Client Onboarding & KYC Policy

Shah Financial Services follows a structured, transparent, and compliant client onboarding process in accordance with SEBI Master Circular for Mutual Funds, AMFI Master Circular for MFDs (14-Jan-2026), Prevention of Money Laundering Act (PMLA) 2002, and Digital Personal Data Protection Act (DPDPA) 2023.

This policy outlines the steps, documentation, and safeguards followed during the onboarding of every new investor to ensure regulatory compliance, investor protection, and audit-readiness.

1. Onboarding Channels

Shah Financial Services accepts new clients through two primary channels:

• Online Onboarding — via our website, digital KYC platforms (CKYC/CVL KRA), and integrated MF transaction platforms (MFU / NSE MF Invest Platform).
• Offline / Physical Onboarding — in-person at our registered office in Borsad, Gujarat, with physical KYC forms and document verification.

2. Eligibility & Pre-Onboarding Checks

Before initiating onboarding, we verify the prospective investor's eligibility:

• Must be an Indian resident or NRI/PIO (with applicable FEMA compliance for non-resident investors).
• Must be at least 18 years of age (minor accounts handled through guardian).
• Must not be a Politically Exposed Person (PEP) without enhanced due diligence.
• Must not appear on any SEBI/RBI/UN sanctions or watch lists.
• Must have a valid PAN and Aadhaar (for KYC) or alternative officially valid documents (OVD).

3. KYC Process

KYC (Know Your Customer) verification is mandatory for all investors and is completed before any transaction is processed:

• CKYC Check: We first verify if the investor has an existing CKYC (Central KYC) record. If yes, we use it directly.
• Fresh KYC: If no CKYC record exists, fresh KYC is completed via KRA (CVL KRA) using OVDs — PAN, Aadhaar, address proof, photograph, and bank account details.
• In-Person Verification (IPV): For physical onboarding, IPV is conducted at our office. For online onboarding, video-based IPV (V-CIP) is performed by authorised personnel.
• FATCA/CRS Self-Declaration is collected from all investors.
• For non-individual investors (HUF, Trust, Partnership, Company), additional documents include: PAN of entity, registration certificate, authorised signatory list, beneficial ownership declaration (UBO), and board resolution / partnership deed.

4. Investor Profiling & Risk Assessment

Once KYC is complete, the investor undergoes mandatory profiling:

• Personal Details: Name, address, contact, occupation, annual income range, net worth bracket.
• Financial Goals: Wealth creation, retirement, child education, home purchase, tax saving, etc.
• Investment Horizon: Short-term (<3Y), Medium-term (3-5Y), Long-term (>5Y).
• Risk Profile Assessment: Completion of our 12-question Risk Profiling Questionnaire categorising the investor into one of 6 tiers.
• Existing Investments: Disclosure of current MF/equity/PMS/FD/insurance holdings to assess overall portfolio context.

5. Documentation Collected

The following documents are mandatory for every new investor:

• PAN card copy
• Aadhaar card copy (or alternate OVD)
• Address proof (utility bill / rental agreement / passport)
• Recent photograph (passport size)
• Cancelled cheque or bank statement (for bank account verification)
• FATCA/CRS self-declaration
• Nomination form (mandatory or opt-out declaration)
• Risk Profiling Questionnaire (signed)
• Client Acknowledgement & Consent Form

6. Account Setup & Folio Creation

• Once KYC and profiling are complete, the investor's account is created on transaction platforms (MFU / NSE MF Invest Platform).
• Investor Identification Number (IIN) on MFU and Folio number on NSE/individual AMCs are generated.
• Login credentials and welcome materials (including Privacy Policy, T&C, Investor Charter, Grievance Process) are shared via email and physical handover.
• The client is onboarded onto our backoffice systems (Redvision / Advisorkhoj) and CRM (Sanchay).

7. First Investment & Suitability Confirmation

Before processing the first investment:

• The recommended scheme(s) are explained, along with risk factors, expected horizon, and BER/commission structure.
• SID, SAI, and KIM links are shared with the investor.
• Suitability is confirmed against the assessed risk profile per our Suitability Matrix.
• Investor's written/digital consent is obtained for the specific transaction.
• Transaction is executed via the appropriate platform and confirmation is shared.

8. Welcome Communication

Upon successful onboarding, every new investor receives:

• Welcome email/letter from Shah Financial Services
• Login credentials for portfolio tracking (Wealth Elite / Sanchay)
• Copy of all signed forms and KYC acknowledgements
• Investor Charter & Grievance Redressal contact details

9. Data Privacy & Security

All personal data collected during onboarding is processed in accordance with DPDPA 2023:

• Data is collected only for the stated purposes (KYC, transaction processing, regulatory compliance).
• Digital records are stored in password-protected backoffice systems with role-based access.
• Physical documents are stored in locked cabinets at our registered office.
• Data is shared only with AMCs, RTAs, KYC agencies, SEBI/AMFI as mandated by law.
• Investors have the right to access, correct, and request erasure of their data per DPDPA 2023.

10. Records Retention

All onboarding documents, KYC records, risk profile assessments, and consent forms are retained for a minimum of 8 years from the date of relationship termination per SEBI/AMFI/PMLA requirements. After the retention period, records are securely destroyed (digital: permanent deletion; physical: shredding).

11. Periodic Review

• KYC details are reviewed periodically and updated when material changes occur (address change, contact change, etc.).
• Risk Profile is reassessed annually or on material life events.
• FATCA/CRS declarations are refreshed every 3 years or on change in tax residency.

12. Refusal of Onboarding

Shah Financial Services reserves the right to refuse onboarding in cases where:

• KYC documents are incomplete, forged, or unverifiable.
• The investor refuses risk profiling.
• The investor appears on any sanctions or watch list.
• Source of funds cannot be reasonably explained (PMLA red flag).
• Any other reason deemed appropriate by the GRO in the interest of compliance.

13. Policy Review

This Client Onboarding Policy is reviewed annually or whenever SEBI/AMFI regulations are updated. Any changes are communicated to all team members and reflected on this website page.