Adjudication Order in the matter of Dwaith Advisory Private Limited

This order addresses an allegation that Dwaith Advisory Private Limited charged fees exceeding the regulatory limits prescribed for investment advisers. SEBI examined whether the firm violated the SEBI (Investment Advisers) Regulations, 2013, and related circulars regarding fee structures for a specific client.

Dwaith Advisory Private Limited (Noticee), Harsh Venkatesh (Managing Director), and Sunil Thamaran (Client).

• SEBI found that Dwaith Advisory Private Limited charged fees of Rs. 80,35,232/- to client Sunil Thamaran, which exceeded the maximum allowable limit of 2.5% of Assets Under Advice (AUA).
• The calculated excess fees charged were Rs. 52,32,523/-.
• The fee structure involved a 25% performance fee above a 6% hurdle rate, which SEBI determined was not permitted under the applicable IA Regulations for the period in question.
• The investigation period covered transactions from December 15, 2023, to February 20, 2024, specifically regarding the scrip of Rail Vikas Nigam Ltd (RVNL).
• The order notes that the Noticee argued the fees were valid under the 'accredited investor' framework, but SEBI's findings indicate the charges violated the prescribed limits.

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