International Money Matters Pvt Ltd.

Item 1 – Cover Page International Money Matters Pvt Ltd. Form ADV Part 2A (“Brochure”) 5th Floor, Capsule Works, South Wing, Shubharam Complex, 144, Mahatma Gandhi Rd Bengaluru, Karnataka 560001 www.immpl.com June 29, 2026 This Brochure provides information about the qualifications and business practices of International Money Matters Pvt Ltd. (“IMMPL”). If you have any questions about the contents of this Brochure, please contact us at +9180-49904565 or sneha.j@immpl.com. The information in this Brochure has not been approved or verified by the United States Securities and Exchange Commission or by any state securities authority. Additional information about International Money Matters Pvt Ltd. is available on the SEC’s website at www.adviserinfo.sec.gov by searching CRD #329433 Please note that the term "registered investment adviser" and the description of our firm and our associates as "registered" do not imply a certain level of skill or training. i  Item 2 - Material Changes Since the last filing of this Brochure, there have been no material changes to report. ii  Item 3 – Table of Contents Item 1 – Cover Page ....................................................................................................................................... i Item 2 - Material Changes ............................................................................................................................. ii Item 3 – Table of Contents ............................................................................................................................ 1 Item 4 – Advisory Business ........................................................................................................................... 2 Item 5 – Fees and Compensation ................................................................................................................. 4 Item 6 – Performance-Based Fees and Side-By-Side Management ............................................................. 6 Item 7 – Types of Clients ............................................................................................................................... 7 Item 8 - Methods of Analysis, Investment Strategies and Risk of Loss ......................................................... 8 Item 9 – Disciplinary Information ............................................................................................................... 11 Item 10 – Other Financial Industry Activities and Affiliations .................................................................... 12 Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading .............. 13 Item 12 – Brokerage Practices .................................................................................................................... 14 Item 13 – Review of Accounts..................................................................................................................... 15 Item 14 – Client Referrals and Other Compensation .................................................................................. 16 Item 15 – Custody ....................................................................................................................................... 17 Item 16 – Investment Discretion ................................................................................................................ 18 Item 17 – Voting Client Securities ............................................................................................................... 19 Item 18 – Financial Information .................................................................................................................. 20 1  Item 4 – Advisory Business International Money Matters Pvt Ltd. (“IMMPL”) is an investment adviser registered with the U.S. Securities and Exchange Commission (the “SEC”) under the Investment Advisers Act of 1940 (“Advisers Act”). IMMPL’s CEO, Lovaii Navlakhi, founded IMMPL and started its operations as a proprietorship firm on November 14, 2001. IMMPL is also organized under India's laws and has been a Registered Investment Adviser with the Securities and Exchange Board of India ("SEBI") since March 14, 2014. IMMPL’s principal shareholders. (i.e., those individuals and entities controlling 25% or more of IMMPL) are: Lovaii Navlakhi – 51.43% As of March 31. 2026, IMMPL managed non-discretionary client assets of $278,307,720. Overview of Advisory Services IMMPL provides investment advisory services based on a client's financial needs. IMMPL adopts a client-centric approach to build stronger relationships by setting expectations through transparent communication. The focus is not to promote a product or service but to create an experience where the client is a co-creator of his or her financial roadmap to achieve financial security and independence, which is achieved through personalized advice with a greater focus on continuous education through the following steps: 1. Initial Discussion - IMMPL provides clients with enhanced clarity regarding how IMMPL can assist them in achieving their financial objectives. IMMPL not only delves into more than just the practical aspects of money but also the emotional dimensions of the client and his or her family. 2. Plan Formulation - IMMPL collects the client’s financial information to develop a personalized financial plan. 3. Plan Presentation - IMMPL presents the results of the personalized financial plan to the client. IMMPL offers a comprehensive explanation of the plan, detailing the proposed strategies and reasoning behind them and discussing any assumptions made during the planning process that could impact projected outcomes. IMMPL ensures the client fully understands the plan and its implications, answers the client’s questions, and addresses any outstanding concerns. IMMPL’s goal is to empower clients with the knowledge and understanding they need to make informed decisions about their financial futures. 4. Implementation - IMMPL will implement the personalized financial plan once it has been finalized and agreed upon with the client. IMMPL works on the specific recommendations and strategies outlined in the plan, such as establishing investment accounts, purchasing required insurance coverage, and creating a reinvestment plan. IMMPL considers the client's objectives and preferences throughout the implementation process, adjusting the financial plan as necessary to accommodate the client’s circumstances and goals. IMMPL is in regular communication with the client to facilitate a smooth implementation process, addressing any concerns or questions that may arise along the way. 2  5. Maintenance & Review - Financial Planning is not a one-time event but an ongoing process that requires regular monitoring and adjustments to stay aligned with changing circumstances and objectives. IMMPL reviews a financial plan periodically to assess its effectiveness and relevance, considering any changes in the client's life or financial situation. IMMPL and the client determine the frequency of these reviews together, considering factors such as the complexity of the plan, the client's preferences, and market conditions. During these reviews, IMMPL will evaluate the progress made towards the client's goals, review any changes in the client’s financial situation, and consider any adjustments to the plan. Regularly reviewing and updating the financial plan ensures that it remains a dynamic and effective tool for achieving the client's long-term financial objectives. IMMPL’s comprehensive financial planning services provide clients with holistic advice in a variety of disciplines, including, but not limited to, cash flow management, insurance and risk management, tax planning, investment planning, and succession planning. 3  Item 5 – Fees and Compensation Financial Planning Services Financial Plan I. • Personalized Cross- border financial plan which covers assets and goals in two or more countries: Pricing- Rs. 75,000/-, or equivalent amount in foreign currency. • If a financial planning client is converted to an advisory client, 50% of the financial planning fees will be adjusted with the Asset Under Advisement (“AUA”)-based fees subsequently. Subsequent Standalone Financial Plan Review II. • Review of cross-border financial plan – Rs 37,500/-, or equivalent amount in foreign currency. • Review pricing applies when there are no significant changes in life circumstances or goals and when review is conducted within 2 years of the original financial plan. Portfolio Management Services Our fee slabs are denominated in Indian Rupee (INR). The United States Dollar (USD) equivalents are indicative and may vary with the INR/USD exchange rate; the underlying fee structure remains unchanged. AUA (INR)) ₹0 - ₹3 crore ₹3 - ₹5 crore Fees 1.25% 1.00% AUA (USD) $ 0k - $ 320k $ 320k - $ 540k 0.75% $ 540k - $ 1,070k ₹5 - ₹10 crore 0.60% $ 1,070k - $ 1,610k ₹10 - ₹15 crore ₹15 - ₹20 crore ₹20 - ₹25 crore Above ₹25 crore 0.50% 0.40% 0.35% $ 1,610k - $ 2,140k $ 2,140k - $ 2,680k Above $ 2,680K 1INR =93.4 USD, round off to nearest 10,000 For certain investment products where a direct investment option is not available, we may receive a commission from the product provider; such products are excluded from the assets on which our advisory fee is calculated. Additionally, certain clients are engaged on a distribution basis, under which no advisory fee is charged, and compensation is received solely in the form of commissions from product providers. The advisory fee is charged annually in advance at the start of each financial year (April), based on the AUA slab as of 31st March of the prior year. Any difference from the previous FY’s actual fee is adjusted in the current FY invoice. New clients onboarded between April and September are billed twice in their first financial year — once in the month of onboarding and once in October (based on AUA as of 30th September), with any difference adjusted in the next invoice. Clients onboarded between October and March are billed once in the month of onboarding. From the second financial year onward, standard annual billing applies. 4 - -  On early termination, IMMPL will refund fees for the unused portion of the contract period, subject to a maximum retention of one quarter’s fee. 5  Item 6 – Performance-Based Fees and Side-By-Side Management IMMPL does not charge fees based on the performance of the assets it manages or for side-by-side management. Avoiding performance-based and side-by-side management fees prevents potential conflicts of interest and helps IMMPL align its interests with those of its clients. Charging a flat advisory fee based on AUM ensures that IMMPL's compensation is not directly tied to short-term performance, fostering a more balanced and client-focused approach. This approach reflects a commitment to ethical and transparent business practices. Clients can rest assured that IMMPL operates independently from any fee structures that might compromise the quality of advisory services. 6  Item 7 – Types of Clients IMMPL provides financial planning and advisory services to individuals, including high-net-worth individuals. Individuals: IMMPL works with individuals from various walks of life, each with their unique financial goals, circumstances, and preferences. IMMPL takes a personalized approach to financial planning, considering each client's specific needs and objectives. High-Net-Worth Individuals (HNWI): In serving the individual client base, IMMPL specifically targets high- net-worth individuals with significant financial assets and complex financial situations. IMMPL handles intricate financial planning requirements involving estate planning, tax optimization, and investment management, covering global allocation, life transitions, and much more. 7  Item 8 - Methods of Analysis, Investment Strategies and Risk of Loss Methods of Analysis IMMPL uses the following methods of analysis in formulating investment advice and managing client assets:  Personal Goals Understanding a client's goals is critical in developing an effective investment strategy. Before delving into the specifics of investments, IMMPL takes time to thoroughly comprehend what the client hopes to achieve with his or her finances. Additionally, IMMPL recognizes that personal goals may evolve or change over time due to changes in life circumstances. Therefore, IMMPL communicates openly with clients to ensure their investment strategy aligns with their evolving goals and objectives. This allows IMMPL to adapt the investment approach as needed, helping the client stay on track to achieve his or her financial aspirations, regardless of any life changes.  Risk Appetite Before formulating an ideal investment strategy, IMMPL assesses three key parameters within each client's risk profile: their need, ability, and willingness to embrace risk. Focusing on risk tolerance level and personal goals, IMMPL tailors an investment strategy to suit every client’s unique circumstances and aspirations.  Diversification IMMPL diversifies investments by spreading them across different assets or asset classes. This strategy effectively reduces the client’s exposure to the specific risks associated with any single investment. The principle that other asset classes react differently to market conditions achieves this risk mitigation, allowing gains in one area to offset losses in another. Diversification reduces portfolio volatility and ensures stability and consistency in returns over the long term.  Portfolio Attributes & Fund Manager IMMPL analyzes a fund management team's knowledge and experience based on quantitative and qualitative attributes. Quantitative attributes include a fund's historical performance, significant drawdowns, and skewness. Qualitative attributes include the investment team's expertise, efficiency, experience, portfolio construction consistent with the stated investment philosophy and process, fund manager's track record, and back-office service.  Fund House IMMPL evaluates the fund house's reputation and credibility within the financial industry. A well- established reputation indicates stability and ethical practices crucial for investor trust. Understanding the fund house's investment philosophy and strategy is paramount, ensuring alignment with personal financial goals and risk tolerance. Regulatory compliance is fundamental, with adherence to financial 8  regulations showcasing the fund house's commitment to investor protection. Equally important is the quality of client services and support, encompassing accessibility and responsiveness.  Risk of Loss All investments in securities carry the risk of losing the principal (invested amount) and any unrealized profits. Clients should be prepared to bear the risk that financial asset prices may fluctuate substantially over time. In addition, as recent global economic events have shown, the performance of any investment is not guaranteed. Description of Material Risks 1) Risks associated with Equity Asset Class a) Price Fluctuations and Volatility Equity shares and equity-related instruments are volatile, and the market value of investments can go up or down because of various factors that affect the capital market in general, such as, but not limited to, changes in interest rates, government policy, global macros, and volatility in the capital markets. Currency exchange rates may also affect security prices. b) Liquidity Risk Trading volumes, settlement periods, and transfer procedures may affect equity investments' liquidity. These factors may also affect the fund manager's ability to make intended purchases/sales, causing potential losses and missing specific investment opportunities. These factors can also affect the time the fund manager takes to redeem Units, which could be significant in the event of massive redemption requests. 2) Risks associated with Fixed Income Asset Class a) Credit Risk Fixed-income securities carry a risk that the issuer of a security will not be able to make principal and interest payments when due. This risk depends on microeconomic factors, such as the borrower's financial soundness and ability, and macroeconomic factors, such as Industry performance. Credit risks of most issuers of Debt securities are rated by Independent and professionally run rating agencies. Ratings of Credit issued by these agencies typically range from "AAA" to "D" (denoting "Default"), with about six distinct ratings between the two extremes. b) Interest-Rate Risk Generally, when interest rates rise, prices of fixed-income securities fall, and when interest rates drop, the prices of fixed-income securities rise. The extent of the fall or rise in the prices is a function of the existing coupon, the payment frequency of such coupon, days to maturity, and the increase or decrease in interest rates. Changing interest rates affects the prices of Government Securities (existing and new). Meanwhile, in the case of corporate or institutional fixed-income securities, such as bonds or debentures, the credit rating and liquidity of securities, in addition to changes in interest rates, affect prices. c) Risk of Rating Migration 9  Rating agencies assign credit ratings to bonds to indicate the issuer's creditworthiness. A higher credit rating suggests lower risk and vice versa. The risk of rating migration comes into play when the issuer's financial situation deteriorates, leading the rating agency to downgrade the bond's credit rating. If agencies downgrade a bond’s rating , the client may experience a loss when selling it. The market tends to view lower-rated bonds as riskier, and its market price may fall. Simply put, the risk of rating migration is that a bond's credit rating could decrease, leading to potential financial consequences for the client. d) Liquidity Risk The corporate debt market is relatively illiquid vis-a-vis the government securities market. However, there could be difficulties exiting corporate bonds in times of uncertainty. Liquidity in a scheme, therefore, may suffer. Even though the Government Securities market is more liquid than other debt instruments, there could be difficulties in transacting in the market due to extreme volatility or unusual constriction in market volumes or when a substantial transaction must be made. Given this, redemption may be unavailable. 3) Risk associated with Commodities such as Gold The value of gold may fluctuate for several reasons, and all such fluctuations will result in changes in its investment value. The factors that can influence the price of gold include, among other things, the demand and supply for gold in the global market, foreign exchange rates, interest rates, inflation trends, and trading in gold as a commodity. Additionally, legal restrictions on the movement or trade of gold that the RBI, the Government of India, or countries that supply or purchase gold to/from India impose can also affect gold prices. 4) Risk associated with International Investments In addition to the risk associated with Equity and Fixed-income asset classes mentioned above, below are the additional risks that international funds are associated with: a) Currency Risk Investments in overseas securities are subject to currency risk. Returns to investors are the result of a combination of returns from investments and movements in exchange rates. For example, if the home currency (Rupee) appreciates versus the U.S. Dollar (USD), the extent of appreciation will lead to lower returns to the investor. b) Risks of Investing in Emerging Markets Investments in emerging market issuers may be subject to a greater risk of loss than investments in issuers located or operating in more developed markets. Emerging markets may be more likely to experience inflation, political turmoil, and rapid changes in economic conditions than developed markets. c) Geographic Risk A natural or other disaster could occur in a geographic region, affecting the economy or business operations of companies in that region and adversely impacting the investment. 10  Item 9 – Disciplinary Information IMMPL must disclose any legal or disciplinary event that could significantly impact clients' assessment of IMMPL or the trustworthiness of its management. IMMPL affirms that there are no legal or disciplinary events to report. 11  Item 10 – Other Financial Industry Activities and Affiliations Insurance Company The Insurance Regulatory and Development Authority of India (IRDAI) has issued a Corporate Agency License to IMMPL, which authorizes IMMPL to advise and sell insurance. Leveraging this license, IMMPL has established partnerships with various service providers through Corporate Agency Agreements. This enables IMMPL to provide comprehensive insurance solutions to its clients, covering Life, General, and Health Insurance, each regulated by IRDAI. IMMPL’s commitment extends beyond initial policy issuance; IMMPL offers ongoing services such as assistance in the claims process, renewals of the policies, product reviews, and insurance planning to ensure IMMPL meets the client's evolving needs. As a licensed entity, IMMPL only receives commissions for renewals and new business. As explicitly mentioned in its agreement, IMMPL only earns commission and does not bill the clients for the insurance services offered. Additionally, IMMPL diligently files returns to IRDAI as part of its regulatory compliance, reinforcing its commitment to transparency and adherence to industry standards. IMMPL recommends insurance policies based on the client's financial plan after identifying the client’s needs. 12  Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading IMMPL has adopted a Code of Ethics/Conduct (the “Code”) in accordance with the SEC Rule 204A-1 under the Adviser Act. This Code sets forth the standard of business conduct that IMMPL expects all team members to follow, ensuring that they act with due skills, care, and diligence in a client’s best interest. The Code also restricts trading in any security about which IMMPL may be privy to material non-public information. It restricts personal trading activities to prevent any conflict of interest between personal and client interests. IMMPL tries to avoid conflicts of interest as much as possible. In unavoidable cases, it ensures appropriate disclosures to the client. The Code also restricts the exchange of gifts and extends entertainment activities to avoid conflicts of interest. Adherence to the Code maintains the confidentiality of client information and provides adequate information to clients when required. Employees must disclose any information necessary that may create a potential conflict of interest. Employees must also maintain an arms-length relationship between professional and personal activities. The Code also limits the political contributions of IMMPL’s managers and employees to prevent any potential conflicts in that area. When joining IMMPL, an employee must disclose any relevant information, accept the Code in writing, and certify adherence to the Code. Clients or prospective clients can request a copy of the Code by contacting the Chief Compliance Officer at the telephone number or via email specified on the cover page of the Brochure. 13  Item 12 – Brokerage Practices IMMPL recommends securities to its clients that offer no commission on their sales. IMMPL charges its clients a fee based on the managed assets. All Mutual Funds and Managed Portfolio Services selected under IMMPL's recommendation have a direct fee category, wherein the fund house offers no commission or brokerages to IMMPL. Whenever no such direct fee plan is available, for example, insurance, IMMPL will not charge the client a fee. 14  Item 13 – Review of Accounts IMMPL conducts a routine assessment of client portfolios each quarter. This assessment ensures investments align with a client's financial objectives and market conditions. An extensive review of investments occurs annually in collaboration with the IMMPL’s research team. IMMPL exercises a deeper portfolio review in this analysis, considering short-term market trends and the client’s long-term financial goals. The reviews ensure that the portfolio aligns with the client's risk tolerance. IMMPL will make necessary adjustments to a client’s portfolio to keep the investments in line with evolving client situations and needs. IMMPL meets annually with each client to review his or her financial plan. This approach ensures that a broader financial strategy, including specific investments, remains relevant and practical. Major life- altering events or changes in the client's circumstances may require an ad-hoc financial plan review. IMMPL will meet more frequently based on the client's needs. IMMPL is committed to a dynamic and client-centric advisory and portfolio recommendation approach. Regular assessments, collaboration with experts, and consideration of life-changes ensure that a client’s portfolios are current with evolving financial landscapes and individual circumstances. 15  Item 14 – Client Referrals and Other Compensation IMMPL does not utilize solicitors to promote its investment advisory services. Compensation that IMMPL receive is based on a percentage of asset under management as described in Item 5 (Fees and Expenses). IMMPL does not receive any economic benefit, including sales awards and other prizes, from non-clients for providing investment advice or other advisory services to its advisory clients. 16  Item 15 – Custody IMMPL does not maintain custody of client funds or securities. 17  Item 16 – Investment Discretion IMMPL does not have discretionary authority to manage securities inside a client’s portfolio. IMMPL will recommend investment options to the client based on their financial situation and risk tolerance, but the client retains the ultimate decision on when to execute on a recommended action. In so doing, IMMPL adheres to the Code, providing the client with comprehensive disclosures of all relevant information. IMMPL follows a rigorous process of ensuring the client understands the purpose of each recommendation and approves the execution of each transaction in their portfolio. IMMPL bases each recommendation on filtered investment options tailored to the client’s risk profile. 18  Item 17 – Voting Client Securities IMMPL does not vote proxies on behalf of its clients. Clients will receive voting proxies or solicitations directly from their custodians or transfer agents. If voting proxies mistakenly arrive at IMMPL, IMMPL will quickly forward them to the respective client and ask that all future communications be directed to the client. 19  Item 18 – Financial Information IMMPL has no financial obligations or commitments that would hinder its ability to fulfil its contractual or fiduciary responsibilities towards its clients. IMMPL does not hold any funds or securities on behalf of its clients and does not operate as a custodian of their investments. IMMPL remains free from any involvement in bankruptcy or legal proceedings. 20