Description
SEBI imposes penalties on M/s Alliance Research (Proprietor: Mudassir Hasan) for violations of Investment Advisers Regulations, PFUTP Regulations, and non-redressal of investor grievances during inspection period April 2018 to February 2020.
Summary
SEBI issued Adjudication Order No. Order/AK/DS/2025-26/31716 against M/s Alliance Research (Proprietor: Mudassir Hasan, PAN: AGDPH7770D, SEBI Regn No.: INA000002934) under Section 15-I of the SEBI Act, 1992. The order follows violations observed during inspection conducted for the period April 01, 2018 to February 11, 2020. SEBI had previously issued an interim ex-parte order on January 06, 2021 and a confirmatory order on July 29, 2022. The adjudication proceedings were initiated on June 15, 2023, with the matter transferred to the current Adjudicating Officer on November 22, 2024.
Key Points
- Investment Adviser M/s Alliance Research found in violation of multiple SEBI regulations during inspection period (April 2018 - February 2020)
- Violations include breach of IA Regulations, PFUTP Regulations, RA Regulations, and Intermediaries Regulations
- Specific violation: Non-redressal of investor grievances under SEBI Circular CIR/OIAE/2014 dated December 18, 2014 read with Regulation 21(1) of IA Regulations
- SEBI conducted inspection at the Noticee’s office and requested detailed information including bank accounts, fee details, client data, and financial statements
- Interim order issued January 06, 2021 under Sections 11(1), 11(4), 11B(1) and 11D of SEBI Act and Regulation 35 of Intermediaries Regulations
- Confirmatory order passed on July 29, 2022 confirming directions against the Noticee
Regulatory Changes
No new regulatory changes introduced. This order enforces existing provisions of:
- SEBI (Investment Advisers) Regulations, 2013
- SEBI (Prohibition of Fraudulent and Unfair Trade Practices relating to Securities Market) Regulations, 2003
- SEBI (Research Analysts) Regulations, 2014
- SEBI (Intermediaries) Regulations, 2008
- SEBI Circular CIR/OIAE/2014 dated December 18, 2014
Compliance Requirements
- Investment Advisers must ensure compliance with investor grievance redressal mechanisms under Regulation 21(1) of IA Regulations
- Registered intermediaries must maintain proper documentation including client agreements, fee records, and audited financial statements
- Investment Advisers must comply with all provisions of IA Regulations, PFUTP Regulations, and Intermediaries Regulations
- Prompt response to SEBI information requests and inspection requirements
Important Dates
- Inspection Period: April 01, 2018 to February 11, 2020
- Interim Ex-parte Order: January 06, 2021
- Confirmatory Order: July 29, 2022
- Information Request: October 28, 2022
- Noticee Reply: November 18, 2022
- Initial AO Appointment: June 15, 2023
- Matter Transfer/Current AO Appointment: November 22, 2024
- Adjudication Order: October 10, 2025
Impact Assessment
Market Impact: Low - Order affects a single registered Investment Adviser (M/s Alliance Research) with limited market-wide implications.
Industry Impact: Medium - Reinforces SEBI’s strict enforcement of Investment Adviser regulations, particularly regarding investor grievance redressal and compliance with PFUTP regulations. Serves as deterrent for other registered Investment Advisers.
Investor Protection: High - Addresses non-redressal of investor grievances, directly impacting client protection mechanisms.
Regulatory Precedent: Demonstrates SEBI’s comprehensive approach to monitoring Investment Advisers through inspections and follow-up adjudication for violations discovered during inspection periods. The multi-year process from inspection (2020) to final adjudication order (2025) shows thoroughness of regulatory proceedings.
Impact Justification
High severity due to multiple regulatory violations by registered Investment Adviser including non-redressal of investor grievances and PFUTP violations. Low market impact as order affects single entity. Medium importance for investment advisory industry compliance standards.