URGENT ACTION REQUIRED - Change in EUIN Remediation stipulated periodNo. of comments:137 Srinivasan, Chennai, 13021 On 13-Dec-2013

As you are all aware indicating EUIN No. on any MF purchase transaction along with the ARN No. has become compulsory. If the EUIN No. is not imprinted on the application then the brokerage will be with held. If within 30 days if a declaration is signed by the investor indicating the EUIN No. then the brokerage will be paid to the distributor. But as per the recent AMFI circular dated August 27, 2013, the stipulated period for remediation (clause 6(d)) stands amended as under: "The current process of providing 90 days for remediation from the date of transaction, failing which commissions on un-remediated transaction shall be forfeited, will continue till September 30, 2013. Remediation period shall be reduced to 30 days from the date of transaction for transactions submitted post October 1, 2013. W.e.f January 1, 2014, remediation period shall be brought to 7 days from the end of the month in which transaction is submitted i.e. All transactions prior to January 31, 2014 shall be re mediated by February 7, 2014 and within 7 days following subsequent months." THEREFORE THE CURRENT CIRCULAR FROM AMFI WILL DO AWAY WITH BOTH 30 DAYS AND NECESSARILY MAKE THE PERIOD OF REMEDIATION TO 7 DAYS FROM 1ST JAN 2013. I THINK THE CURRENT PROCESS OF 30 DAYS IS FINE BUT 7 DAYS IS TOTALLY IMPRACTICAL. THERE ARE SITUATIONS WHERE THE DISTRIBUTOR MISSES THE EUIN NO. ON THE APPLICATION AND IF THE INVESTOR IS OUT OF TOWN OR STATIONED OUT OF THE CITY OR AN OUT OF THE COUNTRY IT IS PRACTICALLY IMPOSSIBLE TO GET THE REMEDIATION APPLICATION SIGNED WITHIN THIS 7 DAYS. I REQUEST WEALTH FORUM TO TAKE UP THIS ISSUE WITH AMFI AND ITS COMMITTEE AND FIND A FAVORABLE SOLUTION TO THE PROBLEM. AT A TIME WHEN IFA'S ARE FACING DIFFICULTIES IN CONVINCING CLIENTS TO INVEST IN MUTUAL FUNDS, SUCH THINGS SHOULD NOT STAND IN THE WAY OF GENUINE TRANSACTIONS. THE PROCESS SHOULD BE CONDUCIVE FOR INCREASING AND PENETRATING MUTUAL FUND BUSINESS AND NOT OBSTRUCTING. HOPE AMFI WILL LOOK INTO THE SAME AND MAKE RELEVANT CHANGES FOR THE BENEFIT OF ALL IFA'S AT LARGE.

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Comments Posted
s n bartake ARN NO :7819 mumbai, 07 Dec 2014

Present limit in period of 7 days, to remediate EUIN deficiency in a transaction done on the last day needs itself to be remediated. Period of remediation should be at least one month from the date of transaction. Again, why can''t IFAs be exempted from mentioning EUIN if they don''t have any selling staff and themselves provide all services including selling to their clients ?

Ravindra Anturkar ARN NO :ARN-15755 Pune , 27 Apr 2014

This is unjust. Why so much importance is given to EUIN No Why ARN is not enough. This is one more hurdle in MF business . I think AMFI wants to discourage MF business . All its officers must also reduce their salaries to save costs and we will help them to reduce their take home salary by giving new ideas e.g. Basic, DA , Conveyance, HRA etc. Firstly they have stopped our commission and still they are not happy , so they found one more way to cause inconvenience/ reduce our income. They now must start from themselves , start working on zero salaries , if they get marks on the basis of our recommendation then only they should get payment . They do not know how much we have to struggle to get the business , how much we have to spent (time,petrol etc.) to give services without anything in return .

SATISH KUMAR JALAN ARN NO :40370 VARANASI, 16 Feb 2014

to provide a period of remediation of 7 days is absolute non-sense. I am at a loss to understand the rationale behind this move, it should be taken back immediately.

Sam Koshy ARN NO :5727 KOLLAM, 09 Feb 2014

Dear All, Has anyone of received an official communication from AMFI or Any AMC that the status quo ( 30 days remediation period)will be maintained till June 2014 ? Infact , I received one of the top 3 AMCs brokerage statement last week and it was mentioned that from Feb 2014 onwards the remediation period will stand as 07 days. Is this the official decision of AMFI ? Somebody pls advice ...

K.Sambath kumar ARN NO :2038 erode, 03 Jan 2014

The time reduced is not fair. In NFO s the AMC releasing commission only after 45 days to 2 months.

Amresh Tyagi ARN NO :20170 Saharanpur, 30 Dec 2013

It''s not realistic action by AMFI 7 days is much less to submission said latter. Kindly should reconsider the matter by AMFI.

Benzi Thomas ARN NO :41038 Kollam, 30 Dec 2013

I agree with Mr. Sam Koshy''s suggestion to capture EUIN automatically with ARN in the case of IFA where only one EUIN is issued against an ARN Number. It will sort out the problem of a number of IFAs. For others, a period of 30 days should be allowed.

Raghuramam ARN NO :82836 Hyderabad, 30 Dec 2013

The purpose of EUIN is to fix the responsibility of selling / advice on to a single individula. That said , if an IFA is doing the business all alone , SEBI , AMFI , and the AMC''s have to provide a mechanism to default this EUIN based on the ARN no. If this is not done , the current system is allowing the AMCs to enjoy the AUM that actually accountable to IFA''s efforts! I am sure that is not their intension , nor it shall be allowed.So I sincerely and earnestly appeal to all the regulatory and executive authorities to look in to this issue on top priority , so that the IFA''s are duely revarded. The same logic shall be applied to online transactions also , the ARN, and EUIN shall get defaulted from the folio , created through the IFA , for all transactions.

Rajiv Jhaveri ARN NO :Jhaveri Investments MUMBAI, 30 Dec 2013

What is the need of EUIN? Actually it is necessary mainly to identify & trace the marketing personnel so that wrong sales can be discouraged. If any distributor is working single handed, whether EUIN is printed or not only one person is responsible, that is distributor himself, so EUIN is not necessary for individual distributors not having any marketing staff. So in this thread we all should request total relaxation in requirement of EUIN. All individual distributors have already submitted declaration about marketing staff. Now it is needed to wave the requirement of EUIN for Individual distributors having no marketing staff.

hanamant p salagare ARN NO :64716 diggewadi, 29 Dec 2013

i am intrested in all mf

C NARAYAN RAO ARN NO :32758 Hyderabad, 28 Dec 2013

Why so many stipulation. Is ARN not enough? After all it is the basic need/qualification to mobilise mutual fund business.

Ghazali ARN NO :58316 NewDelhi, 28 Dec 2013

I really apriciate your point and urge to take Wealth Forum to take ahead to AMFI this massage. Thanks.

KOLLIPARA BHARAT KUMAR ARN NO :49834 HYDERABAD, 28 Dec 2013

Dear Mr.Ramakrishna, what about the cases where an investor invests online and forgets providing EUIN(the investor has to fill in ARN as well as EUIN while doing online investments and there is a probability that he/she might err also)? We know that not many fund houses are providing “EUIN missing” feed promptly and the distributor may not even know that EUIN is missing. Is it fair on the distributor in such a situation that he/she lose commission after all the hard work that he/she puts in? Why should one make it complex when there is an easy solution of declaration akin to self declaration is possible?

P. Ravi Krishnan ARN NO :Krishna Fincon Services Rourkela, 28 Dec 2013

Amfi is simply wasting our precious time and energy. They think that by 30th June 2014, we IFAs will calm down and will forget about EUIN. All our IFA friends are requested to keep ourselves shouting and fight to finish through this wealth forum discussion till AMFI removes EUIN rules for individual IFAs....

praveen chhajed ARN NO :0599 pune, 28 Dec 2013

freinds, i am of the same opinion as above... in addition to that i wud like to suggest that , IF the folio is created with the arn and euin numbers, then further transactions shud automatically be treated as arn and euin complied, unless and unteill investor specifically mentions not to go with arn/euin..

ASHUTOSH SOOD ARN NO :ARN-2427 CHANDIGARH, 28 Dec 2013

I do not understand the logic behind implementing the EUIN for Individual brokers. When every year in the beginning we as proprietor gives self deceleration that " I being individual broker and I do not have any sub broker. " In this case of onus lies on me as I do not have any employee selling MF, then why should we come compulsory under EUIN .

SANTOSH KUMAR BAJAJ ARN NO :ARN-35755 Raipur, 27 Dec 2013

In my opinion, EUIN mandate itself is useless think of IFAs as it we are not the employees of any AMCs nor we have any sub-brokers. Then, why should we use EUIN which means "EMPLOYEE UNIQUE IDENTIFICATION NUMBER", as our ARN No. itself serves this purpose. So, we all together should fight against EUIN Mandate completely.

Navin kumar ARN NO :83441 Patna, 27 Dec 2013

Mr Sam suggested the valid remediation for the IFAs meanwhile I am following the same as suggested by Mr Ramakrishna K since EUIN made mandatory for IFA though unwarranted for the IFA having no sub broker.

Ramakrishna K ARN NO :33313 Bangalore, 27 Dec 2013

Dear Friends, You worry so much about missing the EUIN. Why don''t we prepare one seal with both ARN and EUIN, together This will avoid our BIG HEADACHE. Even if the space provided is not suffficient at the ARN code place, your stamp at any blank space around and assure the thing done. Let us use logics / brains/ senses to make ourselves relieved than grumble.

Srinivasan S ARN NO :13021 Chennai, 27 Dec 2013

Dear Vijay, At the outset I am very happy that Wealth Forum took the initiative on the issue with the concerned. I on behalf of the IFA community thank you and the Amfi Operations & Compliance Committee for all the efforts they have taken for the said issue. I am sure IFA''s will ensure and put in place the necessary mechanism for capturing the EUIN No. along with the ARN No.. The solution given by Amfi Committee still I feel does not address the problem fully i.e., the problem of implementation within 7 days in case of missing entry of EUIN no. on the application or transaction slip. I am sure you will accept that an IFA is more interested in getting his brokerage for the business done rather than anyone else. He will be very cautious in putting the relevant nos. on the application, but there can be situations where he can err too as ''to Err is human''. Only in in such cases we need to look at the time taken for remediation. As you are aware Amfi states that if the Euin no. is missing then the IFA has to take a letter signed by his investor for remediation. The information on the missing EUIN normally reaches after 2-3 days by email and some AMC''s do send a letter which reaches only after a week. So the turn around time for the IFA to approach the client and get the same re mediated is not less than 2 weeks. If the client is out of station or the country more will be the time taken. I only request the Committee to consider the practicality of the problem and leave the 30 days remediation process intact. Some of our other suggestions: I also request the Committee is re format the application forms so that the EUIN No. can appear just below the ARN No. in a single box (one upon the other) this will help the IFA not to miss out the EUIN No.. The IFA''s also would like to know what is the purpose of EUIN No. for an independent IFA (working independently without an employee)? Also some clarity is required with regard to the brokerage - If the EUIN No. is not provided by an IFA within the stipulated time what happens to the Brokerage (to which account it is credited)? For an IFA''s why not the ARN No. automatically capture the EUIN No. also? I think the committee will also request all the amc''s to look into the short comings and expedite the necessary controls. I am sure the Committee will have a thorough look into the problem and give a practical permanent solution to the problem after putting themselves into an IFA shoe.

Mukesh Chothani ARN NO :0512 Nasik, 27 Dec 2013

At last AMFI understand that we are IFA & not clerk! In Economis where there is more Regulation & Less margin Employment generation is very low. When SEBI understand all this ? If we all come together & united then we change this. Its says that ACCEPT which you are not going to change & CHANGE which you are not going to Accept. Now every IFA decide what to Accept & what to Change.....!!!.

Sam Koshy ARN NO :5727 KOLLAM, 27 Dec 2013

The postponement doesn’t answer the basic question raised. Why does an IFA who don’t have any employee need to give EUIN on each and every application? Why can’t he give a simple declaration requesting to capture EUIN each time his/her ARN is stamped on an application?

P. VENKATARAMANAN ARN NO :12255 Rajapalayam, 27 Dec 2013

Thank you for your information. What can I do to know my EUIN ? I have not received the EUIN. regards Venkataramanan

Vijay Venkatram ARN NO :Wealth Forum Mumbai, 27 Dec 2013

I am very happy to share with you that the AMFI Committee on Operations and Compliance, in its meeting held on 20th Dec 2013, has decided to keep in abeyance until 30th June 2014, its earlier decision to bring down the EUIN remediation period to 7 days. This means that until 30th June 2014, the existing rule of remediation within 30 days will continue. The next 6 months should give all distributors sufficient time to get EUINs for employees where this hasn''t been done already as well as put in place mechanisms in their offices to ensure that EUIN is captured for all transactions, just as broker code is captured. We thank Mr. Saurabh Nanavati, Chairman of this committee and his committee members, for taking prompt action on this Discussion thread. Your voice is indeed heard, and is acted upon. Wealth Forum remains committed to taking up constructive suggestions, inputs and feedback that you provide in our Discussion Forum. We remain grateful to AMFI and its committees for deliberating and acting upon issues that we forward them, which you raise on Discussion Forum.

B BALAJE ARN NO :ARN-23759 TIRUPATTUR, 23 Dec 2013

Sir, AMFI may relax the remediation period 7 days to one month,such relax will help all IFA''s

ARVIND KUMAR SUMAN ARN NO :44093 Mathura, 21 Dec 2013

EUIN CONCEPT ITSELF IS WORTHLESS. ONCE AMFI IS ISSUING ARN TO ALL IFA THEN ARN SHOULD BE THE DISTRIBUTORS INDICATORS FOR ALL PURPOSES. THOSE WHO IS WORKING AS IFA THEY SHOULD NOT BE GIVEN ANY OTHER IDENTICAL NUMBER. THOSE WHO ARE WORKING THROUGH ANY CORPORATE BROKER THEY SHOULD BE ALLOTED A PARTICULAR IDENTICAL NUMBER LIKE EUIN TO AVOID IDENTIFICATION CONFUSION OF DEALING PERSON WITH INVESTOR (WHICH COMPEL THE AUTHORITY TO INTRODUCE EUIN CONCEPT).

Akshay Chhajed ARN NO :10237 Dhule, 21 Dec 2013

This is good ! AMFI thinks we are not IFA ,we are clerk!

Sam Koshy ARN NO :5727 KOLLAM, 20 Dec 2013

Dear Sunita Jain from New Delhi, Take up the issue with the particular AMC and ask for the reason for EUIN remediation. Tell them to send the reply to your email. Remember when you sending mails keep cc to their superiors. You manage to get the reply first, then if you are a member of an IFA Association take it up through them. If not mail me (samkoshy.cc@gmail.com). We will try our best to solve this.

manoj Kumar ARN NO :82599 ghaziabad, 20 Dec 2013

I have some clients , who has invested long time back in mutual funds. They do not have the data for the same. My suggestion / request to AMFI and our forum to escalate the matter with AMC''s to send the physical statement of to the clients once in six month. Cams is sending the statement to those clients who has been updated their email Id. But who has not been updated the same , they are not able to get the statement.

shravan singh ARN NO :40063 STEP 2 WEALTH FINANCIAL LUCKNOW, 20 Dec 2013

EUIN

S. Mutharasan. ARN NO :25361 Mumbai, 20 Dec 2013

It will be benefited to IFAs if EUIN automatically linked to ARN and SEBi Should accept this.

KANTI VAGHELA ARN NO :58450 Rajkot, 20 Dec 2013

Make ARN AND EUIN once registrars and update for the same.Yes,this is one of the best solution for all the distributors. because it saves times and also confusion for Distributors,amc and registar

samit pal ARN NO :30213 baroda, 20 Dec 2013

I don''t have any employee/staff/partner to work under/with me. I am an Ex-serviceman. I want work alone only in mutual fund for the person who can trust me. Writing EUIN No. is a useless work for the person like me, who is going to work sincerly for investor thrroughout life alone. So,it is not justified at all to the IFA to write EUIN , who is working alone. Regulator must educate Investor instead of creating hurdle to stop IFA to work.

B V Vijaya BE, CIS ARN NO :13962 Mysore, 20 Dec 2013

Auto capturing of EUIN defeats the purpose of implementation of EUIN. The period of 30days be increased back to 90 days as many times the investors them self may go out of country. SEBI and AMFI should think of any law / clause which is practical. In case of old investments the response from the customers is tough. The investor just trusts the advisor & leaves every thing for advisor.

Calibre Investments ARN NO :ARN-49710 New Delhi, 19 Dec 2013

Please look for simple and practical solutions to this and other problems affecting the industry.

Sunita Jain ARN NO :5314 New Delhi, 19 Dec 2013

EUIN is being demanded for old investments ( made in 2009) which have a trigger option. The amount switched to a scheme as per the trigger need not require EUIN. The statement of account is received more than 30 days after the triggered switch has been effected. How is one to remediate in such circumstances.

GEORGE SEKARAN ARN NO :85356 HYDERABAD, 19 Dec 2013

Auto capturing of EUIN that is mapped with a particular IFA`s ARN number will solve all the problems even if the advisor is out of station or abroad.

Rabindranath Barapanda ARN NO :8939 Kolkata, 19 Dec 2013

It will be helpful to the IFA community if the EUIN automatically linked to the ARN. Hope it will be accepted to SEBI comittee

Ramesh R Bhanusali ARN NO :3113 Calicut, 19 Dec 2013

When the system of EUIN was first introduced and the letter sent to all the Distributors (Valid ARN Holders) It was mentioned in the form to inform if IFA was alone and no other staff so that they can be eliminated from EUIN NO. Only ARN is enough. Now when they have taken new stand at least all IFA who are alone should be allowed submit once in a year the No.along with Self Certification which is given every year .

SRINIVAS CHANDOLU ARN NO :ARN-77718 VIJAYAWADA, 19 Dec 2013

CONTINUE OF OLD SYSTEM OF 30DAYS WILL BE ACCEPTABLE TO ALL AS IT IS AN AMPLE TIME FOR REMEDIATION.BUT AUTO CAPTURING WILL BE A HAPPY SOLUTION TO ALL.

R R Singh ARN NO :0810 Jamshefpur, 19 Dec 2013

EUIN should be captured with ARN automaticly

R R Singh ARN NO :0810 Jamshefpur, 19 Dec 2013

EUIN should be captured with ARN automaticly

ramkumar barchha ARN NO :0163 rajkot, 19 Dec 2013

Sir, when EUIN has become mandatory for all the type of transactions than it makes more sense to link it to an ARN.

Raghuramam ARN NO :82836 Hyderabad, 19 Dec 2013

Dear Mr.Narayanan, I don’t understand how the basic purpose of EUIN will be defeated if a declaration for Auto capture of EUIN of IFAs is taken, can you explain it please. I don’t think distributors with employees are so foolish that they don’t include EUIN as it in a sense is safeguarding their own interest and protecting them from the wrath of SEBI if mis-selling happens. With EUIN these big distributors have a chance to make an employee a scapegoat and get away from a harsher punishment. If there are no employees what is wrong in capturing the EUIN automatically? That way even if our investors miss giving EUIN in online investments we don’t have to run for remediation and concentrate on our business.

NARAYANAN P.S ARN NO :26382 MUMBAI, 19 Dec 2013

AUTO CAPTURE OF EUIN DEFEATS THE VERY PURPOSE OF EUIN. 30 DAYS SHOULD BE THE IDEAL TIME LIMIT. EUIN SHOULD HAVE BEEN MANDATORY FOR CORPORATES OR BROKERS WITH MULTIPLE EMPLOYEES/SUB BROKERS UNDER THEM WHO ALSO MARKET FINANCIAL PRODUCTS. INDEPENDENT FINANCIAL ADVISORS ETC SHOULD HAVE BEEN EXCLUDED AS THEY ARE ALL IN ONE AND NORMALLY ONLY HAVE BACK OFFICE STAFF ETC. UNFORTUNATELY WE IFA''S HAVE NO PROPER SAY AND REPRESENTATION TO EXPLAIN OUR POINT OF VIEWS.

RAMESHKUMAR G P ARN NO :ARN-1965 BANGALORE, 19 Dec 2013

WE request all concerned persons that if we mention ARN NO ,then by default it should take ourEUIN NO also either ONLINE OR OFFLINE . Rameshkumar ARN-1965

Mrs.Vedasree ARN NO :62624 HYDERABAD, 19 Dec 2013

I agree with the suggestion proposed, that a declaration may be brought in(like self declaration) to capture the EUIN associated with the ARN automatically(for both online and offline transactions). Yes it''''s a welcome move where to transact is made easy,by making a one time mandate for EUIN.

KULKARNI ARN NO :42924 HYDERABAD, 19 Dec 2013

I agree with the suggestion proposed, that a declaration may be brought in(like self declaration) to capture the EUIN associated with the ARN automatically(for both online and offline transactions). Yes it''''s a welcome move where to transact is made easy,by making a one time mandate for EUIN.

NAYAN ARN NO :70533 AHMEDABAD, 19 Dec 2013

Yes, please make auto capture of euin for ifa. It will be very nice if AMFI ppl can think deeply and remove the concept for at least IFA.

LALIT ARN NO :58937 BERHAMPUR-GANJAM, 19 Dec 2013

Asking IFAs to quote EUIN is completely against the concept of EUIN in letter and spirit. By default IFA is working independently and there are no employees. Even where the employees work the responsibility of the actions of the employees taken on behalf of the employer should rest with the employer and may be employer and the employee jointly. But in case where there are no employees with IFA those IFAs should be spared from these guidelines.

Narendra Kumar Sharma ARN NO :72881 Meerut, 19 Dec 2013

Its a good suggestion for auto capturing of EUIN and it will be very helpfull for IFA''s.

CVRN.RAO ARN NO :63569 HYDERABAD, 19 Dec 2013

If the EUIN can be captured automatically in case of IFA, since IFA has only one EUIN, then it should be made automatically linked. In this day of reducing paperwork and other unnecessary hassles, AMFI should get this automatic linkage enabled and reduce unnecessary hassle for the IFA. By putting ARN, and automatically linking EUIN for all IFA''''s, it makes a lot of sense. Please implement this ASAP and also for past cases.

Neelesh Gala ARN NO :74224 Mumbai, 19 Dec 2013

I agree with Mr. Sam Koshy''s suggestion to capture EUIN automatically with ARN in case of IFA''s where only one EUIN is issued against a ARN no.

arputharaj ARN NO :38069 chennai, 19 Dec 2013

I agree with the suggestion proposed, that a declaration may be brought in(like self declaration) to capture the EUIN associated with the ARN automatically(for both online and offline transactions). Yes it''s a welcome move where to transact is made easy,by making a one time mandate for EUIN.

Kalpeshkumar Vaghela ARN NO :31993 Vadodara, 19 Dec 2013

Individual Advisor has Same ARN no and EUIN no. So why to load the system

Dalapathy ARN NO :dalapathy finservices Coimbatore, 19 Dec 2013

I agree with Mr Sam Koshy''s suggestion but make the declaration valid till ARN is valid.

Ashwin ARN NO :82314 mangalore, 19 Dec 2013

If the EUIN can be captured automatically in case of IFA, since IFA has only one EUIN, then it should be made automatically linked. In this day of reducing paperwork and other unnecessary hassles, AMFI should get this automatic linkage enabled and reduce unnecessary hassle for the IFA. By putting ARN, and automatically linking EUIN for all IFA''s, it makes a lot of sense. Please implement this ASAP and also for past cases.

Raghuramam ARN NO :82836 Hyderabad, 19 Dec 2013

Suggestion to AMFI: Declaration as suggested by Mr.Sam Koshy may be in force till the expiry of ARN or as long as it is not cancelled by the IFA. If an IFA is doing business all alone , and one provides such decleration , all authorities( SEBI , AMFI , and the AMC''s) shall allow to default the EUIN with the ARN in such cases.

S.V.Rammohan ARN NO :27835 bengaluru, 19 Dec 2013

Already we have enough problems canvassing for MF with curtailed commission.With direct& online txns we will soon be out of picture.Why amfi&sebi make our life more miserable only they can reason.For IFA without any employees arn number alone is more than enough.If euin is not mentioned it means IFA is only responsible.

Ameerali M ARN NO :24260 Karunagappally, 19 Dec 2013

I support Mr Sam Koshy''s suggestion. Declaration should be valid till the ARN and EUIN are valid.

DB DESAI ARN NO :0234 KUDAL, 19 Dec 2013

Asking IFAs to quote EUIN is completely against the concept of EUIN in letter and spirit. By default IFA is working independently and there are no employees. Even where the employees work the responsibility of the actions of the employees taken on behalf of the employer should rest with the employer and may be employer and the employee jointly. But in case where there are no employees with IFA those IFAs should be spared from these guidelines.

P. Ravi Krishnan ARN NO :Krishna Fincon Services Rourkela, 19 Dec 2013

I fully support Sam Koshy''s suggestion... EUIN indication has to be stopped and this has to be linked with ARN''s expiry date. AMFI shuld implement rule that it should be applicable only for NDs, Banks and other sales persons only and not for individual IFAs..

ramesh ARN NO :72204 hyderabad, 19 Dec 2013

Continue old system, dont impose EUIN No compulsorry etc.,

Raajeev Chawla ARN NO :ARN-28987 Varanasi, 19 Dec 2013

A very good suggestion. If this is done the IFAs will be benefited. It''s a request to AMFI to consider the suggestion.

Alka Karnani ARN NO :Money Plant Kolkata, 19 Dec 2013

I totally agree, the AMFI should help the distributors by being proactive

ravendra kr. yadaw ARN NO :ARN-75996 sitapur(u.p.), 19 Dec 2013

EUIN should for sub broker & employee but not for IFA

KOLLIPARA BHARAT KUMAR ARN NO :49834 HYDERABAD, 19 Dec 2013

Suggestion to AMFI: As Mr.Sam Koshy suggested,a declaration for capturing of EUIN automatically solves the issue of most of the IFAs but the declaration may be allowed to be in force as long as the concerned ARN and EUIN are valid or as long as the distributor wishes the declaration to be in force. Fresh declaration may be asked at the renewal of ARN when ARN or EUIN is expired.

Hariprasad.G ARN NO :40175 Bangalore, 19 Dec 2013

I agree with Mr.Srinivasan, it is not practical to reduce from 30 days to 7 days.

Anil kapoor ARN NO :5893 noida, 19 Dec 2013

I agree with this situation.

Sam Koshy ARN NO :5727 KOLLAM, 19 Dec 2013

SUGGESTION TO AMFI ; PLEASE CAPTURE EUIN OF IFAs AUTOMATICALLY. Instead of affixing EUIN on each and every application we request AMFI to give IFAs a chance to give a declaration that EUIN associated with an ARN be captured automatically in all the transactions associated with that ARN. This can be done on a regular interval of monthly or quarterly basis. For those who doesn''t give such declaration, mentioning of EUIN may be made mandatory. It solves the issue of a vast majority of distributors who doesn''t have any employees(as they don''t have to lose commissions for not mentioning EUIN erroneously) and we can comply with SEBI order as well.

WalterCyrilPinto ARN NO :4803 udupi, 19 Dec 2013

Very valid observation Even 30 days is not sufficient In fact, the procedure requirement of investor signature should be done away. If the investor has not signed the ''only transaction-no advisor involved'' clause, IFA signed request should be considered for correction of inclusion of EUIN. Only, if the Investor wants to reverse ''only transaction''clause, Investor signed request, may be made mandatory. If the investor has made an option but later realises the need to get the assistance of an IFA, for service requirements, a provision should be made available to amend the option.

VIKRANT KULKARNI ARN NO :34033 PUNE, 19 Dec 2013

Lets fight for complete EUIN process removal for IFAs itself and ask AMFI that it should be applicable only for NDs, Banks and other sales persons only.

J.M.Sood ARN NO :ARN-3297 New Delhi, 19 Dec 2013

AMFI is an Association of Mutual Funds. Hence it is trying to watch the interest of fund houses and not be Advisers !!!!!!!!!!!

Banyan Financial Advisors ARN NO :74059 Agra, 19 Dec 2013

So true. It is ridiculous to have EUIN for IFAs. It is even more problematic to have a ARN renewal process along with EUIN registration. I would request Wealth Forum to take it further with AMFI to get his anomaly removed.

Navin kumar ARN NO :83441 Patna, 18 Dec 2013

EUIN stand for Employee Unique Identification Number. IFA should be kept out of this EUIN.

Santosh Kumar Bajaj ARN NO :35755 Raipur, 18 Dec 2013

Actually, all these type of regulations are imposed to harass the IFAs. We should first of all read the full form of EUIN i.e. Employee Unique Identification Number. It means it is specially for employees of NDs, Banks and other sales persons. But, it is not for IFAs who are directly engaged into the sales. But, unwantedly it is imposed on IFAs also. Lets fight for complete EUIN itself and ask AMFI to put an end for IFAs and should be applicable only for NDs, Banks and other sales persons only.

C SUBADHRA ARN NO :58400 MYSORE, 18 Dec 2013

We should fight against the remediation period of 7 days. Atleast it should be 30 - 45 Days. Otherwise one thing they can do. If EUIN is not mentioned , let them straight away reject the paper. They want business from us . But the rules are not supportive to us.

V.RAJU ARN NO :84625 Chenai, 18 Dec 2013

pls up date

Dilendra Kumar Nayak ARN NO :64153 Raipur, 18 Dec 2013

If It Is 30 Days Then Its Very Good For Seven Days We Need One Employee To Handle This Kind Of Issue

NIDHI KAPOOR ARN NO :22071 KANPUR, 18 Dec 2013

I TRULY AGREE WITH THIS COMMENT.

Duli chand Garg, mob 09414273105 ARN NO :62623 Sriganganagar, 18 Dec 2013

I think amfi may atleast give concession to ARN holders having only one EUIN number, who are individuals, sole proprietorship, partnership firms and HUF having singal EUIN numbers under their ARNs.

Vijay Venkatram ARN NO :Wealth Forum Mumbai, 18 Dec 2013

Wealth Forum forwarded this issue to Mr. Saurabh Nanavati, CEO, Religare Invesco MF and Chairman of AMFI''s committee on Operations and Compliance. We are happy to inform you that Mr. Nanavati has agreed to table this issue in his committee''s meeting scheduled on Friday, Dec 20th. Mr. Nanavati clarified that the 7 day remediation actually means remediation by the 7th of the following month. This means for transactions done in the first few days of a month, you will get sufficient time to complete the remediation process where required. Mr. Nanavati acknowledges that for transactions done towards the end of the month, the time period until 7th of the following month may be a little short. We hope to hear some positive news on this front, after the committee has deliberated on this matter on Dec 20th. Will keep you posted.

Harbindersingh ARN NO :82408 Anand, 18 Dec 2013

I completely agree with that 7 days are impractical decision & concerned authority should think over it immediately.

Sam Koshy ARN NO :5727 KOLLAM, 17 Dec 2013

Dear Abhijit Ashok Phadke, you don''t need to mention your EUIN number in all the SIP installments. In the case you mentioned , at the time of SIP login ie,in last DEC, EUIN was not mandatory. So nobody is authorized to block your commission on the EUIN case.

V.S.ILANGOVAN ARN NO :66956 dindugul, 17 Dec 2013

This is very good decision.

abhijit ashok phadke ARN NO :79590 pune, 17 Dec 2013

Dear sir/ mam, I want to ask that if I made sip of my client in last dec. for 20 yr period. Whether I should fill up form for all of them with my EUIN?

value ARN NO :65299 mumbai, 17 Dec 2013

7days is injustice,

B S Sahay ARN NO :ARN-10867 PATNA, 16 Dec 2013

I, totally disagree with the Cationed circular. I request Wealth Forum to take up the matter with proper authority and resolve the issue.

VIKAS KHANNA ARN NO :32164 AMRITSAR, 16 Dec 2013

I AGREE TOO,7 DAYS ARE NOT IMPRACTICAL, BUT SEBI AND AMFI WILL CONTINUE MAKING THINGS DIFFICULT AND CONFUSING FOR IFAs.

SATISH KAMAT ARN NO :ARN-14826 DHARWAD, 16 Dec 2013

Wheter the Market is good or bad ,concerned people should simplify & find favourable solution to the problem

Samir Sangal ARN NO :12510 New Delhi, 16 Dec 2013

The identity of all of us is being reduced to number/s. There should be only one number and AMFI no. is enough for distributors. In case of companies the employees are involved, the company can allot internal nos. for their administration as in the past. We are working with figures all the time and after hard work of study, research, advice to clients, proper filling of form, getting receipt and followup on these investments without remuneration alloting us nunbers is too difficult to adhere. Please keepone no. on form ie. AMFI no. and only where applicable internal Employee no.

Shrikant kulkarni ARN NO :ARN-6757 Pune, 16 Dec 2013

The very concept of EUIN is unnecessary and uncalled for. Regulatory body should think of simplifying the procedure instead of making it complicated. The market is not good and it is very difficult to hold on to the AUMs and if at this stage if you introduce more and more regulatory hurdles then it will be very difficult to do the business efficiently.

Manoj Singhal ARN NO :7665 DEWAS, 16 Dec 2013

Sir, I will also oppose the new remediation period of 7 days because if A IFA will not get the information then he cannot comply within 7days period. I request the AMFI/SEBI official to extend it for 30days to save the industry in the bad times like the same

KOLLIPARA BHARAT KUMAR ARN NO :49834 HYDERABAD, 16 Dec 2013

As Mr.Sam Koshy suggested, EUIN for IFAs should automatically be captured and commissions should not be lost by IFAs. For the sake of a few corporates, IFAs should not be made to suffer.

samit pal ARN NO :30213 baroda, 16 Dec 2013

Sebi make rule strictly to stop work. Unless we stop working sebi or amfi/amcs are not going to listen. Nobody understand ground reality. SEBI want to create equity market for FII , HNI & LIC. SEBI MAKING such a rule to loose money by retail / 95% people of INDIA in equity market.

ashit ghelani ARN NO :80899 rajkot, 16 Dec 2013

Dear all, EUIN no. is a big issue,one of my client got a mail from axis where he can invest online,he wanted to invest but in my code only so he saw my broker code and then proceeded but when EUIN column came he did not knew what it was and he simply went forward n invested so i will not get the commission but code is mine. So this is just like we have to serve investors without getting commissions this is a disaster by AMFI.All i say is if they wont to sideline brokers then sideline to full do not put us hanging around this is a meaningless clause. If they are so much concerned about investor put a clause that after every transactions done by an investor AMFI sends a transaction confirmation message to investor and also asks them whether it was an advise or there personal decisions. Some brokers might have misguided investors and AMFI is punishing all the advisors,IS IT FARE? RULE MAKERS SHOULD ASK THEMSELVES.

MEHMOODKHAN ARN NO :32950 NAVI MUMBAI, 16 Dec 2013

Yes 7 days is completely impractical

vikas batra ARN NO :6574 mohali, 16 Dec 2013

why are they just bringing it down, as for a single entity there is no use of euin as such and they will bring it down to 1 day and then 10 minutes so why are they trying to push us into corner, while if cams/karvy/amc misses it its our problem and is it a business of mutual trust or some group trying to ask others to fall in line and in first as money comes and goes from bank so what is the use of kyc at our end, think about it

Sam Koshy ARN NO :5727 KOLLAM, 16 Dec 2013

In case of corporate entities where there will be multiple EUIN holders, it could have been mandatory.But in case of IFAs where the IFA is the sole person who engaged in MF sales EUIN should not be mandatory or EUIN should be captured automatically even if its a execution only transaction. Instead of making more than 90% of ARN holders(who obviously are IFAs) suffer, the rule could have been, if EUIN is not affixed it should be taken as the EUIN attached to ARN code. After all no one is denying the fact that we have to affix EUIN as per SEBI regulation, but we want it to be automatically taken so that even if we ( or our clients while investing online) miss giving EUIN it would not have cost us our commission. It would have solved the issue for IFAs. But, it seems, if this logic is applied, corporate distributors will be under trouble and to safe guard the interest of a few big fellows a majority of small distributors are made to suffer. Moreover if EUIN is not affixed fund houses get to keep the commission. If it is profitable why change it and hence I guess no one is trying to get this rule modified. Expert opinion is that EUIN in its current structure is supporting corporate entities and not IFAs. Corporates give sales pressure to their employees. Poor employees have no other option but to follow orders. if misselling happens corporates will make that particular employee a scapegoat and escape from the wrath of SEBI.

VINITA GARG ARN NO :67866 NOIDA, 16 Dec 2013

THERE R CASES WHEN EUIN IS ON THE APPLICATION BUT AMC OR CAMS OR KARVY MISS THAT AND GV US REMINDER AFTER THAT

Nikhil Thakker ARN NO :14565 Anand, 16 Dec 2013

I 100% agree with 30 days but 7 days is not practical and I insist to AMFI not to take such decision.

ANITA GUPTA ARN NO :2755 bhopal, 15 Dec 2013

EUIN Remediation period should be minimum 45 days

g.somasundaram ARN NO :16932 nagercoil, 15 Dec 2013

very useful

Ramesh Bhat K ARN NO :Aniram Chennai, 15 Dec 2013

A serious thought should be put in by AMFI before implementing it. First we request AMFI to hold the implementation of this from 1st Jan 2014. IFA Association representatives to be called for and Pros and Cons to be discussed before implementation.

Ganesan Muralidharan ARN NO :12558 Chennai, 15 Dec 2013

Yes sir, I agree with you, in few cases we come to know that the EUIN was missed, only after getting the brokerage statement, by that time the stipulated time would be over. God is great

ipcon associates ARN NO :6575 mumbai, 15 Dec 2013

We fully agree with you and support your move.

john p thomas ARN NO :14203 kochi, 15 Dec 2013

how many numbers we have to maintain. ARN EUIN,PAN, ELECTION ID. One AADHAR MUST KEEP AWAY ALL OTHER ID NUMBERS FOR IDENTIFICATION.other ways international community will call us morons.

Sam Koshy ARN NO :5727 KOLLAM, 15 Dec 2013

Dear friend Mahesh Gore from Pune, what you mentioned "WAS" right till some days back. But, it''s found that the majority of the transaction happening is execution only ones. Thats why AMFI made EUIN mandatory for all transactions under distributors even if its execution only one( but they give approvals for exceptional cases only). To know more mail me.

s murali subramanian ARN NO :32851 Madurai, 15 Dec 2013

it is only to make you run and make you keep in tention. on the otherway it is to help the amc to eat away the commission generated by the ifa for that investment. and all the decision so for taken unilaterally and there is no delibrations between the party involved. there is no point in taking about this. if possible accept and perfotm if not think it otherwise. is some cases if everything is in pucca the commission is being withheld saying euin remediation required. this already i wrote in this cloum to surrender my arn. the joking part is the rta till today not disclosing the reasons for that withholding but released the commission.

Navin kumar ARN NO :83441 Patna, 15 Dec 2013

Yes , for an IFA ARN is more than enough.

P SATHISH KHUMAAR ARN NO :80671 CHENNAI, 15 Dec 2013

I HOPE THERE IS NO RATIONALE BEHIND EUIN IS MANDATORY FOR IFA,AS WE REPRESENT THE BUSINESS CLOSURE AS INDIVIDUAL.OUR ARN IS MORE THAN ENOUGH.

Raahul ARN NO :78253 kanpur, 15 Dec 2013

AMFI must evaluate the decision taken by SEBI. What are the result of any decision must be seen. Most of the decisions have negative effect. They must correct. EUIN Does not make sense for the IFA.

PRAKASH RAO BAPAT A ARN NO :12142 SORAB - 577 429, 15 Dec 2013

I can''t understand rational of stipulating unnecessary hurdles to individual IFAs on one side and other side encouraging to bring in Retired Teachers etc to market the MF products. Whether they can handle issue of explaining the investor in which market he is asking for investment. Let us see pity state of affairs of people who invested in Postal Department canvassed MFs products. Not a single investor procured by them has understood the where his money is invested. Now Post Office has shut their counter of MFs and investors have become orphans. It is better the very clause of asking EUIN is dropped where no Sub Brokers or other Staff are engaged in Individual IFAs.

MUTHUKRISHNAN.L. ARN NO :ARN-10460 TIRUNELVLEI, 15 Dec 2013

First of all, INDIVIDUAL IFAs must unite and arrange to exclude us from submitting our EUIN numbers in the application forms. When we have one code number as ARN what is the necessity for us to include our EUIN NUMBER. We agree that it is necessary for National Distributors to specify the person who has initiated and executed the investment. If our investors invest through online it will not be easier for them to REMEMBER OUR ARN AND EUIN CODES AND INCLUDE THE SAME AT THE TIME OF ONLINE INVESTMENTS, So, we must arrange to exclude us from submitting our EUIN numbers in the application forms.

Sunil Bhagat ARN NO :9646 Pondicherry, 15 Dec 2013

Very true. Would also request the '' Voice of Mutual fund Distributor Associations '' to take up the issue with AMFI. Another major problem we see ( as pointed out by one of my IFA friends) is that after a financial transaction is done for our customer the stt received by them does not bear the EUIN no of the advisor in the lower transaction slip portion of the stt, If the customer goes to make an additional purchase , the advisor would lose his future commision which was not really the intention of the investor for his agent. We have taken this issue with some AMCs but the practise still continues.

Narendra Kumar Sharma ARN NO :72881 Meerut, 15 Dec 2013

I also find it to be very genuine that while working sometime one may forget to imprint EUIN/ARN, and 07 days are very less to come to know and to get it corrected. 30 days time is conducive.

PARESH DAND ARN NO :0452 MUMBAI, 15 Dec 2013

I TOTALLY AGREE.Regisrars take two to three days to convey and dist might need 2 to 3 days to correct it if at all client is in town.Else he has to rush for the same thing leaving all other work aside else forget brokerage.Minimum 15 days to 21 days is required in such cases.7 days is out of question.

Mahesh Gore ARN NO :50271 Pune, 15 Dec 2013

Kindly Help. . Currently there is space on all app. form for sign. of investor at declaration regarding blank place of EUIN. This declaration state that tranz. is "execution-only" and no advice taken from broker, and hence no EUIN. If investor sign there, there is no need for EUIN. I want to know that what happen next. 1] As broker and subbroker code mentioned, 2] "tranz. is execution only" declaration signed. 3] plan (of scheme) opted is the plan that is routed through distributor (and not a direct plan). Then tranz. must be under distributor. And though no EUIN mentioned brokarage must be given as client signed "tranz. is execution only" declaration. Kindly let me know is my above logic is right or not. Because if the case, we can intimate client to sign at "tranz. is execution only" declaration also, if client himself submitting application.

Sam Koshy ARN NO :5727 KOLLAM, 15 Dec 2013

Dear All IFAs, There exits certain things regarding the 7days EUIN remediation which cannot be discussed in open public. If you have a valid ARN & valid EUIN mail me from your AMFI registered email address to (samkoshy.cc@gmail.com). If you don''t have a registered email there SMS me from your registered mobile. I will reply you.

Sanjay L Vora ARN NO :42736 Mumbai, 15 Dec 2013

I also demand 30 days should be allowed for correcting of any mistake. Alternatively, I will raise a question to the authority, why not 30 days to correct, if any mistake is done.

manish hathi ARN NO :ARN-31877 MUMBAI, 15 Dec 2013

30 days is very much required, 7 days is very much much less,However looking at the past record of the tough rules in the MF industry I will not be surprised if this close is dropped altogether in future,I mean to say be prepared for a rule that if you not mentioned EUIN no you will get commission,no remidiation allowed,be prepared for such a nasty surprise in future.

Ritesh Khanna ARN NO :51682 New Delhi, 15 Dec 2013

Practical and logical thinking of AMCs has always been towards denying the most hardworking community in the business its due. They remained mute spectators since it all started in that fateful month of Aug a few years back. They do not want the investor to get correct advise. They just want banks to sell products oriented towards sales. It is Association of Mutual Funds in India, not Association of IFAs in India. Therefore, actually if we see it is doing its job well in serving its members. If we want our due and effort to be recognised then we need to unite.

pardeep kapoor ARN NO :10542 faridabad, 15 Dec 2013

EUIN should not compulsary for IFA

Dr.Gautam Haldipur ARN NO :62999 Hubli, Karnataka, 15 Dec 2013

Mr. Srinivasan, you have an absolutely valid point. It is sad to see these stories repeat with frequency in our IFA field. Without imputing any intentions to any of the powers that be, it appears that AMFI has considered only the interest of the Investor at Heart & feel that all the business is centred in the metros. Even in a metro city it is difficult to meet the deadline of 7 days. Please remember that there are a lot of investors living in the remote corners of this country with no access to technology/ proper courier services even now. In such cases it is likely that the remediation process may take in excess of 30 days at times for the reasons already stated by Mr.Srinivasan. What do you do there? again a special provision? Let us be reasonable & just in our interaction avoiding all this avoidable discussions by circulating consultative papers before implementing any regulation. The 7 day deadline is a Double Whammy. If you have a sound logic in this 7 day deadline, then you need to apply the same yard stick when it comes to initiating SIP''s which has 30 days. Why this differentiation?Allow SIP''s to start in 7 days with the technology at your command. PLEASE FOR HEAVEN SAKE! CAN WE SEE MORE PEOPLE ON THE LISTENING POST & HENCE MORE ACCOMODATIVE REGULATION BENEFITING ALL THE STAKEHOLDERS? Before I conclude, just a small note to my friend Rajesh from Jaipur. Sir, lets remember "TO ERR IS HUMAN" & hence making unwitting/ unitentional mistakes needs accomodation & understanding. Please understand the plight of the upcountry distributors who have to run from pillar to post to get things in place. It is not as easy as you have mentioned. People do make mistakes & hence a remediation window is provided. If you wish you can provide me your e-mail i.d. & I can give you a whole host of reasons why? but not on this platform as we have to be as far as possible brief. You can copy paste my mail on this forum if you wish. Please read me in the right spirit. Despite this you have the right to a dissenting note since we are a vibrant democracy!

Ramakrishna K ARN NO :33313 Bengaluru, 15 Dec 2013

I SUPPORT 30 DAYS TIME FRAME FOR REMEDIATION OF APPLICATION IS REASONABLE. 7 DAYS IS NO WAY PRACTICAL APPROACH. ITS QUITE POSSIBLE THAT EITHER THE INVESTOR OR THE DISTRIBUTOR MAY BE OCCUPIED , OUT OF STATION , COULD HAVE MANY REASONS. FURTHER , IT SHOULD BE FROM DATE OF COMMUNICATION AND TRANSACTION . UNLESS THE DISTRIBUTOR IS MAKE AWARE OF THE EVENT , HE CAN NOT START ANY ACTION FOR THE SAME. IF AMFI / AMC"s WANTS TO DEPRIVE OF BROKERAGE TO DISTRIBUTOR , THEN ONLY THIS 7 DAYS IS OK. I FEEL THIS IDEA OF REMEDIATION FOR MISSING EUIN FOR IFA"s APPLICATIONS, REDUCTION OF TIME FRAME FOR REMEDIATION IS FROM AMC''s. YES, I FEEL THEY WANT TO SLOWLY SQUEEZE / STRANGLE IFA''s SOON . AMFI MUST BE SERIOUS ABOUT IT AND DO WHAT IS JUSTIFIED.

jaideep ARN NO :81143 mumbai, 15 Dec 2013

The problem here arises because AMCs have not been able to help us. We have downloaded forms that do not have an option to include the ARN( e.g. ICICI), leave alone the EUIN. In simple terms, for downloaded forms, the IFA must be able to include ARN and EUIN. Otherwise IFAs must make a rubber stamp that includes the EUIN (I have), to take care of this issue. AMFI, of all bodies, must have looked at the practical aspects first. In fact, reports of investments without EUINs but with ARNs, must be sent to IFAs, if they require corrective action. 7 days in any case is ridiculous, just one more reason for AMCs to get away without paying commission.

Nitin ARN NO :33833 Mumbai, 15 Dec 2013

Actually 7 days are very less in today''s fast and busy life. So it should be at least 30 days time to confirm EUIN on investment. I totally agree about the circumstances explained by Mr. Srinivasan and I request Wealth Forum to take up this issue with AMFI and reinstate the prior time limit.

neelu agrawal ARN NO :69991 gorakhpur, 15 Dec 2013

yes agree.

ANISH M CHAUDHARI ARN NO :ARN-68105 Nashik, 15 Dec 2013

EUIN Remediations period should be more than 30 days.In fact EUIN shouldnot be compulsory to Individual IFA''s who has no employees.

Venkateswaran ARN NO :86724 Chennai, 15 Dec 2013

I think 7 days is impractical to implement. It would be better if we stick to the 30 days deadline for EUIN remediation. As with many regulations in India, this would also get implemented and IFAs will learn to accept that! God Save All!!

Rajesh ARN NO :74556 Jaipur, 15 Dec 2013

Can anybody plz explain why we are having so much discussion on EUIN no? When we submit the application form, we mention out ARN no without any delay or mistake. Why is it, that some dIistributors are having so much issues with EUIN no? Why can''t we accept that it is just an addition to the general process? Is there any problem if we mention EUIN no at the time of submission of application form to the registrar/AMC? If it is, can anybody plz share at this platform. I have mentioned my EUIN no on every application, since I got my EUIN no. Am I going to face any problem in future, because of that?

shiva prasad konduru ARN NO :47847 warangal, 15 Dec 2013

some time creating folio taking three to four days time if weekend comes then seven days over recently CAMS people done while entering my EUIN they entered others when i checked after one month i faced by lot problem get investor signture he asked lot questions. In my view those registered as IFA there should be no need EUIN those are having staff they need EUIN in my veiw, Dear SEBI and AMFI we IFA donot have staff to sell MF at least give permission with out using EUIN

Jayanti ARN NO :3069 MUMBAI, 15 Dec 2013

The issue is headche for IFAs, when he/she is the only marketing person under his/her ARN there should be some way out for this issue, its only wastage of time, money and energy... SEBI should come out with some practical ammendments/change for this, at least in case of IFAs with no marketing staff under him

RAJESH JASVANI ARN NO :8078 THANE, 15 Dec 2013

I THINK AND I SUPPORT 30 DAYS TIME FRAME FOR REMIDATION OF APPLICATION IS REASONABLE. 7 DAYS IS NO WAY PRACTICAL APPROACH. ITS QUITE POSSIBLE THAT EITHER THE INVESTOR OR THE DISTRIBUTOR MAY BE OCCCUPIED , OUT OF STATION , COULD HAVE MAYNY REASONS.FURTHER ITS SHOULD BE FROM DATE OF COMMUNICATION AND TRANSACTION . UNLESS THE DISTRIBUTOR IS MAKE AWARE OF THE EVENT , H E CAN NOT START ANY ACTION FOR THE SAME .IF AMFI WANTS TO DEPRIVE OF BROKERAGE TO DISTRIBUTOR , THEN ONLY THIS 7 DAYS IS OK. YES THEY WILL BE EASILY GETTING READ OF IFA SOON . IT CAN ALSO ENCOURAGE MISS SELLING ... AND DO THE TRANSACTION AGAIN SWITCH /REDEEM ETC...... AMFI MUST BE SERIOUS ABOUT IT AND DO WHAT IS JUSTIFIED

Lovey Mehra ARN NO :32629 New Delhi, 15 Dec 2013

I also agree with Mr Srinavasan that this period of remediation is too short. As it is It is nonsense rule for individual IFA as the registrars have the EUIN no . and if at all it is to be put it should be done automatically why the need of another no. to be written. Even the registrars are not fully prepared for this process and still keep committing mistakes

Rabindranath Barapanda ARN NO :8939 Kolkata, 15 Dec 2013

EUIN Remediation time is too short for rectification of the mistake.Ultimately the AMC will be benifited not paying the hard earned commission to the IFA. pl. chang the time period.

R.B.DWIVEDI ARN NO :0242 FARIDABAD-121002, 15 Dec 2013

I full agree with Mr.Srinivasan. It appears the intentions are not good, as the purpose of reducing the remediation period from 90 to 30 and then 7 days, is only to allow AMCs, to earn more and more, by forfieting hard earned commissions of the Distributors.

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