RMS Policy ANSPL

RMS Functions:

• To check capital adequacy for exposure and requirements of the client.
• Monitoring of Clients' Orders, Patterns of Trade, Order rejections, increasing of Exposure/Limits.
• Monitoring MTM profit/loss incurred out of trades.
• Benchmarking Margin vs. Exposure of client.
• Decision taking with regard to squaring off positions on account of MTM loss or Margin shortfalls or any other reasons that may come across.
• Risk management in relation to all the trading activities for Clients is handled by RMS & Surveillance Dept.

Pay-in and Pay-out:

1. Funds and/or securities pay-in to be done on T+1 basis. If funds pay-in are not received by the close of the next working day, a penalty (max 18% p.a.) is levied for the actual delay period.
2. Pay-in of funds and securities must be complete by the close of the next trading day. If securities are not delivered by 10:30 AM (T+1), the transaction goes to auction and the customer bears the auction loss.
3. Local clients can deposit cheques at our corporate office or transfer electronically and email pay-in details to chqrcv@anspl.net. We credit the ledger once we receive the email. If the cheque bounces within two days, we reverse the ledger credit and levy a penalty to the client (plus any bank charges).
4. Payouts are transferred via NEFT/RTGS. Clients on a running account can request payouts anytime (open bills excluded); we release the clear credit balance once requested.

Exposure:

• Margin-based limit is set on a combined basis for all exchange segments.
• Clear credit in the client’s settlement and margin ledger account.
• Margin pledged by client via CDSL’s OTP authentication system.
• Any online funds transfer received in our bank account.
• Credit received in our client bank account against sale of securities.
• Margin amount of open positions (in case of derivatives).
• All cheque-dishonor cases are handled strictly; debit amounts are cleared by RMS dept.
• If a client does an early pay-in of sold securities on T-day, they can use up to 80% of the sale proceeds toward new trades.

No Further Exposure beyond T+5 days of Debit:

If a debit continues for 5 trading days and the client’s available margin (ledger credit + collateral) is consumed by existing open positions, that client will not be allowed to take any new position in either Cash Market or F&O until the clear ledger balance is restored.

Delayed Payment Charges:

1. If utilized funds exceed the available balance in the client’s ledger, and charges are debited without sufficient balance, a debit balance occurs. In such cases, delayed payment interest is levied as per the “Charges, Rights & Obligations” agreed by the client.
2. Exchanges require that 50% of margin for F&O positions must be in cash or cash‐equivalent collateral. Clients must maintain 50% cash and 50% non‐cash collateral—any shortfall will incur delayed payment charges.
3. Components of Collateral:
   • Cleared Credit Ledger Balance + Approved Cash Equivalent securities (valued per the Clearing Corporation’s norms).
   • Approved Non‐Cash Securities (valued per Clearing Corporation’s norms).
4. Clients should review exchange/clearing corporation circulars to understand which securities qualify as approved cash or non‐cash collateral.

Physical Delivery Contracts on Commodity Segment:

1. For clients holding open positions in physically deliverable commodity futures and ITM options, we will notify them five trading days before expiry (Tender Period) to either square off or rollover. No fresh positions in physically deliverable contracts are allowed during the last five trading days—except for clients with active, GST-compliant commodities demat accounts (COMRIS, CCRL, NERL) who intend to take/deliver physicals.
2. If, during the Tender Period, a client fails to square off or rollover, the contract will be physically settled. Failure to meet delivery or pay-in obligations will result in penalties per exchange guidelines.
3. Clients lacking a GST-compliant commodities demat account are advised to square off/rollover positions before the Tender Period begins. ANSPL may liquidate positions of non‐compliant clients without further notice.

Settlement of Clients Funds:

As per regulatory guidelines, ANSPL will settle client funds at least once per quarter or month (e.g., the first Friday of each quarter/month). For clients who haven’t traded in the last 30 days, funds are settled immediately. On settlement days, ANSPL may retain necessary funds for outstanding obligations and to cover expected margin requirements.

Unpaid Shares:

1. We do not transfer unpaid securities to a client’s demat. If payment is not received by the 5th trading day from payout date, unpaid shares will be auctioned proportionally to the unpaid amount; the remaining shares are transferred to the client’s demat.
2. For partial payment against a ledger debit, we may retain full value of the securities for five days post-payout. Within those five days, we transfer unpaid shares after auctioning a proportion equal to the unpaid amount.
3. We may transfer any shares in our CUSA account to the client’s demat (if the client has given us POA), even if the client’s ledger is in debit, to cover the debit. The client must clear the debit within 10 trading days—or we may auction the shares in the demat to recover the debit (with prior notice).

Other Surveillance Measures:

• Refusal of Orders for Penny/Illiquid/ASM/GSM Stocks: ANSPL may refuse or restrict orders in certain illiquid or high-volatility securities, even if margin is available, if the RMS & Surveillance Dept. deems the risk too high. In F&O, we may refuse far-month contracts if deemed too risky.
• Newly listed, illiquid, and “Trade-to-Trade” securities carry high VaR margins and daily price ranges (DPR). Trading in these requires special permission from Surveillance. A blanket limit (e.g., Rs. 10,000) may apply under ASM/GSM to allow minimal settlement trades; this can be adjusted based on market conditions without notice.
• Regulatory Limits & Automatic Square-Off: If a client’s position in any scrip/derivatives hits SEBI/exchange/ANSPL or market-wide open-interest limits, ANSPL may refuse further positions or square off existing ones to protect margin coverage.
• PMLA (Anti-Money Laundering) Guidelines: Clients are classified as High/Medium/Low risk per their KYC profile. Limits are adjusted accordingly; annual income proof is required (ITR, Form 16, Salary Slip, Net Worth Certificate, Bank Statements, Demat Holdings, etc.). If trading volumes don’t match declared financials, the client must explain; ANSPL may restrict limits until clarifications are satisfactory.
• Suspension of Accounts & Withholding Payouts: ANSPL may suspend trading or withhold payouts if internal surveillance flags suspicious trading—for example, circular trading or trading in scrips with unsolicited messages in the market.

System/Network Risk:

• High-volume trading (market open/close or volatile periods) may delay order confirmations/executions.
• Under extreme market conditions, it may be difficult or impossible to liquidate positions at a reasonable price—or at all—if there are no buy/sell orders or if trading is halted (e.g., due to circuit filters).
• Trading relies on electronic systems (satellite/leased lines, servers, exchanges). Communication failures, system glitches, or slow responses may prevent order placement or routing. These are largely beyond our control but represent a risk if you have open positions or unexecuted orders.