Policies & Procedures
Updated 25th March 2024
Firstock Broking Private Limited, is a member of the National Stock Exchange and Bombay Stock Exchange in the Equity and Equity Derivatives segment, having its Registered Office at No 350,1st Floor, 36th A Cross, 7th Main Road 5th Block, Jayanagar, Bengaluru, KA 560041.
For the purpose of these Policies & Procedures, wherever the context so mentions "Client”, “You" or "Your", it shall mean any natural or legal person who has agreed to open an account or initiate the process of opening an account with Firstock by providing their information while registering on the platform as a user. Firstock allows any person to surf the website without registering on the website. The term "We", "Us”, "Our" and "Firstock" shall mean M/s Firstock Broking Private Limited.
Trades
The trades of clients shall be carried out in the respective client code only. The dealers shall take utmost care while executing the trades of the clients regarding the accuracy of Client Code, Quantity, Price, etc.
Product
- CNC (Cash and Carry): If you want to buy for Delivery (buy stock and hold them overnight) in CM segment, you will have to place your orders under product type “CNC”.
- NRML (Normal): If you wish to carry forward your Derivative positions to the next trading day, you will have to place your orders under product type “NRML”.
- MIS (Margin Intraday Square-off): If you wish to trade for intraday purpose in any Exchange and segment (CM or F&O), you will have to place your orders under product type “MIS”.
Funds
System of Pay-in and Pay-out of Funds:
Pay-in: Clients can transfer funds into the Trading Account only from such bank accounts which are registered with Firstock. Payments will only be accepted form of Online Bank Transfers, Payment Gateway transfers, UPI or Cheques. Any transfer from a non-registered bank account will not be considered and the client does not get any trading limit credit for such transfers.
Payment Gateway: The client can transfer funds from the instant payment gateway facility available on the trading platform or on the back office.
NEFT/RTGS/Cheque: If a client chooses to transfer using NEFT or by means of cheque, there will be no cost. Customers can use fund transfer facility from their Bank wherein they can register HDFC Bank a/c of Firstock Broking Private Limited, to which they can transfer funds. The Fund receipt confirmation typically takes 1-3 hours for RTGS and 1 to 4 hours for NEFT.
If the client transfers funds via cheque, the details of the transfer along with a copy of the cheque should be made available to Firstock for the credit to be updated on the trading account.
Pay-out: All pay-outs will have to be placed on the Backoffice access provided to the clients. Firstock approves the pay-out request as mentioned below.
- Pay-Out is processed once a day
- Pay-Out placed on a calendar day before 4.00 PM will be processed same day
- Please note Pay-Out will not be processed on Saturday, Sunday and holidays
Margins
Firstock does not engage in the business of Client Funding. Clients are required to have sufficient balance in their accounts to hold/carry forward positions.
Equity & Derivatives
- NSE/BSE Equity: Firstock has a policy of giving up to 5 times Intraday leverage for stocks on which F&O trading is allowed. 100% margin is required to hold the position.
- NSE Futures: 100% of Total Margin (Span & Exposure) is required to take intraday positions. 100% of Total margin is required to carry forward positions.
Intraday Products Square-off Timings
- Equity/Cash: 3:25 PM onwards.
- Equity Derivatives: 3:25 PM onwards.
Note:
- Intraday square off timings can change based on the discretion of our risk management department.
- A Call & Trade charge of ₹50 plus 18% GST will be applicable for all positions squared off by our RMS desk, including auto square off.
- If any intraday position or an MIS trade is not squared off on the same day due to any link or system failure or any risks associated with internet/wireless-based trading which may occur at the end of the Client, Firstock or the respective Exchange, it shall be treated as a Cash and Carry ("CNC") or NRML position and carried forward to the next trading day. In case of such a situation arising, the onus of squaring off the position will be on the Client. Our RMS desk shall square off any such position, without the requirement of a margin call, if the necessary cash is not available in the Client's account.
- Option premium received from writing options will not be considered as Cash/Capital.
- Positions which do not have sufficient funds can be cut any time at the discretion of our RMS desk. There will be no margin calls or intimation from our RMS desk.
- Any open positions can be squared off at the discretion of our RMS desk If the funds available in your account are short of exchange specified margins. There will be no margin call before the position is squared off. During times of extreme volatility, the loss could be more than the funds available in your account before the position is squared off. All resulting charges or debts that might occur from such square offs will have to be borne by the client.
- Collateral margin will not be considered for equity delivery positions.
- MIS positions will automatically be squared off at the end of each trading day as mentioned above timing
- Fines levied by the exchange for short margin will be payable by the client.
- Clients will have to ensure all intraday products are closed by the EOD.
- Because of illiquidity of stock option contracts, market orders have been disabled on stock options. Only limit orders are allowed. Place a limit buying order higher than the current price or selling order below the current price, this will act as good as market order but will also protect from any impact cost due to illiquidity.
- Instruments available for trading at Firstock are subject to the discretion of the risk management team, and these may change from time to time for various reasons.
- In case your account is in debit balance and/or if you have insufficient funds to manage your trading positions, you will be charged an interest of 0.05% per day as delayed payment charges.
All information mentioned here is subject to change at the discretion of our Risk management team.
Contract Notes and Margin Statements
Firstock will issue contract notes & margin statements to its clients within 24 hours of the trade taking place. Along with the Contract Note, the client shall also be furnished with a copy of the daily margin settlement which is also available to be viewed on their respective Backoffice Personal Ledger.
Firstock Charges
For online clients, we charge zero brokerage for Equity Deliverytrades and 0.03% or Rs.20 per whichever is lower for intraday orders.
Equity Future and Options, we charge Rs.20 per order
For Offline clients we charge as per tariff sheet agreed by the client for full services.
Other Charges
- DP Charges: ₹8 (Firstock) plus ₹5.5 (CDSL)
- STT, GST, NSE Turnover and Transaction Charges, SEBI charges are all as applicable market-wide
- GST will be levied additionally on all charges mentioned in this document as and wherever applicable.
Debit Balance
All clients are advised to make the payment before the pay-in time on the settlement day, though there are instances wherein client may delay the payment beyond the settlement date. Although, it is obligatory for a broker to meet the settlement obligation in time, therefore, in order to ensure timely receipt of funds from clients towards their payment obligation, “charges for delayed payment” are levied in the client’s account. The sum towards “charges for delayed payment” is levied to discourage delayed payment from clients who do not deposit the required sum of money before the pay-in time on the pay in day. “Charges for delayed payment” are levied on the respective ledger debit of the clients at a rate of 0.05% per day of the debit balance in the account. For the purpose of reckoning debit balance, the debit balance in the client ledger is consolidated across all segments of the respective exchange giving effect to the release of margin.
Collateral Margins
- You will be able to use this entire margin after haircut for taking intraday or overnight positions in Futures, and for writing Options of equities & indices. You will not be able to use this margin to buy Options or take further positions on the equity segment.
- Exchanges stipulate that for F&O positions, 50% of the margin needs to compulsorily come in cash and the remaining 50% can be in terms of collateral margin. If you don’t have enough cash, your account will be in debit balance and there will be a delayed payment (interest) charges, charge of 0.0329% per day or 12% P.A applicable on the debit amount. So, if you take positions that require a margin of Rs 2 lakh, you will need at least Rs 1,00,000 in cash irrespective of how much collateral margin you have. Assuming you don’t have this Rs 1,00,000, whatever you are short by will be the debit balance for the day, and delayed payment (interest) charges will be applicable for that amount.
- Liquid funds are considered as cash equivalents by the exchange, so the above 50% rule wouldn’t apply. The Margin received from pledging liquid funds will be as good as having cash in your trading account. All cash equivalent stocks are updated our link.
- All delayed payment (interest) charges accumulated will be debited every day on the ledger. A link to see cumulative delayed payment (interest) charges calculation can be found on the holding page itself.
Closing of Accounts / Dormant Accounts
Account shall be closed upon a specific request from the client. The closure shall be effective only over a period of one month has elapsed from the date of application/intimation or the date of settlement of account whichever is later. Dormant accounts are concerned, we do not close such accounts, but mark the same as “Inactive” till further action by the concerned client.
Inactive Account
Client Account would be treated as INACTIVE if there is no transaction (trade) in the account continuously for 12 Calendar months in any segment
Policy on Unauthenticated News Circulation
- We do not provide any kinds of tips and unauthenticated news circular to our clients, nor allow any of our employees to circulate unauthenticated news.
- We even do not permit any of our employees to indulge in daily trading activities.
- We are very particular to enter the orders as per the instruction of our clients.
- Many a times client asks to us about our opinion on market movement & Market forecast but we have instructed all our employees to refrain from giving any kind of stock specific market forecast.
Online Surveillance
The surveillance team watches the online trades as they happen and extra ordinary volume in the particular scrip is immediately investigated by calling up the branch and asking for details of clients and as per the details made available, the client’s previous purchase or sales transactions are looked into.
Further any big value transactions are checked for whether the client is not trading beyond ones known Income (i.e. Income declared in KYC)
Policy On Pre-Funded Instruments And Electronic Fund Transfer
If the aggregate value of pre-funded instruments is Rs. 50,000/- or more from client per day per client, we may accept the instruments only if the same are accompanied by the name of the bank account holder and number of the bank account debited for the purpose, duly certified by the issuing bank. And the mode of certification may include the following either:
- Certificate from the issuing bank on its letterhead or on a plain paper with the seal of the issuing bank.
- Certified copy of the requisition slip (portion which is retained by the bank) to issue the instrument.
- Certified copy of the passbook/bank statement for the account debited to issue the instrument.
- Authentication of the bank account-number debited and name of the account holder by the issuing bank on the reverse of the instrument. We also maintain an audit trail of the funds received through electronic fund transfers to ensure that the funds are received from their clients only.
Refund & Cancellation Policy
The Refund & Cancellation policy for all payments made towards account opening using the payment gateway shall stand as under:
- The Fees paid towards account opening charges for enabling equity and FNO are non-refundable.
- Pick up of required documents related to the account opening procedure is subject to availability of our representatives, given at any particular time and location.
- In case your account has not been opened by Team Firstock, aver the tenth day passing by from the day of collection of all necessary supporting documents and receipt of all due authorizations from you, you may request for a full refund of the charges as paid by you towards account opening.
- In case you have paid the charges relating to account opening multiple times, please send mail to support and we will initiate the necessary procedure to refund your money.
Note: The completion of the refund procedure is subject to agencies such as banks, payment gateways.
AML and CFT Policy
1. Background
SEBI vide circular dated 18th January 2006, along with all its updates, requires all ‘Market intermediaries’ to lay down a policy framework for anti-money laundering measures to be followed. EBI has also issued a Master circular dated 19th December 2008, which consolidates all the requirements/obligations issued with regard to AML/CFT, last updated on February 3, 2023. Firstock Broking Limited (hereinafter “Firstock”) being a Stock Broker and therefore a market intermediary, is required to adhere to the Master Circular.
2. Objective
The objective of this PMLA policy is to have a system in place for preventing any money laundering financial transactions through Firstock, and to identify, monitor, and report any such transaction to appropriate authorities.
“Know Your Customer “(KYC) is the guiding principle behind the Anti-Money Laundering (AML) measures. It incorporates the “Know Your Customer” Standards & “Anti Money Laundering” Measures, hereinafter to be referred to as “KYC Standards” and “AML Measures". The objective is to have in place adequate policies, practices and procedures that promote high ethical and professional standards and prevent Firstock from being used, intentionally or unintentionally, by criminal elements. KYC Standards and AML Measures would enable Firstock to know/ understand its customers, the beneficial owners, the principals behind customers who are acting as agents and their financial dealings better which in turn will help Firstock manage its risks prudently.
The management of the company is fully committed to establish appropriate policies and procedures for ensuring effectiveness and compliance concerning all relevant legal requirements, and undertakes to periodically review the policies.
3. Regulatory Requirements
- Compliance of the provisions of the PMLA and AML guidelines
- Acting as a central reference point and play and active role in identification & assessment of potential suspicious transactions
Ensuring that Firstock discharges its legal obligation to report suspicious transactions to concerned authorities.
This policy is in relation to customer due diligence, which means:
- Obtaining sufficient information about the client to identify who is the actual beneficial owner of the securities or on whose behalf transaction is conducted
- Verify the customers identity using reliable independent source document, data or information
- Conduct on-going due diligence and scrutiny of the account/ client to ensure that the transaction conducted are consistent with the clients’ background/ financial status, its activities and risk profile.
The customer due diligence process includes three specific parameters:
- Policy for acceptance of clients: Each client should be met in person or complete KYC must be done online. No account may be opened in a fictitious/benami name or on as an anonymous account.
- Suspicious transaction identification and reporting: Any unusual activity compared to past transactions of a client, sudden activity in dormant accounts, or a sudden increase in volume or value transactions is classified as suspicious transactions. These shall be reported to the SEBI and any other person as laid down in applicable law.
- Central Depository Securities Limited (CDSL) communique no. CDSL/OPS/DP/POLCY/2017/176 dated April 05, 2017 and CDSL/OPS/DP/POLCY/2017/354 dated July 18, 2017, and all other applicable regulations advise that beneficial owners should submit/update their Aadhar with their Depository Participant. Please ensure that you update your Aadhar with Firstock as per these applicable regulations.
4. Client Identification
Before opening any account with us, the following measures shall be taken:
a. In-person or complete online KYC verification of the client .
b. Identify beneficial ownership and control, i.e., determine the persons who beneficially own/control the account.
c. Collect information about the Client's background, and occupation and also determine the introducer, if any.
d. Collect and verify all original documents from the client
e. Collect a certified copy of valid documents showing details of his permanent address, current address, PAN, nature of his occupation, and financial status and a recent photograph,
f. For clients trading in F&O segment, documentary proof of his financial details will be collected, determined by policies from time to time,
g. Corporate clients: Collect copies of the certificate of incorporation, the memorandum of association and other documents required by SEBI, and collect adequate information of the persons authorised to deal on behalf of the company.
a. In-person or complete online KYC verification of the client .
b. Identify beneficial ownership and control, i.e., determine the persons who beneficially own/control the account.
c. Collect information about the Client's background, and occupation and also determine the introducer, if any.
d. Collect and verify all original documents from the client
e. Collect a certified copy of valid documents showing details of his permanent address, current address, PAN, nature of his occupation, and financial status and a recent photograph,
f. For clients trading in F&O segment, documentary proof of his financial details will be collected, determined by policies from time to time,
g. Corporate clients: Collect copies of the certificate of incorporation, the memorandum of association and other documents required by SEBI, and collect adequate information of the persons authorised to deal on behalf of the company.
5. KYC Updating Process
a. All corporate clients must submit their annual report to Firstock every year.
b. In the case of individual clients, each Client’s master details shall be sent to the client, who will then confirm that the details are updated correctly, or shall revise or provide details as required. He shall also specify his present occupation and financial income details per annum in the same declaration.
c. No account shall be opened if the client is unable to or refuses to follow the KYC related required.
d. The information shall be adequate to satisfy competent authorities (regulatory/ enforcement authorities) in the future that due diligence was observed by Firstock in compliance with the Guidelines.
e. Failure by a prospective client to provide satisfactory evidence of identity should be noted and reported to the Principal Officer.
f. Further, Firstock should follow up with clients where inconsistencies in the information provided are found, until the client corrects the inconsistencies or provides reasonable proof for the same.
b. In the case of individual clients, each Client’s master details shall be sent to the client, who will then confirm that the details are updated correctly, or shall revise or provide details as required. He shall also specify his present occupation and financial income details per annum in the same declaration.
c. No account shall be opened if the client is unable to or refuses to follow the KYC related required.
d. The information shall be adequate to satisfy competent authorities (regulatory/ enforcement authorities) in the future that due diligence was observed by Firstock in compliance with the Guidelines.
e. Failure by a prospective client to provide satisfactory evidence of identity should be noted and reported to the Principal Officer.
f. Further, Firstock should follow up with clients where inconsistencies in the information provided are found, until the client corrects the inconsistencies or provides reasonable proof for the same.
6. Client Categorization
a. Each client will be marked into 3 categories, High Risk, Medium Risk and Low Risk from the point of view of the anti-money laundering laws. The categorization will be made based on the following parameters/ factors of risk perception: nature of business activity, trading turnover per day, manner of making payments on Firstock’s platforms, etc. Firstock shall internally mark the risk category of each client, and high-risk clients will require regular KYC updates as determined by Firstock.
b. Risk profiling may also vary for high net-worth individuals, trusts, non-profits, charitable organizations, and companies with close family shareholdings.
c. As a general rule, clients who make payments on time and take delivery of shares may be considered low risk.
b. Risk profiling may also vary for high net-worth individuals, trusts, non-profits, charitable organizations, and companies with close family shareholdings.
c. As a general rule, clients who make payments on time and take delivery of shares may be considered low risk.
7. Suspended Persons
SEBI and other authorities suspend or debar persons / entities from participating in the securities market on several instances. Firstock as a broker are required to ensure that such persons do not trade through us, and shall not be liable for any such blocking or closure of accounts.
8. Role of Compliance Team & Internal Audit
a. The compliance team will play an important role in ensuring compliance of the above policies and procedures. The account opening team will exercise adequate due diligence while onboarding clients. There will be periodic checking by the Principal Officer and the same report will be properly filed by Firstock.
b. Here is a system of concurrent audit, which will also include ensuring compliance of the
b. Here is a system of concurrent audit, which will also include ensuring compliance of the
- Due diligence in KYC norms.
- Generation of exception reports.
- Trading in dormant client codes.
- Level of awareness among staff.
9. Risk Management
a. Firstock follows a risk-based approach for mitigation and management of any identified risk. Firstock monitors its policies and may enhance policies if necessary.
b. Client due diligence is undertaken on a risk sensitive basis.
b. Client due diligence is undertaken on a risk sensitive basis.
10. Transaction Monitoring
a. Firstock has undertaken measures to understand the normal and standard activities of each client, to be able to understand deviations in transaction and activities.
b. Firstock shall specifically note complex and unusually large transactions / patterns which appear to have no economic purpose.
c. Firstock shall ensure retention of records as required under the PMLA and all other applicable laws.
b. Firstock shall specifically note complex and unusually large transactions / patterns which appear to have no economic purpose.
c. Firstock shall ensure retention of records as required under the PMLA and all other applicable laws.
11. Illiquid Securities
The Exchanges specifies a list of Illiquid Securities wherein higher due diligence is to be exercised by brokers. The list is displayed on the Firstock website for the client's information. The trade pattern in such scrips by our clients is monitored. We may seek clarifications or justifications from the client in case of a high volume of trades in any scrip compared to the exchange volumes.
12. Employee Training
Firstock has a policy for ongoing employee training so that the staff of Firstock are always aware of the provisions of AML and CFT procedures and amendments thereof. These training programmes are focused on our customer support staff, back-office staff, compliance staff, risk management staff and staff dealing with new customers as it is very crucial that all those concerned fully understand the rationale behind these guidelines, obligations and requirements, implement them consistently and are sensitive to the risks of their systems being misused by unscrupulous elements. A register of attendance of participation in such education and training programs is maintained as records, kept secured with the Compliance Department.
Investor Grievances
The Compliance Officer shall be the designated officer for handling the Investors Grievances and Client Complaints. The email ID you can write to in case you have any grievance is complaints@ncosecurities.com
The resolution of the Complaint shall be done at the earliest and the same shall be recorded in the register along with the date of resolution.
Procedure to file a complaint on SEBI SCORES: Register on SCORES portal. Mandatory details for filing complaints on SCORES: Name, PAN, Address, Mobile Number, E-mail ID. Benefits: Effective Communication, Speedy redressal of the grievances