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Advertisement – Prior Approval from RAASB – When and How

A comprehensive guide on when and how to obtain prior approval from RAASB for Research Analyst advertisements.

25 Jul 20264 min read

Research Analysts (RAs) are required to obtain prior approval from RAASB for their advertisements before they are issued. This requirement ensures that advertisements are reviewed for compliance before being published. This article provides a comprehensive technical analysis of the prior approval requirement.

Regulatory Basis

The prior approval requirement is specified in the Advertisement Code circular dated April 5, 2023 (SEBI/HO/MIRSD/MIRSD-PoD-2/P/CIR/2023/51).

The Prior Approval Requirement

What is Required

Prior approval for the advertisement/material shall be obtained from SEBI recognized supervisory body (RAASB) before issue.

Applicability

The requirement applies to:

  • All advertisements
  • All promotional materials
  • All communications that are advertisements
  • Research reports that are considered advertisements

Who Must Obtain Approval

  • All registered RAs
  • Research entities
  • Associated entities issuing advertisements where the RA is named

When to Obtain Approval

Timing

  • Before the advertisement is issued
  • Before the advertisement is published
  • Before the advertisement is distributed

Process

  1. Prepare the advertisement
  2. Submit to RAASB for review
  3. RAASB reviews for compliance
  4. RAASB grants approval
  5. Advertise

Timeline

The specific timeline for approval is determined by RAASB. RAs should plan ahead to ensure timely approval.

How to Obtain Approval

Step 1: Prepare the Advertisement

  • Ensure all mandatory information is included
  • Ensure no prohibited content is included
  • Include all required disclaimers
  • Prepare the advertisement in the required format

Step 2: Submit to RAASB

  • Submit the advertisement to RAASB
  • Include all supporting documentation
  • Follow the RAASB submission process

Step 3: RAASB Review

  • RAASB reviews the advertisement
  • RAASB checks for compliance
  • RAASB may request changes

Step 4: Address Feedback

  • Address any feedback from RAASB
  • Make any required changes
  • Resubmit if necessary

Step 5: Obtain Approval

  • RAASB grants approval
  • The advertisement can now be issued

What is Subject to Prior Approval

Advertisements

  • All formal advertisements
  • Print advertisements
  • Digital advertisements
  • Social media advertisements
  • Email marketing

Promotional Materials

  • Brochures
  • Pamphlets
  • Flyers
  • Posters
  • Display materials

Communications

  • Any communication that is an advertisement
  • Communications that are promotional in nature

Research Reports

  • Research reports that are considered advertisements
  • Reports containing promotional content

What is Not Subject to Prior Approval

  • Pure research reports (no promotional content)
  • Client-specific communications
  • Regulatory communications
  • Non-promotional content

Retention of Approved Materials

Requirement

Copy of the advertisement shall be retained by RA for a period of five years in terms of Regulation 25(2) of SEBI (Research Analysts) Regulations, 2014.

What to Retain

  • The approved advertisement
  • The approval from RAASB
  • Any related correspondence

Common Compliance Gaps

1. Not Obtaining Prior Approval

Some RAs issue advertisements without obtaining prior approval.

Solution: Obtain prior approval before issuing advertisements.

2. Delayed Submission

Some RAs submit for approval too late.

Solution: Submit well in advance.

3. Not Addressing Feedback

Some RAs do not address RAASB feedback.

Solution: Address all feedback promptly.

4. Not Retaining Copies

Some RAs do not retain copies of approved advertisements.

Solution: Retain copies for five years.

Conclusion and How Anuj Desai & Associates Can Help

Prior approval from RAASB is a mandatory requirement for RA advertisements.

Anuj Desai & Associates offers specialized services to help RAs comply with the prior approval requirement:

  • Review of advertisements before submission
  • Assistance with RAASB submission
  • Guidance on addressing feedback
  • Compliance audit and advisory

Contact us today to ensure your advertisements obtain prior approval. Our team will guide you through the approval process.


Disclaimer: This article is for informational purposes only and does not constitute legal advice. Readers are advised to consult qualified professionals for legal and compliance matters. Anuj Desai & Associates is a SEBI compliance consulting firm based in India.


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