Description

SEBI enforcement order against unregistered investment advisory activities conducted through Telegram channels by M/s Satyam Shivam Sundaram Trading and associates.

Summary

SEBI has issued an enforcement order under Sections 11(1), 11(4), 11(4A), 11B(1), 11B(2) read with Sections 15EB and 15HA of the SEBI Act, 1992 against M/s Satyam Shivam Sundaram Trading (proprietor Mr. Gagan Choudhury), Mr. Gagan Choudhary, Mr. Satyam Suman Choudhary, and Mr. Suman Choudhary for operating unregistered investment advisory services through Telegram channels and soliciting payments from investors.

Key Points

  • M/s Satyam Shivam Sundaram Trading operated under sole proprietorship of Mr. Gagan Choudhury
  • The entity was not registered with SEBI as an investment advisor or intermediary
  • Operated four Telegram channels: (i) Nifty BankNifty Stock Options, (ii) Premium Group Nifty BankNifty Options, (iii) Premium Group Stock Equity Options, and (iv) Premium Group of Investment
  • Received complaints from at least two investors reporting losses and fraudulent advisory services
  • Payments were collected through HDFC Bank account number XXXXXXXXXX6722
  • One complainant reported losses and another reported being duped of Rs. 9,500/-
  • The Telegram channel description stated: “This channel is for stock market study and learning purposes only. We are Not SEBI REGISTERED. You are strictly forbidden to take my calls as advisory. Fees are Non Refundable.”
  • The noticees include family members: Mr. Gagan Choudhury and Mr. Suman Choudhary (brothers), and Mr. Satyam Suman Choudhary (son of Mr. Suman Choudhary)
  • Principal place of business located in Darbhanga, Bihar
  • Contact number used: XXXXXX0268

Regulatory Changes

This order reinforces SEBI’s stance on unregistered investment advisory activities and unauthorized solicitation of investment advice fees. It highlights that:

  • Operating investment advisory services without SEBI registration is prohibited
  • Disclaimer statements (such as “Not SEBI REGISTERED” or “for educational purposes only”) do not exempt entities from regulatory requirements if they are actually providing advisory services and collecting fees
  • Use of digital platforms like Telegram for unregistered advisory activities falls under SEBI’s enforcement purview

Compliance Requirements

  • Any person or entity providing investment advice in securities must obtain registration with SEBI as an Investment Advisor under the SEBI (Investment Advisers) Regulations, 2013
  • Investment advisory services cannot be provided through any platform (including social media and messaging apps) without proper SEBI registration
  • Entities must not solicit or collect fees for investment advisory services without appropriate registration
  • Investors should verify registration status of advisors on SEBI’s official website before engaging their services or making any payments

Important Dates

  • July 17, 2022: First complaint received through SEBI Complaints Redressal System (SCORES)
  • September 7, 2022: Second complaint received via email
  • November 28, 2025: Order issued (document reference: QJA/SS/ERO/ERO-OTHER/31816/2025-26)

Impact Assessment

Investor Impact:

  • Protects retail investors from unregistered and potentially fraudulent advisory services
  • Highlights risks of engaging with unregistered advisors on social media platforms
  • Demonstrates SEBI’s complaint redressal mechanism effectiveness

Market Impact:

  • Reinforces regulatory oversight of digital platforms used for investment services
  • Sends deterrent message to unregistered entities operating advisory services
  • Minimal direct market impact but important for investor protection framework

Operational Impact:

  • Investment advisors must ensure proper registration and compliance
  • Digital platforms and messaging apps are not exempt from regulatory scrutiny
  • Educational content providers must carefully distinguish between education and advisory services to avoid regulatory action

Impact Justification

Enforcement action against unregistered investment advisory activities. Significant for investor protection and regulatory compliance but limited direct market impact.