sebi:QJA/GR/IMD-SEC-5/31387/2025-26
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Facts / Headnote
Held that Noticees carried out unregistered portfolio management in violation of Section 12(1) of SEBI Act, 1992 and Regulation 3 of SEBI (Portfolio Managers) Regulations, 2020
Provisions invoked
- s. 11
- s. 19
- s. 11(1)
- s. 12(1)
- s. 11B
- s. 12A
- s. 15H
- s. 15J
- s. 15F
- s. 28A
Regulations
- Reg. 3
- Reg. 4(1)
- Reg. 2(1)
- Reg. 2
- Reg. 22
- Reg. 23
- Reg. 7(2)
- Reg. 3(1)
- Reg. 22(1)
- Reg. 4(2)(k)
- Reg. 42(1)
- Reg. 202
- Reg. 4(2)(s)
- Reg. 2(1)(o)
- Reg. 3(a)(b)(c)
- Reg. 2(1)(n)
- Reg. 14(1)(a)
- Reg. 42(2)(c)(2)
- Reg. 42(2)(c)(3)
- Reg. 2(o)
Parties
- Bliss Consultants
- Noticee No.1
- Noticee No.2
Holding
Noticees carried out unregistered portfolio management activities for clients trading in NIFTY Options and thereby violated Section 12(1) of the Securities and Exchange Board of India Act, 1992 and Regulation 3 of the SEBI (Portfolio Managers) Regulations, 2020.
Full text
Order in the matter of unregistered portfolio management activities by Bliss Consultants Page 2 of 47 2. In the said complaints, the clients had, inter-alia, alleged that they had invested in Bliss for the purpose of trading in derivatives market. The investments were made based on presentation and assurance provided by Bliss regarding opportunities to invest in derivative market (NIFTY Options) and making potential returns. Also, Bliss was providing returns to the clients on regular basis from trading in NIFTY Options on behalf of the clients. Bliss was charging 30% of the profits made from the trading as fees/commission towards the service provided to the clients. The above fund management activities were conducted by Bliss after entering into agreement with the clients. In this connection, Bliss used to host a website, www.blissconsultant.in, and also a mobile application, D-I-F-M. The complaints were mainly that; Bliss had neither paid any returns nor repaying the amount invested by the clients since from June-2023.
Order in the matter of unregistered portfolio management activities by Bliss Consultants Page 3 of 47 not be issued against them under Section 11(1), 11(4), 11(B)(1) and 11(D) of SEBI Act, 1992 read with provisions of SEBI (Portfolio Managers) Regulations, 2020 and why appropriate penalty should not be imposed upon them under section 11(B)(2) and 11(4A) read with section 15HA and 15HB of SEBI Act, for the alleged violations.
Order in the matter of unregistered portfolio management activities by Bliss Consultants Page 4 of 47 ii. SCN observed that Regulation 22(1) of SEBI (Portfolio Managers) Regulation, 2020 inter alia states that “The portfolio manager shall, before taking up an assignment of management of funds and portfolio on behalf of a client, enter into an agreement in writing with such client that clearly defines the inter se relationship and sets out their mutual rights, liabilities and obligations relating to management of portfolio containing the details as specified in Schedule IV”
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Source: SecMarx — sebi:QJA/GR/IMD-SEC-5/31387/2025-26. 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.