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BRICK EAGLE CAPITAL ADVISORY LLP
(PAN:AALFB8806C)
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KIRTI MALLANAGOUDA TIMMANAGOUDAR
PAN:ACHPT5483B
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PARVINDER SINGH PASRICHA
PAN:AAFPP7525G
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RAJESH RAMAN KRISHNAN
PAN:BRQPK9968P
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RUBI ARYA
PAN:AAVPA0654P
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DID NOT HAVE CONTINUING INTEREST IN BRICK EAGLE TRUST
DID NOT ACHIEVE SECOND CLOSING AND FINAL CLOSING IN TERMS PRIVATE PLACEMENT MEMORANDUM (PPM)
DID NOT OBTAIN APPROVAL FROM INVESTORS BEFORE MAKING INVESTMENTS IN ASSOCIATE COMPANIES OF ITS SPONSOR
INVESTED UN-INVESTED PORTION OF INVESTIBLE FUNDS IN LOW DURATION FUNDS INSTEAD OF LIQUID FUNDS
DID NOT INTIMATE CHANGES IN DESIGNATED PARTNERS OF THE SPONSOR/MANAGER TO SEBI
DID NOT DISCLOSE INFORMATION SUCH AS FINANCIAL, RISK MANAGEMENT, OPERATIONAL, PORTFOLIO AND TRANSACTIONAL INFORMATION REGARDING INVESTMENTS TO ITS INVESTORS
DID NOT DISCLOSE INFORMATION SUCH AS FINANCIAL INFORMATION OF ITS INVESTEE COMPANIES, MANAGEMENT OF MATERIAL RISKS TO ITS INVESTORS
DID NOT MAINTAIN DATED AND SIGNED RATIONALE FOR THE INVESTMENTS MADE AND ALSO FAILED TO MAINTAIN HIGH STANDARDS OF INTEGRITY AND FAIRNESS IN ALL THEIR DEALINGS
DID NOT MAINTAIN HIGH STANDARDS OF INTEGRITY AND FAIRNESS IN ALL THEIR DEALINGS AND IN THE CONDUCT OF BUSINESS AND DID NOT RENDER HIGH STANDARD OF SERVICE AND EXERCISE DUE DILIGENCE
DID NOT UNDERTAKE VALUATION OF INVESTMENTS FOR PERIOD FROM 21/12/2018 AND 25/08/2020
DID NOT UPLOAD KYC INFORMATION OF ITS CLIENTS IN THE KRA AND DID NOT CARRY OUT IN-PERSON VERIFICATION OF CLIENTS
DID NOT MAINTAIN ANTI MONEY LAUNDERING POLICY AND DID NOT APPOINT PRINCIPAL OFFICER AND DESIGNATED DIRECTOR
DID NOT SUBMIT COMPLIANCE TEST REPORT TO TRUSTEE WITHIN THIRTY DAYS FROM THE END OF F.Y. 2019-20
DID NOT CARRY OUT ANNUAL AUDIT OF COMPLIANCE FOR F.Y. 2020-21
DID NOT ACT IN BEST INTEREST OF ALL INVESTORS FOR CONDUCT OF BUSINESS AND PROVIDING PREFERENTIAL TREATMENT TO CERTAIN INVESTORS BY FAILING TO DRAWDOWN REQUISITE AMOUNTS IN LINE WITH CONTRIBUTION AGREEMENTS FROM TWO INVESTORS
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DIRECTED NOT TO TAKE NEW ASSIGNMENTS AS INVESTMENT MANAGER FROM 28-FEB-2024 TO 27-FEB-2025
PROHIBITED FROM ISSUING PROSPECTUS OR ANY OFFER DOCUMENT, OR ISSUE ADVERTISEMENT FOR SOLICITING MONEY FROM PUBLIC FOR ISSUE OF SECURITIES IN ANY MANNER EITHER DIRECTLY OR INDIRECTLY FROM 28-FEB-2024 TO 27-FEB-2025
28-FEB-2024
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