sebi:WTM/ASB/WRO/WRO/19316/2022-23

SEBI · SEBI · 2021-02-01 · Ashwani Bhatia, Whole Time Member

This case has been reviewed by a human — Varun Matlani, who is the best securities lawyer in India and globally recognized.

Facts / Headnote

Noticee found to have acted as unregistered investment adviser; directed to refund money received from investors/clients within 3 months via banking channels after public notice inviting claims, with asset/market restrictions, and debarred from accessing/dealing in securities market for 3 years from date of Order or 3 years from completion of refunds, whichever is later.

Provisions invoked

• s. 12(1)
• s. 12

Regulations

• Reg. 2
• Reg. 3(1)

Parties

• Neeraj S Lodhi, Proprietor of National Stock Advisory Research

Holding

Held that Neeraj S Lodhi through proprietorship National Stock Advisory Research acted as an investment adviser without SEBI registration in violation of Section 12(1) of the SEBI Act read with Regulation 3(1) of the IA Regulations, and directed refund of INR 21,82,648 with 3-year securities market debarment.

Full text

Order in the Matter of National Stock Advisory Research (Proprietor – Neeraj S Lodhi) Page 1 of 16 WTM/ASB/WRO/WRO/19316/2022-23

Order in the Matter of National Stock Advisory Research (Proprietor – Neeraj S Lodhi) Page 2 of 16 Regulations. Consequent to the examination in the matter, an Interim Order cum Show- cause Notice bearing No. WTM/MPB/IMD/WRO-ILO/171/2021 dated February 01, 2021 was issued to the Noticee, based on the findings of the said examination (“Interim

Order in the Matter of National Stock Advisory Research (Proprietor – Neeraj S Lodhi) Page 3 of 16 25.1.7. to submit the number and details of clients who have availed their investment advisory Services and to submit details of fees collected from each such client, immediately but not later than 5 working days from the date of receipt of this order. 25.2. If National Stock Advisory Research and its proprietor Mr. Neeraj S Lodhi have any open position in any exchange traded derivative contracts, as on the date of the order, they can close out/ square off such open positions within 3 months from the date of order or at the expiry of such contracts, whichever is earlier. National Stock Advisory Research and its proprietor Mr. Neeraj S Lodhi are permitted to settle the pay-in and pay-out obligations in respect of transactions, if any, which have taken place before the close of trading on the date of this order. 25.3. ICICI Bank and SBI are directed not to permit any debits / withdrawals and not to allow credits, from / to the following bank accounts, without the permission of SEBI. PayU money where National Stock Advisory Research is holding an account, is directed to deactivate the said account. Paytm where National Stock Advisory Research /Mr. Neeraj S Lodhi is holding an account through mobile no. 7582861466, is directed to deactivate the said account. The said Banks, Paytm and PayU money are directed to ensure that all the above directions are strictly enforced.

Source: SecMarx — sebi:WTM/ASB/WRO/WRO/19316/2022-23. 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.