Research Analysts (RAs) are required to submit periodic reports to RAASB on a half-yearly basis. These reports provide essential information about the RA's operations, compliance, and client base. This article provides a comprehensive technical analysis of the periodic reporting requirements.
Regulatory Basis
Primary Provision: Regulation 24(4)
Regulation 24(4) provides that:
"Research analyst or research entity shall furnish to the Board information and reports as may be specified by the Board from time to time."
Periodic Reporting Circular
The circular dated October 25, 2024 (SEBI/HO/MIRSD/MIRSD-PoD1/P/CIR/2024/148) specifies the periodic reporting format and requirements.
Reporting Periods
Half-Yearly Periods
| Period | Dates |
|---|---|
| Half-Year 1 | April 1 to September 30 |
| Half-Year 2 | October 1 to March 31 |
Reporting Deadlines
| Period | Reporting Deadline |
|---|---|
| September 30 | October 30 |
| March 31 | April 30 |
Who Must Report
| Entity | Reporting Requirement |
|---|---|
| Registered RAs | Submit to RAASB |
| Proxy Advisers | Submit to SEBI |
| Research Entities | Submit to RAASB |
What Must Be Reported
Table 1: General Details of RA
- Registered name
- Trade name/brand name
- PAN
- SEBI Registration Number
- Enlistment number
- Logo (Yes/No)
- Date of Birth/Incorporation
- Legal structure
- Registered office address
- Correspondence address
- Principal place of business
- Number of branches
- Branch addresses
- Total number of employees
- Official website address
- Social media handles
- Bank account details
- Contact person details
- Compliance officer details
- Managing director/partner details
- Other directors/partners
- Shareholding pattern
- NISM certification details
- Inspection details
- Advertisement details
- Investor charter and complaint data
- Number of research reports published
- Number of public appearances
Table 2: Complaint Details
- Complaints pending at the end of previous half-year
- Complaints received during the period
- Complaints resolved during the period
- Complaints pending at the end of the period
- Ageing of pending complaints
- Average complaint resolution time
- Break-up of type of complaints
Table 3: Client and Fee Details
- Number of clients by category
- Fee collected by category
Submission Process
Step 1: Prepare the Report
- Collect all required information
- Complete the report in the specified format
Step 2: Review the Report
- Review for accuracy and completeness
- Verify all data
Step 3: Submit the Report
- Submit to RAASB through the designated portal
- Submit by the deadline
Step 4: Retain Records
- Retain a copy of the report
- Maintain for five years
Common Compliance Gaps
1. Missing the Deadline
Some RAs miss the reporting deadline.
Solution: Set up reminders and submit early.
2. Incomplete Report
Some RAs submit incomplete reports.
Solution: Ensure all sections are completed.
3. Incorrect Data
Some RAs submit incorrect data.
Solution: Verify all data before submission.
4. Not Reporting
Some RAs do not submit the periodic report.
Solution: Submit the report on time.
Consequences of Non-Compliance
1. Regulatory Action
SEBI may take action for non-compliance.
2. Monetary Penalties
SEBI may impose monetary penalties.
3. Reputational Damage
Non-compliance can damage the RA's reputation.
Conclusion and How Anuj Desai & Associates Can Help
Periodic reporting is a critical compliance obligation.
Anuj Desai & Associates offers specialized services to help RAs comply with periodic reporting requirements:
- Preparation of periodic reports
- Review of report data
- Submission assistance
- Compliance audit and advisory
Contact us today to ensure your periodic reports are submitted on time. 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.