This Disclosure Document, herein after called “DD-RA-GVS” provides brief information about the qualifications and business practices of Venkata Subrahmanyam Gutala (GVS), a SEBI (Securities and Exchange Board of India) registered Research Analyst, with registration no: INH200009795 (hereinafter “RA” or “we”).

If you have any questions about the contents of this Brochure, please write to us at helpdesk@gvsrwealth.com. The information in this Brochure has not been approved or verified by SEBI or by any State Securities Authority. Additional information about RA is available on the SEBI’s website at www.sebi.gov.in. You can search this site by a unique identifying number, known as INH number. The INH number for RA is INH200009795.

The current version of our Disclosure Brochure DD-RA-GVS will be available to our existing and prospective clients through our website gvsrwealth.smallcase,com. We urge you to carefully review all subsequent summaries of material changes, as they will contain important information about any significant changes to our Research Analyst services, fee structure, business practices, conflicts of interest, and disciplinary history, from time to time.

Section I: Research Analyst Services of RA:

RA is a SEBI registered, and fee only Research Analyst (SEBI registration number INA200004391. RA has his license with effective date as 10 June, 2022. RA has an overall investment advisory experience for over six years now, including his previous stint (of 6 + years at GVSR Capital Management Pvt. Ltd - a SEBI registered Investment Advisor). RA has also worked as a Partner/executive Director at PwC-India and Grant Thornton India respectively. RA has more than 25 years of Business / Technology / Advisory experience at these firms.

RA aims to offer his Equity Research (Buy / Sell / Rebalance) recommendations on Smallcase.com and other similar online investment platforms made available in India from time to time by the market players. RA also intends to provide Equity Research related services in off-line mode to his select clients. It is important to note that RA does not provide any trade execution support. All the investments made by the Subscriber are expected to be managed by Subscriber himself in a self-directed mode. Further, RA;s stock/ETF specific recommendations are neither prescriptive nor restrictive and the individual subscriber has full right to act / not to act or partially act / modify the buy /sell/rebalance recommendations that the subscriber is expected to receive from the RA during the subscription period with RA. It is to be explicitly understood by the Subscriber that RA’s stock/ETF recommendations are non-binding on the Subscriber and the Subscriber is well within his rights to mange his own portfolio out of his free will and his own judgement.

We are a ‘fee only’ RA and our Stock/ETF recommendations are not limited to any specific security or product or service offered by a broker-dealer or any Mutual Fund House or Insurance Company and will primarily include stock specific / Portfolio specific / smallcase specific recommendations regarding individual securities and ETFs etc.

Section II: Research Analyst Services (RAS):

Clients / Subscribers have the option to subscribe to the Smallcase(s) designed by the RA and published on smallcase.com website, which is a third-party service provider. A smallcase is nothing but a basket of Stocks and/or ETFs tht are dusually designed around a theme or a segment or a sector or an investment strategy.

Section III: Execution Support: RA does not provide any trde execution support to the Subscribers of the Smallase(s) designed and Published by the RA on the Smallcase.com platform. More details about the business process flows relating to trade execution support services enabled by eco-system players can be found at smallcase.com

Section IV: Our Fees and Compensation Details: RA charges a subscription based fee , the details of which are available on the smallcase.com platform itself. Subscription fee is subject to change without prior notice or approval from the subscriber. A subscriber has the choice not to renew or to renew smallcase portfolio products designed and published by the RA from time to time.

Section V: Mutual Fund and ETF Fees and Expenses

All fees paid and charges (statutory charges such as Goods & Services Tax etc) to the RA are independent and separate and distinct from the fees and expenses charged by mutual funds and ETFs to their unit holders. These fees and expenses are described in each fund's prospectus. These fees will generally include a management fee, other fund expenses, and a possible distribution fee

Section Vi: Management, Brokerage and Custodial Fees

In addition to Research Analyst fees paid to the RA on a subscription basis, Subscribers will also be responsible for all transaction, brokerage, custodial fees, minimum account balance charges / other charges incurred as part of their investment account management. This is based on the agreement that the Subscriber may directly have with its broker/custodian/Depository participant etc.

Section VII: Additional Compensation Received by Us

RA is a fee only company and it does not receive any commissions for advising individual securities and/or ETFs or any other financial instruments a part of RA’s services to the Subscribers

Section VIII: No Performance-Based Fees:

RA is in no way connected with the management of investment account of the Subscriber and the Subscriber himself is required to manage his investment account at his own risks and costs. Accordingly, No performance fee shall be charged by the RA to the Subscriber for any over/under performance of the Subscriber’s investment account. RA, in the normal course does not have even view access to the investment account detail of the Subscriber, unless otherwise such read-only / view access rights are granted by the Subscriber to the RA through the Smallcase.com ecosystem.

Section IX: Risk Factors

It may be noted that all investment recommendations made / directed by us for any Smallcase portfolio (of Stocks and ETFs) are subject to volatility, market and business risks and may lose value. We primarily depend on ‘Fundamental Research and Analysis’ in identifying investment opportunities for our Subscribers. A risk associated with ‘fundamental analysis’ is that the price of a security can move up or down along with the overall market regardless of the economic and financial factors considered in evaluating the stock. Therefore, unforeseen market conditions and/or company developments may result in significant price fluctuations that can lead to investor losses.

Section X: Asset Allocation: Alternatively, rather than focusing primarily on securities selection alone, we may attempt to identify an appropriate ratio of securities, fixed income securities or Gold in ETF mode, A risk associated with this approach is that the ratio of securities, fixed income, and cash will change over time due to stock and market movements. Any rebalance actions initiated by the RA to the Smallase portfolio re-balanced may lead to additional costs (including short-term gains or losses.).

Section XI: Mutual Fund and/or ETF Analysis: A risk of mutual fund and/or ETF analysis is that, as with all securities investments, past performance does not guarantee future results and all investments in MFs / ETFs are subject to market and business risks. In addition, as we do not control the underlying investments in a fund or ETF, managers of different funds held by the client may purchase the same security, increasing the risk to the client if that security were to fall in value. There is also a risk that a manager may deviate from the stated investment mandate or strategy of the fund or ETF, which could make the fund or ETF less suitable for the Subscriber’s portfolio. Subscribers are encouraged to carry out their own risk assessment and suitability of the stocks / ETFs being recommended by the RA from time to time.

Section XII: Risks from all forms of analysis: Our securities analysis method relies on the assumption that the companies whose securities we analyse, the rating agencies that review these securities, and other publicly-available sources of information about these securities, provide accurate and unbiased data. While we are alert to indications that data may be incorrect, there is always a risk that our analysis may be compromised by inaccurate or misleading information.

Section XIII: Long-term purchase Recommendations / Views of RA For some of the stocks / ETFs , RA may hold a log-term view to realize the full potential value of the stock, till the valuations become expensive or there are fundamental negative shifts in the performance of the underlying business of the company, whose stock is monitored and reviewed by us. A risk in a long-term purchase strategy is that, by holding the security for a considerable length of time, we may not take advantages of short-term gains that could be profitable to a client. Moreover, if our expectations prove incorrect, a security may decline sharply in value before we make the decision to sell.

Section XIV: Short-term purchase Recommendations / Views of RA: At times, we may also recommend purchase of securities for Subscribers of the Smallcase, with a short-term view, whose period / timelines cannot be predicted in advance and is subject performance of t he underlying business of the Company, whose securities are assessed by the RA from time to time for their inclusion / exclusion from the Smallcase Portfolio..

A risk in a short-term investment strategy is that, should the anticipated price swing not materialize, we are left with the option of having a long-term investment in a security that was designed to be a short-term purchase, or potentially taking a loss. In addition, this strategy involves more frequent trading than does a longer-term strategy and will result in increased brokerage and other transaction-related costs, as well as less favorable tax treatment of short-term capital gains.

Section XV: Trading: On a few occasions, we may recommend purchase securities with the idea of selling them very quickly. RA may provide such re-balance recommendation to take advantage of our belief that the security may experience brief price swings. A risk in a short-term purchase is the potential for sudden losses if the anticipated price swing does not materialize. Moreover, should the anticipated price swing not materialize, we are left with the option of having a long-term investment in a security that was designed to be a short-term purchase, or potentially taking a loss. In addition, this strategy involves more frequent trading than does a longer-term strategy and will result in increased brokerage and other transaction-related costs, as well as the less favorable tax treatment of short-term capital gains.

Section XVI: Disciplinary & Financial Information

RA hereby affirms that he has not been subject to any material legal or disciplinary events as on date. More details about RA can be found at Scores.gov.in, with respect to complaints received and resolved status of RA. The complaints received by SEBI on RA as on date is NIL.

Section XVII: Disclosures around Conflict of Interest

We shall comply with general responsibilities, and other disclosure requirements specified by SEBI in its Research Analysts Regulations, 2014, subject specific terms & conditions of business specified by RA on his microsite www.gvsrwealth.smallcase.

Our RA or his affiliates / family members or Authorized Representatives (ARs) of RA may buy or sell for their personal accounts securities identical to those recommended for Buy / Sell/Rebalance for RA’s Subscribers / clients. In addition, any related person(s) may have an existing interest or position in a certain security (ies) which may also be recommended to a client. This may practically result in a potential conflict of interest, depending the on the individual financial needs / goals / objectives of these individuals or the RA himself. For example, the company may buy or sell securities in the short term to manage its working capital and other financial requirements, (which may result in gains or losses) and that may seem to conflict with the Buy / Sell recommendations provided to the clients. To this extent the holdings/positions of the RA may vary from its Client’s positions and may keep changing from time to time, even in the short-term. We request our potential clients to take cognizance of such approach, which is primarily driven by organizational and personal requirements of RA than any long term investment philosophy. RA shall however comply with regulatory requirements in this regard to the best of his abilities.

Section XVIII: Client Referral Fees & Other Compensation Details:

Our employees / ARs / Client Referral Partners may receive additional compensation for the solicitation arrangements that we may have in place to augment our business. Moreover, from time to time, we may also pay referral fees to other firms and individuals (some of whom may happen to be our Subscribers / Clietns) for referring advisory clients to our busienss. If a client is introduced to us by either an unaffiliated or an affiliated solicitor, we may pay that solicitor an initial and/or an ongoing referral fee, constituting a percentage of the referred client’s advisory fee paid to us..

Payment of fees for the referral of prospective clients may create a potential conflict of interest to the extent that such a referral to us / RA’s business is not unbiased and the solicitor is, at least partially, motivated by financial gain. Therefore, such a referral may be made even if our advisory services are not suitable to a particular client’s needs or entering into an advisory relationship with us is not, overall, in the best interest of the client. As these situations may present a conflict of interest, we have established the following restrictions in order to meet our fiduciary responsibilities. Any such referral fee will be paid solely from our Research Analyst’s Subscription fee, and will not result in any additional charge to the client;

Client / Subscriber is advised to go through this disclosure document for potential conflict situations and the mechanisms we put in place to ensure our fiduciary responsibility to our Clients and make a fully informed investment decision on their own free will.

Section XIX General Terms & Conditions of business:

Potential / existing Clients / Subscribers are encouraged to read and understand the terms & conditions of RA’s business, which are made available on RA’s micro-website: www.gvsrwealth.smallcase.com. For example, all investment recommendations made by us for our Subscribers through the Smallcase portfolio (of Stocks and ETFs) designed and published by the RA on smallase.com platform are subject to several types of risks, including potential / actual loss of invested capital. Not insured; Not guaranteed. Neither the RA nor its affiliates provide any warranties, guarantees w.r.t availability of the smallcase.com platform or the micro-website of RA, namely, gvsrwealth.smallcase.com, its accuracy or adequacy or timeliness of the information, opinions, recommendations provided to the Subscribers from time to time by the RA. There is no liability whatsoever on the RA or its Directors, employees, advisors, affiliates, vendors, partners, related parties of the RA for any action taken or not taken or partially taken or intended to be taken either directly or indirectly by the Subscriber based on RA’s stock / ETF / Smallcase specific recommendations provided by the RA to his subscribers / clients from time to time.

The RA further declares that he does not use any Artificial Intelligence based tools in arriving at stock/ETF specific recommendations.

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