SEBI finds ₹1.20 crore in fees collected without valid NISM certifications

This order details SEBI's adjudication of violations by Rajiv Sharma, an investment adviser, regarding fee limits, certification compliance, and record-keeping identified during a thematic inspection.

Rajiv Sharma (Proprietor of M/s. Capital Life Market Research)

• SEBI alleged violation of Regulation 15(3) of IA Regulations for failing to maintain arm's length distance between advisory activities and personal financial dealings (loans from clients routed through the same bank account).
• SEBI alleged violation of Regulations 7(2), 15(13), and 13(a) for carrying on advisory activities without valid NISM certifications (expired April 2024) and collecting Rs. 1.20 crore in fees during FY 24-25.
• SEBI alleged violations of Regulations 19(1)(a-h), 19(2), 19(3), 15(12), and 15(8) for failure to maintain complete client records, submit annual/periodic reports, and update KYC details for five clients.
• The Noticee claimed the excess amounts were personal loans, not fees, and that record-keeping failures were due to a crashed hard disk and misplaced documents.
• The Noticee failed to submit a written reply to the Show Cause Notice within the stipulated time (April 16, 2026) but was granted a hearing on May 13, 2026, and filed a reply on the same date.

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