21-Jun-2024
To,
All Registered Investment Advisers
Sub: Submission of Periodic reporting by Investment Advisers
This is in continuation to BASL circular no. 20240606-1 dated 06th June 2024 in the captioned matter.
The following changes are being carried out in consultation with SEBI:
- The timeline for submission of periodic report for the period ending on March 31, 2024 is extended to 45 days from the date of this circular. The due date for submission is 5th Aug 2024. The process manual is attached as Annexure 1.
- For the subsequent half-yearly periods, the IAs shall submit periodic reports within 15 days from the end of the respective period.
- In the table named “Details of clients, Assets under Advice and Fees for the half year ended on….” modifications to the format pointers w.r.t –
- Point no. 5 i.e. “Maximum number of client agreements in force on a single day during the period’ is renamed as “Maximum number of client agreements in force on a single day during the period (Applicable to Individual IAs only)”. This field is to be filled only by Individual IAs.
- Further, in the same point bifurcation with respect the category of clients into Resident, Non-Resident and FPI will not be required, only total number of clients to be provided in last column i.e total column.
- Point no. 8 i.e “Number of clients who are Accredited Investors” is renamed as “Number of clients who are Accredited Investors at the end of the period”.
FAQs on submission of periodic reporting is attached as Annexure 2.
All Investment Advisers are requested to take note and comply.
For and on behalf of BSE Administration & Supervision Ltd.
Neeky Subramaniam Diksha Jha
Associate Manager Senior Officer
Annexure 1
USER MANUAL FOR SUBMISSION OF PERIODIC REPORTING
1. Login into BASL Portal using your credentials on the link.
https://membership.bseasl.com/
2. Enter your credentials and click and login.
3. Click on “Compliance Reporting” and sub menu “Periodic Reporting”.
4. Click on download BASL periodic excel utility as shown below.
5. Select the half year for which the filing is being done.
(Please note that the same period has to be selected in the excel file as well)
6. Please read the instructions carefully provided in the Index sheet of the downloaded excel.
7. Post ensuring the system configuration required, start filling the excel sheet.
8. Fill the General Details sheet. While filling details in the General Details sheet, Row no’s 13,14,15,16, 21,22, 24, are rows with additional information to be filled.
9. If the said field is not applicable, then do not click on the tick box “do you have” option.
10. Click on tick box “Do you have” option if you have respective details to be added and then click on “Add Option”.
11. “Add Option” on which you will be redirected to different sheets.
12. Add the no. of rows to be added and validate the sheet after filling the details.
13. After filling all the additional details of General details page, validate the general details sheet.
14. Once general details sheet is validated, start filling details of Complaints sheet.
15. In the details of complaints sheet, Additional information has to be filled in row 7. And follow the same steps mentioned in points 8,9,10,11 in the user manual.
16. Add the no. of rows to be added and validate the additional sheet after filling the required details.
17. After filling all the additional details of Details of complaints sheet, validate the details of Complaints sheet.
18. Now start filling details of Client sheet and add the additional information has to be filled in row 9 and validate the sheet. And follow the same steps mentioned in points 8,9,10,11 in the user manual.
19. Validate the details of client’s sheet.
20. Post validating all the sheets.
21. Validate all option has to be clicked in the general Details sheet.
22. Now upload the sheet in the portal.
23. Upload the file in the BASL portal in “upload Excel” file option.
24. Once the application is submitted check the status of your application under My Application.
Annexure 2
Yes. All IAs whose SEBI registration and BASL membership is active as on 31st March and 30th September respectively, are required to submit the half yearly periodic report.
No. Submission of periodic reporting through mails will not be accepted. Half yearly periodic reporting has to be submitted only through RIA Member login on www.bseasl.com.
Yes. BASL Portal will be open for submission of periodic reporting for all IAs whose SEBI registration and BASL membership is active as on 31st March and 30th September respectively.
For 1st reporting period i.e. as on 31/03/2024 – from 21st June 2024 to 5th Aug 2024
For 2nd reporting onwards – within 15 days of the half year ended 31st March and 30th September.
Part A – FAQs related to General Details
Yes. Registered Name and Trade Name / Brand Name can be same in some cases.
However, in cases where Registered Name and Trade Name / Brand Name are not same, IA to submit data as below:
- Name as registered with SEBI / BASL to be given as Registered Name.
- Name as registered with GST to be given as Trade Name. Registered name and Trade name can be same.
- Brand name is the name an IA uses to advertise apart from its Registered name or trade name. Brand name and Trade name to be given in the same field separated by “/” in case both names are different.
No. Reporting as part of periodic submission will not amount to an intimation of material change to SEBI / BASL.
IAs are required to intimate BASL for any material changes carried out along with the relevant checklist on the email ID-[email protected].
The checklists are available on the following link- https://www.bseasl.com/memb_registration.html.
IAs can click on TICK BOX button provided against respective fields in the excel file, post which respective sheets will be activated. IAs can input relevant details in these sheets.
In case if IA does not have any data, they need NOT CLICK on TICK BOX button against each respective fields in the excel file.
IAs to note that at least 1 bank account details to be provided mandatorily.
Yes. If Principal Officer or Compliance Officer are also designated as contact person, then IAs can submit the same.
IAs to enter the date of visit of BASL inspecting officer in “Period of inspection” field. Also note that in such cases “Date of Inspection” and “Period of inspection” will be same.
IAs to provide only unique advertisements numbers issued during the reporting period even if the same advertisement is issued on multiple social media handles/ websites. For e.g. If same advertisement is issued on Facebook, Instagram, YouTube, Telegram- such advertisement will be counted as single advertisement for the purpose of reporting this data.
This number can vary from the number of Advertisements approved by IAASB during the half year period.
PART B - FAQs related to Complaints Details
IAs need to click on TICK BOX button to enter complaint reasons other than those specifically mentioned in point no. 7. The total count of such complaints is to be entered against point no. 7 sub point “Other (please specify)” in complaints details sheet.
In case if IA does not have complaints pertaining to “Other (please specify)” then they can mention “0” (ZERO) in complaints details sheet WITHOUT clicking on TICK BOX button.
IAs to provide one complaint under only one category. In case a complaint has multiple categories, then IA to include such complaints under the category which fits the most.
Complaints received from clients other than through SCORES portal has to be considered under “Complaints from other sources” category.
PART C – FAQs related to Client Details
IA to enter maximum number of clients whose agreement were active on any single day during the reporting period.
IAs need to click on ADD button to enter multiple other products which are regulated by SEBI such as AIF, PMS etc other than those specifically mentioned in point no. 9. The total amount of such products is to be entered against point no. 9 sub point “Other SEBI regulated products (Please specify)” in client details sheet.
In case if IA does not have products pertaining to “Other SEBI regulated products (Please specify)” then they can mention “0” (ZERO) in client details sheet WITHOUT clicking on TICK BOX button.
IAs need to click on ADD button to enter multiple other products which are not regulated by SEBI such as Corporate Fixed Deposits, etc. The total amount of such products is to be entered against point no. 9 sub point “Other investment products under purview of other financial sector regulators (Please specify)” in client details sheet.
In case if IA does not have products pertaining to “Other investment products under purview of other financial sector regulators (Please specify)” then they can mention “0” (ZERO) in client details sheet WITHOUT clicking on TICK BOX button.
(Please note: If an IA has considered these products {“Other investment products under purview of other financial sector regulators (Please specify)”} in calculation of AUA for the purpose of charging fees then AUA details for such products to be provided by IAs.)
Foreign Portfolio Investor (FPI) means a person as defined under Regulation 2(j) of SEBI (Foreign Portfolio Investors) Regulations, 2019.
