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Is continuing with my policy till maturity wise?

Ramalingam

Ramalingam Kalirajan  |6986 Answers  |Ask -

Mutual Funds, Financial Planning Expert - Answered on Sep 27, 2024

Ramalingam Kalirajan has over 23 years of experience in mutual funds and financial planning.
He has an MBA in finance from the University of Madras and is a certified financial planner.
He is the director and chief financial planner at Holistic Investment, a Chennai-based firm that offers financial planning and wealth management advice.... more
Ram Question by Ram on Sep 27, 2024Hindi
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Thank you for the response! It was indeed detailed! Couple of questions After posting my question, I read that since policy was issued before Feb-2021 (even the last payment of 5th year was made by Jan-2021) Capital gain is 100% tax exempted. life coverage from policy is 30L. Exactly 10x of annual pay! FMC for the funds I chose is 1.35%. ICICI do pay minimum 0.3% loyalty which will partially offset the FMC 1) Given there is no Capital tax under section 10 (10D) and I’m not in need of funds now, isn’t it wise to continue with the policy till maturity? (I would definitely minimize the market volatility risk by moving to lesser risk funds in the last 5 years) 2) Since Fund value exceeded the insurance coverage, will mortality charges still apply? I read the policy document but didn’t understand. If it’s applicable, Typically how much it would be? Approx. % (I’m 43 now) 1) Given

Ans: Thank you for the follow-up!

Continuing the Policy: While the tax exemption and loyalty additions are beneficial, mutual funds generally offer more flexible investment options. For a personalized plan, it’s best to consult a Certified Financial Planner (CFP) to align with your goals.

Mortality Charges: Mortality charges won’t apply as long as the fund value exceeds the cover amount. However, if the market dips and the fund value falls below the cover, they will charge accordingly.

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

Ramalingam Kalirajan  |6986 Answers  |Ask -

Mutual Funds, Financial Planning Expert - Answered on May 26, 2024

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1) I had taken an SBI Life Insurance Policy Retire Smart - LP policy for 10 Lakhs with @1 Lakh premium paid every year. 2) Policy was taken in March 2019, and it was given understanding that I can close the policy after 5 years - without penalty. 3) I had paid 5 Lakhs as premium in this policy and the present fund value is about 5.70 Lakhs. 4) Kindly advice about decision to be taken for this policy after completing 5 years, ie after 7 months. My Age is 74 Years.
Ans: The SBI Life Retire Smart is a Unit Linked Insurance Plan (ULIP) marketed as a pension plan. It invests your premium in equities and debt-oriented funds managed by SBI Life, aiming to provide retirement benefits in the form of an annuity. This review will help you determine if the SBI Life Retire Smart Plan is a good investment for your retirement.

Key Features of SBI Life Retire Smart Plan

This ULIP is designed as a retirement plan and differs from conventional ULIPs. Key features include predefined investment strategies and maturity benefits. For example, if you start this plan at 35 with a 25-year term, paying Rs 1,00,000 annually, your premium will be invested in three different funds under the "Advantage Plan" strategy.

Fund Options and Allocation Strategy

The Retire Smart Plan offers a predefined asset allocation strategy, named the "Advantage Plan." This strategy invests more in high-risk, high-return equity funds in the early years and reallocates to safer funds as the policy matures. This approach aims to balance growth potential with stability over time.

Death Benefits

The death benefit is the highest of the fund value plus terminal addition or 105% of the total premiums paid. Terminal addition is 1.5% of the fund value on the date of death. The nominee can receive the death benefit as a lump sum or use it to purchase an annuity. However, the death benefit does not include a sum assured, making the risk cover minimal.

Maturity Benefits

The maturity benefit is the highest of the fund value plus terminal addition or 101% of the total premiums paid. While the policy guarantees 101% of the premiums paid, the actual return is subject to market performance. The guaranteed maturity benefit may not be sufficient given the potential for higher returns in long-term equity investments.

Analysis of Returns

Guaranteed Returns: If the policy generates an annual return of 4%, the effective annual rate of return (IRR) is approximately 3.62%. After deducting charges, the actual return is even lower.
Higher Returns Scenario: If the policy generates an annual return of 8%, the IRR is around 7.4%. After charges, the actual return is less than 7.4%. Given the 25-year investment horizon, this return is not attractive considering the equity risk.
Comparison with Alternatives

PPF vs. SBI Life Retire Smart

PPF Investment: Investing Rs 1,00,000 annually in PPF for 25 years could provide substantial returns. Assuming the current PPF interest rate of 7.1%, the corpus at the end of 25 years would be approximately Rs 68.7 lakhs.
Tax Benefits: PPF offers tax benefits under section 80C and has the EEE (Exempt-Exempt-Exempt) status. The returns are risk-free and backed by the government.
ELSS vs. SBI Life Retire Smart

ELSS Investment: Investing in ELSS funds could yield an annual return of around 12%. Over 25 years, Rs 1,00,000 invested annually could grow to approximately Rs 1.33 crores, after accounting for 10% long-term capital gains (LTCG) tax.
Flexibility: ELSS investments offer greater flexibility and the potential for higher returns compared to ULIPs. Additionally, ELSS investments provide tax benefits under section 80C.
Surrender and Reinvest Strategy

Considering the low returns and high charges of the SBI Life Retire Smart Plan, it is advisable to surrender the policy after the 5-year lock-in period. You can then reinvest the proceeds into mutual funds.

Reinvestment in Mutual Funds: By investing in diversified mutual funds, you can achieve better returns. Equity mutual funds, in particular, offer significant growth potential over the long term.
Systematic Withdrawal Plan (SWP): During retirement, you can opt for an SWP from your mutual fund investments. SWPs provide regular income by allowing you to withdraw a fixed amount periodically, ensuring a steady cash flow.
Pros and Cons of SBI Life Retire Smart

Pros:

Offers both insurance and investment benefits.
Provides a predefined investment strategy for risk management.
Cons:

High charges for premium allocation and policy administration.
Limited flexibility in fund selection.
Minimal risk cover and guaranteed returns.
Verdict

The SBI Life Retire Smart Plan may not be the best choice for retirement planning. The guaranteed returns are low compared to potential returns from PPF and ELSS. For conservative investors, PPF plus a term insurance plan is a better option. For those with higher risk tolerance, ELSS plus a term insurance plan offers greater growth potential.

Overview

You have an SBI Life Insurance Policy Retire Smart - LP with a sum assured of Rs 10 lakhs, paying an annual premium of Rs 1 lakh since March 2019. With five premiums paid, the current fund value is Rs 5.70 lakhs. You have the option to close the policy after 5 years without penalty. Considering your age of 74 years, the decision should focus on maximizing your retirement funds.

Assessment of Current Situation

Premiums Paid: Rs 5 lakhs
Current Fund Value: Rs 5.70 lakhs
Policy Tenure Completed: Almost 5 years
Your fund has grown modestly, providing a return slightly above the total premiums paid. Given your age and the need for a stable income, it's crucial to evaluate options that ensure financial security and better returns.

Decision After 5 Years

1. Surrender the Policy

After completing 5 years, you can surrender the policy without incurring any penalty. This would be a strategic move considering the limited growth observed in your fund value.

Benefits of Surrendering the Policy:

Avoid Future Charges: ULIPs like this have various charges, including premium allocation, policy administration, and fund management fees, which can eat into returns.
Better Investment Opportunities: You can reinvest the proceeds in more lucrative and less costly investment options.
2. Reinvest in Mutual Funds

After surrendering the policy, consider reinvesting the proceeds into diversified mutual funds. Mutual funds typically offer better returns compared to ULIPs due to lower costs and more focused investment strategies.

Recommended Investment Strategy:

Diversified Equity Funds: Suitable for potentially higher returns, balancing risk with growth opportunities.

Balanced Funds or Hybrid Funds: These funds invest in a mix of equities and debt, offering a balance between growth and stability.

Debt Funds: For conservative investments, providing stable returns with lower risk.

3. Systematic Withdrawal Plan (SWP) for Regular Income

Once reinvested in mutual funds, you can set up a Systematic Withdrawal Plan (SWP) to ensure a regular income. This is particularly beneficial for retirees, offering a steady cash flow while keeping the remaining funds invested for potential growth.

Advantages of SWP:

Regular Income: Fixed amount at regular intervals (monthly, quarterly).
Tax Efficiency: Only the capital gains portion of the withdrawal is taxed.
Flexibility: You can adjust the withdrawal amount based on your needs.
Steps to Implement the Plan:

Surrender the Policy: Contact SBI Life to process the surrender after completing the 5-year term. Ensure you understand the procedure and any documentation required.

Evaluate Mutual Fund Options: With a Certified Financial Planner, choose a mix of mutual funds suited to your risk tolerance and income needs.

Set Up SWP: Once the funds are invested, set up an SWP to provide a regular income.

Conclusion

Considering the limited growth in your current ULIP and your age, surrendering the SBI Life Retire Smart Plan after 5 years is a prudent decision. Reinvesting the proceeds into mutual funds and opting for an SWP can provide better returns and a steady income stream, ensuring financial stability in your retirement years. Always consult a Certified Financial Planner to tailor the strategy to your specific financial situation and goals.

Best Regards,

K. Ramalingam, MBA, CFP,

Chief Financial Planner,

www.holisticinvestment.in

..Read more

Ramalingam

Ramalingam Kalirajan  |6986 Answers  |Ask -

Mutual Funds, Financial Planning Expert - Answered on May 20, 2024

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I am having LIC of a 14 lakhs policy of Jeevan Anand paying premium of 71000. It's going to mature or complete it's 21years term. How much should I expect the maturity amount? Will I be be life covered post maturity amount withdrawal? Where should I invest this maturity amount?
Ans: Assessing Your LIC Jeevan Anand Policy
Understanding Maturity Amount
Your LIC Jeevan Anand policy is nearing the end of its 21-year term. Given a policy sum assured of ?14 lakhs and an annual premium of ?71,000, the maturity amount will include the sum assured along with any applicable bonuses. However, without specific bonus rates, an exact figure is challenging to determine. Generally, LIC policies like Jeevan Anand accrue bonuses over the years, which can significantly enhance the maturity amount.

Life Coverage Post Maturity
One key feature of the LIC Jeevan Anand policy is the continuation of life cover even after the maturity amount is paid out. This means you will still have a life cover equal to the sum assured (?14 lakhs) after the policy matures, providing continued financial security for your beneficiaries.

Investment Recommendations for Maturity Amount
Risk Assessment and Goals
Before deciding where to invest the maturity amount, consider your risk tolerance, financial goals, and investment horizon. Since the maturity amount is likely to be substantial, diversifying across various investment options is prudent.

Investment Options
1. Mutual Funds
Equity Mutual Funds: If you have a high-risk tolerance and a long-term investment horizon, consider equity mutual funds. They offer high growth potential but come with higher volatility.

Balanced or Hybrid Funds: For a moderate risk appetite, balanced funds invest in a mix of equities and debt, providing a balance of growth and stability.

Debt Mutual Funds: If you prefer low risk, debt funds are safer and provide regular income, suitable for short to medium-term goals.

2. Systematic Investment Plan (SIP)
Consider investing a portion of the maturity amount in mutual funds through SIPs. This helps in averaging the purchase cost and reduces the impact of market volatility.

3. Public Provident Fund (PPF)
For long-term, risk-free investments, PPF is a good option. It offers attractive tax-free returns and has a lock-in period of 15 years, making it suitable for retirement planning.

4. National Pension System (NPS)
NPS is another long-term investment option, especially beneficial for retirement planning. It offers a mix of equity, corporate bonds, and government securities with tax benefits.

5. Fixed Deposits (FD)
If you seek safety and assured returns, consider investing a portion in fixed deposits. Although returns are lower compared to equity, FDs provide guaranteed income.

6. Gold
Investing in gold through Gold ETFs or Sovereign Gold Bonds can provide a hedge against inflation and add stability to your portfolio.

Diversified Portfolio Approach
High-Risk Investments: Allocate around 40-50% in equity mutual funds or direct stocks for high growth potential.

Moderate-Risk Investments: Allocate 20-30% in balanced funds or hybrid funds for balanced growth and stability.

Low-Risk Investments: Allocate 20-30% in debt funds, PPF, or FDs for assured returns and safety.

Alternative Investments: Allocate a small portion, around 5-10%, in gold or other alternative assets for diversification.

Conclusion
Upon maturity of your LIC Jeevan Anand policy, you will receive a significant lump sum. Continue benefiting from life coverage even after maturity. To optimize this maturity amount, diversify your investments across equity, debt, and alternative options based on your risk profile and financial goals. Regularly review and adjust your portfolio to stay aligned with your objectives.

Best Regards,

K. Ramalingam, MBA, CFP,

Chief Financial Planner,

www.holisticinvestment.in

..Read more

Ramalingam

Ramalingam Kalirajan  |6986 Answers  |Ask -

Mutual Funds, Financial Planning Expert - Answered on Jul 25, 2024

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I am single and retired with no family or loan commitments. with my enough funds in dividend funds for my routine monthly expenses, I have taken a Health Insurance for Rs.10 lacs with Royal Sundaram and life insurance term plan for Rs.50 lacs and Traditional insurance plan from LIC for Rs. 25 lacs on various named policies out of which except yearly premium of Rs.50,000 all policy payment terms were over. (policies like Jeevan Tarang, Jeevan Amrut etc) To cover this Rs.50000 insurance premium, I am getting survival benefit from Jeevan Tarang policy every year; only the date will differ which I could manage with my credit card payment. Can you please advise me whether the health insurance cover is okay and Life cover is okay; or should I take extra cover. Though I do not require to leave a legacy, I may also surrender the policy, in case of need. please advise
Ans: Financial Overview
Current Status

You are single and retired.

No family or loan commitments.

Insurance Policies

Health insurance: Rs. 10 lakhs with Royal Sundaram.

Life insurance term plan: Rs. 50 lakhs.

Traditional insurance plans from LIC: Rs. 25 lakhs.

Annual insurance premium: Rs. 50,000.

Appreciating Your Efforts
You have a well-structured plan.

Health and life insurance cover your needs.

Insurance Review
Health Insurance

Your health insurance cover is Rs. 10 lakhs.

Consider increasing it to Rs. 20 lakhs.

This ensures better protection against rising medical costs.

Life Insurance

Your life cover is Rs. 50 lakhs.

Since you have no family commitments, this is sufficient.

Traditional Insurance Plans
Jeevan Tarang and Jeevan Amrut

These plans provide survival benefits.

Use these benefits to pay your annual premium.

Surrender Option

Consider surrendering these policies if needed.

The surrender value can be reinvested in mutual funds.

Investment Strategy
Mutual Funds

Actively managed funds can offer higher returns.

Consider SIPs in large-cap and balanced funds.

PPF and NPS

Continue with PPF and NPS investments.

They offer safety and tax benefits.

Disadvantages of Index Funds
Lower Returns

Index funds mimic the market.

They often yield lower returns compared to actively managed funds.

Lack of Flexibility

Index funds have less flexibility.

Actively managed funds adapt to market conditions.

Disadvantages of Direct Funds
Lack of Guidance

Direct funds lack professional advice.

Regular funds provide support through MFDs with CFP credentials.

Higher Risk

Direct funds can be riskier.

Professional guidance helps mitigate risks.

Emergency Fund
Maintain Liquidity

Keep an emergency fund.

Ensure it's equivalent to 6-12 months of expenses.

Liquid Mutual Funds

Consider liquid mutual funds for this purpose.

They offer better returns than savings accounts.

Action Plan
Increase Health Cover

Increase your health insurance to Rs. 20 lakhs.

Review Traditional Policies

Consider surrendering LIC policies.

Reinvest the proceeds in mutual funds.

Continue SIPs

Increase SIP contributions.

Focus on large-cap and balanced funds.

Maintain Emergency Fund

Keep a sufficient emergency fund.

Use liquid mutual funds for better returns.

Final Insights
Your current insurance and investment strategy is commendable.

Consider increasing your health cover for better protection.

Reevaluate traditional policies and focus on mutual funds.

Maintain an emergency fund for financial stability.

Best Regards,

K. Ramalingam, MBA, CFP

Chief Financial Planner

www.holisticinvestment.in

..Read more

Ramalingam

Ramalingam Kalirajan  |6986 Answers  |Ask -

Mutual Funds, Financial Planning Expert - Answered on Aug 28, 2024

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I am a 60-year-young, disciplined bachelor with insurance coverage of Rs. 1 crore, which includes both a term plan and traditional plans. I am self-dependent, and no one is financially dependent on me. Since I don't have a need to create a legacy,. Having decided to surrender my traditional policies (having understood the surrender charges) out of the total insurance coverage of 1 Cr. which includes, Term plan. I narrate the policy terms & benefits, so that you can suggest me the better: 1) PPT (Premium Payment) for the policy is over, I have no premium commitment now. 2) Annual Survival Benefit: Currently receiving 5.5% of the Sum Assured annually. (which is almost equal to the return from FDR or Debt fund) 3) Bonus: at the end of the policy term there will be bonus in the policy which also I got it which is approx 80% of the premiums paid. 3) Life Cover: Coverage until 100 years of age, with annual survival benefit @ 5.5% of Sum assured, and death benfit - the Sum Assured plus accumulated bonuses will be paid to the nominee 4) Maturity Benefit: On survival until 100 years, the entire Sum Assured plus accumulated bonuses will be given to the assured.. I have planned at the time of siginging for the policy agreement, with 12 policies to get every month 5.5% of SA, like pension (passive income). Now, ji, please suggest me, Do you I need to surrender the policy considering 80% of premuium paid is received and getting 5.5% pa every month. with no premium commitment and coverage upto 100 years.
Ans: You have a well-structured insurance portfolio with Rs. 1 crore coverage. This includes term and traditional plans. The plan you mentioned provides a 5.5% annual survival benefit, life cover until age 100, and a maturity benefit. The idea of using these policies as a form of pension by receiving 5.5% of the sum assured monthly is thoughtful.

Given your current situation—no dependents and no need to create a legacy—your focus shifts from protection to optimizing returns. With the premium payment term over, you face no further financial commitments. Your plan is now a source of regular income, and at the end of the term, you will receive a bonus amounting to 80% of the premiums paid.

Evaluating the Need to Continue or Surrender the Policies
Benefits of Continuing with the Policy
Regular Income: The 5.5% survival benefit provides a steady income stream. This is particularly useful if you require a predictable cash flow.

Life Cover Until Age 100: While you may not need life cover, this ensures a safety net is in place. Should anything happen, your nominee receives a substantial amount.

Maturity Benefit: The policy promises the sum assured plus accumulated bonuses at age 100. This is a significant amount that adds to your financial security in your later years.

No Further Commitments: With the premium payment term over, you don’t need to invest any more money into this policy. You are just reaping the benefits now.

Drawbacks of Continuing with the Policy
Low Returns: The 5.5% return is modest, akin to the returns from fixed deposits or debt funds. Over time, inflation might erode the purchasing power of this income.

Opportunity Cost: If you surrender the policy, you could potentially invest the surrender value in higher-yielding investments. This could provide better returns over time.

Limited Flexibility: Insurance policies like this one are rigid. You can't easily adjust your investment based on changing market conditions.

Should You Surrender the Policy?
Factors Favoring Surrender
Unlocking Higher Returns: By surrendering the policy, you can reinvest the surrender value in more lucrative options. Actively managed mutual funds, for instance, offer potential for higher returns.

No Need for Life Cover: With no dependents, the life cover aspect may not be essential. The focus should be on maximizing your financial returns rather than providing a death benefit.

Maximizing Financial Freedom: Reinvesting the surrender value gives you more control over your finances. You can tailor your investments to suit your risk tolerance and financial goals.

Factors Against Surrender
Guaranteed Income: If you value the certainty of the 5.5% survival benefit, continuing the policy is advantageous. This is especially true if you prefer a low-risk, predictable income stream.

Bonus Payout: At the end of the term, you receive a bonus equivalent to 80% of the premiums paid. Surrendering the policy means forfeiting this benefit.

Emotional Comfort: Sometimes, the comfort of having a guaranteed income, regardless of the returns, can outweigh the potential for higher returns elsewhere.

Exploring Alternative Investment Options
Actively Managed Mutual Funds
Higher Returns Potential: Actively managed funds often outperform passive options like index funds. Experienced fund managers can navigate market fluctuations to maximize returns.

Professional Guidance: Investing through a Certified Financial Planner ensures that your investments are aligned with your goals. This helps in optimizing returns while managing risk.

Reinvestment Flexibility: You have the flexibility to reinvest dividends or capital gains, allowing for compounding growth.

Avoiding Direct Funds
Lack of Professional Management: Direct funds require a hands-on approach. Without professional guidance, you might miss out on potential gains or take on unnecessary risks.

Complexity: Direct funds demand more time and knowledge. Unless you’re an expert, this can lead to suboptimal decisions.

Benefits of Regular Funds: By investing through a Certified Financial Planner, you gain access to regular funds. These offer the expertise of a fund manager who can help you navigate market conditions and maximize returns.

Insurance Strategy: Term Plan vs. Traditional Plans
Advantages of Term Plans
Cost-Effective: Term plans provide high coverage at a low cost. This frees up more funds for other investments.

Focus on Wealth Building: With no dependents, you can focus on wealth accumulation rather than protection. The money saved from term insurance premiums can be invested in high-return avenues.

Disadvantages of Traditional Plans
Low Returns: Traditional plans often provide lower returns compared to other investment options. They are primarily designed for protection, not wealth creation.

Lack of Flexibility: Traditional plans are rigid. Once you’re locked in, it’s difficult to adapt to changing financial needs or market conditions.

Should You Retain Your Term Plan?
Minimal Cost: If your term plan premium is low, retaining it might be a good idea. It provides peace of mind at a negligible cost.

Focus on Other Investments: With your primary protection in place, you can focus on building your wealth through other investment options.

Final Insights
In your situation, maximizing your financial returns is key. The traditional policy provides a steady income but may not offer the best returns long-term. Surrendering the policy and reinvesting in actively managed mutual funds could yield better results. This strategy allows you to tailor your investments to your financial goals and risk tolerance.

With no dependents, your primary focus should be on wealth accumulation and enjoying your financial independence. A Certified Financial Planner can guide you through this process, ensuring that your investments are optimized for growth while managing risk.

Best Regards,

K. Ramalingam, MBA, CFP

Chief Financial Planner,

www.holisticinvestment.in

..Read more

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Anu Krishna  |1281 Answers  |Ask -

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Help me!!! 1.I'm starting new "work" on my own(challenging for me) but my mind says quit it, be quite & do nothing. I myself don't know that wether the result of work will be +ive or uncompleted like alws. 2. My mind has become like order seeker type, when someone orders me, I do those things with dedicated(but sad from inside) manner. But when myself will try something different(which i fear, but necessary) then. "I QUITS IT" & sometimes I don't even start. 3. I'm like stuck no clue what/whom I want to do in life, I'm in cllg(1 yr) doing (CSE) ,. 4. I want to do/try (sports,talking girls,study,stocks,coding..) many things, but myself, my thoughts(overthinker), R like just be in the place where u are[confused,po*n,think about past/future(being billio..re,olympics..), girl (that u liked & never talked), abusive/beating self,.. sometimes feels like end life, but don't hv courage for that also.. 5. I tried self help books, spirituality, god, self affirmation, writing... & thay affected me(sometimes) but for only some time, then again that devil me comes up &these things never get completed. As no one in my family knows about all these, so that's Y ,I hv to fight/loose/try again, the battles with myself.
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-What is limiting you?
- What is the reason for putting off things?
- What comes first to the mind when you start something new?
Also, focus on one thing at a time; study and go deep into it...what's this thing with work? I don't understand. When the mind is unsettled, take one thing/activity, pursue it and finish it. It could simply be studying for Year 1 of your college...just only do that...once your mind is trained in completing an activity, you can add another one the next year along with studying and then pursue both...it could be some sport and studying...then the next year, you could add a third activity. This is called 'training the mind in discipline'. Discipline will make sure that you start and finish things...So, go slow and do one thing at a time.

All the best!
Anu Krishna
Mind Coach|NLP Trainer|Author
Drop in: www.unfear.io
Reach me: Facebook: anukrish07/ AND LinkedIn: anukrishna-joyofserving/

...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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