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SEBI / Research Analysts

RAASB – Enlistment of RAs – Deemed Enlistment for Existing RAs

A comprehensive guide on the enlistment of Research Analysts with RAASB, including deemed enlistment for existing RAs.

25 Jul 20264 min read

Research Analysts (RAs) are required to be enlisted with RAASB. The enlistment provisions provide for ease of doing business, including deemed enlistment for existing RAs. This article provides a comprehensive technical analysis of the enlistment requirements.

Regulatory Basis

Enlistment Requirement

Clause (xi) of Regulation 6 of RA Regulations provides that an applicant seeking registration as RA is required to be enlisted with RAASB.

Deemed Enlistment Provisions

The circular dated May 2, 2024 (SEBI/HO/MIRSD/MIRSD-SEC-3/P/CIR/2024/34) provides for deemed enlistment.

Enlistment Provisions

1. Existing RAs

Provision: Existing RAs registered with SEBI shall be deemed to be enlisted with RAASB.

Effect: No separate application or documentation is required.

Examples:

  • An RA registered with SEBI before July 25, 2024, is deemed enlisted with RAASB.

2. Applications Under Process

Provision: Applications for registration as RA received and under process with SEBI up to the effective date of operationalization of RAASB framework shall continue to be processed by SEBI.

Effect: Such RAs shall be deemed to be enlisted with RAASB once registration is granted by SEBI.

Examples:

  • An application submitted before July 25, 2024, that is granted after that date is deemed enlisted.

3. New Applications

Provision: New applications received from the effective date of operationalization of RAASB framework shall be routed through RAASB.

Effect: Enlistment with RAASB shall be a pre-requisite for grant of certificate of registration as RA by SEBI.

Examples:

  • An application submitted on or after July 25, 2024, must go through RAASB.

4. No Additional Documentation

Provision: No additional documentation shall be required for deemed enlistment.

Effect: Existing RAs and applicants with applications under process do not need to submit additional documents.

Summary of Enlistment Provisions

ScenarioEnlistment StatusDocumentation Required
Existing RA before July 25, 2024Deemed enlistedNone
Application under process before July 25, 2024Deemed enlisted on registrationNone
New application on or after July 25, 2024Must enlist before registrationAs per RAASB requirements

Why Deemed Enlistment?

1. Ease of Doing Business

Deemed enlistment reduces the compliance burden on existing RAs.

2. Smooth Transition

Deemed enlistment ensures a smooth transition to the RAASB framework.

3. No Disruption

Deemed enlistment prevents disruption for existing RAs.

4. Efficiency

Deemed enlistment is efficient and avoids duplication.

Process for New Applications

Step 1: Enlistment

  • Apply to RAASB for enlistment
  • Submit required documentation

Step 2: Registration

  • RAASB recommends to SEBI
  • SEBI grants registration

Step 3: Compliance

  • Comply with RAASB requirements
  • Submit periodic reports

Common Compliance Gaps

1. Assuming Deemed Enlistment Applies to All

Some RAs incorrectly assume deemed enlistment applies to all.

Solution: Deemed enlistment applies only to existing RAs and applications under process.

2. Not Enlisting for New Applications

Some RAs do not enlist with RAASB for new applications.

Solution: Enlist with RAASB as a pre-requisite.

3. Not Submitting RAASB Reports

Some RAs do not submit reports to RAASB.

Solution: Submit all required reports.

Conclusion and How Anuj Desai & Associates Can Help

Enlistment with RAASB is a critical requirement for RAs.

Anuj Desai & Associates offers specialized services to help RAs navigate the enlistment process:

  • Understanding enlistment requirements
  • Assistance with RAASB applications
  • Compliance audit and advisory

Contact us today to ensure your RAASB enlistment is in order. 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 GuideRAASB enlistmentdeemed enlistmentexisting RA enlistmentRA registration processenlistment requirementRAASB membershipRA enlistment provisionsautomatic enlistmentRAASB enrollmentAnuj Desai and AssociatesSEBI compliance consultantRAASB compliance expert
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