Research Analysts (RAs) often use brand names or trade names for their business. However, the SEBI-registered name must also be prominently displayed. This rule ensures that clients can identify the registered entity. This article provides a comprehensive technical analysis of this display rule.
Regulatory Basis
The brand name vs SEBI-registered name display rule is specified in the circular dated April 6, 2023 (SEBI/HO/MIRSD/MIRSD-PoD-2/P/CIR/2023/52) on "Usage of brand name/trade name by Investment Advisers (IA) and Research Analysts (RA)."
The Display Rule
Requirement
The information such as:
- Name of the RA as registered with SEBI
- Its logo
- Its registration number
- Its complete address with telephone numbers
Shall be prominently displayed on:
- Portal/website
- Notice board
- Display boards
- Advertisements
- Publications
- Know your client forms
- Client agreements
Why This Rule Exists
| Reason | Description |
|---|---|
| Transparency | Clients should know the registered entity |
| Identification | Easy identification of the RA |
| Regulatory Compliance | Compliance with SEBI requirements |
| Client Protection | Protect clients from unregistered entities |
Key Requirements
1. Prominent Display
The SEBI-registered name must be prominently displayed, not hidden.
- Not in fine print
- Not in a hidden location
- Not in an inconspicuous location
2. Website
The information must be displayed on the website.
- Home page
- About us page
- Footer
- Contact page
3. All Client Communications
The information must be displayed in all client communications.
- Reports
- Emails
- Correspondence
- Agreements
What Must Be Displayed
| Item | Requirement |
|---|---|
| Registered Name | As per SEBI certificate |
| Logo | The RA's logo |
| Registration Number | Full SEBI registration number |
| Address | Complete registered office address |
| Telephone Numbers | Contact phone numbers |
| Compliance Officer Name | Name of compliance officer |
| Compliance Officer Telephone | Telephone number |
| Compliance Officer Email | Email address |
| Grievance Officer Name | Name of grievance officer |
| Grievance Officer Telephone | Telephone number |
| Grievance Officer Email | Email address |
Website Display Requirements
1. Home Page
- Registered name prominently displayed
- Brand name may also be displayed
- Registration number visible
2. About Us Page
- Complete registered name
- Registration details
- Address and contact information
3. Footer
- Registration number
- Registered name
- Disclaimer
4. Contact Page
- Full address
- Telephone numbers
- Email addresses
- Compliance officer details
- Grievance officer details
5. Reports and Publications
- Registered name displayed
- Registration number displayed
Examples
Example 1: Compliant Display
Website Home Page: "XYZ Research Private Limited (SEBI Registration No. IN/RA/XXXXXX)"
Website Footer: "XYZ Research Private Limited, SEBI Registration No. IN/RA/XXXXXX, Registered Office: ABC Building, Mumbai, India."
Example 2: Non-Compliant Display
Website Home Page: "XYZ Research" (only brand name, no registered name)
Website Footer: "SEBI Registered" (no registration number)
Common Compliance Gaps
1. Only Brand Name Displayed
Some RAs display only the brand name without the registered name.
Solution: Display both the brand name and registered name.
2. Registered Name Hidden
Some RAs hide the registered name in fine print.
Solution: Prominently display the registered name.
3. Missing Registration Number
Some RAs do not display the registration number.
Solution: Always display the registration number.
4. Incomplete Address
Some RAs do not display the complete address.
Solution: Display the complete registered office address.
5. No Contact Details
Some RAs do not display contact details.
Solution: Display all required contact details.
Conclusion and How Anuj Desai & Associates Can Help
The display rule ensures transparency and client protection.
Anuj Desai & Associates offers specialized services to help RAs comply with the display rule:
- Review of website content and display
- Guidance on prominent display
- Compliance audit and advisory
Contact us today to ensure your website complies with the display rule. Our team will review your website and provide a tailored compliance roadmap.
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.