Skip to content
SEBI / Research Analysts

Periodic Report – Client and Fee Details – Individual vs Non-Individual Breakdown

A comprehensive guide on the client and fee details that must be reported in the periodic report, including individual vs non-individual breakdown.

25 Jul 20264 min read

The periodic report for Research Analysts (RAs) requires detailed information about clients and fees, including a breakdown by individual and non-individual categories. This article provides a comprehensive technical analysis of these reporting requirements.

Regulatory Basis

The client and fee details are specified in the periodic reporting format (Table-3) of the circular dated October 25, 2024 (SEBI/HO/MIRSD/MIRSD-PoD1/P/CIR/2024/148).

Client Details Reporting

Client Categories

Individual Clients:

  • Resident
  • Non-Resident
  • FPI

Non-Individual Clients:

  • Resident
  • Non-Resident
  • FPI

Required Information

InformationDescription
Number of clients at end of previous half-yearly periodCount as of the end of the previous period
Number of clients acquired during the periodNew clients onboarded
Number of client relationships that ended during the periodClients who terminated
Number of clients at end of the periodCount as of the reporting date

Client Counting Exemption

"In case, research services are provided as free for all as value added service to clients of other services offered by the entity viz. stock broking, PMS etc., the details sought in Table-3 need not be submitted."

Fee Details Reporting

Fee Categories

Individual Clients:

  • Resident
  • Non-Resident
  • FPI

Non-Individual Clients:

  • Resident
  • Non-Resident
  • FPI

Required Information

InformationDescription
Details of fees collected (in Rs.)Total fees collected from each category

Reporting Format

Client Details Table

ParticularsIndividualNon-IndividualTotal
ResidentNon-ResidentFPIResident
Number of clients at end of previous half-yearly period
Number of clients acquired during the period
Number of client relationships that ended during the period
Number of clients at end of the period

Fee Details Table

ParticularsIndividualNon-IndividualTotal
ResidentNon-ResidentFPIResident
Details of fees collected (in Rs.)

Definition of Categories

Resident (Individual)

  • Indian citizens residing in India
  • Resident individuals as per FEMA

Non-Resident (Individual)

  • Indian citizens residing outside India
  • Non-resident individuals as per FEMA
  • NRIs, OCIs, PIOs

FPI (Individual)

  • Foreign Portfolio Investors
  • Registered with SEBI as FPI

Resident (Non-Individual)

  • Resident companies, LLPs, partnerships, trusts, etc.

Non-Resident (Non-Individual)

  • Non-resident companies, LLPs, partnerships, etc.

FPI (Non-Individual)

  • Foreign Portfolio Investors (non-individual)
  • Registered with SEBI as FPI

Common Compliance Gaps

1. Incorrect Client Categorization

Some RAs categorize clients incorrectly.

Solution: Properly categorize clients.

2. Missing Fee Data

Some RAs do not report fee data.

Solution: Report all fee data.

3. Incomplete Data

Some RAs do not provide complete data.

Solution: Ensure all fields are completed.

4. Incorrect Application of Exemption

Some RAs incorrectly apply the exemption.

Solution: Apply the exemption only when applicable.

Conclusion and How Anuj Desai & Associates Can Help

Client and fee details are essential for regulatory reporting.

Anuj Desai & Associates offers specialized services to help RAs comply with client and fee reporting requirements:

  • Review of client data
  • Assistance with categorization
  • Compliance audit and advisory

Contact us today to ensure your client and fee reporting is accurate. 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 Guideperiodic report clientsperiodic report feesindividual clients breakdownnon-individual clients breakdownRA client reportingRA fee reportingclient categories reportingindividual vs non-individualclient breakdown reportingfee breakdown reportingAnuj Desai and AssociatesSEBI compliance consultantRA compliance expert
Share

Related insights

Work with ADA

Ready to talk to an advisor?

Book a consultation and get a clear, considered view from a team that handles audit, tax, regulatory and cross-border work under one roof.