Jatin Khemani, CFA Profile picture
Sep 27, 2020 16 tweets 4 min read Read on X
(Thread) A self-employed professional in the financial services industry has broadly three areas to deal with:

1. Regulators/Compliance (SEBI, MCA, RBI, GST, IT..)
2. Investors (Behavioural Counselling..)
3. Investing/Research (Equities/Mutual Fund..)

1/n
While real value addition is 3rd, followed by 2nd, unfortunately, a significant time & mind share goes in dealing with 1st.
You may have all the passion for the financial markets and relevant experience & academic degrees to back it up, but is that enough to be successful in your
entrepreneurial journey? Turns out the domain knowledge comes a lot later in the pecking order of the skills required to be on your own.
While large institutions have consultants/lawyers, the individuals are left wondering if they are on the right side of compliance (often grey)
which takes a huge mind share/peace.
The frequent and ad hoc changes with short notice periods (less than a week), retrospective implementation, multiple overlapping regulations & lack of clarity in actual regulations vs the intent, unfortunately, might soon end up killing
the nascent & tiny category of fee-only advisors & analysts.
From 1st Oct 2020, the individual advisors/analysts with more than 150 clients can’t accept any new clients, until they form a corporate body (along with a new PAN, TAN, GST…), provide funding of Rs 50 lacs,
apply again to SEBI at a registration fee of Rs 5.5 lacs & get approval, which can all take anywhere b/w 6-12 months.
Not only can they not onboard new clients, but they (along with non-individual IAs) will also be spending most of the next 6 months complying with new regulations
which apply ‘retrospectively' - like entering into physical contracts with all existing clients, segregating advisory and distribution, ensuring fee caps are not breached etc. Earlier, the payment gateways were banned all of a sudden, and now significant restrictions are put on
advance fees which make the model unviable for the vast majority of advisors/analysts. It is not just the financial barrier but also the operational burden which makes compliance very difficult and in some cases, it is not even practical - for instance, an advisor is now supposed
to record each & every telephonic conversation with each of its clients & store the records for the next FIVE years.
Even for PMS, the net worth requirement has been increased to Rs 5 Cr from 2, while that’s tiny for most incumbents, it has actually increased the financial entry
barriers to young talent.
Meanwhile, the Mutual Fund Distributors have been asked to change their name or get registered as IA:
Apparently, the intent behind all these regulations is to protect Investor Interest, but all this is happening at a time when we are in midst of the biggest pandemic ever, and experiencing significant volatility in the markets.
Then shouldn’t all attention of advisors/analysts be solely on the client portfolios and hand-holding their investors? But would there be any time left with individuals after the struggle to meet these stringent and time-bound conditions?
The unfortunate reality is that amidst all this, the scamming hubs like Indore would continue their malpractices through multiple corporate entities and multiple licenses backed by an army of lawyers to deal with regulators.
It’s just the honest individual advisor/analyst who will be managing this entire transition over the next six months and added compliance burden all by himself/herself. Many who recently started practice would simply give up helplessly.
While for Indore guys, the worst case would involve them paying a couple of crores in penalties from 10s of crores they might have earned by selling F&O tips, and eventually, they might even come back in another avatar to continue mis-selling.
You may read more here: 'Killing the Small Advisor' by @Prashanth_Krish portfolioyoga.com/wp/killing-the… (End)

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More from @Jatin_Khemani

Aug 14, 2022
As a process, most long-term investors over time tend to put PSUs in the touch-me-not basket. Newbies often wonder why such a strong bias against this particular class of companies despite some being pseudo monopolies boasting of attractive business characteristics. 1/n
A lot of incremental evidence not only solidifies such a stance but also keeps pushing more investors to avoid the space (with some exceptions). For instance, there’s a listed mining PSU that has not mined anything for the last 12 yrs, as it failed to renew its mining lease.
Implying this company has had zero revenues over this period. But surprisingly it continued to pay full salaries & provide all facilities like free electricity, water, medical services etc. to its workforce. In the absence of any revenues, how did this company afford all this?
Read 12 tweets
Apr 13, 2022
Some hard investing truths & views from Kenneth Andrade, that 20-something, financially independent & full-time investors (with Papa’s money) would NOT be able to tell you on their Instagram or Youtube Video 1/n
‘Usually, you don’t beat markets in the first 5-10 years. I did not beat markets for the first decade. All successful investors made big money only after 55 years of age, by then they have made most mistakes already & stop repeating them.’ 2/n
Stop staring at the scoreboard, instead focus on the game & ensure you stay in it long enough.
‘The best of Fund Managers (with all their might) have a 55% strike rate. On average, the ones who beat the index, have a strike rate of about 45%.’ 3/n
Read 19 tweets
Jun 15, 2020
9,520 have died in India & 4.3 lac globally. These are just 'numbers' until it happens to us or someone we know. I lost my next-door neighbor last week, a young & healthy individual with no pre-existing illness. He was hospitalized (on oxygen) for 10 days but couldn't make it 1/n
His brother & father who also tested positive and are still hospitalized for over 15 days do not yet know about this. Wife & kids probably couldn't even see him due to the way the last rites happen for COVID patients.
There are all kinds of loose opinions floating around on how it spreads or not, how it's fatal or not, how opening up the economy is more important etc.
Read 5 tweets
Dec 18, 2019
A Thread. FASTag rollout has helped NHAI increase daily toll collection from Rs 65 Cr to Rs 80 Cr., a 23% jump. Over the weekend I crossed four tolls en route Chandigarh from Delhi and here’s a thread with some observations & thoughts. 1/n
1) It did not take us more than 3-min to cross any toll, definitely a significant improvement in turnaround time & great for commuters, especially commercial vehicles. (would be down further post 15th Dec)
2). The biggest benefit for tolls is plugging the cash leakage, which is
evident in the overnight jump in the collection. Further, managing Rs 65 Cr. cash every day involved significant time in reconciliation, loss due to fake notes, & cash logistics - taking that cash to the bank. The digital payments completely take away all those headaches & costs.
Read 7 tweets
Nov 24, 2019
A thread. Some of my biggest learnings came in the last two years of my first cycle (9 years of full-time investing):
1) In the beginning, everybody thinks bottom-up stock picking is the holy grail, I thought so too. Whereas, in reality, sectoral tailwinds/headwinds immensely matter and should never be ignored.
2) I always thought technical analysis is all gas and what matters is 'just' the business behind the stock. I was wrong. Price-action, volumes, delivery data, liquidity/flows, index inclusion, etc. also matter & can add value even for fundamental/value investors especially for..
Read 13 tweets
Nov 9, 2019
What a fabulous day at #VIP3
Each of the 4 sessions & Q&A had decades of wisdom distilled into it.
400+ attendees including seasoned investors & money managers who flew to Delhi from across the country. A big thank you to all speakers, moderators, organisers and CFA Society. Image
Good news for those couldn’t attend - All the sessions were recorded and videos will be released shortly.
I’ll share the link in this thread once its available.
Session by Mr. Utpal Shah on “Megatrends & Leadership”
Summary Blog: bit.ly/2XPyVD6
Presentation Slides: bit.ly/2OM1vkV
CFA Society is expected to release videos shortly
Read 7 tweets

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