Treatment of Inactive Trading account
On December 1, 2020, the NSE issued a circular (NSE/INSP/46506) regarding the treatment of inactive trading accounts. This was with reference to an earlier NSE circular (NSE/INSP/43488) dated February 10, 2020. Based on the representations received from members and after consulting other stock exchanges, the NSE issued the following clarification in its latest circular.
● If no trades have been carried out by a client in the last 12 months on any exchange, then the requirement for flagging that client as inactive in the UCC database of the exchanges and the exemption from reporting the weekly submission of securities holding and the monthly upload of client funds and securities balances shall continue.
● If a client approaches the member for reactivation 1 year after being flagged as inactive, then members will need to undertake fresh documentation, due diligence and IPV processes. But if such a client had undertaken any transaction with the member during that period, with regard to subscription for IPOs or mutual funds or DP operations, then that would be considered and the requirement for fresh documentation, due diligence and IPV processes may not be needed.
Also, in the following circumstances, the requirement for undertaking an IPV will not be required.
● If the KYC of the investor is completed using the Aadhaar authentication/verification of UIDAI
● If the KYC form has been submitted online and the documents have been provided through Digi locker or any other source which could be verified online
If a client approaches the member for reactivation within a period of 1 year after being flagged as inactive, then in that case, the member must ensure that while reactivating such a client, the basic details of the client, like their address, mobile number, email ID, bank/DP account are updated in its records as well in the UCC records of the exchange. If there are any changes in these basic details, then the member must collect the documents necessary.
The circular also stated that members were required to ensure that appropriate due diligence was undertaken on an ongoing basis in compliance with PLMA guidelines, which are issued from time to time, and in accordance with their respective KYC policies.