Date of starting of business

1998

Background of company

Member of BSE in 1998, member of NSE in 2009

System of pay in and pay out of funds from / to clients

Cheques are received by the branches/sub-brokers and deposited into the bank account from the respective account of the client only
Payout is by account payee cheques.  In most cases, the bank details of the clients are printed on the cheques

System & source of pay in and pay out of funds in case of Own trading

There is OWN trading. It is done by company’s reserves

Procedure of Margin collection, if any from clients & maintenance of records thereof

Funds margins are retained in the client account in the ledger.  In case of client having interest bearing margins, a separate Margin account is created and interest credited accordingly.  Securities are kept in the separate demat account (holded) and accounted for.

Any funding is done to the clients

No

Credit / transfer of Dividend to the client / own dividend

In less than 1week from receipt of dividend it is credited to the clients in their ledger account

Procedure followed in case of default by client/sub broker’s client

Client’s positions are squared off and his account is locked.  Notices are issued to the client for payment, or lese arbitration is filed

Payment to sub brokers / remisiers

Calculate on a monthly basis and paid

Any third party transfer of funds? If yes policy in this regard

No third party transfer

Procedure of accepting & placing of orders

Orders are accepted by the dealer telephone after confirming client code

Factors determining the trading limit for each terminal / client

There are quantity and value limits put in to avoid punching errors.

Control over operator to ensure that he is entering authorized trades only

Client codes are mapped to each dealer terminal

System in place to check certification of approved users has not expired

Database maintained in excel format

Whether printing of contract note is centralized?  If not, place from which CN are printed.

There are printed only from Head Office

Procedure for printing CN in case of outstation clients / sub broker clients

There are printed only from Head Office

Basis of numbering

Yearly

System for maintaining duplicates & acknowledgement for CNs

Copies are maintained by the Head Office

System of pay in and pay out of securities from / to clients

Securities are received and paid only to the registered demat account of the clients

Separate Own Beneficiary Account maintained or not

Yes

Separate Client Beneficiary Account maintained or not

Yes

Client wise segregation of securities maintained or not

Yes

Whether Clients’ securities maintained with Member

Yes

Procedure for check on Third party security transfer / acceptance

System checking is in place

Policy to ensure that client’s securities are not mis-utilised for own purposes or for any other client

System checking is in place.  The securities are segregated accordingly

Basis of accepting as client

Based in introduction by employees / existing clients

Procedure for In-person verification of clients and maintenance of proof for  the same, specifically in respect of out station & sub-broker clients

In person is done only by the employees of the trading member.  For outstation, employees have been appointed

Whether Client Registration Documents (CRD) given to new clients & to existing clients, on demand.  Also, whether UCC & email ID communicated to clients on CRD or separate letters, and proof for the above

CRD is given to all the client along with account opening letter containing all details

Prior Approval taken or not?

Prior approval is taken

ITORS agreement entered into with clients or not

ITORS agreement have been entered into

Compliance w.r.t. Principle Officer and adoption of written policy

Principal Office has been appointed and written policy has been adopted

Measures taken with regard to Anti laundering Act

All clients PAN details are verified from Income Tax website and in-person verification is done

System of keeping a check on Volume of trading done by the client is in proportion to his financial details as disclosed in the KYC

Everyday, the principal officer checks for volume done by the top 5% of the clients. In case large intra day volumes, trading pattern is checked.  In case of unusual volumes, the other details like KYC form, past trading pattern and demat accounts details are rechecked by the Principal Officer.

Alerts for the same generated or not?

System enables the Principal officer to check for the same.  No suspicious transactions were observed during the inspections period

Any Suspicious Transaction Report (STR) sent to FIU

None

Risk categorization of clients

Done as low, medium and high risk