Description
SEBI enquiry order disposing proceedings against Investment Adviser Manoj Jethanand Varyani without adverse action after investigation into dual IA registrations.
Summary
SEBI has disposed of enquiry proceedings against Investment Adviser Manoj Jethanand Varyani (Registration No. INA000015419) without any adverse action. The investigation examined alleged violations related to maintaining dual IA registrations and failure to maintain arm’s length distance between investment advisory activities.
Key Points
- Manoj Jethanand Varyani operated as proprietor of Smart Financial (individual IA registration INA000015419)
- Also functioned as director with 70% shareholding in Bestway Smart Financial Private Limited (corporate IA registration INA000017392)
- Served as Principal Officer in both entities simultaneously
- SEBI inspection conducted for period April 2022 to July 2023
- Alleged violation of Regulation 15(3) of IA Regulations 2013 regarding arm’s length distance
Regulatory Changes
No regulatory changes introduced. Case represents enforcement of existing IA Regulations 2013 requirements.
Compliance Requirements
- Investment Advisers must maintain arm’s length distance between advisory activities and other business activities
- Individual and corporate IA registrations should not create conflicts of interest
- Principal Officers must ensure compliance with registration requirements
Important Dates
- Inspection Period: April 1, 2022 to July 31, 2023
- 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 proceedings were disposed without adverse action. Case serves as precedent for similar dual registration scenarios. No penalties or sanctions imposed on the Investment Adviser.
Impact Justification
Individual IA case disposed without adverse action, limited market impact