Description

SEBI adjudication order against DMI Capital Private Limited (Merchant Banker) for non-compliances observed in Half Yearly Report for the period ending March 2023, resulting in penalty under Section 15HB of the SEBI Act.

Summary

SEBI’s Adjudicating Officer issued Order No. Order/SM/SM/2025-26/32229 against DMI Capital Private Limited (PAN: AAECD6486C; Reg. No. INM000012193), a SEBI-registered Merchant Banker. The proceedings were initiated following an internal SEBI reference citing non-compliances observed during analysis of DMI Capital’s Half Yearly Report (HYR) for the period ending March 2023. The matter was adjudicated under Section 15HB of the SEBI Act, 1992.

Key Points

  • DMI Capital Private Limited is a SEBI-registered Merchant Banker (Reg. No. INM000012193).
  • Adjudication proceedings were initiated based on an internal SEBI reference regarding non-compliances in the Half Yearly Report (HYR) for the period ending March 2023.
  • Alleged violations span multiple SEBI circulars and regulations including SEBI Circulars dated January 10, 2012, November 23, 2021, and Master Circular dated September 26, 2023, all read with Section 11(1) of the SEBI Act.
  • Specific regulatory violations alleged include Regulations 9A(1)(f), 9A(1)(e), and 28A(1) of SEBI (Merchant Bankers) Regulations, 1992.
  • Regulation 9A(1)(f) violation also invoked in conjunction with SEBI Circular SEBI/HO/MIRSD/MIRSD1/CIR/P/2017/38 dated May 2, 2017.
  • Shri. Amar Navlani was originally appointed as AO on August 19, 2024; the undersigned was subsequently appointed on September 11, 2025 following transfer.
  • Show Cause Notice No. SEBI/HO/EAD/EAD5/P/OW/2024/29160/1 was issued on September 11, 2024.

Regulatory Changes

No new regulatory changes are introduced by this order. The order applies existing provisions of the SEBI Act, 1992 and SEBI (Merchant Bankers) Regulations, 1992 to the facts of the case.

Compliance Requirements

  • Merchant Bankers must ensure timely and accurate submission of Half Yearly Reports (HYR) in compliance with applicable SEBI circulars.
  • Compliance with Regulations 9A(1)(e), 9A(1)(f), and 28A(1) of SEBI (Merchant Bankers) Regulations, 1992 is mandatory.
  • Merchant Bankers must adhere to SEBI circulars on internal controls, net worth maintenance, and reporting obligations as referenced in the SCN.

Important Dates

  • March 2023: Period covered by the Half Yearly Report (HYR) in which non-compliances were observed.
  • August 19, 2024: Original appointment of Adjudicating Officer (Shri. Amar Navlani).
  • September 11, 2024: Show Cause Notice issued to DMI Capital Private Limited.
  • September 11, 2025: Current Adjudicating Officer appointed following transfer of erstwhile AO.

Impact Assessment

This order is limited in market impact as it pertains to internal compliance failures of a single merchant banker entity. However, it reinforces SEBI’s scrutiny of merchant banker HYR submissions and signals ongoing enforcement action for non-compliance with reporting and regulatory obligations. Other merchant bankers should review their own HYR filings and adherence to Regulations 9A and 28A to avoid similar proceedings.

Impact Justification

Order concerns a single merchant banker's internal compliance failures related to half-yearly reporting; no broader market or investor impact identified.