SEBI Bans Course Work Focus, Proprietor Shashank Hirwani for Illegal Investment Advisory
Moneylife Digital Team 06 April 2023
Market regulator Securities and Exchange Board of India (SEBI) has barred Course Work Focus and its proprietor Shashank Hirwani for six months for providing investment advisory services illegally. The firm and its proprietor are also directed to refund the money collected from clients as fees.
In the order, Ananta Barua, whole time member (WTM) of SEBI, says “The activities engaged in by the noticee (Shashank Hirwani), as brought out from the various materials, seen in the backdrop of the regulatory provisions show that the noticee was holding himself out and was acting as an investment adviser, although the noticee was not registered with SEBI in the capacity of the investment adviser. Hence, I find that these activities, as were being made by the noticee without holding the mandatory certificate of registration as an investment adviser, are in violation of Section 12(1) of SEBI Act, 1992 read with regulation 3(1) of the IA regulations, 2013.”
SEBI had received a complaint against Bear2Bulls Pvt Ltd having registration as a research analyst with SEBI. The complainant alleged that he had paid Rs3.30 lakh to the research analyst, who masqueraded as an investment advisor. When getting his first payout of Rs4.52 lakh, the complainant was asked to pay half of the amount as a security deposit for receiving the payout. This made the complainant doubtful about the entity, and further investigation revealed that Bear2Bulls is not a registered investment advisor.
Further investigation of the website revealed that the Axis Bank account attached to the Easebuzz payment found on the website belonged to Mr Hirwani, the proprietor of Course Work Focus.
A detailed report from Easebuzz also revealed that the same bank account was also related to Capital Wealth Mantra. SEBI later found that this was also another illegal investment advisory. The account received Rs62.01 lakh from 13 March 2018 to 8 July 2020. 
A show-cause notice was issued to Mr Hirwani. In contention to the notice, he denied the accusations against him. He stated that Course Work Focus was engaged in telemarketing, and the firm runs in partnership with one Himesh Sethiya. 
Mr Hirwani contented that he was only a silent partner of the firm and has no knowledge about anything else. 
SEBI found these contentions to be baseless. “I note that Mr Hirwani was not only a partner of Course Work Focus but as per his own submission, he was also responsible for actively handling the administrative work of the firm. Thus, I find that even though the partnership deed stipulated that Mr Hirwani would be a sleeping partner, he was actively involved in the administrative work of the firm and was therefore involved in the activities of Course Work Focus. In view of the above, the contention of Mr Hirwani regarding entering into a partnership agreement with another entity and him being a sleeping partner of Course Work Focus is not tenable,” the SEBI WTM says.
The market regulator, after the perusal of the bank details, found that several credit entries to the bank account were titled 'for trading', 'share', 'Investment', 'Fxadvicer', 'money secure investor'. 
Considering the ample evidence, SEBI ordered Mr Hirwani to refund money collected as fees from the concerned clients within three months.
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