The SRO for RIAs is here – All about how to obtain your BASL membership

For the last one year, an SRO (or Self-Regulatory Organisation) for SEBI RIAs has been under discussion.

Finally, the SRO has seen the light of the day. BSE Administration & Supervision Limited (BASL), a subsidiary of BSE Limited (BSE) has become the first registered SRO or Investment Adviser Administration and Supervisory Body (IAASB) with SEBI.

BASL, as an SRO / IAASB, will play the role to administer and supervise registered as well as unregistered investment advisers.

BASL members have to do periodic reporting and submission of documents as required by BASL from time to time.

All existing RIAs are mandatorily required to apply for membership of BASL before October 31, 2021.

Further, all new applicants  are also required to obtain membership of BASL before applying for registration with SEBI as IA.

The applicants whose applications are pending with SEBI also have to make an application to BASL before getting final approval from SEBI.

The application process differs for those who were registered before May 31, 2021 and those after.

BASL has developed an online portal facility for registration of BASL membership. Click here to download the BASL User Manual as available on BASL website.

Process for obtaining membership of BASL for existing RIAs who have renewed their registration before March 31, 2021:

1. Visit BASL membership portal
2. Register yourself to make an account on the BASL portal. The Applicant (in case of non-individuals) can be the person who is authorised to submit the application to BASL.
3. Fill the membership application and attach the relevant documents. All documents need to be self-attested. Click here to download the list of documents to be submitted to BASL.
4. Based on the membership application and fulfilment of BASL specified norms for membership as an Investment adviser, BASL will issue a certificate of membership.
5. No payment of fee to be made unless specified otherwise by BASL / SEBI to pay membership fees.
6. The tenure of BASL membership of BASL will be as decided by BASL and need to be renewed by the investment adviser as per norms specified from time to time.

Process for obtaining membership of BASL for new application as RIA:

1. Visit BASL membership portal
2. Register yourself to make an account on the BASL portal. The Applicant (in case of non-individuals) can be the person who is authorised to submit the application to BASL.
3. Fill the membership application and attach the relevant documents. All documents need to be self-attested. Click here to download the list of documents to be submitted to BASL.
4. You will receive an email from BASL to proceed for filing the application to SEBI.
5. Submit SEBI application for registration as RIA along with all the relevant documents and information on the SEBI intermediary portal. Click here to know the step-by-step SEBI application process.
6. Once SEBI application is approved, SEBI will inform the new applicant to pay the fee to BASL.
7. On payment of fee to BASL, SEBI will issue its certificate of registration.
8. Post communication from SEBI and based on the membership application and fulfilment of BASL specified norms for membership as an Investment adviser, BASL will issue a certificate of membership.

Process for obtaining membership of BASL for existing RIAs whose registration is due for renewal after April 1, 2021:

The existing SEBI registration certificate of existing RIAs will continue to be valid till its maturity date.

The process for renewal is the same as the process for new applicants. However, from the plain reading of the BASL SOP, it looks like the existing RIAs have to go through the entire application process at SEBI for renewal too.

BASL renewal membership process

The process for submission of renewal application to BASL should be carried out at least 3 months before the expiry of the validity period of the certificate of BASL membership and completed prior to expiry of the tenure failing which the membership certificate will become invalid. In my view, the process for renewal of BASL membership will be annual.

Fees to be paid to BASL

In January 2021, SEBI announced reduction in fees for RIAs. The new amendment is applicable from April 1, 2021. So now, all existing RIAs as well as new applicants have to pay registration fee to SEBI as well as pay membership fee to BASL. In short, the reduced fee is shifted to BASL membership fee.

Here are the details of BASL membership fee:

BASL members have to make their relevant payment of fees vide NEFT to below mentioned bank account details of BASL :

BASL Bank Account with : ICICI Bank Ltd.
Bank Account No. : 000405540374
Bank Branch address : 215, Free press house, Free Press Marg, Nariman Point, Mumbai 400021.
Bank IFSC Code : ICIC0000004

BASL members after making payment of fees also need to forward details of the payment  done by them vide mail addressed to bseasl.membership@bseasl.com, clearly mentioning the subject of the mail as “BASL Membership Fees Payment details – (Trade Name of BASL member – BASL Membership ID).

The details to be mentioned in the email are as follows:

One important point to be noted here is that the partnership firms are not considered a non-individual for BASL membership and have to pay the same fee as individuals.

What if there are any changes in the information about RIAs?

For any change in name / change in partners or directors / change in registered office address or correspondence address / shareholding pattern / prior approval for change in control / surrender of registration certificate / loss of certificate / mutilation of certificate / update detail, etc the concerned SEBI RIA will in such cases first approach SEBI and not BASL.

It will be the responsibility of SEBI to update BASL for any change in the information about RIAs. BASL will not recognize any change in status or constitution of the member or change in partners or directors of the Member unless the same is approved by SEBI.

—

To conclude, the role of BASL will be only to administer and supervise registered as well as unregistered investment advisers. RIAs have to maintain their existing certificate of registration with SEBI as well as comply with the Bye Laws of BASL and directions / circulars / notices / regulations / guidelines, etc. issued by BASL / SEBI from time to time.

If you are looking for help in making an application to BASL or SEBI, you can write to me at kruti@cskruti.com