Description

SEBI adjudication order against investment adviser Chenthil R Iyer for continuing investment advisory activities after registration expiry and operating without a valid NISM certificate.

Summary

SEBI’s Adjudicating Officer issued Order No. Order/JS/YK/2025-26/32139 against Mr. Chenthil R Iyer (PAN: AEWPR4380N), a formerly registered Investment Adviser (INA000008905). The order concerns violations of the SEBI (Investment Advisers) Regulations, 2013, specifically for continuing to collect fees and provide investment advisory services after both his IA registration and NISM certification had lapsed.

Key Points

  • Mr. Chenthil R Iyer’s investment adviser registration (INA000008905) expired in November 2022 due to non-payment of renewal fees.
  • His NISM certificate expired on April 01, 2022 and was not renewed.
  • Despite both lapses, the Noticee continued to engage in investment advisory activities and collect fees from clients.
  • Summary proceedings under SEBI (Intermediaries) Regulations, 2008 were initiated for cancellation of registration.
  • Show Cause Notice (Ref. No. DIS/4074/2026) was issued on January 29, 2026 under Section 15-I of the SEBI Act.
  • The Adjudicating Officer was appointed on January 23, 2026 to inquire and adjudge penalties under Section 15EB of the SEBI Act.
  • SEBI sought details of fees collected since April 2022 via emails on October 08, 2025 and November 11, 2025; the Noticee responded with CA certificates dated August 28, 2025 and December 01, 2025.

Regulatory Changes

No new regulatory changes are introduced. This order applies existing provisions of:

  • Section 15-I and Section 15EB of the Securities and Exchange Board of India Act, 1992
  • Rule 3 and Rule 4 of SEBI (Procedure for Holding Inquiry and Imposing Penalties) Rules, 1995
  • Regulations 7(1)(a) and 7(2) of SEBI (Investment Advisers) Regulations, 2013 — requiring investment advisers to hold valid NISM certification at all times.

Compliance Requirements

  • Investment Advisers must ensure their SEBI registration is renewed before expiry; lapsed registration prohibits continuation of advisory activities.
  • Investment Advisers must maintain a valid and current NISM certification as mandated under IA Regulations 7(1)(a) and 7(2).
  • Collecting fees for investment advisory services without valid registration and NISM certification constitutes a violation subject to penalty under Section 15EB of the SEBI Act.
  • Registered Investment Advisers should respond promptly to SEBI information requests regarding certifications and fee collection.

Important Dates

  • April 01, 2022: Noticee’s NISM certificate expired.
  • November 2022: Noticee’s IA registration expired due to non-payment of renewal fees.
  • October 08, 2025: SEBI’s initial email seeking NISM certification details and fee collection data.
  • November 11, 2025: SEBI’s reminder email to the Noticee.
  • August 28, 2025 & December 01, 2025: CA certificates submitted by the Noticee.
  • January 23, 2026: Appointment of Adjudicating Officer.
  • January 29, 2026: Show Cause Notice issued.

Impact Assessment

This is an enforcement action against a single individual investment adviser and has no direct impact on broader markets or listed stocks. The order serves as a compliance precedent and reminder for all SEBI-registered Investment Advisers to maintain valid registration and NISM certifications without interruption. Penalties under Section 15EB of the SEBI Act may be imposed. The case underscores SEBI’s continued scrutiny of unregistered or lapsed intermediaries continuing to operate and collect fees.

Impact Justification

Enforcement action against a single individual investment adviser for operating without valid registration and NISM certification. No systemic market impact; relevant primarily as a compliance precedent for registered investment advisers.