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The Board found the Noticee guilty of violating regulation 13(b) read with 13(a) of the IA Regulations and clauses 1, 5, and 8 of the Code of Conduct under the Third Schedule by failing to update material information and conducting unregistered investment advisory activities through two partnership firms. Although the Designated Authority (DA) viewed the non-updation as a technical violation and recommended no cancellation, the Board disagreed, noting the Noticee's engagement in advisory services prior to registration and prolonged unregistered activities over two years as aggravating factors. The Board rejected the Noticee's police complaint defense and the DA's recommendation against suspension. Considering the gravity of the violations and despite mitigating factors like cessation of activities and fee refunds, the Board imposed a six-month suspension of the Noticee's registration as an Investment Adviser, deeming it proportionate and necessary to uphold regulatory compliance.
The Board found the Noticee guilty of violating regulation 13(b) read with 13(a) of the IA Regulations and clauses 1, 5, and 8 of the Code of Conduct under the Third Schedule by failing to update material information and conducting unregistered investment advisory activities through two partnership firms. Although the Designated Authority (DA) viewed the non-updation as a technical violation and recommended no cancellation, the Board disagreed, noting the Noticee's engagement in advisory services prior to registration and prolonged unregistered activities over two years as aggravating factors. The Board rejected the Noticee's police complaint defense and the DA's recommendation against suspension. Considering the gravity of the violations and despite mitigating factors like cessation of activities and fee refunds, the Board imposed a six-month suspension of the Noticee's registration as an Investment Adviser, deeming it proportionate and necessary to uphold regulatory compliance.
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