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Master Circular for Investment Advisers

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..... to such rescission, shall be deemed to have been done or taken under the corresponding provisions of this Master Circular; b) Any application made to the Board under the rescinded circulars, prior to such rescission, and pending before it shall be deemed to have been made under the corresponding provisions of this Master Circular; c) The previous operation of the rescinded circulars or anything duly done or suffered thereunder, any right, privilege, obligation or liability acquired, accrued or incurred under the rescinded circulars, any penalty, incurred in respect of any violation committed against the rescinded circulars, or any investigation, legal proceeding or remedy in respect of any such right, privilege, obligation, liability, penalty as aforesaid, shall remain unaffected as if the rescinded circulars have never been rescinded. 5. This circular is issued in exercise of the powers conferred under Section 11(1) of the Securities and Exchange Board of India Act, 1992 to protect the interests of investors in securities and to promote the development of, and to regulate the securities market. 6. This circular is available on SEBI website at www.sebi.gov.in . .....

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..... tity i.e. earning individual client in the family. The client shall provide an annual declaration or periodic updation as the case maybe in respect of such dependent family members. (h) IA shall, wherever available, advise direct plans (non-commission based) of products only. (i) The IAs shall maintain on record an annual certificate from an auditor (in case of individual IA) and its statutory auditor (in case of a non-individual IA) confirming compliance with the client level segregation requirements as specified in Regulation 22 of the IA Regulations. Such annual certificate shall be obtained within 6 months of the end of the financial year and form part of compliance audit, in terms of Regulation 19(3) of the IA Regulations. (ii) Agreement between IA and the client (a) Regulation 19(1)(d) of the IA Regulations provides that IA shall enter into an investment advisory agreement with its clients. The said agreement shall mandatorily cover the terms and conditions provided in Annexure A. (b) IA can include additional terms and conditions in the agreement without diluting the provisions of the IA Regulations and amendments thereto as well as circulars issued thereunder .....

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..... ll not be required to comply with the qualification and experience requirements specified under Regulation 7(1)(a) and 7(1)(b) of the IA Regulations. However, such IAs shall hold National Institute of Securities Market (NISM) accredited certifications and comply with other conditions as specified under Regulation 7(2) of the IA Regulations at all times. (v) Registration as Non Individual Investment Advisor a. As per Regulation 13(e) of the IA Regulations, an individual IA shall apply for registration as non-individual investment adviser on or before reaching 150 clients. b. Such application for registration shall be made in FORM-A as per the IA Regulations, along with the requisite fee and same shall be assessed in accordance with the provisions of the IA Regulations and amendments thereto as well as circulars issued thereunder. c. Once number of clients reaches 150 and till grant of registration as a non-individual IA, Individual IA shall not on-board fresh clients. However, during the period of examination of application by SEBI, individual IA shall continue to service existing clients. In case the aforesaid IA does not get registration as non-individual IA, such IA .....

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..... andate risk profiling and suitability for all categories of clients. b. In order to further enhance the risk profiling and encompass suitable factors in case of non-individual clients, IA shall use the investment policy as approved by board/management team of such non- individual clients for risk profiling and suitability analysis. c. The discretion to share the investment policy/relevant excerpts of the policy shall lie with the non-individual client. However, IA shall have discretion not to onboard non-individual clients if they are unable to do risk profiling of the non-individual client in the absence of investment policy. (ix) Display of details on website and in other communication channels In order to protect the interest of investors and bring more transparency in the functioning of the IAs, the IAs shall display the following information prominently on its website, mobile app, printed or electronic materials, know your client forms, client agreements and other correspondences with the clients: Complete name of Investment Adviser as registered with SEBI, Type of Registration-Individual, Non-Individual, Registration number, validity of registrat .....

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..... bove and made available on monthly basis (within 7 days of end of the previous month) in a format as per Annexure C6: III. ADMINISTRATION AND SUPERVISION OF INVESTMENT ADVISERS 3. Administration and Supervision of Investment Advisers7 3.1 SEBI, vide Circular SEBI/HO/MRD/DSA/CIR/P/2016/113 dated October 19, 2016, allowed registered IAs to use infrastructure of the stock exchanges to purchase and redeem mutual fund units directly from Asset Management Companies on behalf of their clients. 3.2 As per Regulation 14 of the IA Regulations, SEBI can recognize any body/body corporate for the purpose of regulating IAs. It further provides that SEBI may, at the time of recognition of such body or body corporate, delegate administration and supervision of IAs to such body or body corporate on such terms and conditions as may be specified. 3.3 Further, the second proviso to Regulation 38 (2) of the Securities Contracts (Regulation) (Stock Exchanges and Clearing Corporations) Regulations, 2018 states, inter alia, that a recognized stock exchange may engage in activities, whether involving deployment of funds or otherwise that are unrelated or not incidental to its activity a .....

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..... ia (Investment Advisers) Regulations, 2013 8 4.1 As per Regulation 14 of the IA Regulations, SEBI may, inter-alia, recognize any body or body corporate for the purpose of regulating the IAs and delegate administration and supervision of the IAs on such terms and conditions as may be specified. Accordingly, an entity granted recognition under the aforesaid Regulation shall be designated as Investment Adviser Administration and Supervisory Body ( IAASB ) and shall be entrusted with the administration and supervision of IAs. 4.2 In this regard, BSE Administration Supervision Limited (BASL), a wholly owned subsidiary of BSE Limited, has been granted recognition as IAASB for a period of three years from June 01, 2021. The details may be perused in the Press Release issued by SEBI on June 14, 2021 and available at https://www.sebi.gov.in/media/press-releases/jun-2021/bse-administration- and-supervision-limited-granted-recognition-for-administration-and- supervision-of-investment-advisers_50540.html, which also provides a link for the Standard Operating Procedure (SOP) and the Frequently Asked Questions (FAQs) issued by BASL. 4.3 IAASB shall inter-alia have following respon .....

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..... ding Software as a Service (SaaS) based solutions 9 5.1 Ministry of Electronics Information Technology, Govt. of India (MoE IT), has informed SEBI that the financial sector institutions are availing or thinking of availing Software as a Service (SaaS) based solution for managing their Governance, Risk Compliance (GRC) functions so as to improve their cyber Security Posture. As observed by MoE IT, though SaaS may provide ease of doing business and quick turnaround, but it may bring significant risk to health of financial sector as many a time risk and compliance data of the institution moves beyond the legal and jurisdictional boundary of India due to nature of shared cloud SaaS, thereby posing risk to the data safety and security. 5.2 In this regard, Indian Computer Emergency Response Team (CERT-in) has issued an advisory for Financial Sector organizations. The advisory has been forwarded to SEBI for bringing the same to the notice of financial sector organization. The advisory can be viewed at Annexure D. 5.3 It is advised to ensure complete protection and seamless control over the critical systems at your organizations by continuous monitoring through direct contr .....

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..... r deals with while availing the services provided by IAs, SEBI has developed an Investor Charter for Investment Advisers. This Charter is a brief document containing details of service provided to investors, their rights, dos and don ts, responsibilities, investor grievance handling mechanism and timelines thereof etc., at one single place, in a lucid language, for ease of reference. 7.2 All registered IAs are advised to bring to the notice of their clients the Investor Charter as provided at Annexure B by prominently displaying on their websites and mobile applications. IAs not having websites/mobile applications shall, as a one-time measure, send Investor Charter to the investors on their registered e-mail address. 7.3 IAs shall disclose the details of investor complaints by 7th of the succeeding month in the revised format as per Annexure C on a monthly basis. IAs not having websites/mobile applications shall send status of Investor Complaints to the investors on their registered email on a monthly basis. 7.4 Further, the IAs are advised to display link/option to lodge complaint with them directly on their websites and mobile apps. Additionally, link to SCORES website/ .....

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..... ecting the same, in order to enable them to take informed decision regarding their continuance or otherwise with the new management; and iii. the fit and proper person criteria as specified in Schedule II of Securities and Exchange Board of India (Intermediaries) Regulations, 2008 are complied with. h. In case the incumbent is a registered stock broker, clearing member, depository participant, in addition to the above, it shall obtain approval /NOC from all the stock exchanges/clearing corporations/depositories, where the incumbent is a member/depository participant and submit self-attested copy of the same to SEBI. iii. The prior approval granted by SEBI shall be valid for a period of six months from the date of such approval within which the applicant shall file application for fresh registration pursuant to change in control. 8.3. To streamline the process of providing approval to the proposed change in control of an IA in matters which involve scheme(s) of arrangement which needs sanction of the National Company Law Tribunal ( NCLT ) in terms of the provisions of the Companies Act, 2013, the following has been decided: i. The application seeking approval for th .....

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..... guous and concise language. iii. Standard warning in legible fonts (minimum 10 font size) which states Investment in securities market are subject to market risks. Read all the related documents carefully before investing . No addition or deletion of words shall be made to/from the standard warning. iv. In audio-visual media based advertisements, the standard warning in visual media based advertisement and accompanying voice over reiteration shall be audible in a clear and understandable manner. For example, in standard warning both the visual and the voice over reiteration containing 20 words running for at least 10 seconds may be considered as clear and understandable. v. Whenever the advertisement is being issued in a language other than English, it will be ensured that the standard warning is accurately translated in the language of the advertisement. vi. In case the mode of advertisement is SMS/Message/Pop-up, social media etc. and the details such as full name, logo/brand name, full registered office address, SEBI registration number, membership number of a SEBI recognized supervisory body and standard disclaimer are not mentioned, then official website hyperl .....

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..... terms such as Best , No. 1 , Top Adviser, Leading , One of the best amongst market leaders , etc. so as to provide any endorsement of quality or standing of the IA. However, factual details of awards received by the IA from independent organizations may be included. xiv. Advertisements shall not include SEBI Logo. d. Other compliances/requirements: i. Prior approval for the advertisement/material shall be obtained from SEBI recognized supervisory body (BSE Administration Supervision Ltd. (BASL)) before issue. ii. In the event of suspension of any IA by SEBI and/or by SEBI recognized supervisory body, the IA so suspended shall not issue any advertisement either singly or jointly with any other IA, during the period of suspension. iii. The IA/RA shall not engage in games, leagues, schemes, competitions etc. which may involve distribution of prize monies, medals, gifts, etc. iv. These norms shall be applicable to any other investment/research/consultancy agency associated with the IA concerned and issuing advertisement wherein the IA has been named in the advertisement. v. Copy of the advertisement shall be retained by IA for a period of five years in .....

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..... , any trade or any other sources without verification. c. Access to Blogs/ Chat forums/Messenger sites etc. should either be restricted under supervision or access should not be allowed. d. Logs for any usage of such Blogs/Chat forums/Messenger sites (called by any nomenclature) shall be treated as records and the same should be maintained as specified by the IA Regulations. e. Employees should be directed that any market related news received by them either in their official mail/personal mail/blog or in any other manner, should be forwarded only after the same has been seen and approved by the IA s Compliance Officer. If an employee fails to do so, he/she shall be deemed to have violated the various provisions contained in SEBI Act/Rules/Regulations etc. and shall be liable for action. The Compliance Officer shall also be held liable for breach of duty in this regard16. 12. Guidelines on Outsourcing of Activities by Intermediaries 17 12.1. SEBI Regulations for various intermediaries require that they shall render at all times high standards of service and exercise due diligence and ensure proper care in their operations. 12.2. It has been observed that often .....

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..... issued from time to time by SEBI. On the lines of Principle 8 of the International Organisation of Securities Commissions (IOSCO) Objectives and Principles of Securities Regulations, it has been decided to put in place comprehensive guidelines to collectively cover such intermediaries, for elimination of their conflict of interest, as detailed hereunder. 14.2. Intermediaries shall adhere to these guidelines for avoiding or dealing with or managing conflict of interest. They shall be responsible for educating their associated persons for compliance of these guidelines. 14.3. For the purpose of these guidelines associated persons shall have the same meaning as defined in Securities and Exchange Board of India (Certification of Associated Persons in the Securities Markets) Regulations, 2007. 14.4. Intermediaries and their associated persons shall, a. lay down, with active involvement of senior management, policies and internal procedures to identify and avoid or to deal or manage actual or potential conflict of interest, develop an internal code of conduct governing operations and formulate standards of appropriate conduct in the performance of their activities, and ens .....

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..... sources in Indian securities markets pursuant to regulatory mandates for reporting and disclosure in public domain are concerned, such data should be made available to users, free of charge both for viewing the data as also for download in the format as specified by regulatory mandate for reporting, as well as their usage for the value addition purposes. 15.2. Further, apart from the data made available free of cost, data which is chargeable should be appropriately identified as such in public domain. 16. Reporting Requirements under Foreign Account Tax Compliance Act 21 16.1. India joined the Multilateral Competent Authority Agreement (MCAA) on Automatic Exchange of Financial Account Information on June 03, 2015. In terms of the MCAA, all countries which are signatory to MCAA, are obliged to exchange a wide range of financial information after collecting the same from financial institutions in their country / jurisdiction. 16.2. On July 09, 2015, the Governments of India and United States of America (USA) signed an agreement to improve international tax compliance and to implement the Foreign Account Tax Compliance Act (FATCA) in India. The USA enacted FATCA i .....

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..... by IAs on their website/ mobile application by 07 th of the succeeding month Formats for investors complaints data to be disclosed monthly by IAs on their website/mobile application: Data for the month ending - Sr. No. Received from Pending at the end of last month Received Resolved * Total Pending # Pending complaints 3months Average Resolution time^ (in days) 1 Directly from Investors 2 SEBI (SCORES) 3 .....

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..... of annual disposal of complaints Sr. No. Year Carried forward from previous year Received Resolved Pending 1 2018-19 2 2019-20 3 2020-21 4 20XX-XX Grand Total * Inclu .....

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..... he Investment Adviser to ask questions and interact with person(s) associated with the investment advice . b) Declaration from the Investment Adviser that: Investment Adviser shall neither render any investment advice nor charge any fee until the client has signed this agreement. Investment Adviser shall not manage funds and securities on behalf of the client and that it shall only receive such sums of monies from the client as are necessary to discharge the client s liability towards fees owed to the Investment Adviser. Investment Adviser shall not, in the course of performing its services to the client, hold out any investment advice implying any assured returns or minimum returns or target return or percentage accuracy or service provision till achievement of target returns or any other nomenclature that gives the impression to the client that the investment advice is risk-free and/or not susceptible to market risks and or that it can generate returns with any level of assurance. c) Fees specified under Investment Adviser Regulations and relevant circulars issued thereunder. (to be specifically mentioned here) d) Fees charged to the cl .....

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..... d as applicable on the investment adviser s fee. 6. Risk Factors: A detailed statement of risks associated with each type of investment covering the standard risks associated with each type of investment in securities and investment products. 7. Validity of advisory services: Minimum period if any, and provision for renewal, if any, along with terms and conditions for such renewal. 8. Amendments The agreement may be amended by mutual written consent of the parties. 9. Termination This Agreement may be terminated under the following circumstances, namely- a) Voluntary/ mandatory termination by the Investment Adviser. b) Voluntary/ mandatory termination by the client. c) Suspension/ Cancellation of registration of Investment Adviser by SEBI. d) Any other action taken by other regulatory body/ Government authority. In case of a voluntary termination of the agreement, the client would be required to give a 30 days prior written notice while the Investment Adviser would be required to give a 30 days prior written notice. In case of suspension of the certificate of registration of the IA, the client may be provided with the .....

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..... No conflict of interest: The Investment Adviser to clearly declare that it will disclose all conflicts of interest as and when they arise and not derive any direct or indirect benefit out of the client s securities/investment products. 16. Maintenance of accounts and confidentiality: Investment Adviser shall be responsible for maintenance of client accounts and data as mandated under the Securities and Exchange Board of India (Investment Advisers) Regulations, 2013. 17. Terms of fees and billing: (a) Provide specific details on the following: i. The quantum and manner of payment of fees for investment advice rendered. ii. Fee modalities and periodicity, by attaching a detailed fee schedule to the agreement; iii. Illustration(s) on how the fee will be determined; iv. whether payment to be made in advance; v. type of documents evidencing receipt of payment of fee; vi. Periodicity of billing with clear date and service period (b) The payment of fees shall be through a mode which shows traceability of funds. Such modes may include account payee crossed cheque/ Demand Drafts or by way of direct credit to the bank accounts thr .....

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..... Board of India (Investment Advisers) Regulations, 2013. 23. Adherence to grievance redressal timelines: Investment Adviser shall be responsible to resolve the grievances within the timelines specified under SEBI circulars. 24. Severability : If any provision of this Agreement shall be held or made invalid by a court decision, statute, rule or otherwise, the remainder of this Agreement shall not be affected thereby. 25. Force Majeure: The Investment Adviser shall not be liable for delays or errors occurring by reason of circumstances beyond its control, including but not limited to acts of civil or military authority, national emergencies, work stoppages, fire, flood, catastrophe, acts of God, insurrection, war, riot, or failure of communication or power supply. In the event of equipment breakdowns beyond its control, the Advisor shall take reasonable steps to minimize service interruptions but shall have no liability with respect thereto. 26. Miscellaneous : Each party agrees to perform such further actions and execute such further agreements as are necessary to effectuate the purposes hereof. ANNEXURE B INVESTOR CHARTER IN RESP .....

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..... lized web based complaints redressal system. SEBI takes up the complaints registered via SCORES with the concerned intermediary for timely redressal. SCORES facilitates tracking the status of the complaint. 3. With regard to physical complaints, investors may send their complaints to: Office of Investor Assistance and Education, Securities and Exchange Board of India, SEBI Bhavan, Plot No. C4-A, G Block, Bandra-Kurla Complex, Bandra (E), Mumbai - 400 051. E. Expectations from the investors (Responsibilities of investors) Do s i. Always deal with SEBI registered Investment Advisers. ii. Ensure that the Investment Adviser has a valid registration certificate. iii. Check for SEBI registration number. Please refer to the list of all SEBI registered Investment Advisers which is available on SEBI website in the following link: https://www.sebi.gov.in/sebiweb/other/OtherAction.do?doRecognisedFpi=yes intm Id=13) iv. Pay only advisory fees to your Investment Adviser. Make payments of advisory fees through banking channels only and maintain duly signed receipts mentioning the details of your payments. v. Always ask for your risk p .....

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..... Total Pending # Pending complaints 3months Average Resolution time^ (in days) 1 Directly from Investors 2 SEBI (SCORES ) 3 Other Sources (if any) Grand Total * Inclusive of complaints of previous months resolved in the current mon .....

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..... 3 2020-21 4 20XX-XX Grand Total * Inclusive of complaints of previous months resolved in the current month. # Inclusive of complaints pending as on the last day of the month ANNEXURE D ADVISORY FOR FINANCIAL SECTOR ORGANIZATIONS SOFTWARE AS A SERVICE (SaaS) BASED SOLUTION TLP:AMBER CERT-Fin Advisory- 201155100308 Advisory for Financial Sector Organisations- RBI and SEBI Overview It has been learnt that some of the financial sector institutions are availing or thinking of availing S .....

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..... tomers who need to know the information to protect themselves or prevent further harm. Sources are at liberty to specify additional intended limits of the sharing: these must be adhered to.) ANNEXURE E DECLARATION CUM UNDERTAKING FOR SEEKING PRIOR APPROVAL FOR CHANGE IN CONTROL We M/s. ( Name of the intermediary/the acquirer/person who shall have the control ), hereby declare and undertake the following with respect to the application for prior approval for change in control of (name of the intermediary along with the SEBI registration no.): 1. The applicant/intermediary (Name) and its principal officer, the directors or managing partners, the compliance officer and the key management persons and the promoters or persons holding controlling interest or persons exercising control over the applicant, directly or indirectly (in case of an unlisted applicant or intermediary, any person holding twenty percent or more voting rights, irrespective of whether they hold controlling interest or exercise control, shall be required to fulfill the fit and proper person criteria) are fit and proper person in terms of Schedule .....

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..... The said information is true to our knowledge. (stamped and signed by the Authorised Signatories) ANNEXURE F PRINCIPLES FOR OUTSOURCING FOR INTERMEDIARIES 1. An intermediary seeking to outsource activities shall have in place a comprehensive policy to guide the assessment of whether and how those activities can be appropriately outsourced. The Board / partners (as the case may be) {hereinafter referred to as the the Board } of the intermediary shall have the responsibility for the outsourcing policy and related overall responsibility for activities undertaken under that policy. 1.1. The policy shall cover activities or the nature of activities that can be outsourced, the authorities who can approve outsourcing of such activities, and the selection of third party to whom it can be outsourced. For example, an activity shall not be outsourced if it would impair the supervisory authority s right to assess, or its ability to supervise the business of the intermediary. The policy shall be based on an evaluation of risk concentrations, limits on the acceptable overall level of outsourced activities, risks arisi .....

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..... nt, as and when needed. Such records shall be regularly updated and may also form part of the corporate governance review by the management of the intermediary. 2.4. Regular reviews by internal or external auditors of the outsourcing policies, risk management system and requirements of the regulator shall be mandated by the Board wherever felt necessary. The intermediary shall review the financial and operational capabilities of the third party in order to assess its ability to continue to meet its outsourcing obligations. 3. The intermediary shall ensure that outsourcing arrangements neither diminish its ability to fulfill its obligations to customers and regulators, nor impede effective supervision by the regulators. 3.1. The intermediary shall be fully liable and accountable for the activities that are being outsourced to the same extent as if the service were provided in-house. 3.2. Outsourcing arrangements shall not affect the rights of an investor or client against the intermediary in any manner. The intermediary shall be liable to the investors for the loss incurred by them due to the failure of the third party and also be responsible for redressal .....

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..... e shall be taken to ensure that the outsourcing contract: 5.2.1. clearly defines what activities are going to be outsourced, including appropriate service and performance levels; 5.2.2. provides for mutual rights, obligations and responsibilities of the intermediary and the third party, including indemnity by the parties; 5.2.3. provides for the liability of the third party to the intermediary for unsatisfactory performance/other breach of the contract 5.2.4. provides for the continuous monitoring and assessment by the intermediary of the third party so that any necessary corrective measures can be taken up immediately, i.e., the contract shall enable the intermediary to retain an appropriate level of control over the outsourcing and the right to intervene with appropriate measures to meet legal and regulatory obligations; 5.2.5. includes, where necessary, conditions of sub-contracting by the third- party, i.e. the contract shall enable intermediary to maintain a similar control over the risks when a third party outsources to further third parties as in the original direct outsourcing; 5.2.6. has unambiguous confidentiality clauses to ensure prot .....

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..... ry to fulfill its obligations to other market participants/clients/regulators and could undermine the privacy interests of its customers, harm the intermediary s reputation, and may ultimately impact on its overall operational risk profile. Intermediaries shall, therefore, seek to ensure that third party maintains appropriate IT security and robust disaster recovery capabilities. 6.4. Periodic tests of the critical security procedures and systems and review of the backup facilities shall be undertaken by the intermediary to confirm the adequacy of the third party s systems. 7. The intermediary shall take appropriate steps to require that third parties protect confidential information of both the intermediary and its customers from intentional or inadvertent disclosure to unauthorised persons. 7.1. An intermediary that engages in outsourcing is expected to take appropriate steps to protect its proprietary and confidential customer information and ensure that it is not misused or misappropriated. 7.2. The intermediary shall prevail upon the third party to ensure that the employees of the third party have limited access to the data handled and only on a nee .....

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..... g Standards (CRS)-Guidance Note 8 SEBI/HO/MRD/DSA/CIR/P /2016/113 19-Oct-16 Facilitating transaction in Mutual Fund schemes through the Stock Exchange Infrastructure 9 SEBI/HO/IMD/DF1/CIR/P/ 2019/169 27-Dec-19 Measures to strengthen the conduct of Investment Advisers (IA) 10 SEBI/HO/IMD/DF1/CIR/P/ 2020/04 09-Jan-20 Operating Guidelines for Investment Advisers in International Financial Services Centre 11 SEBI/HO/IMD/DF1/CIR/P/ 2020/31 28-Feb-20 Operating Guidelines for Investment Advisers in International Financial Services Centre (IFSC) Clarifications 12 SEBI/HO/IMD/DF1/CIR/P/ 2020/148 06-Aug-20 Administration and Supervision of Investment Advisers 13 SEBI/HO/IMD/DF1/CIR/P/ 2020/182 23-Sep-20 Guidelines for Investment Advisers 14 SEBI/HO/IMD .....

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..... HO/IMD/DF1/CIR/P/2020/182 dated September 23, 2020 2 Group and family of an individual investment adviser shall be as per Regulation 22(3)(iii) and Regulation 2(gc) respectively of the IA Regulations 3 Family of client and AUA shall be as per Regulation 2(gb) and Regulation 2(aa) respectively of the IA Regulations 4 Reference: Circular No. SEBI/HO/IMD/IMD-I/DOF1/P/CIR/2021/694 dated December 21, 2021 5 Reference: Circular No. SEBI/HO/IMD/DF1/CIR/P/2019/169 dated December 27, 2019 6 Reference: Circular No. SEBI/HO/IMD/IMD-II CIS/P/CIR/2021/0686 dated December 13, 2021 7 Reference: Circular No. SEBI/HO/IMD/DF1/CIR/P/2020/148 dated August 06, 2020 8 Reference: Circular No. SEBI/HO/IMD/IMD-I/DOF1/P/CIR/2021/579 dated June 18, 2021 9 Reference: Circular No. SEBI/HO/MIRSD2/DOR/CIR/P/2020/221 dated November 03, 2020. SEBI 10 Reference: Circular No.CIR/MIRSD/3/2014 dated August 28, 2014 and SEBI/HO/OIAE/IGRD/P/CIR/2022/0150 dated November 07, 2022 11 Reference: Circular No. SEBI/HO/IMD/IMD-II CIS/P/CIR/2021/0686 dated December 13, 2021 12 Reference: Circular No. SEBI/HO/MIRSD/ MIRSD-PoD-2/P/CIR/2022/163 dated November 28, 20 .....

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