Description

SEBI imposes penalty on research analyst for violations of record maintenance, annual audit, and code of conduct requirements.

Summary

SEBI has issued an adjudication order against research analyst Amit Guruh Sachdeva (Registration No. INH100005190) for violations during the inspection period from April 1, 2022 to February 29, 2024. The order addresses multiple regulatory violations related to record maintenance, annual audit requirements, and code of conduct compliance.

Key Points

  • Research analyst Amit Guruh Sachdeva (PAN: BIJPS0406C) found in violation of multiple SEBI regulations
  • Inspection conducted on March 14-15, 2024 revealed systemic compliance failures
  • Show Cause Notice issued on October 31, 2024 under Section 15-I of SEBI Act
  • Multiple violations across record keeping, audit, and conduct requirements identified

Regulatory Violations

  • Regulations 19 and 25 of SEBI Research Analysts Regulations, 2014
  • Clauses 1, 2, 6, 7 and 8 of Code of Conduct under Third Schedule
  • SEBI Circular dated December 13, 2021 (Clauses 2, 3 and 4)
  • SEBI Circular dated April 6, 2023 (Paragraphs 2(i), 2(ii) and 2(iii))

Record Maintenance Failures

  • Failed to maintain annual audit report copies
  • Missing properly signed and dated research reports
  • Absence of documented research recommendations
  • No rationale provided for research recommendations
  • Missing client master records for clients

Compliance Requirements

  • Research analysts must maintain comprehensive records of all activities
  • Annual audit reports must be properly documented and retained
  • All research reports must be signed, dated, and archived
  • Client master records must be maintained for all clients
  • Code of conduct must be strictly followed

Important Dates

  • Inspection Period: April 1, 2022 to February 29, 2024
  • Inspection Date: March 14-15, 2024
  • Show Cause Notice: October 31, 2024
  • Adjudicating Officer Appointment: May 2, 2025

Impact Assessment

This enforcement action reinforces SEBI’s commitment to ensuring research analysts maintain proper standards and documentation. While the impact is limited to one individual analyst, it serves as a reminder to all research analysts about the importance of regulatory compliance and proper record maintenance.

Impact Justification

Individual research analyst penalty with limited market-wide impact