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In no event will we be liable for any loss or damage including without limitation, indirect or
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being temporarily unavailable due to technical issues beyond our control.
We are committed to protecting your privacy. We will only use the information that we collectabout you lawfully.
The type of information we will collect about you includes:
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We will never collect sensitive information about you without your explicit consent. The
information we hold will be accurate and up to date. You can check the information that we hold
about you by e-mailing us. If you find any inaccuracies we will delete or correct it promptly. The
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CLIENT CODE MODIFICATION POLICY
[Reference : SEBI Circular No. SEBI /HO/CDMRD/DMP/CIR/P/2016/43 29.03.2016]
Preamble –Rayalseema Bullion & Commtrade Pvt. Ltd. is a Commodity Broker member of MCX
. As such, it carries out trading of its clients in respective exchangethrough various branch
offices including offices of its sub-brokers / franchisees /authorised person etc.
While carrying out its functions as a Broker, it might happen sometimes that due to certain
reasons, the client codes might not have been entered correctly at the time of either order entry
or need to be changed once converted into trades so that proper and correct effect of those vary
transactions can be given.
However, SEBI and Exchanges have issued various circulars in this regard. Accordingly, with a
view to minimise the errors being committed in this regard, certain objective criteria for
identifying genuine errors for client code modification of non-institutional trades and guidelines
for the implementation of the requirement of those circulars are given below.
1. To rectify genuine error in entry of client code at the time of placing / modifying the related
order, Permission of Head – RMS or such other higher authority designated by the management
must be obtained prior to changing the client codes.
2. Such permission shall be given to change client codes of non-institutional clients only for the
Error due to communication and/or Punching / Typing error – Such that the original client code /
name and the modified client code/name are similar to each other. [For e.g. if the code entered
by punching D001 instead of B001 due to communication error]
Modification within relatives (“Relative” for this purpose would mean “relative” as defined under
the Companies Act, 2013)
3. In case of shifting of any trade (Institutional or non-institutional trades) not accepted by any
client, such trades MUST be first shifted to designated “ERROR” account and relevant position
subsequently liquidated / closed out in the market. Once, the trades have been transferred to
such Error Account, the same shall NOT be shifted to some other client code.
4. UCC for such Errors Account MUST be uploaded to respective Exchange. Accordingly, KYC
Department is directed to take all necessary steps to upload the same immediately and to report
about successful uploading of the same (with documentary evidences, if any) to the Compliance
& RMS Team.
5. Further, the designated employee(s) MUST inform the respective Exchange (as per the
mechanism established by them in this regard) on a daily basis by end of day, the reasons for
modification of client codes of non-institutional trades based on the aforesaid objective criteria.Further, he/she MUST preserve all related documentary records in this regard so as to assist
the Compliance Team at the time of Inspection in this regard.
6. All related employees are STRICTLY warned not to modify any client code in the back-office
system or after the close of the modification window provided by the Exchange(s). 7. All
concerned or deemed to be concerned employees are strictly advised to comply with this
guideline or policy in true letter and spirit.
Note : The aforesaid policy is approved by the Board of Directors of the Company i.e.
Rayalseema Bullion & Commtrade Pvt. Ltd. as per its meeting held on 01 April, 2017.
DORMANT ACCOUNTS POLICY
Definition of Dormant/Inactive Account
In case of trading account if a period of 6 calendar months (for Rayalseema Bullion &
Commtrade Pvt.Ltd herein after known as RSBC) elapses from the date of last transaction, such
account will be deemed as Dormant/Inactive Account.
Transaction in Dormant/Inactive Trading Account
The dormant/inactive account identified, based on the above criteria shall be flagged as such in
RSBC’s record. RSBC under the guidelines of FMC reserves the right to freeze/deactivate such
account and shall not allow carrying-on of any long open position in such account.
Treatment of Credit balance of Funds/Securities in Dormant/Inactive Account
If there is any credit balance of funds/securities in dormant/inactive account, it shall be returned
to the client intimating them that their account has been frozen/deactivated. In case no contact
could be established with the client, such funds will be retained till such time RSBC hears from
the client or their representative. Trading in such account is suspended.
Debit Transaction in Dormant Account
The accounts wherein no debit transaction has taken place for a continuous period of 6
calendar months shall be flagged as dormant/inactive accounts. Additional due diligence would
be observed over and above the normal verification procedure while processing any debit
transactions in such accounts.
The above stated policy may vary depending on various rules, regulations and bye laws as may
be prescribed by FMC, exchanges or any other authority and also as per the internal policy of
RSBC from time to time. This policy for dormant accounts is over and above the transaction monitoring in Dormant Account as per Monitoring in Dormant Account according to Anti-Money
Laundering Policy of the Company.
Reactivation of Dormant/Inactive Account
The client is required to submit a request for re-activation stating that no material change has
taken place in respect of the details provided initially at the time of account opening along with
the relevant documents as may be mandatorily required in this regard. If there is any material
change in the details of account holder, a fresh KYC Form will have to be duly filled.
The dormant/inactive account will be reactivated after receiving of any written intimationregistered letter/email or verbal intimation i.e. recorded telephonic conversation. Such an
account will be reactivated only after undertaking proper due diligence process and fulfillment of
such conditions as may be deemed fit.
RISK MANAGEMENT POLICY
RAYALSEEMA BULLION AND COMMTRADE PVT LTD is a Trading and Clearing member of
Multi Commodity Exchange of India (MCX) is regulated by the FMC through their respective
byelaws, rules and regulations.
In the course of conducting its broking business, RAYALSEEMA BULLION AND COMMTRADE
PVT LTD is exposed to variety of risks including market, credit, liquidity, operational and other
risk that are material and require comprehensive controls and ongoing oversight.
The risk management framework of RAYALSEEMA BULLION AND COMMTRADE PVT LTD for
its Commodity Futures broking business is based upon the different client segments, applicable
settlement mechanism of FMC/Stock Exchange regulations. We set out below the principles of
our risk management framework:
RISK MANAGEMENT POLICY
- Every client is registered with us after due completion of designated KYC and
satisfactory identification. Detailed information of every client is recorded before
commencing transaction for any new client.
- Initial margin is collected from the respective client and accordingly trading limit is
provided to each client.
- Exposure / Limits are set for each respective client on the basis of deposits / credits
available and are being monitored on real time basis
Real time client-wise Risk Management is done, along with control on margin & MTM
- Trading in Tender period has been restricted as a precautionary measure against Spot
Delivery Settlement Transactions, against strict surveillance.
- Intraday Positions will be squared off when the MTM reaches 80% of the cleared ledger
POLICY FOR DORMANT CLIENTS
Any dormant client (Inactive for Trading for 6 Months) will be re-activated by confirming his/her
identity proof by branch head/in-charge and/or head office staff.
It will be mandatory to provide proper identity proof in original to re-activate any dormant client
prior to trading.
Minimum Margin required at the time of account opening is Rs 25000.00, adequate margin
required for Carry forward positions on T-1 basis.
Required Span Margin would be calculated and blocked on the system of RMS on the Real-time
basis based on the Order placed by the client.
Exposure shall be based on Ledger balance availability of Client’s Trading Account and
it would be “4X” by default.
- No Adhoc margin shall be provided.
- All outstanding intraday position shall be squared off daily at 11.15 pm at Market rate.
- All pending orders shall be cancelled prior to Intraday Square off execution.
- For all orders not executed after running the 1st intraday square off @ 11.15pm for
whatsoever reason further 2nd intraday square off shall be executed @ 11.30pm a
market rate as defined above.
- Margin erosion (MTM) alert message will be sent to the relevant Terminal of mapped
client from 40% and on every 10% incremental level.
- 80% Alert for Margin erosion (M2M) Informing client about Client in Square-off mode
- On 75% Margin erosion (M2M), Client will be put in square-off mode and client shall not
be able to take any further new position.
- On 80% Margin erosion (M2M + Brokerage), M2M square off will be executed from
HO-RMS department at Market rate
- After the execution of Sq-off, the client would not be allowed to place an order until he
gets Approval from the Top Level Authorities of MCL.
PMLA POLICY - Attached Document
PREP FUNDED POLICY - Attached Document