Raghunandan Money – Investment Khushiyon Ka.

Client Code Modification Policy

Client Code Modification Policy

  1. The modification to the client code is to be done only in exceptional cases and not as a routine one.
  2. The    reason   for  modification has  to be  ascertained  and   analyzed  and genuineness  is to be  established and  also it’s impact on the clients  should be Studied  before the modification. If voice recording is in practice, the same is being studied.
  3. Normally as a principle, other than for punching errors, no modification to the client codes is allowed.
  4. Therefore it is imperative that  the issue should be reported to the senior level Manager/ Director and only  with his approval, the modification should be carried  after  being satisfied  that  it is  genuine,  the same is required to be done to protect the interests of the client.
  5. Hence the facility to modify the client codes should be available only at the Corporate Manager level and should not be given to the    branches/ franchise/sub-brokers.
  6. Training  program should be conducted  to all  the Dealers  and  they should be   explained  how code  modifications can   be  misused  and   what  steps Should   be taken  to avoid the same. It also should be explained that code modifications should not be encouraged to the clients except for cases like ‘punching errors’/’typing  errors’.
  7. A register   is to  be  maintained for recording all   the code modifications with details like  error  code,  correct  code,  scrip  name   quantity, client name,  the name   of  the dealer  who punched  the code, the explanation of the  dealer/ Branch  Manager,  the  ‘analysis / study’ of  the    authorised  Manager and his approval/disapproval  for modification.
  8. The company shall levy a penalty for any client code modification not covered in above mentioned cases:-
‘a’ as % of ‘b’Penalty as % of ‘a’
≤ 51
> 52

Where ‘a’ = Value (Turnover) of non-institutional trades where client codes have been modified by the Company in a segment during a month.

‘b’ = Value (Turnover) of non-institutional trades of the company on the segment during the month.

  1. The client code which are classified as “Error Accounts” shall be                disclosed to the Exchange a the time of uploading the UCC.
  2. The genuine code shall be modified after the prior approval of the            Compliance Officer of the Company. Any trade denied for            modification by the Compliance Officer shall not be modified. 

For Raghunandan Capital Private Limited 

  Sd/-Director

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