Proxy Advisers (PAs) must submit periodic reports to SEBI in a specific format. This report covers key information about the PA's operations, complaints, and activities. This article provides a comprehensive technical analysis of the periodic reporting format and submission process.
Regulatory Basis
Periodic Reporting Circular
The circular dated October 25, 2024 (SEBI/HO/MIRSD/MIRSD-PoD1/P/CIR/2024/148) specifies:
"Proxy advisers shall submit the periodic report in a format provided at Annexure J."
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 |
Annexure J – Periodic Reporting Format
1. Identification Information
| Information | Required |
|---|---|
| Registered Name (as per SEBI certificate) | Yes |
| Trade Name/Brand Name | Yes |
| Permanent Account Number (PAN) | Yes |
| SEBI Registration No. | Yes |
| Logo (if any) | Yes/No |
| Date of Incorporation/Birth | Yes |
| Legal Structure | Yes |
2. Address and Branch Details
| Information | Required |
|---|---|
| Registered Office Address | Yes |
| Correspondence Address | Yes |
| Principal Place of Business | Yes |
| Number of Branches | Yes |
| Addresses of Branches | Yes |
3. Personnel Details
| Information | Required |
|---|---|
| Total Number of Employees | Yes |
| Contact Person Details | Yes |
| Compliance Officer Details | Yes |
| Managing Director/Partner Details | Yes |
| Other Directors/Partners | Yes |
4. Shareholding Details
| Information | Required |
|---|---|
| Shareholder Name | Yes |
| Number of Shares | Yes |
| % of Shareholding | Yes |
5. Bank Account Details
| Information | Required |
|---|---|
| Bank Account Name | Yes |
| Account Number | Yes |
| Type of Account | Yes |
| IFSC Code | Yes |
| Bank Name | Yes |
| Bank Branch Name | Yes |
6. Compliance Information
| Information | Required |
|---|---|
| Inspection Details | Yes |
| Number of Advertisements Issued | Yes |
| Complaints Pending/Received/Resolved | Yes |
7. Activity Information
| Information | Required |
|---|---|
| Number of Agenda Items | Yes |
| Number of Reports for General Meetings | Yes |
| Number of Other Reports | Yes |
| Number of Clients/Subscribers | Yes |
| Total Amount of Fees Received | Yes |
Submission Process
Step 1: Prepare the Report
- Collect all required information
- Complete the report in Annexure J format
Step 2: Review the Report
- Review for accuracy and completeness
- Verify all data
Step 3: Submit to SEBI
- Submit directly to SEBI
- Follow the prescribed submission process
Step 4: Retain Records
- Retain a copy of the report
- Maintain for five years
Common Compliance Gaps
1. Not Submitting
Some PAs do not submit the periodic report.
Solution: Submit the report on time.
2. Incomplete Report
Some PAs submit incomplete reports.
Solution: Ensure all sections are completed.
3. Incorrect Data
Some PAs submit incorrect data.
Solution: Verify all data before submission.
4. Missing the Deadline
Some PAs miss the reporting deadline.
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 PA's reputation.
Conclusion and How Anuj Desai & Associates Can Help
Periodic reporting is a critical compliance requirement for PAs.
Anuj Desai & Associates offers specialized services to help PAs comply with periodic reporting requirements:
- Report preparation
- Data verification
- Submission assistance
- Compliance audit and advisory
Contact us today to ensure your periodic reports comply with SEBI requirements. 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.