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POLICIES AND PROCEDURES AS PER SEBI CIRCULAR NO. MIRSD/ SE/CIR-19/2009 DATED 3 DEC, 2009 POLICIES AND PROCEDURES:

1.     Refusal of orders for penny stocks:

Stock broker is advising to the clients not to deal in penny securities and if client deals with the penny stocks, 100% margin will be taken from the client and these shares will not be taken to as Margin deposit. The stock broker shall have authority from time to time limit(quantity/value) orrefuseordersin oneormore securities due to various reasons including market liquidity, value of security(ies) or may require compulsory settlement/advance payment of expected settlement value/ delivery of securities for settlement prior to acceptance / placement of order(s) as well, the order being for securities which are not in the permittedlistofthestockbroker/ exchange(s)/SEBI or does not commensurate with the risk profile of the client as assessed by the broker. Decision of Broker will be binding on the client and will be final.

2.    Setting Up Client's Exposure Limits:

The client agrees to abide by the exposure limits, if any, set by the stock broker or by the Exchange or Clearing Corporation or SEBI from time to time. The client is aware and agrees that the stock broker may need to vary or reduce or impose new limits urgently on the basis of the stock broker's risk perception, risk profile of the client and other factors considered relevant by the stock broker including but not limited to limits on account of exchange/ SEBI directions/ limits (such as broker level/ market level limits in security specific / volume specific exposures etc.).
The stock broker may be unable to inform the client of such variation, reduction or imposition in advance. The client agrees that the stock broker shall not be responsible for such variation, reduction or imposition orthe client'sinability toroute anyorder throughthe stock broker's trading system on account of any such variation, reduction or imposition of limits. Sometimes client's sauda may go to IOC (Immediate or Cancel) instead of normal bidding if broker terminal is on square off mode.
The Stock Broker at its sole discretion can give extra exposure or intraday limit to the client, such extra exposure will automatically be squared off by trading mechanism without any further reference to the client appx. 15 minutes before the scheduled closing.

3.    Applicable Brokerage Rate:

a.   For Cash Market Segment:
The maximum brokerage chargeable in relation to trades effected in the securities admitted to dealings on the Capital Market segment of the Exchange shall be 2.5 % of the contract price exclusive of statutory levies. It is hereby further clarified that where the sale / purchase value of a share is Rs. 10/- or less, a maximum brokerage of 25 paise per share may be collected.

b.  For Option contracts:
Brokerage for option contracts would not exceed Rs. 100/- per lot single side or such other rates as provided by the exchanges.


4.    Imposition of penalty/delayed payment charges by either party, specifying the rate and the period (This must not result in funding by the broker in contravention of the applicable laws)

Client shall be liable to penalty and other charges on nonpayment of margin money, short selling of securities or units, failure on payment of auction, cheque bounce, non delivery of shares, increase open position or on any orders / trades / deals / actions of the client which are contrary to this agreement / rules / regulations / bye laws of the exchange or any other law for the time being in force as per Rules, Regulations, Guidelines and Circulars issued by SEBI and stock exchange time to timeand clientwill bekept informedabout therate of such penalties & fines. Similarly in case of non receipt of full payment of value of delivery purchased, margin imposed (initial + MTM) interest will be charged at 21% p.a. calculated on daily basis on shortfall amount till the date of actual realization of money. All fines/penalties and charges levied upon the Client due to its acts / deeds or transactions will be recovered by the Stock Broker directly from the client's account.

5.    The right to sell clients' securities or close clients' positions, without giving notice to the client, on account of non-payment of client's dues (This shall be limited to the extent of settlement/ margin obligation)

  1. If payment/securities towards the  Margin  or shortfall in Margin is not received instantaneously to enable restoration of sufficient Margin in the Client's account.
  2. In case of benefit of margin will be given only after realization of instrument..
  3. If  the   client  gives   orders  /  trades   in   the anticipation  of the  required  securities  being available   subsequently   for   pay   in   through anticipated payout from the exchange or through borrowings or any off market delivery(s) and if such anticipated availability does not materialize in actual availability of securities / funds for pay in for any reason before the close of market.
  4. The stock broker has the right but not the obligation, to cancel all pending orders and to sell/close/liquidate all open positions/ securities / shares at the pre-defined square off time or when Mark to Market (M-T-M) percentage reaches or crosses stipulated margin percentage mentioned on the website, whichever is earlier, similarly all transactions outstanding under limit by whatsoever name called may be closed out at specified time if not squared off by the client.
    1. In  case  open   position   (Le.  short/long)  gets converted into delivery due to non square off because of any reason whatsoever, the client agrees to provide securities/funds to fulfill the payin obligation failing which the client will have to face auctions or internal close outs; in addition to this the client will have to pay penalties and charges levied by exchange in actual and losses, if any.
    2. Any reference in these terms to sale or transfer of securities by the Stock Broker shall be deemed to include sale of the securities which form part of the Margin maintained by the Client with the Stock Broker.

6.    Shortages in obligations arising out of internal netting of trades

The policy and procedure forsettlement of shortages in obligationsarisingoutof internalnettingoftradesis as under:

a.  The short delivering client is debited by an amountequivalentto20%aboveofclosing rate of day prior to Pay-in/Payout Day. The securities delivered short are purchased from market on T + 3 day which is the Auction Day on Exchange, and the purchase consideration (inclusive of all statutory taxes & levies + 5 % extra) is debited to> the short delivering seller client along with reversal entry of provisionally amount debited earlier.

b.     If securities cannot be purchased from market due to any force majeure condition, the short delivering seller is debited at the closing rate on T + 3 day or Auction day on Exchange +10%. Where the delivery is matched partially or fully at the Exchange Clearing, the delivery and debits/ credits shall  be as per Exchange Debits and Credits after deducting exchange penalties.

c.    In cases of securities having corporate actions all cases of short delivery of cum transactions which cannot be auctioned on cum basis or where the cum basis auction payout is after the book closure / record date, would be compulsory closed out at higherof I0%above theofficial closingprice on theauctionday   orthehighest   tradedpricefrom first trading day of the settlement till the auction

7.    Conditions under which a client may not be allowed to take further position or the broker may close the existing position of a client.

The stock broker may refuse to execute / allow execution of orders due to but not limited to the reason of lack of margin / securities or the order being outside the limits set by stock broker / exchange/ SEBI and any other reasons which the stock broker may deem appropriate in the circumstances.

  1. Fornon-payment orerosion ofmargins orother amounts, outstanding debts, etc. and adjust the proceeds of such liquidation / close out, if any, against the client's liabilities/obligations.
  2. Any   order   which   is   executed   without   the required Margin in the Client's account or the brokers exposure is more than 90% and above so no fresh trade will betaken.
  3. The client hereby authorizes the Stock Broker to square up all his outstanding positions at the discretion of the Stock Broker, which are not marked for delivery 15 minutes before the closing time of the normal market or if the client's margin is evapourated by 90% in any of exchanges, reserves the right to square off positions.
  4. Under certainmarket conditions,it may be difficult or impossible to liquidate a position in the market at a reasonable price or at all, when there areno outstandingorders eitheron thebuy side or the sell side, or if trading is halted in a security due to any action on account of unusual trading activity or stock hitting circuit filters or for any other reason as prescribed or instructed by SEBI.
  5. The stock broker is entitled to disable / freeze the account or trading facility / any other service if, in the opinion of the stock broker, the client has committed crime, fraud or has acted in contradiction of this agreement or / evade / violate any laws, rules, regulations, directions of a lawful authority whether Indian or foreign or if the stock broker so apprehends.
    y profit/loss arising out of these transactions shall be at the risk of and borne by the client.


8. Temporarily suspending or closing a client's account at the client's request Client may instruct the member to close out the account or suspend the trading through client's account for the period as specified in the request in written and duly signed by him. The stock broker can with hold the payouts of client and suspend his trading account due to his surveillance action or judicial or / and regulatory order/action requiring client suspension.

9. Policy regarding treatment of inactive accounts:

When Trade is not done in an account for more than 6 months, Stock Broker reserves the right to temporarily suspend the operations. The Management may allow operations   in   such   account   after   making   such verification   as   it   deems   fit.   The   balance   of securities/funds will be transferred to client after due verification.

10. Deregistering a client

A client is at liberty to deregister himself/ itself from the member. For that purpose client will be liable first to settle his account in full. In case of any shortfall or any dues or payment remaining after adjusting the margin account, the client will be liable to make payment of the same.Andincaseofsurplusarisingoutafternettingof account, client shall be entitled to receipt of the same. The member shall also have power to deregister the client after settling his account at its sole discretion.
 
 
In case of any grievances please write to clientnse@adroitfinancial.com,investorgrievance@adroitfinancial.com
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