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021 Voluntary Freezing Policy

Applicability

As per the requirement of SEBI Circular No. SEBI/HO/MIRSD/POD-1/P/CIR/2024/4 dated January 12, 2024 on Ease of Doing Investment by Investors - Facility of Voluntary freezing/unfreezing of Trading accounts by Client, Industry Standards Forum in consultation with the Exchanges issued Framework for the Trading Members for providing the facility of voluntary freezing the online access of the trading account of their client on account of suspicious activities in NSE Circular reference no. NSE/INSP/61529 dated April 8, 2024 and BSE Circular 20240408-12 dated April 8, 2024.

This policy applies to all clients of Diamond Hands LLP (021 Trade) who wish to avail themselves of the facility to voluntarily freeze/block their trading account access due to concerns over suspicious activities and subsequently desire to unfreeze the same. The provision is available to all clients, subject to the terms and conditions outlined in this policy and the relevant SEBI regulations.

The following framework outlines the procedure adopted by Diamond Hands LLP for providing the facility of voluntary freezing/blocking of online access to client trading accounts in case of any observed suspicious activity. This framework has been finalized based on the guidance of the Brokers' Industry Standards Forum in consultation with the Exchanges.

Communication modes for requesting freezing/blocking

Diamond Hands LLP, offering internet-based/mobile online trading services, shall provide at least two of the following channels through which a client can raise a request to voluntarily freeze or block online access to their trading account:

  • Email from registered e-mail ID
  • IVR/Calling on the customer care contact details

Diamond Hands LLP has designated an email ID and/or telephone number for receipt of such freezing/blocking requests. The email ID to give any freezing or blocking instructions is: [email protected].

Actions upon receiving request

Upon receiving the freezing/blocking request, Diamond Hands LLP shall:

A. Validate the request

Confirm the authenticity of the request and, once validated, issue an acknowledgment and proceed to freeze/block the client's online trading access, and cancel all pending orders.

Timelines for action

ScenarioTimelines
Request received during trading hours or within 30 minutes before the start of tradingWithin 30 minutes
Request received after trading hours or 30 minutes before the start of tradingBefore the start of the next trading session

To begin with, this 30-minute limit will be reviewed after six months and may be revised to enhance investor protection.

Trading hours reference

  • Capital Market Segment: 9:15 a.m. to 3:30 p.m.
  • Equity Derivatives Segment: 9:15 a.m. to 3:30 p.m.

B. Client communication and confirmation

Diamond Hands LLP shall inform the client via their registered mobile number and email ID, stating:

  • Online access has been frozen/blocked
  • Pending orders have been cancelled
  • Process for re-enablement

C. Position disclosure

Within one hour of account freezing/blocking, Diamond Hands LLP shall communicate details of any open positions and contract expiry information. (Note: This timeline will also be reviewed after six months to improve investor protection.)

D. Client authentication mechanism

To ensure that freezing/blocking requests originate from the genuine client, Diamond Hands LLP shall:

  • Verify if the request originates from the client's registered phone number or email ID, or
  • If not, implement a Two-Factor Authentication (2FA) or
  • Follow any additional guidelines issued by the Exchanges or SEBI from time to time.

Record maintenance

Diamond Hands LLP shall maintain comprehensive logs and records related to:

  • Receipt of freezing/blocking requests
  • Acknowledgement and confirmation of blocking
  • Cancellation of pending orders

E. Re-enablement of online access

Online access to the trading account shall be restored by Diamond Hands LLP only after:

  • Necessary due diligence
  • Validation of the client's request
  • Completion of unfreezing/unblocking procedures

Clarifications

Freezing/blocking is limited to online access only. It does not restrict Diamond Hands LLP's Risk Management activities.

Please note, such requests do not equate to inactivation of the client's Unique Client Code (UCC) in exchange records.