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Policies & Procedures

Client Code Modification and Error Code Policy

Client Code Modification is a massive problem of the organization. The main objective of the company to framed a policy for modification of client code for post trade execution and takes the report on such modification of client codes. Further educate the dealers and create awareness among them about this policy.
Brief criteria about Client code Modification Client code modification means modification of client code after the execution of trade. The stock exchange provides a facility to modify the client code to rectify an error. Further only the genuine errors will be modify and after being transferred to ‘Error Account’. The modification should be done within the Stock Exchange guidelines. The modification of client code is to be done only in exceptional cases and not in routine case.

Details about Genuine error

The following trades shall be modify/ allowed to be modify, shall be treated as genuine error and transferred to Error Account.
Punching error / typing error of client codes due to any genuine error or mistake in order entry, while punching the order, by any of dealer.
Trade entered for wrong client due to any miscommunication from the client /authorized representative of the client
Client code/name and modified client code/name are similar to each other but such Modifications are not repetitive.Family Code (spouse, dependent parents, dependent children and HUF)
Institutional trades modified to broker error/pro account.

Example of Genuine Error

The criteria for determining the genuineness of client code modification are as follows:
Client code FA 1234 wrongly entered MN5678 would be constructed as intentionally committed whereas FA1234 entered as AF 1234 or FA 2341 may be a genuine punching error.
The Board and Management Directives
The Board and Management have approved under mention policy in this regard and instruct all the office bearers to follow it strictly.
To control the punching error, it has been decided that client code mapping will be restricted in trading terminals.
To create a separate error account in the name of “Berkeley Securities Ltd” as per the exchange circular.
To maintain Client Modification registers with immediate effect for recording the errors.
To review periodically list of inactive clients for marking in CTCL Surveillance System.
Dealers are advised to hear patiently the client code /scrip name and reconfirm the same to their best possible efforts before placing order into the system.
Department head/ compliance officer are advice to analyses the mistake and to take/ implement corrective measures to their best possible efforts to minimize.
Department Head/ Compliance officer are advice to update the report to the Board / management on the implementation of the said policy periodically.

Reporting System

Client code modification issues should be reported to the Key Personnel’s and can be done only after getting approval after knowing it’s genuinely as per exchange directives.
Any client code modification shall be subjected to this policy be carried at Head Office of the company.
The company review every day the Error Account file send by the Exchange.
A separate register to be maintained by the company for above purpose where full details will be recorded.

Reference to the Circular

SEBI Circulars No. – CIR/DNPD/6/2011 dated January 01, 2011
Circulars No. – CIR/DNPD/01/2011 dated July 05, 2011

NSE Circular No. – NSE/INVG/2011/596 dated February 17, 2011
Circular No.- NSE/INVG/2011/18484 dated July 29, 2011
Circular No. – NSE /INVG/2011/870 dated August 26, 2011.

Pre- funded Instruments Policy

[In accordance with SEBI circular ref. no. CIR/ MIRSD/ 02/ 2011 dated June 9, 2011 and the Exchange circular download ref no. NSE/ INSP/ 18024 and Circular No. NSE/ INSP/ 2011/ 118 dated June 9, 2011]
1. DD’s / Pay Order are accepted only along with a self declaration given by the client. (Copy of the declaration enclosed)

2. In case the aggregate value of pre-funded instruments is Rs. 50,000/- or more, the instrument is to be accompanied by any of the following:
(i) Certificate from the issuing bank on its letterhead or on a plain paper with the seal of the issuing bank.
(ii) Certified copy of the requisition slip (portion which is retained by the bank) to issue the instrument.
(iii) Certified copy of the passbook/bank statement for the account debited to issue the instrument.
(iv) Authentication of the bank account-number debited and name of the account holder by the issuing bank on the reverse of the instrument.
(v) In case of electronic funds transfers like RTGS/NEFT, the clients may also submit the screenshot from the bank’s website clearly indicating the bank details to identify the source from where the funds are transferred.

3. In case of online transfers, since we are using Closed User Group (CUG) payment gateway, the funds can only be credited from the client’s bank account which has been mapped with our account and no third parties transfers can be received.

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