SEBI finds 50 orders missing pre-order confirmation from Goodwill Wealth

This order details SEBI's adjudication proceedings against Goodwill Wealth Management Private Limited (GMWPL) for alleged violations of regulatory provisions regarding order confirmation, complaint redressal, and outsourcing of core functions during a thematic inspection from April 2024 to July 2025.

Goodwill Wealth Management Private Limited (GMWPL)

• SEBI alleged GMWPL failed to maintain pre-order confirmation or documentary evidence for 50 orders placed by 15 clients (out of a sample of 281 orders).
• SEBI alleged GMWPL outsourced its core compliance function of grievance redressal to an Authorized Person (AP), violating Clause 86.5.1 of the SEBI Master Circular.
• SEBI alleged GMWPL failed to maintain complete documentary records for complaint redressal, specifically noting a pattern of complaints being withdrawn without available communication records.
• SEBI alleged GMWPL settled 37 complaints related to unauthorized trading by making payments, which SEBI viewed as an acceptance of lapses in internal controls.
• SEBI rejected GMWPL's reply and claimed corrective actions (such as centralized POC systems and restricted AP access) because they were implemented only after the inspection observations were made.
• The order cites violations of Clause 35.2, 35.3, 35.4, 35.5, and 86.5.1 of the SEBI Master Circular for Stock Brokers, as well as specific NSE regulations and the Code of Conduct for Stock Brokers.

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