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Kruti is an accomplished compliance professional who has an experience of over 14 years. She has spent a decade servicing clients in the financial services industry (RA, RIA, PMS, AIF) across India. 

As a Practising Company Secretary, she was one of the first to establish an independent practice focused on SEBI related registration and compliance. She has helped register, audit and advise several marquee names in the space. (Testimonials)

Kruti is committed to ensure that registered participants see and use compliance as more than a cost centre, as a trust building tool leading to better business outcomes. She is known to transparently bring up difficult issues for clients and address them promptly.

She also provides thought leadership with her blog where she covers current regulations as well as the possible direction. She has conducted webinars and training sessions to educate industry members. 

She has been covered in the media and has also been a speaker at the webinars organised by various organisations in the industry. 

Kruti is ably supported by fellow experienced professionals and a dedicated team to offer the best in class services. 

You can follow her journey and thoughts on 

Read about Kruti’s journey so far.

If you have any questions about a career in the field, write to her at kruti@cskruti.com

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141 thoughts on “About”

  1. GM Ma’am,
    I am Post Graduate from Amity Business school(2004 pass out) at that time this was not Govt recognised. I am MF distributor since last 10+ years. I have cleared NISm RIA level 1 and 2 . Can I apply with SEBI as Individual category RIA. pl advise.

    • Hi Jetten, In my view, SEBI can consider your PG provided it is in activities relating to financial products or markets or securities or fund or asset or portfolio management and is of 2 years duration.
      SEBI considers the experience of MFD business. However, SEBI may ask you to surrender or discontinue the MFD license.

  2. Hi Kruti,

    Thanks a ton for this blog – very very helpful.

    I am stuck in one of the steps. After registering on the SEBI Intermediary portal for Research Analyst, I got a confirmation email from them. Login ID is also created (per the website). However I am waiting for the activation email from SEBI last 7 days. In your blog post you mentioned 2 to 3 days waiting is normal.

    Can you please advise what I need to do?

    Best Regards
    Poulomi

  3. For Research Analyst, does the entity and the person to whom advice is given need to have any agreement ?How can the RA charge fees for the services rendered? is it semi annual or annual? any limits to the amount that can be charged?

    • Agreement is not mandatory under RA regulations. In my view, RAs can charge only subscription based fee. There is no limit on the amount and the periodicity of charging fees.

  4. I am SEBI registered RESEARCH ANALYST here I am not getting support in compliance. onboarding to Audit I need full support. can you guide me in that

  5. I am a SEBI registered Research Analyst, I want to create a distributor/referrer channel, does my distributor/referrer need any certification-AMFI or NISM. If yes then under which regulation and is there any circular regarding this

    • There is nothing mention in the RA regulations about using referrer / distributor for RA services and also there is no circular regarding the same.

  6. I am Independed RA , can i associated with compnay like advisormandi or others? Where they collect the fees from claients and they share due % share to me? and advisor mandi it self is not SEBI RA, then it is legal ? any issue arise for me?

    • I am not sure how SEBI sees this kind of arrangement where revenue is being shared. Just make sure that the research services / recommendations are given in your name if your SEBI RA registration number is being used.

  7. Are the individual research anlaysts need to get audited. My interpretation is only entites like companies llp need to get audited.

    • Yes, all research analysts, whether individual or corporate, are required to get audited. This is applicable since the regulations have been in force.

  8. Dear Ms. Kruti,

    I need your guidance on the latest circular published by SEBI on Dec 13, 2021 regarding the Investor Charter which is required to be published by all SEBI registered IA’s and RA’s. My question is:

    “Does the Investor Charter have to consist of exactly the same content as provided in Annexure – A of the circular or can it be tailor made according to the Investment Advisers business details and other requirements?”

  9. Hi Kruti, can one get registration as a research analyst if he’s already holding ARN number of amfi?

  10. Hi CS Kruti,

    Is it necessary to get SEBI registration for becoming research analyst or investment advisor? or by passing the NISM exam we can work as non-SEBI registered research analyst or investment advisor, as the case may be with appropriate disclosure as Non SEBI registered research analyst or investment advisor.

    • Hi Devesh, if you are planning to charge fees, you need to get registered with SEBI as an IA or RA. Just passing NISM exam is not sufficient.

  11. Hi kruti,

    I want to Apply for SEBI Informal Guidance scheme 2003, but could not find the procedure. Can you please help with that?

  13. Hi Kruti

    Have applied for RA certification on the 31st July and have mailed the Form A as well, it has been 2 months now have not received any form of communication from SEBI.

    Am aware SEBI has to reply in 30 days but still no form of communication from their end.

    The processing application status is mentioning that it is “under process” but am concerned with the time being taken can you please assist me on what i should do further and what is the estimated time frame required.

    Thanks a lot

    • Hi Yashesh, pls contact SEBI’s regional / local office near you and send the email to the concerned officer.

  14. Dear Kruti,

    Meri last working company me Sebi ka inspection hua tha jiska order abhi tak pass nai hua h or mene sebi registered RA ke leye apply kiya h kya mujhe application me Sebi local office se dikkat ho sakti h

    • Hi Sohan, are you still associated with the company? Were you involved in providing services to clients on behalf of the company? Why was the inspection carried on by SEBI?

      • Ji mam 5 yrs ho gae the license renewal ke time par sebi ka insection hua h or me waha par research analyst ki post me ppoint tha jisme ki me 1yes bina nism ke recomendation provide karta tha

        meri company ka abhi tak order pass nai hua h to kya mujhe registration lene me dikkat hogi kyuki me purani compani se belong karta hu

    • Hi Shubham, you can give research recommendations and research reports to your clients. The recommendations can be for short term and / or long term. Not sure what do you mean by trading advice.

  16. Hi Kruti ,

    I have a doubt regarding registration ra i have applied for INDIVIDUAL Research Analyst in which i have prepared research report as well as recommendation in that case what is the Applicant category its Independent research firm or individual research Analyst

  17. HI

    THIS IS CA DEEPAK GUPTA FROM PUNJAB. CAN I HAVE YOUR WHATS UP CONTACT. LIKE TO DISCUSS ABOUT RIA OF FOREIGN SUBSIDIARY

    THANKS
    9463953945

  18. Hello Madam,
    This is Mayur here. I have applied to SEBI for RIA on 2 previous occasions, once in February 2020 and after i was informed to do so again in June 2020. But my application doesn’t find a mention in their Status Report. I did send an email to them asking them for the reason for the same but all they told me was to apply again online which i did in June 2020. Still the online status shows “Under Process”.
    I meet the criteria of work experience as well as professional qualification/NISM qualification. But still i have not received a satisfactory resolution as to why the delay.
    Can you advise/ suggest anything.
    Thank you.
    Mayur

    • Hi Mayur, The only option now is to keep following up with the officer assigned to your application. Usually, SEBI does not respond atleast for a month after the application is filed.

  19. Hi, We would like to register with SEBI for Investment Adviser & We are ready to avail your service on this. Need your Guidance & Support to get the formalities completed.
    Kindly mail me for the next step.

  20. Hi ,

    Iam graduate B.COM & having experience in 4 year experience in broking industry & 4 year experience in IA as a research analyst after new amendment qualification requirement i will eligible for apply new registration of IA.

    I have TA certification NCFM
    RA NISM
    IA NISM

    • Hi Aman, you will also need a professional qualification / post-graduate degree / post-graduate diploma.

        • Yes, you can apply provided you have the relevant experience certificates with you which mention about your experience.

          • I have only one more doubt.
            I have holding IRDA (Health Insurance Agent) Licence this creating any problem during registration

            • SEBI may ask you to surrender the license. However, best is to confirm this with SEBI’s regional/ local office near you.

  21. Hello Mam.

    Can you please help me out

    I am in process of forming a Company
    and
    My system is not supporting the Form AOA and MOA- I mean the subscriber sheet is not showing up. Once the subscribers put DSCs on it.

    Do you have any solution?

    • Hi Haresh. It means working experience with broker or a research analyst in preparation of research reports or arriving at a recommendation or call of giving analysis on stocks, mutual funds, derivatives, etc. Hope this helps.

  23. Hello Ma’am,

    I have one Query Regarding that Can a Company Secretary in Employment become a Mutual Fund Distributor after Passing NISM Exam ?

    • Hi Dhrumil. Yes a CS can. However you will also have to check if the employment agreement allows you to do so.

      • Hello Ma’am,

        Having Query Regarding that Can a CS in Employment become a Insurance Agent and Post Office Agent ?

        • Hi Megha. Did not read anywhere that CS in employment cannot become an Insurance Agent. Best is to get in touch with the institute and get clarification. You should also check your employment agreement for any restrictions.

  24. Hi CS Kruti,

    Presently i am a mutual fund distributor and getting my commission from AMC’s, now i am interest to become SEBI registered Research analyst.

    If i registered as a RA, can i continue my mutual fund distributor work parallel or not.

    as per SEBI, Investment adviser (RIA) cannot do mutual fund distributor work parallel, same condition will apply
    for Research analyst?
    Please suggest

    • Hi Vishwanath, will you be providing research on stocks or mutual funds? I am not sure if SEBI will allow you to continue with MF distribution as SEBI may see this as a conflict of interest. Best is to get in touch with SEBI’s local office near you.

  26. can a company secretary apply for investment adviser? reg 7 (1) says “A professional qualification or post- graduate degree or post graduate diploma in finance, accountancy, business management, commerce, economics, capital market, banking, insurance or actuarial science from a university or an institution
    recognized by the central government or any state government or a recognised foreign university or institution or association”.
    membership of CS falls individually under “professional qualification from an institute” but the subject is not clear, unlike in case of a CA which fall under “professional qualification in accountancy from an institute”

    please guide.

    • Hi Supriya. Yes CS is considered as a professional qualification. You need to have your membership number before you apply to SEBI.

  27. Hello mam,
    I want to start my section 8 company for education purpose for poor students. I want only director of it my self I saw ministry website about can’t find procedure for section 8 company formation.

    • Hi Mansur, I am not sure if I understand your query correctly. For section 8 company, you need minimum two directors. If you are still looking to form section 8 company, pls let me know.

  28. Hello Kruti, one of my friends is working as an employee in a company. He wants to become a director of a company and also continue his existing job. Will there be any problem with that?

    • Hi Mallesh. In my view there should not be an issue as a director. However he has to check his employee agreement with his company.

  29. Hello Kruti..What i was trying to ask was ..if i work as part time RIA with my current job in IT industry..can SEBI raise the concern..as i have two source of income

    Thanks

    • Hi Ranjit, as I mentioned earlier, I don’t think SEBI will have any concern. However, best is to confirm with them.

  30. thanks Kruthi,

    what is success rate if i have professional qualification B.E. + PG diploma and i apply for SEBI RA Registration and fulfill registration cafeteria.
    Also Can any other RA/Firm/advisory company give me some kind of licence/right by paying and I can do consultation under their name and charge to my customers.

    thanks for your advice

    • If you have PG Diploma as required by SEBI and also fulfill other requirements, then you can go ahead and apply to SEBI.
      You can have an arrangement with another advisory company where you can provide research services to that company and get consultancy fees. You cannot charge customers through them. You still need to fulfill RA requirements.

  31. Hi Kruti,

    Sorry if I was not clear.

    I am working in personal technical research and giving calls to friend and social media till now. They are working well. I want to start this as business and want to start charging my customers as getting good response. I tried to find information about RA and RIA registration from SEBI but seems a lengthy process as I am having only a B.E. Degree and working in IT. So I thought of searching information if I can get a broker terminal – is it makes me eligible for selling recommandation (which you already answered).

    So my query now : is there any third was Kruti which allows me to sell my recommendation and research.

    Thanks so much for taking time and answering Kruti.

    Thanks

    • Hi Raksha, unfortunately there is no other way. You either need professional qualification or post graduate degree or diploma OR you need to have minimum 5 years of working experience in the field of research or analysis.

  32. Thanks Kruti , you answered my query.

    I am already working in stock technical research and planning to take monthly or quarterly fee for my subscription with my customers and was looking for this broker route.
    Could you pls suggest what is other route for same as getting SEBI “RA” and “RIA”(registered investment adviser ) registration is very lengthy process.

    thank you
    Raksha

    • Hi Raksha, not sure if I understand your plan correctly. If you are already a broker and are providing calls to your clients who have availed your brokerage services then you are currently exempted from getting registered with SEBI. However, you have to comply with chapter III of IA regulations. If you can provide more details about your query, I will be able to answer it well. You can also email it to kruti@cskruti.com

  33. Hello Kruti,

    I want to work as SEBI research advisory and want to sell my recommendation in future.
    I am also planning to take a Dealer terminal from Broker, is this terminal allows me to sell my advice.
    could you pl advice.
    sorry not able to find relevant advice and found your blog very useful.

    thanks , Raksha

    • Hi Raksha. Will you be getting any commissions from the broker? As per SEBI you can either be an advisor or can be a broker/AP. SEBI does not allow you to be both as SEBI consider this as a conflict of interest. Hope I have answered your question.

  34. Hi Kruti, I came across your blog while searching for RIA and PMS. This space is very informative and thanks for your efforts.
    I have two questions. I am a member of ICWAI and regulation 4 (f) exempts registration. Does it mean that I can start practicing right away or need to still communicate with SEBI? Also, does this regulation “who provides investment advice to their clients, incidental to his professional service” means that ICWA has to be already in practice?

    • Hi Jayesh, the exemption mentioned under Investment Advisers Reg. says “…who provides investment advice to their clients, incidental to his professional
      service”. This means that if a person is already your client and availing your CWA service, and then you give investment advice to that person, you are exempted. But if you give advice to other people or general public, you need to get registered as IA with SEBI. Yes, CWA has to be in practice to avail this exemption. Hope I have answered your query.

  35. Hello Kruti,

    With your Guidance i have got my SEBI RIA completed and have become RIA now.

    In my Business Plan ..i told Sebi ..that i will generate leads from my Blog..

    Now my concern is that i am still working in my Job which is in Engineering Sector..as my project timeline got extended by 7 months..because of the our product Flaw..

    So will this be a problem..that i have got my RIA and still working in a diffrent sector..

    After this job..i am planning to start my own practice or i will take a job in body corporate RIA..

    Pls help

    Rajneet

      • Hello Kruti..Really appreciate your response..

        My concern is more from SEBI compliance and Audit perspective, Will they raise the concern that i am not practicing as RIA or working in a different sector..in-spite of getting the licence?

        Thanks

        • Hi Ranjit, I don’t think SEBI will have any issue. As soon as you start taking clients, you have to be compliant of the regulations.

          • Really Appreciate your Response..Just a final Thought..can i start taking clients or practice while doing my job in an IT industry?

            As i have already start getting queries to help people on their Financial concerns and i am single can devote time to my practice after my work hours and on weekends.

            Thanks Kruti

    • Hi Ankit, as per SEBI you need post-graduate degree or post graduate diploma in finance, accountancy, business management, commerce, economics, capital
      market, financial services or markets. Not sure if the course qualifies for the same. I would request you to confirm with SEBI’s regional office near you.

  38. Hi! I am sub-broker with a national broking firm and an IFA having my own ARN and distribution. Have cleared my Investment Advisor exam and now wish to register with SEBI. Can you help guide and prepare the documents and explain the process. Thanks.

    • Hi Nitten, sure will be happy to guide you. Can you pl send an email mentioning your education qualification and number of years you are a sub-broker and a distributor. Pls send an email to kruti@cskruti.com.

    • Hi Manish, if you are researching in spot commodities, in my view you need not get register with SEBI. Regarding profit share, it all depends on your contract with the person with whom you are working.

  40. Hi. Please reply if possible. If some one handling account and getting salary and commission on profit as a freelancer or employee of individual then as per normal employer and employee can SEBI create problem. Not joined as financial advisor or any analyst. If prove working as assistant or agent of that person on mutual understandng like friends, relative etc. Grateful to you if get answer.

      • Thanx mam.Actually I had very good knowledge in trading commodities on Mcx. Many people are interested to work with me in profit share.But as trading in mcx after reading your blog seems it is securities. My qualification is CS but I have not done any training. So as I am working independently my experience does not count. So if my client hire me on salary like normal employee or freelancer as they are busy in their day to day job.so can Sebi create problem on hired by some one as his employee or agent. Otherwise they will pay me gift. I have no problem to pay taxes. I have very bright future in it but I don’t want Sebi problem till I am in this country. After that I leave this country for ever.

  41. Thanks a lot Kruti for reply.

    I am working in IT company for 18 yrs.

    I spent 7-8 years with financial products and institutions like Apolo sindoori capital for brokerage services, DSP Merrill Lynch, jpms chase, Citi bank and bank of America as analyst but all the time into IT side.

    Coming to the 2nd points, what post graduate degree and diploma SEBI looks for.

    Are these need to be done in any particular subject and any post graduate will do.
    If I get MBA in finance degree in next yr or so, do I need any experience also after that or this is sufficient to fulfill the criteria.

    Thanks

  42. I am engineer working in IT for 18 years and spent 8+ years in finance side. I have NISM RA certificate, want to know if I am eligible for SEBI registration. Can you pls help with registration.

    thanks

    • Hi Ankit. To become eligible you should have professional qualification or post graduate diploma or degree. If not, then need to have at least 5 years of expertise in research related field. Not sure what you mean when you say you have experience in finance side. If you can pl let me know the details. Thanks.

  44. Hi Kruti. Thru Quora somehow I landed on your blog. Went thru it and am impressed with the way all the information is laid out. Have just subscribed to your blog by entering my email id. Hope to keep in touch. Cheers Ujjal.

  46. Great Work Kruti!! I’ve been reading your articles past few days and found them really handy. I’ve an educational blog on share market (named Trade Brains) and I’m planning to apply for RA soon. Your RA guide has helped me a lot. Thank you for sharing your knowledge. Cheers! __Kritesh

    • Many thanks Kritesh. Do let me know if you are looking for any professional services to make RA application.

  49. Hi Kruti….I read your articles regularly and I must say they are very insightful. I had a small query regarding SEBI Investment Advisory License. If the license expires in 2022 and the NISM certification expires end of this year, is one supposed to undertake NISM level 1 and level 2 exams again before this year ends. Though the SEBI licence is still valid till 2022.

    • Hi Nalini. Yes, you need to renew your certification. Your NISM certificate should be valid at all times.

  51. Hey Kruti!

    Excellent piece of info. Pretty impressed.

    I also am looking for solution on issue related to Compliance officer’s Eligibility / Roles & Penalty that may be applicable for Portfolio Management Services.

    • Hi Shanthan, as per PMS regulations, there is no eligibility criteria for Compliance officer. However, he / she needs to be an employee of the company. Also, there is no individual penalty for the compliance officer. In my view, the penalty will be for the company in case of non-compliance.

  52. Hello Kruti. Thanks for your valuable contribution on SEBI RIA process.
    Would you know if a PG diploma in Finance without the 5 year experience in Finance qualify for applying for a Sebi RIA. Also can this diploma be acquired by way of distance education mode and not full time?

    • Hi Ganesh, Yes you can go ahead. Make sure that the PGD is from a central or state government recognised university / institute.

  53. Hi Kruti, you are doing excellent service. I read your article on Trademark application on your previous blog. You explained it beautifully. All my doubts were cleared. I just want to know what is Legal Status in Trademark Registration form ? Should we write Sole Proprietor ?

    • Hi Ankit, thanks for your feedback. The legal status will be the status of the applicant. So if you are applying for a trademark as an Individual, you should mention as “Individual”. If you have a sole proprietorship firm, pl mention the same.

  55. hai madam ,

    i was just googled to get the information to start a portfolio management service ,especially the certification requirement.your blog is very helpful and informative .
    Thanks a lot for your great work.

  56. Need your guidance for registering as a Sebi registered research & technical analyst , I have done NISM SERIES- XV Research Analyst Certification Examination on Feb’2017.

  57. First of all I want to thank you kruti for providing a wonderful information on your blog. A particular article “When SEBI Research Analyst Regulations do not apply to you” is very interesting and really helpful for me as I started my personal blog tracking my personal investments. Please continue doing good work & Cheers!!!!!!!

  61. Iam highly impressed with your handling of queries. Most people today are money oriented ad always work for money. But i see you to be very humane which is the most touching aspect in you. In fact i had some doubts and i raised it with you and you obliged by replying promptly.

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