“Two roads diverged in a yellow wood, and I— I took the one less traveled by, And that has made all the difference.”

These words by Robert Frost have echoed through many moments of my professional life, but never more than when I reflect on how my entrepreneurial journey as a wealth advisor began.

I started my career as a management trainee at ANZ Grindlays Bank, which later became part of Standard Chartered, and spent seventeen years with the Bank in India and Singapore before returning home to lead the Private Banking division for the firm in India. Those years offered a close view of how the banking industry organised itself. Large institutions shaped client engagement, product-led propositions dominated business strategy, and distribution incentives were firmly embedded in the system.

By most conventional measures, it was a very successful career. But as time passed, my success sat uneasily next to the growing realisation that the system rewarded outcomes I did not always believe served clients best. At the time, clients were gaining access to products, yet many sought something more: a partner who could think with them across investments, their legacy planning and risk governance.

That realisation forced a more uncomfortable question: in a system designed to distribute products efficiently, where does independent judgment truly belong?

Choosing to step away from a distribution-led model meant giving up the commercial certainty that comes with it. But it also marked a return to first principles. When I founded Waterfield Advisors, it was driven by a belief that advice, to be meaningful, must be structurally independent of product incentives, and that clients with complex financial lives instinctively value this separation, even if it comes at a visible cost.

My entrepreneurial jump in late 2011 was followed by SEBI’s RIA framework in January 2013, in what then felt like a landscape-changing shift. SEBI created the RIAs category to address a specific challenge: investors were operating in a marketplace with expanding instruments, multiple intermediaries with divergent incentives, and a regulatory architecture that was still adapting to the pace of participation.

However, fast forward to today, and the Investor-RIA story has not played out as expected. In 2016, there were ~2.45 Crore demat account holders in India. Today, there are more than 20 Crore demat account holders. On the other hand, the number of RIAs is barely reaching 1,000. Of these, the total number of active and practising financial planners is less than 400. This “advice gap” is massive, and it’s a number we should be concerned about.

In this edition of CuriouSR, I will illustrate what wealth advisory looks like, share my thoughts on the factors causing the advice gap, and suggest what must change if advisory is to play the role our markets increasingly demand of it.

What “Good” Looks Like: Advisory Value in Practice

When people ask me what distinguishes a wealth advisor from a distributor, I often find that abstract explanations do not fully convey the depth of the advisory function. The distinction becomes clearest when seen in practice.

Below are three representative examples from our client interactions that illustrate the role of a wealth advisor

Case 1: Improving Efficiencies in a Family Portfolio

A third-generation promoter of a large listed pharmaceutical company had built significant wealth over decades. On the surface, the family’s portfolio appeared conservative and stable. Underneath, however, it was deeply inefficient.

The family was working with multiple distributors and paying annual fees of INR 4–5 crore on a largely fixed-income-heavy portfolio. No one was accountable for overall portfolio construction, risk management, or long-term alignment with the family’s objectives.

The advisory intervention began with a full diagnostic - mapping every asset, understanding ownership structures, and questioning whether the value delivered justified the fees paid. This led to a structured migration plan, a formal investment policy, and a governance framework that separated family pools from individual capital.

Case 2: Wealth Structuring Post Windfall Gains

A technology entrepreneur became extraordinarily wealthy after his company listed on NASDAQ. Overnight, 80–90% of his net worth was tied to a single publicly traded stock. His challenges were concentration risk, liquidity timing, cross-border taxation, and estate exposure. Selling too fast would destroy value. Waiting too long would amplify risk.

Advisory judgement helped answer uncomfortable questions: how much to liquidate, when to sell, how to manage exposure across jurisdictions, and how to structure assets so that wealth remained accessible to family members across borders. Instead of pushing products, the advisory approach focused on sequencing decisions such as liquidity planning, estate structuring, and jurisdiction-aware asset allocation.

Case 3: Simplifying an Overdiversified Portfolio

A multi-generational listed manufacturing family encountered a large liquidity event in the family. Multiple fund managers, overlapping strategies, and high-cost structures had accumulated over time, without anyone viewing the portfolio as a whole.

An initial diagnostic revealed excessive diversification, duplicated PMS exposures, and annual cost leakages running into several crores. More importantly, no one could clearly articulate the family’s risk posture or long-term intent. The advisory intervention focused on simplification - reducing overlap, aligning portfolios to clearly defined objectives, and restoring accountability. A formal investment policy was created, and governance structures were put in place, so decisions were no longer reactive.

Across these scenarios, a common pattern emerges. Effective advisory clarifies the structure of a client’s financial life, identifies risks that are not immediately visible and supports decisions that hold up over time. A common allegory suggests viewing a wealth advisor just like a family doctor, who treats your financial health for a fee.

Two important observations from building Waterfield Advisors as one of India’s largest RIAs -

• Advisory relationships are sticky - Clients tend to stick with their trusted advisors for not years, but across generations. One of the numbers we are extremely proud of at Waterfield is our client retention rate.
• Advisory is getting democratised - The idea that advisory is relevant only for ultra-high-net-worth families (net worth > INR 1,000 Crore) is not true anymore. India’s rapidly growing wealth creators (HNIs, net worth > INR 1 Crore) are demanding fee-based advisory services and seeing the benefit of having a trusted advisor.

But why is advisory not scaling in India yet?

The Advice Gap: Scale Without Judgment

I want to stress the numbers again.

20 crore demat account holders. 5 crore mutual fund investors. Less than 1,000 registered investment advisors. This advice gap reflects a structural disconnect.

We have built unprecedented access to markets, but not a commensurate capacity for independent judgment. Millions of investors are making increasingly complex financial decisions in an environment where advice, when available, is often fragmented, incentive-laden, or episodic.

The consequences of this gap do not worry us yet, because they are subtle.

• Portfolios may appear diversified while remaining exposed to hidden concentrations.
• Liquidity decisions are taken without reference to long-term obligations.
• Behavioural risks (overconfidence in rising markets and panic during drawdowns) go largely unmanaged.

These subtle consequences shape the resilience of the broader system.

Commission-based wealth management scaled faster because it is economically simpler to replicate. Product-linked models offered clear revenue visibility, lower entry barriers and quicker commercial traction. Advisory, by contrast, demands something less tangible: time, trust and the willingness to charge explicitly for judgment.

The Real Trade-offs Behind Advisory

The limited scale of India’s RIA ecosystem is caused by deeper trade-offs embedded in how our system has evolved. Advisory has not failed to scale because it is flawed, but because it demands choices that are harder to make.

Transparent Fees vs Familiar Comfort

Across geographies, investor behaviour remains consistent: chase returns, confidence peaks in bull markets, panic spreads in bear markets. It is exciting to evaluate new and innovative products with with no visible upfront cost. It may not be equally thrilling to stick to the fundamentals of long-term thinking and strategic asset allocation for a visible annual fee.

Depth of Care vs Ease of Replication

The RIA framework rightly insists on documented suitability, transparent recommendations, client agreements, and ongoing review. These are safeguards of fiduciary duty. Yet they introduce a second trade-off. High standards of care are harder to replicate quickly. Distribution models, by design, can be templated and scaled with speed. Advisory requires context, iteration, and accountability, elements that resist standardisation.

Predictable Revenue vs Uncomfortable Honesty

For a wealth manager, the distribution models offer early revenue visibility through commissions and trail income. Advisory does not. It requires advisors to build trust slowly, charge transparently, and sometimes recommend decisions that reduce short-term revenue. This creates an uncomfortable economic asymmetry. Advisory rewards patience and reputation; distribution rewards velocity. Neither is inherently unethical, but they serve different purposes.

Faster Careers vs Deeper Craft

Advisory is a demanding profession. It requires analytical rigour, behavioural understanding, planning expertise, and a strong ethical compass. Yet India has relatively few structured pathways that position fiduciary advisory as a long-term career of stature. Young professionals often gravitate toward distribution because the entry points are clearer and economic rewards arrive sooner.

Visibility vs Verifiable Competence

High-quality advisers are not always the most visible. In the absence of widely understood signals of competence, investors often choose intermediaries based on reach, brand familiarity, or referral momentum. Advisory ecosystems mature when there are credible ways for investors to identify expertise, through transparent disclosures, verified credentials, and institutional credibility rather than marketing scale.

How does the RIA number increase from here on?

India’s path toward a more advisory-led ecosystem will not be linear. It will require improvements in pricing frameworks, operational processes and talent pipelines.

Below are some suggested reforms to help grow the RIA community -

Increase Awareness for Advisory - A movement on the lines of ‘Mutual Fund Sahi Hai’. Collaborate with industry bodies and large platforms to increase public awareness of the value of SEBI-registered advice. Publicise success stories and highlight the importance of registration for investor protection.

AI-integrated Digital Infrastructure - Standardised, regulator-aligned tools for risk profiling, suitability mapping, documentation, audit trails, and periodic reviews would allow advisers to spend more time on judgment and less on process. Intelligent systems can flag inconsistencies, prompt periodic reviews, and automate record-keeping in ways that improve both compliance quality and efficiency.

Talent Development - Structured training programmes that go beyond product knowledge, covering financial planning, behavioural finance, governance, estate structuring, and ethical decision-making. Apprenticeship models within established advisory firms, mentorship frameworks, and clearer progression from junior planner to lead adviser would help professionalise the field.

Ease of Transition from Distributor to Advisory Model - Offer practical transition support and relaxed requirements for AMFI-registered mutual fund distributors or other financial intermediaries who wish to migrate to the fiduciary RIA model.

Reduced Ongoing Compliance for Low-Volume RIAs - Offer proportionate compliance requirements and lower deposit/net worth standards for individual and small-scale RIAs handling fewer clients, incentivizing new solo practitioners and niche firms.

Ease of Transition for an Investor from Distributor to Advisory Model – Allow a simple switch for investors to move from a Distributor Code to an Advisory Direct Code/Share Class instead of treating the change as a redemption and taxable event. This is perhaps the single biggest hurdle for the industry today.

Fixed Fees Slab - Raise the maximum fixed fee slab (currently Rs. 1.5 lakh per client annually) to allow greater compensation for advisors delivering high-value and complex financial planning services.

Fee Structures - Continue enhancing flexibility in payment structures and fee options, including allowing tailored, performance-based, or multi-year fee arrangements by mutual consent.

Final Thoughts

“I shall be telling this with a sigh Somewhere ages and ages hence: Two roads diverged in a wood, and I— I took the one less traveled by, And that has made all the difference.”

Robert Frost ends his poem “with a sigh,” leaving the reader to decide whether that sigh carries regret or quiet satisfaction. I have come to believe it is neither. It is the sound that accompanies any meaningful choice, one made with full awareness of what was left behind.

As India’s financial ecosystem continues to expand, the decisions we make today about how advice is structured, valued, and delivered will shape outcomes far beyond individual portfolios. The road toward a stronger advisory culture will require patience, thoughtful design, and collective intent. It will not be free of doubt. But it is a road worth taking, deliberately, responsibly, and with confidence in the direction it leads.

If, someday, we look back and pause with a sigh, I hope it is one of resolve, recognising that building an advisory-led ecosystem was never about choosing the safer option, but about choosing the right one.