sebi:QJA/KS/ERO/ERO/29552/2023-24
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Facts / Headnote
Findings of violation recorded against the Noticee; penalty determination not included in the provided excerpt
Provisions invoked
- s. 19
- s. 15B
- s. 12
- s. 227
Regulations
- Reg. 13
- Reg. 8
- Reg. 15
- Reg. 14
- Reg. 40
- Reg. 18
- Reg. 23
- Reg. 24
- Reg. 25
- Reg. 27
- Reg. 26(1)
- Reg. 26
- Reg. 9A(1)(b)
- Reg. 40(7)
- Reg. 2
- Reg. 43
Parties
- S. K. Infosolutions Private Limited
Holding
The Noticee, S. K. Infosolutions Private Limited, was found to have violated multiple provisions of the RTA Regulations, LODR Regulations, and SEBI circulars relating to processing of transfer re-lodgements without necessary documents, failure to enter into legally binding agreements with all client companies before rendering services, and other compliance lapses.
Full text
Page 2 of 49 Enquiry proceedings in the matter of S. K. Infosolutions Private Limited 2.3. Sub Clause (a) of Clause 1 “Specific Activities” of Schedule 1 and Draft Agreement in Annexure B of Schedule II in SEBI Circular “Instruction to Registrars to an Issue/ share Transfer Agents” dated October 11, 1994 (hereinafter referred to as “SEBI Circular dated October 11, 1994”) 2.4. Clauses B(1) and B(2) of Schedule VII read with Regulation 40(7) and 61(4) of SEBI (Listing Obligations and Disclosure Requirements) Regulations, 2015 (hereinafter referred to as “LODR Regulations”) 2.5. Clause A(1), C(2)(a)(ii) of Schedule VII read with Regulation 40(7) of the LODR Regulations 2.6. Clauses 2(b) and 2(c) of SEBI Circular SEBI/HO/MIRSD/DOS3/CIR/P/ 2018/139 dated November 06, 2018 (hereinafter referred to as “SEBI Circular dated November 06, 2018”) 2.7. Clause 3, Sub-Clause (2) of Part I (Provisions with regard to Payment of Dividend/ Interest/ Redemption) and Clauses 4, 9, 13, 14 and 15 of Part II (Provisions with regard to Transfer/ Transmission/ Correction of Errors etc.) of Annexure to SEBI Circular SEBI/HO/MIRSD/DOP1/CIR/P/2018/73 dated April 20, 2018 (hereinafter referred to as “SEBI Circular dated April 20, 2018”)
Page 3 of 49 Enquiry proceedings in the matter of S. K. Infosolutions Private Limited made against the Noticee as prescribed under Regulation 26 of Intermediaries Regulations.
Page 4 of 49 Enquiry proceedings in the matter of S. K. Infosolutions Private Limited 5.4. Noticee had processed 11 Transfer Re-lodgement requests during the Inspection Period. Out of the above, Noticee had processed 9 requests without seeking the necessary documents and clarifications, allegedly resulting in violation of provisions of Clause A(1) of Schedule VII read with Regulation 40(7) of the LODR Regulations, Clauses B(1) and B(2) of Schedule VII read with Regulations 40(7) and 61(4) of the LODR Regulations, Clauses 2(b) and 2(c) of SEBI Circular dated November 06, 2018, Clause 4 of Part II (Provisions with regard to Transfer/Transmission/Correction of Errors etc.) of Annexure to SEBI Circular dated April 20, 2018 and Clause 3 and 16 of Schedule III read with Regulation 13 of the RTA Regulations.
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Source: SecMarx — sebi:QJA/KS/ERO/ERO/29552/2023-24. 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.