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The company has laid down policy guidelines which have been framed in the light of National Stock Exchange (NSE) Circular No. : 831/2013 Ref. No. : NSE/INVG/22908. In pursuance of above said circular FINVASIA SECURITIES PVT. LTD. is implementing this surveillance policy applicable to all clients .

Objective of this policy

  1. To establish a surveillance mechanisms and controls in the operations /trading activity of Finvasia Securities Pvt. Ltd . clients.
  2. To put in place appropriate controls for the detection and reporting of suspicious trading activities in accordance with applicable laws/laid down procedures.
  3. To comply with applicable laws and regulatory guidelines.

Duties and Responsibilities

This Surveillance policy is approved by the Board of Directors of Finvasia Securities Pvt. Ltd . and A quarterly MIS shall be put up to the Board on the number of alerts pending at the beginning of the quarter, generated during the quarter, disposed off during the quarter and pending at the end of the quarter. Further, reasons for pendency alongwith appropriate action taken to resolve them shall be discussed. Board shall be apprised of any exception noticed during the disposition of alerts.

Designated directors/ Compliance officer shall be the responsible for all surveillance activities carried out by Finvasia Securities Pvt. Ltd ., maintenance of record and reporting of such activities.

Internal auditor of Finvasia Securities Pvt. Ltd . shall review the surveillance policy, its implementation, effectiveness and the alerts generated during the period of audit. Internal auditor shall record the observation with respect to the same in their report.

Transaction Alerts

Finvasia Securities Pvt. Ltd . surveillance desk shall download all the below mentioned alert based on the trading activity of client provided by the exchange vide Circular No. : 831/2013 Ref. No. : NSE/INVG/22908.

S. No. Transaction Alerts Segment
1 Significantly increase in client activity Cash
2 Sudden trading activity in dormant account Cash
3 Clients/Group of Client(s), deal in common scrips Cash
4 Client(s)/Group of Client(s) is concentrated in a few illiquid scrips Cash
5 Client(s)/Group of Client(s) dealing in scrip inminimum lot size Cash
6 Client / Group of Client(s) Concentration in a scrip Cash
7 Circular Trading Cash
8 Pump and Dump Cash
9 Wash Sales Cash & Derivatives
10 Reversal of Trades Cash & Derivatives
11 Front Running Cash
23 Concentrated position in the Open Interest / High Turnover concentration Derivatives
13 Order book spoofing i.e. large orders away from Cash

Clients Due Diligence

Finvasia Securities Pvt. Ltd . shall carry out the Due Diligence of client(s) on a continuous basis and shall update all the KYC parameters as prescribed by SEBI and latest information of the client in Unique Client Code (UCC) database of the Exchange.

Analysis:

In order to analyze the trading activity of the Client(s) / Group of Client(s) or scrips identified based on above alerts, the Finvasia Securities Pvt. Ltd . shall require to:

  1. Finvasia Securities Pvt. Ltd . shall require explanation from such identified Client(s) / Group of Client(s) for entering into such transactions as enclosed the Format (Form No.- ).
  2. Finvasia Securities Pvt. Ltd . shall require documentary evidence such as bank statement / demat transaction statement or any other documents .In case of funds, Finvasia Securities Pvt. Ltd . shall require Bank statements of the Client(s) / Group of Client(s) from which funds pay-in have been met, to be sought. In case of securities, Finvasia Securities Pvt. Ltd . shall require demat account statements of the Client(s) / Group of Client(s) from which securities pay-in has been met, to be sought.

 

Note* The period for such statements may be at least +/- 15 days from the date of transactions to verify whether the funds / securities for the settlement of such trades actually belongs to the client for whom the trades were transacted.

  1. Finvasia Securities Pvt. Ltd . shall analyze the documentary evidences, including the bank / demat statement, Finvasia Securities Pvt. Ltd . shall record its observations for such identified transactions or Client(s) / Group of Client(s).
  2. In case adverse observations are recorded, Finvasia Securities Pvt. Ltd . shall report all such instances to the Exchange within 45 days of the alert generation.
  3. In case of extension is required, Finvasia Securities Pvt. Ltd . shall send a request to exchange for a period of extension.
  4. If explanation on the same shall not satisfactory / reply shall not receive within time period as above mentioned then Finvasia Securities Pvt. Ltd . suspend the client from trading / report the instance to Regulators (if suspicious).

 

To,

Client Name

Client Address

 

Sub.: Alert received from (Exchange Name) in respect of your trading during the period from _________ to _________.

Dear Sir,

With reference to above, please note that we have received following alert form the exchange in respect of your trading activity during the period from___________ to _______________.

Sr. No. Date of Alert Exchange Alert Type

 

In this regard you are requested to clarify the following:

  1. Basis of Investment
  2. Objectives of Investment
  3. Source of funds used for making the Investment
  4. Whether such investment is based on any research report if so please provide the detail.
  5. Reason for sudden increase in turnover
  6. Whether you are related party to the Investee company? If yes, please provide complete details of such relation.

Further you are requested to provide self attested copy of Bank Account Statement and Demat Account Transaction Statement for the period from __________ to ____________ along with any other relevant document within seven days from the date of this letter.

Please note that your failure to submit reasonable explanation and required documentary evidence within above said time may lead to suspension of trading facility in your account.

Please do the needful and oblige.

 

Thanking you,

For : Finvasia Securities Pvt. Ltd .

 

(Compliance Officer)