Annual Compliance Audit Report
Audit of Research Analyst compliance for the financial year 2024–2025 in accordance with SEBI (Research Analyst) Regulations, 2014 and applicable SEBI/BSE circulars.
Audit Overview
The statutory annual compliance audit for Dream Trade's Research Analyst registration reviewed books of accounts, compliance records, and operational processes against SEBI (Research Analyst) Regulations, 2014 and relevant SEBI/BSE circulars for FY 2024–2025.
- Audit confirms that required books, records, and documents are properly maintained as per regulatory standards.
- The Research Analyst is found compliant with SEBI Act, RA Regulations, and applicable BSE circulars.
- No direct or indirect conflict of interest identified with the Research Analyst beyond the scope of this assignment.
- Client-level segregation certificate confirms no distribution activity for research clients.
Key Facts (FY 2024–2025)
- Entity Type: Individual Research Analyst
- Name: Sagar Balasaheb Shelar
- SEBI Registration: INH000017611
- BSE Enlistment: 6307
- Principal Officer: Sagar Shelar
- Phone: +91 97671 57519
- Email: shelarsagar1997@gmail.com
- Total Clients: 17 (as on 31-03-2025)
- Segregation: ✓ Compliant
- KYC Records: ✓ Maintained
📋 Certificate for Annual Audit Compliance
We have examined the relevant books of accounts, records and documents maintained by Mr. Sagar Balasaheb Shelar, bearing SEBI registration number INH000017611 and a member of the BSE Ltd. bearing BSE Enlistment No. 6307 to fulfil the Annual Audit Compliance requirement as prescribed vide SEBI (Research Analyst) Regulations, 2014, guidelines and circulars, for the year ended 2024-2025.
Purpose of Audit: To examine the processes, procedures followed, and the operations carried out by the Research Analyst as per the applicable Acts, Rules, Regulations, Byelaws and Circulars prescribed by SEBI and BSE.
Audit Scope: Conducted within the framework provided by SEBI/BSE for the purpose of this audit. Based on scrutiny of relevant books of accounts, records and documents, the member has complied with the relevant provisions of SEBI Act, 1992, SEBI (Research Analyst) Regulations, 2014 and various circulars of SEBI & BSE except otherwise mentioned in the Annexure to this report.
✅ Compliance Status Summary
All regulatory requirements reviewed and documented:
| Regulation / Circular | Requirement | Status |
|---|---|---|
| Regulation 3 | Application for grant of certificate | Complied |
| Regulation 6 & 7 | Eligibility criteria & Qualification Requirements | Complied |
| Regulation 8 | Net worth requirement & Deposit requirement | Complied |
| Regulation 13(ii)-(iv) | Conditions of certificate | Complied |
| Regulation 14 | Enlistment with RAASB | Complied |
| Regulation 15(1) & (2) | Internal policies & procedures; Independence of research | Complied |
| Regulation 15A | Fees for Research services | Complied |
| Regulation 16(3)-(6) | Limitations on trading by research analysts | Complied |
| Regulation 17 | Compensation of research analysts | Complied |
| Regulation 18(1), (4)-(5), (7)-(8) | Publication & conduct of business restrictions | Complied |
| Regulation 19 & 19A | Disclosures in research reports & Website | Complied |
| Regulation 20 | Contents of research report | Complied |
| Regulation 22 | Distribution of research reports | Complied |
| Regulation 24 | General Responsibility | Complied |
| Regulation 25 | Maintenance of records | Complied |
| Regulation 26B | Redressal of investor grievances | Complied |
| SEBI/HO/MIRSD/MIRSD-PoD-1/P/CIR/2025/004 | Client Level Segregation - Research & Distribution | Complied |
| SEBI Circular - Master Circular 2024/49 | Conflict of Interest, Data Access, AML/CFT, Reporting | Complied |
🔐 Client Level Segregation Certificate
Annual certificate confirming compliance with the client level segregation requirements as specified in Regulation 26C of the SEBI (Research Analyst) Regulations, 2014
Segregation Compliance Confirmations:
- RA has not provided any distribution services to clients receiving research services
- No family member of RA is engaged in distribution services to clients availing research services
- RA has not rendered research services to any client receiving distribution services from a family member
- Appropriate processes are in place to ensure client-level segregation between research and distribution activities within the family
- New clients eligible to avail either research or distribution services (option provided at on-boarding)
- Existing clients allowed to continue with current arrangements without forced liquidation
- PAN of each client recorded for identification and segregation purposes
- Individual clients' family members reckoned as single client unit with joint and several PANs
- Dependent family members identified as those whose assets originate from single earning entity
- Clients provide annual declarations regarding family status
📚 Qualification & Certification Requirements
NISM Certification Requirements (as per SEBI Circular 2025/004):
- NISM-Series-XV: Research Analyst Certification Examination - ✓ Obtained
- NISM-Series-XV-B: Research Analyst Certification (Renewal) Examination - ✓ Valid
- All persons associated with research services maintain required certifications
- Compliance with revised qualification requirements (exemption for existing individual RAs)
- Continuation compliance with SEBI/BSE certification guidelines
📝 KYC & Record Maintenance
Know Your Customer (KYC) Compliance Status:
- KYC procedures followed for all fee-paying clients as per SEBI requirements
- Comprehensive KYC records maintained for all 17 active clients
- Client information systematically documented and organized
- Audit trail for all client transactions and interactions maintained
- Digital and physical records securely stored with access controls
- Regular backups and disaster recovery procedures implemented
- Data protection measures in compliance with applicable laws
- Segregation of records between research and distribution activities
- Client consent documentation properly maintained and updated
- Compliance with Regulation 25 - Maintenance of records requirements
⚙️ Internal Policies & Procedures
Regulatory Compliance Mechanisms (Regulation 15):
- Written internal policies and control procedures governing dealing and trading
- Appropriate mechanisms ensure independence of research activities from other business
- Proper documentation basis for preparing research reports (Regulation 18-7)
- No promise or assurance of favourable review as consideration for business
- Research reports consistent with independence standards (Regulation 18-9)
- Adequate disclosure in research reports (Regulation 19)
- Functional website with prescribed details maintained (Regulation 19A)
- Distribution of research reports without selective advance availability (Regulation 22)
- Third party research report review and conflict disclosure process
- Compensation of research analysts compliant with Regulation 17
📋 Auditor Details
| Auditor Name: | CS Megha Kyal |
| Organization: | Megha Kyal & Associates |
| Designation: | Practicing Company Secretary |
| Certificate Number: | 22896 |
| UDIN: | F013680G001373709 |
| Address: | 127, Hilton Center, Near Belapur Station, Belapur, Navi Mumbai – 400614 |
| Email: | mail@csmeghakyal.in |
| Phone: | +91 98197 28359 |
| Certificate Date: | 29 September 2025 |
| Place: | Navi Mumbai |