SEBI INFORMAL GUIDANCE – WHO IS A PRINCIPAL OFFICER FOR THE PURPOSE OF SEBI (INVESTMENT ADVISERS) REGULATIONS, 2013?

Authored by Aishwarya Lakshmi V.M.

Applicant: PayTM Money Limited

Date of the guidance: 09.04.2021

Factual Background:

1. The Applicant is a non-individual SEBI registered Investment Adviser and is also carrying on the business of stock broking and depository participant.

2. The Applicant also offers execution services to its clients inter alia including Asset Management Companies by incurring out-of-pocket expenses, but without getting any commission or brokerage.

3. The Applicant intends to obtain electronic consent from its clients for executing the mandatory agreement as prescribed by SEBI in its Circular dated September 23, 2020.

4. Also, the Applicant intends to appoint an

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