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FORM ADV
UNIFORM APPLICATION FOR INVESTMENT ADVISER REGISTRATION AND REPORT BY EXEMPT REPORTING ADVISERS
Primary Business Name: JM FINANCIAL LIMITED CRD Number: 293667
Annual Amendment - All Sections Rev. 10/2021
6/27/2026 1:13:56 PM
WARNING: Complete this form truthfully. False statements or omissions may result in denial of your application, revocation of your registration, or criminal prosecution.
You must keep this form updated by filing periodic amendments. See Form ADV General Instruction 4.
Item 1 Identifying Information
Responses to this Item tell us who you are, where you are doing business, and how we can contact you. If you are filing an umbrella registration, the information in Item
1 should be provided for the filing adviser only. General Instruction 5 provides information to assist you with filing an umbrella registration.
A. Your full legal name (if you are a sole proprietor, your last, first, and middle names):
JM FINANCIAL LIMITED
B. (1) Name under which you primarily conduct your advisory business, if different from Item 1.A.
JM FINANCIAL LIMITED
List on Section 1.B. of Schedule D any additional names under which you conduct your advisory business.
(2) If you are using this Form ADV to register more than one investment adviser under an umbrella registration, check this box
If you check this box, complete a Schedule R for each relying adviser.
C. If this filing is reporting a change in your legal name (Item 1.A.) or primary business name (Item 1.B.(1)), enter the new name and specify whether the name
change is of
your legal name or your primary business name:
D. (1) If you are registered with the SEC as an investment adviser, your SEC file number:
(2) If you report to the SEC as an exempt reporting adviser, your SEC file number: 802-112989
(3) If you have one or more Central Index Key numbers assigned by the SEC ("CIK Numbers"), all of your CIK numbers:
No Information Filed
E. (1) If you have a number ("CRD Number") assigned by the FINRA's CRD system or by the IARD system, your CRD number: 293667
If your firm does not have a CRD number, skip this Item 1.E. Do not provide the CRD number of one of your officers, employees, or affiliates.
(2) If you have additional CRD Numbers, your additional CRD numbers:
No Information Filed
F. Principal Office and Place of Business
(1) Address (do not use a P.O. Box):
Number and Street 1: Number and Street 2:
7TH FLOOR, CNERGY, APPASAHEB MARATHE MARG PRABHADEVI
City: State: Country: ZIP+4/Postal Code:
MUMBAI, MAHARASTRA India 400025
If this address is a private residence, check this box:
List on Section 1.F. of Schedule D any office, other than your principal office and place of business, at which you conduct investment advisory business. If you are
applying for registration, or are registered, with one or more state securities authorities, you must list all of your offices in the state or states to which you are
applying for registration or with whom you are registered. If you are applying for SEC registration, if you are registered only with the SEC, or if you are reporting to the
SEC as an exempt reporting adviser, list the largest twenty-five offices in terms of numbers of employees as of the end of your most recently completed fiscal year.
(2) Days of week that you normally conduct business at your principal office and place of business:
Monday - Friday Other:
Normal business hours at this location:
9 AM TO 6 PM
(3) Telephone number at this location:
+91 22 6630 3030
(4) Facsimile number at this location, if any:
+91 22 6630 3223
(5) What is the total number of offices, other than your principal office and place of business, at which you conduct investment advisory business as of the end of
your most recently completed fiscal year?
0
G. Mailing address, if different from your principal office and place of business address:
Number and Street 1: Number and Street 2:
City: State: Country: ZIP+4/Postal Code:
If this address is a private residence, check this box:
H. If you are a sole proprietor, state your full residence address, if different from your principal office and place of business address in Item 1.F.:
Number and Street 1: Number and Street 2:
City: State: Country: ZIP+4/Postal Code:
Yes No
I. Do you have one or more websites or accounts on publicly available social media platforms (including, but not limited to, Twitter, Facebook and LinkedIn)?
If "yes," list all firm website addresses and the address for each of the firm's accounts on publicly available social media platforms on Section 1.I. of Schedule D. If a website
address serves as a portal through which to access other information you have published on the web, you may list the portal without listing addresses for all of the other
information. You may need to list more than one portal address. Do not provide the addresses of websites or accounts on publicly available social media platforms where
you do not control the content. Do not provide the individual electronic mail (e-mail) addresses of employees or the addresses of employee accounts on publicly available
social media platforms.
J. Chief Compliance Officer
(1) Provide the name and contact information of your Chief Compliance Officer. If you are an exempt reporting adviser, you must provide the contact information for
your Chief Compliance Officer, if you have one. If not, you must complete Item 1.K. below.
Name: Other titles, if any:
Telephone number: Facsimile number, if any:
Number and Street 1: Number and Street 2:
City: State: Country: ZIP+4/Postal Code:
Electronic mail (e-mail) address, if Chief Compliance Officer has one:
(2) If your Chief Compliance Officer is compensated or employed by any person other than you, a related person or an investment company registered under the
Investment Company Act of 1940 that you advise for providing chief compliance officer services to you, provide the person's name and IRS Employer Identification
Number (if any):
Name:
IRS Employer Identification Number:
K. Additional Regulatory Contact Person: If a person other than the Chief Compliance Officer is authorized to receive information and respond to questions about this
Form ADV, you may provide that information here.
Name: Titles:
Telephone number: Facsimile number, if any:
Number and Street 1: Number and Street 2:
City: State: Country: ZIP+4/Postal Code:
Electronic mail (e-mail) address, if contact person has one:
Yes No
L. Do you maintain some or all of the books and records you are required to keep under Section 204 of the Advisers Act, or similar state law, somewhere
other than your principal office and place of business?
If "yes," complete Section 1.L. of Schedule D.
Yes No
M. Are you registered with a foreign financial regulatory authority?
Answer "no" if you are not registered with a foreign financial regulatory authority, even if you have an affiliate that is registered with a foreign financial regulatory authority.
If "yes," complete Section 1.M. of Schedule D.
Yes No
N. Are you a public reporting company under Sections 12 or 15(d) of the Securities Exchange Act of 1934?
Yes No
O. Did you have $1 billion or more in assets on the last day of your most recent fiscal year?
If yes, what is the approximate amount of your assets:
$1 billion to less than $10 billion
$10 billion to less than $50 billion
$50 billion or more
For purposes of Item 1.O. only, "assets" refers to your total assets, rather than the assets you manage on behalf of clients. Determine your total assets using the total
assets shown on the balance sheet for your most recent fiscal year end.
P. Provide your Legal Entity Identifier if you have one:
254900XWK81ULQY0IE29
A legal entity identifier is a unique number that companies use to identify each other in the financial marketplace. You may not have a legal entity identifier.
SECTION 1.B. Other Business Names
No Information Filed
SECTION 1.F. Other Offices
No Information Filed
SECTION 1.I. Website Addresses
List your website addresses, including addresses for accounts on publicly available social media platforms where you control the content (including, but not limited to,
Twitter, Facebook and/or LinkedIn). You must complete a separate Schedule D Section 1.I. for each website or account on a publicly available social media platform.
Address of Website/Account on Publicly Available Social Media Platform: https://www.facebook.com/jmfinancial/
Address of Website/Account on Publicly Available Social Media Platform: https://www.linkedin.com/company/jm-financial-ltd/posts/?feedView=all&viewAsMember=true
Address of Website/Account on Publicly Available Social Media Platform: HTTPS://WWW.JMFL.COM
SECTION 1.L. Location of Books and Records
No Information Filed
SECTION 1.M. Registration with Foreign Financial Regulatory Authorities
List the name and country, in English, of each foreign financial regulatory authority with which you are registered. You must complete a separate Schedule D Section 1.M.
for each foreign financial regulatory authority with whom you are registered.
Name of Country/Foreign Financial Regulatory Authority:
India - Securities and Exchange Board of India
Other:
Item 2 SEC Registration/Reporting
SEC Reporting by Exempt Reporting Advisers
B. Complete this Item 2.B. only if you are reporting to the SEC as an exempt reporting adviser. Check all that apply. You:
(1) qualify for the exemption from registration as an adviser solely to one or more venture capital funds, as defined in rule 203(l)-1;
(2) qualify for the exemption from registration because you act solely as an adviser to private funds and have assets under management, as defined in rule
203(m)-1, in the United States of less than $150 million;
(3) act solely as an adviser to private funds but you are no longer eligible to check box 2.B.(2) because you have assets under management, as defined in rule
203(m)-1, in the United States of $150 million or more.
If you check box (2) or (3), complete Section 2.B. of Schedule D.
SECTION 2.B. Private Fund Assets
If you check Item 2.B.(2) or (3), what is the amount of the private fund assets that you manage? $0
NOTE: "Private fund assets" has the same meaning here as it has under rule 203(m)-1. If you are an investment adviser with its principal office and place of business
outside the United States only include private fund assets that you manage at a place of business in the United States.
Item 3 Form of Organization
If you are filing an umbrella registration, the information in Item 3 should be provided for the filing adviser only.
A. How are you organized?
Corporation
Sole Proprietorship
Limited Liability Partnership (LLP)
Partnership
Limited Liability Company (LLC)
Limited Partnership (LP)
Other (specify):
If you are changing your response to this Item, see Part 1A Instruction 4.
B. In what month does your fiscal year end each year?
MARCH
C. Under the laws of what state or country are you organized?
State Country
India
If you are a partnership, provide the name of the state or country under whose laws your partnership was formed. If you are a sole proprietor, provide the name of the
state or country where you reside.
If you are changing your response to this Item, see Part 1A Instruction 4.
Item 6 Other Business Activities
In this Item, we request information about your firm's other business activities.
A. You are actively engaged in business as a (check all that apply):
(1) broker-dealer (registered or unregistered)
(2) registered representative of a broker-dealer
(3) commodity pool operator or commodity trading advisor (whether registered or exempt from registration)
(4) futures commission merchant
(5) real estate broker, dealer, or agent
(6) insurance broker or agent
(7) bank (including a separately identifiable department or division of a bank)
(8) trust company
(9) registered municipal advisor
(10) registered security-based swap dealer
(11) major security-based swap participant
(12) accountant or accounting firm
(13) lawyer or law firm
(14) other financial product salesperson (specify):
If you engage in other business using a name that is different from the names reported in Items 1.A. or 1.B.(1), complete Section 6.A. of Schedule D.
Yes No
B. (1) Are you actively engaged in any other business not listed in Item 6.A. (other than giving investment advice)?
(2) If yes, is this other business your primary business?
If "yes," describe this other business on Section 6.B.(2) of Schedule D, and if you engage in this business under a different name, provide that name.
Yes No
(3) Do you sell products or provide services other than investment advice to your advisory clients?
If "yes," describe this other business on Section 6.B.(3) of Schedule D, and if you engage in this business under a different name, provide that name.
SECTION 6.A. Names of Your Other Businesses
No Information Filed
SECTION 6.B.(2) Description of Primary Business
Describe your primary business (not your investment advisory business):
If you engage in that business under a different name, provide that name:
SECTION 6.B.(3) Description of Other Products and Services
Describe other products or services you sell to your client. You may omit products and services that you listed in Section 6.B.(2) above.
If you engage in that business under a different name, provide that name:
Item 7 Financial Industry Affiliations
In this Item, we request information about your financial industry affiliations and activities. This information identifies areas in which conflicts of interest may occur
between you and your clients.
A. This part of Item 7 requires you to provide information about you and your related persons, including foreign affiliates. Your related persons are all of your advisory
affiliates and any person that is under common control with you.
You have a related person that is a (check all that apply):
(1) broker-dealer, municipal securities dealer, or government securities broker or dealer (registered or unregistered)
(2) other investment adviser (including financial planners)
(3) registered municipal advisor
(4) registered security-based swap dealer
(5) major security-based swap participant
(6) commodity pool operator or commodity trading advisor (whether registered or exempt from registration)
(7) futures commission merchant
(8) banking or thrift institution
(9) trust company
(10) accountant or accounting firm
(11) lawyer or law firm
(12) insurance company or agency
(13) pension consultant
(14) real estate broker or dealer
(15) sponsor or syndicator of limited partnerships (or equivalent), excluding pooled investment vehicles
(16) sponsor, general partner, managing member (or equivalent) of pooled investment vehicles
Note that Item 7.A. should not be used to disclose that some of your employees perform investment advisory functions or are registered representatives of a broker-
dealer. The number of your firm's employees who perform investment advisory functions should be disclosed under Item 5.B.(1). The number of your firm's employees
who are registered representatives of a broker-dealer should be disclosed under Item 5.B.(2).
Note that if you are filing an umbrella registration, you should not check Item 7.A.(2) with respect to your relying advisers, and you do not have to complete Section 7.A.
in Schedule D for your relying advisers. You should complete a Schedule R for each relying adviser.
For each related person, including foreign affiliates that may not be registered or required to be registered in the United States, complete Section 7.A. of Schedule D.
You do not need to complete Section 7.A. of Schedule D for any related person if: (1) you have no business dealings with the related person in connection with advisory
services you provide to your clients; (2) you do not conduct shared operations with the related person; (3) you do not refer clients or business to the related person, and
the related person does not refer prospective clients or business to you; (4) you do not share supervised persons or premises with the related person; and (5) you have
no reason to believe that your relationship with the related person otherwise creates a conflict of interest with your clients.
You must complete Section 7.A. of Schedule D for each related person acting as qualified custodian in connection with advisory services you provide to your clients (other
than any mutual fund transfer agent pursuant to rule 206(4)-2(b)(1)), regardless of whether you have determined the related person to be operationally independent
under rule 206(4)-2 of the Advisers Act.
SECTION 7.A. Financial Industry Affiliations
Complete a separate Schedule D Section 7.A. for each related person listed in Item 7.A.
1. Legal Name of Related Person:
JM FINANCIAL SINGAPORE PTE LTD
2. Primary Business Name of Related Person:
JM FINANCIAL SINGAPORE PTE LTD
3. Related Person's SEC File Number (if any) (e.g., 801-, 8-, 866-, 802-)
-
or
Other
4. Related Person's
(a) CRD Number (if any):
(b) CIK Number(s) (if any):
No Information Filed
5. Related Person is: (check all that apply)
(a) broker-dealer, municipal securities dealer, or government securities broker or dealer
(b) other investment adviser (including financial planners)
(c) registered municipal advisor
(d) registered security-based swap dealer
(e) major security-based swap participant
(f) commodity pool operator or commodity trading advisor (whether registered or exempt from registration)
(g) futures commission merchant
(h) banking or thrift institution
(i) trust company
(j) accountant or accounting firm
(k) lawyer or law firm
(l) insurance company or agency
(m) pension consultant
(n) real estate broker or dealer
(o) sponsor or syndicator of limited partnerships (or equivalent), excluding pooled investment vehicles
(p) sponsor, general partner, managing member (or equivalent) of pooled investment vehicles
Yes No
6. Do you control or are you controlled by the related person?
7. Are you and the related person under common control?
8. (a) Does the related person act as a qualified custodian for your clients in connection with advisory services you provide to clients?
(b) If you are registering or registered with the SEC and you have answered "yes," to question 8.(a) above, have you overcome the presumption that you
are not operationally independent (pursuant to rule 206(4)-2(d)(5)) from the related person and thus are not required to obtain a surprise examination
for your clients' funds or securities that are maintained at the related person?
(c) If you have answered "yes" to question 8.(a) above, provide the location of the related person's office responsible for custody of your clients' assets:
Number and Street 1: Number and Street 2:
City: State: Country: ZIP+4/Postal Code:
If this address is a private residence, check this box:
Yes No
9. (a) If the related person is an investment adviser, is it exempt from registration?
(b) If the answer is yes, under what exemption?
FOREIGN PRIVATE ADVISER EXEMPTION
10. (a) Is the related person registered with a foreign financial regulatory authority ?
(b) If the answer is yes, list the name and country, in English of each foreign financial regulatory authority with which the related person is registered.
Name of Country/English Name of Foreign Financial Regulatory Authority
India - Securities and Exchange Board of India
Singapore - Monetary Authority of Singapore
11. Do you and the related person share any supervised persons?
12. Do you and the related person share the same physical location?
1. Legal Name of Related Person:
JM FINANCIAL PRODUCTS LIMITED
2. Primary Business Name of Related Person:
JM FINANCIAL PRODUCTS LIMITED
3. Related Person's SEC File Number (if any) (e.g., 801-, 8-, 866-, 802-)
-
or
Other
4. Related Person's
(a) CRD Number (if any):
(b) CIK Number(s) (if any):
No Information Filed
5. Related Person is: (check all that apply)
(a) broker-dealer, municipal securities dealer, or government securities broker or dealer
(b) other investment adviser (including financial planners)
(c) registered municipal advisor
(d) registered security-based swap dealer
(e) major security-based swap participant
(f) commodity pool operator or commodity trading advisor (whether registered or exempt from registration)
(g) futures commission merchant
(h) banking or thrift institution
(i) trust company
(j) accountant or accounting firm
(k) lawyer or law firm
(l) insurance company or agency
(m) pension consultant
(n) real estate broker or dealer
(o) sponsor or syndicator of limited partnerships (or equivalent), excluding pooled investment vehicles
(p) sponsor, general partner, managing member (or equivalent) of pooled investment vehicles
Yes No
6. Do you control or are you controlled by the related person?
7. Are you and the related person under common control?
8. (a) Does the related person act as a qualified custodian for your clients in connection with advisory services you provide to clients?
(b) If you are registering or registered with the SEC and you have answered "yes," to question 8.(a) above, have you overcome the presumption that you
are not operationally independent (pursuant to rule 206(4)-2(d)(5)) from the related person and thus are not required to obtain a surprise examination
for your clients' funds or securities that are maintained at the related person?
(c) If you have answered "yes" to question 8.(a) above, provide the location of the related person's office responsible for custody of your clients' assets:
Number and Street 1: Number and Street 2:
City: State: Country: ZIP+4/Postal Code:
If this address is a private residence, check this box:
Yes No
9. (a) If the related person is an investment adviser, is it exempt from registration?
(b) If the answer is yes, under what exemption?
10. (a) Is the related person registered with a foreign financial regulatory authority ?
(b) If the answer is yes, list the name and country, in English of each foreign financial regulatory authority with which the related person is registered.
Name of Country/English Name of Foreign Financial Regulatory Authority
Other - INDIA - RESERVE BANK OF INDIA
Other - INDIA-MAHARASHTRA REAL ESTATE REGULATORY AUTHORITY
11. Do you and the related person share any supervised persons?
12. Do you and the related person share the same physical location?
1. Legal Name of Related Person:
INFINITE INDIA INVESTMENT MANAGEMENT LIMITED
2. Primary Business Name of Related Person:
INFINITE INDIA INVESTMENT MANAGEMENT LIMITED
3. Related Person's SEC File Number (if any) (e.g., 801-, 8-, 866-, 802-)
802 - 75822
or
Other
4. Related Person's
(a) CRD Number (if any):
161559
(b) CIK Number(s) (if any):
No Information Filed
5. Related Person is: (check all that apply)
(a) broker-dealer, municipal securities dealer, or government securities broker or dealer
(b) other investment adviser (including financial planners)
(c) registered municipal advisor
(d) registered security-based swap dealer
(e) major security-based swap participant
(f) commodity pool operator or commodity trading advisor (whether registered or exempt from registration)
(g) futures commission merchant
(h) banking or thrift institution
(i) trust company
(j) accountant or accounting firm
(k) lawyer or law firm
(l) insurance company or agency
(m) pension consultant
(n) real estate broker or dealer
(o) sponsor or syndicator of limited partnerships (or equivalent), excluding pooled investment vehicles
(p) sponsor, general partner, managing member (or equivalent) of pooled investment vehicles
Yes No
6. Do you control or are you controlled by the related person?
7. Are you and the related person under common control?
8. (a) Does the related person act as a qualified custodian for your clients in connection with advisory services you provide to clients?
(b) If you are registering or registered with the SEC and you have answered "yes," to question 8.(a) above, have you overcome the presumption that you
are not operationally independent (pursuant to rule 206(4)-2(d)(5)) from the related person and thus are not required to obtain a surprise examination
for your clients' funds or securities that are maintained at the related person?
(c) If you have answered "yes" to question 8.(a) above, provide the location of the related person's office responsible for custody of your clients' assets:
Number and Street 1: Number and Street 2:
City: State: Country: ZIP+4/Postal Code:
If this address is a private residence, check this box:
Yes No
9. (a) If the related person is an investment adviser, is it exempt from registration?
(b) If the answer is yes, under what exemption?
PRIVATE FUND ADVISER EXEMPTION
10. (a) Is the related person registered with a foreign financial regulatory authority ?
(b) If the answer is yes, list the name and country, in English of each foreign financial regulatory authority with which the related person is registered.
No Information Filed
11. Do you and the related person share any supervised persons?
12. Do you and the related person share the same physical location?
1. Legal Name of Related Person:
JM FINANCIAL COMMTRADE LIMITED
2. Primary Business Name of Related Person:
JM FINANCIAL COMMTRADE LIMITED
3. Related Person's SEC File Number (if any) (e.g., 801-, 8-, 866-, 802-)
-
or
Other
4. Related Person's
(a) CRD Number (if any):
(b) CIK Number(s) (if any):
No Information Filed
5. Related Person is: (check all that apply)
(a) broker-dealer, municipal securities dealer, or government securities broker or dealer
(b) other investment adviser (including financial planners)
(c) registered municipal advisor
(d) registered security-based swap dealer
(e) major security-based swap participant
(f) commodity pool operator or commodity trading advisor (whether registered or exempt from registration)
(g) futures commission merchant
(h) banking or thrift institution
(i) trust company
(j) accountant or accounting firm
(k) lawyer or law firm
(l) insurance company or agency
(m) pension consultant
(n) real estate broker or dealer
(o) sponsor or syndicator of limited partnerships (or equivalent), excluding pooled investment vehicles
(p) sponsor, general partner, managing member (or equivalent) of pooled investment vehicles
Yes No
6. Do you control or are you controlled by the related person?
7. Are you and the related person under common control?
8. (a) Does the related person act as a qualified custodian for your clients in connection with advisory services you provide to clients?
(b) If you are registering or registered with the SEC and you have answered "yes," to question 8.(a) above, have you overcome the presumption that you
are not operationally independent (pursuant to rule 206(4)-2(d)(5)) from the related person and thus are not required to obtain a surprise examination
for your clients' funds or securities that are maintained at the related person?
(c) If you have answered "yes" to question 8.(a) above, provide the location of the related person's office responsible for custody of your clients' assets:
Number and Street 1: Number and Street 2:
City: State: Country: ZIP+4/Postal Code:
If this address is a private residence, check this box:
Yes No
9. (a) If the related person is an investment adviser, is it exempt from registration?
(b) If the answer is yes, under what exemption?
10. (a) Is the related person registered with a foreign financial regulatory authority ?
(b) If the answer is yes, list the name and country, in English of each foreign financial regulatory authority with which the related person is registered.
Name of Country/English Name of Foreign Financial Regulatory Authority
India - Securities and Exchange Board of India
Other - INDIA - MULTI COMMODITY EXCHANGE OF INDIA LIMITED
Other - INDIA - NATIONAL COMMODITY AND DERIVATIVES EXCHANGE LIMITED
Other - INDIA - NATIONAL SPOT EXCHANGE LIMITED
11. Do you and the related person share any supervised persons?
12. Do you and the related person share the same physical location?
1. Legal Name of Related Person:
JM FINANCIAL SERVICES LIMITED
2. Primary Business Name of Related Person:
JM FINANCIAL SERVICES LIMITED
3. Related Person's SEC File Number (if any) (e.g., 801-, 8-, 866-, 802-)
-
or
Other
4. Related Person's
(a) CRD Number (if any):
(b) CIK Number(s) (if any):
No Information Filed
5. Related Person is: (check all that apply)
(a) broker-dealer, municipal securities dealer, or government securities broker or dealer
(b) other investment adviser (including financial planners)
(c) registered municipal advisor
(d) registered security-based swap dealer
(e) major security-based swap participant
(f) commodity pool operator or commodity trading advisor (whether registered or exempt from registration)
(g) futures commission merchant
(h) banking or thrift institution
(i) trust company
(j) accountant or accounting firm
(k) lawyer or law firm
(l) insurance company or agency
(m) pension consultant
(n) real estate broker or dealer
(o) sponsor or syndicator of limited partnerships (or equivalent), excluding pooled investment vehicles
(p) sponsor, general partner, managing member (or equivalent) of pooled investment vehicles
Yes No
6. Do you control or are you controlled by the related person?
7. Are you and the related person under common control?
8. (a) Does the related person act as a qualified custodian for your clients in connection with advisory services you provide to clients?
(b) If you are registering or registered with the SEC and you have answered "yes," to question 8.(a) above, have you overcome the presumption that you
are not operationally independent (pursuant to rule 206(4)-2(d)(5)) from the related person and thus are not required to obtain a surprise examination
for your clients' funds or securities that are maintained at the related person?
(c) If you have answered "yes" to question 8.(a) above, provide the location of the related person's office responsible for custody of your clients' assets:
Number and Street 1: Number and Street 2:
City: State: Country: ZIP+4/Postal Code:
If this address is a private residence, check this box:
Yes No
9. (a) If the related person is an investment adviser, is it exempt from registration?
(b) If the answer is yes, under what exemption?
FOREIGN PRIVATE ADVISER EXEMPTION
10. (a) Is the related person registered with a foreign financial regulatory authority ?
(b) If the answer is yes, list the name and country, in English of each foreign financial regulatory authority with which the related person is registered.
Name of Country/English Name of Foreign Financial Regulatory Authority
India - Securities and Exchange Board of India
Other - INDIA - BSE LIMITED
Other - INDIA - METROPOLITAN STOCK EXCHANGE OF INDIA LIMITED
Other - INDIA - MULTI COMMODITY EXCHANGE OF INDIA LIMITED
Other - INDIA - NATIONAL COMMODITY AND DERIVATIVES EXCHANGE LIMITED
Other - INDIA - NATIONAL STOCK EXCHANGE OF INDIA LIMITED
11. Do you and the related person share any supervised persons?
12. Do you and the related person share the same physical location?
1. Legal Name of Related Person:
JM FINANCIAL TRUSTEE COMPANY PRIVATE LIMITED
2. Primary Business Name of Related Person:
JM FINANCIAL TRUSTEE COMPANY PRIVATE LIMITED
3. Related Person's SEC File Number (if any) (e.g., 801-, 8-, 866-, 802-)
-
or
Other
4. Related Person's
(a) CRD Number (if any):
(b) CIK Number(s) (if any):
No Information Filed
5. Related Person is: (check all that apply)
(a) broker-dealer, municipal securities dealer, or government securities broker or dealer
(b) other investment adviser (including financial planners)
(c) registered municipal advisor
(d) registered security-based swap dealer
(e) major security-based swap participant
(f) commodity pool operator or commodity trading advisor (whether registered or exempt from registration)
(g) futures commission merchant
(h) banking or thrift institution
(i) trust company
(j) accountant or accounting firm
(k) lawyer or law firm
(l) insurance company or agency
(m) pension consultant
(n) real estate broker or dealer
(o) sponsor or syndicator of limited partnerships (or equivalent), excluding pooled investment vehicles
(p) sponsor, general partner, managing member (or equivalent) of pooled investment vehicles
Yes No
6. Do you control or are you controlled by the related person?
7. Are you and the related person under common control?
8. (a) Does the related person act as a qualified custodian for your clients in connection with advisory services you provide to clients?
(b) If you are registering or registered with the SEC and you have answered "yes," to question 8.(a) above, have you overcome the presumption that you
are not operationally independent (pursuant to rule 206(4)-2(d)(5)) from the related person and thus are not required to obtain a surprise examination
for your clients' funds or securities that are maintained at the related person?
(c) If you have answered "yes" to question 8.(a) above, provide the location of the related person's office responsible for custody of your clients' assets:
Number and Street 1: Number and Street 2:
City: State: Country: ZIP+4/Postal Code:
If this address is a private residence, check this box:
Yes No
9. (a) If the related person is an investment adviser, is it exempt from registration?
(b) If the answer is yes, under what exemption?
10. (a) Is the related person registered with a foreign financial regulatory authority ?
(b) If the answer is yes, list the name and country, in English of each foreign financial regulatory authority with which the related person is registered.
No Information Filed
11. Do you and the related person share any supervised persons?
12. Do you and the related person share the same physical location?
1. Legal Name of Related Person:
JM FINANCIAL ASSET MANAGEMENT LIMITED
2. Primary Business Name of Related Person:
JM FINANCIAL ASSET MANAGEMENT LIMITED
3. Related Person's SEC File Number (if any) (e.g., 801-, 8-, 866-, 802-)
-
or
Other
4. Related Person's
(a) CRD Number (if any):
(b) CIK Number(s) (if any):
No Information Filed
5. Related Person is: (check all that apply)
(a) broker-dealer, municipal securities dealer, or government securities broker or dealer
(b) other investment adviser (including financial planners)
(c) registered municipal advisor
(d) registered security-based swap dealer
(e) major security-based swap participant
(f) commodity pool operator or commodity trading advisor (whether registered or exempt from registration)
(g) futures commission merchant
(h) banking or thrift institution
(i) trust company
(j) accountant or accounting firm
(k) lawyer or law firm
(l) insurance company or agency
(m) pension consultant
(n) real estate broker or dealer
(o) sponsor or syndicator of limited partnerships (or equivalent), excluding pooled investment vehicles
(p) sponsor, general partner, managing member (or equivalent) of pooled investment vehicles
Yes No
6. Do you control or are you controlled by the related person?
7. Are you and the related person under common control?
8. (a) Does the related person act as a qualified custodian for your clients in connection with advisory services you provide to clients?
(b) If you are registering or registered with the SEC and you have answered "yes," to question 8.(a) above, have you overcome the presumption that you
are not operationally independent (pursuant to rule 206(4)-2(d)(5)) from the related person and thus are not required to obtain a surprise examination
for your clients' funds or securities that are maintained at the related person?
(c) If you have answered "yes" to question 8.(a) above, provide the location of the related person's office responsible for custody of your clients' assets:
Number and Street 1: Number and Street 2:
City: State: Country: ZIP+4/Postal Code:
If this address is a private residence, check this box:
Yes No
9. (a) If the related person is an investment adviser, is it exempt from registration?
(b) If the answer is yes, under what exemption?
FOREIGN PRIVATE ADVISER EXEMPTION
10. (a) Is the related person registered with a foreign financial regulatory authority ?
(b) If the answer is yes, list the name and country, in English of each foreign financial regulatory authority with which the related person is registered.
Name of Country/English Name of Foreign Financial Regulatory Authority
India - Securities and Exchange Board of India
11. Do you and the related person share any supervised persons?
12. Do you and the related person share the same physical location?
1. Legal Name of Related Person:
JM FINANCIAL INSTITUTIONAL SECURITIES LIMITED
2. Primary Business Name of Related Person:
JM FINANCIAL INSTITUTIONAL SECURITIES LIMITED
3. Related Person's SEC File Number (if any) (e.g., 801-, 8-, 866-, 802-)
-
or
Other
4. Related Person's
(a) CRD Number (if any):
(b) CIK Number(s) (if any):
No Information Filed
5. Related Person is: (check all that apply)
(a) broker-dealer, municipal securities dealer, or government securities broker or dealer
(b) other investment adviser (including financial planners)
(c) registered municipal advisor
(d) registered security-based swap dealer
(e) major security-based swap participant
(f) commodity pool operator or commodity trading advisor (whether registered or exempt from registration)
(g) futures commission merchant
(h) banking or thrift institution
(i) trust company
(j) accountant or accounting firm
(k) lawyer or law firm
(l) insurance company or agency
(m) pension consultant
(n) real estate broker or dealer
(o) sponsor or syndicator of limited partnerships (or equivalent), excluding pooled investment vehicles
(p) sponsor, general partner, managing member (or equivalent) of pooled investment vehicles
Yes No
6. Do you control or are you controlled by the related person?
7. Are you and the related person under common control?
8. (a) Does the related person act as a qualified custodian for your clients in connection with advisory services you provide to clients?
(b) If you are registering or registered with the SEC and you have answered "yes," to question 8.(a) above, have you overcome the presumption that you
are not operationally independent (pursuant to rule 206(4)-2(d)(5)) from the related person and thus are not required to obtain a surprise examination
for your clients' funds or securities that are maintained at the related person?
(c) If you have answered "yes" to question 8.(a) above, provide the location of the related person's office responsible for custody of your clients' assets:
Number and Street 1: Number and Street 2:
City: State: Country: ZIP+4/Postal Code:
If this address is a private residence, check this box:
Yes No
9. (a) If the related person is an investment adviser, is it exempt from registration?
(b) If the answer is yes, under what exemption?
10. (a) Is the related person registered with a foreign financial regulatory authority ?
(b) If the answer is yes, list the name and country, in English of each foreign financial regulatory authority with which the related person is registered.
Name of Country/English Name of Foreign Financial Regulatory Authority
India - Securities and Exchange Board of India
Other - INDIA - BSE LIMITED
Other - INDIA - NATIONAL STOCK EXCHANGE OF INDIA LIMITED
11. Do you and the related person share any supervised persons?
12. Do you and the related person share the same physical location?
Item 7 Private Fund Reporting
Yes No
B. Are you an adviser to any private fund?
If "yes," then for each private fund that you advise, you must complete a Section 7.B.(1) of Schedule D, except in certain circumstances described in the next sentence and in
Instruction 6 of the Instructions to Part 1A. If you are registered or applying for registration with the SEC or reporting as an SEC exempt reporting adviser, and another SEC-
registered adviser or SEC exempt reporting adviser reports this information with respect to any such private fund in Section 7.B.(1) of Schedule D of its Form ADV (e.g., if you
are a subadviser), do not complete Section 7.B.(1) of Schedule D with respect to that private fund. You must, instead, complete Section 7.B.(2) of Schedule D.
In either case, if you seek to preserve the anonymity of a private fund client by maintaining its identity in your books and records in numerical or alphabetical code, or similar
designation, pursuant to rule 204-2(d), you may identify the private fund in Section 7.B.(1) or 7.B.(2) of Schedule D using the same code or designation in place of the fund's
name.
SECTION 7.B.(1) Private Fund Reporting
Funds per Page: 15 Total Funds: 4
A. PRIVATE FUND
Information About the Private Fund
1. (a) Name of the private fund:
JM FINANCIAL INDIA FUND
(b) Private fund identification number:
(include the "805-" prefix also)
805-1927345041
2. Under the laws of what state or country is the private fund organized:
State: Country:
India
3. (a) Name(s) of General Partner, Manager, Trustee, or Directors (or persons serving in a similar capacity):
Name of General Partner, Manager, Trustee, or Director
JM FINANCIAL TRUSTEE COMPANY PRIVATE LIMITED
(b) If filing an umbrella registration, identify the filing adviser and/or relying adviser(s) that sponsor(s) or manage(s) this private fund.
No Information Filed
4. The private fund (check all that apply; you must check at least one):
(1) qualifies for the exclusion from the definition of investment company under section 3(c)(1) of the Investment Company Act of 1940
(2) qualifies for the exclusion from the definition of investment company under section 3(c)(7) of the Investment Company Act of 1940
5. List the name and country, in English, of each foreign financial regulatory authority with which the private fund is registered.
Name of Country/English Name of Foreign Financial Regulatory Authority
India - Securities and Exchange Board of India
Yes No
6. (a) Is this a "master fund" in a master-feeder arrangement?
(b) If yes, what is the name and private fund identification number (if any) of the feeder funds investing in this private fund?
Name of private fund Private fund identification number
JM FINANCIAL - OLD LANE INDIA CORPORATE OPPORTUNITIES II LIMITED 805-1542831184
Yes No
(c) Is this a "feeder fund" in a master-feeder arrangement?
(d) If yes, what is the name and private fund identification number (if any) of the master fund in which this private fund invests?
Name of private fund:
Private fund identification number:
(include the "805-" prefix also)
NOTE: You must complete question 6 for each master-feeder arrangement regardless of whether you are filing a single Schedule D, Section 7.B.(1) for the
master-feeder arrangement or reporting on the funds separately.
7. If you are filing a single Schedule D, Section 7.B.(1) for a master-feeder arrangement according to the instructions to this Section 7.B.(1), for each of the feeder
funds answer the following questions:
Additional Feeder Fund Information : 1 Record(s) Filed.
7. If you are filing a single Schedule D, Section 7.B.(1) for a master-feeder arrangement according to the instructions to this Section 7.B.(1), for each of the
feeder funds answer the following questions:
(a) Name of the private fund:
JM FINANCIAL - OLD LANE INDIA CORPORATE OPPORTUNITIES II LIMITED
(b) Private fund identification number:
(include the "805-" prefix also)
805-1542831184
(c) Under the laws of what state or country is the private fund organized:
State: Country:
Mauritius
(d) (1) Name(s) of General Partner, Manager, Trustee or Directors (or persons serving in a similar capacity):
Name of General Partner, Manager, Trustee or Director
SOOPAYA PARIANEN
THAMOTHIRAM MANOGARAN
(d) (2) If filing an umbrella registration, identify the filing adviser and/or relying adviser(s) that sponsor(s) or manage(s) this private fund:
No Information Filed
(e) The private fund (check all that apply; you must check at least one):
(1) qualifies for the exclusion from the definition of investment company under section 3(c)(1) of the Investment Company Act of 1940
(2) qualifies for the exclusion from the definition of investment company under section 3(c)(7) of the Investment Company Act of 1940
(f) List the name and country, in English, of each foreign financial regulatory authority with which the private fund is registered.
Name of Country/English Name of Foreign Financial Regulatory Authority
Mauritius, Republic of - Financial Services Commission
NOTE: For purposes of questions 6 and 7, in a master-feeder arrangement, one or more funds ("feeder funds") invest all or substantially all of their assets in a
single fund ("master fund"). A fund would also be a "feeder fund" investing in a "master fund" for purposes of this question if it issued multiple classes (or
series) of shares or interests, and each class (or series) invests substantially all of its assets in a single master fund.
Yes No
8. (a) Is this private fund a "fund of funds"?
NOTE: For purposes of this question only, answer "yes" if the fund invests 10 percent or more of its total assets in other pooled investment vehicles,
regardless of whether they are also private funds or registered investment companies.
(b) If yes, does the private fund invest in funds managed by you or by a related person?
Yes No
9. During your last fiscal year, did the private fund invest in securities issued by investment companies registered under the Investment Company Act of
1940 (other than "money market funds," to the extent provided in Instruction 6.e.)?
10. What type of fund is the private fund?
hedge fund liquidity fund private equity fund real estate fund securitized asset fund venture capital fund Other private fund:
NOTE: For definitions of these fund types, please see Instruction 6 of the Instructions to Part 1A.
11. Current gross asset value of the private fund:
$ 2,961,810
Ownership
12. Minimum investment commitment required of an investor in the private fund:
$ 22,300
NOTE: Report the amount routinely required of investors who are not your related persons (even if different from the amount set forth in the organizational
documents of the fund).
13. Approximate number of the private fund's beneficial owners:
90
14. What is the approximate percentage of the private fund beneficially owned by you and your related persons:
4%
15. (a) What is the approximate percentage of the private fund beneficially owned (in the aggregate) by funds of funds:
22%
Yes No
(b) If the private fund qualifies for the exclusion from the definition of investment company under section 3(c)(1) of the Investment Company Act of
1940, are sales of the fund limited to qualified clients?
16. What is the approximate percentage of the private fund beneficially owned by non-United States persons:
74%
Your Advisory Services
Yes No
17. (a) Are you a subadviser to this private fund?
(b) If the answer to question 17.(a) is "yes," provide the name and SEC file number, if any, of the adviser of the private fund. If the answer to question 17.(a)
is "no," leave this question blank.
No Information Filed
Yes No
18. (a) Do any investment advisers (other than the investment advisers listed in Section 7.B.(1).A.3.(b)) advise the private fund?
(b) If the answer to question 18.(a) is "yes," provide the name and SEC file number, if any, of the other advisers to the private fund. If the answer to question
18.(a) is "no," leave this question blank.
No Information Filed
Yes No
19. Are your clients solicited to invest in the private fund?
NOTE: For purposes of this question, do not consider feeder funds of the private fund.
20. Approximately what percentage of your clients has invested in the private fund?
0%
Private Offering
Yes No
21. Has the private fund ever relied on an exemption from registration of its securities under Regulation D of the Securities Act of 1933?
22. If yes, provide the private fund's Form D file number (if any):
No Information Filed
B. SERVICE PROVIDERS
Auditors
Yes No
23. (a) (1) Are the private fund's financial statements subject to an annual audit?
(2) If the answer to question 23.(a)(1) is "yes," are the financial statements prepared in accordance with U.S. GAAP?
If the answer to question 23.(a)(1) is "yes," respond to questions (b) through (h) below. If the private fund uses more than one auditing firm, you must
complete questions (b) through (f) separately for each auditing firm.
Additional Auditor Information : 1 Record(s) Filed.
If the answer to question 23.(a)(1) is "yes," respond to questions (b) through (h) below. If the private fund uses more than one auditing firm, you
must complete questions (b) through (f) separately for each auditing firm.
(b) Name of the auditing firm:
B S R & CO LLP
(c) The location of the auditing firm's office responsible for the private fund's audit (city, state and country):
City: State: Country:
MUMBAI India
Yes No
(d) Is the auditing firm an independent public accountant?
(e) Is the auditing firm registered with the Public Company Accounting Oversight Board?
If yes, Public Company Accounting Oversight Board-Assigned Number:
1209
(f) If "yes" to (e) above, is the auditing firm subject to regular inspection by the Public Company Accounting Oversight Board in accordance
with its rules?
Yes No
(g) Are the private fund's audited financial statements for the most recently completed fiscal year distributed to the private fund's investors?
(h) Do all of the reports prepared by the auditing firm for the private fund since your last annual updating amendment contain unqualified opinions?
Yes No Report Not Yet Received
If you check "Report Not Yet Received," you must promptly file an amendment to your Form ADV to update your response when the report is available.
Prime Broker
Yes No
24. (a) Does the private fund use one or more prime brokers?
If the answer to question 24.(a) is "yes," respond to questions (b) through (e) below for each prime broker the private fund uses. If the private fund uses
more than one prime broker, you must complete questions (b) through (e) separately for each prime broker.
No Information Filed
Custodian
Yes No
25. (a) Does the private fund use any custodians (including the prime brokers listed above) to hold some or all of its assets?
If the answer to question 25.(a) is "yes," respond to questions (b) through (g) below for each custodian the private fund uses. If the private fund uses more
than one custodian, you must complete questions (b) through (g) separately for each custodian.
Additional Custodian Information : 1 Record(s) Filed.
If the answer to question 25.(a) is "yes," respond to questions (b) through g) below for each custodian the private fund uses. If the private fund uses
more than one custodian, you must complete questions (b) through (g) separately for each custodian.
(b) Legal name of custodian:
HDFC BANK LIMITED
(c) Primary business name of custodian:
HDFC BANK LIMITED
(d) The location of the custodian's office responsible for custody of the private fund's assets (city, state and country):
City: State: Country:
MUMBAI India
Yes No
(e) Is the custodian a related person of your firm?
(f) If the custodian is a broker-dealer, provide its SEC registration number (if any):
-
CRD Number (if any):
(g) If the custodian is not a broker-dealer, or is a broker-dealer but does not have an SEC registration number, provide its legal entity identifier (if any)
Administrator
Yes No
26. (a) Does the private fund use an administrator other than your firm?
If the answer to question 26.(a) is "yes," respond to questions (b) through (f) below. If the private fund uses more than one administrator, you must
complete questions (b) through (f) separately for each administrator.
No Information Filed
27. During your last fiscal year, what percentage of the private fund's assets (by value) was valued by a person, such as an administrator, that is not your related
person?
0%
Include only those assets where (i) such person carried out the valuation procedure established for that asset, if any, including obtaining any relevant quotes,
and (ii) the valuation used for purposes of investor subscriptions, redemptions or distributions, and fee calculations (including allocations) was the valuation
determined by such person.
Marketers
Yes No
28. (a) Does the private fund use the services of someone other than you or your employees for marketing purposes?
You must answer "yes" whether the person acts as a placement agent, consultant, finder, introducer, municipal advisor or other solicitor, or similar person.
If the answer to question 28.(a) is "yes," respond to questions (b) through (g) below for each such marketer the private fund uses. If the private fund uses
more than one marketer you must complete questions (b) through (g) separately for each marketer.
Additional Marketer Information : 2 Record(s) Filed.
You must answer "yes" whether the person acts as a placement agent, consultant, finder, introducer, municipal advisor or other solicitor, or similar
person. If the answer to question 28.(a) is "yes," respond to questions (b) through (g) below for each such marketer the private fund uses. If the
private fund uses more than one marketer, you must complete questions (b) through (g) separately for each marketer.
Yes No
(b) Is the marketer a related person of your firm?
(c) Name of the marketer:
ICICI BANK LIMITED
(d) If the marketer is registered with the SEC, its file number (e.g., 801-, 8-, or 866-):
-
and CRD Number (if any):
(e) Location of the marketer's office used principally by the private fund (city, state and country):
City: State: Country:
MUMBAI India
Yes No
(f) Does the marketer market the private fund through one or more websites?
(g) If the answer to question 28.(f) is "yes," list the website address(es):
No Information Filed
You must answer "yes" whether the person acts as a placement agent, consultant, finder, introducer, municipal advisor or other solicitor, or similar
person. If the answer to question 28.(a) is "yes," respond to questions (b) through (g) below for each such marketer the private fund uses. If the
private fund uses more than one marketer, you must complete questions (b) through (g) separately for each marketer.
Yes No
(b) Is the marketer a related person of your firm?
(c) Name of the marketer:
JM FINANCIAL SERVICES LIMITED
(d) If the marketer is registered with the SEC, its file number (e.g., 801-, 8-, or 866-):
-
and CRD Number (if any):
(e) Location of the marketer's office used principally by the private fund (city, state and country):
City: State: Country:
MUMBAI India
Yes No
(f) Does the marketer market the private fund through one or more websites?
(g) If the answer to question 28.(f) is "yes," list the website address(es):
No Information Filed
A. PRIVATE FUND
Information About the Private Fund
1. (a) Name of the private fund:
JM FINANCIAL INDIA FUND II - A SCHEME OF JM FINANCIAL INDIA TRUST II
(b) Private fund identification number:
(include the "805-" prefix also)
805-9157454572
2. Under the laws of what state or country is the private fund organized:
State: Country:
India
3. (a) Name(s) of General Partner, Manager, Trustee, or Directors (or persons serving in a similar capacity):
Name of General Partner, Manager, Trustee, or Director
JM FINANCIAL TRUSTEE COMPANY PRIVATE LIMITED
(b) If filing an umbrella registration, identify the filing adviser and/or relying adviser(s) that sponsor(s) or manage(s) this private fund.
No Information Filed
4. The private fund (check all that apply; you must check at least one):
(1) qualifies for the exclusion from the definition of investment company under section 3(c)(1) of the Investment Company Act of 1940
(2) qualifies for the exclusion from the definition of investment company under section 3(c)(7) of the Investment Company Act of 1940
5. List the name and country, in English, of each foreign financial regulatory authority with which the private fund is registered.
Name of Country/English Name of Foreign Financial Regulatory Authority
India - Securities and Exchange Board of India
Yes No
6. (a) Is this a "master fund" in a master-feeder arrangement?
(b) If yes, what is the name and private fund identification number (if any) of the feeder funds investing in this private fund?
Name of private fund Private fund identification number
JM FINANCIAL INDIA FUND II (MAURITIUS) LIMITED 805-1406030048
Yes No
(c) Is this a "feeder fund" in a master-feeder arrangement?
(d) If yes, what is the name and private fund identification number (if any) of the master fund in which this private fund invests?
Name of private fund:
Private fund identification number:
(include the "805-" prefix also)
NOTE: You must complete question 6 for each master-feeder arrangement regardless of whether you are filing a single Schedule D, Section 7.B.(1) for the
master-feeder arrangement or reporting on the funds separately.
7. If you are filing a single Schedule D, Section 7.B.(1) for a master-feeder arrangement according to the instructions to this Section 7.B.(1), for each of the feeder
funds answer the following questions:
Additional Feeder Fund Information : 1 Record(s) Filed.
7. If you are filing a single Schedule D, Section 7.B.(1) for a master-feeder arrangement according to the instructions to this Section 7.B.(1), for each of the
feeder funds answer the following questions:
(a) Name of the private fund:
JM FINANCIAL INDIA FUND II (MAURITIUS) LIMITED
(b) Private fund identification number:
(include the "805-" prefix also)
805-1406030048
(c) Under the laws of what state or country is the private fund organized:
State: Country:
Mauritius
(d) (1) Name(s) of General Partner, Manager, Trustee or Directors (or persons serving in a similar capacity):
Name of General Partner, Manager, Trustee or Director
JOSE ARUNASALOM
SOOPAYA PARIANEN
THAMOTHIRAM MANOGARAN
(d) (2) If filing an umbrella registration, identify the filing adviser and/or relying adviser(s) that sponsor(s) or manage(s) this private fund:
No Information Filed
(e) The private fund (check all that apply; you must check at least one):
(1) qualifies for the exclusion from the definition of investment company under section 3(c)(1) of the Investment Company Act of 1940
(2) qualifies for the exclusion from the definition of investment company under section 3(c)(7) of the Investment Company Act of 1940
(f) List the name and country, in English, of each foreign financial regulatory authority with which the private fund is registered.
Name of Country/English Name of Foreign Financial Regulatory Authority
Mauritius, Republic of - Financial Services Commission
NOTE: For purposes of questions 6 and 7, in a master-feeder arrangement, one or more funds ("feeder funds") invest all or substantially all of their assets in a
single fund ("master fund"). A fund would also be a "feeder fund" investing in a "master fund" for purposes of this question if it issued multiple classes (or
series) of shares or interests, and each class (or series) invests substantially all of its assets in a single master fund.
Yes No
8. (a) Is this private fund a "fund of funds"?
NOTE: For purposes of this question only, answer "yes" if the fund invests 10 percent or more of its total assets in other pooled investment vehicles,
regardless of whether they are also private funds or registered investment companies.
(b) If yes, does the private fund invest in funds managed by you or by a related person?
Yes No
9. During your last fiscal year, did the private fund invest in securities issued by investment companies registered under the Investment Company Act of
1940 (other than "money market funds," to the extent provided in Instruction 6.e.)?
10. What type of fund is the private fund?
hedge fund liquidity fund private equity fund real estate fund securitized asset fund venture capital fund Other private fund:
NOTE: For definitions of these fund types, please see Instruction 6 of the Instructions to Part 1A.
11. Current gross asset value of the private fund:
$ 52,420,480
Ownership
12. Minimum investment commitment required of an investor in the private fund:
$ 141,000
NOTE: Report the amount routinely required of investors who are not your related persons (even if different from the amount set forth in the organizational
documents of the fund).
13. Approximate number of the private fund's beneficial owners:
80
14. What is the approximate percentage of the private fund beneficially owned by you and your related persons:
18%
15. (a) What is the approximate percentage of the private fund beneficially owned (in the aggregate) by funds of funds:
21%
Yes No
(b) If the private fund qualifies for the exclusion from the definition of investment company under section 3(c)(1) of the Investment Company Act of
1940, are sales of the fund limited to qualified clients?
16. What is the approximate percentage of the private fund beneficially owned by non-United States persons:
97%
Your Advisory Services
Yes No
17. (a) Are you a subadviser to this private fund?
(b) If the answer to question 17.(a) is "yes," provide the name and SEC file number, if any, of the adviser of the private fund. If the answer to question 17.(a)
is "no," leave this question blank.
No Information Filed
Yes No
18. (a) Do any investment advisers (other than the investment advisers listed in Section 7.B.(1).A.3.(b)) advise the private fund?
(b) If the answer to question 18.(a) is "yes," provide the name and SEC file number, if any, of the other advisers to the private fund. If the answer to question
18.(a) is "no," leave this question blank.
No Information Filed
Yes No
19. Are your clients solicited to invest in the private fund?
NOTE: For purposes of this question, do not consider feeder funds of the private fund.
20. Approximately what percentage of your clients has invested in the private fund?
0%
Private Offering
Yes No
21. Has the private fund ever relied on an exemption from registration of its securities under Regulation D of the Securities Act of 1933?
22. If yes, provide the private fund's Form D file number (if any):
No Information Filed
B. SERVICE PROVIDERS
Auditors
Yes No
23. (a) (1) Are the private fund's financial statements subject to an annual audit?
(2) If the answer to question 23.(a)(1) is "yes," are the financial statements prepared in accordance with U.S. GAAP?
If the answer to question 23.(a)(1) is "yes," respond to questions (b) through (h) below. If the private fund uses more than one auditing firm, you must
complete questions (b) through (f) separately for each auditing firm.
Additional Auditor Information : 1 Record(s) Filed.
If the answer to question 23.(a)(1) is "yes," respond to questions (b) through (h) below. If the private fund uses more than one auditing firm, you
must complete questions (b) through (f) separately for each auditing firm.
(b) Name of the auditing firm:
B S R & CO LLP
(c) The location of the auditing firm's office responsible for the private fund's audit (city, state and country):
City: State: Country:
MUMBAI India
Yes No
(d) Is the auditing firm an independent public accountant?
(e) Is the auditing firm registered with the Public Company Accounting Oversight Board?
If yes, Public Company Accounting Oversight Board-Assigned Number:
1209
(f) If "yes" to (e) above, is the auditing firm subject to regular inspection by the Public Company Accounting Oversight Board in accordance
with its rules?
Yes No
(g) Are the private fund's audited financial statements for the most recently completed fiscal year distributed to the private fund's investors?
(h) Do all of the reports prepared by the auditing firm for the private fund since your last annual updating amendment contain unqualified opinions?
Yes No Report Not Yet Received
If you check "Report Not Yet Received," you must promptly file an amendment to your Form ADV to update your response when the report is available.
Prime Broker
Yes No
24. (a) Does the private fund use one or more prime brokers?
If the answer to question 24.(a) is "yes," respond to questions (b) through (e) below for each prime broker the private fund uses. If the private fund uses
more than one prime broker, you must complete questions (b) through (e) separately for each prime broker.
No Information Filed
Custodian
Yes No
25. (a) Does the private fund use any custodians (including the prime brokers listed above) to hold some or all of its assets?
If the answer to question 25.(a) is "yes," respond to questions (b) through (g) below for each custodian the private fund uses. If the private fund uses more
than one custodian, you must complete questions (b) through (g) separately for each custodian.
Additional Custodian Information : 1 Record(s) Filed.
If the answer to question 25.(a) is "yes," respond to questions (b) through g) below for each custodian the private fund uses. If the private fund uses
more than one custodian, you must complete questions (b) through (g) separately for each custodian.
(b) Legal name of custodian:
HDFC BANK LIMITED
(c) Primary business name of custodian:
HDFC BANK LIMITED
(d) The location of the custodian's office responsible for custody of the private fund's assets (city, state and country):
City: State: Country:
MUMBAI India
Yes No
(e) Is the custodian a related person of your firm?
(f) If the custodian is a broker-dealer, provide its SEC registration number (if any):
-
CRD Number (if any):
(g) If the custodian is not a broker-dealer, or is a broker-dealer but does not have an SEC registration number, provide its legal entity identifier (if any)
Administrator
Yes No
26. (a) Does the private fund use an administrator other than your firm?
If the answer to question 26.(a) is "yes," respond to questions (b) through (f) below. If the private fund uses more than one administrator, you must
complete questions (b) through (f) separately for each administrator.
No Information Filed
27. During your last fiscal year, what percentage of the private fund's assets (by value) was valued by a person, such as an administrator, that is not your related
person?
100%
Include only those assets where (i) such person carried out the valuation procedure established for that asset, if any, including obtaining any relevant quotes,
and (ii) the valuation used for purposes of investor subscriptions, redemptions or distributions, and fee calculations (including allocations) was the valuation
determined by such person.
Marketers
Yes No
28. (a) Does the private fund use the services of someone other than you or your employees for marketing purposes?
You must answer "yes" whether the person acts as a placement agent, consultant, finder, introducer, municipal advisor or other solicitor, or similar person.
If the answer to question 28.(a) is "yes," respond to questions (b) through (g) below for each such marketer the private fund uses. If the private fund uses
more than one marketer you must complete questions (b) through (g) separately for each marketer.
Additional Marketer Information : 4 Record(s) Filed.
You must answer "yes" whether the person acts as a placement agent, consultant, finder, introducer, municipal advisor or other solicitor, or similar
person. If the answer to question 28.(a) is "yes," respond to questions (b) through (g) below for each such marketer the private fund uses. If the
private fund uses more than one marketer, you must complete questions (b) through (g) separately for each marketer.
Yes No
(b) Is the marketer a related person of your firm?
(c) Name of the marketer:
ATHUL MURALI
(d) If the marketer is registered with the SEC, its file number (e.g., 801-, 8-, or 866-):
-
and CRD Number (if any):
(e) Location of the marketer's office used principally by the private fund (city, state and country):
City: State: Country:
ERNAKULAM India
Yes No
(f) Does the marketer market the private fund through one or more websites?
(g) If the answer to question 28.(f) is "yes," list the website address(es):
No Information Filed
You must answer "yes" whether the person acts as a placement agent, consultant, finder, introducer, municipal advisor or other solicitor, or similar
person. If the answer to question 28.(a) is "yes," respond to questions (b) through (g) below for each such marketer the private fund uses. If the
private fund uses more than one marketer, you must complete questions (b) through (g) separately for each marketer.
Yes No
(b) Is the marketer a related person of your firm?
(c) Name of the marketer:
AVESTAR ADVISORY
(d) If the marketer is registered with the SEC, its file number (e.g., 801-, 8-, or 866-):
-
and CRD Number (if any):
(e) Location of the marketer's office used principally by the private fund (city, state and country):
City: State: Country:
MUMBAI India
Yes No
(f) Does the marketer market the private fund through one or more websites?
(g) If the answer to question 28.(f) is "yes," list the website address(es):
No Information Filed
You must answer "yes" whether the person acts as a placement agent, consultant, finder, introducer, municipal advisor or other solicitor, or similar
person. If the answer to question 28.(a) is "yes," respond to questions (b) through (g) below for each such marketer the private fund uses. If the
private fund uses more than one marketer, you must complete questions (b) through (g) separately for each marketer.
Yes No
(b) Is the marketer a related person of your firm?
(c) Name of the marketer:
JM FINANCIAL SERVICES LIMITED
(d) If the marketer is registered with the SEC, its file number (e.g., 801-, 8-, or 866-):
-
and CRD Number (if any):
(e) Location of the marketer's office used principally by the private fund (city, state and country):
City: State: Country:
MUMBAI India
Yes No
(f) Does the marketer market the private fund through one or more websites?
(g) If the answer to question 28.(f) is "yes," list the website address(es):
No Information Filed
You must answer "yes" whether the person acts as a placement agent, consultant, finder, introducer, municipal advisor or other solicitor, or similar
person. If the answer to question 28.(a) is "yes," respond to questions (b) through (g) below for each such marketer the private fund uses. If the
private fund uses more than one marketer, you must complete questions (b) through (g) separately for each marketer.
Yes No
(b) Is the marketer a related person of your firm?
(c) Name of the marketer:
POSITRON CONSULTING SERVICES PRIVATE LIMITED
(d) If the marketer is registered with the SEC, its file number (e.g., 801-, 8-, or 866-):
-
and CRD Number (if any):
(e) Location of the marketer's office used principally by the private fund (city, state and country):
City: State: Country:
MUMBAI India
Yes No
(f) Does the marketer market the private fund through one or more websites?
(g) If the answer to question 28.(f) is "yes," list the website address(es):
No Information Filed
A. PRIVATE FUND
Information About the Private Fund
1. (a) Name of the private fund:
JM FINANCIAL INDIA FUND III
(b) Private fund identification number:
(include the "805-" prefix also)
805-4655224504
2. Under the laws of what state or country is the private fund organized:
State: Country:
India
3. (a) Name(s) of General Partner, Manager, Trustee, or Directors (or persons serving in a similar capacity):
Name of General Partner, Manager, Trustee, or Director
JM FINANCIAL TRUSTEE COMPANY PRIVATE LIMITED
(b) If filing an umbrella registration, identify the filing adviser and/or relying adviser(s) that sponsor(s) or manage(s) this private fund.
No Information Filed
4. The private fund (check all that apply; you must check at least one):
(1) qualifies for the exclusion from the definition of investment company under section 3(c)(1) of the Investment Company Act of 1940
(2) qualifies for the exclusion from the definition of investment company under section 3(c)(7) of the Investment Company Act of 1940
5. List the name and country, in English, of each foreign financial regulatory authority with which the private fund is registered.
No Information Filed
Yes No
6. (a) Is this a "master fund" in a master-feeder arrangement?
(b) If yes, what is the name and private fund identification number (if any) of the feeder funds investing in this private fund?
No Information Filed
Yes No
(c) Is this a "feeder fund" in a master-feeder arrangement?
(d) If yes, what is the name and private fund identification number (if any) of the master fund in which this private fund invests?
Name of private fund:
Private fund identification number:
(include the "805-" prefix also)
NOTE: You must complete question 6 for each master-feeder arrangement regardless of whether you are filing a single Schedule D, Section 7.B.(1) for the
master-feeder arrangement or reporting on the funds separately.
7. If you are filing a single Schedule D, Section 7.B.(1) for a master-feeder arrangement according to the instructions to this Section 7.B.(1), for each of the feeder
funds answer the following questions:
No Information Filed
NOTE: For purposes of questions 6 and 7, in a master-feeder arrangement, one or more funds ("feeder funds") invest all or substantially all of their assets in a
single fund ("master fund"). A fund would also be a "feeder fund" investing in a "master fund" for purposes of this question if it issued multiple classes (or
series) of shares or interests, and each class (or series) invests substantially all of its assets in a single master fund.
Yes No
8. (a) Is this private fund a "fund of funds"?
NOTE: For purposes of this question only, answer "yes" if the fund invests 10 percent or more of its total assets in other pooled investment vehicles,
regardless of whether they are also private funds or registered investment companies.
(b) If yes, does the private fund invest in funds managed by you or by a related person?
Yes No
9. During your last fiscal year, did the private fund invest in securities issued by investment companies registered under the Investment Company Act of
1940 (other than "money market funds," to the extent provided in Instruction 6.e.)?
10. What type of fund is the private fund?
hedge fund liquidity fund private equity fund real estate fund securitized asset fund venture capital fund Other private fund:
NOTE: For definitions of these fund types, please see Instruction 6 of the Instructions to Part 1A.
11. Current gross asset value of the private fund:
$ 817,386
Ownership
12. Minimum investment commitment required of an investor in the private fund:
$ 22,300
NOTE: Report the amount routinely required of investors who are not your related persons (even if different from the amount set forth in the organizational
documents of the fund).
13. Approximate number of the private fund's beneficial owners:
90
14. What is the approximate percentage of the private fund beneficially owned by you and your related persons:
4%
15. (a) What is the approximate percentage of the private fund beneficially owned (in the aggregate) by funds of funds:
22%
Yes No
(b) If the private fund qualifies for the exclusion from the definition of investment company under section 3(c)(1) of the Investment Company Act of
1940, are sales of the fund limited to qualified clients?
16. What is the approximate percentage of the private fund beneficially owned by non-United States persons:
74%
Your Advisory Services
Yes No
17. (a) Are you a subadviser to this private fund?
(b) If the answer to question 17.(a) is "yes," provide the name and SEC file number, if any, of the adviser of the private fund. If the answer to question 17.(a)
is "no," leave this question blank.
No Information Filed
Yes No
18. (a) Do any investment advisers (other than the investment advisers listed in Section 7.B.(1).A.3.(b)) advise the private fund?
(b) If the answer to question 18.(a) is "yes," provide the name and SEC file number, if any, of the other advisers to the private fund. If the answer to question
18.(a) is "no," leave this question blank.
No Information Filed
Yes No
19. Are your clients solicited to invest in the private fund?
NOTE: For purposes of this question, do not consider feeder funds of the private fund.
20. Approximately what percentage of your clients has invested in the private fund?
0%
Private Offering
Yes No
21. Has the private fund ever relied on an exemption from registration of its securities under Regulation D of the Securities Act of 1933?
22. If yes, provide the private fund's Form D file number (if any):
No Information Filed
B. SERVICE PROVIDERS
Auditors
Yes No
23. (a) (1) Are the private fund's financial statements subject to an annual audit?
(2) If the answer to question 23.(a)(1) is "yes," are the financial statements prepared in accordance with U.S. GAAP?
If the answer to question 23.(a)(1) is "yes," respond to questions (b) through (h) below. If the private fund uses more than one auditing firm, you must
complete questions (b) through (f) separately for each auditing firm.
Additional Auditor Information : 1 Record(s) Filed.
If the answer to question 23.(a)(1) is "yes," respond to questions (b) through (h) below. If the private fund uses more than one auditing firm, you
must complete questions (b) through (f) separately for each auditing firm.
(b) Name of the auditing firm:
B S R & CO LLP
(c) The location of the auditing firm's office responsible for the private fund's audit (city, state and country):
City: State: Country:
MUMBAI India
Yes No
(d) Is the auditing firm an independent public accountant?
(e) Is the auditing firm registered with the Public Company Accounting Oversight Board?
If yes, Public Company Accounting Oversight Board-Assigned Number:
1209
(f) If "yes" to (e) above, is the auditing firm subject to regular inspection by the Public Company Accounting Oversight Board in accordance
with its rules?
Yes No
(g) Are the private fund's audited financial statements for the most recently completed fiscal year distributed to the private fund's investors?
(h) Do all of the reports prepared by the auditing firm for the private fund since your last annual updating amendment contain unqualified opinions?
Yes No Report Not Yet Received
If you check "Report Not Yet Received," you must promptly file an amendment to your Form ADV to update your response when the report is available.
Prime Broker
Yes No
24. (a) Does the private fund use one or more prime brokers?
If the answer to question 24.(a) is "yes," respond to questions (b) through (e) below for each prime broker the private fund uses. If the private fund uses
more than one prime broker, you must complete questions (b) through (e) separately for each prime broker.
No Information Filed
Custodian
Yes No
25. (a) Does the private fund use any custodians (including the prime brokers listed above) to hold some or all of its assets?
If the answer to question 25.(a) is "yes," respond to questions (b) through (g) below for each custodian the private fund uses. If the private fund uses more
than one custodian, you must complete questions (b) through (g) separately for each custodian.
Additional Custodian Information : 1 Record(s) Filed.
If the answer to question 25.(a) is "yes," respond to questions (b) through g) below for each custodian the private fund uses. If the private fund uses
more than one custodian, you must complete questions (b) through (g) separately for each custodian.
(b) Legal name of custodian:
HDFC BANK LIMITED
(c) Primary business name of custodian:
HDFC BANK LIMITED
(d) The location of the custodian's office responsible for custody of the private fund's assets (city, state and country):
City: State: Country:
MUMBAI India
Yes No
(e) Is the custodian a related person of your firm?
(f) If the custodian is a broker-dealer, provide its SEC registration number (if any):
-
CRD Number (if any):
(g) If the custodian is not a broker-dealer, or is a broker-dealer but does not have an SEC registration number, provide its legal entity identifier (if any)
Administrator
Yes No
26. (a) Does the private fund use an administrator other than your firm?
If the answer to question 26.(a) is "yes," respond to questions (b) through (f) below. If the private fund uses more than one administrator, you must
complete questions (b) through (f) separately for each administrator.
No Information Filed
27. During your last fiscal year, what percentage of the private fund's assets (by value) was valued by a person, such as an administrator, that is not your related
person?
0%
Include only those assets where (i) such person carried out the valuation procedure established for that asset, if any, including obtaining any relevant quotes,
and (ii) the valuation used for purposes of investor subscriptions, redemptions or distributions, and fee calculations (including allocations) was the valuation
determined by such person.
Marketers
Yes No
28. (a) Does the private fund use the services of someone other than you or your employees for marketing purposes?
You must answer "yes" whether the person acts as a placement agent, consultant, finder, introducer, municipal advisor or other solicitor, or similar person.
If the answer to question 28.(a) is "yes," respond to questions (b) through (g) below for each such marketer the private fund uses. If the private fund uses
more than one marketer you must complete questions (b) through (g) separately for each marketer.
Additional Marketer Information : 2 Record(s) Filed.
You must answer "yes" whether the person acts as a placement agent, consultant, finder, introducer, municipal advisor or other solicitor, or similar
person. If the answer to question 28.(a) is "yes," respond to questions (b) through (g) below for each such marketer the private fund uses. If the
private fund uses more than one marketer, you must complete questions (b) through (g) separately for each marketer.
Yes No
(b) Is the marketer a related person of your firm?
(c) Name of the marketer:
ICICI BANK LIMITED
(d) If the marketer is registered with the SEC, its file number (e.g., 801-, 8-, or 866-):
-
and CRD Number (if any):
(e) Location of the marketer's office used principally by the private fund (city, state and country):
City: State: Country:
MUMBAI India
Yes No
(f) Does the marketer market the private fund through one or more websites?
(g) If the answer to question 28.(f) is "yes," list the website address(es):
No Information Filed
You must answer "yes" whether the person acts as a placement agent, consultant, finder, introducer, municipal advisor or other solicitor, or similar
person. If the answer to question 28.(a) is "yes," respond to questions (b) through (g) below for each such marketer the private fund uses. If the
private fund uses more than one marketer, you must complete questions (b) through (g) separately for each marketer.
Yes No
(b) Is the marketer a related person of your firm?
(c) Name of the marketer:
JM FINANCIAL SERVICES LIMITED
(d) If the marketer is registered with the SEC, its file number (e.g., 801-, 8-, or 866-):
-
and CRD Number (if any):
(e) Location of the marketer's office used principally by the private fund (city, state and country):
City: State: Country:
MUMBAI India
Yes No
(f) Does the marketer market the private fund through one or more websites?
(g) If the answer to question 28.(f) is "yes," list the website address(es):
No Information Filed
A. PRIVATE FUND
Information About the Private Fund
1. (a) Name of the private fund:
JM FINANCIAL INDIA GROWTH FUND III (A SCHEME OF JM FINANCIAL INDIA GROWTH TRUST III)
(b) Private fund identification number:
(include the "805-" prefix also)
805-9525682993
2. Under the laws of what state or country is the private fund organized:
State: Country:
India
3. (a) Name(s) of General Partner, Manager, Trustee, or Directors (or persons serving in a similar capacity):
Name of General Partner, Manager, Trustee, or Director
BEACON TRUSTEESHIP LIMITED
(b) If filing an umbrella registration, identify the filing adviser and/or relying adviser(s) that sponsor(s) or manage(s) this private fund.
No Information Filed
4. The private fund (check all that apply; you must check at least one):
(1) qualifies for the exclusion from the definition of investment company under section 3(c)(1) of the Investment Company Act of 1940
(2) qualifies for the exclusion from the definition of investment company under section 3(c)(7) of the Investment Company Act of 1940
5. List the name and country, in English, of each foreign financial regulatory authority with which the private fund is registered.
Name of Country/English Name of Foreign Financial Regulatory Authority
India - Securities and Exchange Board of India
Yes No
6. (a) Is this a "master fund" in a master-feeder arrangement?
(b) If yes, what is the name and private fund identification number (if any) of the feeder funds investing in this private fund?
Name of private fund Private fund identification number
JM FINANCIAL INDIA GROWTH FUND III VCC 805-9165849570
Yes No
(c) Is this a "feeder fund" in a master-feeder arrangement?
(d) If yes, what is the name and private fund identification number (if any) of the master fund in which this private fund invests?
Name of private fund:
Private fund identification number:
(include the "805-" prefix also)
NOTE: You must complete question 6 for each master-feeder arrangement regardless of whether you are filing a single Schedule D, Section 7.B.(1) for the
master-feeder arrangement or reporting on the funds separately.
7. If you are filing a single Schedule D, Section 7.B.(1) for a master-feeder arrangement according to the instructions to this Section 7.B.(1), for each of the feeder
funds answer the following questions:
Additional Feeder Fund Information : 1 Record(s) Filed.
7. If you are filing a single Schedule D, Section 7.B.(1) for a master-feeder arrangement according to the instructions to this Section 7.B.(1), for each of the
feeder funds answer the following questions:
(a) Name of the private fund:
JM FINANCIAL INDIA GROWTH FUND III VCC
(b) Private fund identification number:
(include the "805-" prefix also)
805-9165849570
(c) Under the laws of what state or country is the private fund organized:
State: Country:
Singapore
(d) (1) Name(s) of General Partner, Manager, Trustee or Directors (or persons serving in a similar capacity):
Name of General Partner, Manager, Trustee or Director
ARIFIN SEAL
SAMEER KAUL
(d) (2) If filing an umbrella registration, identify the filing adviser and/or relying adviser(s) that sponsor(s) or manage(s) this private fund:
No Information Filed
(e) The private fund (check all that apply; you must check at least one):
(1) qualifies for the exclusion from the definition of investment company under section 3(c)(1) of the Investment Company Act of 1940
(2) qualifies for the exclusion from the definition of investment company under section 3(c)(7) of the Investment Company Act of 1940
(f) List the name and country, in English, of each foreign financial regulatory authority with which the private fund is registered.
Name of Country/English Name of Foreign Financial Regulatory Authority
Singapore - Monetary Authority of Singapore
NOTE: For purposes of questions 6 and 7, in a master-feeder arrangement, one or more funds ("feeder funds") invest all or substantially all of their assets in a
single fund ("master fund"). A fund would also be a "feeder fund" investing in a "master fund" for purposes of this question if it issued multiple classes (or
series) of shares or interests, and each class (or series) invests substantially all of its assets in a single master fund.
Yes No
8. (a) Is this private fund a "fund of funds"?
NOTE: For purposes of this question only, answer "yes" if the fund invests 10 percent or more of its total assets in other pooled investment vehicles,
regardless of whether they are also private funds or registered investment companies.
(b) If yes, does the private fund invest in funds managed by you or by a related person?
Yes No
9. During your last fiscal year, did the private fund invest in securities issued by investment companies registered under the Investment Company Act of
1940 (other than "money market funds," to the extent provided in Instruction 6.e.)?
10. What type of fund is the private fund?
hedge fund liquidity fund private equity fund real estate fund securitized asset fund venture capital fund Other private fund:
NOTE: For definitions of these fund types, please see Instruction 6 of the Instructions to Part 1A.
11. Current gross asset value of the private fund:
$ 67,738,437
Ownership
12. Minimum investment commitment required of an investor in the private fund:
$ 121,650
NOTE: Report the amount routinely required of investors who are not your related persons (even if different from the amount set forth in the organizational
documents of the fund).
13. Approximate number of the private fund's beneficial owners:
95
14. What is the approximate percentage of the private fund beneficially owned by you and your related persons:
17%
15. (a) What is the approximate percentage of the private fund beneficially owned (in the aggregate) by funds of funds:
0%
Yes No
(b) If the private fund qualifies for the exclusion from the definition of investment company under section 3(c)(1) of the Investment Company Act of
1940, are sales of the fund limited to qualified clients?
16. What is the approximate percentage of the private fund beneficially owned by non-United States persons:
100%
Your Advisory Services
Yes No
17. (a) Are you a subadviser to this private fund?
(b) If the answer to question 17.(a) is "yes," provide the name and SEC file number, if any, of the adviser of the private fund. If the answer to question 17.(a)
is "no," leave this question blank.
No Information Filed
Yes No
18. (a) Do any investment advisers (other than the investment advisers listed in Section 7.B.(1).A.3.(b)) advise the private fund?
(b) If the answer to question 18.(a) is "yes," provide the name and SEC file number, if any, of the other advisers to the private fund. If the answer to question
18.(a) is "no," leave this question blank.
No Information Filed
Yes No
19. Are your clients solicited to invest in the private fund?
NOTE: For purposes of this question, do not consider feeder funds of the private fund.
20. Approximately what percentage of your clients has invested in the private fund?
0%
Private Offering
Yes No
21. Has the private fund ever relied on an exemption from registration of its securities under Regulation D of the Securities Act of 1933?
22. If yes, provide the private fund's Form D file number (if any):
No Information Filed
B. SERVICE PROVIDERS
Auditors
Yes No
23. (a) (1) Are the private fund's financial statements subject to an annual audit?
(2) If the answer to question 23.(a)(1) is "yes," are the financial statements prepared in accordance with U.S. GAAP?
If the answer to question 23.(a)(1) is "yes," respond to questions (b) through (h) below. If the private fund uses more than one auditing firm, you must
complete questions (b) through (f) separately for each auditing firm.
Additional Auditor Information : 1 Record(s) Filed.
If the answer to question 23.(a)(1) is "yes," respond to questions (b) through (h) below. If the private fund uses more than one auditing firm, you
must complete questions (b) through (f) separately for each auditing firm.
(b) Name of the auditing firm:
B S R & CO LLP
(c) The location of the auditing firm's office responsible for the private fund's audit (city, state and country):
City: State: Country:
MUMBAI India
Yes No
(d) Is the auditing firm an independent public accountant?
(e) Is the auditing firm registered with the Public Company Accounting Oversight Board?
If yes, Public Company Accounting Oversight Board-Assigned Number:
1209
(f) If "yes" to (e) above, is the auditing firm subject to regular inspection by the Public Company Accounting Oversight Board in accordance
with its rules?
Yes No
(g) Are the private fund's audited financial statements for the most recently completed fiscal year distributed to the private fund's investors?
(h) Do all of the reports prepared by the auditing firm for the private fund since your last annual updating amendment contain unqualified opinions?
Yes No Report Not Yet Received
If you check "Report Not Yet Received," you must promptly file an amendment to your Form ADV to update your response when the report is available.
Prime Broker
Yes No
24. (a) Does the private fund use one or more prime brokers?
If the answer to question 24.(a) is "yes," respond to questions (b) through (e) below for each prime broker the private fund uses. If the private fund uses
more than one prime broker, you must complete questions (b) through (e) separately for each prime broker.
No Information Filed
Custodian
Yes No
25. (a) Does the private fund use any custodians (including the prime brokers listed above) to hold some or all of its assets?
If the answer to question 25.(a) is "yes," respond to questions (b) through (g) below for each custodian the private fund uses. If the private fund uses more
than one custodian, you must complete questions (b) through (g) separately for each custodian.
Additional Custodian Information : 1 Record(s) Filed.
If the answer to question 25.(a) is "yes," respond to questions (b) through g) below for each custodian the private fund uses. If the private fund uses
more than one custodian, you must complete questions (b) through (g) separately for each custodian.
(b) Legal name of custodian:
HDFC BANK LIMITED
(c) Primary business name of custodian:
HDFC BANK LIMITED
(d) The location of the custodian's office responsible for custody of the private fund's assets (city, state and country):
City: State: Country:
MUMBAI India
Yes No
(e) Is the custodian a related person of your firm?
(f) If the custodian is a broker-dealer, provide its SEC registration number (if any):
-
CRD Number (if any):
(g) If the custodian is not a broker-dealer, or is a broker-dealer but does not have an SEC registration number, provide its legal entity identifier (if any)
Administrator
Yes No
26. (a) Does the private fund use an administrator other than your firm?
If the answer to question 26.(a) is "yes," respond to questions (b) through (f) below. If the private fund uses more than one administrator, you must
complete questions (b) through (f) separately for each administrator.
No Information Filed
27. During your last fiscal year, what percentage of the private fund's assets (by value) was valued by a person, such as an administrator, that is not your related
person?
100%
Include only those assets where (i) such person carried out the valuation procedure established for that asset, if any, including obtaining any relevant quotes,
and (ii) the valuation used for purposes of investor subscriptions, redemptions or distributions, and fee calculations (including allocations) was the valuation
determined by such person.
Marketers
Yes No
28. (a) Does the private fund use the services of someone other than you or your employees for marketing purposes?
You must answer "yes" whether the person acts as a placement agent, consultant, finder, introducer, municipal advisor or other solicitor, or similar person.
If the answer to question 28.(a) is "yes," respond to questions (b) through (g) below for each such marketer the private fund uses. If the private fund uses
more than one marketer you must complete questions (b) through (g) separately for each marketer.
Additional Marketer Information : 2 Record(s) Filed.
You must answer "yes" whether the person acts as a placement agent, consultant, finder, introducer, municipal advisor or other solicitor, or similar
person. If the answer to question 28.(a) is "yes," respond to questions (b) through (g) below for each such marketer the private fund uses. If the
private fund uses more than one marketer, you must complete questions (b) through (g) separately for each marketer.
Yes No
(b) Is the marketer a related person of your firm?
(c) Name of the marketer:
JM FINANCIAL SERVICES LIMITED
(d) If the marketer is registered with the SEC, its file number (e.g., 801-, 8-, or 866-):
-
and CRD Number (if any):
(e) Location of the marketer's office used principally by the private fund (city, state and country):
City: State: Country:
MUMBAI India
Yes No
(f) Does the marketer market the private fund through one or more websites?
(g) If the answer to question 28.(f) is "yes," list the website address(es):
No Information Filed
You must answer "yes" whether the person acts as a placement agent, consultant, finder, introducer, municipal advisor or other solicitor, or similar
person. If the answer to question 28.(a) is "yes," respond to questions (b) through (g) below for each such marketer the private fund uses. If the
private fund uses more than one marketer, you must complete questions (b) through (g) separately for each marketer.
Yes No
(b) Is the marketer a related person of your firm?
(c) Name of the marketer:
POSITRON CONSULTANCY SERVICES PRIVATE LIMITED
(d) If the marketer is registered with the SEC, its file number (e.g., 801-, 8-, or 866-):
-
and CRD Number (if any):
(e) Location of the marketer's office used principally by the private fund (city, state and country):
City: State: Country:
ERNAKULAM India
Yes No
(f) Does the marketer market the private fund through one or more websites?
(g) If the answer to question 28.(f) is "yes," list the website address(es):
No Information Filed
Funds per Page: 15 Total Funds: 4
SECTION 7.B.(2) Private Fund Reporting
No Information Filed
Item 10 Control Persons
In this Item, we ask you to identify every person that, directly or indirectly, controls you. If you are filing an umbrella registration, the information in Item 10 should be
provided for the filing adviser only.
If you are submitting an initial application or report, you must complete Schedule A and Schedule B. Schedule A asks for information about your direct owners and
executive officers. Schedule B asks for information about your indirect owners. If this is an amendment and you are updating information you reported on either
Schedule A or Schedule B (or both) that you filed with your initial application or report, you must complete Schedule C.
Yes No
A. Does any person not named in Item 1.A. or Schedules A, B, or C, directly or indirectly, control your management or policies?
If yes, complete Section 10.A. of Schedule D.
B. If any person named in Schedules A, B, or C or in Section 10.A. of Schedule D is a public reporting company under Sections 12 or 15(d) of the Securities Exchange Act
of 1934, please complete Section 10.B. of Schedule D.
SECTION 10.A. Control Persons
No Information Filed
SECTION 10.B. Control Person Public Reporting Companies
No Information Filed
Item 11 Disclosure Information
In this Item, we ask for information about your disciplinary history and the disciplinary history of all your advisory affiliates. We use this information to determine whether
to grant your application for registration, to decide whether to revoke your registration or to place limitations on your activities as an investment adviser, and to identify
potential problem areas to focus on during our on-site examinations. One event may result in "yes" answers to more than one of the questions below. In accordance
with General Instruction 5 to Form ADV, "you" and "your" include the filing adviser and all relying advisers under an umbrella registration.
Your advisory affiliates are: (1) all of your current employees (other than employees performing only clerical, administrative, support or similar functions); (2) all of your
officers, partners, or directors (or any person performing similar functions); and (3) all persons directly or indirectly controlling you or controlled by you. If you are a
"separately identifiable department or division" (SID) of a bank, see the Glossary of Terms to determine who your advisory affiliates are.
If you are registered or registering with the SEC or if you are an exempt reporting adviser, you may limit your disclosure of any event listed in Item 11 to ten years following the
date of the event. If you are registered or registering with a state, you must respond to the questions as posed; you may, therefore, limit your disclosure to ten years following
the date of an event only in responding to Items 11.A.(1), 11.A.(2), 11.B.(1), 11.B.(2), 11.D.(4), and 11.H.(1)(a). For purposes of calculating this ten-year period, the date of an
event is the date the final order, judgment, or decree was entered, or the date any rights of appeal from preliminary orders, judgments, or decrees lapsed.
You must complete the appropriate Disclosure Reporting Page ("DRP") for "yes" answers to the questions in this Item 11.
Yes No
Do any of the events below involve you or any of your supervised persons?
For "yes" answers to the following questions, complete a Criminal Action DRP:
A. In the past ten years, have you or any advisory affiliate: Yes No
(1) been convicted of or pled guilty or nolo contendere ("no contest") in a domestic, foreign, or military court to any felony?
(2) been charged with any felony?
If you are registered or registering with the SEC, or if you are reporting as an exempt reporting adviser, you may limit your response to Item 11.A.(2) to charges that are
currently pending.
B. In the past ten years, have you or any advisory affiliate:
(1) been convicted of or pled guilty or nolo contendere ("no contest") in a domestic, foreign, or military court to a misdemeanor involving: investments or
an investment-related business, or any fraud, false statements, or omissions, wrongful taking of property, bribery, perjury, forgery, counterfeiting,
extortion, or a conspiracy to commit any of these offenses?
(2) been charged with a misdemeanor listed in Item 11.B.(1)?
If you are registered or registering with the SEC, or if you are reporting as an exempt reporting adviser, you may limit your response to Item 11.B.(2) to charges that are
currently pending.
For "yes" answers to the following questions, complete a Regulatory Action DRP:
C. Has the SEC or the Commodity Futures Trading Commission (CFTC) ever: Yes No
(1) found you or any advisory affiliate to have made a false statement or omission?
(2) found you or any advisory affiliate to have been involved in a violation of SEC or CFTC regulations or statutes?
(3) found you or any advisory affiliate to have been a cause of an investment-related business having its authorization to do business denied, suspended,
revoked, or restricted?
(4) entered an order against you or any advisory affiliate in connection with investment-related activity?
(5) imposed a civil money penalty on you or any advisory affiliate, or ordered you or any advisory affiliate to cease and desist from any activity?
D. Has any other federal regulatory agency, any state regulatory agency, or any foreign financial regulatory authority:
(1) ever found you or any advisory affiliate to have made a false statement or omission, or been dishonest, unfair, or unethical?
(2) ever found you or any advisory affiliate to have been involved in a violation of investment-related regulations or statutes?
(3) ever found you or any advisory affiliate to have been a cause of an investment-related business having its authorization to do business denied,
suspended, revoked, or restricted?
(4) in the past ten years, entered an order against you or any advisory affiliate in connection with an investment-related activity?
(5) ever denied, suspended, or revoked your or any advisory affiliate's registration or license, or otherwise prevented you or any advisory affiliate, by order,
from associating with an investment-related business or restricted your or any advisory affiliate's activity?
E. Has any self-regulatory organization or commodities exchange ever:
(1) found you or any advisory affiliate to have made a false statement or omission?
(2) found you or any advisory affiliate to have been involved in a violation of its rules (other than a violation designated as a "minor rule violation" under a
plan approved by the SEC)?
(3) found you or any advisory affiliate to have been the cause of an investment-related business having its authorization to do business denied,
suspended, revoked, or restricted?
(4) disciplined you or any advisory affiliate by expelling or suspending you or the advisory affiliate from membership, barring or suspending you or the
advisory affiliate from association with other members, or otherwise restricting your or the advisory affiliate's activities?
F. Has an authorization to act as an attorney, accountant, or federal contractor granted to you or any advisory affiliate ever been revoked or suspended?
G. Are you or any advisory affiliate now the subject of any regulatory proceeding that could result in a "yes" answer to any part of Item 11.C., 11.D., or 11.E.?
For "yes" answers to the following questions, complete a Civil Judicial Action DRP:
H. (1) Has any domestic or foreign court: Yes No
(a) in the past ten years, enjoined you or any advisory affiliate in connection with any investment-related activity?
(b) ever found that you or any advisory affiliate were involved in a violation of investment-related statutes or regulations?
(c) ever dismissed, pursuant to a settlement agreement, an investment-related civil action brought against you or any advisory affiliate by a state or
foreign financial regulatory authority?
(2) Are you or any advisory affiliate now the subject of any civil proceeding that could result in a "yes" answer to any part of Item 11.H.(1)?
Schedule A
Direct Owners and Executive Officers
1. Complete Schedule A only if you are submitting an initial application or report. Schedule A asks for information about your direct owners and executive officers. Use
Schedule C to amend this information.
2. Direct Owners and Executive Officers. List below the names of:
(a) each Chief Executive Officer, Chief Financial Officer, Chief Operations Officer, Chief Legal Officer, Chief Compliance Officer(Chief Compliance Officer is required if you
are registered or applying for registration and cannot be more than one individual), director, and any other individuals with similar status or functions;
(b) if you are organized as a corporation, each shareholder that is a direct owner of 5% or more of a class of your voting securities, unless you are a public reporting
company (a company subject to Section 12 or 15(d) of the Exchange Act);
Direct owners include any person that owns, beneficially owns, has the right to vote, or has the power to sell or direct the sale of, 5% or more of a class of your
voting securities. For purposes of this Schedule, a person beneficially owns any securities: (i) owned by his/her child, stepchild, grandchild, parent, stepparent,
grandparent, spouse, sibling, mother-in-law, father-in-law, son-in-law, daughter-in-law, brother-in-law, or sister-in-law, sharing the same residence; or (ii) that
he/she has the right to acquire, within 60 days, through the exercise of any option, warrant, or right to purchase the security.
(c) if you are organized as a partnership, all general partners and those limited and special partners that have the right to receive upon dissolution, or have
contributed, 5% or more of your capital;
(d) in the case of a trust that directly owns 5% or more of a class of your voting securities, or that has the right to receive upon dissolution, or has contributed, 5% or
more of your capital, the trust and each trustee; and
(e) if you are organized as a limited liability company ("LLC"), (i) those members that have the right to receive upon dissolution, or have contributed, 5% or more of
your capital, and (ii) if managed by elected managers, all elected managers.
3. Do you have any indirect owners to be reported on Schedule B? Yes No
4. In the DE/FE/I column below, enter "DE" if the owner is a domestic entity, "FE" if the owner is an entity incorporated or domiciled in a foreign country, or "I" if the
owner or executive officer is an individual.
5. Complete the Title or Status column by entering board/management titles; status as partner, trustee, sole proprietor, elected manager, shareholder, or member; and
for shareholders or members, the class of securities owned (if more than one is issued).
6. Ownership codes are: NA - less than 5% B - 10% but less than 25% D - 50% but less than 75%
A - 5% but less than 10% C - 25% but less than 50% E - 75% or more
7. (a) In the Control Person column, enter "Yes" if the person has control as defined in the Glossary of Terms to Form ADV, and enter "No" if the person does not have
control. Note that under this definition, most executive officers and all 25% owners, general partners, elected managers, and trustees are control persons.
(b) In the PR column, enter "PR" if the owner is a public reporting company under Sections 12 or 15(d) of the Exchange Act.
(c) Complete each column.
FULL LEGAL NAME (Individuals: Last DE/FE/I Title or Status Date Title or Status Ownership Control PR CRD No. If None: S.S. No. and Date of
Name, First Name, Middle Name) Acquired MM/YYYY Code Person Birth, IRS Tax No. or Employer ID No.
KAMPANI, VISHAL, NIMESH I VICE CHAIRMAN & 10/2024 NA Y N 3257428
MANAGING DIRECTOR
KAMPANI, NIMESH, NAGINDAS I NON-EXECUTIVE 10/2016 B Y N 6040206
CHAIRMAN OF THE
BOARD
J.M.FINANCIAL & INVESTMENT FE SHAREHOLDER 03/2002 B Y N
CONSULTANCY SERVICES PRIVATE LIMITED
J.M. ASSETS MANAGEMENT PRIVATE FE SHAREHOLDER 07/1991 B Y N
LIMITED
Palamadai, Jayakumar, Sundararajan I INDEPENDENT 07/2020 NA N N 7401660
DIRECTOR ON THE
BOARD
PATEL, ADI, RUSI I MANAGING DIRECTOR 10/2021 NA Y N 7589255
ON THE BOARD
BAKSHI, ROSHINI I INDEPENDENT 12/2021 NA N N 7589257
DIRECTOR ON THE
BOARD
KANAKIA, PRADIP, MANILAL I INDEPENDENT 02/2022 NA N N 7589261
DIRECTOR ON THE
BOARD
UDWADIA, NAVROZ, DARIUS I INDEPENDENT 12/2021 NA N N 6020115
DIRECTOR ON THE
BOARD
BOSE, SUMIT I INDEPENDENT 05/2022 NA N N 7656846
DIRECTOR ON THE
BOARD
SHAH, NISHIT, ASHWIN I CHIEF FINANCIAL 10/2023 NA N N 7835431
OFFICER
AIYAR, HARIHARAN, RAMAMURTHI I NON-EXECUTIVE 05/2025 NA N N 2085292
DIRECTOR OF THE
BOARD
Pandya, Hemant, Vijay I COMPANY SECRETARY 07/2024 NA N N 8125653
Schedule B
Indirect Owners
1. Complete Schedule B only if you are submitting an initial application or report. Schedule B asks for information about your indirect owners; you must first complete
Schedule A, which asks for information about your direct owners. Use Schedule C to amend this information.
2. Indirect Owners. With respect to each owner listed on Schedule A (except individual owners), list below:
(a) in the case of an owner that is a corporation, each of its shareholders that beneficially owns, has the right to vote, or has the power to sell or direct the sale of,
25% or more of a class of a voting security of that corporation;
For purposes of this Schedule, a person beneficially owns any securities: (i) owned by his/her child, stepchild, grandchild, parent, stepparent, grandparent,
spouse, sibling, mother-in-law, father-in-law, son-in-law, daughter-in-law, brother-in-law, or sister-in-law, sharing the same residence; or (ii) that he/she has the
right to acquire, within 60 days, through the exercise of any option, warrant, or right to purchase the security.
(b) in the case of an owner that is a partnership, all general partners and those limited and special partners that have the right to receive upon dissolution, or have
contributed, 25% or more of the partnership's capital;
(c) in the case of an owner that is a trust, the trust and each trustee; and
(d) in the case of an owner that is a limited liability company ("LLC"), (i) those members that have the right to receive upon dissolution, or have contributed, 25% or
more of the LLC's capital, and (ii) if managed by elected managers, all elected managers.
3. Continue up the chain of ownership listing all 25% owners at each level. Once a public reporting company (a company subject to Sections 12 or 15(d) of the
Exchange Act) is reached, no further ownership information need be given.
4. In the DE/FE/I column below, enter "DE" if the owner is a domestic entity, "FE" if the owner is an entity incorporated or domiciled in a foreign country, or "I" if the
owner is an individual.
5. Complete the Status column by entering the owner's status as partner, trustee, elected manager, shareholder, or member; and for shareholders or members, the
class of securities owned (if more than one is issued).
6. Ownership codes are: C - 25% but less than 50% E - 75% or more
D - 50% but less than 75% F - Other (general partner, trustee, or elected manager)
7. (a) In the Control Person column, enter "Yes" if the person has control as defined in the Glossary of Terms to Form ADV, and enter "No" if the person does not have
control. Note that under this definition, most executive officers and all 25% owners, general partners, elected managers, and trustees are control persons.
(b) In the PR column, enter "PR" if the owner is a public reporting company under Sections 12 or 15(d) of the Exchange Act.
(c) Complete each column.
FULL LEGAL NAME (Individuals: DE/FE/I Entity in Which Interest is Owned Status Date Status Ownership Control PR CRD No. If None: S.S. No.
Last Name, First Name, Middle Acquired Code Person and Date of Birth, IRS Tax
Name) MM/YYYY No. or Employer ID No.
KAMPANI CONSULTANTS LIMITED FE J.M.FINANCIAL & INVESTMENT SHAREHOLDER 12/1988 D Y N
CONSULTANCY SERVICES PRIVATE
LIMITED
KAMPANI, NIMESH, NAGINDAS I KAMPANI CONSULTANTS LIMITED SHAREHOLDER 12/1988 C Y N 6040206
SNK INVESTMENTS PRIVATE LIMITED FE KAMPANI CONSULTANTS LIMITED SHAREHOLDER 04/1982 C Y N
KAMPANI, NIMESH, NAGINDAS I SNK INVESTMENTS PRIVATE LIMITED SHAREHOLDER 09/1986 C Y N 6040206
KAMPANI, ARUNA, NIMESH I SNK INVESTMENTS PRIVATE LIMITED SHAREHOLDER 11/1975 C Y N 6365088
J.M. FINANCIAL & INVESTMENT FE J.M. ASSETS MANAGEMENT PRIVATE SHAREHOLDER 03/1992 E Y N
CONSULTANCY SERVICES PRIVATE LIMITED
LIMITED
Schedule D - Miscellaneous
You may use the space below to explain a response to an Item or to provide any other information.
For the purpose of Schedule A - Direct Owners and Executive Officers, the effective date on which the individual has acquired the existing Title or Status has been
considered.
DRP Pages
CRIMINAL DISCLOSURE REPORTING PAGE (ADV)
No Information Filed
REGULATORY ACTION DISCLOSURE REPORTING PAGE (ADV)
GENERAL INSTRUCTIONS
This Disclosure Reporting Page (DRP ADV) is an INITIAL AMENDED response used to report details for affirmative responses to Items 11.C., 11.D., 11.E., 11.F.
OR
or 11.G. of Form ADV.
Regulatory Action
Check item(s) being responded to:
11.C(1) 11.C(2) 11.C(3) 11.C(4) 11.C(5)
11.D(1) 11.D(2) 11.D(3) 11.D(4) 11.D(5)
11.E(1) 11.E(2) 11.E(3) 11.E(4)
11.F. 11.G.
Use a separate DRP for each event or proceeding . The same event or proceeding may be reported for more than one person or entity using one DRP. File with a
completed Execution Page.
One event may result in more than one affirmative answer to Items 11.C., 11.D., 11.E., 11.F. or 11.G. Use only one DRP to report details related to the same event. If
an event gives rise to actions by more than one regulator, provide details for each action on a separate DRP.
PART I
A. The person(s) or entity(ies) for whom this DRP is being filed is (are):
You (the advisory firm)
You and one or more of your
advisory affiliates
One or more of your
advisory affiliates
If this DRP is being filed for an advisory affiliate, give the full name of the advisory affiliate below (for individuals, Last name, First name, Middle name).
If the advisory affiliate has a CRD number, provide that number. If not, indicate "non-registered" by checking the appropriate box.
ADV DRP - ADVISORY AFFILIATE
CRD
This advisory affiliate is a Firm an Individual
Number:
Registered:
Yes No
Name: JM FINANCIAL PRODUCTS LIMITED
(JMFPL)
(For individuals, Last, First,
Middle)
This DRP should be removed from the ADV record because the advisory affiliate(s) is no longer associated with the adviser.
This DRP should be removed from the ADV record because: (1) the event or proceeding occurred more than ten years ago or (2) the adviser is registered or
applying for registration with the SEC or reporting as an exempt reporting adviser with the SEC and the event was resolved in the adviser's or advisory
affiliate's favor.
If you are registered or registering with a state securities authority , you may remove a DRP for an event you reported only in response to Item 11.D(4), and only
if that event occurred more than ten years ago. If you are registered or registering with the SEC, you may remove a DRP for any event listed in Item 11 that
occurred more than ten years ago.
This DRP should be removed from the ADV record because it was filed in error, such as due to a clerical or data-entry mistake. Explain the circumstances:
B. If the advisory affiliate is registered through the IARD system or CRD system, has the advisory affiliate submitted a DRP (with Form ADV, BD or U-4) to the IARD or
CRD for the event? If the answer is "Yes," no other information on this DRP must be provided.
Yes No
NOTE: The completion of this form does not relieve the advisory affiliate of its obligation to update its IARD or CRD records.
PART II
1. Regulatory Action initiated by:
SEC Other Federal State Foreign
SRO
(Full name of regulator, foreign financial regulatory authority, federal, state, or SRO)
RESERVE BANK OF INDIA (RBI)
2. Principal Sanction:
Cease and Desist
Other Sanctions:
CEASE AND DESIST, WITH IMMEDIATE EFFECT, FROM DOING ANY FORM OF FINANCING AGAINST SHARES AND DEBENTURES INCLUDING SANCTION AND DISBURSAL
OF LOANS AGAINST INITIAL PUBLIC OFFERING OF SHARES AS WELL AS AGAINST SUBSCRIPTION TO DEBENTURES, TILL A SPECIAL AUDIT INSTITUTED BY RBI WAS
COMPLETED.
3. Date Initiated (MM/DD/YYYY):
03/05/2024 Exact Explanation
If not exact, provide explanation:
4. Docket/Case Number:
NOT APPLICABLE
5. Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
NOT APPLICABLE
6. Principal Product Type:
Other
Other Product Types:
(FINANCING AGAINST SHARES AND DEBENTURES INCLUDING IN IPO OF SHARES AND DEBENTURES)
7. Describe the allegations related to this regulatory action (your response must fit within the space provided):
THE PRINCIPAL ALLEGATIONS ARE: JMFPL ALLEGEDLY FACILITATED IPO AND NCD SUBSCRIPTIONS USING LOANED FUNDS WITH INADEQUATE CREDIT
UNDERWRITING AND VERY LOW MARGINS. JMFPL OPERATED CUSTOMERS' APPLICATION PROCESSES, DEMAT ACCOUNTS, AND BANK ACCOUNTS THROUGH POWERS
OF ATTORNEY (POAS), EFFECTIVELY ACTING AS BOTH LENDER AND BORROWER, RAISING CONCERNS ABOUT REGULATORY COMPLIANCE AND CORPORATE
GOVERNANCE.
8. Current Status? Pending On Appeal Final
9. If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and Date Appeal Filed:
NOT APPLICABLE
If Final or On Appeal, complete all items below. For Pending Actions, complete Item 13 only.
10. How was matter resolved:
Other
11. Resolution Date (MM/DD/YYYY):
10/18/2024 Exact Explanation
If not exact, provide explanation:
RBI VIDE ITS LETTER DATED OCTOBER 18, 2024, LIFTED THE RESTRICTIONS IMPOSED BY IT ON JMFPL. HOWEVER, AS A CORRECTIVE MEASURE, JMFPL DECIDED TO
DISCONTINUE ITS IPO BUSINESS.
12. Resolution Detail:
A. Were any of the following Sanctions Ordered (check all appropriate items)?
Monetary/Fine Amount: $
Revocation/Expulsion/Denial Disgorgement/Restitution
Censure Cease and Desist/Injunction
Bar Suspension
B. Other Sanctions Ordered:
NOT APPLICABLE
Sanction detail: if suspended, enjoined or barred, provide duration including start date and capacities affected (General Securities Principal, Financial
Operations Principal, etc.). If requalification by exam/retraining was a condition of the sanction, provide length of time given to requalify/retrain, type of
exam required and whether condition has been satisfied. If disposition resulted in a fine, penalty, restitution, disgorgement or monetary compensation,
provide total amount, portion levied against you or an advisory affiliate, date paid and if any portion of penalty was waived:
NOT APPLICABLE
13. Provide a brief summary of details related to the action status and (or) disposition and include relevant terms, conditions and dates (your response must fit
within the space provided).
RBI VIDE ITS ORDER DATED MARCH 5, 2024 HAD DIRECTED JMFPL TO CEASE AND DESIST, FROM DOING ANY FORM OF FINANCING AGAINST SHARES AND
DEBENTURES INCLUDING SANCTION AND DISBURSAL OF LOAN AGAINST INITIAL PUBLIC OFFERING (IPO) OF SHARES AS WELL AS AGAINST SUBSCRIPTION TO
DEBENTURES, TILL A SPECIAL AUDIT INSTITUTED BY RBI WAS COMPLETED. POST SUBMISSION OF RESPONSE BY JMFPL, RBI VIDE ITS LETTER DATED OCTOBER 18,
2024, LIFTED THE RESTRICTIONS IMPOSED BY IT ON JMFPL. HOWEVER, AS A CORRECTIVE MEASURE, JMFPL DECIDED TO DISCONTINUE ITS IPO BUSINESS (MATTER
CLOSED).
GENERAL INSTRUCTIONS
This Disclosure Reporting Page (DRP ADV) is an INITIAL AMENDED response used to report details for affirmative responses to Items 11.C., 11.D., 11.E., 11.F.
OR
or 11.G. of Form ADV.
Regulatory Action
Check item(s) being responded to:
11.C(1) 11.C(2) 11.C(3) 11.C(4) 11.C(5)
11.D(1) 11.D(2) 11.D(3) 11.D(4) 11.D(5)
11.E(1) 11.E(2) 11.E(3) 11.E(4)
11.F. 11.G.
Use a separate DRP for each event or proceeding . The same event or proceeding may be reported for more than one person or entity using one DRP. File with a
completed Execution Page.
One event may result in more than one affirmative answer to Items 11.C., 11.D., 11.E., 11.F. or 11.G. Use only one DRP to report details related to the same event. If
an event gives rise to actions by more than one regulator, provide details for each action on a separate DRP.
PART I
A. The person(s) or entity(ies) for whom this DRP is being filed is (are):
You (the advisory firm)
You and one or more of your
advisory affiliates
One or more of your
advisory affiliates
If this DRP is being filed for an advisory affiliate, give the full name of the advisory affiliate below (for individuals, Last name, First name, Middle name).
If the advisory affiliate has a CRD number, provide that number. If not, indicate "non-registered" by checking the appropriate box.
ADV DRP - ADVISORY AFFILIATE
No Information Filed
This DRP should be removed from the ADV record because the advisory affiliate(s) is no longer associated with the adviser.
This DRP should be removed from the ADV record because: (1) the event or proceeding occurred more than ten years ago or (2) the adviser is registered or
applying for registration with the SEC or reporting as an exempt reporting adviser with the SEC and the event was resolved in the adviser's or advisory
affiliate's favor.
If you are registered or registering with a state securities authority , you may remove a DRP for an event you reported only in response to Item 11.D(4), and only
if that event occurred more than ten years ago. If you are registered or registering with the SEC, you may remove a DRP for any event listed in Item 11 that
occurred more than ten years ago.
This DRP should be removed from the ADV record because it was filed in error, such as due to a clerical or data-entry mistake. Explain the circumstances:
B. If the advisory affiliate is registered through the IARD system or CRD system, has the advisory affiliate submitted a DRP (with Form ADV, BD or U-4) to the IARD or
CRD for the event? If the answer is "Yes," no other information on this DRP must be provided.
Yes No
NOTE: The completion of this form does not relieve the advisory affiliate of its obligation to update its IARD or CRD records.
PART II
1. Regulatory Action initiated by:
SEC Other Federal State Foreign
SRO
(Full name of regulator, foreign financial regulatory authority, federal, state, or SRO)
SECURITIES AND EXCHANGE BOARD OF INDIA
2. Principal Sanction:
Other
Other Sanctions:
NO ACTION TAKEN BY SEBI
3. Date Initiated (MM/DD/YYYY):
03/07/2024 Exact Explanation
If not exact, provide explanation:
4. Docket/Case Number:
NOT APPLICABLE
5. Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
NOT APPLICABLE
6. Principal Product Type:
Other
Other Product Types:
PUBLIC ISSUE OF DEBT SECURITIES
7. Describe the allegations related to this regulatory action (your response must fit within the space provided):
PRIMA FACIE VIOLATION OF CERTAIN REGULATIONS ISSUED BY SEBI.
8. Current Status? Pending On Appeal Final
9. If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and Date Appeal Filed:
NOT APPLICABLE
If Final or On Appeal, complete all items below. For Pending Actions, complete Item 13 only.
10. How was matter resolved:
Settled
11. Resolution Date (MM/DD/YYYY):
09/19/2025 Exact Explanation
If not exact, provide explanation:
12. Resolution Detail:
A. Were any of the following Sanctions Ordered (check all appropriate items)?
Monetary/Fine Amount: $ 314,856.00
Revocation/Expulsion/Denial Disgorgement/Restitution
Censure Cease and Desist/Injunction
Bar Suspension
B. Other Sanctions Ordered:
Sanction detail: if suspended, enjoined or barred, provide duration including start date and capacities affected (General Securities Principal, Financial
Operations Principal, etc.). If requalification by exam/retraining was a condition of the sanction, provide length of time given to requalify/retrain, type of
exam required and whether condition has been satisfied. If disposition resulted in a fine, penalty, restitution, disgorgement or monetary compensation,
provide total amount, portion levied against you or an advisory affiliate, date paid and if any portion of penalty was waived:
AS PER THE SETTLEMENT TERMS, JM FINANCIAL LIMITED ("JMFL") AGREED TO A VOLUNTARY DEBARMENT FROM ACTING AS A LEAD MANAGER IN ANY PUBLIC
ISSUE OF DEBT SECURITIES FOR A PERIOD OF THREE MONTHS FROM THE DATE OF THE SETTLEMENT ORDER, I.E., SEPTEMBER 19, 2025.
13. Provide a brief summary of details related to the action status and (or) disposition and include relevant terms, conditions and dates (your response must fit
within the space provided).
IN RESPECT OF THE ORDERS ISSUED BY SEBI AGAINST JM FINANCIAL LIMITED (THE "JMFL"), VIZ., AN INTERIM EX-PARTE ORDER DATED MARCH 7, 2024 IN THE
MATTER OF PUBLIC ISSUE OF CERTAIN DEBT SECURITIES, WHICH WAS CONFIRMED BY THE HON'BLE WHOLE TIME MEMBER OF SEBI VIDE THE CONFIRMATORY
ORDER DATED JUNE 20, 2024, JMFL MADE VOLUNTARY SETTLEMENT APPLICATION UNDER THE SEBI (SETTLEMENT PROCEEDINGS) REGULATIONS, 2018. PURSUANT
TO THE ABOVE APPLICATION, SEBI VIDE ITS ORDER DATED SEPTEMBER 19, 2025 (THE "SETTLEMENT ORDER") SETTLED THE PROCEEDINGS THAT MAY HAVE BEEN
INITIATED AGAINST JMFL IN THE SUBJECT MATTER UPON JMFL MAKING PAYMENT OF THE SETTLEMENT AMOUNT OF INR. 1,56,27,512/- ($176,591) AND THE
DISGORGEMENT AMOUNT OF INR. 1,22,35,849/- ($138,265), WITHOUT JMFL ADMITTING OR DENYING THE FINDINGS OF FACTS AND CONCLUSIONS OF LAW.
ADDITIONALLY, JMFL ALSO AGREED TO VOLUNTARY DEBARMENT FROM ACTING AS A LEAD MANAGER IN ANY PUBLIC ISSUE OF DEBT SECURITIES FOR A PERIOD OF 3
MONTHS FROM THE DATE OF THE SETTLEMENT ORDER, VIZ. SEPTEMBER 19, 2025. (MATTER CLOSED)
GENERAL INSTRUCTIONS
This Disclosure Reporting Page (DRP ADV) is an INITIAL AMENDED response used to report details for affirmative responses to Items 11.C., 11.D., 11.E., 11.F.
OR
or 11.G. of Form ADV.
Regulatory Action
Check item(s) being responded to:
11.C(1) 11.C(2) 11.C(3) 11.C(4) 11.C(5)
11.D(1) 11.D(2) 11.D(3) 11.D(4) 11.D(5)
11.E(1) 11.E(2) 11.E(3) 11.E(4)
11.F. 11.G.
Use a separate DRP for each event or proceeding . The same event or proceeding may be reported for more than one person or entity using one DRP. File with a
completed Execution Page.
One event may result in more than one affirmative answer to Items 11.C., 11.D., 11.E., 11.F. or 11.G. Use only one DRP to report details related to the same event. If
an event gives rise to actions by more than one regulator, provide details for each action on a separate DRP.
PART I
A. The person(s) or entity(ies) for whom this DRP is being filed is (are):
You (the advisory firm)
You and one or more of your
advisory affiliates
One or more of your
advisory affiliates
If this DRP is being filed for an advisory affiliate, give the full name of the advisory affiliate below (for individuals, Last name, First name, Middle name).
If the advisory affiliate has a CRD number, provide that number. If not, indicate "non-registered" by checking the appropriate box.
ADV DRP - ADVISORY AFFILIATE
No Information Filed
This DRP should be removed from the ADV record because the advisory affiliate(s) is no longer associated with the adviser.
This DRP should be removed from the ADV record because: (1) the event or proceeding occurred more than ten years ago or (2) the adviser is registered or
applying for registration with the SEC or reporting as an exempt reporting adviser with the SEC and the event was resolved in the adviser's or advisory
affiliate's favor.
If you are registered or registering with a state securities authority , you may remove a DRP for an event you reported only in response to Item 11.D(4), and only
if that event occurred more than ten years ago. If you are registered or registering with the SEC, you may remove a DRP for any event listed in Item 11 that
occurred more than ten years ago.
This DRP should be removed from the ADV record because it was filed in error, such as due to a clerical or data-entry mistake. Explain the circumstances:
B. If the advisory affiliate is registered through the IARD system or CRD system, has the advisory affiliate submitted a DRP (with Form ADV, BD or U-4) to the IARD or
CRD for the event? If the answer is "Yes," no other information on this DRP must be provided.
Yes No
NOTE: The completion of this form does not relieve the advisory affiliate of its obligation to update its IARD or CRD records.
PART II
1. Regulatory Action initiated by:
SEC Other Federal State Foreign
SRO
(Full name of regulator, foreign financial regulatory authority, federal, state, or SRO)
SECURITIES AND EXCHANGE BOARD OF INDIA ("SEBI")
2. Principal Sanction:
Other
Other Sanctions:
NO ACTION TAKEN BY SEBI
3. Date Initiated (MM/DD/YYYY):
05/25/2023 Exact Explanation
If not exact, provide explanation:
4. Docket/Case Number:
NOT APPLICABLE
5. Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
NOT APPLICABLE
6. Principal Product Type:
Other
Other Product Types:
(EQUITY SHARES LISTED ON STOCK EXCHANGE)
7. Describe the allegations related to this regulatory action (your response must fit within the space provided):
SEBI HAD ISSUED A SHOW-CAUSE NOTICE DATED MAY 25, 2023 ("SCN") IN THE MATTER OF VOLUNTARY DELISTING OFFER BY ONE OF THE CLIENTS OF JM
FINANCIAL LIMITED ("JMFL") TO CERTAIN ENTITIES, INCLUDING JMFL. IT WAS ALLEDGED IN THE SCN THAT JMFL FAILED TO EXERCISE DUE DILIGENCE, CARE AND
PROFESSIONAL JUDGEMENT AS THE MANAGER TO THE DELISTING OFFER AND HENCE, HAVE ALLEGEDLY VIOLATED REGULATION 29(4) OF SEBI (DELISTING OF
EQUITY SHARES) REGULATIONS, 2021 & REGULATION 13 READ WITH SCHEDULE III OF SEBI (MERCHANT BANKERS) REGULATIONS, 1992
8. Current Status? Pending On Appeal Final
9. If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and Date Appeal Filed:
NOT APPLICABLE
If Final or On Appeal, complete all items below. For Pending Actions, complete Item 13 only.
10. How was matter resolved:
Settled
11. Resolution Date (MM/DD/YYYY):
05/21/2024 Exact Explanation
If not exact, provide explanation:
12. Resolution Detail:
A. Were any of the following Sanctions Ordered (check all appropriate items)?
Monetary/Fine Amount: $ 18,000.00
Revocation/Expulsion/Denial Disgorgement/Restitution
Censure Cease and Desist/Injunction
Bar Suspension
B. Other Sanctions Ordered:
NOT APPLICABLE
Sanction detail: if suspended, enjoined or barred, provide duration including start date and capacities affected (General Securities Principal, Financial
Operations Principal, etc.). If requalification by exam/retraining was a condition of the sanction, provide length of time given to requalify/retrain, type of
exam required and whether condition has been satisfied. If disposition resulted in a fine, penalty, restitution, disgorgement or monetary compensation,
provide total amount, portion levied against you or an advisory affiliate, date paid and if any portion of penalty was waived:
JMFL SETTLED WITH SEBI THE ADJUDICATION PROCEEDINGS INITIATED AGAINST IT, WITHOUT ADMITTING OR DENYING THE FINDINGS OF FACTS AND
CONCLUSIONS OF LAW BY AGREEING TO PAY A SETTLEMENT AMOUNT OF INR. 15,00,000/- (APPROXIMATELY EQUIVALENT TO USD 18,000/-) TOWARDS THE
SETTLEMENT TERMS.
13. Provide a brief summary of details related to the action status and (or) disposition and include relevant terms, conditions and dates (your response must fit
within the space provided).
JMFL HAD SUBMITTED ITS RESPONSE TO THE SCN AND HAD ALSO FILED A SETTLEMENT APPLICATION WITH SEBI IN THE MATTER. JMFL SETTLED WITH SEBI THE
ADJUDICATION PROCEEDINGS INITIATED AGAINST IT VIDE THE SCN, WITHOUT ADMITTING OR DENYING THE FINDINGS OF FACTS AND CONCLUSIONS OF LAW BY
AGREEING TO PAY A SETTLEMENT AMOUNT OF RS. 15,00,000/- (APPROXIMATELY EQUIVALENT TO USD 18,000/-) TOWARDS THE SETTLEMENT TERMS PURSUANT TO
WHICH SEBI PASSED A SETTLEMENT ORDER DATED MAY 21, 2024 AND THE PROCEEDINGS INITIATED IN TERMS OF THE SCN, HAVE BEEN DISPOSED OF. (MATTER
CLOSED)
GENERAL INSTRUCTIONS
This Disclosure Reporting Page (DRP ADV) is an INITIAL AMENDED response used to report details for affirmative responses to Items 11.C., 11.D., 11.E., 11.F.
OR
or 11.G. of Form ADV.
Regulatory Action
Check item(s) being responded to:
11.C(1) 11.C(2) 11.C(3) 11.C(4) 11.C(5)
11.D(1) 11.D(2) 11.D(3) 11.D(4) 11.D(5)
11.E(1) 11.E(2) 11.E(3) 11.E(4)
11.F. 11.G.
Use a separate DRP for each event or proceeding . The same event or proceeding may be reported for more than one person or entity using one DRP. File with a
completed Execution Page.
One event may result in more than one affirmative answer to Items 11.C., 11.D., 11.E., 11.F. or 11.G. Use only one DRP to report details related to the same event. If
an event gives rise to actions by more than one regulator, provide details for each action on a separate DRP.
PART I
A. The person(s) or entity(ies) for whom this DRP is being filed is (are):
You (the advisory firm)
You and one or more of your
advisory affiliates
One or more of your
advisory affiliates
If this DRP is being filed for an advisory affiliate, give the full name of the advisory affiliate below (for individuals, Last name, First name, Middle name).
If the advisory affiliate has a CRD number, provide that number. If not, indicate "non-registered" by checking the appropriate box.
ADV DRP - ADVISORY AFFILIATE
CRD
This advisory affiliate is a Firm an Individual
Number:
Registered:
Yes No
Name: JM FINANCIAL TRUSTEE COMPANY
PRIVATE LIMITED
(For individuals, Last, First,
Middle)
This DRP should be removed from the ADV record because the advisory affiliate(s) is no longer associated with the adviser.
This DRP should be removed from the ADV record because: (1) the event or proceeding occurred more than ten years ago or (2) the adviser is registered or
applying for registration with the SEC or reporting as an exempt reporting adviser with the SEC and the event was resolved in the adviser's or advisory
affiliate's favor.
If you are registered or registering with a state securities authority , you may remove a DRP for an event you reported only in response to Item 11.D(4), and only
if that event occurred more than ten years ago. If you are registered or registering with the SEC, you may remove a DRP for any event listed in Item 11 that
occurred more than ten years ago.
This DRP should be removed from the ADV record because it was filed in error, such as due to a clerical or data-entry mistake. Explain the circumstances:
B. If the advisory affiliate is registered through the IARD system or CRD system, has the advisory affiliate submitted a DRP (with Form ADV, BD or U-4) to the IARD or
CRD for the event? If the answer is "Yes," no other information on this DRP must be provided.
Yes No
NOTE: The completion of this form does not relieve the advisory affiliate of its obligation to update its IARD or CRD records.
PART II
1. Regulatory Action initiated by:
SEC Other Federal State Foreign
SRO
(Full name of regulator, foreign financial regulatory authority, federal, state, or SRO)
SECURITIES AND EXCHANGE BOARD OF INDIA ("SEBI")
2. Principal Sanction:
Civil and Administrative Penalt(ies) /Fine(s)
Other Sanctions:
NA
3. Date Initiated (MM/DD/YYYY):
11/15/2022 Exact Explanation
If not exact, provide explanation:
4. Docket/Case Number:
ORDER/NH/RJ/2024-25/30635-30641
5. Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
NOT APPLICABLE
6. Principal Product Type:
Mutual Fund(s)
Other Product Types:
7. Describe the allegations related to this regulatory action (your response must fit within the space provided):
JM FINANCIAL TRUSTEE COMPANY PRIVATE LIMITED ("JMFTCPL") WAS ALLEGED TO HAVE VIOLATED THE PROVISIONS OF CLAUSE 2 OF FIFTH SCHEDULE TO THE
SEBI (MUTUAL FUNDS) REGULATIONS, 1996
8. Current Status? Pending On Appeal Final
9. If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and Date Appeal Filed:
NOT APPLICABLE
If Final or On Appeal, complete all items below. For Pending Actions, complete Item 13 only.
10. How was matter resolved:
Order
11. Resolution Date (MM/DD/YYYY):
07/31/2024 Exact Explanation
If not exact, provide explanation:
12. Resolution Detail:
A. Were any of the following Sanctions Ordered (check all appropriate items)?
Monetary/Fine Amount: $ 11,933.00
Revocation/Expulsion/Denial Disgorgement/Restitution
Censure Cease and Desist/Injunction
Bar Suspension
B. Other Sanctions Ordered:
NA
Sanction detail: if suspended, enjoined or barred, provide duration including start date and capacities affected (General Securities Principal, Financial
Operations Principal, etc.). If requalification by exam/retraining was a condition of the sanction, provide length of time given to requalify/retrain, type of
exam required and whether condition has been satisfied. If disposition resulted in a fine, penalty, restitution, disgorgement or monetary compensation,
provide total amount, portion levied against you or an advisory affiliate, date paid and if any portion of penalty was waived:
SEBI IMPOSED A MONETARY PENALTY OF INR 10,00,000/- (APPROXIMATELY EQUIVALENT TO USD 11,933/-) ON JMFTCPL AS PER SECTION 15HB OF THE SEBI
ACT, 1992 WHICH HAS BEEN PAID BY JMFTCPL ON SEPTEMBER 4, 2024
13. Provide a brief summary of details related to the action status and (or) disposition and include relevant terms, conditions and dates (your response must fit
within the space provided).
SEBI ISSUED A SHOW-CAUSE NOTICE DATED NOVEMBER 15, 2022 TO JMFTCPL IN RESPECT OF TRANSACTIONS EXECUTED BY CERTAIN EMPLOYEES OF JM
FINANCIAL ASSET MANAGEMENT LIMITED IN THE SCHEMES OF JM FINANCIAL MUTUAL FUND, WHICH WAS RESPONDED TO BY JMFTCPL. JMFTCPL IS THE TRUSTEE TO
THE SCHEMES OF JM FINANCIAL MUTUAL FUND. POST THE SUBMISSIONS OF JMFTCPL, SEBI ISSUED AN ORDER ON JULY 31, 2024 IMPOSING A PENALTY OF INR
10,00,000/- (APPROXIMATELY EQUIVALENT TO USD 11,933/-) ON JMFTCPL AS PER SECTION 15HB OF SEBI ACT, 1992 FOR FAILING TO COMPLY WITH CLAUSE 2 OF
FIFTH SCHEDULE TO SEBI (MUTUAL FUNDS) REGULATIONS, 1996. THE ABOVE PENALTY WAS PAID BY JMFTCPL ON SEPTEMBER 4, 2024. (MATTER CLOSED)
GENERAL INSTRUCTIONS
This Disclosure Reporting Page (DRP ADV) is an INITIAL AMENDED response used to report details for affirmative responses to Items 11.C., 11.D., 11.E., 11.F.
OR
or 11.G. of Form ADV.
Regulatory Action
Check item(s) being responded to:
11.C(1) 11.C(2) 11.C(3) 11.C(4) 11.C(5)
11.D(1) 11.D(2) 11.D(3) 11.D(4) 11.D(5)
11.E(1) 11.E(2) 11.E(3) 11.E(4)
11.F. 11.G.
Use a separate DRP for each event or proceeding . The same event or proceeding may be reported for more than one person or entity using one DRP. File with a
completed Execution Page.
One event may result in more than one affirmative answer to Items 11.C., 11.D., 11.E., 11.F. or 11.G. Use only one DRP to report details related to the same event. If
an event gives rise to actions by more than one regulator, provide details for each action on a separate DRP.
PART I
A. The person(s) or entity(ies) for whom this DRP is being filed is (are):
You (the advisory firm)
You and one or more of your
advisory affiliates
One or more of your
advisory affiliates
If this DRP is being filed for an advisory affiliate, give the full name of the advisory affiliate below (for individuals, Last name, First name, Middle name).
If the advisory affiliate has a CRD number, provide that number. If not, indicate "non-registered" by checking the appropriate box.
ADV DRP - ADVISORY AFFILIATE
CRD
This advisory affiliate is a Firm an Individual
Number:
Registered:
Yes No
Name: JM FINANCIAL ASSET
MANAGEMENT LIMITED
(For individuals, Last, First,
Middle)
This DRP should be removed from the ADV record because the advisory affiliate(s) is no longer associated with the adviser.
This DRP should be removed from the ADV record because: (1) the event or proceeding occurred more than ten years ago or (2) the adviser is registered or
applying for registration with the SEC or reporting as an exempt reporting adviser with the SEC and the event was resolved in the adviser's or advisory
affiliate's favor.
If you are registered or registering with a state securities authority , you may remove a DRP for an event you reported only in response to Item 11.D(4), and only
if that event occurred more than ten years ago. If you are registered or registering with the SEC, you may remove a DRP for any event listed in Item 11 that
occurred more than ten years ago.
This DRP should be removed from the ADV record because it was filed in error, such as due to a clerical or data-entry mistake. Explain the circumstances:
B. If the advisory affiliate is registered through the IARD system or CRD system, has the advisory affiliate submitted a DRP (with Form ADV, BD or U-4) to the IARD or
CRD for the event? If the answer is "Yes," no other information on this DRP must be provided.
Yes No
NOTE: The completion of this form does not relieve the advisory affiliate of its obligation to update its IARD or CRD records.
PART II
1. Regulatory Action initiated by:
SEC Other Federal State Foreign
SRO
(Full name of regulator, foreign financial regulatory authority, federal, state, or SRO)
SECURITIES AND EXCHANGE BOARD OF INDIA ("SEBI")
2. Principal Sanction:
Civil and Administrative Penalt(ies) /Fine(s)
Other Sanctions:
NA
3. Date Initiated (MM/DD/YYYY):
11/15/2022 Exact Explanation
If not exact, provide explanation:
4. Docket/Case Number:
ORDER/NH/RJ/2024-25/30635-30641
5. Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
NOT APPLICABLE
6. Principal Product Type:
Mutual Fund(s)
Other Product Types:
NA
7. Describe the allegations related to this regulatory action (your response must fit within the space provided):
JM FINANCIAL ASSET MANAGEMENT LIMITED ("JMFAML") WAS ALLEGED TO HAVE ACTED IN CONTRAVENTION OF THE SEBI CIRCULAR DATED NOVEMBER 17, 2016
AND VIOLATED THE PROVISIONS OF CLAUSE 2 OF FIFTH SCHEDULE TO THE SEBI (MUTUAL FUNDS) REGULATIONS, 1996.
8. Current Status? Pending On Appeal Final
9. If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and Date Appeal Filed:
NOT APPLICABLE
If Final or On Appeal, complete all items below. For Pending Actions, complete Item 13 only.
10. How was matter resolved:
Order
11. Resolution Date (MM/DD/YYYY):
07/31/2024 Exact Explanation
If not exact, provide explanation:
NA
12. Resolution Detail:
A. Were any of the following Sanctions Ordered (check all appropriate items)?
Monetary/Fine Amount: $ 29,831.00
Revocation/Expulsion/Denial Disgorgement/Restitution
Censure Cease and Desist/Injunction
Bar Suspension
B. Other Sanctions Ordered:
NA
Sanction detail: if suspended, enjoined or barred, provide duration including start date and capacities affected (General Securities Principal, Financial
Operations Principal, etc.). If requalification by exam/retraining was a condition of the sanction, provide length of time given to requalify/retrain, type of
exam required and whether condition has been satisfied. If disposition resulted in a fine, penalty, restitution, disgorgement or monetary compensation,
provide total amount, portion levied against you or an advisory affiliate, date paid and if any portion of penalty was waived:
SEBI IMPOSED A MONETARY PENALTY OF INR 25,00,000/- (APPROXIMATELY EQUIVALENT TO USD 29,831/-) ON JMFAML AS PER SECTION 15E OF SEBI ACT,
1992 WHICH HAS BEEN PAID BY JMFAML ON SEPTEMBER 4, 2024.
13. Provide a brief summary of details related to the action status and (or) disposition and include relevant terms, conditions and dates (your response must fit
within the space provided).
SEBI ISSUED A SHOW-CAUSE NOTICE DATED NOVEMBER 15, 2022 TO JMFAML IN RESPECT OF TRANSACTIONS EXECUTED BY CERTAIN EMPLOYEES OF JMFAML IN
THE SCHEMES OF JM FINANCIAL MUTUAL FUND, WHICH WAS RESPONDED TO BY JMFAML. POST THE SUBMISSIONS OF JMFAML, SEBI ISSUED AN ORDER ON JULY 31,
2024 IMPOSING A PENALTY OF INR 25,00,000/- (APPROXIMATELY EQUIVALENT TO USD 29,831/-) ON JMFAML AS PER SECTION 15E OF SEBI ACT, 1992 FOR FAILING
TO COMPLY WITH THE PROVISIONS OF SEBI CIRCULAR DATED NOVEMBER 17, 2016 AND CLAUSE 2 OF FIFTH SCHEDULE TO SEBI (MUTUAL FUNDS) REGULATIONS,
1996. THE ABOVE PENALTY WAS PAID BY JMFAML ON SEPTEMBER 4, 2024. (MATTER CLOSED)
GENERAL INSTRUCTIONS
This Disclosure Reporting Page (DRP ADV) is an INITIAL AMENDED response used to report details for affirmative responses to Items 11.C., 11.D., 11.E., 11.F.
OR
or 11.G. of Form ADV.
Regulatory Action
Check item(s) being responded to:
11.C(1) 11.C(2) 11.C(3) 11.C(4) 11.C(5)
11.D(1) 11.D(2) 11.D(3) 11.D(4) 11.D(5)
11.E(1) 11.E(2) 11.E(3) 11.E(4)
11.F. 11.G.
Use a separate DRP for each event or proceeding . The same event or proceeding may be reported for more than one person or entity using one DRP. File with a
completed Execution Page.
One event may result in more than one affirmative answer to Items 11.C., 11.D., 11.E., 11.F. or 11.G. Use only one DRP to report details related to the same event. If
an event gives rise to actions by more than one regulator, provide details for each action on a separate DRP.
PART I
A. The person(s) or entity(ies) for whom this DRP is being filed is (are):
You (the advisory firm)
You and one or more of your
advisory affiliates
One or more of your
advisory affiliates
If this DRP is being filed for an advisory affiliate, give the full name of the advisory affiliate below (for individuals, Last name, First name, Middle name).
If the advisory affiliate has a CRD number, provide that number. If not, indicate "non-registered" by checking the appropriate box.
ADV DRP - ADVISORY AFFILIATE
CRD
This advisory affiliate is a Firm an Individual
Number:
Registered:
Yes No
Name: JM FINANCIAL PRODUCTS LIMITED
(JMFPL)
(For individuals, Last, First,
Middle)
This DRP should be removed from the ADV record because the advisory affiliate(s) is no longer associated with the adviser.
This DRP should be removed from the ADV record because: (1) the event or proceeding occurred more than ten years ago or (2) the adviser is registered or
applying for registration with the SEC or reporting as an exempt reporting adviser with the SEC and the event was resolved in the adviser's or advisory
affiliate's favor.
If you are registered or registering with a state securities authority , you may remove a DRP for an event you reported only in response to Item 11.D(4), and only
if that event occurred more than ten years ago. If you are registered or registering with the SEC, you may remove a DRP for any event listed in Item 11 that
occurred more than ten years ago.
This DRP should be removed from the ADV record because it was filed in error, such as due to a clerical or data-entry mistake. Explain the circumstances:
B. If the advisory affiliate is registered through the IARD system or CRD system, has the advisory affiliate submitted a DRP (with Form ADV, BD or U-4) to the IARD or
CRD for the event? If the answer is "Yes," no other information on this DRP must be provided.
Yes No
NOTE: The completion of this form does not relieve the advisory affiliate of its obligation to update its IARD or CRD records.
PART II
1. Regulatory Action initiated by:
SEC Other Federal State Foreign
SRO
(Full name of regulator, foreign financial regulatory authority, federal, state, or SRO)
RESERVE BANK OF INDIA ("RBI")
2. Principal Sanction:
Other
Other Sanctions:
SHOW CAUSE NOTICE
3. Date Initiated (MM/DD/YYYY):
07/05/2024 Exact Explanation
If not exact, provide explanation:
4. Docket/Case Number:
NOT APPLICABLE
5. Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
NOT APPLICABLE
6. Principal Product Type:
Other
Other Product Types:
RELATED PARTY DISCLOSURES
7. Describe the allegations related to this regulatory action (your response must fit within the space provided):
RBI VIDE ITS LETTER DATED JULY 05, 2024, ISSUED A SHOW CAUSE NOTICE IN RELATION TO AN INADVERTENT MISS OF DISCLOSURE OF A RELATED PARTY
TRANSACTION IN ANNUAL REPORT PURSUANT TO PARAGRAPH 4.3(A) OF ANNEX XVI OF MASTER DIRECTION NON BANKING FINANCIAL COMPANY SYSTEMICALLY
IMPORTANT NON-DEPOSIT TAKING COMPANY AND DEPOSIT TAKING COMPANY (RESERVE BANK) DIRECTIONS, 2016.
8. Current Status? Pending On Appeal Final
9. If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and Date Appeal Filed:
NOT APPLICABLE
If Final or On Appeal, complete all items below. For Pending Actions, complete Item 13 only.
10. How was matter resolved:
Acceptance, Waiver & Consent(AWC)
11. Resolution Date (MM/DD/YYYY):
03/13/2025 Exact Explanation
If not exact, provide explanation:
12. Resolution Detail:
A. Were any of the following Sanctions Ordered (check all appropriate items)?
Monetary/Fine Amount: $ 3,565.00
Revocation/Expulsion/Denial Disgorgement/Restitution
Censure Cease and Desist/Injunction
Bar Suspension
B. Other Sanctions Ordered:
NOT APPLICABLE
Sanction detail: if suspended, enjoined or barred, provide duration including start date and capacities affected (General Securities Principal, Financial
Operations Principal, etc.). If requalification by exam/retraining was a condition of the sanction, provide length of time given to requalify/retrain, type of
exam required and whether condition has been satisfied. If disposition resulted in a fine, penalty, restitution, disgorgement or monetary compensation,
provide total amount, portion levied against you or an advisory affiliate, date paid and if any portion of penalty was waived:
NOT APPLICABLE
13. Provide a brief summary of details related to the action status and (or) disposition and include relevant terms, conditions and dates (your response must fit
within the space provided).
PURUSUANT TO PARAGRAPH 4.3(A) OF ANNEX XVI OF MASTER DIRECTION NON BANKING FINANCIAL COMPANY SYSTEMICALLY IMPORTANT NONDEPOSIT TAKING
COMPANY AND DEPOSIT TAKING COMPANY (RESERVE BANK) DIRECTIONS, 2016, RBI VIDE ITS LETTER DATED JULY 05, 2024, ISSUED A SHOW CAUSE NOTICE IN
RELATION TO AN INADVERTENT MISS OF DISCLOSURE OF A RELATED PARTY TRANSACTION IN ANNUAL REPORT. JMFPL REPLIED TO THE SHOW CAUSE NOTICE
STATING THAT THE SAID TRANSACTION HAS DISCLOSED IN ITS AUDITED FINANCIAL STATEMENTS UNDER THE RELATED PARTY TRANSACTIONS AND THAT THE
MISSED DISCLOSURE OF RELATED PARTY TRANSACTION WAS PURELY ON THE GROUND OF INTERPRETATION, RBI VIDE ITS ORDER DATED MARCH 13, 2025 LEVIED A
PENALTY OF RS. 3.10 LAKH ON JMFPL (MATTER CLOSED).
GENERAL INSTRUCTIONS
This Disclosure Reporting Page (DRP ADV) is an INITIAL AMENDED response used to report details for affirmative responses to Items 11.C., 11.D., 11.E., 11.F.
OR
or 11.G. of Form ADV.
Regulatory Action
Check item(s) being responded to:
11.C(1) 11.C(2) 11.C(3) 11.C(4) 11.C(5)
11.D(1) 11.D(2) 11.D(3) 11.D(4) 11.D(5)
11.E(1) 11.E(2) 11.E(3) 11.E(4)
11.F. 11.G.
Use a separate DRP for each event or proceeding . The same event or proceeding may be reported for more than one person or entity using one DRP. File with a
completed Execution Page.
One event may result in more than one affirmative answer to Items 11.C., 11.D., 11.E., 11.F. or 11.G. Use only one DRP to report details related to the same event. If
an event gives rise to actions by more than one regulator, provide details for each action on a separate DRP.
PART I
A. The person(s) or entity(ies) for whom this DRP is being filed is (are):
You (the advisory firm)
You and one or more of your
advisory affiliates
One or more of your
advisory affiliates
If this DRP is being filed for an advisory affiliate, give the full name of the advisory affiliate below (for individuals, Last name, First name, Middle name).
If the advisory affiliate has a CRD number, provide that number. If not, indicate "non-registered" by checking the appropriate box.
ADV DRP - ADVISORY AFFILIATE
CRD
This advisory affiliate is a Firm an Individual
Number:
Registered:
Yes No
Name: JM FINANCIAL SERVICES LIMITED
(JMFSL)
(For individuals, Last, First,
Middle)
This DRP should be removed from the ADV record because the advisory affiliate(s) is no longer associated with the adviser.
This DRP should be removed from the ADV record because: (1) the event or proceeding occurred more than ten years ago or (2) the adviser is registered or
applying for registration with the SEC or reporting as an exempt reporting adviser with the SEC and the event was resolved in the adviser's or advisory
affiliate's favor.
If you are registered or registering with a state securities authority , you may remove a DRP for an event you reported only in response to Item 11.D(4), and only
if that event occurred more than ten years ago. If you are registered or registering with the SEC, you may remove a DRP for any event listed in Item 11 that
occurred more than ten years ago.
This DRP should be removed from the ADV record because it was filed in error, such as due to a clerical or data-entry mistake. Explain the circumstances:
B. If the advisory affiliate is registered through the IARD system or CRD system, has the advisory affiliate submitted a DRP (with Form ADV, BD or U-4) to the IARD or
CRD for the event? If the answer is "Yes," no other information on this DRP must be provided.
Yes No
NOTE: The completion of this form does not relieve the advisory affiliate of its obligation to update its IARD or CRD records.
PART II
1. Regulatory Action initiated by:
SEC Other Federal State Foreign
SRO
(Full name of regulator, foreign financial regulatory authority, federal, state, or SRO)
NATIONAL STOCK EXCHANGE OF INDIA LIMITED
2. Principal Sanction:
Other
Other Sanctions:
MONETARY FINE
3. Date Initiated (MM/DD/YYYY):
03/03/2025 Exact Explanation
If not exact, provide explanation:
4. Docket/Case Number:
NOT APPLICABLE
5. Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
NOT APPLICABLE
6. Principal Product Type:
No Product
Other Product Types:
7. Describe the allegations related to this regulatory action (your response must fit within the space provided):
NSE MCSGFC, COMMITTEE VIDE ORDER DATED MARCH 03, 2025, HAS LEVIED PENALTY OF RS. 5,60,000/- ($6,384) FOR VIOLATION OBSERVED DURING ONSITE
INSPECTION OF AUTHORIZED PERSON. WE HAVE SUBMITTED A REQUEST FOR REVERSAL OF THE PENALTY LEVIED.
8. Current Status? Pending On Appeal Final
9. If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and Date Appeal Filed:
If Final or On Appeal, complete all items below. For Pending Actions, complete Item 13 only.
10. How was matter resolved:
11. Resolution Date (MM/DD/YYYY):
Exact Explanation
If not exact, provide explanation:
12. Resolution Detail:
A. Were any of the following Sanctions Ordered (check all appropriate items)?
Monetary/Fine Amount: $
Revocation/Expulsion/Denial Disgorgement/Restitution
Censure Cease and Desist/Injunction
Bar Suspension
B. Other Sanctions Ordered:
Sanction detail: if suspended, enjoined or barred, provide duration including start date and capacities affected (General Securities Principal, Financial
Operations Principal, etc.). If requalification by exam/retraining was a condition of the sanction, provide length of time given to requalify/retrain, type of
exam required and whether condition has been satisfied. If disposition resulted in a fine, penalty, restitution, disgorgement or monetary compensation,
provide total amount, portion levied against you or an advisory affiliate, date paid and if any portion of penalty was waived:
13. Provide a brief summary of details related to the action status and (or) disposition and include relevant terms, conditions and dates (your response must fit
within the space provided).
NSE MCSGFC, COMMITTEE VIDE ORDER DATED MARCH 03, 2025, HAS LEVIED PENALTY OF RS. 5,60,000/- ($6,384) FOR VIOLATION OBSERVED DURING ONSITE
INSPECTION OF AUTHORIZED PERSON. WE HAVE SUBMITTED A REQUEST FOR REVERSAL OF THE PENALTY LEVIED.
GENERAL INSTRUCTIONS
This Disclosure Reporting Page (DRP ADV) is an INITIAL AMENDED response used to report details for affirmative responses to Items 11.C., 11.D., 11.E., 11.F.
OR
or 11.G. of Form ADV.
Regulatory Action
Check item(s) being responded to:
11.C(1) 11.C(2) 11.C(3) 11.C(4) 11.C(5)
11.D(1) 11.D(2) 11.D(3) 11.D(4) 11.D(5)
11.E(1) 11.E(2) 11.E(3) 11.E(4)
11.F. 11.G.
Use a separate DRP for each event or proceeding . The same event or proceeding may be reported for more than one person or entity using one DRP. File with a
completed Execution Page.
One event may result in more than one affirmative answer to Items 11.C., 11.D., 11.E., 11.F. or 11.G. Use only one DRP to report details related to the same event. If
an event gives rise to actions by more than one regulator, provide details for each action on a separate DRP.
PART I
A. The person(s) or entity(ies) for whom this DRP is being filed is (are):
You (the advisory firm)
You and one or more of your
advisory affiliates
One or more of your
advisory affiliates
If this DRP is being filed for an advisory affiliate, give the full name of the advisory affiliate below (for individuals, Last name, First name, Middle name).
If the advisory affiliate has a CRD number, provide that number. If not, indicate "non-registered" by checking the appropriate box.
ADV DRP - ADVISORY AFFILIATE
CRD
This advisory affiliate is a Firm an Individual
Number:
Registered:
Yes No
Name: JM FINANCIAL SERVICES LIMITED
(JMFSL)
(For individuals, Last, First,
Middle)
This DRP should be removed from the ADV record because the advisory affiliate(s) is no longer associated with the adviser.
This DRP should be removed from the ADV record because: (1) the event or proceeding occurred more than ten years ago or (2) the adviser is registered or
applying for registration with the SEC or reporting as an exempt reporting adviser with the SEC and the event was resolved in the adviser's or advisory
affiliate's favor.
If you are registered or registering with a state securities authority , you may remove a DRP for an event you reported only in response to Item 11.D(4), and only
if that event occurred more than ten years ago. If you are registered or registering with the SEC, you may remove a DRP for any event listed in Item 11 that
occurred more than ten years ago.
This DRP should be removed from the ADV record because it was filed in error, such as due to a clerical or data-entry mistake. Explain the circumstances:
B. If the advisory affiliate is registered through the IARD system or CRD system, has the advisory affiliate submitted a DRP (with Form ADV, BD or U-4) to the IARD or
CRD for the event? If the answer is "Yes," no other information on this DRP must be provided.
Yes No
NOTE: The completion of this form does not relieve the advisory affiliate of its obligation to update its IARD or CRD records.
PART II
1. Regulatory Action initiated by:
SEC Other Federal State Foreign
SRO
(Full name of regulator, foreign financial regulatory authority, federal, state, or SRO)
SECURITIES AND EXCHANGE BOARD OF INDIA ("SEBI")
2. Principal Sanction:
Disgorgement
Other Sanctions:
PUBLIC OF ISSUE OF DEBT SECURITIES
3. Date Initiated (MM/DD/YYYY):
03/07/2024 Exact Explanation
If not exact, provide explanation:
4. Docket/Case Number:
NOT APPLICABLE
5. Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
NOT APPLICABLE
6. Principal Product Type:
Other
Other Product Types:
PUBLIC ISSUE OF DEBT SECURITIES
7. Describe the allegations related to this regulatory action (your response must fit within the space provided):
JMFSL HAS BEEN REFERRED IN THE INTERIM EX PARTE ORDER DATED MARCH 7, 2024 PASSED BY SEBI AGAINST JM FINANCIAL LIMITED (JMFL) IN THE MATTER OF
PUBLIC OF ISSUE OF CERTAIN DEBT SECURITIES. THE SAID CONFIRMATORY ORDER IMPOSED RESTRICTIONS ON JMFL TO UNDERTAKE ANY NEW MANDATE FOR
PUBLIC ISSUE OF DEBT SECURITIES TILL MARCH 31, 2025 BUT CLARIFIED THAT JMFL CAN UNDERTAKE PUBLIC ISSUE OF EQUITY INSTRUMENTS.
8. Current Status? Pending On Appeal Final
9. If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and Date Appeal Filed:
If Final or On Appeal, complete all items below. For Pending Actions, complete Item 13 only.
10. How was matter resolved:
Settled
11. Resolution Date (MM/DD/YYYY):
09/19/2025 Exact Explanation
If not exact, provide explanation:
12. Resolution Detail:
A. Were any of the following Sanctions Ordered (check all appropriate items)?
Monetary/Fine Amount: $ 367,203.00
Revocation/Expulsion/Denial Disgorgement/Restitution
Censure Cease and Desist/Injunction
Bar Suspension
B. Other Sanctions Ordered:
NOT APPLICABLE
Sanction detail: if suspended, enjoined or barred, provide duration including start date and capacities affected (General Securities Principal, Financial
Operations Principal, etc.). If requalification by exam/retraining was a condition of the sanction, provide length of time given to requalify/retrain, type of
exam required and whether condition has been satisfied. If disposition resulted in a fine, penalty, restitution, disgorgement or monetary compensation,
provide total amount, portion levied against you or an advisory affiliate, date paid and if any portion of penalty was waived:
SETTLEMENT AMOUNT . RS. 191,60,599/- ($216,515) DISGORGEMENT AMOUNT: RS. . 1,33,35,239/- ($150,688)
13. Provide a brief summary of details related to the action status and (or) disposition and include relevant terms, conditions and dates (your response must fit
within the space provided).
JMFL HAS ADHERED TO THE SAID ORDERS. JMFSL MADE A VOLUNTARY SETTLEMENT APPLICATION UNDER THE SEBI (SETTLEMENT PROCEEDINGS) REGULATIONS,
2018. PURSUANT TO THE SAID APPLICATION, SEBI VIDE ITS ORDER DATED SEPTEMBER 19, 2025 (THE "SETTLEMENT ORDER") SETTLED THE PROCEEDINGS THAT
MAY HAVE BEEN INITIATED AGAINST JMFSL IN THE SUBJECT MATTER UPON JMFSL MAKING PAYMENT OF THE SETTLEMENT AMOUNT OF RS. 191,60,599/- ($216,515)
AND THE DISGORGEMENT AMOUNT OF RS. 1,33,35,239/- ($150,688), WITHOUT JMFSL ADMITTING OR DENYING THE FINDINGS OF FACTS AND CONCLUSIONS OF
LAW. ADDITIONALLY, JMFSL ALSO AGREED TO VOLUNTARY DEBARMENT FROM ACTING AS A DISTRIBUTOR IN ANY PUBLIC ISSUE OF DEBT SECURITIES FOR A PERIOD
OF 3 MONTHS FROM THE DATE OF THE SETTLEMENT ORDER, VIZ. SEPTEMBER 19, 2025.
GENERAL INSTRUCTIONS
This Disclosure Reporting Page (DRP ADV) is an INITIAL AMENDED response used to report details for affirmative responses to Items 11.C., 11.D., 11.E., 11.F.
OR
or 11.G. of Form ADV.
Regulatory Action
Check item(s) being responded to:
11.C(1) 11.C(2) 11.C(3) 11.C(4) 11.C(5)
11.D(1) 11.D(2) 11.D(3) 11.D(4) 11.D(5)
11.E(1) 11.E(2) 11.E(3) 11.E(4)
11.F. 11.G.
Use a separate DRP for each event or proceeding . The same event or proceeding may be reported for more than one person or entity using one DRP. File with a
completed Execution Page.
One event may result in more than one affirmative answer to Items 11.C., 11.D., 11.E., 11.F. or 11.G. Use only one DRP to report details related to the same event. If
an event gives rise to actions by more than one regulator, provide details for each action on a separate DRP.
PART I
A. The person(s) or entity(ies) for whom this DRP is being filed is (are):
You (the advisory firm)
You and one or more of your
advisory affiliates
One or more of your
advisory affiliates
If this DRP is being filed for an advisory affiliate, give the full name of the advisory affiliate below (for individuals, Last name, First name, Middle name).
If the advisory affiliate has a CRD number, provide that number. If not, indicate "non-registered" by checking the appropriate box.
ADV DRP - ADVISORY AFFILIATE
CRD
This advisory affiliate is a Firm an Individual
Number:
Registered:
Yes No
Name: JM FINANCIAL SERVICES LIMITED
(JMFSL)
(For individuals, Last, First,
Middle)
This DRP should be removed from the ADV record because the advisory affiliate(s) is no longer associated with the adviser.
This DRP should be removed from the ADV record because: (1) the event or proceeding occurred more than ten years ago or (2) the adviser is registered or
applying for registration with the SEC or reporting as an exempt reporting adviser with the SEC and the event was resolved in the adviser's or advisory
affiliate's favor.
If you are registered or registering with a state securities authority , you may remove a DRP for an event you reported only in response to Item 11.D(4), and only
if that event occurred more than ten years ago. If you are registered or registering with the SEC, you may remove a DRP for any event listed in Item 11 that
occurred more than ten years ago.
This DRP should be removed from the ADV record because it was filed in error, such as due to a clerical or data-entry mistake. Explain the circumstances:
B. If the advisory affiliate is registered through the IARD system or CRD system, has the advisory affiliate submitted a DRP (with Form ADV, BD or U-4) to the IARD or
CRD for the event? If the answer is "Yes," no other information on this DRP must be provided.
Yes No
NOTE: The completion of this form does not relieve the advisory affiliate of its obligation to update its IARD or CRD records.
PART II
1. Regulatory Action initiated by:
SEC Other Federal State Foreign
SRO
(Full name of regulator, foreign financial regulatory authority, federal, state, or SRO)
NATIONAL STOCK EXCHANGE OF INDIA LIMITED
2. Principal Sanction:
Civil and Administrative Penalt(ies) /Fine(s)
Other Sanctions:
PENALTY LEVIED FOR OBSERVATION RAISED UPON INSPECTION CONDUCTED
3. Date Initiated (MM/DD/YYYY):
09/05/2019 Exact Explanation
If not exact, provide explanation:
4. Docket/Case Number:
NOT APPLICABLE
5. Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
NOT APPLICABLE
6. Principal Product Type:
No Product
Other Product Types:
7. Describe the allegations related to this regulatory action (your response must fit within the space provided):
NSE VIDE ITS LETTER DATED SEPTEMBER 5, 2019 HAS COMMUNICATED THE DECISION MADE BY THE MEMBER SELECTION COMMITTEE ("MSC") OF THE EXCHANGE
AND LEVIED A PENALTY OF RS.5,00,000/- ($6950) FOR CONTINUED TO REMAIN CONNECTED TO THE FALLBACK / SECONDARY SERVER OF THE EXCHANGE THROUGH
THE CO-LOCATION FACILITY PROVIDED DURING MAY 2012 TO JULY 2014. MATTER CLOSED
8. Current Status? Pending On Appeal Final
9. If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and Date Appeal Filed:
NOT APPLICABLE
If Final or On Appeal, complete all items below. For Pending Actions, complete Item 13 only.
10. How was matter resolved:
Settled
11. Resolution Date (MM/DD/YYYY):
09/05/2019 Exact Explanation
If not exact, provide explanation:
12. Resolution Detail:
A. Were any of the following Sanctions Ordered (check all appropriate items)?
Monetary/Fine Amount: $ 6,950.00
Revocation/Expulsion/Denial Disgorgement/Restitution
Censure Cease and Desist/Injunction
Bar Suspension
B. Other Sanctions Ordered:
NOT APPLICABLE
Sanction detail: if suspended, enjoined or barred, provide duration including start date and capacities affected (General Securities Principal, Financial
Operations Principal, etc.). If requalification by exam/retraining was a condition of the sanction, provide length of time given to requalify/retrain, type of
exam required and whether condition has been satisfied. If disposition resulted in a fine, penalty, restitution, disgorgement or monetary compensation,
provide total amount, portion levied against you or an advisory affiliate, date paid and if any portion of penalty was waived:
MONETARY FINE PAID RS. 5,00,000/- ($6950)
13. Provide a brief summary of details related to the action status and (or) disposition and include relevant terms, conditions and dates (your response must fit
within the space provided).
NSE VIDE ITS LETTER DATED SEPTEMBER 5, 2019 HAS COMMUNICATED THE DECISION MADE BY THE MEMBER SELECTION COMMITTEE ("MSC") OF THE EXCHANGE
AND LEVIED A PENALTY OF RS.5,00,000/- ($6950) FOR CONTINUED TO REMAIN CONNECTED TO THE FALLBACK / SECONDARY SERVER OF THE EXCHANGE THROUGH
THE CO-LOCATION FACILITY PROVIDED DURING MAY 2012 TO JULY 2014. MATTER CLOSED.
GENERAL INSTRUCTIONS
This Disclosure Reporting Page (DRP ADV) is an INITIAL AMENDED response used to report details for affirmative responses to Items 11.C., 11.D., 11.E., 11.F.
OR
or 11.G. of Form ADV.
Regulatory Action
Check item(s) being responded to:
11.C(1) 11.C(2) 11.C(3) 11.C(4) 11.C(5)
11.D(1) 11.D(2) 11.D(3) 11.D(4) 11.D(5)
11.E(1) 11.E(2) 11.E(3) 11.E(4)
11.F. 11.G.
Use a separate DRP for each event or proceeding . The same event or proceeding may be reported for more than one person or entity using one DRP. File with a
completed Execution Page.
One event may result in more than one affirmative answer to Items 11.C., 11.D., 11.E., 11.F. or 11.G. Use only one DRP to report details related to the same event. If
an event gives rise to actions by more than one regulator, provide details for each action on a separate DRP.
PART I
A. The person(s) or entity(ies) for whom this DRP is being filed is (are):
You (the advisory firm)
You and one or more of your
advisory affiliates
One or more of your
advisory affiliates
If this DRP is being filed for an advisory affiliate, give the full name of the advisory affiliate below (for individuals, Last name, First name, Middle name).
If the advisory affiliate has a CRD number, provide that number. If not, indicate "non-registered" by checking the appropriate box.
ADV DRP - ADVISORY AFFILIATE
CRD
This advisory affiliate is a Firm an Individual
Number:
Registered:
Yes No
Name: JM FINANCIAL PRODUCTS LIMITED
(JMFPL)
(For individuals, Last, First,
Middle)
This DRP should be removed from the ADV record because the advisory affiliate(s) is no longer associated with the adviser.
This DRP should be removed from the ADV record because: (1) the event or proceeding occurred more than ten years ago or (2) the adviser is registered or
applying for registration with the SEC or reporting as an exempt reporting adviser with the SEC and the event was resolved in the adviser's or advisory
affiliate's favor.
If you are registered or registering with a state securities authority , you may remove a DRP for an event you reported only in response to Item 11.D(4), and only
if that event occurred more than ten years ago. If you are registered or registering with the SEC, you may remove a DRP for any event listed in Item 11 that
occurred more than ten years ago.
This DRP should be removed from the ADV record because it was filed in error, such as due to a clerical or data-entry mistake. Explain the circumstances:
B. If the advisory affiliate is registered through the IARD system or CRD system, has the advisory affiliate submitted a DRP (with Form ADV, BD or U-4) to the IARD or
CRD for the event? If the answer is "Yes," no other information on this DRP must be provided.
Yes No
NOTE: The completion of this form does not relieve the advisory affiliate of its obligation to update its IARD or CRD records.
PART II
1. Regulatory Action initiated by:
SEC Other Federal State Foreign
SRO
(Full name of regulator, foreign financial regulatory authority, federal, state, or SRO)
SECURITIES EXCHANGE BOARD OF INDIA ("SEBI")
2. Principal Sanction:
Other
Other Sanctions:
INTERIM EX-PARTE ORDER AND CONFIRMATORY ORDER
3. Date Initiated (MM/DD/YYYY):
03/07/2024 Exact Explanation
If not exact, provide explanation:
03/07/2024 AND 06/20/2024
4. Docket/Case Number:
NOT APPLICABLE
5. Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
NOT APPLICABLE
6. Principal Product Type:
Debt - Corporate
Other Product Types:
DEBT SECURITIES
7. Describe the allegations related to this regulatory action (your response must fit within the space provided):
JMFPL HAD BEEN REFERRED IN THE ORDERS ISSUED BY SEBI AGAINST JM FINANCIAL LIMITED ("JMFL"), VIZ., AN INTERIM EX-PARTE ORDER DATED MARCH 7, 2024
AND CONFIRMATORY ORDER DATED JUNE 20, 2024 IN THE MATTER OF PUBLIC ISSUE OF CERTAIN DEBT SECURITIES.
8. Current Status? Pending On Appeal Final
9. If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and Date Appeal Filed:
NOT APPLICABLE
If Final or On Appeal, complete all items below. For Pending Actions, complete Item 13 only.
10. How was matter resolved:
Settled
11. Resolution Date (MM/DD/YYYY):
09/19/2025 Exact Explanation
If not exact, provide explanation:
12. Resolution Detail:
A. Were any of the following Sanctions Ordered (check all appropriate items)?
Monetary/Fine Amount: $ 49,900.00
Revocation/Expulsion/Denial Disgorgement/Restitution
Censure Cease and Desist/Injunction
Bar Suspension
B. Other Sanctions Ordered:
SETTLEMENT AMOUNT OF RS. 44,00,000/- ($49,900)
Sanction detail: if suspended, enjoined or barred, provide duration including start date and capacities affected (General Securities Principal, Financial
Operations Principal, etc.). If requalification by exam/retraining was a condition of the sanction, provide length of time given to requalify/retrain, type of
exam required and whether condition has been satisfied. If disposition resulted in a fine, penalty, restitution, disgorgement or monetary compensation,
provide total amount, portion levied against you or an advisory affiliate, date paid and if any portion of penalty was waived:
JMFPL MADE VOLUNTARY SETTLEMENT APPLICATION UNDER SEBI (SETTLEMENT PROCEEDINGS) REGULATIONS, 2018 IN RESPECT OF SEBI ORDERS DATED
MARCH 7, 2024 AND JUNE 20, 2024 BY NEITHER ADMITTING NOR DENYING THE FINDINGS OF FACT AND CONCLUSIONS OF LAW. PURSUANT TO THE ABOVE
APPLICATION, SEBI VIDE ITS ORDER DATED SEPTEMBER 19, 2025 SETTLED THE PROCEEDINGS THAT MAY HAVE BEEN INITIATED AGAINST JMFPL AFTER
PAYMENT OF RS. 44,00,000/- ($49,900) AS SETTLEMENT AMOUNT. FURTHER, JMFPL AGREED FOR VOLUNTARY DEBARMENT FROM UNDERTAKING THE BUSINESS
OF INITIAL PUBLIC OFFER FINANCING FOR A PERIOD OF 3 MONTHS FROM THE DATE OF SETTLEMENT ORDER.
13. Provide a brief summary of details related to the action status and (or) disposition and include relevant terms, conditions and dates (your response must fit
within the space provided).
JMFPL HAD BEEN REFERRED IN THE ORDERS ISSUED BY SEBI AGAINST JM FINANCIAL LIMITED ("JMFL"), VIZ., AN INTERIM EX-PARTE ORDER DATED MARCH 7, 2024
AND CONFIRMATORY ORDER DATED JUNE 20, 2024 IN THE MATTER OF PUBLIC ISSUE OF CERTAIN DEBT SECURITIES. JMFPL MADE VOLUNTARY SETTLEMENT
APPLICATION UNDER THE SEBI (SETTLEMENT PROCEEDINGS) REGULATIONS, 2018. PURSUANT TO THE ABOVE APPLICATION, SEBI VIDE ITS ORDER DATED
SEPTEMBER 19, 2025 SETTLED THE PROCEEDINGS THAT MAY HAVE BEEN INITIATED AGAINST JMFPL IN THE MATTER (MATTER CLOSED).
GENERAL INSTRUCTIONS
This Disclosure Reporting Page (DRP ADV) is an INITIAL AMENDED response used to report details for affirmative responses to Items 11.C., 11.D., 11.E., 11.F.
OR
or 11.G. of Form ADV.
Regulatory Action
Check item(s) being responded to:
11.C(1) 11.C(2) 11.C(3) 11.C(4) 11.C(5)
11.D(1) 11.D(2) 11.D(3) 11.D(4) 11.D(5)
11.E(1) 11.E(2) 11.E(3) 11.E(4)
11.F. 11.G.
Use a separate DRP for each event or proceeding . The same event or proceeding may be reported for more than one person or entity using one DRP. File with a
completed Execution Page.
One event may result in more than one affirmative answer to Items 11.C., 11.D., 11.E., 11.F. or 11.G. Use only one DRP to report details related to the same event. If
an event gives rise to actions by more than one regulator, provide details for each action on a separate DRP.
PART I
A. The person(s) or entity(ies) for whom this DRP is being filed is (are):
You (the advisory firm)
You and one or more of your
advisory affiliates
One or more of your
advisory affiliates
If this DRP is being filed for an advisory affiliate, give the full name of the advisory affiliate below (for individuals, Last name, First name, Middle name).
If the advisory affiliate has a CRD number, provide that number. If not, indicate "non-registered" by checking the appropriate box.
ADV DRP - ADVISORY AFFILIATE
CRD
This advisory affiliate is a Firm an Individual
Number:
Registered:
Yes No
Name: JM FINANCIAL SERVICES LIMITED
(JMFSL)
(For individuals, Last, First,
Middle)
This DRP should be removed from the ADV record because the advisory affiliate(s) is no longer associated with the adviser.
This DRP should be removed from the ADV record because: (1) the event or proceeding occurred more than ten years ago or (2) the adviser is registered or
applying for registration with the SEC or reporting as an exempt reporting adviser with the SEC and the event was resolved in the adviser's or advisory
affiliate's favor.
If you are registered or registering with a state securities authority , you may remove a DRP for an event you reported only in response to Item 11.D(4), and only
if that event occurred more than ten years ago. If you are registered or registering with the SEC, you may remove a DRP for any event listed in Item 11 that
occurred more than ten years ago.
This DRP should be removed from the ADV record because it was filed in error, such as due to a clerical or data-entry mistake. Explain the circumstances:
B. If the advisory affiliate is registered through the IARD system or CRD system, has the advisory affiliate submitted a DRP (with Form ADV, BD or U-4) to the IARD or
CRD for the event? If the answer is "Yes," no other information on this DRP must be provided.
Yes No
NOTE: The completion of this form does not relieve the advisory affiliate of its obligation to update its IARD or CRD records.
PART II
1. Regulatory Action initiated by:
SEC Other Federal State Foreign
SRO
(Full name of regulator, foreign financial regulatory authority, federal, state, or SRO)
NATIONAL STOCK EXCHANGE OF INDIA LIMITED
2. Principal Sanction:
Other
Other Sanctions:
MONETARY FINE
3. Date Initiated (MM/DD/YYYY):
05/13/2024 Exact Explanation
If not exact, provide explanation:
4. Docket/Case Number:
NOT APPLICABLE
5. Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
NOT APPLICABLE
6. Principal Product Type:
No Product
Other Product Types:
7. Describe the allegations related to this regulatory action (your response must fit within the space provided):
NSE VIDE ITS LETTER DATED MAY 13, 2024 HAS LEVIED A PENALTY OF RS. 6,08,000/- ($7,296) FOR OBSERVATIONS RAISED IN INSPECTION CONDUCTED FOR THE
PERIOD OCTOBER 01, 2022 TO SEPTEMBER 30, 2023.
8. Current Status? Pending On Appeal Final
9. If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and Date Appeal Filed:
If Final or On Appeal, complete all items below. For Pending Actions, complete Item 13 only.
10. How was matter resolved:
Settled
11. Resolution Date (MM/DD/YYYY):
12/03/2025 Exact Explanation
If not exact, provide explanation:
12. Resolution Detail:
A. Were any of the following Sanctions Ordered (check all appropriate items)?
Monetary/Fine Amount: $ 6,083.00
Revocation/Expulsion/Denial Disgorgement/Restitution
Censure Cease and Desist/Injunction
Bar Suspension
B. Other Sanctions Ordered:
NOT APPLICABLE
Sanction detail: if suspended, enjoined or barred, provide duration including start date and capacities affected (General Securities Principal, Financial
Operations Principal, etc.). If requalification by exam/retraining was a condition of the sanction, provide length of time given to requalify/retrain, type of
exam required and whether condition has been satisfied. If disposition resulted in a fine, penalty, restitution, disgorgement or monetary compensation,
provide total amount, portion levied against you or an advisory affiliate, date paid and if any portion of penalty was waived:
NSE VIDE ITS LETTER DATED MAY 13, 2024 HAS LEVIED A PENALTY OF RS. 6,08,000/- ($7296) FOR OBSERVATIONS RAISED IN INSPECTION CONDUCTED FOR
THE PERIOD OCTOBER 01, 2022 TO SEPTEMBER 30, 2023. NSE MEMBER COMMITTEE VIDE ITS LETTER DATED DECEMBER 03, 2025, HAS DECIDED TO WAIVE
OFF THE PENALTY OF RS. 1,00,000/- ($1197) ONLY LEVIED WITH RESPECT TO INSPECTION OF BRANCHES / REGISTERED AUTHORIZED PERSONS. MATTER
CLOSED.
13. Provide a brief summary of details related to the action status and (or) disposition and include relevant terms, conditions and dates (your response must fit
within the space provided).
NSE VIDE ITS LETTER DATED MAY 13, 2024 HAS LEVIED A PENALTY OF RS. 6,08,000/- ($7,296) FOR OBSERVATIONS RAISED IN INSPECTION CONDUCTED FOR THE
PERIOD OCTOBER 01, 2022 TO SEPTEMBER 30, 2023. NSE MEMBER COMMITTEE VIDE ITS LETTER DATED DECEMBER 03, 2025, HAS DECIDED TO WAIVE OFF THE
PENALTY OF RS. 1,00,000/- ($1197)) ONLY LEVIED WITH RESPECT TO INSPECTION OF BRANCHES / REGISTERED AUTHORISED PERSONS (APS). MATTER CLOSED.
GENERAL INSTRUCTIONS
This Disclosure Reporting Page (DRP ADV) is an INITIAL AMENDED response used to report details for affirmative responses to Items 11.C., 11.D., 11.E., 11.F.
OR
or 11.G. of Form ADV.
Regulatory Action
Check item(s) being responded to:
11.C(1) 11.C(2) 11.C(3) 11.C(4) 11.C(5)
11.D(1) 11.D(2) 11.D(3) 11.D(4) 11.D(5)
11.E(1) 11.E(2) 11.E(3) 11.E(4)
11.F. 11.G.
Use a separate DRP for each event or proceeding . The same event or proceeding may be reported for more than one person or entity using one DRP. File with a
completed Execution Page.
One event may result in more than one affirmative answer to Items 11.C., 11.D., 11.E., 11.F. or 11.G. Use only one DRP to report details related to the same event. If
an event gives rise to actions by more than one regulator, provide details for each action on a separate DRP.
PART I
A. The person(s) or entity(ies) for whom this DRP is being filed is (are):
You (the advisory firm)
You and one or more of your
advisory affiliates
One or more of your
advisory affiliates
If this DRP is being filed for an advisory affiliate, give the full name of the advisory affiliate below (for individuals, Last name, First name, Middle name).
If the advisory affiliate has a CRD number, provide that number. If not, indicate "non-registered" by checking the appropriate box.
ADV DRP - ADVISORY AFFILIATE
CRD
This advisory affiliate is a Firm an Individual
Number:
Registered:
Yes No
Name: JM FINANCIAL SERVICES LIMITED
(JMFSL)
(For individuals, Last, First,
Middle)
This DRP should be removed from the ADV record because the advisory affiliate(s) is no longer associated with the adviser.
This DRP should be removed from the ADV record because: (1) the event or proceeding occurred more than ten years ago or (2) the adviser is registered or
applying for registration with the SEC or reporting as an exempt reporting adviser with the SEC and the event was resolved in the adviser's or advisory
affiliate's favor.
If you are registered or registering with a state securities authority , you may remove a DRP for an event you reported only in response to Item 11.D(4), and only
if that event occurred more than ten years ago. If you are registered or registering with the SEC, you may remove a DRP for any event listed in Item 11 that
occurred more than ten years ago.
This DRP should be removed from the ADV record because it was filed in error, such as due to a clerical or data-entry mistake. Explain the circumstances:
B. If the advisory affiliate is registered through the IARD system or CRD system, has the advisory affiliate submitted a DRP (with Form ADV, BD or U-4) to the IARD or
CRD for the event? If the answer is "Yes," no other information on this DRP must be provided.
Yes No
NOTE: The completion of this form does not relieve the advisory affiliate of its obligation to update its IARD or CRD records.
PART II
1. Regulatory Action initiated by:
SEC Other Federal State Foreign
SRO
(Full name of regulator, foreign financial regulatory authority, federal, state, or SRO)
NATIONAL STOCK EXCHANGE OF INDIA LIMITED
2. Principal Sanction:
Other
Other Sanctions:
MONETARY FINE
3. Date Initiated (MM/DD/YYYY):
10/17/2023 Exact Explanation
If not exact, provide explanation:
4. Docket/Case Number:
NOT APPLICABLE
5. Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
NOT APPLICABLE
6. Principal Product Type:
No Product
Other Product Types:
7. Describe the allegations related to this regulatory action (your response must fit within the space provided):
NSE VIDE ITS INVOICE DATED OCTOBER 17, 2023, HAS LEVIED PENALTY OF RS.5,41,850/- ($6502) AS NSE_MCSGFC COMMITTEE-MATCH AND REVERSAL OF TRADE
(VINOD SOMANI HUF & BEENA SOMANI).IN ONE OF THE CLIENTS. MATTER CLOSED.
8. Current Status? Pending On Appeal Final
9. If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and Date Appeal Filed:
If Final or On Appeal, complete all items below. For Pending Actions, complete Item 13 only.
10. How was matter resolved:
Settled
11. Resolution Date (MM/DD/YYYY):
10/17/2023 Exact Explanation
If not exact, provide explanation:
12. Resolution Detail:
A. Were any of the following Sanctions Ordered (check all appropriate items)?
Monetary/Fine Amount: $ 6,502.00
Revocation/Expulsion/Denial Disgorgement/Restitution
Censure Cease and Desist/Injunction
Bar Suspension
B. Other Sanctions Ordered:
NOT APPLICABLE
Sanction detail: if suspended, enjoined or barred, provide duration including start date and capacities affected (General Securities Principal, Financial
Operations Principal, etc.). If requalification by exam/retraining was a condition of the sanction, provide length of time given to requalify/retrain, type of
exam required and whether condition has been satisfied. If disposition resulted in a fine, penalty, restitution, disgorgement or monetary compensation,
provide total amount, portion levied against you or an advisory affiliate, date paid and if any portion of penalty was waived:
NSE VIDE ITS INVOICE DATED OCTOBER 17, 2023, HAS LEVIED PENALTY OF RS.5,41,850/- ($6502) AS NSE_MCSGFC COMMITTEE-MATCH AND REVERSAL OF
TRADE (VINOD SOMANI HUF & BEENA SOMANI).IN ONE OF THE CLIENTS. MATTER CLOSED.
13. Provide a brief summary of details related to the action status and (or) disposition and include relevant terms, conditions and dates (your response must fit
within the space provided).
NSE VIDE ITS INVOICE DATED OCTOBER 17, 2023, HAS LEVIED PENALTY OF RS.5,41,850/- ($6502) AS NSE_MCSGFC COMMITTEE-MATCH AND REVERSAL OF TRADE
(VINOD SOMANI HUF & BEENA SOMANI).IN ONE OF THE CLIENTS. MATTER CLOSED.
GENERAL INSTRUCTIONS
This Disclosure Reporting Page (DRP ADV) is an INITIAL AMENDED response used to report details for affirmative responses to Items 11.C., 11.D., 11.E., 11.F.
OR
or 11.G. of Form ADV.
Regulatory Action
Check item(s) being responded to:
11.C(1) 11.C(2) 11.C(3) 11.C(4) 11.C(5)
11.D(1) 11.D(2) 11.D(3) 11.D(4) 11.D(5)
11.E(1) 11.E(2) 11.E(3) 11.E(4)
11.F. 11.G.
Use a separate DRP for each event or proceeding . The same event or proceeding may be reported for more than one person or entity using one DRP. File with a
completed Execution Page.
One event may result in more than one affirmative answer to Items 11.C., 11.D., 11.E., 11.F. or 11.G. Use only one DRP to report details related to the same event. If
an event gives rise to actions by more than one regulator, provide details for each action on a separate DRP.
PART I
A. The person(s) or entity(ies) for whom this DRP is being filed is (are):
You (the advisory firm)
You and one or more of your
advisory affiliates
One or more of your
advisory affiliates
If this DRP is being filed for an advisory affiliate, give the full name of the advisory affiliate below (for individuals, Last name, First name, Middle name).
If the advisory affiliate has a CRD number, provide that number. If not, indicate "non-registered" by checking the appropriate box.
ADV DRP - ADVISORY AFFILIATE
CRD
This advisory affiliate is a Firm an Individual
Number:
Registered:
Yes No
Name: JM FINANCIAL SERVICES LIMITED
(JMFSL)
(For individuals, Last, First,
Middle)
This DRP should be removed from the ADV record because the advisory affiliate(s) is no longer associated with the adviser.
This DRP should be removed from the ADV record because: (1) the event or proceeding occurred more than ten years ago or (2) the adviser is registered or
applying for registration with the SEC or reporting as an exempt reporting adviser with the SEC and the event was resolved in the adviser's or advisory
affiliate's favor.
If you are registered or registering with a state securities authority , you may remove a DRP for an event you reported only in response to Item 11.D(4), and only
if that event occurred more than ten years ago. If you are registered or registering with the SEC, you may remove a DRP for any event listed in Item 11 that
occurred more than ten years ago.
This DRP should be removed from the ADV record because it was filed in error, such as due to a clerical or data-entry mistake. Explain the circumstances:
B. If the advisory affiliate is registered through the IARD system or CRD system, has the advisory affiliate submitted a DRP (with Form ADV, BD or U-4) to the IARD or
CRD for the event? If the answer is "Yes," no other information on this DRP must be provided.
Yes No
NOTE: The completion of this form does not relieve the advisory affiliate of its obligation to update its IARD or CRD records.
PART II
1. Regulatory Action initiated by:
SEC Other Federal State Foreign
SRO
(Full name of regulator, foreign financial regulatory authority, federal, state, or SRO)
MULTI COMMODITY EXCHANGE OF INDIA LIMITED
2. Principal Sanction:
Other
Other Sanctions:
MONETARY FINE
3. Date Initiated (MM/DD/YYYY):
12/26/2025 Exact Explanation
If not exact, provide explanation:
4. Docket/Case Number:
NOT APPLICABLE
5. Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
NOT APPLICABLE
6. Principal Product Type:
No Product
Other Product Types:
INSPECTION ON STOCK BROKER
7. Describe the allegations related to this regulatory action (your response must fit within the space provided):
MCX VIDE EMAIL DATED DECEMBER 26, 2025, HAS LEVIED A PENALTY OF RS. 6,34,900 ($7047) FOR THE ABNORMAL TRADES EXECUTED IN CRUDEOILM OPTION
CONTRACTS BY ONE OF THE CLIENT. MATTER CLOSED.
8. Current Status? Pending On Appeal Final
9. If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and Date Appeal Filed:
If Final or On Appeal, complete all items below. For Pending Actions, complete Item 13 only.
10. How was matter resolved:
Settled
11. Resolution Date (MM/DD/YYYY):
12/26/2025 Exact Explanation
If not exact, provide explanation:
12. Resolution Detail:
A. Were any of the following Sanctions Ordered (check all appropriate items)?
Monetary/Fine Amount: $ 7,047.00
Revocation/Expulsion/Denial Disgorgement/Restitution
Censure Cease and Desist/Injunction
Bar Suspension
B. Other Sanctions Ordered:
NOT APPLICABLE
Sanction detail: if suspended, enjoined or barred, provide duration including start date and capacities affected (General Securities Principal, Financial
Operations Principal, etc.). If requalification by exam/retraining was a condition of the sanction, provide length of time given to requalify/retrain, type of
exam required and whether condition has been satisfied. If disposition resulted in a fine, penalty, restitution, disgorgement or monetary compensation,
provide total amount, portion levied against you or an advisory affiliate, date paid and if any portion of penalty was waived:
MONETARY FINE - RS. 6,34,900/- ($7047)
13. Provide a brief summary of details related to the action status and (or) disposition and include relevant terms, conditions and dates (your response must fit
within the space provided).
MCX VIDE EMAIL DATED DECEMBER 26, 2025, HAS LEVIED A PENALTY OF RS. 6,34,900 ($7047) FOR THE ABNORMAL TRADES EXECUTED IN CRUDEOILM OPTION
CONTRACTS BY ONE OF THE CLIENT. MATTER CLOSED.
CIVIL JUDICIAL ACTION DISCLOSURE REPORTING PAGE (ADV)
GENERAL INSTRUCTIONS
This Disclosure Reporting Page (DRP ADV) is an INITIAL AMENDED response used to report details for affirmative responses to Item 11.H. of Part 1A or Item
OR
2.F. of Part 1B of Form ADV.
Civil Judicial
Check Part 1A item(s) being responded to:
11.H(1)(a) 11.H(1)(b) 11.H(1)(c) 11.H(2)
Check Part 1B item(s) being responded to:
2.F(1) 2.F(2) 2.F(3) 2.F(4) 2.F(5)
Use a separate DRP for each event or proceeding . The same event or proceeding may be reported for more than one person or entity using one DRP. File with a
completed Execution Page.
One event may result in more than one affirmative answer to Item 11.H. of Part 1A or Item 2.F. of Part 1B. Use only one DRP to report details related to the same
event. Unrelated civil judicial actions must be reported on separate DRPs.
PART I
A. The person(s) or entity(ies) for whom this DRP is being filed is (are):
You (the advisory firm)
You and one or more of your
advisory affiliates
One or more of your
advisory affiliates
If this DRP is being filed for an advisory affiliate, give the full name of the advisory affiliate below (for individuals, Last name, First name, Middle name).
If the advisory affiliate has a CRD number, provide that number. If not, indicate "non-registered" by checking the appropriate box.
ADV DRP - ADVISORY AFFILIATE
CRD 6040206
This advisory affiliate is a Firm an Individual
Number:
Registered:
Yes No
Name: KAMPANI, NIMESH, NAGINDAS
(For individuals, Last, First,
Middle)
This DRP should be removed from the ADV record because the advisory affiliate(s) is no longer associated with the adviser.
This DRP should be removed from the ADV record because: (1) the event or proceeding occurred more than ten years ago or (2) the adviser is registered or
applying for registration with the SEC or reporting as an exempt reporting adviser with the SEC and the event was resolved in the adviser's or advisory
affiliate's favor.
If you are registered or registering with a state securities authority , you may remove a DRP for an event you reported only in response to Item 11.H.(1)(a), and
only if that event occurred more than ten years ago. If you are registered or registering with the SEC, you may remove a DRP for any event listed in Item 11
that occurred more than ten years ago.
This DRP should be removed from the ADV record because it was filed in error, such as due to a clerical or data-entry mistake. Explain the circumstances:
B. If the advisory affiliate is registered through the IARD system or CRD system, has the advisory affiliate submitted a DRP (with Form ADV, BD or U-4) to the IARD or
CRD for the event? If the answer is "Yes," no other information on this DRP must be provided.
Yes No
NOTE: The completion of this form does not relieve the advisory affiliate of its obligation to update its IARD or CRD records.
PART II
1. Court Action initiated by: (Name of regulator, foreign financial regulatory authority, SRO, commodities exchange, agency, firm, private plaintiff, etc.)
PETITIONERS/PRIVATE PLAINTIFF HAVE FILED REVIEW PETITIONS IN THE HIGH COURT OF JUDICATURE OF ANDHRA PRADESH AT HYDERABAD, INDIA
2. Principal Relief Sought:
Other
Other Relief Sought:
THE RELIEF SOUGHT IN TWO OF THE REVIEW PETITIONS BY THE PETITIONERS/PRIVATE PLAINTIFFS, INTER ALIA, INCLUDES SETTING ASIDE OF THE ORDER DATED
MARCH 30, 2010 AND WINDING UP NAGARJUNA FINANCE LIMITED UNDER THE INDIAN COMPANIES ACT, 1956. ADDITIONALLY REFER TO DETAILS IN POINT 14 OF
PART II OF CIVIL JUDICIAL ACTION DISCLOSURE REPORTING PAGE (ADV)
3. Filing Date of Court Action (MM/DD/YYYY):
07/12/2010 Exact Explanation
If not exact, provide explanation:
THE REVIEW PETITIONS HAVE BEEN FILED BY THE PETITIONERS/ PRIVATE PLAINTIFFS ON DIFFERENT DATES IN JULY 2010 AND AUGUST 2010.
4. Principal Product Type:
Other
Other Product Types:
NAGARJUNA FINANCE LIMITED HAD ACCEPTED DEPOSITS (BORROWED FUNDS) FROM THE PUBLIC IN INDIA BY GIVING AN ADVERTISEMENT IN THE NEWSPAPERS AS
WAS/IS REQUIRED UNDER THE INDIAN COMPANIES ACT, 1956.
5. Formal Action was brought in (include name of Federal, State or Foreign Court, Location of Court - City or County and State or Country, Docket/Case Number):
THE HON'BLE HIGH COURT OF JUDICATURE OF ANDHRA PRADESH AT HYDERABAD, INDIA. - C. A. NO. 15 OF 2003, W. P. NO. 17814 OF 2004.
6. Advisory Affiliate Employing Firm when activity occurred which led to the civil judicial action (if applicable):
MR. NIMESH N KAMPANI, ONE OF THE ADVISORY AFFILIATES OF THE REPORTING ENTITY WAS ONE OF THE NON-EXECUTIVE DIRECTORS OF NAGARJUNA FINANCE
LTD. (NFL) FOR THE PERIOD DECEMBER 14, 1982. TO APRIL 28, 1999. NFL HAD SOME DEFAULTS IN REPAYMENT OF DEPOSITS AND PAYMENT OF INTEREST THEREON
AFTER MR. KAMPANI CEASED TO BE A NON-EXECUTIVE DIRECTOR OF NFL
7. Describe the allegations related to this civil action (your response must fit within the space provided):
PLEASE REFER TO DETAILS IN POINT 14 OF PART II OF CIVIL JUDICIAL ACTION DISCLOSURE REPORTING PAGE (ADV)
8. Current Status? Pending On Appeal Final
9. If on appeal, action appealed to (provide name of court) and Date Appeal Filed (MM/DD/YYYY):
THE HON'BLE HIGH COURT OF JUDICATURE OF ANDHRA PRADESH AT HYDERABAD, INDIA. VARIOUS DATES IN JULY 2010 AND AUGUST 2010.
10. If pending, date notice/process was served (MM/DD/YYYY):
Exact Explanation
If not exact, provide explanation:
NOT APPLICABLE
If Final or On Appeal, complete all items below. For Pending Actions, complete Item 14 only.
11. How was matter resolved:
Judgment Rendered
12. Resolution Date (MM/DD/YYYY):
03/30/2010 Exact Explanation
If not exact, provide explanation:
13. Resolution Detail:
A. Were any of the following Sanctions Ordered or Relief Granted(check appropriate items)?
Monetary/Fine Amount: $
Revocation/Expulsion/Denial Disgorgement/Restitution
Censure Cease and Desist/Injunction
Bar Suspension
B. Other Sanctions:
RELIEF GRANTED BY THE COURT. ALSO REFER TO DETAILS IN POINT 14 OF PART II OF CIVIL JUDICIAL ACTION DISCLOSURE REPORTING PAGE (ADV).
C. Sanction detail: if suspended, enjoined or barred, provide duration including start date and capacities affected (General Securities Principal, Financial
Operations Principal, etc.). If requalification by exam/retraining was a condition of the sanction, provide length of time given to requalify/retrain, type of
exam required and whether condition has been satisfied. If disposition resulted in a fine, penalty, restitution, disgorgement, or monetary compensation,
provide total amount, portion levied against you or an advisory affiliate, date paid and if any portion of penalty was waived:
RELIEF GRANTED BY THE COURT. ALSO REFER TO DETAILS IN POINT 14 OF PART II OF CIVIL JUDICIAL ACTION DISCLOSURE REPORTING PAGE (ADV).
14. Provide a brief summary of circumstances related to the action(s), allegation(s), disposition(s) and/or finding(s) disclosed above (your response must fit within
the space provided).
MR. NIMESH N KAMPANI, ONE OF THE ADVISORY AFFILIATES, WAS APPOINTED AS A NON-EXECUTIVE DIRECTOR, IN HIS PERSONAL CAPACITY, OF NAGARJUNA
FINANCE LTD. (NFL) A HYDERABAD BASED NONBANKING FINANCE COMPANY BELONGING TO THE NAGARJUNA GROUP ON DECEMBER 14, 1982. JM FINANCIAL GROUP
HAD NO RELATIONSHIP WITH NAGARJUNA GROUP EXCEPT BUSINESS ADVISORY ON SOME OCCASIONS. MR. KAMPANI CEASED TO BE A DIRECTOR OF NFL WITH
EFFECT FROM APRIL 28, 1999 UPON HIS RESIGNATION FROM NFL'S BOARD. NFL WAS ENGAGED IN HIRE PURCHASE AND VARIOUS OTHER FINANCIAL SERVICES
ACTIVITIES. NFL MOBILISED FIXED DEPOSITS FROM PUBLIC AS ONE OF THE MODES OF RAISING FUNDS FOR ITS BUSINESS ACTIVITIES. DURING MR. KAMPANI'S
TENURE AS A NONEXECUTIVE DIRECTOR, NFL AT ALL TIMES, HAD A FULL TIME MANAGING DIRECTOR WHO WAS RESPONSIBLE FOR THE MANAGEMENT OF THE
AFFAIRS OF NFL AND WHO ATTENDED TO ITS DAY-TO-DAY BUSINESS ACTIVITIES. SOMETIME IN THE YEAR 2000, NFL WAS UNABLE TO REPAY THE DEPOSITS
TOGETHER WITH INTEREST THEREON TO ITS VARIOUS DEPOSITORS. NFL WAS NOT IN DEFAULT OF REPAYMENT OF FIXED DEPOSITS AND/OR INTEREST THEREON
DURING THE TIME MR. KAMPANI REMAINED AS A NON-EXECUTIVE DIRECTOR OF NFL. IN THE ANNUAL REPORT FOR THE FINANCIAL YEAR 1998-99 PUBLISHED BY
NFL, IT WAS INTER ALIA MENTIONED THAT NFL HAS CONTINUED TO REPAY THE FIXED DEPOSITS DURING THE YEAR ENDED ON JUNE 30, 1999. NFL HAD MADE AN
APPLICATION TO THE COMPANY LAW BOARD (CLB) IN OCTOBER 1999 PROPOSING A SCHEME OF DEFERMENT OF PAYMENT OF DEPOSITS WHICH WAS HEARD AND
APPROVED IN FEBRUARY 2000. LATER DURING SEPTEMBER 2000, THE PROMOTERS OF NFL TRANSFERRED ALL THEIR EQUITY SHARES IN NFL IN FAVOUR OF M/S.
MAHALAXMI FACTORING SERVICES LTD. (MFSL), WHICH COMPANY THEN APPOINTED ITS NOMINEES TO THE BOARD OF NFL. THEREAFTER, THERE HAVE BEEN
REPORTED DEFAULTS OF AROUND RS. 100 CRORE (APPROXIMATELY USD 13.24 MILLION AS PER THE EXCHANGE RATE PREVAILING AS OF DATE) BY NFL TO ITS
DEPOSIT HOLDERS. NFL, AFTER IT WAS TAKEN OVER BY MFSL, FILED A COMPANY PETITION FOR RE-SCHEDULING THE REPAYMENT SCHEDULE IN 2003 ON THE
GROUNDS THAT THE PROMOTER AND THE ERSTWHILE DIRECTORS ARE RESPONSIBLE FOR PAYMENT. THE CLB DISMISSED THE SAID PETITION AND AGAINST SAID
ORDER AN APPEAL WAS FILED BY NFL IN THE YEAR 2003 IN THE HON'BLE HIGH COURT OF JUDICATURE AT ANDHRA PRADESH, HYDERABAD. THE APPEAL FILED BY
NFL IN 2003 WAS REFERRED TO THE DIVISION BENCH OF HON'BLE HIGH COURT OF JUDICATURE AT ANDHRA PRADESH, HYDERABAD. HEARING THE SAID APPEAL,
THE HON'BLE HIGH COURT PASSED AN ORDER DATED MARCH 30, 2010, INTER ALIA, STATING THAT THE PROMOTER AND THE ERSTWHILE DIRECTORS HAVE CEASED
THEIR INTERESTS FROM THE DATE ON WHICH THEY TRANSFERRED THEIR SHARES AND RESIGNED FROM THE POST OF DIRECTORS AND HENCE, THE PROMOTER AND
THE ERSTWHILE DIRECTORS ARE NOT LIABLE FOR THE AFFAIRS OF NFL AFTER THEIR RESIGNATION FROM THE BOARD OF DIRECTORS AND CONSEQUENTLY THEY
ARE PERSONALLY NOT LIABLE TO PAY THE AMOUNTS TO THE DEPOSITORS AND NFL BE WOUND UP AND LIQUIDATOR BE APPOINTED. TO THE BEST OF OUR
KNOWLEDGE AND BELEIF AND TO THE EXTENT OF INFORMATION AVAILABLE TO US, REVIEW PETITIONS HAVE BEEN FILED IN THE HON'BLE HIGH COURT OF
JUDICATURE AT ANDHRA PRADESH, HYDERABAD AGAINST THE ABOVE ORDER SEEKING, INTER ALIA, SETTING ASIDE OF THE ABOVE COURT ORDER DATED MARCH 30,
2010. TO THE BEST OF OUR KNOWLEDGE, THE REVIEW PETITIONS HAVE YET TO COME UP FOR HEARING IN THE HON'BLE HIGH COURT.
GENERAL INSTRUCTIONS
This Disclosure Reporting Page (DRP ADV) is an INITIAL AMENDED response used to report details for affirmative responses to Item 11.H. of Part 1A or Item
OR
2.F. of Part 1B of Form ADV.
Civil Judicial
Check Part 1A item(s) being responded to:
11.H(1)(a) 11.H(1)(b) 11.H(1)(c) 11.H(2)
Check Part 1B item(s) being responded to:
2.F(1) 2.F(2) 2.F(3) 2.F(4) 2.F(5)
Use a separate DRP for each event or proceeding . The same event or proceeding may be reported for more than one person or entity using one DRP. File with a
completed Execution Page.
One event may result in more than one affirmative answer to Item 11.H. of Part 1A or Item 2.F. of Part 1B. Use only one DRP to report details related to the same
event. Unrelated civil judicial actions must be reported on separate DRPs.
PART I
A. The person(s) or entity(ies) for whom this DRP is being filed is (are):
You (the advisory firm)
You and one or more of your
advisory affiliates
One or more of your
advisory affiliates
If this DRP is being filed for an advisory affiliate, give the full name of the advisory affiliate below (for individuals, Last name, First name, Middle name).
If the advisory affiliate has a CRD number, provide that number. If not, indicate "non-registered" by checking the appropriate box.
ADV DRP - ADVISORY AFFILIATE
CRD
This advisory affiliate is a Firm an Individual
Number:
Registered:
Yes No
Name: JM FINANCIAL SERVICES LIMITED
(JMFSL)
(For individuals, Last, First,
Middle)
This DRP should be removed from the ADV record because the advisory affiliate(s) is no longer associated with the adviser.
This DRP should be removed from the ADV record because: (1) the event or proceeding occurred more than ten years ago or (2) the adviser is registered or
applying for registration with the SEC or reporting as an exempt reporting adviser with the SEC and the event was resolved in the adviser's or advisory
affiliate's favor.
If you are registered or registering with a state securities authority , you may remove a DRP for an event you reported only in response to Item 11.H.(1)(a), and
only if that event occurred more than ten years ago. If you are registered or registering with the SEC, you may remove a DRP for any event listed in Item 11
that occurred more than ten years ago.
This DRP should be removed from the ADV record because it was filed in error, such as due to a clerical or data-entry mistake. Explain the circumstances:
B. If the advisory affiliate is registered through the IARD system or CRD system, has the advisory affiliate submitted a DRP (with Form ADV, BD or U-4) to the IARD or
CRD for the event? If the answer is "Yes," no other information on this DRP must be provided.
Yes No
NOTE: The completion of this form does not relieve the advisory affiliate of its obligation to update its IARD or CRD records.
PART II
1. Court Action initiated by: (Name of regulator, foreign financial regulatory authority, SRO, commodities exchange, agency, firm, private plaintiff, etc.)
NATIONAL STOCK EXCHANGE / COURT
2. Principal Relief Sought:
Other
Other Relief Sought:
ARBITRATION CLAIM
3. Filing Date of Court Action (MM/DD/YYYY):
08/18/2022 Exact Explanation
If not exact, provide explanation:
4. Principal Product Type:
No Product
Other Product Types:
5. Formal Action was brought in (include name of Federal, State or Foreign Court, Location of Court - City or County and State or Country, Docket/Case Number):
NATIONAL STOCK EXCHANGE, DELHI AND DISTRICT COURT, GURGAON
6. Advisory Affiliate Employing Firm when activity occurred which led to the civil judicial action (if applicable):
NOT APPLICABLE
7. Describe the allegations related to this civil action (your response must fit within the space provided):
THE CLIENT NITIN JOSHI FILED AN ARBITRATION CLAIM AGAINST THE COMPANY AT NATIONAL STOCK EXCHANGE OF INDIA LIMITED, DELHI CLAIMING AN AMOUNT
OF RS.1,47,065/-. THE ISSUE RELATED TO AUCTION SETTLEMENT OF 1300 SHARES OF UPL LIMITED ARISING OUT OF NON-FULFILMENT OF OBLIGATION UNDER THE
OPTION CONTRACT HAVING STRIKE PRICE OF 729/- OF EXPIRY DATED 24.02.2022
8. Current Status? Pending On Appeal Final
9. If on appeal, action appealed to (provide name of court) and Date Appeal Filed (MM/DD/YYYY):
10. If pending, date notice/process was served (MM/DD/YYYY):
Exact Explanation
If not exact, provide explanation:
NA
If Final or On Appeal, complete all items below. For Pending Actions, complete Item 14 only.
11. How was matter resolved:
Dismissed
12. Resolution Date (MM/DD/YYYY):
07/07/2025 Exact Explanation
If not exact, provide explanation:
13. Resolution Detail:
A. Were any of the following Sanctions Ordered or Relief Granted(check appropriate items)?
Monetary/Fine Amount: $
Revocation/Expulsion/Denial Disgorgement/Restitution
Censure Cease and Desist/Injunction
Bar Suspension
B. Other Sanctions:
THE APPEAL FILED BY THE COMPANY WAS DISMISSED BY THE DISTRICT COURT
C. Sanction detail: if suspended, enjoined or barred, provide duration including start date and capacities affected (General Securities Principal, Financial
Operations Principal, etc.). If requalification by exam/retraining was a condition of the sanction, provide length of time given to requalify/retrain, type of
exam required and whether condition has been satisfied. If disposition resulted in a fine, penalty, restitution, disgorgement, or monetary compensation,
provide total amount, portion levied against you or an advisory affiliate, date paid and if any portion of penalty was waived:
THE APPEAL FILED BY THE COMPANY WAS DISMISSED BY THE DISTRICT COURT
14. Provide a brief summary of circumstances related to the action(s), allegation(s), disposition(s) and/or finding(s) disclosed above (your response must fit within
the space provided).
THE ARBITRATION AWARD PASSED IN FAVOUR OF THE CLIENT FOR RS.1,47,065/-. AGGRIEVED BY THE AWARD, THE COMPANY FILED AN APPEAL AT NSE, DELHI,
WHICH WAS ALSO REJECTED. THE COMPANY CHALLENGED APPELLATE AWARD BEFORE THE HON'BLE DISTRICT COURT WHICH WAS DISMISSED VIDE ORDER DATED
07.07.2025.
GENERAL INSTRUCTIONS
This Disclosure Reporting Page (DRP ADV) is an INITIAL AMENDED response used to report details for affirmative responses to Item 11.H. of Part 1A or Item
OR
2.F. of Part 1B of Form ADV.
Civil Judicial
Check Part 1A item(s) being responded to:
11.H(1)(a) 11.H(1)(b) 11.H(1)(c) 11.H(2)
Check Part 1B item(s) being responded to:
2.F(1) 2.F(2) 2.F(3) 2.F(4) 2.F(5)
Use a separate DRP for each event or proceeding . The same event or proceeding may be reported for more than one person or entity using one DRP. File with a
completed Execution Page.
One event may result in more than one affirmative answer to Item 11.H. of Part 1A or Item 2.F. of Part 1B. Use only one DRP to report details related to the same
event. Unrelated civil judicial actions must be reported on separate DRPs.
PART I
A. The person(s) or entity(ies) for whom this DRP is being filed is (are):
You (the advisory firm)
You and one or more of your
advisory affiliates
One or more of your
advisory affiliates
If this DRP is being filed for an advisory affiliate, give the full name of the advisory affiliate below (for individuals, Last name, First name, Middle name).
If the advisory affiliate has a CRD number, provide that number. If not, indicate "non-registered" by checking the appropriate box.
ADV DRP - ADVISORY AFFILIATE
CRD
This advisory affiliate is a Firm an Individual
Number:
Registered:
Yes No
Name: JM FINANCIAL SERVICES LIMITED
(JMFSL)
(For individuals, Last, First,
Middle)
This DRP should be removed from the ADV record because the advisory affiliate(s) is no longer associated with the adviser.
This DRP should be removed from the ADV record because: (1) the event or proceeding occurred more than ten years ago or (2) the adviser is registered or
applying for registration with the SEC or reporting as an exempt reporting adviser with the SEC and the event was resolved in the adviser's or advisory
affiliate's favor.
If you are registered or registering with a state securities authority , you may remove a DRP for an event you reported only in response to Item 11.H.(1)(a), and
only if that event occurred more than ten years ago. If you are registered or registering with the SEC, you may remove a DRP for any event listed in Item 11
that occurred more than ten years ago.
This DRP should be removed from the ADV record because it was filed in error, such as due to a clerical or data-entry mistake. Explain the circumstances:
B. If the advisory affiliate is registered through the IARD system or CRD system, has the advisory affiliate submitted a DRP (with Form ADV, BD or U-4) to the IARD or
CRD for the event? If the answer is "Yes," no other information on this DRP must be provided.
Yes No
NOTE: The completion of this form does not relieve the advisory affiliate of its obligation to update its IARD or CRD records.
PART II
1. Court Action initiated by: (Name of regulator, foreign financial regulatory authority, SRO, commodities exchange, agency, firm, private plaintiff, etc.)
NATIONAL STOCK EXCHANGE/COURT
2. Principal Relief Sought:
Other
Other Relief Sought:
ARBITRATION CLAIM
3. Filing Date of Court Action (MM/DD/YYYY):
05/27/2016 Exact Explanation
If not exact, provide explanation:
THE CLIENT FILED AN ARBITRATION CLAIM AGAINST THE COMPANY
4. Principal Product Type:
No Product
Other Product Types:
5. Formal Action was brought in (include name of Federal, State or Foreign Court, Location of Court - City or County and State or Country, Docket/Case Number):
NATIONAL STOCK EXCHANGE OF INDIA LIMITED, DELHI & DISCTRICT COURT, DELHI
6. Advisory Affiliate Employing Firm when activity occurred which led to the civil judicial action (if applicable):
NOT APPLICABLE
7. Describe the allegations related to this civil action (your response must fit within the space provided):
THE CLIENT NAVEEN KUMAR DAHIYA FILED AN ARBITRATION CLAIM AGAINST THE COMPANY AT NATIONAL STOCK EXCHANGE OF INDIA LIMITED, DELHI CLAIMING AN
AMOUNT OF RS.12,39,000 ($14400) ON ACCOUNT OF UNAUTHORIZED TRADE/ SQUARING OFF HIS OPEN POSITIONS.
8. Current Status? Pending On Appeal Final
9. If on appeal, action appealed to (provide name of court) and Date Appeal Filed (MM/DD/YYYY):
10. If pending, date notice/process was served (MM/DD/YYYY):
Exact Explanation
If not exact, provide explanation:
If Final or On Appeal, complete all items below. For Pending Actions, complete Item 14 only.
11. How was matter resolved:
Dismissed
12. Resolution Date (MM/DD/YYYY):
07/21/2025 Exact Explanation
If not exact, provide explanation:
13. Resolution Detail:
A. Were any of the following Sanctions Ordered or Relief Granted(check appropriate items)?
Monetary/Fine Amount: $
Revocation/Expulsion/Denial Disgorgement/Restitution
Censure Cease and Desist/Injunction
Bar Suspension
B. Other Sanctions:
THE COMPANY'S APPEAL FILED IN DISTRICT COURT CHALLENGING THE AWARD WAS DISMISSED
C. Sanction detail: if suspended, enjoined or barred, provide duration including start date and capacities affected (General Securities Principal, Financial
Operations Principal, etc.). If requalification by exam/retraining was a condition of the sanction, provide length of time given to requalify/retrain, type of
exam required and whether condition has been satisfied. If disposition resulted in a fine, penalty, restitution, disgorgement, or monetary compensation,
provide total amount, portion levied against you or an advisory affiliate, date paid and if any portion of penalty was waived:
THE COMPANY'S APPEAL FILED IN DISTRICT COURT CHALLENGING THE AWARD WAS DISMISSED
14. Provide a brief summary of circumstances related to the action(s), allegation(s), disposition(s) and/or finding(s) disclosed above (your response must fit within
the space provided).
INITIALLY, THE ARBITRATION AWARD CAME IN FAVOUR OF THE JMFSL WHICH WAS CHALLENGED BY THE CLIENT IN APPEAL AT NSE, DELHI. THE APPELLATE
ARBITRAL PANEL SET ASIDE THE FIRST AWARD AND AWARDED AN AMOUNT RS. 12,39,000 ($14,400) IN FAVOUR OF THE CLIENT. THE COMPANY CHALLENGED
APPELLATE AWARD BEFORE THE HON'BLE DISTRICT COURT WHICH WAS DISMISSED.
Execution Pages
DOMESTIC INVESTMENT ADVISER EXECUTION PAGE
You must complete the following Execution Page to Form ADV. This execution page must be signed and attached to your initial submission of Form ADV to the SEC and
all amendments.
Appointment of Agent for Service of Process
By signing this Form ADV Execution Page, you, the undersigned adviser, irrevocably appoint the Secretary of State or other legally designated officer, of the state in
which you maintain your principal office and place of business and any other state in which you are submitting a notice filing, as your agents to receive service, and agree
that such persons may accept service on your behalf, of any notice, subpoena, summons, order instituting proceedings, demand for arbitration, or other process or
papers, and you further agree that such service may be made by registered or certified mail, in any federal or state action, administrative proceeding or arbitration
brought against you in any place subject to the jurisdiction of the United States, if the action, proceeding, or arbitration (a) arises out of any activity in connection with
your investment advisory business that is subject to the jurisdiction of the United States, and (b) is founded, directly or indirectly, upon the provisions of: (i) the
Securities Act of 1933, the Securities Exchange Act of 1934, the Trust Indenture Act of 1939, the Investment Company Act of 1940, or the Investment Advisers Act of
1940, or any rule or regulation under any of these acts, or (ii) the laws of the state in which you maintain your principal office and place of business or of any state in
which you are submitting a notice filing.
Signature
I, the undersigned, sign this Form ADV on behalf of, and with the authority of, the investment adviser. The investment adviser and I both certify, under penalty of
perjury under the laws of the United States of America, that the information and statements made in this ADV, including exhibits and any other information submitted,
are true and correct, and that I am signing this Form ADV Execution Page as a free and voluntary act.
I certify that the adviser's books and records will be preserved and available for inspection as required by law. Finally, I authorize any person having custody or
possession of these books and records to make them available to federal and state regulatory representatives.
Signature: Date: MM/DD/YYYY
Printed Name: Title:
Adviser CRD Number:
293667
NON-RESIDENT INVESTMENT ADVISER EXECUTION PAGE
You must complete the following Execution Page to Form ADV. This execution page must be signed and attached to your initial submission of Form ADV to the SEC and
all amendments.
1. Appointment of Agent for Service of Process
By signing this Form ADV Execution Page, you, the undersigned adviser, irrevocably appoint each of the Secretary of the SEC, and the Secretary of State or other
legally designated officer, of any other state in which you are submitting a notice filing, as your agents to receive service, and agree that such persons may accept
service on your behalf, of any notice, subpoena, summons, order instituting proceedings, demand for arbitration, or other process or papers, and you further agree that
such service may be made by registered or certified mail, in any federal or state action, administrative proceeding or arbitration brought against you in any place
subject to the jurisdiction of the United States, if the action, proceeding or arbitration (a) arises out of any activity in connection with your investment advisory business
that is subject to the jurisdiction of the United States, and (b) is founded, directly or indirectly, upon the provisions of: (i) the Securities Act of 1933, the Securities
Exchange Act of 1934, the Trust Indenture Act of 1939, the Investment Company Act of 1940, or the Investment Advisers Act of 1940, or any rule or regulation under
any of these acts, or (ii) the laws of any state in which you are submitting a notice filing.
2. Appointment and Consent: Effect on Partnerships
If you are organized as a partnership, this irrevocable power of attorney and consent to service of process will continue in effect if any partner withdraws from or is
admitted to the partnership, provided that the admission or withdrawal does not create a new partnership. If the partnership dissolves, this irrevocable power of
attorney and consent shall be in effect for any action brought against you or any of your former partners.
3. Non-Resident Investment Adviser Undertaking Regarding Books and Records
By signing this Form ADV, you also agree to provide, at your own expense, to the U.S. Securities and Exchange Commission at its principal office in Washington D.C., at
any Regional or District Office of the Commission, or at any one of its offices in the United States, as specified by the Commission, correct, current, and complete copies
of any or all records that you are required to maintain under Rule 204-2 under the Investment Advisers Act of 1940. This undertaking shall be binding upon you, your
heirs, successors and assigns, and any person subject to your written irrevocable consents or powers of attorney or any of your general partners and managing
agents.
Signature
I, the undersigned, sign this Form ADV on behalf of, and with the authority of, the non-resident investment adviser. The investment adviser and I both certify, under
penalty of perjury under the laws of the United States of America, that the information and statements made in this ADV, including exhibits and any other information
submitted, are true and correct, and that I am signing this Form ADV Execution Page as a free and voluntary act.
I certify that the adviser's books and records will be preserved and available for inspection as required by law. Finally, I authorize any person having custody or
possession of these books and records to make them available to federal and state regulatory representatives.
Signature: Date: MM/DD/YYYY
RAJKUMAR AGRAWAL 06/24/2026
Printed Name: Title:
RAJKUMAR AGRAWAL AUTHORISED SIGNATORY
Adviser CRD Number:
293667