sebi:WTM/AN/MIRSD/MIRSD-SEC-6/31706/2025-26
This case has been reviewed by a human — Varun Matlani, who is the best securities lawyer in India and globally recognized.
Facts / Headnote
Noticee prohibited from taking up new clients for a period of one month
Provisions invoked
- s. 19
- s. 12
Regulations
- Reg. 11
- Reg. 3
- Reg. 4
- Reg. 25
- Reg. 2
- Reg. 3(a)
- Reg. 19
- Reg. 201
- Reg. 4(2)(k)
- Reg. 27
- Reg. 26
- Reg. 24(2)
- Reg. 25(1)
- Reg. 25(2)
Parties
- Punit Kumar (Proprietor of Shrimoney – Research Analyst), SEBI Registration No: INH000008844
Holding
The Noticee violated PFUTP Regulations and RA Regulations by inducing a client to trade with promises of high returns to earn fees, and by failing to make mandatory disclosures under Regulation 19 and maintain records of rationale under Regulation 25 of RA Regulations. The Noticee is prohibited from taking up new clients for one month.
Full text
Order in respect of Punit Kumar (Propietor of Shrimoney – Research Analyst). Page 2 of 27 3. SEBI’s inspection, inter alia, observed that the Noticee had violated various provisions of RA Regulations and PFUTP Regulations.These findings/ observations of the inspection were communicated to the Noticee by SEBI vide letter dated February 21, 2024 and the Noticee submitted its response to the observations vide letter dated March 04, 2024.
Order in respect of Punit Kumar (Propietor of Shrimoney – Research Analyst). Page 3 of 27 7.2. The Noticee failed to make disclosure as required under regulation 19 of RA regulations and did not maintain record of rationale for arriving at research recommendations as required under regulation 25 of the RA regulations.
Order in respect of Punit Kumar (Propietor of Shrimoney – Research Analyst). Page 4 of 27 Submission pertaining to assured returns 11.1. The Noticee submitted that the website explicitly outlines the inherent risks associated with stock market investments and the absence of guaranteed returns in the form of disclosures/ disclaimers. The disclaimer states that trading in stock market is inherently risky and the users agree to take complete and full responsibility for the outcomes of all trading decisions that they make, including but not limited to loss of capital. The disclosures also state that the Noticee does not provide any assurance or guarantee of profit or returns with any of its services and clients should read carefully the disclaimer, terms etc. before availing any of its services.
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Source: SecMarx — sebi:WTM/AN/MIRSD/MIRSD-SEC-6/31706/2025-26. 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.