sebi:Order/BM/JR/2024-25/30664

SEBI · SEBI · 2018-03-22 · Barnali Mukherjee, Adjudicating Officer

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Facts / Headnote

Violation established; penalty of Rs.3,00,000 imposed

Provisions invoked

• s. 24
• s. 15A
• s. 15
• s. 15H
• s. 15I
• s. 15J

Regulations

• Reg. 21
• Reg. 21(1)

Parties

• SS Corporate Securities Limited

Holding

The Noticee violated Clause III of SEBI circular dated March 22, 2018 and Regulation 21(1) and 21(4) of the Brokers Regulations r/w Code of Conduct, and is liable to monetary penalty under Sections 15A(a), 15A(c) and 15HB of the SEBI Act aggregating to Rs.3,00,000.

Full text

Adjudication Order in the matter of SS Corporate Securities Limited Page 2 of 21 Sr. No. Alleged Violations (summarized) Regulatory provisions A Call recording/

Adjudication Order in the matter of SS Corporate Securities Limited Page 3 of 21  The Noticee has sufficiently provided its submissions to SEBI by way of its earlier responses dated December 18, 2023 (Original Reply) and January 8, 2024 (Supplementary Reply), which seems to have not been considered by SEBI for the purposes of issuing this SCN, and, which sufficiently provides answers and evidences against the allegations put up by SEBI originally in the notice dated November 24, 2023, carried forward in this SCN, which if would have been

Adjudication Order in the matter of SS Corporate Securities Limited Page 4 of 21 of the stock broker or the APs, giving instructions and evidencing the trade being placed directly under his/her supervision, instruction and presence, clearly and rightly in front of his/her eyes.  There is no need or requirement of evidencing the presence of the client by checking his/her entries in the office of the broker or the APs in a Visitor's register.  Para II, III and Para IV of the 2018 Circular nowhere obliges or even hints that a stock broker needs to maintain a visitor register at its office and use this as evidence to confirm that the client visiting the stock broker office.  The maximum of the allegations put up by SEBI in Annexure 2, Annexure 3 and Annexure 4 of the SCN, are talking about the non-maintenance of the Visitor Register and related issues, which is not required to be maintained by the applicable law.  The Noticee submits that for each of the 16 client trades mentioned in Annexure 3, the Noticee has submitted detailed explanations relating to the gap in understanding from SEBI's side regarding those trades, in its replies dated December 18, 2023 and January 8, 2024.  The Noticee submit that all the investors (Noticee's clients) in question have submitted respective Affidavits that all the orders were placed by them with the Noticee or with APs themselves, personally, while visiting the office of the Noticee. Inspite of clear evidence of all Order Confirmation Sli

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