Description

SEBI enquiry order against Research Analyst Nikhil Dayanand Baljekar for failing to cooperate during inspection and allowing third parties to misuse his registration.

Summary

SEBI has issued an enquiry order against Research Analyst Nikhil Dayanand Baljekar (Registration No. INH000009001) for violations during the inspection period from April 1, 2022 to January 31, 2024. The analyst failed to cooperate with SEBI’s inspection and allegedly allowed third parties to misuse his registration for providing investment advice and research services.

Key Points

  • Research Analyst registration number: INH000009001
  • PAN: ABYPB7880N
  • Inspection period: April 1, 2022 to January 31, 2024
  • Failed to provide requested information during on-site visit and follow-up emails
  • Did not respond to inspection findings communicated on March 20, 2024
  • Allegedly allowed third parties to use his IA and RA licenses
  • Shared client details with unauthorized third parties
  • Permitted third parties to give recommendations under his name

Regulatory Violations

  • Regulation 29(1) & (2) of SEBI (Research Analyst) Regulations 2014 - Non-cooperation with inspection
  • Clauses 1, 2 & 7 of Code of Conduct under Third Schedule of RA Regulations 2014
  • Regulations 3(a-d), 4(1) and 4(2)(s) of PFUTP Regulations 2003
  • Sections 12A(a), (b) and (c) of SEBI Act 1992
  • Various clauses of Investment Advisers and Research Analyst Master Circulars

Compliance Requirements

  • Research Analysts must fully cooperate with SEBI inspections
  • Cannot outsource core activities to third parties
  • Must not allow unauthorized use of registration
  • Cannot share client details with unauthorized parties
  • Must maintain proper records and documentation

Important Dates

  • Inspection period: April 1, 2022 to January 31, 2024
  • Reminder emails: February 28, 2024 and March 14, 2024
  • Inspection findings communicated: March 20, 2024
  • Show cause notice issued: June 10, 2024

Impact Assessment

This enforcement action reinforces SEBI’s commitment to ensuring compliance by registered intermediaries. While specific to one analyst, it serves as a warning to all Research Analysts about the importance of cooperating with regulatory inspections and maintaining proper operational standards. The case highlights risks of license misuse and outsourcing of regulated activities.

Impact Justification

Enforcement action against individual analyst with limited market-wide impact