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Client Policies

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POLICIES AND PROCEDURES
This document from TSL is mandatory as per SEBI Circular No. MIRSD/SE/Cir-19/2009 dated 03.12.2009 and requires your utmost care, attention and understanding.

  • 1. Policy for Penny Stocks:
    TSL Shall have absolute discretion to accept, refuse, or partially accept any buy or sell order for execution from a client in respect of penny stock, illiquid stocks, stocks have low liquidity, illiquid “options”, far month “option”, writing of “options”,stocks in S,Z and B2 category and any other contracts which as per the perception of TSL are extremely volatile or subject to Market manipulation and/or depending on the market conditions.
    TSL shall have the prerogative to place such restrictions, notwithstanding the fact that the client has adequate credit balance or margin available in his account and/or the client had previously purchased or sold such securities / contracts through TSL itself. TSL and/or any of its directors, employees, associates, sub-brokers, will not be held responsible due to losses due to such refusal
  • 2. Setting up Client’s Exposure Limits:

    TSL may from time to time vary limits (exposure limits, turnover limits, limits as to the number, value and/or kind of securities in respect of which orders can be placed etc.) on the orders that the client can place through TSL's trading system. The client is aware and agrees that TSL may need to vary or reduce the limits or impose new conditions for limits urgently on the basis of TSL's risk perception and other factors considered relevant by TSL 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.), and TSL may be unable to inform the client of such variation, reduction or imposition in advance. The client agrees that TSL shall not be responsible for such variation, reduction or imposition or the client's inability to route any order through TSL’s trading system on account of any such variation, reduction or imposition of limits.

    The client further agrees that TSL may at any time, at its sole discretion and without prior notice, prohibit or restrict the client's ability to place orders or trade in securities through TSL, or it may subject any order placed by the client to a review before its entry into the trading systems and 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 TSL/exchange/SEBI and any other reasons which TSL may deem appropriate in the circumstances. The client agrees that the losses, if any on account of such refusal or due to delay caused by such review, shall be borne exclusively by the client alone.

    TSL has margin based RMS system. Total deposits of the clients (Funds and Securities lying with TSL either as Margin or in running account) are uploaded in the system and client may take exposure on the basis of margin applicable for respective security as per VAR based margining system of the stock exchange and/or margin defined by RMS based on risk perception. Any failure on the client’s part in payment of margins shall be viewed seriously and TSL is authorized not to allow the client any further exposure and also authorized to square off client’s existing position/s and/or sell the securities lying with TSL as collateral.

  • 3. The right to sell client’s securities or close client’s open positions:

    Without prejudice to TSL’s other right (Including the right to refer the matter to arbitration), TSL shall be entitled to liquidate/close out all or any of the clients position without giving notice to the client for non payment of margins or other amounts including the pay in obligation, outstanding debts etc. and adjust the proceeds of such liquidation/close out, if any, against the clients liabilities/obligations. The client shall ensure timely availability of funds/securities in form and manner at designated time and in designated bank and depository account(s), for meeting his/her/its pay in obligation of funds and securities. Any and all losses and financial charges on account of such liquidations/closing out shall be charged to & born by the client.

  • 4. Restrictions/Prohibition to take further position or Closing Existing Position:
    Under following circumstances, the client may not be permitted to take any further position by TSL and/or TSL shall close existing position without any further intimation to the client:
    • Failure or delay to meet pay-in or margin obligation on time and/or to clear outstanding dues to TSL.
    • Repeated bouncing of cheques of the client.
    • Unnecessary/unwarranted dispute from client with TSL without any substantial cause/reason.
    • Client’s attitude of not coming to an amicable settlement for any dispute that can be settled without involvement of Exchange and /or SEBI.
    • As per findings of Risk Management department of TSL.
    • Any direction from SEBI/Exchange or such other authorities.
    • Under any such other circumstances as TSL may think just and proper on case to case basis.
  • 5. Temporary Suspending or Closing Client’s Account:
    Client’s Account may be suspended or closed by TSL from further dealing through TSL in following circumstances:
    • As per Client’s prior written request in prescribed format submitted to TSL at its Hyderabad H.O. (subject to clearance of entire outstanding/obligations).
    • Dormant or in-active status of client account beyond specified time limit as may be prescribed by TSL and
    • Under any circumstances mentioned in point no.‘7’.
  • 6. Temporary Suspending or Closing Client’s Account:

    As per TSL’s policy, the account in which no transaction of any nature has taken place during last SIX months shall be considered as Dormant/in-active account. In case TSL treats the account of client as Dormant/in-active account, the funds or securities lying with TSL shall be refunded/returned to clients immediately on demand by the client. In case TSL treats the account of client as dormant/in-active account, and if trade is executed in such account, then it is verified with client over telephone. In order to reactivate the inactive account, client needs to instruct TSL in writing in prescribed format in advance at its Hyderabad H.O. Such written request DULY SIGNED BY CLIENT may also be sent by way of Fax on 040-23541256 to Compliance Officer or by e-mail to compliance department at info@tradewellmail.com from client’s own e-mail account registered with TSL. TSL shall reactivate the said account subject to fulfilment of such conditions as TSL may consider fit and proper.

  • 7. Policy for Client code modification/Error account :

    • TSL shall have the absolute discretion to accept, refuse or partially accept the client code Modification requests based on Risk Perception and other factors considered relevant by TSL; TSL and/or any of its directors, employees will not be held responsible for Damages/losses due to such refusal or due to delay caused by such review.
    • Client code modification requests will be strictly accepted only to rectify genuine error in entry of client code at the time of placing /modifying the related order; consequently dealers are expected to take utmost care/precaution while execution of client trades.
    • As per SEBI circular dated July 5, 2011 on client code modifications, penalty will be levied on all client code modifications w.e.f. August 1, 2011 (including genuine errors).
    • TSL will allow Modifications in the client Codes of Non-Institutional clients only for the following objective Criteria provided there is no consistent pattern in such modifications: Error due to communication and/or punching or typing such that the original client code/name and the modified client code/name are similar to each other. Modification within relatives (Relative for this purpose would mean ‘Relative’ as defined under sec. 6 the Companies Act, 1956).
    • For easy identification of “ERROR ACCOUNT”, TSL have registered a fresh client code No. ERROR as “ERROR ACCOUNT” in Back office & same has been uploaded in the UCC database of the Exchange
    • Any transfer of trade (institutional or non-institutional) to “ERROR ACCOUNT” of TSL would not be treated as modification of client code and would not attract any amount of penalty, provided the trades in “ERROR ACCOUNT” are subsequently liquidated in the market and not shifted to some other client code. However operational costs as applicable & Profit/Loss from the transaction will be transferred to the concerned Dealer/Associate.
    • Client Code Modification requests through “ERROR ACCOUNT” will be accepted only till 3:30 PM IST.
    • All cases of modification of client codes of non-institutional trades executed on the Exchange”, shall be liable for a penalty as laid down by regulators from time to time [As per SEBI Circular No. CIR/DNPD/6/2011 dated July 5, 2011 a penalty of 1% of value of non-institutional trades modified will be levied if value of non-institutional trades modified as a percentage of total value of non-institutional trades executed is less than or equal to 5% and penalty of 2% if modification exceeds 5%, in a segment during a month].
    • In addition to above it is well within rights of TSL to levy additional penalties in case concerned Dealer/Associate fails to submit any sufficiently valid reason for client code Modification.
    • TSL will levy Penalties as applicable in relation to client code modification on next day of the Modification date, though Bills/Files in relation to same may be provided by exchange on a later date.
    • The TSL shall conduct a special inspection of the concerned Dealer/Associate, if modification exceeds 1% of the value of trades executed during a month and take appropriate disciplinary action, if any deficiency is observed.
  • 8. Policy on Pre-Funded Instruments:

    With reference to SEBI Circular No. CIR/MIRSD/03/2011 dated June 9, 2011 the drafted Organization policy on Pre-funded Instrument is as given hereunder:

    • As a general policy Prefunded Instruments are not accepted by TSL & clients are advised to avoid use of pre-funded instruments for making payments. The clients are also educated about the Exchange and PMLA rules & byelaws.
    • The instruments received from clients are checked before depositing the same into bank. If the instrument is identified as Pay Order/DD, then a suitable Reason/clarification in requisite format is required to be obtained from the client.
    • If the aggregate value of pre-funded instruments is Rs. 50,000/- or more per client per day, we may accept the instruments only if the same is accompanied by the name of the bank account holder and number of the bank account debited for the purpose, duly certified by the issuing bank. The mode of certification may include the either of the following:
      • Certification from the issuing bank on its letterhead or on plain paper with the seal of the issuing bank.
      • Certified copy of the requisition slip (portion which is retained by the bank) to issue the instrument.
      • Certified copy of the passbook/bank statement for the account debited to issue the instrument.
      • Authentication of the bank account number debited and name of the account holder by the issuing bank on the reverse of the instrument.
    • The details of the instrument must be tallied with the detail provided by the clients in KYC before entering into back office software. In case of mismatch is identified, it should be reported to department head/ Management/ key personnel’s for taking appropriate action.

  • 9. Policy for Dormant/In-active account:
  • As per TSL’s policy, the account in which no transaction of any nature has taken place during last SIX months shall be considered as Dormant/in-active account. In case TSL treats the account of client as Dormant/in-active account, the funds or securities lying with TSL shall be refunded/returned to clients immediately on demand by the client. In case TSL treats the account of client as dormant/in-active account, and if trade is executed in such account, then it is verified with client over telephone. In order to reactivate the inactive account, client needs to instruct TSL in writing in prescribed format in advance at its Hyderabad H.O. Such written request DULY SIGNED BY CLIENT may also be sent by way of Fax on 040-23541256 to Compliance Officer or by e-mail to compliance department at info@tradewellmail.com from client’s own e-mail account registered with TSL. TSL shall reactivate the said account subject to fulfilment of such conditions as TSL may consider fit and proper.

NOTE : TSL hereby states and informs that it undertakes Proprietary trading in addition to client based trading.

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