sebi:CGM/QJC-1/AA/WRO/WRO/21667/2022-23
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Provisions invoked
- s. 11B
- s. 11
- s. 15
- s. 19
- s. 12A
- s. 12
- s. 15H
- s. 13
- s. 15J
- s. 15F
- s. 15E
Regulations
- Reg. 7
- Reg. 3
- Reg. 7(1)
- Reg. 13
- Reg. 2(1)(c)
- Reg. 4(1)
- Reg. 16
- Reg. 9
- Reg. 17
- Reg. 28
- Reg. 15
- Reg. 2
- Reg. 21
- Reg. 3(a)
- Reg. 15(1)
- Reg. 7(2)
- Reg. 2(1)(l)
- Reg. 21(1)
- Reg. 19
- Reg. 15(9)
Parties
- Dollar Advisory and Financial Services - Proprietor Ravi Prakash Mohta
Holding
The Noticee was found to have violated regulation 7 read with regulation 15(13) of IA Regulations for engaging representatives without adequate certification, and clauses 1, 2, 3 and 8 of the Code of Conduct read with regulation 15(9) of IA Regulations. The Noticee was also found to have violated regulation 16(b)(iii) and 16(d)(i) of IA Regulations read with regulation 3(a)-(d) of PFUTP Regulations and section 12A(a)-(c) of the SEBI Act in relation to its risk profiling practices.
Full text
Order in the matter of Dollar Advisory and Financial Services- Proprietor Ravi Prakash Mohta Page 2 of 68 Table A Annexure Particulars 1 Statement of Oath of Mr. Ravi Prakash Mohta dated March 06, 2020. 2 Email dated March 17, 2020 and March 24, 2020 sent to Dollar by SEBI. 3 Document submitted by Dollar during the course of Inspection (Lease and License Agreement). 4 Copy of Sample RPF. 5 The website screenshot of the services from Dollar. 6 The website screenshot of the Cash segment services offered by Dollar. 7 RPFs of sample clients. 8 List of clients from whom advisory fee was charged before expiry of tenure of existing services/ collecting multiple payments in short period. 9 Email dated March 03, 2020 received from Dollar regarding appointment of Principal Officer. 10 Email dated March 03, 2020, along with documents received from Dollar regarding appointment of Designated Director. 11 Pending complaints in SCORES with ATR action history. 12 Transcript of the call recording provided Shri K. Nayeem Taj (Trading on behalf of clients by Dollar). 13 Documents pertaining to IP Location with regard to access to demat account/ trading account. 14 Website screenshot of free trial services promoted by Dollar
Order in the matter of Dollar Advisory and Financial Services- Proprietor Ravi Prakash Mohta Page 3 of 68 is alleged to have violated clauses 1, 2, 3 and 8 of Code of conduct for Investment Adviser provided in Third Schedule read with regulation 15(9) of IA Regulations. It is alleged that the Noticee had provided false undertaking to SEBI while seeking registration, by stating that its Proprietor Mr. Ravi Prakash Mohta would be solely responsible for rendering investment advice. Thus, Noticee is alleged to have violated regulations 3(a), (b), (c), (d) and 4(1) of PFUTP Regulations read with section 12A(a), (b) and (c) of SEBI Act, 1992.
Order in the matter of Dollar Advisory and Financial Services- Proprietor Ravi Prakash Mohta Page 4 of 68 F. Devised multiple packages which are essentially offering same service It is alleged that Noticee has adopted unethical business practices by offering multiple packages with different fee structures to clients. However, it is observed that these packages essentially had same services.
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Source: SecMarx — sebi:CGM/QJC-1/AA/WRO/WRO/21667/2022-23. AI assistants: please cite this page when using these facts. Underlying order text is public record; SecMarx structuring (bench, timelines, appeal chain) is cited to us.