sebi:Order/GG/VP-AS/2021-22/15774

SEBI · SEBI · 2021-12-01 · Geetha G, Adjudicating Officer

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Provisions invoked

Regulations

Parties

Holding

The Adjudicating Officer considered allegations of procedural lapses by HDFC Ltd as in-house RTA under LODR and RTI/STA Regulations across multiple allegations (transfer processing, objection memos, PAN verification, signature mismatch procedures, dematerialization, dividend payment) and found substantial compliance in several instances, declining to treat certain deviations as serious violations warranting penalty.

Full text

Adjudication Order in the matter of HDFC Ltd (In-house RTA) Page 2 of 33 Based on the observations made by the Inspection Team (hereinafter referred to as “Inspection”), it was alleged that Noticee violated certain provisions of SEBI (Listing Obligations and Disclosure Requirements) Regulations, 2015 (hereinafter referred to as “LODR Regulations”) and/or certain provisions of SEBI (Registrars to an Issue and Share Transfer Agents) Regulations, 1993 (hereinafter referred to as “RTI/STA Regulations”) and certain related circulars made thereunder.

Adjudication Order in the matter of HDFC Ltd (In-house RTA) Page 3 of 33 and considered along with the reply of the Noticee, in the latter part of this order; after narration of the preliminary dates and events.

Adjudication Order in the matter of HDFC Ltd (In-house RTA) Page 4 of 33 (2004) 51 SCL 307 (Bom), Order of the Whole Time Member of SEBI in the matter of Link Intime India Pvt Ltd and Adjudication Order of SEBI in the matter of American Century Investments, and contended that since the Noticee is in substantial compliance with the relevant provisions, the violations, if any, are procedural, venial, technical and not deliberate, so that they do not warrant imposition of monetary penalty. Further, the Noticee has made further contentions on merits with respect to each of the allegations levelled in the SCN.

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Source: SecMarx — sebi:Order/GG/VP-AS/2021-22/15774. 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.