Anmol Share Broking Limited RMS Policy INTRODUCTION Risk Management is an intergral part of any orgationisation. We need to deal with various kind of risk like credit Risk, Market Risk, default Risk, liquidity Risk and other risk. In Securities Market, customers have to be alerted with respect to their obligations, open positions, market conditions, Margin requirements, regulatory requirements and steps initiated by brokers in case of changing market situations. With a view to enhance customer knowledge and safeguarding investor interests, Anmol Share has devised a comprehensive Risk Management & Surveillance (RMS) Policy to make sure that customers are aware of criteria based on which Anmol Share monitors risk and initiates actions to safeguard the interest. Regulators are now insisting on new regimes of compliance measures to make sure that risks are recognized and something is to be done about them. Risk Management is the answer and the policy below is the key to effective compliance and comprehensive management of risks. We present below our Risk Management Policy, which is built, with a database that learns from our experience. Many people have contributed towards the development of the practical methods for risk compliance, internal audit processes and procedures that have been built into the current policy. This is a centrally designed and functional system for all the Franchisees and Branches which intelligently takes a decision based on various logic and parameters whether the company is exposed to Risk or not. In case it finds there is a risk, it takes pre-defined actions to curtail/reduce the risk. 1. DEFINITIONS 1.1. Cash - The clear balance available in the customer s ledger account in our books 1.2. Margin- The underlying stake provided by the customer in the form of cash, FDR and/or stock to mitigate market (price) or settlement (auction) risk 1.3. Exposure - The aggregate of the customer s obligations arising out of the buy + sell trades awaiting settlement in the cash segment and profit/loss amounts that are yet to be settled on the closed positions.
1.4. Exposure multiple- The number of times that exposure is allowed on the underlying margin on the cash segment would have to be made either on the availability of cash margin or on the availability of the stocks (which are to be sold) in our margin account, by executing a transfer before any order is initiated. 1.5. Stock qualifying for margin in the cash segment transactions - Securities in the approved list of ASBL. 1.6. Total Deposit- The aggregate of client deposit available with us in the form of cash, shares (after applicable hair cut) and FDR. 2. NATURE OF CUSTOMER TRANSACTIONS 2.1. Intraday Cash Segment: The amount of purchase (or sale) in a scrip on any trading day that is reversed by the end of the day by making a contra sale (or purchase) of exactly the same quantity, thereby nullifying the original position. 2.2. Delivery Trades: The net purchase or sale of scrip in a client account that is settled by way of a delivery on T+2 (or as per settlement schedule). Delivery in respect of sale transactions in the cash segment has to be settled by the client by tendering securities in demat form before the payin deadline, failing which the client faces risk of auction. 2.3. Sell against Buy before delivery: A purchase order executed on the Exchange today and the (undelivered) purchased stock sold in its entirety on the next trading day. In this case the first transaction would be settled on T+2 while the sale would be settled on the third business day after the purchase transaction. Note ASBL is not responsible for any Short payout of security from exchange. 3. RISK MANAGEMENT 3.1. Cash Segment: Normally we provide limit up to 4 times of Available Margin after Haircut if any, which may vary depending upon long term relationship with clients, payment history and volatility in market. In this system total deposit of client is uploaded in system. Now client can take exposure in any scrip(s) (excluding the scrip(s) expressively barred by ASBL). Margin call is made to clients who take delivery positions based on above limits if Margin available with us falls below 30%, the client is asked to make payment or his trade is squared off from Head office or Branch Office after proper communication to him/her.
Example: A client with the following position intends to trade: Particulars Amount (In Rs.) Ledger Balance Credit 50000 Margin Shares before hair cut 100000 Margin Shares after hair cut (VAR Margin 20%) 80000 Total Deposit (50000+80000) 130000 Suppose the client wants to buy XYZ Ltd. Then He will be allowed limit of 520000 (130000*4). In this case we should have minimum Available deposit of Rs 676000 (520000+30%) In case of T2T or Z category stock we provide limit only on Available cash credit with us and no leverage is provided in T2T or Z category Shares. Note: If any client trades in any particular scrip where the volume compared to exchange volume is more than 10%, then our compliance team traces that trade and examines. If the same sounds to be an unusual transaction, then the compliance will send letter to the respective client for certain queries and clarification for their satisfaction and to comply with regulators. 3.1.1. Franchise / Branch wise Margining System: Every branch is started with some security deposit which is initially treated as margin, on the basis of which limit is provided to various clients. After the client has traded and made us the payment, the margin is created automatically and then the margining system can be utilized for providing the limit. For the branch / franchisee clients, the risk of clients belongs primarily to the branch head/ franchisee. Hence, in the worst case scenario, ASBL can withhold the Terminal Margin given by the branch head/ Franchisee to recover the bad debts of the branch / franchisee client. However, such extreme action is taken in rare cases and that too after due intimation and consent of the franchisee. 3.1.2. Communication: Though the client has to be aware about his position and Risk, the branch head/ Franchisee is also responsible to communicate to the client about his shortfalls. ASBL is under no legal obligation to send any formal communication but as a customer centric company we take extra effort to ensure that the client is informed about the Risk and the actions which may follow. The communication would generally be through Telephone / Email subject to the correctness and availability of the data in the system. 3.1.3. Action from HO:
In case of Offline/Online Clients action will be taken on T+5 basis for the Ledger debit irrespective of whether we are in Risk zone or not with respect to the particular client. For example, if the position has been taken on Monday then the selling will happen on Monday, the next week. This condition would not be applicable in PANIC Market Selling. In that case we may ask Clients to square off trade even on T+1 depending upon the volatility in stock price in which client has taken leveraged position. Further, Client will be suspended from Trading by RMS on selling day and suspension would be removed after selling. The selling confirmations will be made available on compliance software. The selling will be done for Debit in his ledger which is due to us from him. 3.2. F & O Segment: Margin: Derivative Segment is Margin driven segment. Margin will be collected under normal/panic conditions as per the requirement of the Exchange. i.e SPAN + Exposure Margin + Additional Margin ( if any made applicable by the Exchange ) For common limit in both Cash and Derivative segments based on actual ledger credit, cash credit will be updated for limits in derivatives also subject to the following conditions:- Client should have traded in derivatives segment in last one year Client should have given PoA Cash ledger amount will be credited in derivatives to the extent of PoA or cash ledger balances whichever is lower. If ledger credit is required in cash segment then request needs to be placed online. 3.2.1. Combination of margins is acceptable in F&O Segment: Typically as per exchange rules, margin can be accepted in cash and shares equally. Only liquid stocks (as acceptable to exchange in F&O Segment) are accepted. F&O Margin which will be accepted after a haircut is applicable as per Exchange. 3.2.2. Communication: Client can view details of his ledger, margin, shortfall etc through his secured login on ASBL website. The client has to be aware about his position, outstanding balance and Risk. The branch head/ franchisee is responsible to communicate to its clients, ASBL is under no obligation legally to send any formal communication but as a customer centric company we do wish to take those extra efforts generally to ensure that client is informed about the Risk and the actions, which will follow. The communication would generally be through Compliance Software, SMS/Email, subject to the correctness and availability of data in the system. 3.2.3. Action from HO:
In case of Offline, action will be taken on T+2 basis for the MTM debit / Margin Shortfall. In case of Online, general client action will be taken on T+3 basis for the MTM debit / Margin Shortfall. 3.2.4. Selling sequence when HO takes action: First the primary Position in F&O Segment will be squared off towards margin shortage. In case of MTM debit, collateral will be sold first to clear the ledger debit and then to the extent of Margin shortage, the position will be sold. Finally Cash Position both lying in debit stock and in DP Account with POA will be sold to clear the Debit. Process for clients who are in Risk due to market conditions:- - Offline: When the Mark to Market reaches 80% of the deposit action can be taken even before the above stipulated dates - Online: When the MTM is 85% of Deposit, position will be squared off. - Those clients will be allowed to take exposure on span margin strictly for intraday only. If on any particular day the client is unable to sq off intraday then he will be only on sq off mode on T+1 day and will not be allowed to create fresh positions on T+1 day. 3.2.5. F & O Market: In case of F & O segment, all the far Month Option contracts and third Month Option Contract (Except Nifty) will not have buy and sell limit due to its illiquid nature, however in all the above cases if the client still wishes to trade then they will need to speak to the respective RM to set the limit, which can be provided on a case to case basis. 3.3. Other Tools Available: 3.3.1. Dormant account: We have a system of identifying the trading done after a long gap. For this precaution is taken and SMS is send to client that he has traded after a long gap of say X no of days. 3.3.2. Simply Buy and Sale: Through this we identify those clients who have traded during a particular period but have not made any cheque transaction. A proper follow up is provided through our surveillance team and due care is taken for avoidance of the same. 3.3.3. Third Party cheque: The bank account of each and every client is updated in our back office software and the same is also printed on the instrument when a cheque is issued so that he cannot deposit the cheque in his other account. Also when a client gives us cheque a due care is taken that he gives us cheque only from the account(s) mentioned in his KYC.
3.3.4. Client Trading statistics: We have a system in our back office through which we can identify whether a client is involved only on delivery or intraday or derivatives transactions. 3.3.5. Cheque Dishonour: We are regularly tracking the clients where cheques are being dishonored regularly. We also have a system in place wherein clients are tracking for short selling on regular basis and which subsequently leads to auction of shares. 3.3.6. Duplicate Demat ID: Clients with duplicate Demat id are taken care off and we have a very good system in place where the same can be avoided. 3.3.7. PAN missing details: No clients are allowed to trade who have not provided us PAN details. 3.4. Other Miscellaneous Steps: Apart from all the above steps, SMS is being sent to clients regarding their trading on daily basis which includes their billing for the day and their net positions. Clients having Debit balance are also being sent SMS regularly, mentioning their debit balance. The SMS for all the cheque receipt and payments are also being sent on daily basis. Emails are also sent to clients on daily basis which contains their ledger and trades. Running Account Settlement of client balances is done on a quarterly basis. Clients also get concurrent SMS of the trades executed in any segment within half an hour time after the trade is executed. 4. OTHER SURVEILLANCE ACTIONS: 4.1. Refusal of order for penny stocks / illiquid contracts: Anmol Share may refuse or restrict a client in placing the order in certain securities depending on various conditions like volume / value / part of illiquid scrip s / Z group of securities although a client may have credit balance or sufficient margin in the trading account. List of such scrip s will be reviewed on a periodical basis and will be updated on Anmol Share website.
However Anmol Share under exceptional circumstances may execute clientele order. Anmol Share has the discretion to reject execution of such orders based on its risk perception. In case of F & O segment, all the far Month Option contracts and third Month Option Contract (Except Nifty) will not have buy and sell limit due to its illiquid nature, However in all above cases if client still wish to trade then the client needs to coordinate with the respective branch and the limit will be set by Head Office after analyzing the requirement. 4.2. Regulatory conditions under which a client may not be allowed to take further position or Anmol Share may close the existing position of the client: In case overall position in a scrip / derivatives contract has reached the Regulators prescribed Exchange limit / Market wide open interest limit / Client level limit, then client may not be allowed to take further positions, till such time Regulators prescribed limit comes down to create a new position. Further Anmol Share may close the existing position of a client to the extent of debit balances to release the margin from the Exchange. In case if Anmol Share has sufficient margin cover on behalf of its clients, it may still decide based on the market conditions and risk perception not to allow further position or may close the existing position of a client. 4.3. PMLA Guidelines: Client will be categorized as High, Medium and Low risk customer as per their risk appetite and their current profile as mentioned in Know your client form (KYC). The same will be reviewed at regular intervals. Exposure to client may also be governed by customer profiling mentioned above as well as clients financial income made available to Anmol Share from time to time. Client needs to furnish their income details on yearly basis. Following documents will be accepted as a income proof Copy of ITR Acknowledgement Copy of Annual Accounts Copy of Form 16 in case of salary income Net worth certificate Salary Slip Bank account statement for last 6 months Copy of demat account Holding statement Any other relevant documents substantiating ownership of assets. If there is a major disparity between financial details and trading volumes, client will be asked to furnish suitable explanation and based on the same further trading limits will be sanctioned. 4.4. Suspension of Clients:
Anmol Share may withhold the payout of client and suspend his trading account due to any internal surveillance (if client indulges into manipulative trade practice) / regulatory orders (debarring orders) / if the client is dormant (not traded > 12 months). *Detailed dormant account policy is separately prepared and is available on the website 5. RESOURCES DEPLOYED 5.1. Manpower: RMS Department is a well-staffed team containing qualified personnel who have been well trained and groomed to deal with branches/ franchisees and clients. The number of branches/ franchisees mapped to a RM varies from 10 to 50 depending upon the experience and capability of Risk Manager. RM is the first point of contact with respect to providing limits and squaring-off the trades. There is also a floor manager who supervises the work of all the RMs. The care of all the escalations and major decisions are taken by the Department Head of the RM team. 5.2. Software: The current software resources used by the RMS department are among the best of its kind in the industry. Currently we are using the NOW software for our risk management system. 6. DISCLAIMER ASBL Management will have a discretion to alter/change any of Exposure limit, selling parameter defined in this policy on the basis of prevailing market conditions with or without prior intimation and can use their discretion to grant any kind of exemption/permission in case they deem fit on case to case basis Important Details: Board line Number: 080-40463100 Email address: info@anmolshare.com Website address: www.anmolshare.com