sebi:QJA/MN/MIRSD/MIRSD-SEC-2/31552/2025-26

SEBI · SEBI · 2024-05-21 · N Murugan, Quasi-Judicial Authority, Securities and Exchange Board of India

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Facts / Headnote

Directions issued including refund of fees to clients, public notice, and filing of completion report

Provisions invoked

• s. 11(4)
• s. 15
• s. 12(1)
• s. 12
• s. 15J
• s. 15E

Regulations

• Reg. 6
• Reg. 13
• Reg. 9
• Reg. 19
• Reg. 201
• Reg. 25(3)
• Reg. 13(i)
• Reg. 26A
• Reg. 6(x)

Parties

• Priyanka Yadav - Proprietor of Trade Money Research

Holding

The Noticee was found to have violated Section 12 of the SEBI Act and Regulations 6(vii), 6(x), 13, 19, and 25(3) of the RA Regulations by allowing her debarred husband Sandeep Yadav to operate the RA business under her registration and by failing to conduct annual audit; however, allegations under Regulation 13(ii) (address change) and Regulation 26A/Point 4.2 (grievance mechanism) were not substantiated.

Full text

Order in the matter of Priyanka Yadav - Proprietor of Trade Money Research Page 2 of 27 market. 2.2. Regulation 6(vii) and 6(x) read with Regulation 13(i) of RA Regulations for having association with Sandeep Yadav in contravention of the conditions for grant of registration and for not complying with the fit and proper criteria. 2.3. Regulation 13(ii) of RA Regulations for obtaining registration for RA activities by stating Nagpur address while carrying out actual activities from Indore with no intimation to SEBI/ Research Analyst Administration and Supervisory Body (RAASB). 2.4. Regulation 19 of the RA Regulations for not communicating to its clients that the operations of the entity are being run by a person debarred by SEBI. 2.5. Regulation 25(3) of RA Regulations for failing to conduct annual audit from the member of ICAI / ICSI. 2.6. Point No. 4.2 of SEBI Master Circular Ref. No. SEBI/HO/MIRSD/MIRSD-PoD- 1/P/CIR/2024/49 dated May 21, 2024, read with Regulation 26A of RA Regulations for failing to comply with requirements relating to investor grievance mechanism and updating the same on the website.

Order in the matter of Priyanka Yadav - Proprietor of Trade Money Research Page 3 of 27 June 27, 2025, vide hearing notice dated June 16, 2025. Since, the Noticee didn’t appear for the said hearing, another opportunity of hearing was provided on July 10, 2025, vide hearing notice dated July 02, 2025. AR of the Noticee appeared in the said hearing and reiterated the submissions made vide reply dated June 07, 2025. The AR of the Noticee also submitted that he will produce signed Research Reports sent to the clients along with proof of communication of the same. However, the same is not submitted till date.

Order in the matter of Priyanka Yadav - Proprietor of Trade Money Research Page 4 of 27 day-today basis. e) The Noticee categorically declares that Sandeep Yadav had no involvement whatsoever in the business operations, apart from assisting in documentations and lease formalities. f) On the date of SEBI’s visit at Noticee’s Indore office, neither the Noticee nor Sandeep Yadav were present at the office premises. Sandeep Yadav was called by the BSE officer on the day of the inspection and was asked to reach the office of Trade Money Research. Upon reaching, there was a power cut at the office premises, following which the SEBI team had taken him to the SEBI Indore Local Office. g) The email communication mentioned in Annexure C of the SCN, purportedly written and sent by Sandeep Yadav on 08th October 2024, was not authored or sent by him voluntarily. The SEBI officer asked from Sandeep Yadav for the email credentials of Trade Money Research belonging to the Noticee who then logged into the email account of the Noticee without her prior consent and sent the email to themselves. The email’s content, vocabulary & professionalism reflects a professional tone that the Noticee or Sandeep Yadav does not possess or use. The Noticee requests SEBI to verify the IP address and geolocation from which the email in Annexure C of the SCN was sent. h) The compliance audit of F.Y. 2023-24 was under the process at the time of inspection and hence the report could not be submitted at the time of

Source: SecMarx — sebi:QJA/MN/MIRSD/MIRSD-SEC-2/31552/2025-26. 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.