Research Analysts (RAs) are required to disclose complaint data on their websites on a monthly basis. This requirement ensures transparency in the investor grievance redressal mechanism. This article provides a comprehensive technical analysis of the complaint data disclosure requirements.
Regulatory Basis
Primary Requirement
RAs are required to disclose on their respective websites and mobile applications all complaints received against them or against issues dealt by them and redressal thereof, latest by the 7th of the succeeding month in a prescribed format.
Format
The format for complaint data disclosure is specified in the Investor Charter circular (Annexure B).
Disclosure Format
Monthly Complaint Data Table
Format for investors complaints data to be disclosed monthly by RAs on their website/mobile application:
Data for the month ending - [Month, Year]
| Sr. No. | Received from | Pending at the end of last month | Received | Resolved* | Total Pending# | Pending complaints > 3 months | Average Resolution time^ (in days) |
|---|---|---|---|---|---|---|---|
| 1 | Directly from Investors | ||||||
| 2 | SEBI (SCORES) | ||||||
| 3 | Other Sources (if any) | ||||||
| Grand Total |
Notes:
-
- Inclusive of complaints of previous months resolved in the current month.
-
Inclusive of complaints pending as on the last day of the month.
- ^ Average Resolution time is the sum total of time taken to resolve each complaint, in days, in the current month divided by total number of complaints resolved in the current month.
Impersonation Complaints
Number of complaints received during month against the RA due to impersonation by some other entity:
Note: In case of any complaints received against the RA due to impersonation of the RA by some other entity, the RA may adjust the number of such complaints from total number of received/resolved complaints while preparing the above table. Further, RA must close such impersonation related complaints after following the due process as specified by SEBI/RAASB.
Trend of Monthly Disposal of Complaints
| Sr. No. | Month | Carried forward from previous month | Received | Resolved* | Pending# |
|---|---|---|---|---|---|
| 1 | April, YYYY | ||||
| 2 | May, YYYY | ||||
| 3 | June, YYYY | ||||
| 4 | ... | ||||
| 5 | March, YYYY | ||||
| Grand Total |
Notes:
-
- Inclusive of complaints of previous months resolved in the current month.
-
Inclusive of complaints pending as on the last day of the month.
Trend of Annual Disposal of Complaints
| Sr. No. | Year | Carried forward from previous year | Received | Resolved* | Pending# |
|---|---|---|---|---|---|
| 1 | 2021-22 | ||||
| 2 | 2022-23 | ||||
| 3 | 2023-24 | ||||
| 4 | 20XX-XX | ||||
| Grand Total |
Notes:
-
- Inclusive of complaints of previous years resolved in the current year.
-
Inclusive of complaints pending as on the last day of the year.
Compliance Requirements
1. Monthly Disclosure
- Disclose complaint data monthly
- By the 7th of the succeeding month
2. Website/Mobile App
- Display on website
- Display on mobile applications
3. Prescribed Format
- Use the SEBI-prescribed format
4. Impersonation Complaints
- Adjust impersonation complaints
- Close after due process
Common Compliance Gaps
1. Not Disclosing Monthly
Some RAs do not disclose complaint data monthly.
Solution: Disclose by the 7th of the succeeding month.
2. Incorrect Format
Some RAs use an incorrect format.
Solution: Use the prescribed format.
3. Not Including All Data
Some RAs do not include all complaint data.
Solution: Include all complaints.
4. Not Handling Impersonation
Some RAs do not handle impersonation complaints properly.
Solution: Adjust and close impersonation complaints.
Consequences of Non-Compliance
1. Regulatory Action
SEBI may take action for non-compliance.
2. Lack of Transparency
Clients may not have visibility into complaints.
3. Reputational Damage
Non-disclosure can damage the RA's reputation.
Conclusion and How Anuj Desai & Associates Can Help
Monthly complaint data disclosure is a critical transparency requirement.
Anuj Desai & Associates offers specialized services to help RAs comply with complaint data disclosure:
- Review of complaint data
- Assistance with format and publication
- Compliance audit and advisory
Contact us today to ensure your complaint data is properly disclosed. Our team will guide you through the 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.