Description
SEBI concludes enquiry proceedings against Investment Adviser Manoj Jethanand Varyani without imposing penalties for alleged violation of arm's length distance requirements.
Summary
SEBI has disposed of enquiry proceedings against Manoj Jethanand Varyani (Registration No. INA000015419), Proprietor of Smart Financial, without any adverse action. The case involved alleged violations of arm’s length distance requirements between investment advisory activities and other business activities during April 2022 to July 2023.
Key Points
- Noticee was registered as Investment Adviser in individual capacity (Registration No. INA000015419)
- Alleged violation: functioning as director (70% shareholding) of another registered IA, Bestway Smart Financial Private Limited
- Served as Principal Officer in both Smart Financial and Bestway Smart Financial Private Limited
- SEBI inspection conducted on August 18, 2023 for period April 1, 2022 to July 31, 2023
- Show cause notice issued on July 12, 2024
- Designated Authority recommended disposal without adverse action
Regulatory Changes
No regulatory changes introduced. This is an enforcement action concluding an individual case.
Compliance Requirements
The order reinforces existing requirements for Investment Advisers to maintain arm’s length distance between investment advisory activities and other business activities as per Regulation 15(3) of IA Regulations, 2013.
Important Dates
- Inspection Period: April 1, 2022 to July 31, 2023
- SEBI Inspection Date: August 18, 2023
- Show Cause Notice: July 12, 2024
- Enquiry Report: February 28, 2025
- Order Date: August 6, 2025
Impact Assessment
Minimal market impact as this relates to an individual Investment Adviser case that was disposed of without penalties. The order demonstrates SEBI’s enforcement approach while showing restraint when circumstances warrant disposal without adverse action.
Impact Justification
Individual case disposed without adverse action, limited market impact