Description

SEBI issues Completion Order for Recovery Certificate No. 8738 of 2025, confirming full recovery of dues from 3M Team Research Private Limited and its principals for operating an unregistered Portfolio Management Service.

Summary

SEBI has issued a Completion Order for Recovery Certificate No. 8738 of 2025 against 3M Team Research Private Limited, Rakesh Sethi, and Pramod Jain in the matter of operating an unregistered Portfolio Management Service (PMS). The completion order signifies that the full recovery amount specified under the Recovery Certificate has been successfully realised by SEBI.

Key Points

  • Recovery Certificate No. 8738 of 2025 has been fully executed and the recovery proceedings are now complete
  • The three respondents — 3M Team Research Private Limited, Rakesh Sethi (individual), and Pramod Jain (individual) — were found to have operated an unregistered Portfolio Management Service
  • Operating a PMS without SEBI registration violates the SEBI (Portfolio Managers) Regulations and the SEBI Act, 1992
  • This Completion Order is issued alongside a separate Release Order (for the same RC No. 8738 of 2025) which releases any attachments or liens placed on assets during the recovery process
  • The order is published under SEBI’s enforcement/recovery-proceedings section

Regulatory Changes

No new regulatory changes are introduced by this order. It is an enforcement conclusion order under existing SEBI recovery mechanisms, pursuant to Section 28A of the SEBI Act, 1992, which enables SEBI to recover amounts as arrears of land revenue.

Compliance Requirements

  • No new compliance obligations are imposed on the broader market by this order
  • The named parties (3M Team Research Private Limited, Rakesh Sethi, Pramod Jain) have fulfilled their financial obligations under the Recovery Certificate
  • Any person or entity providing Portfolio Management Services must hold a valid SEBI registration under the SEBI (Portfolio Managers) Regulations, 2020

Important Dates

  • Recovery Certificate No. 8738 issued: 2025 (exact date in original order)
  • Completion Order date: April 29, 2026
  • Recovery proceedings concluded: April 2026

Impact Assessment

This order has minimal market-wide impact. It is a case-specific enforcement conclusion affecting only the named parties. The completion of recovery proceedings demonstrates SEBI’s continued enforcement against unregistered intermediaries offering portfolio management services. Investors who may have availed services from 3M Team Research Private Limited should be aware that the firm was not a registered PMS provider. The accompanying Release Order (RC No. 8738 of 2025) indicates that any asset attachments made during the recovery process have now been lifted.

Impact Justification

This is an administrative completion order confirming that recovery proceedings against specific parties have concluded. It has no direct market-wide impact and affects only the named parties. Relevant for compliance tracking of enforcement actions against unregistered intermediaries.