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Omkeshwar

Omkeshwar Singh  | Answer  |Ask -

Head, Rank MF - Answered on Dec 02, 2021

Mutual Fund Expert... more
Sri Question by Sri on Dec 02, 2021Hindi
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I am 21 years old and I am still studying. I am investing in these funds through SIP:

HDFC Top 100 Fund Direct-Growth: Rs 1,000 since one year.

Axis Long Term Equity Fund Direct -- Growth: Rs 1,000 since one year.

I want to invest a lump sum of Rs 5,000 to Rs 10,000.

Please give me a suggestion for this portfolio, Should I stay invested or consider any other funds?

Ans: You may continue with the HDFC and Axis funds. Parag Parikh Flexi Cap Fund -- Regular Plan, Growth, is a good flex cap fund for your lump sum investment.

 

DISCLAIMER: The content of this post by the expert is the personal view of the rediffGURU. Users are advised to pursue the information provided by the rediffGURU only as a source of information to be as a point of reference and to rely on their own judgement when making a decision.
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Omkeshwar

Omkeshwar Singh  | Answer  |Ask -

Head, Rank MF - Answered on Apr 22, 2022

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I am 52 year professional, working in private sector. Other than my EPF & PF savings I am having following mutual fund investments (both in SIP & lump su). My goal is to have a corpus of Rs 1.5 - 2 cr in next 4-5 years. I am ready to invest Rs 40K in SIP on monthly basis and may be Rs 5-10 lump sum in another 6 months’ time. Request you to review my portfolio and advise on what SIPs I can start (also any correction required for existing funds?) as well as whether to invest in good equity stocks (I am having a demat account with few direct equities of Rs 2 L only) or in lump sum mutual fund for annual Rs 5-10 L surplus. Company No of shares Price Recommendation PORTFOLIO DETAILS A MONTHLY SIP MUTUAL FUND     Sl No Fund Details Current value in Rs L SIP AMOUNT in RS 1 HDFC Flexi Cap Fund - Regular Plan Growth 4.32 3000 2 Axis Mid cap fund 0.6 5000 3 Mirage assets large cap fund 0.58 5000 4 Axis Special situation fund - Regular Plan - Growth 0.09 2000 5 Aditya Birla Sun Life Frontline Equity Fund Growth 3.8 3000 6 Kotak Emerging Equity Fund - Regular Plan Growth 0.09 3000 7 Kotak Equity Opportunity Fund - Regular Plan Growth 0.09 3000                 B LUMP SUM MUTUAL FUND     Sl No Fund Details Current value in Rs L Initial Value in Rs L 1 Axis Retirement Savings Fund - Conservative Plan - Regular Growth 6.2 5 2 Axis ESG Equity Fund Regular Plan Growth 4.85 3 3 Axis Blue-chip Fund Growth 5.2 3 4 Tata Focused Equity Fund - Regular Plan 6.16 4 5 LIC Debt Fund - Secured NA 2 6 LIC balanced Fund NA 2
Ans: Please continue, we can review after 1 year

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Omkeshwar

Omkeshwar Singh  | Answer  |Ask -

Head, Rank MF - Answered on Jun 10, 2022

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I am 48. Sir I have SIP in the following funds. Please let me know if I should continue or need to do any change in my investment. 1) ADITYA BIRLA SUN LIFE FRONTLINE EQUITY FUND-GROWTH Rs.1000 13.06.2016 (date) 2) DSP MID CAP FUND--GROWTH Rs.3000 12.06.2017 3) HDFC MID CAP OPPORTUNITIES FUND-GROWTH Rs.2000 20.12.2016 4) ICICI PRUDENTIAL VALUE DISCOVERY FUND-GROWTH Rs.1000 14.06.2016 5) MIRAE ASSET EMERGING BLUECHIP FUND-GROWTH Rs.1000 14.06.2016 6) MIRAE ASSET TAX SAVER FUND-GROWTH Rs.2000 19.12.2016 7) HDFC CHILDRENS GIFT FUND-GROWTH Rs.1000 13.06.2016 8) AXIS FLEXI CAP FUND-GROWTH Rs.3000 02.06.2021 9) MIRAE ASSET HYBRID-EQUITY FUND-GROWTH Rs.1500 02.06.2021 10) MIRAE ASSET MIDCAP FUND-GROWTH Rs.3000 05.07.2021 11) NIPPON INDIA SMALL CAP FUND -GROWTH Rs.1000 26.12.2017 Sir I have invested lump sum amount in the following funds. Please suggest whether to continue or exit. 1) ADITYA BIRLA SUN LIFE BANKING AND FINANCIAL Rs.50,000 22.08.2016 (date) Rs.79,647 (present value) SERVICES FUND-GROWTH 2) ADITYA BIRLA SUN LIFE FRONTLINE EQUITY Rs.50,000 22.08.2016 Rs.87,455 FUND-GROWTH 3) ADITYA BIRLA SUN LIFE SMALL CAP FUND-GROWTH Rs.100,000 29.06.2017 Rs.132,490 4) HDFC HYBRID EQUITY FUND-GROWTH Rs.120,273 01.06.2018 Rs.178,746 5) ICICI PRUDENTIAL BLUECHIP FUND-RETAIL-GROWTH Rs.20,042 22.02.2018 Rs.31,422 6) L&T INDIA VALUE FUND-GROWTH Rs.25,000 22.08.2016 Rs.48,505 7) L&T INDIA VALUE FUND-GROWTH Rs.150,000 17.04.2017 Rs.245,565 8) MIRAE ASSET TAX SAVER FUND-GROWTH Rs.25,000 22.08.2016 Rs.61,878 9) MIRAE ASSET TAX SAVER FUND-GROWTH Rs.105,000 28.04.2017 Rs.216,372 10) ADITYA BIRLA SUN LIFE PURE VALUE FUND-GROWTH Rs.50,000 06.11.2018 Rs.65,281 11) ADITYA BIRLA SUN LIFE TAX RELIEF 96-GROWTH Rs.100,000 06.11.2018 Rs.128,895 12) L&T EMERGING BUSINESS FUND-GROWTH Rs.100,000 13.12.2017 Rs.155,097 13) MIRAE ASSET BANKING & FINANCIAL Rs.264,987 16.12.2020(STP) Rs.273,346 SERVICES FUND-GROWTH 14) MIRAE ASSET BANKING & FINANCIAL Rs.50,000 23.11.2021 Rs.44,129 SERVICES FUND-GROWTH 15) MIRAE ASSET GREAT CONSUMER FUND-GROWTH Rs.180,000 13.12.2017 Rs.284,600 16) MIRAE HEALTHCARE FUND-GROWTH Rs.200,000 09.11.2018 Rs.401,429 17) MIRAE ASSET MIDCAP FUND-GROWTH Rs.235,462 9.12.2020(STP) Rs.280,601 18) NIPPON INDIA SMALL CAP FUND-GROWTH Rs.100,000 12.12.2017 Rs.178,693 19) TATA FLEXI CAP FUND-GROWTH Rs.100,000 09.11.2018 Rs.149,127 20) TATA INDIA CONSUMER FUND-PLAN A-GROWTH Rs.100,000 09.11.2018 Rs.141,382 21) UTI SMALL CAP FUND-GROWTH Rs.100,523 22.12.2020(STP) Rs.137,025
Ans: Too many funds, please consolidate it in 4 to 5 funds

..Read more

Ramalingam

Ramalingam Kalirajan  |7101 Answers  |Ask -

Mutual Funds, Financial Planning Expert - Answered on Nov 01, 2024

Asked by Anonymous - Oct 31, 2024Hindi
Money
Hi, I’m a beginner to mutual fund and stock market investment. I’m 39 year old and recently started SIP by own. Now my portfolio has 9 different direct mutual funds. I know I should diversify and rebalance my portfolio.. 1) Now I have some quantitative money to invest as lump-sum (3.5 lakhs). So howmany funds I should choose? 2) Is this right time (market downtime as on 31st Oct 2024) invest as lump-sum? 3) Could you please help me with some mutual fund names with good returns over a period of 5 to 10 years? I chose below funds... - Quant Smallcap - ?Motilal Oswal Midcap - ?SBI Contra Fund - ?Motilal Oswal Nifty Smallcap 250 Index Fund - ?Nippon India Multicap fund - ?Motilal Oswal Nifty 200 Momentum 30 Index Fund - ?Parag Parikh Flexicap fund Please advise. Thank you
Ans: You’ve taken an excellent step by beginning your journey into mutual funds and stock markets. Diversifying and rebalancing your portfolio is indeed important, and your current enthusiasm for learning and improving your financial health is admirable. I’ll help you answer your questions and outline an optimal approach to maximise returns while managing risk.

Assessing Your Current Mutual Fund Portfolio
Your existing portfolio of nine direct mutual funds reflects your willingness to diversify. However, managing too many funds can lead to overlap and complexities in tracking performance. Here’s a more streamlined approach that ensures you achieve effective diversification without unnecessary fund overlap.

Limit to Essential Fund Categories: Aim to retain only 4-5 core categories. These include a mix of large-cap, mid-cap, and flexi-cap funds, along with a smaller allocation to contra or sectoral funds for tactical growth.

Avoid Index Funds in This Case: Index funds replicate the market and lack active management, which may limit gains, especially during volatile market phases. Actively managed funds allow skilled fund managers to optimise performance based on market trends.

Reconsider Direct Funds: Investing through regular funds with a Certified Financial Planner (CFP) helps you benefit from professional guidance. While direct funds save on distributor fees, they require significant knowledge and time to monitor effectively. An MFD with CFP credentials will help you align your investments with both market trends and personal goals.

Investment Strategy for Your Lump-Sum Amount
With Rs 3.5 lakhs to invest as a lump sum, your next steps are crucial for maximising returns.

1. Choosing the Right Number of Funds
Limit Fund Selection: For the Rs 3.5 lakh investment, focus on a manageable selection of 4-5 funds. Over-diversification may dilute returns without proportionate risk reduction.

Strategic Allocation: Allocate funds in a way that balances growth with stability. For example, allocate portions to large-cap, mid-cap, and flexi-cap funds, with a smaller allocation to a contra fund if you’re open to moderate risk.

Prioritise Active Funds over Passive Index Options: Actively managed funds allow professional adjustments in line with changing market conditions, aiming for higher returns over time.

2. Timing of Lump-Sum Investment
Market Timing vs. Systematic Approach: As markets can fluctuate unpredictably, consider a phased approach, such as a Systematic Transfer Plan (STP). This way, you can gradually move the lump sum from a low-risk fund to equity funds over a few months, reducing the risk of investing all at once during a downturn.

Assessing Current Market Levels: The market downtime you mentioned may appear tempting, but markets may take time to stabilise. By investing in phases, you mitigate risk while capitalising on potential market rebounds.

Suggested Mutual Fund Categories for Long-Term Growth
Since you’re aiming for a 5 to 10-year period, a well-structured portfolio with actively managed funds is crucial. I’ll avoid suggesting specific schemes and instead outline fund categories that align with your goals.

1. Large-Cap Funds for Stability
Why Large-Cap Funds? These funds invest in established companies, offering stability and consistent growth. Over time, they help anchor the portfolio, especially during market volatility.

Ideal Allocation: Allocate about 30-40% of your lump-sum investment to large-cap funds to ensure stability in your portfolio.

2. Mid-Cap Funds for Growth Potential
Mid-Cap Funds’ Role: Mid-cap funds balance stability with higher growth prospects. While they’re slightly more volatile than large-cap funds, they offer strong potential returns.

Ideal Allocation: Consider allocating 20-25% of your lump-sum investment to mid-cap funds to capture this growth.

3. Flexi-Cap Funds for Market Flexibility
Flexi-Cap Benefits: These funds provide flexibility by investing across large, mid, and small-cap stocks based on market conditions. This helps maximise growth potential while managing risk.

Ideal Allocation: Allocate around 25% of your lump-sum investment here. Flexi-cap funds give fund managers room to adapt the fund based on market trends.

4. Contra or Value Funds for Tactical Growth
Tactical Role of Contra Funds: Contra or value funds invest in undervalued stocks, aiming to capitalise when these stocks eventually rise. They add a contrarian growth element to the portfolio.

Ideal Allocation: Allocate a smaller portion, around 10-15%, to a contra fund to enhance returns while maintaining manageable risk.

Tax Implications to Keep in Mind
Understanding tax implications helps optimise net returns. Here’s a snapshot of the applicable taxes:

Equity Mutual Funds: Gains above Rs 1.25 lakh per annum are taxed at 12.5% for long-term capital gains (LTCG). Short-term gains are taxed at 20%.

Debt Mutual Funds: Both LTCG and short-term capital gains (STCG) are taxed as per your income tax slab. If you include debt funds for a part of your portfolio, consider this in your tax planning.

Additional Recommendations to Strengthen Your Financial Position
1. Build an Emergency Fund
Maintain a separate emergency fund covering at least six months’ expenses. This fund acts as a safety net, ensuring you don’t need to dip into your investments for unforeseen expenses.
2. Term Insurance for Financial Security
Ensure adequate term insurance coverage, providing financial stability to your dependents in your absence. This policy type offers high coverage at low costs, making it an ideal safety net.
3. Health Insurance for Your Family
Having comprehensive health insurance prevents your investment corpus from being impacted by medical expenses. Check for policies that cover critical illnesses for robust coverage.
4. Review Portfolio Regularly with a CFP
A Certified Financial Planner can help assess and adjust your portfolio as needed. Regular reviews allow you to stay aligned with your financial goals and market conditions.
5. Consider Goal-Based SIPs for Future Objectives
While your lump-sum investment supports wealth creation, consider setting up goal-based SIPs to address specific future goals, such as a child’s education or retirement.
Final Insights
Your commitment to long-term investment is commendable. With a structured approach and regular reviews, your portfolio can be geared for strong growth over the next 5-10 years. By focusing on actively managed funds, phased investments, and strategic fund selection, you’re well-positioned to achieve both security and growth.

For any further queries or detailed discussions, please feel free to reach out.

Best Regards,
K. Ramalingam, MBA, CFP,
Chief Financial Planner,
www.holisticinvestment.in
https://www.youtube.com/@HolisticInvestment

..Read more

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Ravi

Ravi Mittal  |431 Answers  |Ask -

Dating, Relationships Expert - Answered on Nov 22, 2024

Asked by Anonymous - Nov 22, 2024Hindi
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A bit long story I'm 21 student preparing for medical competative entrance exam for past 3 years (21-24).2 year ago this phase I was in a long distance relationship for 4 months with a girl I met in my class .But it didn't last long due to the problems created due to distance as she couldn't understand myself and I couldn't understand herself.so there was a misunderstanding and I couldn't hold on as I was in heavy pressure by exams and financial problems.so I couldn't handle and I felt like too early and broke up with her by losing my mind.she was completely disappointed as I didn't speak to her for more than an year due to one more year preparation.i missed her very much but I didnt tell her.I missed govt seat in border mark and the same year she got into a relationship with another guy in her class.i don't blame her. But I feel like my entire life is shattered and I couldn't move on from that girl till now.I couldn't concentrate on my career too.im kind of person who is always confident in all aspects but I have totally lost my mind .I can see that in an danger situation as age is running and family pressure, everyone of my classmates are far ahead of me I couldn't withstand this situation and couldn't make proper decision in any aspect. Mam please help me out.
Ans: Dear Anonymous,
I understand your concerns. The first step is to focus on moving on; she has, and you should too. Prioritize your career, your family, and your future. Next, what has happened to your career progress has already happened. It's unfortunate, but there's no way to change that. But give yourself a second chance; work harder and achieve greater things than you even imagined before. Trust me, you are not the only person who is standing in a situation like this. Many have, and many more will. But the ones who have passed this time will give you the same advice that I did.

Best Wishes.

...Read more

Milind

Milind Vadjikar  |682 Answers  |Ask -

Insurance, Stocks, MF, PF Expert - Answered on Nov 22, 2024

Asked by Anonymous - Nov 13, 2024Hindi
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Sir, I am 40yrs old. Having monthly takehome salary of 1.1 lakh and rental income of 36000. My investment are 2 flats worth of 1cr. 4 plots in Bhubaneswar worth of 2crs. EPF balance 50 lakh, LIC policies worth of 16 lakhs, NPS worth of 10 lakhs. My monthly saving commitments are - EPF (employee+employer) 28000 NPS 15000 MF 7500 Gold scheme 5000 Financial burden - HL emi of 24000 Monthly expanses 50000 I would like to retire at 50. Please advise for retirement plan with life expectancy of 80yrs.
Ans: Hello;

The value of your investments after 10 years;

A. EPF Corpus+Contribution: 1.6 Cr
B. NPS Corpus+Contribution: 53 L
C. MF(sip) + Gold(sip): 25 L
D. Real estate (land): 3.26 Cr

So sum of A, C & D gives us a corpus of 5.11 Cr

Since you will withdraw NPS before 60 age 80% of corpus will go into annuity while 20% will be available to you.

So you may expect monthly income of around 21 K from annuity(42.4 L).

Balance 10.6 L get added to 5.11L taking your total corpus to ~ 5.2 Cr.

If you invest 5 Cr in a conservative hybrid debt fund and do a SWP at the rate of 3%, you may expect a monthly income of around 1.1 L(post-tax).

Add your monthly rental income of 36 K(No growth factored) and annuity income of 21 K to this and you have total monthly income of 1.67 L after 10 years.

Your current monthly expenses of 50 K after 10 years would be around 90 K and 1.6 L after 20 years.

Considering return of around 7-7.5% from the conservative hybrid debt fund you will still generate inflation adjusted return at 3% SWP after 80 years of age.

Assumptions:
Inflation rate-6%
Return from EPF-8%
Return from NPS-9%
Return from MF-10%
Return from gold-7%
Return from Land-5%
Annuity rate-6%

The spare flat is not considered in this because it will continue to yield you rental income in retirement.

Since real estate(land) returns may fluctuate over 10 years suggest to increase MF sip(6X) as a back-up, also in this case you may decide to retain & invest in NPS upto 60 age.

Of course MF returns are also not assured but you are improving the odds by backing two appreciable assets(RE & equity) over long-term.

Happy Investing;
X: @mars_invest

...Read more

Ramalingam

Ramalingam Kalirajan  |7101 Answers  |Ask -

Mutual Funds, Financial Planning Expert - Answered on Nov 22, 2024

Money
My age 62, male, getting rental income Rs. 90k nett. Already subscribing 12.5k in PPF for the past 2 1/2 years. No other investments. My target is 5 crores in 10 years. I already have Mediclaim Rs.50 lakhs for me & wife . Please advice me what to do.
Ans: Your current financial foundation is strong and shows promise:

A rental income of Rs. 90,000 per month provides consistent and predictable cash flow. This stability can serve as the backbone for your investment strategy.

PPF contributions of Rs. 12,500 per month for 2.5 years reflect disciplined saving. However, its returns may be insufficient to achieve a high-growth target like Rs. 5 crores in 10 years.

A robust Mediclaim policy of Rs. 50 lakhs for you and your wife ensures adequate health coverage. This safeguard allows you to focus on wealth-building without worrying about medical emergencies.

Despite these positive factors, achieving Rs. 5 crores in 10 years requires a carefully crafted and growth-oriented strategy.

Defining and Prioritising Your Financial Goals
Achieving Rs. 5 crores is ambitious yet achievable with a focused approach:

Define this target as your primary financial goal over the next decade.

Break it into manageable milestones: for example, Rs. 50 lakhs every 1-2 years in cumulative investments and growth.

Prioritise high-return investments that align with your risk tolerance and financial capacity.

Optimising Existing PPF Contributions
While PPF is a secure investment, its growth potential is limited:

Returns: PPF currently offers an interest rate of approximately 7-7.5%, which barely outpaces inflation.

Contribution Review: Consider capping your PPF contributions at Rs. 1.5 lakh annually (to utilise the Section 80C benefit). This ensures that excess funds are redirected to higher-return investments.

PPF can serve as a low-risk component of your portfolio but should not dominate your investment strategy.

Building a Diversified Investment Portfolio
A diversified portfolio will provide a balance of risk and reward. Include the following components:

1. Equity Mutual Funds for Growth
Equity mutual funds are essential for achieving high returns over the long term:

Large-Cap Funds: These invest in established companies and offer stability with moderate growth. They are ideal for a portion of your portfolio to reduce risk.

Multi-Cap or Flexi-Cap Funds: These provide exposure to companies of all sizes, offering growth and diversification.

Sectoral and Thematic Funds: Avoid these unless you have a high risk tolerance and understand market dynamics.

ELSS Funds: These not only provide tax savings under Section 80C but also deliver market-linked returns.

Why Avoid Index Funds?

Index funds may offer simplicity and lower expense ratios, but they lack flexibility. They cannot adapt to market conditions or capitalise on outperforming sectors. Actively managed funds, on the other hand, have the potential to outperform the market, especially in a developing economy like India.

Start with a Systematic Investment Plan (SIP) in selected funds to build wealth steadily.

2. Debt Mutual Funds for Stability
Debt funds add stability to your portfolio and reduce overall risk:

Choose funds with low credit risk and moderate duration to ensure safety and predictable returns.

Debt funds are suitable for short- to medium-term goals or as a fallback during market corrections.

Taxation Note: Both LTCG and STCG on debt funds are taxed as per your income tax slab. This should be factored into your planning.

3. Balanced Advantage Funds
Balanced advantage funds (BAFs) dynamically allocate assets between equity and debt. They:

Provide exposure to equity while minimising downside risk.

Offer a suitable option for someone nearing retirement but seeking growth.

4. Gold Investments for Diversification
Allocate a small portion (5-10%) of your portfolio to gold:

Gold serves as a hedge against inflation and currency depreciation.

Choose gold ETFs or sovereign gold bonds for ease of liquidity and better returns.

Emergency Fund Creation
Having an emergency fund is non-negotiable:

Maintain at least 6-12 months of expenses in liquid investments like liquid mutual funds or high-interest savings accounts.

This ensures liquidity for unforeseen events without disturbing your long-term investments.

Focus on Retirement Planning
At 62, balancing growth and safety becomes critical:

Estimate your monthly retirement expenses, considering inflation over the next 10-15 years.

Your target of Rs. 5 crores should primarily serve as your retirement corpus.

Allocate assets thoughtfully:

60-70% in equity funds for growth.
30-40% in debt funds for stability.
Periodically rebalance your portfolio to maintain this allocation.

Strategic Tax Planning
Tax efficiency can significantly impact your returns:

Continue using Section 80C to its full potential, including ELSS funds and PPF.

Consider the National Pension System (NPS) for an additional Rs. 50,000 deduction under Section 80CCD(1B).

Be mindful of the new taxation rules for mutual funds:

Equity Mutual Funds: LTCG above Rs. 1.25 lakh is taxed at 12.5%; STCG at 20%.
Debt Funds: LTCG and STCG are taxed as per your income slab.
Consult a Certified Financial Planner to optimise your tax strategy.

Regular Portfolio Monitoring and Rebalancing
Investing is not a one-time activity:

Review your portfolio every six months or annually to track performance.

Rebalance your asset allocation periodically to align with your financial goals and risk appetite.

Stay committed to SIPs even during market downturns, as this ensures cost-averaging.

Additional Suggestions
Avoid Over-Reliance on PPF
While PPF is safe, it is not sufficient for wealth creation. Shift excess contributions to equity-based investments for better returns.

Avoid Direct Stocks
Direct equity investing requires time, expertise, and constant monitoring. It carries higher risk and may lead to losses without proper research. Instead, rely on equity mutual funds managed by professionals.

Avoid Mixing Insurance and Investments
Do not invest in ULIPs or endowment plans, as they offer suboptimal returns. Stick to pure insurance products for protection and mutual funds for growth.

The Role of a Certified Financial Planner
To achieve Rs. 5 crores, a well-crafted financial plan is essential. A Certified Financial Planner (CFP) can:

Analyse your current investments and recommend improvements.

Design a customised strategy tailored to your income, expenses, and goals.

Provide periodic reviews to ensure you stay on track.

Finally
Achieving Rs. 5 crores in 10 years is a realistic goal if you adopt a disciplined and diversified approach.

Optimise your PPF contributions and channel excess funds into higher-growth investments.

Build a diversified portfolio with equity and debt mutual funds.

Include a small allocation to gold and maintain an emergency fund.

Stay consistent with your SIPs and review your investments regularly.

Work with a Certified Financial Planner to create a personalised roadmap.

By following these steps, you can secure your financial future and meet your goals.

Best Regards,

K. Ramalingam, MBA, CFP,

Chief Financial Planner,

www.holisticinvestment.in
https://www.youtube.com/@HolisticInvestment

...Read more

DISCLAIMER: The content of this post by the expert is the personal view of the rediffGURU. Investment in securities market are subject to market risks. Read all the related document carefully before investing. The securities quoted are for illustration only and are not recommendatory. Users are advised to pursue the information provided by the rediffGURU only as a source of information and as a point of reference and to rely on their own judgement when making a decision. RediffGURUS is an intermediary as per India's Information Technology Act.

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