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.

Who it concerns: Goodwill Wealth Management Private Limited (GMWPL)

What SEBI found or ordered

• 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to maintain complete documentary records for complaint redressal, specifically noting a pattern of complaints being withdrawn without available communication records.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.

Also in the document

• The inspection period covered April 1, 2024, to July 31, 2025.
• SEBI noted that GMWPL settled 37 unauthorized trading complaints via payment, which SEBI characterized as reflecting serious deficiencies in ensuring valid client authorization.
• The order states that GMWPL's reply was not accepted for 50 orders due to a claimed software migration issue, while it was accepted for 83 orders where pre-order confirmations were provided.