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Complaint Data – Impersonation Complaints – How to Adjust and Close

A detailed guide on how Research Analysts should handle impersonation complaints, including adjustment and closure procedures.

25 Jul 20264 min read

Research Analysts (RAs) may receive complaints against them due to impersonation by some other entity. These complaints must be handled properly, including adjustment in complaint data and closure after due process. This article provides a comprehensive technical analysis of handling impersonation complaints.

Regulatory Basis

Impersonation Complaint Provision

The Investor Charter for Research Analysts includes a specific provision for impersonation complaints:

"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."

What is an Impersonation Complaint?

Definition

An impersonation complaint is a complaint received against an RA where the actual perpetrator is another entity impersonating the RA.

Examples

  • Fraudster using the RA's name
  • Fake website posing as the RA
  • Unauthorized use of the RA's brand
  • Identity theft of the RA

Handling Impersonation Complaints

Step 1: Identify Impersonation

  • Identify that the complaint is due to impersonation
  • Verify that the RA is not responsible

Step 2: Document Evidence

  • Document evidence of impersonation
  • Collect relevant information

Step 3: Report to Authorities

  • Report to SEBI/RAASB
  • Report to law enforcement if necessary

Step 4: Adjust Complaint Data

  • Adjust the number of impersonation complaints from total received/resolved complaints
  • Maintain records of adjustment

Step 5: Close Complaint

  • Close the impersonation complaint
  • Follow due process as specified by SEBI/RAASB

Adjustment of Complaint Data

How to Adjust

Original DataAdjustmentAdjusted Data
Total complaints received: 10Impersonation complaints: 3Adjusted received: 7
Total complaints resolved: 8Impersonation complaints resolved: 3Adjusted resolved: 5

Recording the Adjustment

  • Maintain a separate record of impersonation complaints
  • Document the adjustment
  • Explain the adjustment if requested

Due Process for Closure

1. Investigation

  • Conduct an investigation
  • Confirm impersonation

2. Documentation

  • Document the investigation
  • Maintain records

3. Reporting

  • Report to SEBI/RAASB
  • Provide evidence

4. Closure

  • Close the complaint
  • Update complaint data

Common Compliance Gaps

1. Not Adjusting Data

Some RAs do not adjust complaint data for impersonation.

Solution: Adjust data as per the provision.

2. Not Closing Complaints

Some RAs do not close impersonation complaints.

Solution: Close complaints after due process.

3. No Documentation

Some RAs do not document impersonation.

Solution: Maintain documentation.

4. Not Reporting

Some RAs do not report impersonation.

Solution: Report to SEBI/RAASB.

Consequences of Not Handling Impersonation

1. Inflated Complaint Data

Complaint data will be inflated.

2. Regulatory Scrutiny

SEBI may question inflated complaint data.

3. Reputational Damage

Non-handling of impersonation can damage reputation.

Conclusion and How Anuj Desai & Associates Can Help

Impersonation complaints must be handled properly.

Anuj Desai & Associates offers specialized services to help RAs handle impersonation complaints:

  • Identification and investigation
  • Documentation and reporting
  • Data adjustment
  • Compliance audit and advisory

Contact us today to ensure your impersonation complaints are handled properly. 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.


Compliance Guideimpersonation complaintscomplaint adjustmentcomplaint closureRA impersonationfraud complaintsidentity theftimpersonation fraudRA complaint handlingcomplaint due processAnuj Desai and AssociatesSEBI compliance consultantRA compliance expert
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