Order in the matter of Wasankar Wealth Management Limited

WTM/MPB/EFD-1-DRA-IV/146 /2018 BEFORE THE SECURITIES AND EXCHANGE BOARD OF INDIA CORAM: MADHABI PURI BUCH, WHOLE TIME MEMBER FINAL ORDER Under Regulation 28 (2) of the Securities and Exchange Board of India (Intermediaries) Regulations, 2008 In the matter of Wasankar Wealth Management Limited In respect of: Sl.No Name of the Entity Registration No./ PAN INA000000219/ 1 Wasankar Wealth Management Limited AAACW8073C

2 Shri Prashant Jaidev Wasankar, Director AAIPW1864A 3 Ms Mithila Vinay Wasankar, Director ANFPM0123J 4 Shri Vinay Jaidev Wasankar, Director AALPW3215A Ms. Bhagyashree Prashant Wasankar, 5 Director AALPW3274H

6 Shri Abhijeet Jayant Chaudhari, Director AIUPC8611M

1. Wasankar Wealth Management Limited (“WWML”) is a public company incorporated on July 16, 2008 and an ‘Investment Adviser’ registered with Securities and Exchange Board of India ("SEBI"), having registration number INA000000219.

2. SEBI conducted an examination into the fund-raising activity of WWML and found that WWML had made an offer of Non-Convertible Preference Shares (“NCPS”) in the financial years 2009-2010, 2010-2011 and 2012-2013 and raised an amount of Rs.12.89 Crores from 228 allottees. The same was found to be in violation of provisions of the SEBI Act, 1992 (hereinafter referred to as “SEBI Act”) and the Companies Act, 1956. In view of this, SEBI

Order in the matter of Wasankar Wealth Management Limited passed an Order dated May 18, 2015 and issued the following directions against WWML and its promoters and directors viz., Shri Prashant Jaidev Wasankar, Ms. Mithila Vinay Wasankar, Shri Vinay Jaidev Wasankar, Ms. Bhagyashree Prashant Wasankar and Shri Abhijeet Jayant Chaudhari (hereinafter referred to as “the Noticees”):

a. “Wasankar Wealth Management Limited [PAN: AAAVW8073C] and its promoters/ directors including Mr. Prashant Jaidev Wasankar [PAN: AAIPW1864A], Ms. Mithila Vinay Wasankar [PAN: ANFPM0123J], Mr. Vinay Jaidev Wasankar [PAN: AALPW3215A], Mr. Bhagyashree Prashant Wasankar [PAN: AALPW3274H] and Mr. Abhijeet Jayant Chaudhari [PAN: AIUPC8611M] shall jointly and severally, forthwith refund the money collected by the Company through the issuance of Non- Convertible Preference Shares (which have been found to be issued in contravention of the public issue norms stipulated under the Companies Act, 1956), to the investors including the money collected from investors, till date, pending allotment of NCPS, if any, with an interest of 15% per annum compounded at half yearly intervals, from the date when the repayments became due (in terms of Section 73(2) of the Companies Act, 1956) to the investors till the date of actual payment. b. The repayments to investors shall be effected only in cash through Bank Demand Draft or Pay Order. c. The Company/ its present management is permitted to sell the assets of the Company only for the sole purpose of making the refunds as directed above and deposit the proceeds in an Escrow Account opened with a nationalised Bank. d. The Company shall issue public notice, in all editions of two National Dailies (one English and one Hindi) and in one local daily (in Marathi) with wide circulation, detailing the modalities for refund, including details on contact persons including names, addresses and contact details, within fifteen days of this Order coming into effect. e. After completing the aforesaid repayments, the Company shall file a certificate of such completion with SEBI from two independent peer reviewed Chartered

Order in the matter of Wasankar Wealth Management Limited

Accountants who are in the panel of any public authority or public institution. For the purpose of this Order, a peer reviewed Chartered Accountant shall mean a Chartered Accountant, who has been categorized so by the Institute of Chartered Accountants of India ('ICAI'). f. Wasankar Wealth Management Limited and its promoters and directors including Mr. Prashant Jaidev Wasankar, Ms. Mithila Vinay Wasankar, Mr. Vinay Jaidev Wasankar, Ms. Bhagyashree Prashant Wasankar and Mr. Abhijeet Jayant Chaudhari are also directed to provide a full inventory of all their assets and properties and details of all their bank accounts, demat accounts and holdings of shares/ securities, if held in physical form. g. Wasankar Wealth Management Limited is directed not to, directly or indirectly, access the capital market by issuing prospectus, offer document or advertisement soliciting money from the public and is further restrained and prohibited from buying, selling or otherwise dealing in the securities market, directly or indirectly in whatsoever manner, from the date of this Order till the expiry of four (4) years from the date of completion of refunds to investors, made to the satisfaction of SEBI, as directed above. The Company is restrained from accessing the securities market for the purposes of raising funds with immediate effect. h. The promoters and directors including Mr. Prashant Jaidev Wasankar, Ms. Mithila Vinay Wasankar, Mr. Vinay Jaidev Wasankar, Mr. Bhagyashree Prashant Wasankar and Mr. Abhijeet Jayant Chaudhari shall be restrained from accessing the securities market and further prohibited from buying, selling or otherwise dealing in securities market, directly or indirectly, with immediate effect. They are also restrained from associating themselves with any listed public company and any public company which intends to raise money from the public, or any intermediary registered with SEBI. These directions shall come into force with immediate effect and shall continue to be in force for a further period of four (4) years on completion of the refunds to the investors, as directed above. i. In case of failure of the Company/ its directors, to comply with the aforesaid

Order in the matter of Wasankar Wealth Management Limited directions, SEBI shall take appropriate action against them and other persons/ officers who are in default, including launching of prosecution proceedings, adjudication proceedings and recovery proceedings, in accordance with law.”

3. Pursuant to the aforesaid order, SEBI initiatiated proceedings against the Noticees in terms of the SEBI (Intermediaries) Regulations, 2008 (hereinafter referred to as 'the Intermediaries Regulations') in order to determine whether WWML continues to satisfy the criteria for ‘fit and proper person’ in the light of the aforesaid SEBI order. SEBI vide order dated June 11, 2015 appointed a Designated Authority (hereinafter referred to as 'DA') under Section 19 of the SEBI Act read with Regulation 24 of the Intermediaries Regulations to enquire into the alleged violations of Regulation 6(f) of SEBI (Investment Advisor) Regulations, 2013 (hereinafter referred to as ‘IA Regulations’) read with Regulation 7 (2)(e), Schedule II of the Intermediaries Regulations. On completion of the proceedings, the DA vide Report dated November 25, 2016 recommended cancellation of the certificate of registration granted to WWML. The DA has also recommended that the key management personnel of WWML viz., Shri Prashant Jaidev Wasankar, Ms. Mithila Vinay Wasankar, Shri Vinay Jaidev Wasankar, Ms. Bhagyashree Prashant Wasankar and Shri Abhijeet Jayant Chaudhari be debarred from being employed or associated with any registered intermediary or other registered person in the capital market forever.

4. Subsequently, SEBI issued a Show Cause Notice dated April 25, 2017 (“SCN”) under Regulation 28(1) of the Intermediaries Regulations, to the Noticees, asking them to show cause as to why the action recommended by the DA or higher penalty should not be imposed on them as deemed fit.

5. The Noticees were advised to reply to the SCN within twenty one (21) days from the receipt thereof. SEBI informed the Noticees that in case of failure to reply, it would be presumed that they had no explanation to offer and that the matter would be proceeded on the basis of the evidence available on record. The Noticees were further advised to indicate if they would

Order in the matter of Wasankar Wealth Management Limited like to avail an opportunity of personal hearing before SEBI. A copy of the Report of DA was also forwarded to the Noticees along with the said SCN.

6. Service of SCN: The SCN was sent to the Noticees through Speed Post with acknowledgment. The SCN sent to WWML was served through affixture. Since Shri Prashant Jaidev Wasankar, Shri Vinay Jaidev Wasankar, Ms. Bhagyashree Prashant Wasankar and Shri Abhijeet Jayant Chaudhari are in judicial custody, a copy of the SCN was also served to them through Jail Superintendent, Central Jail, Nagpur.

7. Replies: Ms. Mithila Vinay Wasankar vide e-mail dated May 19, 2017 sought an extension of time upto two weeks to file reply to the SCN since all the family members viz., Shri Prashant Jaidev Wasankar, Shri Vinay Jaidev Wasankar, Ms. Bhagyashree Prashant Wasankar and Shri Abhijeet Jayant Chaudhari are under judicial custody. No reply has been received from the remaining Noticees.

8. Vide hearing notice dated July 24, 2017 an opportunity of personal hearing was granted to the Noticees on September 13, 2017. The hearing notice sent to WWML through Speed post with acknowledgment returned undelivered. The same was served through affixture. The hearing notice sent to the remaining Noticees were delivered and acknowledgment received.

9. Pursuant to the hearing notice, vide letters dated August 9 and 11, 2017, Mr. Aagam J. Doshi, Advocate and authorized representative of Ms. Mithila Vinay Wasankar and Shri Vinay Jaidev Wasankar, sought an adjournment of the hearing and requested for inspection of the documents in the matter.

10. Hearing and submissions: WWML, Shri Prashant Jaidev Wasankar, Ms. Bhagyashree Prashant Wasankar and Shri Abhijeet Jayant Chaudhari did not avail the opportunity of hearing held on September 13, 2017 nor filed any reply to the SCN till date. Mr. Kunal

Order in the matter of Wasankar Wealth Management Limited

Kataria, Authorised Representative of Ms. Mithila Vinay Wasankar and Shri Vinay Jaidev Wasankar appeared before me and sought an adjournment of hearing and requested for inspection of documents so as to file detailed reply to the SCN. The inspection of documents was granted and another opportunity of hearing was granted to the said Noticees on December 21, 2017.

11. On December 21, 2017, Mr. Kunal Kataria from Aagam Doshi & Co. (“AR”) appeared for and on behalf of Ms. Mithila Vinay Wasankar and Shri Vinay Jaidev Wasankar and submitted the following: Submissions of Ms. Mithila Vinay Wasankar: i. WWML is controlled by Mr. Prasant Wasankar, brother in law of Ms. Mithila Vinay Wasankar. Mr. Prasant Jaidev Wasankar is holding 60% of the shares in WWML and 37% of the shares are with his wife Ms. Bhagyashree Wasankar; ii. Ms. Mithila Vinay Wasankar is a house wife. She is a non-executive director of WWML and the same is also reflected in the Form 32. She was never involved in any Board meeting or financial transactions of WWML or had any knowledge of the affairs of WWML. iii. Ms. Mithila Vinay Wasankar never issued any postdated cheques to any depositors or collected or had any dealing with depositors. In support of the said claim a copy of order in the bail application of Ms. Mithila Vinay Wasankar, wherein the Hon’ble Court has taken notice of the fact that Ms. Mithila Wasankar did not induce the depositors to invest and she has not tampered with the prosecution evidence in the matter and accordingly Ms. Mithila Wasankar was granted bail. Submissions of Mr. Vinay Wasankar: i. Mr. Vinay Jaidev Wasankar was a director of WWML till 2010. Mr. Vinay Jaidev Wasankar and Ms. Mithila Vinay Wasankar are jointly holding approximately 2% of the shares in WWML.

Order in the matter of Wasankar Wealth Management Limited ii. Mr. Vinay Jaidev Wasankar had no control over the affairs of WWML. It is further submitted that for any acts and omissions or violations committed by WWML after his resignation cannot be attributed to him. The AR was granted time till January 21, 2018 to submit a written submissions/ reply to the SCN, if any, in the matter. It is noted that AR has not filed any written submissions/reply till date.

12. I have considered the SCN, the Report submitted by DA, oral submissions made by AR for Ms. Mithila Vinay Wasankar and Shri Vinay Jaidev Wasankar and all other relevant material available on record. On perusal of the same, the following issue arise for consideration:  Whether the Noticees satisfy the criteria for ‘fit and proper persons’ in terms of Regulation 6(f) of the IA Regulations read with Regulation 7(2) e, Schedule II of Intermediaries Regulations?

13. Before dealing with the issue, the relevant legal provisions, the contravention of which have been alleged in the instant case are reproduced hereunder: “Regulation 6 (f) of IA Regulations: For the purpose of the grant of certificate the Board shall take into account all matters which are relevant to the grant of certificate of registration and in particular the following, namely,- …. (f) whether the applicant, its representatives and partners, if any, are fit and proper persons based on the criteria as specified in Schedule II of the Securities and Exchange Board of India (Intermediaries) Regulations, 2008; … Regulation 7 (2) of IA Regulations: Any application for grant of certificate:- … (e) where the applicant is not a “fit and proper person” as stated in Schedule II;

Order in the matter of Wasankar Wealth Management Limited

…. shall be rejected by the Board for reasons to be recorded by the Board in writing. Schedule II- Intermediaries Regulations: Criteria for determining a “fit and proper person” For the purpose of determining as to whether an applicant or the intermediary is a “fit and proper person” the Board may take account of any consideration as it deems fit, including but not limited to the following criteria in relation to the applicant or the intermediary, the principal officer, the director, the promoter and the key management persons by whatever name called – (a) integrity, reputation and character; (b) absence of convictions and restraint orders; (c) competence including financial solvency and networth (d) absence of categorization as a wilful defaulter.”

Issue : whether the Noticees satisfy the criteria for ‘fit and proper persons’ in terms of Regulation 6(f) of the IA Regulations read with Regulation 7(2)e, Schedule II of Intermediaries Regulations? 14. I note that WWML is a SEBI registered Investment Advisor with effect from October 25, 2013.

15. I also note that SEBI has passed an Order dated May 18, 2015 wherein SEBI found that WWML had made an offer of NCPS in financial years 2009-2010, 2010-2011 and 2012- 2013 and raised an amount of Rs.12.89 Crores from 228 allottees; The said allotment of NCPS was a ‘public issue’ under the first proviso to Section 67(3) of the Companies Act, 1956; Accordingly, WWML was required to comply with the requirement of listing such securities in a stock exchange in terms of Section 73 of the Companies Act, 1956. WWML neither made any application for listing of NCPS nor refunded the amounts to its investors forthwith. In view of the same, SEBI inter alia directed the Noticees herein to refund the money collected to the investors and also prohibited the Noticees from buying, selling or Order in the matter of Wasankar Wealth Management Limited otherwise dealing in the securities market, directly or indirectly in whatsoever manner, from the date of the said order till the expiry of 4 years from the date of completion of refunds to investors. It is noted that the Noticees have not filed any appeal against the said order till date.

16. I also note from the Report of DA and also from the oral submissions made by AR for Ms. Mithila Vinay Wasankar, Shri Vinay Jaidev Wasankar that the directors of WWML were arrested for the offences under Sections 420, 406, 409, 120B read with Section 34 of IPC along with Section 3 of Maharashtra (Protection of Interest of Depositors) Act, 1999. Further, Ms. Mithila Vinay Wasankar got released on bail and remaining directors viz., Shri Prashant Jaidev Wasankar, Shri Vinay Jaidev Wasankar, Ms. Bhagyashree Prashant Wasankar and Shri Abhijeet Jayant Chaudhari are presently in judicial custody.

17. In addition, I note that despite order of SEBI to refund the money collected from the investors, the Noticees have failed to make any refund to its investors and SEBI has initiated Recovery Proceedings in the matter.

18. I note that the intermediaries registered with SEBI have to fulfill the criteria of 'fit and proper person' at the time of registration and the same criteria should continuously be satisfied throughout the period of the validity of their registration/ the period they are associated with the securities market. As per Regulation 6 of the IA Regulations, 2013 to continue as a registered intermediary, an entity and its principal officer, the director, the promoter and the key management persons by whatever name called are required to fulfil the criteria of ‘fit and proper’ person as provided in Schedule II of the Intermediaries Regulations. I note that the requirement that the fit and proper criteria laid down for an intermediary is continuous as long as it is a registered intermediary, has been upheld in various judgments.

19. In this regard, the following observations of Hon’ble Securities Appellate Tribunal in the matter of Jermyn Capital LLC Vs. SEBI (Appeal No. 21/2006) is noteworthy: “The Regulations apply across to all sets of regulations and all intermediaries of the Order in the matter of Wasankar Wealth Management Limited securities market including those who associate themselves with the market and they all have to satisfy the criteria of “fit and proper person” before they could be registered under any of the relevant regulations and this criteria they must continue to satisfy throughout the period of validity of their registration and throughout the period they associate with the market. The purpose of the Regulations is to achieve the aforesaid objects and make the securities market a safe place to invest. One bad element can, not only pollute the market but can play havoc with it which could be detrimental to the interests of the innocent investors. In this background, the Board may, in a given case, be justified in keeping a doubtful character or an undesirable element out from the market rather than running the risk of allowing the market to be polluted.”

20. I also note that Regulation 23 of the Intermediaries Regulations, provides that if a person who is granted a certificate of registration breaches the conditions of registration or the securities laws, action in the manner provided under the Intermediaries Regulations shall be taken: "Cancellation or suspension of registration and other actions. Where any person who has been granted a certificate of registration under the Act or regulations made thereunder, – (a) fails to comply with any conditions subject to which a certificate of registration has been granted to him; (b) contravenes any of the provisions of the securities laws or directions, instructions or circulars issued thereunder; the Board may, without prejudice to any action under the securities laws or directions, instructions or circulars issued thereunder, by order take such action in the manner provided under these regulations".

21. I also note that in terms of Intermediaries Regulations, criteria for ‘fit and proper persons’ is also applicable to the Key Management Personnel and Principal Officers of the registered intermediary. From the Report of DA, I note that the Noticees viz., Shri Prashant Jaidev

Order in the matter of Wasankar Wealth Management Limited

Wasankar, Ms. Mithila Vinay Wasankar, Shri Vinay Jaidev Wasankar, Ms. Bhagyashree Prashant Wasankar and Shri Abhijeet Jayant Chaudhari are mentioned as Directors of WWML and therefore considered as key management personnel of WWML. I also note that none of the Noticees filed any reply to the SCN till date. However, I note that AR for Ms. Mithila Vinay Wasankar and Shri Vinay Jaidev Wasankar appeared for the personal hearing and submitted that Shri Vinay Jaidev Wasankar has resigned from the directorship of WWML on July 01, 2010 and contended that he is not liable for any violation committed after his resignation. Further, Ms. Mithila Vinay Wasankar contented that she is a non-executive director of the Company and was not involved in the financial matters or day to day affairs of the Company. The AR has submitted that the major shareholding of WWML is with Shri Prashant Jaidev Wasankar together with his wife Ms. Bhagyashree Prashant Wasankar is holding 97% of the shares in WWML and Ms. Mithila Vinay Wasankar, Shri Vinay Jaidev Wasankar are only holding 2 % of the shares in WWML hence, they have no control over the affairs of WWML. In the present matter, the following are pertinent to be noted:- i. There is a restraint order of SEBI against WWML, a registered intermediary and its directors viz., Shri Prashant Jaidev Wasankar, Ms. Mithila Vinay Wasankar, Shri Vinay Jaidev Wasankar, Ms. Bhagyashree Prashant Wasankar and Shri Abhijeet Jayant Chaudhari. ii. I also note that despite Order to refund the investors, the Noticees have failed to take effective steps to refund the investors till date. iii. As per the Intermediaries Regulations, in order to continue as registered intermediary, Board has to take account of any consideration as it deems fit, including but not limited to the criteria laid down in Schedule II of the Intermediaries Regulations in relation to the applicant or the intermediary, the principal officer, the director, the promoter and the key management persons. iv. Though Ms. Mithila Vinay Wasankar contended that she is a non-executive director of the company and was not involved in the day to day affairs of the company, I find that being a director of the Company she must continue to satisfy the fit and proper

Order in the matter of Wasankar Wealth Management Limited criteria throughout the period of validity of the registration of WWML as an intermediary and throughout the period she associates with the securities market. Though Ms. Mithila Vinay Wasankar contended that she was a non-executive director and was not involved in the day to day affairs of the Company, I note that by virtue of her directorship in the company as an officer in default she was made liable to make refund to the investors and she was also debarred from the securities market. Being a director of the WWML, I find that she is responsible and liable for acts/omissions committed by WWML. Further, the Intermediaries Regulations providing for the criteria for fit and proper persons does not distinguish between different categories of directors. In view of the same, I am not inclined to accept the contentions of Ms. Mithila Vinay Wasankar. On account of the restraint orders and failure to comply with SEBI’s order regarding refund to investors etc., I find that Ms. Mithila Vinay Wasankar does not qualify to be a ‘fit and proper person’ in terms of the criteria laid down in the Intermediaries Regulations. v. In respect to the contention of resignation of Shri Vinay Jaidev Wasankar, I note that as per MCA records, Shri Vinay Jaidev Wasankar resigned from WWML on July 01, 2010. Though he has resigned from the directorship of the Company, I note that Shri Vinay Jaidev Wasankar is still continuing to be a shareholder of the Company and at present under judicial custody for the offences mentioned above.

Further, I also note that the he was in the Board of Directors during the period of first issuance of NCPS i.e. during the FY 2009-2010. In view of the same I am not inclined to accept the contention of the Noticee. vi. The fact that Ms. Bhagyashree Prashant Wasankar and Shri Vinay Jaidev Wasankar resigned from WWML does not take away the status of intermediary being unfit because, the intermediary itself has suffered the criteria of being unfit (on account of restraint order). Further, there are directors who satisfy the unfit criteria (since restraint orders are passed against them) who continue to be directors in the intermediary. Further, the fact that Ms. Bhagyashree Prashant Wasankar owns 37% in WWML leads to the fact that she has substantial control. Therefore, in view of the Order in the matter of Wasankar Wealth Management Limited

Hon’ble Securities Appellate Tribunal (SAT) Order dated July 28, 2017 in the matter of Sahara Asset Management Company Limited (Appeal No. 428/2015), it can be considered that the restraint order against her will also be a factor for determination of the fit and proper criteria of the intermediary. The observations of the Hon’ble SAT in this regard is as under: “The argument that only the Applicant Company as a sponsor is to be fit and proper and the requirement that the Promoter / Director need not be fit and proper cannot be accepted. Regulation 7A of the Mutual Fund Regulations, 1996 read with Schedule-II of the SEBI (Intermediaries) Regulations, 2008 specify that the fit and proper criteria applies to the Principal Officer and the key managerial persons of the sponsor by whatever name called and should possess integrity, reputation and character; absence of any convictions and restraint orders and competence including solvency and net worth.”

vii. Further, the Report of DA takes into account the arrest of Shri Prashant Jaidev Wasankar, Shri Vinay Jaidev Wasankar, Ms. Bhagyashree Prashant Wasankar and Shri Abhijeet Jayant Chaudhari as additional ground to hold that the intermediary is unfit. In this regard, I rely upon the observations of Hon’ble SAT in the matter of Jermyn Capital LLC Vs. SEBI (Appeal No. 21/2006), where the arrest of the Director was considered as relevant to determine the status of fitness of the intermediary. viii. In view of the foregoing, I agree with the observations made by the DA that the persons who do not satisfy the 'fit and proper person' criteria as per IA Regulations read with Intermediary Regulations cannot be permitted to continue to act as intermediary or associate themselves with any registered intermediary in the securities market.

22. The various provisions under the SEBI Act, Regulations, Circulars etc. in respect of an intermediary registered with SEBI are enumerated for the purpose of protection of interests of investors. IA Regulations, inter alia provide the framework for regulating the activity of Order in the matter of Wasankar Wealth Management Limited entities who are in the business of providing investment advice in respect of securities and investment products. These Regulations seek to create a standardized operating structure within which these entities will operate and also make them duly accountable for their activities by requiring them to comply with the criteria, set out in the relevant provisions of the aforesaid Regulations. Significant responsibilities are entrusted upon the investment advisers registered with SEBI, such as to maintain high standards of integrity, diligence, honesty, and fairness, not to indulge in any act detrimental to the interests of investors, etc. SEBI has been entrusted with the important mandate of protecting the investors and safeguarding the integrity of the securities market. In this regard, necessary powers have been conferred upon it under the securities laws. It is, therefore, necessary that SEBI exercises these powers firmly and effectively to insulate the market and its investors from the fraudulent actions of any of the participants in the securities markets. In view of the gravity of the violations perpetrated by the Noticees and its consequent restraints on them as brought out in the foregoing paragraphs, I am of the opinion that they do not qualify to be ‘fit and proper persons’ in terms of Regulation 6(f) of the IA Regulations read with Regulation 7(2)(e), Schedule II of the Intermediaries Regulations, 2008.

23. Accordingly, I am inclined to agree with the recommendation of the DA that the certificate of registration of WWML be cancelled and the directors of WWML viz., Shri Prashant Jaidev Wasankar, Ms. Mithila Vinay Wasankar, Shri Vinay Jaidev Wasankar, Ms. Bhagyashree Prashant Wasankar and Shri Abhijeet Jayant Chaudhari, be debarred from being employed or associated with any registered intermediary or other registered person in the capital market.

24. In view of the above, I in exercise of the powers conferred upon me in terms of Section 19 of the Securities and Exchange Board of India Act, 1992 read with Regulation 28(2) of Securities and Exchange Board of India (Intermediaries) Regulations, 2008, hereby issue the following directions;

i. The Certificate of Registration granted to Wasankar Wealth Management Limited

Order in the matter of Wasankar Wealth Management Limited as an Investment Advisor shall be cancelled forthwith; ii. The directors of WWML viz., Shri Prashant Jaidev Wasankar, Ms. Mithila Vinay Wasankar, Shri Vinay Jaidev Wasankar, Ms. Bhagyashree Prashant Wasankar and Shri Abhijeet Jayant Chaudhari shall be debarred from being employed or associated with any registered intermediary or other registered person in the capital market for a period of 14 (fourteen) years from the date of completion of refund as directed in SEBI Order dated May 18, 2015.

25. The above directions shall come into force with immediate effect. 26. The SCN issued against the Noticees is accordingly disposed of.

DATE: March 01, 2018 MADHABI PURI BUCH PLACE: Mumbai WHOLE TIME MEMBER SECURITIES AND EXCHANGE BOARD OF INDIA

Order in the matter of Wasankar Wealth Management Limited