SEBI finds research analyst outsourced work without valid agreement

This order details SEBI's adjudication proceedings against Rishabh Tanwar, a registered Research Analyst, for alleged violations of outsourcing regulations, failure to maintain client records, and non-compliance with code of conduct requirements during the period of April 2023 to October 2024.

Who it concerns: Rishabh Tanwar (Registered Research Analyst, SEBI Reg. No. INH100009293); Govind Mohanrao Surnar (Third-party service provider associated with the RA).

What SEBI found or ordered

• SEBI found violations regarding outsourcing business activities without a valid agreement in place at the time of commencement.
• SEBI found the RA lacked a comprehensive outsourcing policy and risk management program.
• SEBI found the RA failed to conduct adequate due diligence on the third-party service provider.
• SEBI found the RA failed to maintain contingency plans, resulting in the loss of KYC records for 471 out of 509 clients.
• SEBI found the RA outsourced core business activities (KYC and client grievances) and paid approximately 90% of fees to the service provider.
• SEBI found the RA failed to display complaint status on the website monthly as required.
• The Noticee admitted to the lapses, citing inexperience and lack of compliance staff, and sought leniency.

Also in the document

• The inspection period covered from April 1, 2023, to October 31, 2024.
• The Show Cause Notice was issued on September 4, 2026, and the hearing took place on September 24, 2026.
• The Noticee stated that he ceased all activities with the service provider and acknowledged the failures were due to documentation and oversight lapses rather than dishonesty.