Published on 17 August,2026
Risk information exists. Can the
investor see the whole picture?
Nayakanti Prashant
3rd Gen Banker & Citizen Lobbyist – Bengaluru
The Starting Point
Dear SEBI Team,
At the outset, looking forward soon to share my responses for
the questions raised by your team on the draft circulars for Accredited
Investors.
Readers, please note SEBI is reviewing its framework for Accredited
Investors.
At the same time, it has proposed a Credit Risk-o-Meter
for certain debt securities — an attempt to make credit risk easier to understand
through a common visual language.
That combination caught my
attention.
An Accredited Investor may hold investments across Mutual
Funds, Specialized Investment Funds, Alternative Investment Funds, Portfolio
Management Services, Angel Funds, Debt Securities and other eligible
avenues.
Different investments.
Different managers.
Different disclosures.
Different ways of expressing risk.
Some may be rated.
Some may be unrated.
The information exists.
But does it speak one common visual language?
This Citizen Observation is not about deciding what is risky
or safe.
It is not about creating a new risk methodology.
It is simply about asking:
Can technology help an Accredited Investor see the
different risk information across the portfolio in one place?
And perhaps...
see the whole picture or at least the major part.
Act I — One Investor. Many Risk
Languages.
Picture an Accredited Investor opening a digital view of the
portfolio.
One investment carries a risk indicator.
Another carries a credit rating.
Another provides detailed risk disclosures.
Another may be unrated.
The investments are all visible.
The risk information is there.
But the languages are different.
And somewhere between the individual investments and the
complete portfolio sits a simple citizen question:
Can all these different risk signals be brought
into one common visual language — without pretending that they are the same
thing?
Perhaps the technology can show the information.
Perhaps the methodology can remain with the domain experts.
Perhaps the investor simply needs a better way to see the
whole picture.
Act II — One Investor. Many
Managers. Many Risk Signals.
Imagine an Accredited Investor looking at the portfolio.
One investment sits with one manager.
Another sits with another.
A mutual fund may carry a prescribed Risk-o-meter.
A debt security may carry a credit rating.
An alternative investment may come with detailed risk
disclosures.
Another investment may be unrated.
The investor is not short of information.
The challenge is that the information may arrive in different
languages.
One says:
Low. Moderate. High.
Another says:
AAA. AA. A.
Another provides pages of disclosures.
And another may simply say:
Unrated.
Different instruments.
Different methodologies.
Different managers.
One portfolio.
Act III — Can the Languages Come
Together?
Now imagine a digital tool.
The investor brings the portfolio together.
The tool does not decide what is safe or unsafe.
It does not replace the existing methodologies.
It simply brings the available risk information together and
presents it through a common visual language.
Perhaps:
🟢 Lower
risk information
🟡 Moderate
risk information
🟠Higher
risk information
🔴 High
risk information
And where a common assessment is not available:
⚪ Risk
information not available / unrated
The important point is not the colour.
The important point is the translation.
Different risk information could remain attributable to its
original methodology, while the investor gets a consolidated visual view.
Act IV — One Citizen Illustration
Perhaps the view could look something like this:
|
Investment |
Existing Risk Information |
Common Visual View |
|
Mutual Fund A |
Risk-o-meter |
🟢 |
|
Debt Security B |
Credit rating |
🟡 |
|
AIF C |
Risk disclosure |
🟠|
|
PMS D |
Portfolio risk information |
🔴 |
|
Investment E |
Unrated / insufficient common information |
⚪ |
Illustrative only.
The colours are not proposed classifications.
They are simply an illustration of how different forms of
existing risk information might become visible through one common visual
language.
And perhaps, for the first time, the investor could see:
not just the investments,
but the risk information surrounding the investments.
One Citizen Thought
Perhaps the future is not about creating one universal
definition of risk.
Perhaps it is about making the different risk information
already available easier to see together.
The methodology can remain with the regulators, rating
agencies, asset managers and other domain experts.
The technology can simply help bring the information together.
Because an Accredited Investor may not need another opinion.
Perhaps the investor needs a better view of the opinions
and risk information that already exist.
And if different methodologies produce different views,
perhaps that difference itself should remain visible.
One portfolio.
Multiple risk languages.
One common visual language.
The First Line on the Whiteboard
Risk information exists. Can the investor see the
whole picture?
A Citizen Observation
This is not a proposal for SEBI to assign a single risk score
to every Accredited Investor.
It is not a recommendation to replace existing risk
methodologies.
It is simply a thought:
Could an appropriately designed digital tool help
an Accredited Investor visualise the risk information across investments,
managers and instruments through a common visual language?
The underlying data, methodologies, classifications, privacy
safeguards, access controls and implementation would naturally belong to the
concerned regulators and domain experts.
The citizen observation is only about making the
information easier to see.
Closing Thought
We already make many things visible digitally.
A transaction can be seen.
A balance can be seen.
A portfolio can be seen.
A credit rating can be seen.
A Risk-o-meter can be seen.
Perhaps the next question is:
Can the different pieces of risk information be
seen together?
Because sometimes the challenge is not finding more
information.
It is seeing the whole picture.
Disclaimer
This Citizen Observation is based on publicly available
information relating to the Securities and Exchange Board of India’s
consultation proposals concerning the Accredited Investor framework and the
proposed Credit Risk-o-Meter for debt securities.
It is a citizen observation and not investment advice,
regulatory advice or an assessment of the merits of any SEBI proposal.
The visual examples and classifications used in this article
are illustrative only. They do not represent proposed risk
classifications for any security, fund, portfolio or investor.
Any actual common visualisation tool would require appropriate
methodology, data standards, privacy protections, access controls, governance
and implementation by the concerned regulators and domain experts.
April 11 — Digital Transactions Day
A digital transaction is more than a transaction.
It is a journey.
Discover → Check → Decide → Authenticate → Transact → Confirm
At each stage, information is created.
The better that information can be organised and made
meaningfully visible, the better the journey can be understood.
Perhaps investment journeys are no different.
Risk information already exists.
The question is whether digital systems can help the investor see
the whole picture.
That is one small thought behind Digital Transactions Day —
April 11.
The Joy of Digital Transactions
The Joy of Digital Transactions
Nayakanti Prashant
3rd Gen Banker & Citizen Lobbyist – Bengaluru
Advocating Digital Transactions Day (April 11)
Author’s Blogs
https://prashantrandomthoughts.blogspot.com
https://prashantnepayments.blogspot.com
https://innovationinbanking.blogspot.com
