Observations of Internal Auditor Management

Remarks
No. of (Para
Compliance samples wise,
Status verified Amount/v where
{C- % of alue auditor
S.No. Area of Verification
Complied, No. of instances involved has
NC-Not Remarks instances where non- where non- Whether reported
Complied, in case of where non complianc complianc Auditor non-
NA-Not observatio complianc e is e is comments complianc Applicabil
Applicable} n e observed observed observed accepted e) ity
Client registration documentation /Anti Money Laundering
1
compliance
All relevant Client Registration Documents executed with
All
clients in compliance with SEBI circulars and supporting
Refer Members-
collected from the clients are available and are easily retrievable
a C Sampling Registered
and no material discrepancies were observed (viz. Photograph,
Criteria 1 for Any
signature, Pan Card details, Proof of Address/Identity Not
Segment
provided)
All
Correct and updated KYC details/ information of the clients are Refer Members-
b uploaded in the UCC database of the Exchange as per KYC details C Sampling Registered
and the same is matching with KRA/ C-KYC database. Criteria 1 for Any
Segment
No clauses are included in any of thedocuments executed with the
clients-
All
a) which dilutes responsibility of member or
Refer Members-
b) which is in conflict with any of the clauses in mandatory
c C Sampling Registered
documents, Rules, Bye-laws, Regulations,Notices, Guidelines &
Criteria 1 for Any
Circulars issued by SEBI & Exchanges or
Segment
c) which is not in the interest of the Investor.
d) No blanket confirmation / authorisation obtained from clients.
 All the mandatory clauses/documents and Annexures such as
KYC, details relating to trading account , rights and Obligation, All
Dos and Don’ts , RDD and Tariff sheet and contact details of Refer Members-
d senior officials and Investor Grievance Cell of the member as C Sampling Registered
stipulated by SEBI/Exchanges have been included in the Criteria 1 for Any
mandatory section of the Account opening document executed Segment
with the clients and no material details were omitted.
All
In-person verification is done by Employee or Authorised Person
Refer Members-
only and the date of verification, name, designation and signature
e C Sampling Registered
of the official who has done in-person verification and the Rubber
Criteria 1 for Any
Stamp is incorporated in the client registration form.
Segment
Click to
enter detail
[Lower of
Any changes (including address, bank account or demat account)
50 clients
in the information in the account opening form as provided at the All
or 100%
time of account opening has been notified by the client to the Members-
wherever
f member in writing and member has carried out necessary due C Registered
changes
diligence to verify correctness of any such changes and updated for Any
have been
those changes in relevant records in their back office, UCC Segment
made
Database of the Exchange, KRA and CKYCR.
during the
audit
period.]
All
Trading member has taken documentary evidence in support of Refer Members-
g financial information provided by the client for derivatives C Sampling Registered
segment at the time of registration. Criteria 1 for Any
Segment
All
Client details including financial details are reviewed and updated Refer Members-
h periodically / at least once in a financial year in compliance with C Sampling Registered
Exchange's circulars. Criteria 3 for Any
Segment
 Trading code and the unique client code allotted to a client and the All
e-mail furnished by the client for the purpose of receiving ECN Refer Members-
i and other details, are communicated by the trading member C Sampling Registered
through the client account opening form or otherwise in writing to Criteria 1 for Any
the client. Segment
Member has identified the beneficial owners of the client ( non-
All
individuals) and has taken reasonable measures to verify the
Refer Members-
identity of such person as per SEBI Circular Nos.CIR/ MIRSD/
j C Sampling Registered
2/2013 dated January 24, 2013 and
Criteria 1 for Any
SEBI/HO/MIRSD/SECCFATF/P/CIR/2023/169 dated October
Segment
12, 2023
All
Refer Members-
Member has a process to identify the authority of the person who
k C Sampling Registered
is placing orders on behalf of the client.
Criteria 1 for Any
Segment
All
Risk profiling/categorization of the clients has been done as per Refer Members-
l the written down policy of the member as per the PMLA master C Sampling Registered
circular. Criteria 1 for Any
Segment
All
Refer Members-
Member has adopted sufficient due diligence process for clients
m C Sampling Registered
according to their risk profile as per the PMLA master circular.
Criteria 1 for Any
Segment
Member is having a clearly defined policy for acceptance of
All
clients and has ensured that an account is not opened where the
Refer Members-
member is unable to apply appropriate client due diligence
n C Sampling Registered
measures/KYC Policies.
Criteria 1 for Any
Trading member has implemented clients identification
Segment
procedures & programs at various stages.
 All
Refer Members-
Member has identified clients of special category (CSC) as per the
o C Sampling Registered
PMLA master circular.
Criteria 1 for Any
Segment
All
Refer Members-
The Client has opted and signed against stock exchange as well as
p C Sampling Registered
market segment where he intends to trade/traded during the year.
Criteria 1 for Any
Segment
Copies of complete set of client registration documents executed All
by the clients including POA/ email id provided by clients for Refer Members-
q receiving ECN was delivered to the clients free of charge and C Sampling Registered
within 7 days from the date of execution of documents by the Criteria 1 for Any
clients Segment
All
Refer Members-
Authorizations from the client sought in non-mandatory document
r C Sampling Registered
are separate & do have client’s specific consent.
Criteria 1 for Any
Segment
All
The member has correctly uploaded & updated all UCC details
Refer Members-
including Email ID and the Mobile number of the clients in the
s C Sampling Registered
UCC database as per the details given by the client in the client
Criteria 1 for Any
registration documents.
Segment
All
The member has collected correct PAN number and verified the
Refer Members-
authenticity of such PAN issued by the Income Tax (IT)
t C Sampling Registered
Department, for all their clients and uploaded same in UCC
Criteria 1 for Any
Database of the Exchange.
Segment
The member has correctly uploaded and updated the same E mail
All Active All
ID & the Mobile number of the client in the Exchange UCC
clients at Members-
records and in the Member’s back office records and there are no
u C the end of Registered
variations. Member has periodically reconciled their backoffice
the Audit for Any
records with the Exchange UCC records to avoid mismatch in the
period Segment
UCC of their clients and ensure that there are no variations.
 Member has complied with the requirement of uploading the KYC
information with the SEBI registered KRAs for all the clients on a All
continuous basis within the prescribed time limit as per SEBI Refer Members-
v circular MIRSD/Cir-26/2011 dated December 23, 2011 and C Sampling Registered
MIRSD/Cir-5/2012 dated April 13, 2013 and complied with the Criteria 1 for Any
provisions of the Circular and no other procedural lapses were Segment
observed.
All
Refer Members-
Member has downloaded KYC information from KRA system for
w C Sampling Registered
new clients who are already registered with KRA
Criteria 1 for Any
Segment
All
Refer Members-
Member has uploaded the KYC data with CKYCR in respect of
x C Sampling Registered
all accounts (except FPIs) opened during the Audit period.
Criteria 1 for Any
Segment
All
Member has uploaded the KYC records to CKYCR when the
Refer Members-
updated KYC information is obtained/received from the client in
y C Sampling Registered
case of Legal Entity's accounts (except FPIs) opened prior to April
Criteria 1 for Any
1, 2021
Segment
Member has uploaded the KYC data with CKYCR in respect of
All
all existing individual accounts (i.e. accounts opened prior to the
Members-
Audit period). Further, member has uploaded the KYC records
z C All Clients Registered
with CKYCR pertaining to accounts of individuals opened prior to
for Any
August 01, 2016, as and when updated KYC information is
Segment
obtained / received from the client.
Trading Member has prominently displayed on account opening
kits, Advertisement, publication, notice board and display board, All
portal website (if any) the following details- Members-
Audit
aa i) name of the member as registered with SEBI, C Registered
Period
ii) its own logo, if any, for Any
iii) its registration number, Segment
iv) its complete address with telephone numbers.
 Member has made available the documents relating to rights & All
obligations, uniform risk disclosure document, do’s & don’t to the Refer Members-
ab clients either in electronic or physical mode as per the preference C Sampling Registered
of the client and maintained acknowledgment in writing / Criteria 1 for Any
appropriate logs of delivery for the same. Segment
All
Members have displayed the documents relating to rights &
Members-
obligations, uniform risk disclosure document, do’s & don’t in Audit
ac C Registered
vernacular languages on their own website (if any) and copy of the Period
for Any
same is provided to clients on request.
Segment
All
Member has not uploaded same E mail ID and Mobile numbers to Members-
Audit
ad multiple clients except for family as defined by SEBI circular C Registered
Period
CIR/MIRSD/15/2011 dated August 02, 2011. for Any
Segment
All
For client registered through online KYC process, member has
Refer Members-
adhered to all applicable guidelines which facilitate online KYC in
ae C Sampling Registered
accordance with SEBI Circular no.
Criteria 1 for Any
SEBI/HO/MIRSD/DOP/CIR/P/2020/73 dated April 24,2020
Segment
All
Refer Members-
af Member has mapped client code with back office code C Sampling Registered
Criteria 1 for Any
Segment
All
Member has included procedure for filing of complaints on Refer Members-
ag SCORES and benefits of the same in the welcome kit given to C Sampling Registered
investors at the time of registration. Criteria 1 for Any
Segment
Member has verified their existing backoffice records with the
All
MNRL List published on TRAI Website and in case the mobile
Members-
number of their existing clients is appearing in the MNRL (Mobile Audit
ah C Registered
Number Revocation list) List, member has updated correct mobile Period
for Any
number in their back office records as well as in UCC database of
Segment
the Exchange.
 All
Members are required to verify, update and ensure that correct Members-
Audit
ai permanent address details of the clients are uploaded in UCC C Registered
Period
database of the Exchange. for Any
Segment
Member has complied with SEBI Circular CIR/MIRSD/2/2015
dated August 26, 2015 as per which “foreign financial institutions
All
in India will be required to report tax information about US
Members-
account holders / taxpayers directly to the Indian government Audit
aj C Registered
which will, in turn, relay that information to the US Internal Period
for Any
Revenue Service (IRS) and Guidance note on implementation of
Segment
reporting requirements under rules 114F to 114h of the Income-
Tax Rules, 1962 for implementation of FATCA guidelines.
All
Refer Members-
Member has collected client identification documents as
ak C Sampling Registered
prescribed by Exchange/SEBI.
Criteria 1 for Any
Segment
Members-
In case, in-person verification of non-resident clients is not done, Registered
Refer
attestation of KYC documents is done by Notary Public, Court, for other
al C Sampling
Magistrate, Judge, Local Banker, Indian Embassy/ Consulate than
Criteria 1
General in the country where the client resides. Commodit
y Segment
Members-
Registered
KYC requirements as stipulated in respect of Foreign Portfolio Audit
am C for
Investors (FPIs) has been complied. Period
Commodit
y Segment
Members-
Member has complied with the applicable regulatory requirements
Registered
of SEBI Circular no. SEBI/HO/IMD/DF1/ CIR/P/2019/066 and Audit
an C for
relevant Exchange circulars regarding "Participation of Portfolio Period
Commodit
Managers in Commodity Derivatives Market in India"
y Segment
 Members-
Member has complied with the applicable regulatory requirements
Registered
of SEBI Circular no. SEBI/HO/IMD/DF2/ CIR/P/2019/65 and Audit
ao C for
relevant Exchange circulars regarding "Participation of Mutual Period
Commodit
Funds in Commodity Derivatives Market in India"
y Segment
All active
clients Members-
Member has obtained self-declaration from their Clients on
registered Registered
commodity wise categorization as prescribed by SEBI Circular no.
ap C as at the for
SEBI/HO/CDMRD/DNPMP/CIR/P/2019/08 dated January 04,
end of the Commodit
2019.
Audit y Segment
period
All active
clients Members-
Member has correctly uploaded commodity-wise categorization of registered Registered
aq clients on the Exchange platform based on self declaration C as at the for
obtained from clients. end of the Commodit
Audit y Segment
period
Member has sensitized their investors and created investor
awareness on fraudsters that are collecting data of customers who
are already into trading on Exchanges and sending them bulk
Members-
messages on the pretext of providing investment tips and luring
Registered
them to invest with them in their bogus firms by promising huge Audit
ar C for
profits. Period
Commodit
AND
y Segment
Member has taken necessary steps to safeguard data of the
customers / investors registered with him and/or has not shared or
revealed such data to unauthorized persons.
Member has made available the facility for online closure of All
trading accounts and informed their clients regarding the Members-
Audit
as availability of facility for online closure of trading accounts and its C Registered
Period
guidelines through emails, SMS, weekly / fortnightly /monthly for Any
newsletters etc., if applicable. Segment
 All
Member has ensured that clients whose KYC records are not Refer Members-
at found to be valid by KRA after the validation process are allowed C Sampling Registered
to transact in securities market only after their KYC is validated. criteria 1 for Any
Segment
All
Trading Member has maintained a website and URL of the same is
Members-
reported to the exchange. Further, a declaration for maintenance of Member's
au C Registered
Website and any modification in the URL shall be reported to the Website
for Any
Exchange within 3 days.
Segment
 Trading Member has displayed the following details on its website
-
1) Set of standard documents/ policies for information
2) Name of the member as registered with SEBI, its own logo, if
any, its registration number, and its complete address with
telephone numbers.
3) "Filing Complaints on SCORES- Easy & quick
a. Register on SCORES portal
b. Mandatory details for filing complaints on SCORES:
i. Name,PAN,Address,Mobile Number, Email ID
c. Benefits:
i. Effective Communication
ii. Speedy redressal of the grievances"
4)Following message at a prominent place on the homepage of All
their website (if any) . Members-
Member's
av “Attention Investors C Registered
Website
1. Stock Brokers can accept securities as margin from clients only for Any
by way of pledge in the depository system w.e.f. September 01, Segment
2020.
2. Update your email id and mobile number with your stock
broker / depository participant and receive OTP directly from
depository on your email id and/or mobile number to create
pledge.
3. Check your securities / MF / bonds in the consolidated account
statement issued by NSDL/CDSL every month.
.......... Issued in the interest of Investors"
5) Data on complaints received against them or against issues
dealt by them and redressal thereof, latest by 7th of succeeding
month as per the format prescribed by SEBI vide Circular No.
SEBI/HO/MIRSD/DOP/P/CIR/2021/676 dated December 02,
2021
 Member having website have displayed following message on
their website:-
1. Message on their websites informing their clients to update their Members-
Email IDs & Mobile numbers with the member. Registered
2. Link to voting URLs on voting on motions moved by Listed Member's for other
aw C
Companies, which will redirect the investor to the webpage of the Website than
respective Depository who in turn will enable access to the e- Commodit
voting portals of various ESPs y Segment
3.Risk Disclosure requirement with respect to trading by
individual traders in Equity F&O segment
Members-
Trading Member has registered their new clients on all the active Registered
Refer
stock Exchanges after obtaining the trading preference in the for other
ax C Sampling
prescribed format for the clients registered on or after August 01, than
criteria 1
2023 Commodit
y Segment
Members-
Trading Member has obtained express consent and/or explicit
Registered
confirmation from the clients for the trading preferences in the Refer
for other
ay Equity Derivatives/Currency Derivatives/Commodities C Sampling
than
Derivatives Segments by providing an option to the clients to only Criteria 1
Commodit
select/opt in at the time of onboarding of the client.
y Segment
Trading Member has complied with the provisions of SEBI
All
Circular No.SEBI/HO/OIAE_IAD-1/P/CIR/2023/0000000163
Members-
dated October 3, 2023 w.r.t verification of the death certificate, Audit
az C Registered
updation of records in KRA system, intimation of transmission of Period
for Any
assets of deceased investor and other obligations pertaining to
Segment
reporting of demise of an investor.
2 Order management and risk management systems
All
Trading member has well documented risk management policy Members-
Audit
a including policy on Margin collection from clients/Trading C Registered
Period
members. for Any
Segment
 Trading member has not undertaken or was not party to or has not
facilitated any fund based activity to fund any secondary market All
transactions or margin requirements in respect of transactions Members-
Audit
b executed by the trading members on behalf of their clients through C Registered
Period
financier including any associate, related or third party for Any
entities.Trading Member has adhered to the guidelines laid down Segment
in relevant circulars on financing of securities transactions.
All
Members-
Checks are in place to ensure that no unauthorized orders are Audit
c C Registered
executed from any of the terminals. Period
for Any
Segment
All
All applicable margins are collected from respective clients in the
Refer Members-
prescribed form of funds, fixed deposit receipts, bank guarantees
d C Sampling Registered
and approved/ liquid securities and approved commodities with
Criteria 2 for Any
appropriate haircut.
Segment
All
Members-
Proper systems are in place to ensure timely collection for pay-in Audit
e C Registered
from the respective client as per settlement schedule. Period
for Any
Segment
All
Trading member has not outsourced their core business activities Members-
Audit
f and compliance functions and adhered to the provisions of SEBI C Registered
Period
circular CIR/MIRSD/24/2011 dated 15th Dec 2011. for Any
Segment
All
Members-
Member has not passed penalty to clients on account of short/non- Audit
g C Registered
collection of upfront margins Period
for Any
Segment
 All
If the Member has passed on penalty for short reporting of Members-
Audit
h margins other than "upfront margins", the same is on actual basis C Registered
Period
& has provided relevant supporting documents to the client. for Any
Segment
Member has drafted and implemented surveillance policy as per
SEBI/Exchange circulars Further Policy should cover:
All
i. Receipt of Alerts from Exchange/ generated at member's end.
Members-
ii. Time frame for disposal of alerts and if there is any delay in Audit
i C Registered
disposal, reason for the same shall be documented. Period
for Any
iii. Suspicious/ Manipulative activity identification and reporting
Segment
process
iv. Record Maintenance.
All
Member has executed trades of clients only after keeping evidence Refer Members-
j of the client placing such order and maintained the record of the C Sampling Registered
same in the manner specified by SEBI from time to time. Criteria 3 for Any
Segment
Member has undertaken fresh documentation, due diligence and
IPV where a client is reactivated after a period of 1 year of being
flagged as inactive except where client has undertaken transaction
through the Member with respect to IPO / Mutual Fund All
subscription and DP operations (if the Member is a DP) during Members-
Audit
k this period.In case a client is reactivated before a period of 1 year C Registered
Period
of being flagged as inactive, Member has ensured that the basic for Any
details of such client like Address, Mobile number, Email ID, Segment
Bank/DP account are updated in its records as well in the UCC
records of the Exchange and necessary documents has been
collected in case of any changes.
All
Member has an efficient system for collecting and reporting client
Refer Members-
margin collection to the Exchange / clearing corporation as per the
l C Sampling Registered
Exchange / clearing corporation / SEBI requirements including
Criteria 2 for Any
initial, peak, other margins, MTM.
Segment
 All
Member has reported margin correctly and in case of Refer Members-
m false/incorrect reporting give instancewise complete details in an C Sampling Registered
annexure and summary in remarks column Criteria 2 for Any
Segment

Top 25 (or
100%
whichever
is lower)
clients with
highest
MTM
losses in
the Audit
All
period and
Members-
Proper monitoring mechanism is in place to review the client top 10
n C Registered
MTM losses incurred and recovery of the same related
for Any
party
Segment
clients with
highest
MTM
losses in
the Audit
period (or
100%
whichever
is lower)

Member has framed a policy regarding treatment of inactive All

accounts which should, inter-alia, cover aspects of time period, Members-
Audit
o return of client assets and procedure for reactivation of the same C Registered
Period
and has also displayed the same on its website, (if any) in for Any
accordance with the guidelines issued by the Exchange. Segment
 All
Members-
Member has identified all inactive client accounts and marked / Audit
p C Registered
flagged as Inactive in UCC database of the Exchange. Period
for Any
Segment
Quarterly MIS has been placed upto the Board (in case of
Corporate Trading Member) , Partners (in case of partnership
All
firms) or Proprietor (in case of sole proprietorship firm) on the
Members-
number of alerts pending at the beginning of the quarter, generated Audit
q C Registered
during the quarter , disposed off during the quarter and pending at Period
for Any
the end of quarter along with reasons for pendency and
Segment
appropriate action taken and Board is apprised of any exception
noticed during the disposal of alerts as per the Exchange Circulals.
All
Members-
Audit
r Member has taken indemnity insurance policy. C Registered
Period
for Any
Segment
All
Member has mandatorily used telephone recording system to Refer Members-
s record the order instructions received from clients through C Sampling Registered
telephone. Criteria 3 for Any
Segment
All
Member has not executed trades which do not appear to be
Members-
genuine and they have appropriate internal system and control to Audit
t C Registered
ensure that Abnormal / Non-genuine orders/trades are not entered Period
for Any
at unrealistic price / executed from members trading terminals.
Segment
All
Members-
Member has adopted/maintained policy regarding pre-funded Audit
u C Registered
instrument as per regulatory requirements Period
for Any
Segment
 All
Members-
Member has adopted/maintained policy for assessment of Audit
v C Registered
activities outsourced as per regulatory requirements. Period
for Any
Segment
Trading member has implemented proper internal code of conduct
Members-
and adequate internal controls to ensure that proper checks and
Registered
balances are in place with respect to SEBI Circular Cir/ ISD/ 1/
Audit for other
w 2011, dated March 23, 2011 and Cir/ ISD/ 2/ 2011 dated March C
Period than
24, 2011 on the subject ‘Unauthenticated news circulated by SEBI
Commodit
registered market intermediaries through various modes of
y Segment
communication.
Members-
Member has implemented appropriate checks for value and / or Registered
quantity based on the respective risk profile of their clients as per Audit for other
x C
the provisions of SEBI Circular CIR/ MRD/ DP/ 34/ 2012 dated Period than
December 13, 2012. Commodit
y Segment
Members-
The member has put-in place a mechanism to limit the cumulative Registered
value of all unexecuted orders placed from their terminals to Audit for other
y C
below a threshold limit set by them as per the provisions of SEBI Period than
Circular CIR/ MRD/ DP/ 34/ 2012 dated December 13, 2012. Commodit
y Segment
Members-
Member has taken adequate documentary evidences as specified
Click here Registered
in SEBI circular CIR/ MRD/ DP/ 20/ 2014 dated June 20, 2014
to enter for other
z in case of participants taking positions in CD segment in excess of C
data (10 than
the applicable position limits based on underlying exposure
Clients) Commodit
specified in the said circular.
y Segment
 Trading Member has adhered to the guidelines laid down by
Exchanges while offering client incentives/referral schemes. Also,
Trading Member has framed an internal policy w.r.t.
Members-
quantum/maximum limit on the incentive to be provided to the
Registered
referring person in compliance with guidelines laid down in the
Audit for other
aa applicable circulars. Such policy is duly approved by its Board (in C
Period than
case of corporate trading member), Partners (in case of partnership
Commodit
firms) or Proprietor (in case of sole proprietorship firm) as the
y Segment
case may be. Trading Member has taken adequate steps to review
and monitor the adherence to the said policy on a regular basis, at
such intervals not later than one year.
Members-
Member has made available the mechanism for physical settlement Registered
in stock derivatives to all their clients who wish to avail of the said Audit for other
ab C
facility without having any default option of mandatory/automated Period than
squaring off the positions in compliance to Exchange Circulars. Commodit
y Segment
Members-
Registered
Member has transactional alerts facility with respect to Exchange's Audit
ac C for
circulars. Period
Commodit
y Segment
Members-
Trading member has established groups / associations amongst Registered
Audit
ad clients to identify multiple accounts / common account / group of C for
Period
clients as per relevant Exchange's circular Commodit
y Segment
 Trading member has profiled their clients and categorised the
clients under one of the category namely Commercial participant
(value chain participant / exporter / importer, hedger, etc) or Non -
All clients
commercial participant (financial participant / trader / arbitrager, Members-
registered
etc). as per relevant Exchange's Circular. Registered
as at the
ae Further, member has monitored any sudden change in the trading C for
end of the
pattern of the client which is not in line with the profile of client. Commodit
Audit
Also, Member has kept a watch on the trading behaviour of their y Segment
period
clients and monitored the same in view of their financial
soundness/income/net-worth and business background as per
relevant Exchange's circular.
Trading member has a process of analysing the trading activity of
the client(s) / group of clients(s) or commodity identified based on
Members-
transactional alerts and wherever adverse observations are
Registered
recorded, member has reported all such instances to the Exchange Audit
af C for
within 45 days of alert generation or extended time period sought Period
Commodit
from the Exchange, wherever required.
y Segment
Auditor shall verify the alerts generated during the audit period
and provide their observations
Members-
Member has submitted the status of the alerts forwarded to them
Registered
on a quarterly basis to the Exchange in the prescribed format Audit
ag C for
within 15 days from the last trading day of the respective quarter Period
Commodit
as per Exchange's circular.
y Segment
Member has conducted periodic analysis of trading behaviour of
Members-
clients who appear repeatedly in the transactional alerts and/or
Registered
have been repeatedly found to be breaching the norms prescribed Audit
ah C for
by SEBI/Exchange. Further, Member has monitored any sudden Period
Commodit
trading activity in dormant account and informed such abnormality
y Segment
to the Exchange as per Exchange's circular.
Members-
Member is not involved in unauthorized or illegal trading
Registered
activities / fictitious transactions or unfair trade practice including Audit
ai C for
Circular Trading, cross deals, price rigging, price manipulation Period
Commodit
and other market Abuses.
y Segment
 All
In case member has passed on penalty of short collection of Members-
Audit
aj upfront margin to clients after October 11, 2021, then member has C Registered
Period
refunded the said collected penalty to clients. for any
Segment
Member has not directly/indirectly referred to any past or
expected future return/performance of an algorithm trading
services/strategies in any form of advertisements/business All
communication on publicly accessible platforms such as social Members-
Audit
ak media/websites/digital & print media etc. and is not associated C Registered
Period
with any platform providing such reference, and has adhered to the for any
guidelines issued vide SEBI circular Segment
SEBI/HO/MIRSD/DOP/P/CIR/2022/117 dated September 02,
2022
All
Trading Member has conducted proper due diligence/verification Members-
Audit
al before registering/accepting the clients seeking exemption of PAN C Registered
Period
including investors residing in the state of Sikkim. for any
Segment
Member has done additional due diligence and maintained Members-
documents/records for all existing and new clients, by capturing Registered
the details of devices (Computer/ Tablet/Mobile including Audit for other
am C
Executable Applications, Browser based Apps, Mobile Apps) used Period than
to place/modify/cancel orders by the clients based out of Sikkim to Commodit
verify if the orders are placed from ‘Sikkim’ y Segment
Members-
Registered
Trading member has displayed "Risk Disclosure" on the login
Member’s for other
an page of trading account of client if client has registered under C
Website than
F&O segment
Commodit
y Segment
Contract notes, Client margin details and Statement of
3
accounts
 Click here All
to enter Members-
a Member has issued contract notes to clients C data Registered
6 dates per for Any
segment Segment
Click here All
to enter Members-
b Contract notes are sent in the prescribed format. C data Registered
6 dates per for Any
segment Segment
Click here All
Contract notes are sent within 24 hours of the close of trading to enter Members-
c hours when the trade is executed and Proof of delivery / dispatch/ C data Registered
log for dispatch of Contract Notes is maintained. 6 dates per for Any
segment Segment
Click here All
Trading member has issued contract notes only for trades done to enter Members-
d under the rules, byelaws & regulations/business rules of the C data Registered
Exchange and not otherwise. 6 dates per for Any
segment Segment
All
All prescribed details including running serial number initiated at
Members-
the start of every financial year, name and signature of authorized Audit
e C Registered
signatory, dealing office details and brokerage are contained in Period
for Any
contract note.
Segment
All
Daily Margin statement is issued to the respective clients with the Refer Members-
f details as specified and within the prescribed time limit and Proof C Sampling Registered
of delivery / dispatch/ log for dispatch is maintained. Criteria 3 for Any
Segment
 Member has complied with regulatory requirements related to
Electronic contract notes (ECN) if the contract notes are sent
electronically as mentioned below:
1. Whether digitally signed ECNs are in accordance with
provisions of IT Act, 2000? All
2. Whether ECN's sent to Email accounts created / provided by Refer Members-
g clients? C Sampling Registered
3. Whether authorization for receiving ECN given by the client (if Criteria 3 for Any
any) is signed by client and not by POA (Power of Attorney) Segment
holder?
4. Whether log report generated by the system at the time of
sending contract notes is maintained?
5. ECN displayed on website
All
Trail of bounced mails is maintained and physical delivery is Refer Members-
h ensured in case of bounce mails for ECNs within stipulated time C Sampling Registered
(24 hours). Criteria 3 for Any
Segment
All
Member has complied with the Guidelines on Compliance
Members-
Officers as issued by the Exchange further details regarding Audit
i C Registered
appointment of Compliance Officer and changes there in, if any, Period
for Any
have been informed to the Exchange.
Segment
Trading Member has prominently displayed on contract notes,
statement of funds and securities, correspondences with the clients
the following details- All
i) name of the member as registered with SEBI, Members-
Audit
j ii) its own logo, if any, C Registered
Period
iii) its registration number, for Any
iv) its complete address with telephone numbers, Segment
v) the name of the compliance officer, his telephone number and e-
mail address.
 All active
clients All
registered Members-
k Trading member has not created/provided e-mail ids for clients. C as at the Registered
end of the for Any
Audit Segment
period
All
Member has collected physical letters from the clients who have
Members-
requested for change in e-mail id.In respect of internet clients, the Audit
l C Registered
request for change of email id may be made through the secured Period
for Any
access by way of client specific user id & password.
Segment
All
Member has issued Annual Global Statement to their clients Refer Members-
m within 30 days from the end of the financial year and contain C Sampling Registered
details of all transactions executed by client in the financial year. Criteria 3 for Any
Segment
All
Member has sent complete 'Statement of Accounts' for funds,
Refer Members-
securities and commodities in respect of each of its clients on
n C Sampling Registered
weekly basis as required by relevant Exchange circulars with error
Criteria 3 for Any
reporting clause and proof of delivery / dispatch log is maintained.
Segment
Trading Member has registered themselves as Principal Entities All
with their respective Telecom Service Provider(s) (TSPs) and also Members-
Audit
o registered their existing headers and content templates for specific C Registered
Period
header with respective Telecom Service Provider(s) (TSPs) in for Any
compliance with Exchange circulars. Segment
All
Click here
Members-
There is no difference in trade rate as per TWS system / Trade to enter
p C Registered
File and the rate charged to clients in contract note. data (12
for Any
dates)
Segment
 All
Click here
Members-
Member has not issued consolidated contract notes to the client to enter
q C Registered
(Single entry for multiple trades/orders) data (12
for Any
dates)
Segment
All
Members-
Member has maintained proper records in respect of brokerage Audit
r C Registered
(i.e. incomplete/ erroneous/ delay in entries) Period
for Any
Segment
All
Click here
Members-
Member has maintained copies / duplicates of contract notes to enter
s C Registered
issued to clients in physical or electronic form. data (12
for Any
dates)
Segment
If member has made margin calls to the client and the client has
failed to comply with these margin calls, then the contract note
Click here All
issued by Member for transactions owing to non-compliance of
to enter Members-
such margin calls bear a remark specifying the same.
t C data (30 Registered
random for Any
Further, member has maintained a verifiable record of having
instances) Segment
made such margin calls and that the clients have not complied with
the same.
Members-
Registered
In case facsimile signatures are used on physical contract notes,
Audit for other
u Member has maintained well-documented & approved policy C
Period than
regarding its use
Commodit
y Segment
Members-
Registered
Member has sent text of Regulation 19 & 20 of Securities
Audit for other
v Contracts (SECC )Regulations, 2018 to clients dealing with listed C
Period than
Stock Exchanges along with the contract notes.
Commodit
y Segment
 Members-
Member has intimated the Exchange of any change in statutory Registered
Audit
w auditor within 30 days from the date of such change in the C for
Period
Exchange prescribed format. Commodit
y Segment
Members-
Member has paid all applicable statutory dues including GST
Registered
payable in adherence to The Central Goods And Services Tax Act, Audit
x C for
2017 within timeline prescribed. Further, member has kept records Period
Commodit
w.r.t. payment of statutory dues.
y Segment
All
If member is issuing Electronic Contract Notes (ECN) through Members-
Audit
y SMS/electronic instant messaging services then the member has C Registered
Period
complied with relevant guidelines issued by the Exchanges. for any
Segment
4 Dealing with clients’ funds and securities and Commodities
All
Client’s funds and securities & commodities are used only for the Refer Members-
a purpose of the respective client’s transactions. If not, instances to C Sampling Registered
be provided in remarks column. Criteria 3 for Any
Segment
Member has not pledged clients’ securities to the Banks/NBFCs All
for raising funds, even with authorization by client as the same Members-
Audit
b would amount to fund based activity which is in contravention of C Registered
Period
Rule 8(1)(f) & 8(3)(f) of Securities Contracts (Regulation) Rules, for Any
1957 Segment
All
Client bank accounts are used for authorized purposes only. In Members-
Audit
c case of any irregularity observed, mention the instances in remarks C Registered
Period
column. for Any
Segment
All
Member has not accepted cash from their clients/other entities
Members-
either directly or by way of cash deposit to the bank account of Audit
d C Registered
member. Period
for Any
No cash payments have been made to the clients/other entities
Segment
 In case where aggregate value of banker’s cheque / demand draft
All
/ pay order is of Rs 50,000 or more per client per day, then the
Members-
same are accompanied with name of bank account holder and Audit
e C Registered
number of bank account debited, duly certified by issuing bank as Period
for Any
per the provisions of SEBI Circular CIR/ MIRSD/ 03/ 2011,
Segment
dated June 9, 2011.
All
Member maintains audit trail of the funds received and systems Members-
Audit
f are in place to ensure that the funds are received from their C Registered
Period
respective clients only. for Any
Segment
All
Receipts/payment of funds and receipt/delivery of
Members-
securities/commodities are received/ transferred from/to respective Audit
g C Registered
clients only and no third party payment/ receipts has been Period
for Any
accepted / made on behalf of client
Segment
All
Members-
Audit
h Payment to clients are not made from proprietary bank accounts. C Registered
Period
for Any
Segment
All
In case of any transfer of funds between client account/s &
Members-
proprietary account/s for legitimate purposes, Member has Audit
i C Registered
maintained a daily reconciliation statement clearly indicating the Period
for Any
details of funds transferred.
Segment
All
Click here
Client’s funds / fully paid securities/commodities are transferred to Members-
to enter
j respective clients within one working day of pay-out from C Registered
data (12
Exchange in case of no running account authorization. for Any
dates)
Segment
All
Click here
Members-
The Delivery of securities to constituent is not made from to enter
k C Registered
Proprietary account. data (12
for Any
dates)
Segment
 All
Click here
Members-
Excess Brokerage was not charged on trades executed on the to enter
l C Registered
Exchange. data (6
for Any
dates)
Segment
All
Click here
Member has charged Brokerage for Option Contracts only on the Members-
to enter
m premium amount at which the Option Contract was bought or sold C Registered
data (6
and not on the strike price of the Option Contract. for Any
dates)
Segment
All
Members-
Not more than one client code is allotted to a single client. (Except Audit
n C Registered
as permitted in the exchange's circular) Period
for Any
Segment
All
Members Bank books and bank statements for each bank account
Members-
are reconciled and reconciliation statement for the same is Audit
o C Registered
prepared periodically and there are no long pending outstanding Period
for Any
reconcilable items.
Segment
All
Register of Securities/commodities and Holding statement from
Members-
depositories for each DP account and warehouse records are Audit
p C Registered
reconciled and reconciliation statement for the same is prepared Period
for Any
periodically.
Segment
All
Dividend and other corporate benefits received on behalf of clients Members-
Audit
q is paid/credited/passed on to the respective clients account without C Registered
Period
any delay. for Any
Segment
All
Refer Members-
Trading member has taken consent from the client regarding
r C Sampling Registered
monthly /quarterly settlement in the running account authorisation.
Criteria 1 for Any
Segment
 Trading member has settled funds of all clients on first Friday of
the Quarter - Oct-Dec 23 and on first Friday/Saturday from the
All
quarter Jan-Mar 2024 onwards.
Members-
If the client has opted for Monthly settlement, running account Audit
s C Registered
settlement has been done on first Friday of the month (for Oct- Period
for Any
Dec 2023) and first Friday/Saturday of the month from Jan 2024
Segment
onwards . If first Friday/Saturday is a trading holiday, then such
settlement shall happen on the previous trading day.
All
Member has returned funds to clients having credit balance and Members-
Audit
t who have not done any transaction in the 30 calendar days since C Registered
Period
the last transaction. for Any
Segment
All
Member has sent an intimation including the details about the Members-
Audit
u transfer of funds to clients by SMS & Email at the time of running C Registered
Period
account settlement of funds. for Any
Segment
All
Trading member has sent a statement of accounts containing an
Members-
extract from client ledger for funds & securities along with a Audit
v C Registered
statement explaining the retention of funds/securities, within five Period
for Any
days from the date when the account is considered to be settled.
Segment
All
Trading member has not done any inter-client adjustment or Members-
Audit
w passed any journal entries for the purpose of client level quarterly/ C Registered
Period
monthly settlement. for Any
Segment
 Member has transferred the funds to the respective clients while
carrying on the actual settlement of client fund. Bank details for
initiating electronic fund transfers has been obtained from new
All
clients and also updated for existing clients and the settlement of
Members-
funds is done only by way of electronic funds transfer viz., Audit
x C Registered
through National Electronic Funds Transfer (NEFT), Real Time Period
for Any
Gross Settlement (RTGS), etc .Only in cases where electronic
Segment
payment instructions have failed or have been rejected by the
bank, then the stock broker has issued a physical payment
instrument.
The following statutory levies/ fee/ charges are not collected from All
clients in excess of actuals levied on the members. Such as- Members-
Audit
y i) Securities Transaction Tax, C Registered
Period
ii) SEBI turnover fees, for Any
If Excess is collected, please give complete details. Segment
All
Members-
Member has not levied Excess transaction charges to clients in the Audit
z C Registered
contract notes. Period
for Any
Segment
The running account authorization taken by trading member from All
client(s) is dated and signed by such clients and not by POA Refer Members-
aa (Power of Attorney) holder and contains a clause which explicitly C Sampling Registered
allows a client to revoke the said running account authorization at Criteria 1 for Any
any time and would continue until such revocation. Segment
All
Members-
Member has not transferred funds from client bank account to any Audit
ab C Registered
third party or any other non-client account Period
for Any
Segment
All
Members-
Member has not transferred funds to its Group companies/ Audit
ac C Registered
Associates from client bank accounts Period
for Any
Segment
 All
Members-
Payment for own trades (PRO) are not made from client bank Audit
ad C Registered
accounts Period
for Any
Segment
All
Members-
Member is not operating any assured returns schemes and Audit
ae C Registered
mobilizing deposits from investors. If yes, please provide details. Period
for Any
Segment
All
Members-
Member has not taken securities/commodities from any client for Audit
af C Registered
purposes other than margin or meeting the client’s obligation. Period
for Any
Segment
All
Member has ensured that the funds available in the client
Members-
settlement bank accounts and balances available with clearing Audit
ag C Registered
Member and funds with Exchange/ clearing corporation are not Period
for Any
less than the funds payable to the client at all times.
Segment
The stock broker has submitted the correct details to Exchange All
regarding Monitoring of Client assets under Enhanced Supervision Members-
Audit
ah framework as per SEBI circular SEBI/HO/ C Registered
Period
MIRSD/MIRSD2/CIR/P/2016/95 dated September 26, 2016 upto for Any
the week ended January 5, 2024. Segment
All
Members-
The stock broker has submitted the correct details in the Risk Audit
ai C Registered
Based Supervision data submitted to the Exchange. Period
for Any
Segment
All
Member has correctly reported to the Exchange the Securities
Members-
holding balances for each of the DP account maintained by Audit
aj C Registered
it.(Details of the difference between the actual data and the Period
for Any
reported data should clearly be brought out).
Segment
 All
Members-
Trading member has closed all Client Securities accounts in Audit
ak C Registered
compliance with relevant Exchange circulars. Period
for Any
Segment
All
PAN recorded in the Register of Securities & the Holding Members-
Audit
al statement submission should match with the UCC database of the C Registered
Period
Exchange. for Any
Segment
All
Trading Member has opened a separate Client Bank and set aside
Members-
the funds and securities of Inactive/untraceable clients in such Audit
am C Registered
accounts and TM has upstreamed the untraceable/unclaimed Period
for Any
clients funds to CC.
Segment
All
Member has correctly reported day-wise balance (as per the bank
Members-
statement) of all bank accounts for all the calendar days of that Audit
an C Registered
week except Sunday within prescribed timelines (Upto the week Period
for Any
ended October 28, 2023)
Segment
All
Member has correctly uploaded data of Cash & Cash Equivalent
Members-
balances on a weekly basis for all calendar days of the week Audit
ao C Registered
except Sunday on stock exchange system within prescribed Period
for Any
timelines.
Segment
All
Member has closed all existing demat accounts tagged as Client Members-
Audit
ap Collateral and Client Margin Trading Securities accounts in C Registered
Period
compliance with relevant Exchange Circulars for Any
Segment
 Member has accepted securities as margin obligation from clients
only by way of margin pledge/repledge in the depository system All
by opening a separate demat account for accepting margin pledge Members-
Audit
aq which shall be tagged as “Client Securities Margin Pledge C Registered
Period
account". in accordance with SEBI circular for Any
no.SEBI/HO/MIRSD/DOP/CIR/P/2020/28 dated February Segment
25,2020.
Member has maintained audit trail of UCC wise client funds All
transferred to / from such bank account and UCC wise / BO ID Members-
Audit
ar wise securities transferred to / from separate and single client C Registered
Period
collateral demat account (as the case may be) for inactive and for Any
untraceable clients Segment
In case of bounce back of emails and non delivery of SMS,
provide comments with reasons thereof after verification.
All
Members-
Member has taken corrective steps for the instances where SMS Audit
as C Registered
and/or email is/are returned undelivered/bounced back including Period
for Any
updating the details of mobile number and email address in the
Segment
Exchange UCC database so as to avoid instances of non-delivery /
non-communication in future
All
Members-
Auditor should verify the details of generation of alerts for misuse Audit
at C Registered
of client funds and give specific comments with reasons thereof. Period
for Any
Segment
Auditor should verify whether the Member has correctly submitted
All
the details of financial indicators and ratios for "Monitoring of
Members-
Financial Strength of Stock Brokers" and give specific comments Audit
au C Registered
with reasons thereof. (Refer 5.1.1 and 5.1.2 as per SEBI Period
for Any
CIRCULAR SEBI/HO/MIRSD/MIRSD2/CIR/P/2016/95 dated
Segment
September 26,2016 )
All
Member has not levied any charges other than brokerage,
Refer Members-
exchange's transaction charges, applicable statutory and regulatory
av C Sampling Registered
dues in the contract note as permitted and it's on actual basis and
Criteria 3 for Any
not in excess of actuals
Segment
 Funds settled through running account settlement is transferred to All
the respective client’s bank account and members has not run any Refer Members-
aw scheme to invest the actual settlement dues (Monthly / Quarterly) C Sampling Registered
with the consent of the client / through POA in any scheme or Criteria 3 for Any
investment product including mutual funds etc. Segment
Member has not funded its clients in contravention to the
All
Exchange / SEBI requirements i.e. member has not granted further
Refer Members-
exposure to the clients when debit balances arise out of client's
ax C Sampling Registered
failure to pay the required amount and such debit balance has not
Criteria 3 for Any
continued beyond the fifth trading day, as reckoned from date of
Segment
pay-in (Except in accordance with Margin Trading Guidelines)
Members has cautioned and created awareness amongst their
clients/investors to abstain them from dealing in any schemes of All
unauthorised collective investments/portfolio management, Members-
Audit
ay indicative/ guaranteed/fixed returns / payments etc. Further C Registered
Period
Member has also displayed the messages on their respective for Any
websites under a separate banner “Advisory for investors” as per Segment
Exchange circular.
All
Members-
There is no delay in payment of funds / collaterals to clients Audit
az C Registered
beyond 3 working days from the date of receipt of request Period
for Any
Segment
Members-
Registered
Member has put in place systems for dealing with conflict of
Audit for other
ba interest as per SEBI circular CIR/ MIRSD/ 5/ 2013 dated C
Period than
August 27, 2013.
Commodit
y Segment
Members-
Registered
Member has levied delayed payment charges on client’s net debit
Audit for other
bb balances across all segments in accordance with the Exchange C
Period than
circulars
Commodit
y Segment
 Members-
Incase member has Margin Trading Facility, the securities lying in Registered
‘Client Securities under Margin Funding Account’ are not pledged Audit for other
bc C
with any other Bank/ NBFC in accordance with SEBI circular no. Period than
SEBI/HO/MIRSD/DOP/CIR/P/2020/28 dated February 25, 2020 Commodit
y Segment
Member has correctly posted entries in client ledgers related to Members-
trade/margin obligations, receipts and payments from/to clients are Registered
Refer
commensurate to the trades executed in the Exchange platform, for other
bd C Sampling
statutory/ regulatory levies as per applicable guidelines on actual than
Criteria 3
basis, brokerage/other allowable charges as agreed by the clients Commodit
in the tariff sheet, actual dividend and other corporate benefits. y Segment
Members-
Excess Client's securities provided as early pay-in (EPI) and
Registered
released by the clearing corporation/clearing member on T Day
Audit for other
be are transferred to the respective beneficiary account of their clients C
Period than
on the Trade day (T Day) itself in compliance with relevant
Commodit
circulars.
y Segment
Members-
Registered
Securities received in payout against which payment has been
Audit for other
bf made in full by the clients are not transferred to Client Unpaid C
Period than
Securities Account
Commodit
y Segment
Members-
Clients Commodities received as margin are utilised for respective
Refer Registered
clients only and not utilized for execution of proprietary trades or
bg C Sampling for
trades in the name of Directors/ Key Promoters/
Criteria 3 Commodit
shareholders/Other Clients
y Segment
Members-
Refer Registered
Member has maintained records of rate at which brokerage is
bh C Sampling for
charged and clientwise brokerage earned during the audit period.
Criteria 3 Commodit
y Segment
 Members-
Registered
Dealing with Foreign Portfolio Investors (FPIs) is in compliance Audit
bi C for
with guidelines of SEBI and Exchange in this regard. Period
Commodit
y Segment
Client funds received by the members in the client bank accounts All
is not invested in any Liquid Mutual Funds, Gilt Funds, Members-
Audit
bj Government Securities or any other liquid funds and not been C Registered
Period
considered for reporting under client asset for enhanced for Any
submission Segment
All
Funds of clients having credit balance has used for margin Members-
Audit
bk obligation of respective client only and not for obligation of any C Registered
Period
other clients / Proprietary trading for Any
Segment
All
Member has ensured that the securities available in the Members-
Audit
bl EPI/Pool/CUSPA are not less than the securities payable to the C Registered
Period
client at all times. for Any
Segment
Trading member has done correct reporting to the Exchange on
the following requirement on Settlement of Running Account of All
Client’s Funds lying with Trading Member Members-
Audit
bm 1. Summary of settlement of clients’ funds within 2 Trading Days C Registered
Period
post settlement date for Any
2.Submission of UCC wise settlement details within 10 Trading Segment
Days post settlement date
Members-
Registered
Trading member has made early pay-in of funds to the clearing Audit for other
bn C
corporation where clients have made an early pay-in of funds. Period than
Commodit
y Segment
 Members-
Registered
Intimation has been sent to the clients by SMS and Email on the
Audit for other
bo registered mobile number and email id upon successful early pay- C
Period than
in of funds.
Commodit
y Segment
Trading Member has ensured that no Bank Guarantees has been
created out of clients' funds. Also members (other than carrying
All
out only proprietary trading) have submitted
Members-
a certificate to the Stock Exchange by October 16, 2023, Audit
bp C Registered
confirming the implementation of Period
for Any
provisions of SEBI Circular SEBI/HO/MIRSD/MIRSD-PoD-
Segment
1/P/CIR/2023/061 dated April 25, 2023 duly certified by their
Statutory Auditor.
All
Members-
Member invoking client securities (under margin pledge) in case Audit
bq C Registered
of default and only to the extent of debit balance of client. Period
for Any
Segment
All
Trading Member has ensured that funds received from clients, Members-
whose running account has been settled, remain in the “Up Registered
br Audit Period
Streaming Client Nodal Bank Account” and no such funds shall be for Any
used for settlement of running account of other clients. Segment
All
Trading Member has ensured that all the clients’ clear credit Members-
balances are upstreamed to the clearing Corporation on EOD Audit Period Registered
Basis for Any
bs Segment
 The following conditions are met if any FDRs has been created All
out of clients funds: - Members-
Registered
i. The FDR shall be created only with banks which satisfy the for Any
CC’s exposure norms as specified by CCs/SEBI from time to time. Segment
ii. FDRs created only from ‘Up Streaming Client Nodal Bank
Account (USCNBA)’ and has been lien-marked to one of the
Clearing Corporations at all times.
iii. The tenor of FDRs created after July 01, 2023 are not more
bt than one year and one day; and the FDRs is pre-terminable on Audit Period
demand.
iv. The principal amount of the FDR is remained protected
throughout the tenure, even after accounting for all possible pre-
termination costs.
v. Members has not availed any funded or non-funded banking
facilities based on FDRs created out of clients’ funds
vi. Existing FDRs (created out of clients’ funds and having tenor
of more than one-year) created prior to June 30, 2023 shall be
allowed to be grandfathered till maturity.
All
Trading Members has ensured that client funds have been invested Members-
only in such MFOS that deploy funds into risk-free government Registered
bu Audit Period
bond overnight repo markets and overnight Triparty Repo Dealing for Any
and Settlement (TREPS Segment
All
Trading Member has maintained a dedicated demat account to as Members-
bv “Client Nodal MFOS Account” for subscription/ redemption of Audit Period Registered
MFOS units in case they are investing clients funds in MFOS for Any
Segment
Trading Member has ensured that any clear credit balance that All
could not be upstreamed to Clearing Corporations due to receipt Members-
bw of funds from clients beyond cut-off time has remained in Audit Period Registered
UNSCBA and upstreamed to Clearing Corporation on the next for Any
day Segment
 All
Trading member complied with the provisions of SEBI circular Members-
bx SEBI/HO/MIRSD/MIRSD-PoD-1/P/CIR/2023/187 dated Audit Period Registered
December 12, 2023 with respect to bank guarantees for Any
Segment
Members-
Trading Member has complied with the provisions of SEBI Registered
circular no. SEBI/HO/MIRSD/MIRSD-PoD-1/P/CIR/2022/153 for other
by Audit Period
dated November 11, 2022 regarding "Handling of Clients’ than
Securities by Trading Members(TM)" Commodit
y Segment
All
Member has correctly reported the data towards "Segregation and Members-
bz Monitoring of Collateral at Client Level" to their respective Audit Period Registered
Clearing Member for Any
Segment
5 Banking and Demat account operations
All
Members-
Member maintains separate bank account for client funds and own Audit
a C Registered
funds. Period
for Any
Segment
All
Members-
Member maintains separate demat account for clients securities Audit
b C Registered
and own securities. Period
for Any
Segment
All
Members-
Clients funds and securities & commodities are segregated from Audit
c C Registered
own funds and securities & commodities. Period
for Any
Segment
 All
Member has reported all their Bank & DP account details to the
Members-
Exchange as required by SEBI circular dated September 26, 2016. Audit
d C Registered
Further, closure of reported bank and demat accounts has been Period
for Any
correctly intimated to the Exchange within prescribed timeline.
Segment
Member has named/ tagged their Bank & DP accounts details to
the Exchange as required by SEBI circular dated September 26,
All
2016, June 22, 2017,
Members-
SEBI/HO/MIRSD/MIRSD_DPIEA/P/CIR/2022/83 dated June 20, Audit
e C Registered
2022, SEBI/HO/MIRSD/MIRSD-PoD-1/P/CIR/2023/84 dated Period
for Any
June 08, 2023, SEBI/HO/MIRSD/MIRSD-PoD-1/P/CIR/2023/110
Segment
dated June 30, 2023 & SEBI/HO/MIRSD/MIRSD-PoD-
1/P/CIR/2023/187 dated December 12, 2023
Trading Member has submitted Undertaking cum Indemnity bond
All
to Exchange empowering the Exchange to freeze the bank
Members-
accounts of the Trading member in compliance to SEBI circular Audit
f C Registered
SEBI/HO/MIRSD/DPIEA/CIR/P/2020/115 dated July 01, 2020, Period
for Any
on the subject "Standard Operating Procedure in the cases of
Segment
Trading Member /Clearing Member leading to default".
All
As on last
Member has maintained maximum of 30 bank accounts named as Members-
date of the
g "Name of Stock Broker - Client Account"/USCNBA/DSCNBA C Registered
audit
across all segments and Exchanges at a time. for Any
period
Segment
All
Trading Member has submitted Undertaking/Authorisation to Members-
Audit
h Exchange to access the information/statements pertaining to all C Registered
Period
bank accounts (maintained by members) from Banks. for Any
Segment
All
Multiple client code is not mapped with single bank/demat
Members-
account or multiple demat/bank account of different entities are Audit
i C Registered
not mapped with a single client code (Except where permitted by Period
for Any
the exchange)
Segment
 Member has maintained client bank accounts/USCNBA/DSCNBA
with followings banks only
All
i. Banks designated as Clearing Banks by any of the Clearing
Members-
Corporations from time to time Audit
j C Registered
ii. Banks which are not designated as Clearing Banks however Period
for Any
empaneled for the purpose of issuance of BGs and FDRs by any of
Segment
the Clearing Corporations from time to time
iii. Payment Banks licensed under Banking Regulation Act, 1949.
Member has provided a bank confirmation to the Exchanges in
case the client bank accounts/USCNBA/DSCNBA are maintained All
with the following banks; Members-
Audit
k i. Banks which are not designated as Clearing Banks however C Registered
Period
empaneled for the purpose of issuance of BGs and FDRs by any of for Any
the Clearing Corporations from time to time. Segment
ii. Payment Banks licensed under Banking Regulation Act, 1949.
All
Member has displayed details of all their active client bank Members-
Member's
l accounts/USCNBA on their website which are reported to C Registered
Website
Exchange. for Any
Segment
6 Terminal operations and systems
All
Trading terminals are located in the head office, branch office of Members-
a the Member or at the office of Authorised Person subject to C 100% Registered
compliance of guidelines specified by the Exchanges. for Any
Segment
All
Trading terminals are operated by approved persons/approved Members-
b users. And not provided TWS/CTCL terminals to unauthorised C 100% Registered
intermediaries. for Any
Segment
All
Correct Terminal details are reported to the Exchange and Members-
c terminals observed at the inspection location are as per the C 100% Registered
information submitted to the Exchange. for Any
Segment
 All
Member has ensured that associated persons functioning as Members-
Audit
d compliance officer employed has obtained NISM series III A C Registered
Period
certification. for Any
Segment
All
Records of trading terminals are updated and correctly uploaded Members-
Audit
e to the Exchange CTCL database and periodically reconciled with C Registered
Period
Exchange database. for Any
Segment
Valid NISM/ MCCP (MCX Certified Commodity Professional) / All
NICR (NCDEX Institute of Commodity Markets and Research) / Members-
Audit
f NCFM (NSE’s Certification in Financial Markets – Commodity C Registered
Period
Market Module) Certification held by employees are as per for Any
exchange requirements. Segment
All
No Offices/Branches/Franchises or User ID's/ Trade Work
Members-
Stations (TWS) or Trading Terminal are being used for doing Audit
g C Registered
unauthorized / illegal trading / fictitious transactions or any trade Period
for Any
outside the Exchange trading platform.
Segment
Member has complied with the advisory for Financial Sector
All
Organizations regarding Software as a Service (SaaS) based
Members-
solutions issued by the Indian Computer Emergency Response Audit
h C Registered
Team (CERT-in) as per SEBI Circular no. Period
for Any
SEBI/HO/MIRSD2/DOR/CIR/P/2020/221 dated November 03,
Segment
2020
Members-
Member has ensured that all associated person as defined in SEBI Registered
Verificatio
Notification LAD-NRO/GN/2010-11/21/29390 dated December for other
i C n of
10, 2010 have valid NISM series VII certification - (Securities than
Certificate
Operations and Risk Management Certification Examination). Commodit
y Segment
 Members-
Registered
Member has taken adequate steps as specified by Exchange's
Audit for other
j circular to review & monitor the Trading Terminals mapped to its C
Period than
branch/ AP
Commodit
y Segment
Management of branches / Authorised Person and internal
7
control
All All
branches Members-
In case of closure of branch/ Authorised Person location, advance
a C closed Registered
notice of the same is sent to clients.
during the for Any
period Segment
Member has adequate follow up mechanism in case of adverse
observations during branch / Authorised Person inspections and All or 25 All
Member has on an annual basis placed an MIS before their Board (inspection Members-
b (in case of corporate trading member), Partners (in case of C s of AP / Registered
partnership firms) or Proprietor (in case of sole proprietorship Branch) for Any
firm) on the number of Branch / Authorised Person inspections whichever Segment
undertaken, irregularities observed and action taken. is less
All
Trading member has not dealt with unregistered intermediaries for Members-
Audit
c transactions on the Exchange and All Authorised persons are C Registered
Period
registered with the Exchange for Any
Segment
The member has not shared commission/ brokerage with entities All
with whom trading members are forbidden to do business / another Members-
Audit
d trading member / employee in the employment of another trading C Registered
Period
member / person doing Intermediary activities without for Any
registration. Segment
All
Trading Member has inspected at least 30% of its active
Members-
Authorised Persons/ Branches every year and also ensure that, Audit
e C Registered
each active Authorised Person/ Branch is inspected at least once in Period
for Any
every three years as per guidelines laid down by the Exchanges.
Segment
 All
Members-
Member has not acted through brokers of other exchange for its Audit
f C Registered
clients without registering as a authorized person of these brokers Period
for Any
Segment
All
Members-
Member is not dealing with more than one member/authorized Audit
g C Registered
person of another exchange for proprietary trading. Period
for Any
Segment
All
Members-
Audit
h Changes in authorized person details are informed to the Exchange C Registered
Period
for Any
Segment
Members-
Registered
There is a monitoring mechanism to identify sudden increase /
Audit for other
i decrease in client level turnover from any specific branch/ C
Period than
Authorised Person location.
Commodit
y Segment
Members-
Registered
Member has submitted AP Inspections report as per the timelines Audit for other
j C
prescribed by the Exchange. Period than
Commodit
y Segment
All
Member has timely reported and provided complete/correct details Members-
Audit
k of clients (UCC) mapped to the Authorised Person as per C Registered
Period
Exchange circulars for Any
Segment
 All
Internal auditor shall verify whether the Member has reported the Refer Members-
l action taken by the Member of APs in case of adverse C Sampling Registered
observations are found by the member in the AP inspections. Criteria 4 for Any
Segment
All
Internal auditor shall verify sample inspection reports of APs Refer Members-
m conducted by the Trading Members for completeness of the C Sampling Registered
indicative scope of AP inspection prescribed by the Exchange. Criteria 4 for Any
Segment
8 Investor grievance handling
All
Member is maintaining a register of investor complaints. Register
Members-
of complaints / grievances contains name of client, UCC details, Audit
a C Registered
date, particulars of complaints, action taken by the member and if Period
for Any
matter is referred to arbitration then the particulars thereof.
Segment
All
Members-
Member has a system of resolution of investor complaints in a Audit
b C Registered
time bound manner. Period
for Any
Segment
All
Members-
A designated email id for investor grievance is created and Audit
c C Registered
informed to the investors and Exchange. Period
for Any
Segment
All
Members-
Complaints received on the designated email ID are being looked Audit
d C Registered
into to address the same. Period
for Any
Segment
All
The member has informed the Stock Exchange/Investor about the Members-
Audit
e actions taken for the redressal of grievances of the investor on C Registered
Period
monthly basis within 7 days of the subsequent month. for Any
Segment
 All
The member has to take adequate steps to resolve the complaints
Members-
within 30 days from the date of receipt of the complaint. Please Audit
f C Registered
provide the details of complaints, if any, pending for more than 30 Period
for Any
days.
Segment
Information about the grievance redressal mechanism as specified All
by SEBI circular SEBI/HO/OIAE/OIAE_IAD-1/P/CIR/2023/135 Members-
Audit
g dated July 31, 2023 (updated as on August 04, 2023) is displayed C Registered
Period
at all the offices of the Member and its Authorised Person(s) for for Any
information of the investors. Segment
The member have created a seperate page on their website for
Investor charter wherein the relevant details provided viz Vision,
Mission, Services Provided by the member, Grievance Redressal All
Mechanism of the Member and Exchange along with the logo of Members-
Audit
h trading member.The link to access the Investor charter is available C Registered
Period
on the home page of the website. Also member has displayed for any
investor charter at the prominent places in the office and provided Segment
a copy of Investor Charter as a part of account opening kit to the
clients, through e-mails/ letters etc.
All
Dissemination of the provisions of the SEBI circular Members-
Audit
i SEBI/HO/OIAE/OIAE_IAD-1/P/CIR/2023/135 dated July 31, C Registered
Period
2023 (updated as on August 04, 2023) on Member’s website. for any
Segment
All
Member has complied with the Escalation Matrix as prescibed by Members-
Audit
j SEBI/Exchanges and updated on website/mobile application of the C Registered
Period
trading member. for any
Segment
All
Member has complied with the mechanism of Online dispute Members-
Member's
k resolution as per SEBI Circular No. SEBI/HO/OIAE/OIAE_IAD- C Registered
Website
3/P/CIR/2023/195 dated December 28, 2023 for any
Segment
9 Maintenance of Books of Accounts
 Prescribed books of accounts/records including Register of
All
securities, Securities holding statements, Exchange wise client
Members-
ledgers, bank books, margin deposit book / records of margin and Audit
a C Registered
client master etc. are maintained as per the specified format Period
for Any
containing the required details and for the stipulated period as per
Segment
regulatory requirements.
All
Members-
Register of securities/ commodities is maintained client wise-scrip Audit
b C Registered
wise/ commodity wise/ contract wise. Period
for Any
Segment
All
All Entries for receipt and payment/transfer of securities & Members-
Audit
c commodities are duly recorded in the register of securities & C Registered
Period
commodities. for Any
Segment
All
Members-
Segment wise/Exchange wise separate books of accounts are Audit
d C Registered
maintained, as applicable as per relevant circulars. Period
for Any
Segment
All
Prior approval has been obtained by member for changes in Members-
Audit
e directors/partners/constitution/trade name. If No, post facto C Registered
Period
application has been submitted to the Exchange for the same. for Any
Segment
Member has obtained prior approval or intimated (as applicable)
All
to Exchange / SEBI, as applicable in case of any change in the
Members-
shareholding/ sharing pattern of the company / LLP, partnership Audit
f C Registered
firm with or without change in control respectively. Period
for Any
If No, post facto application has been submitted to the Exchange
Segment
for the same.
 Prior approval has been obtained in case the member has traded
All
with another member of the Exchange.
Members-
Member has not dealt with / traded with other member of the Audit
g C Registered
Exchange by becoming a constituent or through AP of such other Period
for Any
member or not allowed any other member of the Exchange to be
Segment
their constituent to trade without prior approval of the Exchange.
All
Members-
Member has intimated the Exchange in case they have traded with Audit
h C Registered
member of another stock exchange. Period
for Any
Segment
All
Whether the member has incurred any advertisement expenses
Members-
during the audit period and has complied with the regulations of Audit
i C Registered
obtaining Exchange approval before issuance of all such Period
for Any
advertisements.
Segment
The Member, its Group companies/ third party or its associate has All
not offered any schemes/ leagues/ competitions and has not issued Members-
Audit
j any advertisement for the same. Further, the stock broker has not C Registered
Period
carried out advertisements in which celebrities form part of the for Any
advertisement. Segment
All
Members-
SEBI registration certificate of the Trading Member was displayed Audit
k C Registered
at the location of audit. Period
for Any
Segment
All
Members-
Trading member has not dealt with suspended/defaulter/expelled Audit
l C Registered
members and entities prohibited from accessing market. Period
for Any
Segment
All
Last submitted net worth certificate to the Exchange is correctly Members-
Audit
m submitted. In case of incorrect reporting of Networth is leading to C Registered
Period
shortfall, please specify in remarks. for Any
Segment
 All
Member has not engaged in any activity involving any personal
Members-
financial liability, other than of securities or commodities Audit
n C Registered
derivative or which is connected to or incidental to or Period
for Any
consequential upon securities / commodities business.
Segment
All
Members-
Dividend and other corporate benefits received on behalf of clients Audit
o C Registered
is paid/credited/passed on to the respective clients account. Period
for Any
Segment
As on 31st
December/
Members-
30th June
Registered
Member has maintained Net worth as prescribed by the SEBI of every
for other
p Gazette Notification No. SEBI/LAD-NRO/GN/2022/73 dated C year as
than
February 23, 2022 applicable
Commodit
in the
y Segment
Audit
period
All
Member, its Directors, Promoters, Partners, Principal Officer,
Members-
Compliance Officer and Key Management Persons, are Fit and Audit
q C Registered
Proper Persons as per the criteria specified by Exchange / SEBI Period
for Any
from time to time.
Segment
Member has intimated the details of Politically Exposed Persons
All
(PEP) associated with the member entity in the prescribed
Members-
format.(if applicable). Audit
r C Registered
Member is aware that it shall submitted the details to Exchange as Period
for Any
and when there is change in any of the details of Politically
Segment
Exposed Persons’ (PEP).
Systems & Procedures pertaining to Prevention of Money
10
Laundering Act, PMLA, 2002
All
Members-
Principal officer has been appointed and details of the same or any Audit
a C Registered
change thereafter was intimated to FIU & Exchange Period
for Any
Segment
 All
Designated Director has been appointed and details of the same or Members-
Audit
b any change thereafter was intimated to Financial Intelligence C Registered
Period
Unit(FIU) & Exchange for Any
Segment
All
Members-
The member has adopted and implemented written guidelines Audit
c C Registered
prescribed under PMLA, 2002. Period
for Any
Segment
All
The Member has adequate system in place that allows continuous Members-
Audit
d monitoring of transactions and generates alerts based on set C Registered
Period
parameters for suspicious transactions. for Any
Segment
All
Adequate systems & procedures are in place to scrutinize the Members-
Audit
e alerts for arriving at suspicious transactions and reporting the same C Registered
Period
to FIU. for Any
Segment
All
Members-
Member has adequate systems & procedures in place to ensure Audit
f C Registered
screening of employees while hiring. Period
for Any
Segment
All
Record of transactions, its nature & value and records of reporting Members-
Audit
g made to FIU are maintained and preserved by the member as C Registered
Period
prescribed under Rule 3, 7 & 8 of PMLA. for Any
Segment
All
Members-
Member has ongoing training program for employees so that staff Audit
h C Registered
are adequately trained in AML & CFT procedure. Period
for Any
Segment
 All
Member has taken adequate measures to carry out & document Members-
Audit
i risk assessment to identify, assess and mitigate its money C Registered
Period
laundering and terrorist financing risk. for Any
Segment
All
Member has complied with the requirements of the various FATF Members-
Audit
j public statements and updated UNSC lists which are circulated by C Registered
Period
the exchanges for Any
Segment
Member has complied with the following w.r.t FIU Registration,
All
i. Member has done the online registration with FIU-India and has
Members-
got the FIU Registration no. (FIU-REID). Audit
k C Registered
ii. Whether all reporting entities (REs) (including the Stock- Period
for Any
Brokers) registered in FINnet 1.0 are re-registered themselves in
Segment
FINnet 2.0 module.
All
Members-
Whether all relevant RFIs (Red Flag Indicator) have been Audit
l C Registered
implemented by the member per letter issued by FIU. Period
for Any
Segment
All
Senior management approval has been obtained for starting Members-
Audit
m account relationship with a PEP client or for continuing the C Registered
Period
relationship. for Any
Segment
All
Record of transactions are preserved and maintained in terms of Members-
Audit
n Section 12 of Prevention of Money Laundering Act C Registered
Period
(PMLA),2002. for Any
Segment
All
Members-
Audit
o The AML policy is in line with PMLA requirements. C Registered
Period
for Any
Segment
 All
Members-
AML policy has been updated to reflect recent changes or has Audit
p C Registered
been updated with considerable delay Period
for Any
Segment
Member has maintained updated designated list in electronic form
and names of existing clients are checked from such list. Further,
All
member runs a check on the given parameters on a regular basis to
Members-
verify whether designated individuals/entities are holding any Audit
q C Registered
funds, financial assets or economic resources or related services Period
for Any
held in the form of securities with them and have informed the
Segment
relevant authority in timely manner in the event of any particulars
matched with list of designated individuals / entities
Review of the appointment process of Principal Officer
- Verify internal norms for appointment
- Board of Director’s approval for appointment All
- Role and responsibilities Members-
Audit
r - internal norms for appointment and reappointment C Registered
Period
- Review of the nature and frequency of the reporting done for Any
between the Board or senior management with the Principal Segment
Officer and compliance dept. staff
- Seniority of the Principal Officer within the TM organisation.
Verify the trading member’s policy on appointment of third party /
All
registered intermediary for the purpose of (a) identification and
Members-
verification of the identity of a client and (b) determination of Audit
s C Registered
whether the client is acting on behalf of a beneficial owner, Period
for Any
identification of the beneficial owner and verification of the
Segment
identity of the beneficial owner.
All
Member has ensured that exposure to clients (i.e. open positions,
Refer Members-
Margin received, MTM loss incurred,receipts of funds etc.) is not
t C Sampling Registered
disproportionate to client’s updated financial information
Criteria 2 for Any
(i.e.Income/profit/Net worth of the client).
Segment
 All
Member has complied with the guidance published by FATF
Members-
regarding Risk Based Approach (RBA) for Securities Sector for Audit
u C Registered
effective implementation of revised FATF International Standards Period
for Any
as per Exchange Circulars.
Segment
Names of prospective clients are checked against the names of All
entities/individuals against whom sanctions have been applied and Members-
Audit
v member has a practice of verifying its name of clients with latest C Registered
Period
updated FATF Statements and UNSC list circulated from time to for Any
time Segment
All
Cash Transaction Report and Suspicious Transaction Report is Members-
Audit
w submitted wherever applicable to FIU-IND in the prescribed C Registered
Period
format for Any
Segment
All
Trading member has adopted risk assessment while implementing Members-
Audit
x client due diligence and the same is documented & updated C Registered
Period
regularly as per PMLA guidelines for Any
Segment
All
Members-
Trading member has applied enhanced due diligence measures for Audit
y C Registered
clients categorized as high risk and special category. Period
for Any
Segment
All
Trading member has applied enhanced due diligence measures for Members-
Audit
z clients who are residents of jurisdictions listed in Financial Action C Registered
Period
Task Force (FATF) statements. for Any
Segment
11 Transfer of trades
 Click here
Trades were executed in respective clients account and are not All
to enter
transferred from one client code to another client code or from Members-
data 36
a client code to pro or vice-versa in the back office of the member. C Registered
dates
In case of such transfers, if any specific pattern is observed for Any
across all
instances to be provided in remarks column. Segment
segments
All
All client code modifications were done to rectify a genuine error Members-
Audit
b in entry of client code and no patterns were observed. If any C Registered
Period
pattern is observed, please give details. for Any
Segment
All
Systems are put in place to monitor/ prevent the use of client code Members-
Audit
c modification facility for purposes other than correcting mistakes C Registered
Period
arising out of client code order entry. for Any
Segment
All
The trades modified by the member to the ERROR code have Members-
Audit
d been settled in ERROR account and not shifted to some other C Registered
Period
client code. If not complied, please provide the details. for Any
Segment
All
Members-
Trading Member has a well-documented error policy to handle Audit
e C Registered
client code modifications, approved by their board/management. Period
for Any
Segment
All
Members-
Audit
f Member has maintained Trade Log and Order Log C Registered
Period
for Any
Segment
12 Margin Trading
 Members-
Registered
Member has obtained specific approval from the exchange, in case Audit for other
a C
he is providing margin trading facility to his clients. Period than
Commodit
y Segment
Members-
Registered
Member have clearly segregated client MTF and Non-MTF Audit for other
b C
account/ledger at back-office level Period than
Commodit
y Segment
Members-
Registered
Member has provided MTF facility only for eligible securities as Audit for other
c C
mentioned in the circular Period than
Commodit
y Segment
Members-
Registered
Sufficient margin is collected with appropriate hair cut for funded Audit for other
d C
securities under MTF Period than
Commodit
y Segment
Members-
Registered
Audit for other
e Member has not used more than allowable exposure towards MTF C
Period than
Commodit
y Segment
Members-
Registered
Member has fulfilled minimum networth requirement criteria for Audit for other
f C
MTF during the audit period Period than
Commodit
y Segment
 Members-
Registered
Member has an efficient system for collecting and reporting client
Audit for other
g margin collection to the Exchange for MTF trades C
Period than
Commodit
y Segment
13 Proprietary Trading
All
Refer Members-
If member is doing pro trading, then member has disclosed this
a C Sampling Registered
information to his clients.
Criteria 1 for Any
Segment
All
If member is doing pro trading from multiple locations, the Members-
Audit
b member has obtained prior approval from the Exchange in this C Registered
Period
regard. for Any
Segment
Top 12
All
dates of
Members-
Proprietory losses have been met by the own funds & securities of Proprietary
c C Registered
the Trading Member only losses in
for Any
each
Segment
segment
All
All trades in own account were done in PRO code only and such Members-
Audit
d trades were done through approved terminals at approved C Registered
Period
locations only. for Any
Segment
14 Internet Trading
All
Member has obtained specific approval from the exchange, in case
Members-
he is providing internet trading facility to his clients and Member Audit
a C Registered
has complied with regulatory requirements related to internet Period
for Any
trading.
Segment
15 Execution of Power of Attorney (POA)
 Members-
Registered
Refer
The POA executed with the client (if any) is in the favour of the for other
a C Sampling
member and it is not in favor of any other person. than
Criteria 1
Commodit
y Segment
Members-
The Power of Attorney executed in favour of trading member is Registered
Refer
only limited to the purposes as allowed and adheres to the for other
b C Sampling
Provisions of SEBI circular than
Criteria 1
SEBI/HO/MIRSD/DOP/CIR/P/2020/158 dated August 27, 2020 Commodit
y Segment
Members-
Registered
Refer
The PoA executed does not prohibit operation of trading account for other
c C Sampling
by client(s). than
Criteria 1
Commodit
y Segment
Members-
Registered
Refer
The Member has adopted sufficient internal controls to ensure that for other
d C Sampling
POA is not misutilised. than
Criteria 1
Commodit
y Segment
Members-
Registered
Refer
Flagging of POA has been undertaken in the UCC with respect of for other
e C Sampling
all clients registered after February 13th, 2015 than
Criteria 1
Commodit
y Segment
Member has complied with respect to SEBI circular on Execution
All
of 'Demat Debit and Pledge Instruction' for transfer of securities
Refer Members-
towards deliveries /settlement obligation and pledging/repledging
f C Sampling Registered
of securities with effect from September 01, 2022 and Mutual
Criteria 1 for any
Fund transactions/Tendering shares in open offers with effect from
Segment
November 18, 2022
 All
Trading member has not directly / indirectly compelled the clients
Refer Members-
to execute Power of Attorney (PoA) or Demat Debit and Pledge
g C Sampling Registered
Instruction (DDPI) or deny services to the client if the client
Criteria 1 for any
refuses to execute PoA or DDPI.”
Segment
16 Securities Lending & Borrowing Scheme
Members-
Registered
Member has obtained specific approval from the exchange for Audit for other
a C
offering SLBS. Period than
Commodit
y Segment
Members-
Registered
Member has complied with regulatory requirements related to Audit for other
b C
SLBS. Period than
Commodit
y Segment
17 Other items
Change in Address (registered / correspondence/branch office),
All
contact details (if any) and authorised signatories are carried out
Members-
with intimation to the Exchange by submitting the specified Audit
a C Registered
documents as per the formats and updation in the Exchange portal Period
for Any
is done within 15 working days from the date of such changes
Segment
carried out by the member.
All
Members-
Exchange Market data has not been used other than for legitimate Audit
b C Registered
purposes. Period
for Any
Segment
Member has correctly provided PAN of all their Directors, Key All
Management Personnel and dealers to the Stock Exchanges within Members-
Audit
c the prescribed timelines and any change in those details are C Registered
Period
correctly intimated to the Stock Exchanges within seven days of for Any
such change. Segment
 All
Members-
Adverse comments in Statutory Audit Report of Corporate Audit
d C Registered
Member have been considered. Period
for Any
Segment
In case of submision Aadhar card as a proof during client
All
registration, member have adhered to the Exchange guidelines that
Members-
includes: Audit
e C Registered
a. consent letter Period
for Any
b. Aadhaar card number should be redacted or blacked out or
Segment
masked
Members-
Registered
Audit
f Member has not used MCX / NCDEX Logo/Emblem C for
Period
Commodit
y Segment
Members-
Registered
Audit
g ROC related non - compliances are not observed C for
Period
Commodit
y Segment
Members-
Registered
Comments /observation on any other specific area which is not Audit
h C for
covered under any of the above area of verification. Period
Commodit
y Segment
Members-
Member is not Involved in fund lending/borrowing activities- with Registered
Audit
i the exception of those in connection with or incidental to or C for
Period
consequential upon the commodities business Commodit
y Segment
 Member has discontinued the usage of pool accounts for
transactions in the units of Mutual Funds and ensured the
following. Members-
i. not accept mandates for SIPs or Lumpsum transactions in their Registered
name; Audit for other
j C
ii. accepted cheque payments from investors issued in favor of the Period than
respective SEBI recognized Clearing Corporations or mutual fund Commodit
scheme(s) only. y Segment
iii. not accepted or handled funds or units of investors in their
proprietary accounts or pool accounts in any form or manner.
In case of clients registered for transactions in units of Mutual
Funds on the Stock Exchanges Platforms (demat transactions),
member has ensured the following during client registration. Members-
i. KYC Compliant Registered
ii. FATCA declaration obtained from client. Audit for other
k C
Iii. Ultimate Beneficil Owner (UBO) details obtained in case of Period than
non-individual client. Commodit
iv. Bank account and Demat account details obtained with Third y Segment
Party Validation (TPV)
v. Email id and mobile number obtained.
All
Members-
Audit
l Trading Member has updated the details of KMP to the Exchange. C Registered
Period
for Any
Segment
Members-
Trading member has complied with the provisions related to Registered
Execution Only Platforms for facilitating transactions in direct Audit for other
m C
plans of schemes of Mutual Funds as per SEBI Circular No. Period than
SEBI/HO/IMD/IMD-PoD-1/P/CIR/2023/86 dated June 13, 2023 Commodit
y Segment
All
Members-
Whether Member has placed the disciplinary action letter received Audit
n C Registered
from Exchanges/SEBI before Board for consideration. Period
for Any
Segment
18 Compliances related to Online Bond Platform
 Members-
Registered
The entity has appointed a Company Secretary as a compliance Audit for other
a C
officer Period than
Commodit
y Segment
Members-
Registered
The entity has appointed at least two qualified key managerial
Audit for other
b personnel with experience of at least three years in the securities C
Period than
market
Commodit
y Segment
Members-
The entity has obtained a SEBI Complaints Redress System
Registered
(SCORES)
Audit for other
c authentication and has put in place a well-defined mechanism to C
Period than
address grievances that may arise or likely arise while carrying out
Commodit
OBP operations.
y Segment
Trading Member has establish necessary systems and frame
suitable policies, in writing, for registration of
Members-
users/ investors/ sellers on the OBP, execution of transactions and
Registered
orders, roles and
Audit for other
d responsibilities of investors and sellers, risk management and C
Period than
control, liability
Commodit
framework for OBP, investors and sellers in case of breach of the
y Segment
policies, restrictions
or other requirements that may apply for accessing the OBP
Members-
Member has entered into an agreement in writing where he allows Registered
third party sellers of debt securities to use the OBP to sell such Audit for other
e C
securities, defining inter-se relationship and sets out their mutual Period than
rights, liabilities and obligations relating to such assignments. Commodit
y Segment
 Members-
Registered
The entity shall comply with Know Your Client (KYC) Audit for other
f C
requirements and verify the identity of its investors and sellers Period than
Commodit
y Segment
All Orders with respect to listed debt securities placed on OBP are
Members-
mandatorily routed through the Request for Quote platform (RFQ)
Registered
of the recognised Stock Exchange(s) and settled through the
Audit for other
g respective Clearing Corporations C
Period than
All Orders with respect to debt securities proposed to be listed
Commodit
through a public offering placed on OBP shall be mandatorily
y Segment
routed and settled through the stock exchange mechanism.
Members-
Registered
Trading member has issued order receipt, deal sheet and quote Audit for other
h C
receipt with all the precribed details Period than
Commodit
y Segment
Members-
Registered
The entity shall ensure that investors and sellers are also regularly
Audit for other
i updated on the status of transactions electronically through SMS, C
Period than
email etc.
Commodit
y Segment
Members-
The entity shall ensure compliance with the minimum disclosure Registered
requirements as specified in SEBI circular Audit for other
j C
SEBI/HO/DDHS/DDHS-RACPOD1/P/CIR/2022/154 dated Period than
November 14, 2022 Commodit
y Segment
 The entity undertakes to ensure that its advertisements shall be in Members-
conformity with the Advertisement Code as specified in SEBI Registered
circular nos. SEBI/HO/DDHS/DDHS- Audit for other
k C
RACPOD1/P/CIR/2022/154 dated November 14, 2022 and Period than
SEBI/HO/DDHS/POD1/P/CIR/2023/194 dated December 28, Commodit
2023 y Segment
Members-
Registered
The entity has adequate grievance redress mechanism for redressal
Audit for other
l of grievances of the investors within 30 days from the date of the C
Period than
receipt of the complaint.
Commodit
y Segment
Members-
Entity has a comprehensive risk management framework covering Registered
all aspects of its operations and shall ensure that risks associated Audit for other
m C
with its operations are identified Period than
properly and managed prudently. Commodit
y Segment
Entity has establish appropriate safeguards and procedures to deal Members-
with exigencies like suspension or cessation of trading in debt Registered
securities, cancellation of Audit for other
n C
orders or transactions by the investors and sellers, malfunctions or Period than
erroneous use of its systems by investors and sellers, or other Commodit
unforeseen situations y Segment
Members-
Registered
The entity undertakes to identify and disclose on its OBP, all
Audit for other
o instances of conflict of interest, if any, arising from its transactions C
Period than
or dealings with related parties
Commodit
y Segment
Compliance status of last inspection carried out by SEBI/
19
Exchanges/ Internal Auditor
 All
Member has taken corrective steps to rectify the deficiencies
Members-
observed in the inspection carried out by SEBI. Further whether Audit
a C Registered
Member has complied with the qualifications/violations made in Period
for Any
last SEBI inspection report.
Segment
All
Member has taken corrective steps to rectify the deficiencies
Members-
observed in the inspection carried out by Exchange. Further Audit
b C Registered
Member has complied with the qualifications/violations made in Period
for Any
last Exchange inspection report.
Segment
All
Members-
Member has taken corrective steps to rectify the deficiencies Audit
c C Registered
observed in the latest half yearly internal audit report Period
for Any
Segment
All
Comments of the auditor on any other area or any other Members-
Audit
20 Internal Audit conducted for the Trading member during the C Registered
Period
Audit period for Any
Segment
All
Members-
The last half years Internal Audit Report was placed/ Audit
21 C Registered
approved by the Board/ Proprietor/ partners. Period
for Any
Segment