CRM for SEBI registered advisers and research analysts
SEBI does not ask whether you have a CRM. It asks you to produce the record of a conversation from three years ago. This is built so that you can.
If you are a registered Investment Adviser, Regulation 19(1) of the SEBI (Investment Advisers) Regulations, 2013, read with circular SEBI/HO/IMD/DF1/CIR/P/2020/182, requires you to keep records of conversations relating to advice with all clients — including prospective clients, before they are onboarded. Those records begin at the first interaction, continue until advisory services end, and must be kept for five years. If a dispute is raised they must be kept until it is resolved, and if SEBI asks you to preserve specific records, until SEBI says otherwise.
Registered Research Analysts have a parallel obligation under the SEBI (Research Analysts) Regulations, 2014, with the same five-year retention.
The regulations accept several forms of record: a signed physical record, telephone recordings, emails from a registered email ID, SMS records, or any other legally verifiable record. Recording is not required where the channel already leaves a digital footprint, such as email.
None of that is hard when you have three clients. With fifteen callers and a few thousand clients, the hard part is not making recordings — it is being able to find the right one, attached to the right client, three years later, while the agent who made the call left eighteen months ago.
The operational problems this creates
The recording exists but nobody can find it
Most firms we meet are recording calls. Very few can produce one specific client's call from two years ago in under ten minutes. A recording on a shared drive named by timestamp is not a usable record.
The agent left and took the context with them
When calls happen on personal handsets, or notes live in an agent's own notebook, the record walks out of the door with them. Records stored centrally against the client do not.
Prospective clients are the gap
The obligation starts at the first interaction, before onboarding. Firms that only start recording once someone pays have a gap in exactly the period where a dispute is most likely to arise.
A dispute freezes one client, not the whole system
When a complaint comes in, you need that client's complete history held indefinitely while everything else follows the normal five-year cycle. That is only practical if records are organised by client.
Renewals lapse quietly
Advisory is subscription revenue. The commercial problem and the compliance problem share a solution: a system that knows when each client's term ends and reminds someone before it does.
Advisory and distribution have to stay separate — Reg 22(5)
Client-level segregation between advisory and distribution services needs to be visible in whatever system your team works in, not just in a spreadsheet the compliance officer keeps.
What the CRM does about it
Recordings attached to the client
Every call is stored against the client record with the agent, time, duration and disposition — not in a folder named by date.
History from first contact
A prospective client is a record from the first call. When they convert, the earlier conversations stay attached rather than starting fresh.
Search and export for inspection
Find a client's calls across a date range and export the recordings and logs together.
Role-based access
Each adviser sees their own clients. Managers see their team. The audit trail shows who opened what.
Renewal and follow-up reminders
The system tells you before a client's term lapses, which protects the revenue and keeps the record current.
Calls, WhatsApp and SMS in one place
The regulations accept several record formats. Keeping them against one client record means you are not reconstructing a conversation from three systems.
Hosted in India, backed up daily
Your client data and recordings sit on Indian servers with daily backups.
Predictive dialer for the calling floor
The compliance side is the reason you buy it. The dialer is why your team gets through the follow-up list.
What the rules ask for, and where it lives
| The obligation | What it means in practice | In JugnuCRM |
|---|---|---|
| Records of advice conversations — IA Reg 19(1) | Every call where advice is discussed has to leave a record | Calls are recorded and stored against the client record with agent, time and notes |
| Including prospective clients, before onboarding | The record starts at the first contact, not at the first invoice | Leads are records from first contact, and keep their history when they convert |
| Five-year retention | Recordings and logs must survive staff changes and server moves | Recordings sit centrally, not on handsets. Agree the retention window with us so it meets your obligation |
| Longer if a dispute is raised | You need to put a hold on one client's records indefinitely | Records are per client, so a single client's history can be exported and preserved |
| Produce specific records when SEBI asks | Find one client's calls across a date range, quickly | Search by client, agent or date and export the calls and logs |
| KYC and risk profiling — IA Regs 16 and 17 | Client-wise KYC and suitability records | Custom fields hold KYC and risk-profile data on the client record |
| Who inside your firm can see what | Advisers should see their own clients, not everyone's | Role-based access limits each user to their own clients |
| Permitted record formats | Calls, registered email, SMS and signed records all count | Calls, WhatsApp and SMS are logged against the same client record |
How we set it up for an advisory firm
Talk to whoever owns compliance
Your compliance officer or auditor tells us what they need to produce at inspection. We configure backwards from that.
Map your client lifecycle
Prospect, risk profile, onboarding, advice, renewal. Your stages, your fields, your terminology.
Set retention deliberately
We agree how long recordings are kept and how a dispute hold works, so the five-year obligation is met by the system rather than by someone remembering.
Import and train
Existing clients and history imported from Excel, then a walkthrough for your advisers and a separate one for whoever answers at inspection.
See JugnuCRM in action
A short walkthrough: how a caller works through leads, logs a call and sets the next follow-up, and what the owner sees in reports.
Questions compliance officers ask us
Does using JugnuCRM make us SEBI compliant?
No, and be wary of any vendor who says otherwise. Compliance is your firm's obligation, and no software is certified by SEBI. What a CRM can do is make the records exist, stay attached to the right client, and be retrievable when asked for. The rest — agreements, risk profiling, fee structure, segregation, the annual audit — is your process. Please confirm anything on this page with your own compliance officer rather than relying on us.
How long do records have to be kept?
Five years, for both Investment Advisers and Research Analysts. Longer in two situations: if a dispute is raised, until it is resolved; and if SEBI directs you to preserve specific records, until SEBI intimates otherwise.
Do we have to record every call?
The regulations accept several forms of record — signed physical records, telephone recordings, emails from a registered email ID, SMS records, or any other legally verifiable record. Recording is not required for channels that already leave a digital footprint, such as email. For conversations that happen by phone, a recording is usually the only practical record.
Has anything changed recently for Research Analysts?
Yes. SEBI circular No. HO/38/11/(9)2026-MIRSD-POD/I/24272/2026, dated 23 October 2026, amends Regulation 25(1)(vii) of the Research Analysts Regulations so that maintaining call recordings of communications with institutional investors is no longer mandatory. It takes effect from 8 November 2026. Other record-keeping obligations are unchanged, and this relaxation does not extend to other clients. Read the circular yourself before changing any internal policy.
Do records have to start before onboarding?
Yes. The obligation runs from the first interaction with a client, including prospective clients before they are onboarded, and continues until services are complete. That is the gap we see most often — firms that start recording only once someone has paid.
Can we export records if SEBI asks?
Yes. You can search by client, agent or date range and export the call logs and recordings together. If your auditor wants a particular format, tell us during setup and we will match it.
We are a small firm. Is this overkill?
Possibly. If you are two advisers with thirty clients, a disciplined folder structure and a recording app may genuinely be enough, and we would rather say that than sell you something. This starts to earn its place at around five callers, or whenever you realise you could not produce a specific call quickly if you were asked for it.
Related
CRM for Stock Advisory
Your callers work through hundreds of leads a day, turn free trials into paying clients and chase renewals every month. JugnuCRM keeps all of it on one screen, with every call recorded.
Read more →Number Masking
Your lead database is the business. Number masking lets agents call, talk and record outcomes while the phone number stays hidden from them, so nobody walks out with your list.
Read more →Predictive Dialer
Stop paying callers to listen to ringing phones. JugnuCRM dials for your team, skips the numbers that do not answer, and puts the lead's history on screen the moment someone picks up.
Read more →Get a demo set up for your team
Tell us how your team works and we'll show you the CRM and dialer set up the way you'd actually use it — not a generic slide deck.
Bangali Square, Indore, Madhya Pradesh 452016