Research analyst and investment advisor regulation violation

Nithin,there are some Youtubers suggesting is that legal?

Bro at least @

Someone asked me on DM to respond to this thread hence I am writing.

It’s okay if it comes with a Disclaimer that these are mere opinion and not investment advice and you are not liable for any kind of loss caused due to the same.

Many times we do not realize how rules can affect us until we actually get into the soup. Here, an example of a consumer court ruling about a husband using wife’s ATM card.

@nithin It’s about the choice of words and how you present the information with a disclaimer. For example, many times, I have noticed Zerodha publishes a tweet, LinkedIn or Facebook post when a new tranche of SGB is launched, saying SGB is the ‘best’ way to invest in gold. Reference:

As a stockbroker Zerodha can’t advise. It can recommend, it can share opinion calling it research report but with a disclaimer and without any bias or prejudice. ‘Best’ is a superlative adjective here and Zerodha is passing a verdict. Zerodha is marketing SGB by terming it best. Even if it is your personal opinion that SGB is best, you can’t impose this through Zerodha because needless to tell you that Nithin and Zerodha are two different legal entities.

I would request your team to be careful about the choice of words.

hmm… stockbrokers are allowed to advise. It is considered incidental to the business and hence no RIA/RA registrations are also required. But yeah, I get your point.


@nithin I just randomly thought of checking how Zerodha promoted the SGB series launched just before Diwali.

Screen Shot 2020-11-30 at 5.33.49 PM

It again uses the superlative adjective ‘best’ which I had mentioned in my previous response that Zerodha being a neutral stockbroking company, should see every product equally without any prejudice, and shouldn’t pick colour from your personal preferences and biases because you and zerodha are two different entities.

I don’t know if the copywriter got the message or not, but if I had to write it, I would have written -

Option 1:
This Dhanteras, all that glitters is Sovereign Gold Bonds. Know why:

  • You get paid interest of 2.5% every year
  • Guaranteed by the Government of India
  • No expenses, no other charges

Invest today. #HappyDhanteras

Option 2:
Thinking of buying Gold this Dhanteras? Invest in Sovereign Gold Bonds. Know why:

  • You get paid interest of 2.5% every year
  • Guaranteed by the Government of India
  • No expenses, no other charges

Invest today. #HappyDhanteras

The above copy doesn’t pass any judgment that SGB is the ‘best’. It simply shares the features, makes the investors aware; but let them decide for themselves.

Hope the copywriters gets it this time. I would watch out for the copy of next SGB series.


Again, Zerodha is promoting SGB as the “BEST.

Why is Zerodha doing so, again and again?
That too when you had accepted that Zerodha needs to be neutral.

I had shared ways to communicate the reasons to believe (RTBs) as facts without using ‘best’ or making a claim.

Awaiting response.
P.S. I have also raised an official ticket #20201228378709.

If we feel it’s right for our investors we’re going to say it. If it doesn’t jive with you, feel free to ignore. You seem to under the impression that everything you say is right and we’re in the wrong, but we can’t change that


So you are accepting in public that Zerodha has the rights to promote SGB as “THE BEST”. Please consult with your legal team before responding.

Please read the previous responses, as brokers we can say that!

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Okay. Awaiting Zerodha’s official response on ticket #20201228378709. Let’s see what does SEBI has to say on this.

This is from RBI FAQ on SGBs. Link here.

@siva and @Bhuvan, very humbly :pray: and to shatter my wrong image of being a troublemaker, I am only trying to highlight that Zerodha being a stockbroker has to be neutral while promoting. It can’t market SGB as ‘the best’. That’s it. Common sense asks, why doesn’t Zerodha shout out that buy Reliance or any script for that matter calling it “the best”?

I did a small 10 minutes google search and found some traces for your help from SEBI guidelines to a stockbroker. Just search for ‘Neutral’. There would be more extensive rules and regulations by SEBI that your legal team would know.

Screen Shot 2020-12-28 at 7.52.46 PM

Screen Shot 2020-12-28 at 7.53.08 PM

Also, @siva about the reference link from RBI that you shared, I read it completely and also the underlined sentence where RBI says ‘a superior alternative to holding gold in physical form’. If you read it again and again and again, and consult with your copywriter and also with your legal team, they would tell you that RBI is simply mentioning that SGB is a superior alternative to physical gold. I repeat to physical gold. It is superior in nature to physical gold. And there may be other alternatives available. May be, focus again. It’s one of those alternatives. But superior is only specific in comparison to physical gold. RBI is not claiming SGB is the superior amongst all alternatives to physical gold. Also, RBI is not claiming that SGB is ‘the superior most’ option. It’s the choice of words and the art of copywriting and legally saving the a**. Trust me on that for being in copywriting, advertising, and marketing for 12 odd years.

This below “neutral” is out of context, you really thought we are not aware of what you have posted about, that is talking about something else altogether.

That’s why I have mentioned it, bro. Can we stop this war of narratives please. I am telling this in public that let the truth come out from the horse’s mouth. If at all I am wrong, I would accept and apologise on this thread for taking up that mental space of readers. And taking it in a right spirit I would learn from it. Now your turn.

Is it legal to post technical analysis videos for educational purposes with a disclaimer of stocks and selling courses of TA without any registration from SEBI?
Disclaimer will consist that the contents in the video/course does not constitute research report/ research analysis
Not a recommendation/advice
Only for educational and teaching purposes
@nithin @siva

Should be okay I think.

1 Like

Thank you sir

Sir another query can we do live streming of trading with a disclaimer(which contains strictly for educational purposes) on YT? Or do we need specific licenses/registration

I guess you can do but should not give advice or collect fees from others.

Ok sir thank you