Reply to SEBI on 30-Jun-2020
Name
of the Entity/ Person: Atul
Gandhi CommunicateAtul@Gmail.com
9371331337
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Sl.
No.
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Proposal
Page no para number
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Suggestions
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Rationale
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1
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Overall
comment on regulation environment
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I)
Allow Indian entrepreneurs to do business.
Over
a period SEBI has created so much complex structure of regulations
that SEBI itself is finding difficult to take call on SEBI’s
own consultation paper issued in way back 2016.
Create
simplified, fair and transparent regulation / legal structure for
securities business in India
“Transparency”
is the only way to rise for India
i)
Single law should be applicable to all Intermediaries and
print-tv-online media whether Individual or non individual
ii)
Anyone talking about a stock (whether recommending buy or sales or
not or just talk positively /negatively) should disclose
present
holding,
purchases
/ sale in past one year and
purchases
/ sale in next one year
directly
or through group company / subsidiary / related party
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1)
SEBI is institutionalizing securities market business. More
people should be allowed to do business. Competition is always
welcome. In telecom sector, prior to JIO data was selling at Rs
250 per GB, afterwords it come down Rs 3 per GB. Institutions are
more concerned about their profit over investor. In down market
institution continue to sell SIP.
2)
If you create so much complex regulation environment, business
owner will spend 20% or 30% of their time only on compliance not
on business. Countries with simple legal background can flourish
easily
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2
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3.4.4
page 11
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Be
realistic
Along
with option A & B, “profit share %” should be allowed.
Fees
should be fair and transparent
No
fixed fees restriction like Rs 75000
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Not
every client is willing to give fixed fees or fee on AUM, say IA
advising client having investment of say 100 crore. Say in bull
market client doable his investment money in a year. Now client
is making 100 crore profit and SEBI is asking to charge fee of
Just Rs 75,000 ??
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3
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3.5.2.3
page 15
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Talent
can be criteria to do business in India. Don’t put any net worth
criteria to do business in India
One
lakh is good amount of net worth for individual IA and five lakh
for non individual IA to do business.
In
India parents facilitate (provide shelter – home – pay fees)
to their children for education, as well as help (money or allow
use of their home or office) to children to do business so ,its
preferred to include parents home, office and net worth along with
IA net worth
SEBI
should charge nominal token fees of Rs 5000 towards IA
registration for both Individual or Non Individual IA
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1)
India
has population of over 100 crore. Even after 70 years political
party still talks about removing poverty. Political parties has
not removed poverty from India. Indian business people /
entrepreneurs can overcome poverty. Being free nation people
should be allowed to do business
2)
Number of so called global business / big brands in todays world
are started from small set up like garage back side of home or a
flat. Entrepreneurship is welcome. SEBI has allowed only rich
people / institution to do business in securities market. Money
should not be criteria to do business
3)
Those who got lots of money create business verticals / subsidiary
/ division. And those who have less money should not do business ?
4)
Talent
can be criteria to do business. Indian brands like Narendra Modi
or Sachin Tendulkar or Lata Mangeshkar has not come from rich
family background. What do you think had Indian cricket board said
money is criteria to play cricket ?
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4
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3.5.2.6
page 16
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People
should have liberty to choose legal structure.
Don’t
put any legal restriction to do business
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1)
In era of whatsapp and facebook any one can have few thousand
clients or few hundred crore AUM
2)
People can choose legal structure to do business as per their
convenience
3)
Though TCS one of the early mover in software than Infosys, it got
listed after few years of Infosys
4)
Today, even after 100 + years in business Tata’s are holding
companies under “Trust” legal structure
5)
Allow entrepreneur to choose suitable legal structure
6)
Create simple legal environment
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