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Most Important Terms & Conditions (MITC)

Fees, consent, records, refunds, and the do's and don'ts.

Important disclaimer

The SEBI registration, enlistment with RAASB and NISM certification do not guarantee the performance of the research analyst or assure any returns to the client.

Annexure A — Most Important Terms and Conditions

  1. These terms and conditions, and consent thereon, are for the research services provided by the Research Analyst (RA), and the RA cannot execute or carry out any trade (purchase or sell transaction) on behalf of the client. Clients are advised not to permit the RA to execute any trade on their behalf.
  2. The fee charged by the RA to the client will be subject to the maximum amount prescribed by SEBI / Research Analyst Administration and Supervisory Body (RAASB) from time to time (applicable only for individual and HUF clients).
    • 2.1. The current fee limit is ₹1,51,000 per annum per family of client for all research services of the RA.
    • 2.2. The fee limit does not include statutory charges.
    • 2.3. The fee limits do not apply to a non-individual client or an accredited investor.
  3. The RA may charge fees in advance if agreed by the client. Such advance shall not exceed the period stipulated by SEBI; presently it is one quarter. In case of premature termination of the RA services by either the client or the RA, the client shall be entitled to seek refund of proportionate fees only for the unexpired period.
  4. Fees to the RA may be paid by the client through any of the specified modes such as cheque, online bank transfer or UPI. Cash payment is not allowed. Optionally, the client can make payments through the Centralized Fee Collection Mechanism (CeFCoM) managed by BSE Limited (the currently recognised RAASB).
  5. The RA is required to abide by the applicable regulations, circulars and directions specified by SEBI and RAASB from time to time in relation to disclosure and mitigation of any actual or potential conflict of interest. The RA will endeavour to promptly inform the client of any conflict of interest that may affect the services being rendered.
  6. Any assured, guaranteed or fixed-return scheme, or any other scheme of a similar nature, is prohibited by law. No scheme of this nature shall be offered to the client by the RA.
  7. The RA cannot guarantee returns, profits, accuracy or risk-free investments from the use of the RA's research services. All opinions, projections and estimates of the RA are based on analysis of available data under certain assumptions as of the date of preparation or publication of the research report.
  8. Any investment made based on recommendations in research reports is subject to market risks, and recommendations do not provide any assurance of returns. There is no recourse to claim any losses incurred on investments made based on the recommendations in the research report. Any reliance placed on a research report provided by the RA shall be as per the client's own judgement and assessment of the conclusions contained in it.
  9. The SEBI registration, enlistment with RAASB and NISM certification do not guarantee the performance of the RA or assure any returns to the client.
  10. For any grievances:
    • Step 1: The client should first contact the RA using the details on this website, or on +91 62666 59514 · info@posaresearch.com.
    • Step 2: If the resolution is unsatisfactory, the client can also lodge grievances through SEBI's SCORES platform at scores.sebi.gov.in.
    • Step 3: The client may also consider Online Dispute Resolution (ODR) through the Smart ODR portal at smartodr.in.
  11. Clients are required to keep contact details, including email id and mobile number, updated with the RA at all times.
  12. The RA shall never ask for the client's login credentials or OTPs for the client's trading account, demat account or bank account. Never share such information with anyone, including the RA.

Annexure B — Disclosure of mandatory terms and conditions

In compliance with the SEBI circular dated 8 January 2025, research analysts are required to maintain records of interactions with all clients (including prospective clients prior to onboarding), where any conversation related to the services has taken place, in the form of:

  1. a physical record written and signed by the client;
  2. telephone recordings;
  3. email from a registered email id;
  4. a record of SMS messages;
  5. any other legally verifiable record.

Such records begin with the first interaction and continue until completion of the research services. Research analysts are required to maintain these records for five years; where a dispute is raised, records are maintained until resolution, or as further specified by SEBI.

Standard terms of service

The consent of the client shall be taken on the following understanding:

"I / We have read and understood the terms and conditions applicable to a research analyst as defined under regulation 2(1)(u) of the SEBI (Research Analyst) Regulations, 2014, including the fee structure. I / We are subscribing to the research services for our own benefit and consumption, and any reliance placed on the research report provided by the research analyst shall be as per our own judgement and assessment of the conclusions contained in the research report. I / We understand that — (i) any investment made based on the recommendations in the research report is subject to market risk; (ii) recommendations in the research report do not provide any assurance of returns; (iii) there is no recourse to claim any losses incurred on the investments made based on the recommendations in the research report."

Termination & refund

The RA may suspend or terminate research services on account of suspension or cancellation of the registration of the RA by SEBI, and shall refund the residual amount to the client. In case of cancellation by the client, NIL refund shall be provided. In case of suspension of the RA's certificate of registration for more than 60 days, or cancellation of the RA registration, the RA shall refund fees on a pro-rata basis for the period from the effective date of cancellation or suspension to the end of the subscription period.

Mandatory notice — do's and don'ts

Clients are requested to go through the do's and don'ts while dealing with a research analyst, as specified in SEBI master circular SEBI/HO/MIRSD-POD-1/P/CIR/2024/49 dated 21 May 2024, or as may be specified by SEBI from time to time.

Who to contact

Compliance & grievancesinfo@posaresearch.com · +91 62666 59514
Registered officeShop No. M-26, 2nd Floor, Mapple High Street, Narmadapuram Road, Bhopal, Madhya Pradesh, India
EscalationSEBI SCORES · scores.sebi.gov.in · ODR smartodr.in

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