sebi:Order/BM/DS/2024-25/30584
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Facts / Headnote
The supplied excerpt does not include the final operative disposition or penalty. It records a finding that the Noticee should have reported the change in its research analysts, while the alleged entity-level trading-limit violation was not established because its research activity was found to be segregated; it also records that the identified trade by Rohan Patil contravened the five-day restriction.
Provisions invoked
- s. 15A
- s. 15
- s. 15J
- s. 28A
- s. 15E
Regulations
- Reg. 13
- Reg. 16
- Reg. 16(5)
- Reg. 9
- Reg. 16(2)
- Reg. 21
- Reg. 15(1)
- Reg. 29(2)
- Reg. 21(1)
- Reg. 16(3)
- Reg. 24
- Reg. 19
- Reg. 201
- Reg. 24(1)
- Reg. 16(1)
- Reg. 15(2)
- Reg. 17(2)
- Reg. 20(1)
- Reg. 20(3)
- Reg. 24(2)
Parties
- Bonanza Portfolio Limited
Holding
The excerpt finds that the Noticee was required to inform SEBI of the change in research analysts and did so only after inspection findings were communicated. It also finds that Rohan Patil’s identified trade was within the prohibited five-day period, but that the alleged trading-limit violation by the Noticee itself did not stand established because its research activity was segregated; the final overall disposition is not included.
Full text
Adjudication Order in the matter of Bonanza Portfolio Limited Page 2 of 44 Table 1 Sr. No. Alleged Violations (Summarized) Regulatory Provisions 1 Not using the term ‘Research Analyst’ in correspondences with clients Regulation 13(iii) of RA Regulations, 2014 and clauses 2, 6, 7 and 8 of Code of Conduct as specified in the Third Schedule under Regulation 24(2) of the RA Regulations, 2014 2 Not informing the Board regarding material changes in the information already submitted Regulation 13(ii) and clauses 2, 6, 7 and 8 of Code of Conduct as specified in Third Schedule under Regulation 24(2) of the RA Regulations, 2014 3 Non-Compliance with the limitations on trading by Research Analyst - Rohan Patil and the Entity Regulations 15(1), 16(1), 16(2) and 16(3) read with Regulation 16 (5) and clauses 1, 2, 3, 6 ,7 and 8 of the Code of Conduct as specified in Third Schedule under Regulation 24 (2) of the RA Regulations, 2014 4 Not ensuring independence of Research Activities from its other business activities; non- maintenance of an arms-length relationship and segregation/separation between its research activity and other activities Regulations 15(2), 18(10), 24(1) and clauses 2, 6, 7 and 8 of the Code of Conduct as specified in the Third Schedule under Regulation 24 (2) of the RA Regulations, 2014 5 Non-compliances in respect of Compensation of Research Analysts and Research Analysts under supervision and control of employees of Broking and other services Regulations 17(2), 17(4)
Adjudication Order in the matter of Bonanza Portfolio Limited Page 3 of 44 Sr. No. Alleged Violations (Summarized) Regulatory Provisions content in respect of research reports/ recommendations Third Schedule under Regulation 24(2) of the RA Regulations, 2014 7 Not making required disclosures in Research Reports and Recommendations Regulations 19, 21(1) and clauses 1, 2 3, 6, 7 and 8 of the Code of Conduct as specified in the Third Schedule under Regulation 24(2) of the RA Regulations, 2014 8 Not taking SCORES login and providing false information for the same Regulation 29(2), SEBI Circular no CIR/OIAE/1/2014 dated December 18, 2014 and the clauses 1, 2, 6, 7 and 8 of the Code of Conduct as specified in the Third Schedule under Regulation 24(2) of the RA Regulations, 2014 9 Not abiding by provisions of the Act and Regulations Regulation 13(i) and clauses 2, 6, 7 and 8 of the Code of Conduct as specified in the Third Schedule of Regulation 24(2) of the RA Regulations, 2014
Adjudication Order in the matter of Bonanza Portfolio Limited Page 4 of 44 (Procedure for Holding Inquiry and Imposing Penalties) Rules, 1995 (hereinafter referred to as “SEBI Adjudication Rules”), to inquire into and adjudge under Section 15A(a), 15A(c) and Section 15EB of SEBI Act, 1992, the violations of aforesaid provisions alleged to have been committed by the Noticee.
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Source: SecMarx — sebi:Order/BM/DS/2024-25/30584. 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.