SEBI compliances & registrations
Registration with SEBI as a research analyst or an investment adviser, and the compliance that follows: what each step involves, and where we come in.
How people usually arrive.
You share stock calls, price targets or a model portfolio, and have been told it needs a SEBI registration.
You want to charge for advice on investments, and are working out which registration that needs and whether you qualify.
You have another profession and want to register part-time.
You are registered, and the half-yearly reports and the yearly compliance audit are due.
Where we come in.
What you can engage us to help with here, how it usually begins, and what is useful to have.
- Whether you need to register, and as what
- We look at what you give clients and how you are paid for it, and tell you whether a registration is needed and which: research analyst, investment adviser or another. We check the qualification, the NISM certification and the fit and proper standing it asks of you and of the people who will deal with clients, and whether a part-time registration fits.
- The application
- We prepare the application and what goes with it for BSE, which checks it and recommends it to SEBI: the proofs, the description of your services, the conflict-of-interest policy, the declarations and, for advisers, the risk-profiling process. We answer the queries that come back until the registration and the enlistment issue.
- Set up to comply from the first client
- We put in place what the regulations expect before any service or fee: the client terms and consent, the fee rules, the records, the disclosures, the website and the Investor Charter, and the grievance process.
- Every half year and every year
- We keep the calendar of the half-yearly reports to BSE, the yearly review of the deposit and the renewal of certifications, and prepare what the yearly compliance audit examines.
It begins with what you do, or plan to do, for clients, how you are or will be paid, and whether you will work alone, through a firm or a company, or alongside another profession.
Useful to have, if you have it
- A description of the services you offer, or plan to
- Degree certificates and any NISM certificates, yours and your team’s
- The firm’s or company’s registration documents, if you will apply through one
- Any correspondence with BSE or SEBI, if an application is under way
Where this needs another specialist
We do not give investment advice or publish research ourselves, and we do not tell you what to buy or sell. Where a registration falls outside what we handle, or the situation needs a specialist, we say so and refer you to someone who does it.
What becomes relevant, and when.
Each consideration at the stage it tends to arrive, explained once. The ones shared with other matters say so.
Before you apply
- Eligibility & certification
Whether a registration is needed turns on what you give clients and whether you are paid or otherwise benefit: stock-specific calls, price targets, model portfolios or research call for research analyst registration, and personalised advice on securities for investment adviser registration. Each asks for a qualification, a current NISM certification for you and for everyone who deals with clients, and a fit and proper standing. A part-time registration exists for people with another profession, with its own conditions and a limit on clients, and certifications are renewed before they lapse.
- Registrations & filings
The registration can be held by an individual, a partnership, an LLP or a company, and the form matters: each carries its own conditions, and a firm or a company keeps its own registrations and filings running alongside the SEBI ones.
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The application
- Application
The application goes first to BSE, which SEBI has recognised to administer and supervise research analysts and investment advisers: it checks the papers and recommends the case to SEBI, which grants the registration. Proofs of identity, qualification and certification go with it, with a description of the services and, for advisers, the process for profiling clients’ risk. Fees are paid to both, and a deposit is kept under lien to BSE before the registration and the enlistment issue.
- GST
The application asks for the GST registration, or a declaration where there is none. Fees for research or advice are a service, so the GST position is settled before the first invoice.
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Once registered
- Ongoing compliance
A registration brings duties from the first client: the prescribed terms and the client’s consent before any service or fee, limits on what individual clients may be charged, records of every recommendation and its reasoning, disclosures of conflicts, a website with the Investor Charter, a grievance process, and BSE’s approval before any advertisement. Reports go to BSE every half year, and a compliance audit each year examines it all; its findings are published and the report goes to clients.
- Books
Fees received, refunds for unexpired periods and the accounts behind them feed the compliance audit, the GST returns and the income-tax return, so they are kept from the first client.
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Every year
Relevant here too. Explained under Once registered.
Relevant here too. Explained under Before you apply.
- Income-tax return
Income from research or advice is reported in the income-tax return of whoever holds the registration, the individual or the firm, from the same books.
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