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nism-series-xv-mandatory-disclosures-regulation-19[ RESEARCH ANALYST ]
Under Regulation 19 of SEBI (Research Analysts) Regulations, 2014, which of the following disclosures is MANDATORY in every research report and public appearance?
[ A ]The private residential home addresses and personal passport numbers of all independent directors.
[ B ]Whether the analyst/entity has financial interest in the subject company, whether the analyst/entity/relatives hold 1% or more equity ownership at the end of the preceding month, and whether compensation was received from the subject company in the past 12 months.[ CORRECT ]
[ C ]A confidential list of the personal bank account balances of the research analyst's neighbors.
[ D ]The detailed dietary meal preferences of the company's factory manufacturing employees.
Takeaway
Option B is correct: Whether the analyst/entity has financial interest in the subject company, whether the analyst/entity/relatives hold 1% or more equity ownership at the end of the preceding month, and whether compensation was received from the subject company in the past 12 months.
Derivation
Regulation 19 mandates comprehensive conflict disclosures in all research reports and public appearances: (1) Ownership and Conflicts: Details of any financial interest held by the analyst, entity, associates, or relatives; explicit disclosure if actual/beneficial equity ownership equals or exceeds 1% of the subject company's share capital at the end of the month preceding publication. (2) Compensation History: Whether the analyst/entity/associates received any compensation for investment banking, merchant banking, brokerage, or other services from the subject company in the past 12 months; whether they managed public offers, or acted as officers/directors. This tests Regulation 19 disclosures. The common error is assuming disclosures are required only if ownership exceeds 5%.
Why the others fail
A — The private residential home addresses and personal passport numbers of all independent directors.
Private residential addresses and passport numbers are protected personal data and are never disclosed in public research reports.
C — A confidential list of the personal bank account balances of the research analyst's neighbors.
Personal financial data of unrelated third parties is completely irrelevant to corporate securities conflict disclosures.
D — The detailed dietary meal preferences of the company's factory manufacturing employees.
Employee dietary preferences are irrelevant operational trivia with zero connection to financial research conflicts of interest.
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