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Mutual Fund Mis-Selling Complaint: AMC, SCORES, AMFI and ODR

To make a mutual fund mis-selling complaint, write first to the asset management company (AMC) whose scheme was sold, naming the distributor and its ARN and attaching proof of what you were told. If the AMC does not resolve it, file on SEBI SCORES within one year, complain to AMFI about the distributor’s conduct, and use SEBI’s SMART ODR portal for a money claim. If a bank sold the scheme, you can also complain about the bank under the RBI Integrated Ombudsman Scheme, 2026.

PointPosition
RegulatorSEBI (SEBI (Mutual Funds) Regulations, 1996)
DistributorAMFI Registration Number (ARN); paid commission by the AMC through regular plans
Investment adviserSEBI registration starting “INA”; fee from client only, no commission
Direct plansEvery scheme must offer one since 1 January 2013, with no distributor commission
Entry loadAbolished in 2009
Complaint ladderAMC, then SCORES (within 1 year), AMFI, SMART ODR
Bank as sellerAlso RBI Integrated Ombudsman Scheme, 2026, after complaining to the bank

Distributor, adviser or research analyst: who sold it to you?

The law separates three roles, and your complaint depends on which one you dealt with.

  • Mutual fund distributor: holds an ARN from AMFI after NISM certification, earns commission from the AMC built into regular plans, and may give incidental guidance under AMFI’s code of conduct. A distributor is not your adviser.
  • Registered investment adviser (RIA): registered with SEBI under the Investment Advisers Regulations, 2013, number starting “INA”. Charges a fee only to you, under a written agreement, and cannot take commission from product makers.
  • Research analyst: registered under the Research Analysts Regulations, 2014, number starting “INH”.

Titles such as “wealth manager” or “financial planner” on a visiting card mean nothing legally. Check the ARN on AMFI’s website and an INA or INH number on SEBI’s website.

What counts as mis-selling

  • Calling a market-linked scheme “guaranteed”, “safe like an FD” or “no risk”.
  • Selling a high-risk scheme to a retired person who asked for safety, without explaining the risk.
  • Frequent switching between schemes to earn fresh commission (“churning”).
  • Hiding that a direct plan exists, or hiding the exit load.
  • Selling an insurance policy, such as a ULIP, as if it were a mutual fund or deposit.
  • Asking for your login, OTP or signed blank forms “to manage everything”.
  • An unregistered person charging a fee for “advice”.

A loss alone is not mis-selling. Every scheme carries a six-level riskometer (Low to Very High), evaluated monthly, and the Key Information Memorandum discloses risks and exit loads. Your complaint is strongest where you can show the seller said something different from what the documents say, ideally in writing.

Learn this properly, with a certificate. Module 3 covers mutual fund protections, the distributor and adviser rules, mis-selling and IPO rights, and Module 4 shows how to use SCORES and SMART ODR, with complaint formats in Module 6. Legal Rights of Investors, ₹349: self-paced lessons, module quizzes and a 30-question final test; pass at 60% for a verifiable Lexfolio certificate.

How to file a mutual fund mis-selling complaint, step by step

  1. Collect evidence: application form, KIM, account statements, and especially WhatsApp messages, emails or brochures showing what you were told. Note dates, branch and the seller’s name and ARN.
  2. Write to the AMC’s investor service or grievance officer. State the facts in date order, name the distributor and ARN, and ask for a specific remedy: for example, reversal of switches, refund of the exit load charged, or compensation for loss caused by the misrepresentation. AMCs are responsible for monitoring distributors who sell their schemes.
  3. Complain to AMFI about the distributor’s conduct. AMFI can act against an ARN under its code of conduct.
  4. File on SEBI SCORES against the AMC if its reply is unsatisfactory or late, within one year of the event. The AMC must file an Action Taken Report within 21 calendar days. See SEBI SCORES complaint.
  5. Use SMART ODR (smartodr.in) for a disputed money claim against the AMC or another SEBI-regulated intermediary: conciliation, then arbitration.
  6. If a bank sold it, complain to the bank and, if it rejects or does not reply in 30 days, go to the RBI Ombudsman at cms.rbi.org.in. See RBI Ombudsman complaint.

If what you were sold was actually an insurance policy, the route is the insurer, IRDAI’s Bima Bharosa portal and the Insurance Ombudsman. A life or health policy can be returned within the 30-day free-look period.

Real-life examples

Pooja, Lucknow: a bank relationship manager sold her a scheme as “safe like an FD with better returns”. Six months later it was down and an exit load applied. The KIM showed “Very High” risk and the exit load, so her complaint rests on the manager’s written WhatsApp message calling it “FD-like” and “no risk”. She complains to the AMC, then SCORES, and separately to the bank under the RBI scheme.

Mr and Mrs Joshi, Pune: a “financial planner” with an ARN, not an INA registration, moved ₹15 lakh from deposits into equity schemes and switched them twice in a year, earning commission each time. They write to the AMCs with his messages, report churning to AMFI and escalate to SCORES when one AMC’s reply is vague.

Against an unregistered tipster or fake app, SCORES and ODR will not help; see fake trading app fraud what to do.

Frequently asked questions

Where do I file a mutual fund mis-selling complaint?

Start with the AMC whose scheme was sold, naming the distributor and ARN. If unresolved, file on SEBI SCORES within one year, complain to AMFI about the distributor, and use SMART ODR for a money claim. If a bank sold the scheme, the RBI Ombudsman is also available.

Can a mutual fund distributor give investment advice?

A distributor may give incidental guidance while distributing schemes, but is not a SEBI-registered investment adviser. Personalised advice for a fee is the role of an RIA, registered with SEBI with a number starting “INA”, who cannot take commission.

Is a loss in a mutual fund enough to prove mis-selling?

No. Market losses are disclosed risks. Mis-selling needs evidence of misrepresentation or unsuitable selling, such as a written “guaranteed return” claim, hidden exit loads or churning.

What is the difference between a direct plan and a regular plan?

Both invest in the same portfolio. A regular plan pays distributor commission out of scheme expenses, so its expense ratio is higher; a direct plan has no distributor commission. Every scheme has had to offer a direct plan since 1 January 2013.

Quick quiz

Q1. A SEBI-registered investment adviser’s number begins with:

  1. ARN
  2. INZ
  3. INA
  4. INH
Show answer

Answer: C. Advisers registered under the SEBI (Investment Advisers) Regulations, 2013 carry “INA” numbers.

Q2. Where should a mutual fund mis-selling complaint go first?

  1. The AMC
  2. The Supreme Court
  3. The stock exchange
  4. The Income Tax Department
Show answer

Answer: A. SEBI’s complaint ladder requires approaching the entity (the AMC) before SCORES.

Q3. Since when must every mutual fund scheme offer a direct plan?

  1. 1 April 2009
  2. 1 January 2013
  3. 1 April 2024
  4. 1 September 2026
Show answer

Answer: B. SEBI required direct plans from 1 January 2013 under the Mutual Funds Regulations framework.

Mutual fund mis-selling complaint formats for AMCs and distributors are in Legal Rights of Investors (₹349), which teaches rights and remedies, not what to invest in. It gives a Lexfolio certificate of completion, not a professional qualification.

Sources

  • SEBI (Mutual Funds) Regulations, 1996
  • SEBI (Investment Advisers) Regulations, 2013; SEBI (Research Analysts) Regulations, 2014
  • SEBI circulars on SCORES 2.0 (20 September 2023) and Online Dispute Resolution (31 July 2023)
  • Reserve Bank Integrated Ombudsman Scheme, 2026

This page is for education and general information, not legal advice for a specific case. Law as on 31 October 2026.

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