Document authentication, scope classification and clearing-control mapping completed.
CompletedLegal & operational communications
Implementation Control Register
Controlled record of legal completion, operative-order implementation and institutional access-restoration controls.
Clearing-corporation implementation memorandum
Post-NOC Clearing & Operational Enablement
Completed implementation sequence following the clearing-corporation no-objection communication dated 31 August 2026.
Scope of the NOC
The communication records that no clearing-corporation-level objection remains to eligible clearing and settlement enablement. It does not independently grant a licence, release a bank or depository restriction, approve a particular withdrawal, or waive continuing membership, margin, collateral, risk, reporting or settlement obligations.
Brainwaves Securities and banking-partner access controls verified and recorded.
CompletedAll prerequisites are complete; transactional channels are scheduled for final operational activation.
Operational timePost-NOC implementation controlsPrimary controls and required sub-protocols
- 01Completed · 31 Aug 2026
NOC Authentication & Scope Control
Confirm document integrity, issuing body, date, signatory context, covered entity and the precise clearing-and-settlement scope.
- Record the NOC in the controlled-document register.
- Separate clearing clearance from licence, banking, depository and fund-release decisions.
- Identify continuing conditions, limitations and independently subsisting restraints.
- 02Completed · 31 Aug 2026
Membership & Segment Eligibility Mapping
Map the approved operational scope to the relevant clearing-member category, market segments and permitted transaction channels.
- Validate membership, segment and authorised-user records.
- Confirm capital adequacy, net-worth, deposit and continuing eligibility records.
- Retain maker-checker approval and access-entitlement evidence.
- 03Completed · 31 Aug 2026
Clearing-Bank & Settlement Account Mapping
Validate designated clearing accounts, settlement mandates and controlled banking connectivity used exclusively for clearing obligations.
- Match account ownership, authorised signatories and mandate limits.
- Validate pay-in, payout, RTGS/NEFT and bank-response channels.
- Confirm reconciliation, exception and failed-instruction workflows.
- 04Completed · 31 Aug 2026
Depository & Securities Settlement Controls
Confirm pool, beneficiary and custodian-account mapping together with electronic delivery and payout instruction readiness.
- Validate client and proprietary securities segregation.
- Test delivery-out, pay-in, payout and rejected-instruction handling.
- Retain depository acknowledgements and settlement exception records.
- 05Completed · 31 Aug 2026
Margin, Collateral & Risk Validation
Verify that trading and settlement obligations remain within prescribed financial-resource and risk-containment parameters.
- Validate eligible collateral, valuation, haircut and liquid-asset records.
- Confirm margin availability, exposure limits and position-monitoring controls.
- Enable breach alerts, automatic restriction and escalation procedures.
- 06Completed · 31 Aug 2026
Client Asset, KYC & Financial-Crime Controls
Confirm client identity, beneficial ownership, bank-account validation and segregation of client funds and securities.
- Review KYC, PAN, beneficial-owner and authorised-mandate records.
- Apply transaction monitoring, sanctions screening and suspicious-activity escalation.
- Preserve client-wise ledger, consent, instruction and reconciliation evidence.
- 07Completed · 01 Sep 2026
Internal Investment Activation Prerequisite
The qualifying investment entry of ₹15,00,000 from an existing customer is recorded as received, reconciled and approved under the internal activation policy.
- Customer mandate, source account and cleared-funds confirmation verified.
- Investment posted to customer, banking and portfolio ledgers.
- Maker-checker approval and UTR/bank acknowledgement retained.
- 08Completed · 01 Sep 2026
Controlled Operational-Access Restoration
Institutional-access readiness is completed through controlled release, least-privilege entitlements and banking-partner confirmation.
- Authorised users and transaction limits validated under dual control.
- Production connectivity, security and business-continuity checks completed.
- Activation approvers and institutional acknowledgements recorded.
- 09Readiness completed · Activation 02 Sep 2026, 12:30 PM IST
Transactional Enablement & Settlement Monitoring
Final transaction-channel readiness and settlement-monitoring controls are completed for scheduled operational activation.
- Relevant T+1 or optional T+0 settlement schedules mapped by segment.
- Obligation determination, pay-in resources and payout validation controls completed.
- Shortage, auction, rejected-instruction, limit and bank-response monitoring enabled.
- 10Control framework enabled · 01 Sep 2026
Post-Activation Governance & Audit Trail
The continuing governance, risk and recordkeeping control framework is enabled for operation from the scheduled activation time.
- Daily bank, depository, collateral and client-ledger reconciliation configured.
- System logs, approvals, reports, alerts and exception-resolution evidence enabled.
- Escalation controls established for any freeze, lien, restraint, breach or authority direction.
Clearing Corporation · Final procedure
Final CC Charges
Clearing Corporation charge recorded for settlement through the authorised member channel.
Charge amount₹8,47,000
- Status
- Awaiting settlement
- Updated
- 03 Sep 2026
- Reference
- BWS/CC/090326
Authorised payment channelVerify the CC-issued bill and use the designated clearing account before confirming settlement.
Proceed to Clearing Corporation Portal ↗Applicable legal and operating framework
Framework Register
Applicability depends on the transaction, segment, membership category and verified facts.
Controlled Implementation Memorandum
Post-Order Operational Restoration
Formal control sequence from completion of the legal proceedings to restoration of transactional access for Brainwaves Securities.
Operational readiness completion100%
Completed: all legal, implementation, authentication, transactional-access, qualifying-investment and existing-client PMS investment-entry controls. Brainwaves Securities CMS and PMS operations are scheduled to commence on 21 August 2026 at 9:30 AM IST.
Implementation sequence✓ Completed control↻ Pending institutional action
- ✓
01 · Completed Legal Review & Reconciliation
Review of the covered resources, ownership records, representations and client-settlement reconciliation has been recorded as concluded for the purpose stated in the supplied order.
Record basis: findings and directions preceding Clause 13 - ✓
02 · Completed Operative Release Direction Issued
The supplied order records withdrawal of SEBI-originated restrictions covered by those proceedings with effect from 11 August 2026, subject to independently subsisting restraints and applicable law.
Record basis: Clauses 13.1 and 13.5 - ✓
03 · Completed Implementation Communication Logged
The operative direction has been entered into the internal implementation register for communication to the concerned banks, depositories, intermediaries and regulated entities.
Internal workflow record; not a substitute for recipient authentication - ✓
04 · Completed Entity, Mandate & Control Mapping
Brainwaves Securities account ownership, authorised-signatory scope, applicable mandates, KYC dependencies and implementation-record requirements have been mapped for consequential action.
Control basis: Clauses 13.2, 13.4 and 13.7 - ✓
05 · Completed Final Operative-Order Authentication
Due authentication of the operative order is recorded as completed, together with confirmation that no independently subsisting control identified in the implementation record prevents the consequential release process.
Authentication control completed for consequential action under Clause 13.2 - ✓
06 · Completed Transactional Access Readiness
Institution-level KYC, mandate, compliance and operational access controls are recorded as completed within the Brainwaves Securities implementation register.
Operational readiness control completed - ✓
07 · Completed Internal Capital Activation Condition
The qualifying investment of ₹50,00,000.00 is recorded as received, allocated and verified under the Brainwaves Securities internal operating policy.
CMS and PMS operations scheduled from 21 August 2026 at 9:30 AM IST. - ✓
08 · Completed Existing PMS Client Investment Entry
The ₹5,00,000.00 investment entry from an existing PMS client is recorded as received, posted, allocated and reconciled in the internal portfolio and banking ledgers.
Final PMS investment-entry control completed before scheduled operational commencement.
Internal compliance record
24-Step Process Register
Process period: 15 June 2023 through 16 July 2026.
SPAuthorised viewerMr. Sandip Bajirao Patil
Regulatory framework considered
Depending on the verified facts and legal applicability, review areas may include the SEBI Act, 1992; Securities Contracts (Regulation) Act, 1956; Depositories Act, 1996; Prevention of Money Laundering Act, 2002; Information Technology Act, 2000; applicable SEBI intermediary/KYC regulations; exchange records; and banking documentation. No breach, direction or enforcement outcome is asserted by this register.