Regulatory Scope and MITC Incorporation
This policy governs the cancellation and refund of fees paid for services provided by Shrimoney. This policy forms part of the Most Important Terms and Conditions (MITC) incorporated into the client agreement, in accordance with Regulation 19(1)(d) of the SEBI (Investment Advisers) Regulations, 2013 and SEBI Circular No. SEBI/HO/MIRSD/MIRSD-PoD/P/CIR/2025/19 dated February 17, 2025.
Cancellation of Advisory Services
Cancellation by the Client
The Client may terminate the investment advisory services at any time by providing written notice to the Investment Adviser. The termination shall be effective from the date specified in the notice, which shall not be earlier than the date of receipt of such notice by the Investment Adviser.
Cancellation by the Investment Adviser
The Investment Adviser may terminate the advisory services by providing written notice to the Client. The Investment Adviser reserves the right to terminate the services immediately in the event of:
- Material breach by the Client of any term of the Agreement;
- Non-payment of advisory fees by the Client;
- Any regulatory direction, suspension, or cancellation of registration preventing continuation of services.
Refund on Premature Termination
In the event of premature termination of the investment advisory services by either the Client or the Investment Adviser, the Client shall be entitled to seek a refund of proportionate fees only for the unexpired period of the subscription.
The Investment Adviser is entitled to retain a maximum breakage fee of not greater than one-quarter (25%) of the total fees paid or payable for the engagement period.
This provision is a statutory regulatory requirement under SEBI's Most Important Terms and Conditions (MITC) framework and cannot be modified or waived by contract.
Explanation of the Refund Calculation
- Total Fees Paid: The entire amount paid by the Client for the agreed advisory period.
- Unexpired Period: The remaining duration of the advisory engagement after the effective date of termination.
- Proportionate Refund: The fees attributable to the unexpired period, calculated on a pro-rata basis.
- Breakage Fee: The maximum amount the Investment Adviser may retain, capped at one-quarter (25%) of total fees.
If a Client pays ₹1,00,000 for a 12-month advisory engagement and terminates after 3 months:
| Total Fees Paid: | ₹1,00,000 |
| Advisory Engagement: | 12 Months (Elapsed: 3 months) |
| Unexpired Remaining Period: | 9 Months |
| Proportionate Fee for Unexpired Period: | ₹75,000 (9/12 × ₹1,00,000) |
| Maximum Breakage Fee Permitted (≤ 1/4): | - ₹25,000 (25% of ₹1,00,000) |
| Net Refund Payable to Client: | ₹50,000 |
Interactive Refund Estimator Tool
Adjust your engagement fee and elapsed period to simulate the proportionate refund and breakage fee calculation:
Advance Fees and Refund Implications
The Investment Adviser may charge fees in advance if agreed by the Client. Such advance shall not exceed the period stipulated by SEBI, which is currently a maximum of two quarters (6 months).
In the event of premature termination, the refund of advance fees shall be governed by the same principle: the Client is entitled to a refund for the unexpired period, and the Investment Adviser may retain a breakage fee not exceeding one-quarter of the total fees.
Mode of Refund
Refunds shall be processed to the original mode of payment used by the Client. Refunds shall be made through bank transfer, UPI, cheque, or any other mode through which the fees were originally paid.
Timeline for Refund Processing
Refunds shall be processed within 30 days from the effective date of termination of the advisory services.
The effective date of termination shall be:
- The date of receipt of the Client's written termination notice by the Investment Adviser; or
- The date of receipt of the Investment Adviser's written termination notice by the Client; or
- The date of any regulatory event that prevents the Investment Adviser from continuing the services.
Fees for Non-SEBI Regulated Services
Investment advisory services are limited to securities under SEBI's purview. In the event the Investment Adviser offers any services related to products or services not under the purview of SEBI, such services shall be governed by separate terms. The refund provisions of this policy shall apply only to fees paid for SEBI-regulated investment advisory services.
No Refund in Certain Circumstances
No refund shall be payable in the following circumstances:
- Where the Client has not paid the advisory fees;
- Where the termination is initiated by the Investment Adviser due to material breach by the Client of the Investment Advisory Agreement;
- Where the services have been fully rendered and the engagement period has expired by efflux of time;
- Where the fees paid are statutory charges or taxes that are non-refundable under applicable law.
Grievance Redressal
If the Client is not satisfied with the refund calculation or the processing of the refund, the Client may escalate the matter through the grievance redressal mechanism:
Email: grievance@srimoney.in | Phone: +91 91525 79187.
If the grievance is not resolved within the timeframe specified in the grievance redressal policy, the Client may escalate the matter to SEBI through the SEBI Complaints Redress System (SCORES) at scores.sebi.gov.in.
Governing Law and Jurisdiction
This Cancellation and Refund Policy shall be governed by and construed in accordance with the laws of India. Any dispute arising out of or in connection with this policy shall be subject to the exclusive jurisdiction of the courts at Mumbai, India.
Cancellation and Refund Helpdesk
For cancellation or refund requests, please submit your written notice to:
Entity: Shrimoney
Email: support@srimoney.in
Phone: +91 91525 79187
Grievance Officer: Grievance Officer / Customer Support Head (grievance@srimoney.in)
Related Governing Documents: