Turtle Wealth Management


Incorporated on 23 April 2012, Turtle Wealth Management Pvt. Ltd. offers portfolio management services, wealth management and smallcase services to clients. 

Their clients are HNIs, HUFs, Family Offices, Corporates, NRIs and partnership firms.

The company is SEBI registered PMS with their registration number being INP000006758. 

Key staff

Rohan Mehra is CEO and fund manager of the company. He has a total of 15 years of experience in fund management. Prior to these qualifications, he was a research head at Jainam Share Consultants Pvt. Ltd. He is an author of the book ‘212° The Complete Trader’. He has done his MBA in marketing and finance from K.P.E.S English School. LinkedIn profile

Vibhati Arya has been COO of the company since 2012. She has 11 years of experience in equities. Prior to this, she was a research executive at Jainam Share Consultants Pvt. Ltd.  She has a masters in finance degree from Symbiosis Centre for Distance Learning. LinedIn profile

Hardik Gandhi is the Co-founder and Chief Business Officer of Turtle Wealth Management. Prior to this, he was an equity research analyst at Jainam Share Consultants Pvt. Ltd. for 3 years. He has done his MBA and post graduation in  finance and financial management services from MIT School of Business. LinkedIn profile

Funds managed

Fund nameAsset class License 
Turtle Wealth – 212° Wealth MantraMulti-cap fundPMS

212° Symbolism – In his book “212° The Complete Trader” Fund Manager Rohan Mehra highlights the importance of 212° as “Till 211 degrees, water is hot and after reaching 212°, it starts boiling. And with the boiling water, comes steam, and with steam, you can empower even a train! In any profession, it’s that one Extra Degree that makes a difference of being a Winner or a follower”. So probably this could be the inception of the fund name.

Turtle Wealth – 212° Wealth Mantra is a multi-cap PMS fund, the date of inception of which was 30 September 2019. It is managed by Rohan Mehra. The benchmark of this fund is the Nifty 500 and the return is calculated using the TWRR method. The minimum investment amount required starts from INR 1 crore that equates to US$ 137 thousand with no existent lock in period. The funds managers expense is 2%. 

According to PMS AIF World, as of 28th February 2021, the number of stocks in their portfolio were 20 with the market cap allocation of 65.60% in large cap, 27.30% in mid cap, 3.50% in small cap and 3.60% in cash. Their portfolio PE was 68.18. With the use of the data provided by PMS AIF World, a few comparative charts have been created to show the sectoral allocation and performance of the PMS as compared to its benchmark. A table for the portfolio holdings is also shown below. 

The above figure shows the Sectoral allocation as of 28/02/2021.

The above figure shows the performance as compared to the benchmark as of 28/02/2021.

Portfolio holdings table sourced from PMS AIF World (Holdings as of 28th February 2021)

Investment philosophy

What can be understood from the diagram is that the fund is always aware of the risks that it is facing and always calculates the downside limits. They premeditate the exit position even before they enter a position. They want to have a higher quality of investors that are ready for 15-20% downside risks and a minimum 5 years of investment horizon. They believe that if biases are controlled, they will eventually be rewarded. They believe that a positive trend is the foremost factor in the selection of a stock and in keeping a low churning ratio. Turtle invests and allocates more when a company is doing good and eliminates the company from the portfolio if the business of the company is underperforming. This is pyramid profits >= exiting fees criteria. When to buy is a question that the firm answers using the lollapalooza effect. Asset allocation philosophy that they possess is to invest 100% when there are opportunities and 0% when there are no opportunities or the market is in a structural bear zone. 

Apart from this, in the media link that we have listed below, Rohan Mehra, the fund manager also shares the diagram of the cycle of market emotions. He says that he has been using this as an input since the last 10 years and it helped him create good returns in the past and he presently also uses this model and believes that at the point of maximum potential is where investors should find grade companies and invest for a long term. 


The investment objective states that the company wishes to create 100x wealth in the next 25 years with a CAGR of 20%. This is to be achieved by investing in outstanding businesses where leadership and growth are existent with a bottom up approach. The investments are made in the stocks that exhibit growth and are compounders. They believe that a positive trend is the foremost factor in the selection of a stock which gives an indication to the fact that they are momentum based investors. 


The firm invests in upto 18 stocks with a mix of growth and compounders. They say that they use a bottom up approach by which their process of investing should be close to what is mentioned here. The stock selection made by the firm is based on their PPP formula (price, profit, people). The company analyses the price of the stock, the profit that the business is earning by checking its financials and the check on the people that are running the business while they are looking for a stock. Horizontal growth, moat in business, growth potential, lowest to 0 debt to equity, high entry barriers in business, consistent track record, high corporate governance and least possibility of disruption are some criterias that are a part of the stock selection screens. Turtle selects the assets to be allocated only when it sees opportunities in the business and then the asset class. Then they have a risk management system that has a drawdown cover at 18% of invested value i.e., there is only a per stock risk of 1.2%. The firm uses, very rarely, derivatives for hedging purposes. Asset allocation philosophy that they possess is to invest 0% when there are no opportunities or the market is in a structural bear zone which gives a hint towards the economic analysis. How much emphasis is given to it is yet to be known. 


Wealth Creation – The Turtle’s Way (May Edition), 21 May 2020. 

In this online meeting, Rohan Mehra talks about how the company functions. He talks about what investors should look at before investing, how he started the business with few of his colleagues and how the business is a PMS now. He then goes to talk about the core ideologies, investment philosophy and the investment rationale of the company. He also shares a chart about the cycle of market emotion that we have talked about in the investment philosophy section. 

Analyst questions

  1. What is your stance on timing the market? How do you decide when to exit before you enter into a position? 
  2. The company says that it invests 0% when there is no opportunity in the market. Where do you invest the funds in hand in positions where you do not look to invest? 
  3. The investments that your firm makes are said to be in stocks that are growth and compounders. This being said, what makes you refrain from value investing? 
  4. What economic variables do you look at while analysing and opportunity and what weightage do you give to economic analysis in general? 
  5. How do you quantify the quality checks that you do for businesses? 

Prepared by – Madhav Patel

Date – 19 March, 2020

Peer review and additional questions

Q1- Do you make cash calls and what is your rationale on how much to keep as liquid cash?

Q2- How have you come up with 18% drawdown limit? 

Q3- As per your investment philosophy you say “pyramid as per the opportunity”, could you elaborate it and explain what parameters governs this decision of yours?Q4- As your company was founded in 2012 and fund was started in 2019, but as per your factsheet you are showing results of alpha for the last 11 years why is so? What is the rationale behind this?

Peer Reviewed by – Rajesh Pathak May 2021



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