SEBI finds Dwaith Advisory charged 10.21% fee instead of 2.5% limit
This order addresses an investigation into Dwaith Advisory Private Limited for allegedly charging fees that exceeded the limits prescribed by SEBI regulations for investment advisers. The core issue examined was whether the performance-based fee structure charged to a client violated the maximum allowable fee caps.
Dwaith Advisory Private Limited (Noticee), Sunil Thamaran (Client), Harsh Venkatesh (Managing Director/Proxy)
- SEBI found that Dwaith Advisory Private Limited charged fees of Rs. 80,35,232/- (10.21% of AUA) instead of the maximum allowable 2.5% (Rs. 28,02,709/-).
- The excess fees charged were calculated at Rs. 52,32,523/-.
- The violation involved charging performance-based fees (25% above a 6% hurdle rate) which SEBI noted is not allowed under the IA Regulations for the applicable category.
- The order cites violations of Clause 2(iii) of SEBI Circular dated September 23, 2020, and Regulation 15A of the IA Regulations.
Written from the document by AI, and checked against it. The original below is authoritative.
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Document details
| Official title | Adjudication Order in the matter of Dwaith Advisory Private Limited |
| Source body | Securities & Exchange Board of India (SEBI) — enforcement orders |
| Reference number | Order/AK/GN/2026-27/32407 |
| Status | closed (order) |
| Year | 2026 |
| Closing date | — |
| Documents | 1 |