Description
SEBI order under Section 12(3) against registered Investment Adviser Alliance Research and its proprietor Mudassir Hasan following inspection findings and interim order dated January 6, 2021.
Summary
SEBI has issued an order under Section 12(3) of the SEBI Act, 1992 read with Regulation 27 and 35 of SEBI (Intermediaries) Regulations, 2008 and Regulation 28 of SEBI (Investment Advisers) Regulations, 2013 against M/s Alliance Research (Proprietor: Mudassir Hasan), a registered Investment Adviser (Registration Number: INA000002934, PAN: AGDPH7770D). The order follows an inspection and interim order dated January 6, 2021, with the Designated Authority recommending suspension of registration certificate for six months in a report dated October 17, 2023.
Key Points
- Alliance Research is a proprietary firm registered as Investment Adviser with SEBI since April 16, 2015
- Interim order was passed against the IA on January 6, 2021 during ongoing inspection
- Three parallel proceedings initiated: (1) Section 12(3) proceedings, (2) Adjudication under Section 15I, and (3) Confirmatory order process
- Confirmatory order passed on July 29, 2022 confirmed interim directions but noted findings were prima facie, pending detailed Section 12(3) proceedings
- Designated Authority submitted report on October 17, 2023 recommending six-month suspension of registration certificate
- Noticee filed for settlement of both Section 12(3) and Adjudication proceedings on November 1, 2023 under SEBI (Settlement Proceedings) Regulations, 2018
- Settlement application remains pending for disposal
- Case referred for disposal in March 2025 after resolution of procedural deadlock regarding parallel proceedings
Regulatory Changes
No new regulatory changes introduced. This order relates to enforcement of existing SEBI Act provisions and Investment Advisers Regulations.
Compliance Requirements
- Investment Advisers must comply with SEBI (Investment Advisers) Regulations, 2013
- Registered intermediaries are subject to inspection by SEBI
- Non-compliance may result in suspension or cancellation of registration under Section 12(3) proceedings
- Settlement option available under SEBI (Settlement Proceedings) Regulations, 2018 for pending enforcement matters
Important Dates
- April 16, 2015: Alliance Research registered as Investment Adviser
- January 6, 2021: Interim order passed against the IA
- July 29, 2022: Confirmatory order issued
- October 17, 2023: Designated Authority submitted report recommending six-month suspension
- November 1, 2023: Noticee filed settlement application
- March 2025: Matter referred for disposal after procedural resolution
- October 7, 2025: Order issued
Impact Assessment
Impact on Alliance Research: Faces potential six-month suspension of Investment Adviser registration as recommended by Designated Authority, pending final order. Settlement application offers possibility of negotiated resolution.
Market Impact: Limited direct market impact as this concerns a single registered Investment Adviser. However, demonstrates SEBI’s enforcement approach for IA regulation violations and availability of multiple enforcement pathways.
Procedural Significance: Case highlights complexity of parallel proceedings under different SEBI Act sections and settlement mechanisms available to regulated entities facing enforcement actions.
Industry Implications: Reinforces importance of compliance with Investment Adviser regulations and inspection requirements for all registered IAs.
Impact Justification
Enforcement action against a registered Investment Adviser involving potential suspension and multiple parallel proceedings under SEBI Act sections 12(3) and 15I, with settlement application pending