPO. We therefore charge custodian/handling

fees to the clients as and when applicable. In addition, administrative fees are also charged from Clients.

3. Registrar and transfer agent fee: Registrar and transfer agent fee as applicable are charged at actual.

4. Management Fees: Refer Annexure I

5. Brokerage and transaction cost: Brokerage and transaction cost are detailed below: Cash market: upto

1.00 % + service tax + securities transaction tax + transaction charges + other charges . Derivatives

market: upto 0.25 % + service tax + securities transaction tax + transaction cost + other charges .

6. Demat charges: Demat charges are payable as per DP plan at actual as charged by the depository

participant to the clients accounts.

7. Bank charges: Bank charges are payable at actual as charged by the bank and / or depository participant.

8. Legal Fees: Legal fees are payable at actual as charged by the concerned agency.

9. Stamp Duty: Stamp duty are payable at actual rates.

10. Administration cost: Total Administration cost would be at the prevalent applicable rates.

11. All other costs, fees, charges and expenses incurred by the Portfolio Manager or any other person

appointed by the Portfolio Manager arising out of or in connection with or in relation to the management,

acquisition, holding, custody, sale and/or transfer, of the Assets or the rendering of the Portfolio

Management services or the performance of any act pursuant to or in connection with the Client

Agreement shall be paid or reimbursed by the Client.

11) TAXATION:

Income from investments in securities can be classified in two ways:

1. Dividend Income – For the current financial year, dividend income is tax-free in the hands of the

recipient. Future taxation will be determined by prevailing laws.

2. Capital Gains – Shall be taxed in accordance with the prevailing laws. Long term Capital Gain where the

securities are held for more than one year in respect of Listed Securities is exempt from tax.

3. According to Section 94(7) of the Income tax Act, 1961 if any person buys or acquires shares within a

period of three months prior to the record date fixed for declaration of dividend and sell the same within

a period of three months from such record date, then losses if any arising from such sale shall, to the

extent of dividend received, be ignored for the purpose of computing the loss.

4. Losses under the head Capital Gains cannot be setoff against income under any other head. Long Term

capital Losses cannot be setoff against Short Term Capital Gain. Short Term capital Losses can be setoff

against Long Term Capital Gain.

5. Transactions in Derivative Market will not be construed as Speculation Business.

6. It shall be the client’s responsibility to pay the advance tax installments on the due dates as per Income

Tax Act.

7. If any tax is required to be withheld on account of any future legislation, the Portfolio Manager shall be

obliged to act in accordance with the regulatory requirement in this regard

12) ACCOUNTING POLICIES:

We maintain separate books of accounts on behalf and for the clients. The Accounts shall be maintained on

Mercantile System and shall be in compliance with all the prescribed Accounting Standards prescribed by the

Institute of Chartered Accountants of India. The following Accounting policy will be applied for the Portfolio

Management Service:

1. Investment in Equities/Derivatives and Mutual Funds will be valued at the closing market prices of the

exchange (BSE/NSE as the case may be) or the Repurchase Net Asset Value declared for the relevant

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Fund on the date of the report or any cut off date. Alternatively, the last available prices on the exchange

or the most recent NAV will be used for valuation

2. Realised gain/losses will be calculated by First in First out (FIFO) method.

3. Dividend on shares and units in mutual funds shall be accounted on when right to receive such dividend

is established.

13) Broker:

Please note that the Portfolio Manager is taking broking service from Kisan Ratilal Choksey Shares & Securities

Pvt. Ltd. for the PMS clients. Kisan Ratilal Choksey Shares & Securities is registered as a Stock Broker and a

Depository Participant with SEBI.

It provides/will provide inter-alia, the following services:

1. Broking Services as a member of BSE (INB/F010975834) , NSE (INB/F/E 230975832) and MCX-SX. -

(INB/F/E260975835)

2. Depository Services as a participant of the CDSL. (IN-DP-CDSL-07-99)

3. Portfolio Management Services as a Portfolio Manager registered under the SEBI (Portfolio Managers)

Regulations 1993. - (INP000001124)

The Portfolio Manager shall avail the aforesaid services of securities broking and depository in managing the

portfolio of the Clients. The Client will bear the cost of these services.

14) INVESTOR SERVICES:

1. Name, address and telephone number of the investor relations’ officer who shall attend to investor

queries and complaints.

2. Mr. Vikash Khemka, Abhishek, C-5 & 6, 5th Floor, Dalia Industrial Estate, Link Road, Andheri (W),

Mumbai - 400 058. Tele: 022-66965555 and email: [email protected]

3. Grievance redressed and dispute settlement mechanism.

4. Any and all disputes arising out of or in connection with the provision of services as a portfolio manager

shall be settled by arbitration by a single Arbitrator to be appointed by KRChoksey. The arbitration shall

be held, in Mumbai in accordance with the provisions of the Arbitration and Conciliation Act, 1996, as

amended from time to time.

5. In the event of any complaint, investor can approach us and if you are not be satisfied with our response,

you can lodge the complaint online. Therefore, you should know whom you should turn to, to get your

complaint redressed. SCORES facilitates you to lodge your complaint online with SEBI and

subsequently view its status.

Place: Mumbai Date: 02nd

December 2016

Director Signature Director Signature

Kisan Ratilal Choksey Rajiv Kisan Choksey

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Annexure I to Risk Disclosure Document

Fees may be a fixed sum or a percentage of the quantum of funds managed or may be linked to the portfolio

returns achieved or a combination of any of the above as may be decided by the Portfolio Manager.

Performance Based Fees for Clients under PMS:

For Existing clients Performance Based Fees will be computed on the basis of annualized return computed on the

completion of the year & thereafter on a quarterly basis if feasible in application on a high watermark basis

subject to consent of clients. For New Clients Performance Based Fees will be computed on the basis of

annualized return computed on the completion of the every financial quarter on a high watermark basis.

FEE STRUCTURE

1) KRChoksey – Diversified Equity

Fixed Fees: Upto 2% p.a. chargeable quarterly on the daily NAV or a fixed annual fees.

Fixed Fees structure:

Size of Portfolio (Rs.) 25,00,000

up to 1,00,00,000

1,00,00,000

& above

Fixed Fee (%) 0.5% (Per Qtr) 0.25% (Per Qtr)

Existing (I) Performance based Fee structure is as follows:

Size of Portfolio (Rs.) 0-15% 15-25% 25-50% Above 50 %

10,00,000 – 25,00,000 0 10% 20% 30%

25,00,000 – 1,00,00,000 0 20% 20% 20%

Above 1,00,00,000 0 10% 10% 10%

Existing (II) performance base Fee structure is as follows:

Size of Portfolio (Rs.) 0-25% 25-50% Above 50 %

10,00,000 – 25,00,000 10% 20% 30%

25,00,000 – 1,00,00,000 20% 20% 20%

Above 1,00,00,000 10% 10% 10%

Revised performance base Fee structure is as follows ( For Prospective Clients) :

Size of Portfolio (Rs.) 0-8% Above 8 %

Above 25,00,000 0 20%

Note –

1. The above mentioned Fees structure will be applicable to all new clients.

2. We also propose to apply this Fees structure to our existing clients subject to seeking their

Prior approval.

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2) KRChoksey – Emerging Cap

Fixed Fees:

Upto 2% p.a. chargeable quarterly on the daily NAV or a fixed annual fees.

Fixed Fees structure:

Size of Portfolio (Rs.) 25,00,000

up to 1,00,00,000

1,00,00,000

& above

Fixed Fee (%) 0.5% (Per Qtr) 0.25% (Per Qtr)

Existing (I) Performance based Fee structure till date:

Size of Portfolio (Rs.) 0-15% 15-25% 25-50% Above 50 %

10,00,000 – 25,00,000 0 10% 20% 30%

25,00,000 – 1,00,00,000 0 20% 20% 20%

Above 1,00,00,000 0 10% 10% 10%

Existing (II) Performance base Fee structure is as follows -

Size of Portfolio (Rs.) 0-25% 25-50% Above 50 %

10,00,000 – 25,00,000 10% 20% 30%

25,00,000 – 1,00,00,000 20% 20% 20%

Above 1,00,00,000 10% 10% 10%

Revised Performance base Fee structure is as follows ( For Prospective Clients)

Size of Portfolio (Rs.) 0-8% Above 8 %

Above 25,00,000 0 20%

Note –

1. The above mentioned Fees structure will be applicable to all new clients.

2. We also propose to apply this Fees structure to our existing clients subject to seeking

their prior approval.

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3) KRChoksey – Flexicap

Fixed Fees: Upto 2% p.a. chargeable quarterly on the daily NAV or a fixed annual fees.

Fixed Fees structure:

Size of Portfolio (Rs.) 25,00,000

up to 1,00,00,000

1,00,00,000

& above

Fixed Fee (%) 0.5% (Per Qtr) 0.25% (Per Qtr)

Existing (I) Performance based Fee structure till date:

Size of Portfolio (Rs.) 0-15% 15-25% 25-50% Above 50 %

10,00,000 – 25,00,000 0 10% 20% 30%

25,00,000 –1,00,00,000 0 20% 20% 20%

Above 1,00,00,000 0 10% 10% 10%

Existing (II) Performance base Fee structure is as follows -

Size of Portfolio (Rs.) 0-25% 25-50% Above 50 %

10,00,000 – 25,00,000 10% 20% 30%

25,00,000 – 1,00,00,000 20% 20% 20%

Above 1,00,00,000 10% 10% 10%

Revised Performance base Fee structure is as follows ( For Prospective Clients)

Size of Portfolio (Rs.) 0-8% Above 8 %

Above 25,00,000 0 20%

Note –

1. The above mentioned Fees structure will be applicable to all new clients.

2. We also propose to apply this Fees structure to our existing clients subject to seeking their

Prior approval.

4) KRChoksey – Short Term – (CLOSED)

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5) KRChoksey Vision Infrastructure

Upfront Fees: 2 %

Fixed Fees: Upto 2% p.a. chargeable quarterly on the daily NAV

Performance base Fee structure is as follows:

Size of Portfolio (Rs.) 0-8% Above 8 %

Above 25,00,000 0 20%

6) KRChoksey Vision Structured Product - Series I

Upfront Fees: 4 %

Place: Mumbai Date: 02nd

December 2016

Director Signature Director Signature

Kisan Ratilal Choksey Rajiv Kisan Choksey

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FORM C

SECURITIES AND EXCHANGE BOARD OF INDIA

(PORTFOLIO MANAGERS) REGULATIONS, 1993

(Regulation 14)

Kisan Ratilal Choksey Shares & Securities Pvt. Ltd.

Regd. Off.: 1102, Stock Exchange Tower, Dalal Street, Mumbai – 400 001

Tel.: 6696 5555 Fax: 6691 9576 website: www.krchoksey.com

We confirm that:

I) The Disclosure Document forwarded to the Board is in accordance with the SEBI (Portfolio Managers)

Regulations, 1993 and the guidelines and directives issued by the Board from time to time;

ii) The disclosures made in the document are true, fair and adequate to enable the investors to make a well

informed decision regarding entrusting the management of the portfolio to us / investment in the Portfolio

Management Scheme;

iii) The Disclosure Document has been duly certified by independent chartered accountants as on

02nd

December 2016. Details of Chartered Accountants are as under:

Deepa Rathi

Partner,

R Kabra & Co.

Chartered Accountants

Membership No.: 104808

Address:

515, Tulsiani Chambers,

Nariman Point,

Mumbai 400021

Tel No.: 22044737

Cell No.: 9920111345

For Kisan Ratilal Choksey Shares & Securities Pvt. Ltd.

Rajiv Kisan Choksey

(Principal Officer)

1102, Stock Exchange Tower,

Dalal Street, Mumbai – 400 001

Date: 02nd

December 2016

Place: Mumbai