Description
SEBI adjudication order imposing penalties on research analyst Amit Guruh Sachdeva for violations of record maintenance and regulatory compliance requirements.
Summary
SEBI has issued an adjudication order against Amit Guruh Sachdeva (Registration Number INH100005190), a registered research analyst, following an inspection conducted for the period April 1, 2022 to February 29, 2024. The order addresses multiple violations of research analyst regulations, primarily related to record maintenance and compliance requirements.
Key Points
- Research analyst Amit Guruh Sachdeva violated multiple SEBI regulations during inspection period
- Inspection conducted on March 14-15, 2024 for period April 2022 to February 2024
- Show Cause Notice issued on October 31, 2024
- Multiple record maintenance failures identified during inspection
- Violations span across Research Analyst Regulations, Code of Conduct, and SEBI circulars
Regulatory Violations
- Regulations 19 and 25 of SEBI (Research Analysts) Regulations, 2014
- Code of Conduct violations: Clauses 1, 2, 6, 7 and 8 of Third Schedule read with regulation 24(2)
- SEBI Circular violations: Clauses 2, 3 and 4 of December 13, 2021 circular
- Additional violations: Paragraphs 2(i), 2(ii) and 2(iii) of April 6, 2023 circular
Compliance Failures
Record Maintenance Issues:
- Failed to maintain copy of annual audit report
- Missing research reports duly signed and dated
- Absent research recommendations provided to clients
- No rationale documented for research recommendations
- Missing client master records
Important Dates
- Inspection Period: April 1, 2022 to February 29, 2024
- Inspection Dates: March 14-15, 2024
- Findings Communication: June 27, 2024
- Noticee Response: June 29, 2024
- Show Cause Notice: October 31, 2024
- AO Appointment: May 2, 2025
Impact Assessment
This adjudication order reinforces SEBI’s focus on ensuring research analysts maintain proper records and comply with regulatory requirements. While specific to one individual, it serves as a reminder to all research analysts about the importance of maintaining comprehensive documentation and adhering to prescribed conduct standards. The case highlights SEBI’s continued surveillance and enforcement activities in the research analyst space.
Impact Justification
Individual research analyst penalty with limited market-wide impact but important for regulatory compliance