Action Taken Report

A complaint on SCORES is not a letter into a void. It is forwarded automatically to the entity complained against, and the entity has to come back on the record with what it actually did.

That reply is the Action Taken Report. It is uploaded to SCORES, not posted to the investor, and the system routes it to the complainant on its own.

Everything that follows — first review, second review, escalation to SEBI — is measured from the date of that report. The ATR is therefore both an answer and a starting gun.

The framework is SEBI circular SEBI/HO/OIAE/IGRD/CIR/P/2023/156 dated 20 September 2023, which revised SCORES and linked it to the Online Dispute Resolution platform. The clock runs like this:

For a stock broker, the Designated Body is the stock exchange, and it is the Designated Body's job to ensure the entity submits its ATR within the 21 days. On a first review the Designated Body may seek clarification from the entity, and must stipulate a timeline tight enough to let it file the revised ATR within its own 10 calendar days.

Two disposal rules complete the picture. If the complainant is satisfied with the Designated Body's ATR, or does not seek a second review within 15 calendar days, the complaint is disposed on SCORES. And a second-review complaint is treated as resolved, disposed or closed only when SEBI itself disposes or closes it — merely filing an ATR against a SEBI review complaint does not dispose of it.

An investor's broker fails to credit a Rs 2.4 lakh pay-out. She complains to the broker's compliance officer first, as she must — taking the grievance up with the entity directly is mandatory before SCORES. Nothing happens. She lodges on SCORES on 1 September.

1 Sep    Complaint lodged on SCORES, auto-forwarded to the broker
         Email acknowledgement generated for tracking

22 Sep   Last day for the broker to resolve and upload the ATR
         (21 calendar days). ATR filed: "funds released".
         Routed automatically to the complainant.

7 Oct    Last day to seek a FIRST review (15 calendar days
         from the ATR). She does: only Rs 1.9 lakh arrived.

17 Oct   Last day for the stock exchange, as Designated Body,
         to submit the revised ATR (10 calendar days).

1 Nov    Last day to seek a SECOND review (15 calendar days).
         SEBI may then take cognizance through SCORES.

And the limitation that decides whether she can start at all: a complaint may be lodged on SCORES within one year from the date of the cause of action, while the limitation period for filing an arbitration reference with a stock exchange is three years.

Chapter 7 (Investor Grievances and Arbitration, section 7.2.2.1) sets out SCORES and the ATR chain, and the chapter is generous with numbers, which means the paper is too. The four-number sequence 21 - 15 - 10 - 15 is the single most examinable string in the chapter. Series VII is marked at 50 per cent to pass with 25 per cent negative marking, so a guess between 15 and 21 days on a review window is not a free shot — if the sequence is not solid, the honest move is to leave the question blank.

• 21 / 15 / 10 / 15, all calendar days. Entity 21 to file the ATR, complainant 15 to seek first review, Designated Body 10 for the revised ATR, complainant 15 for second review.
• The Designated Body for a stock broker is the stock exchange, not SEBI and not the depository.
• Silence disposes the complaint. If the complainant does not seek a second review within 15 calendar days, it is disposed on SCORES — inaction counts as acceptance.
• A SEBI review complaint is not disposed by filing an ATR. Only SEBI disposing or closing it ends it. This distinction is stated explicitly in the workbook and is a natural question.
• Approach the entity first. It is mandatory to take the grievance up with the entity's designated official before lodging on SCORES.
• One year for SCORES, three years for arbitration. Two different limitation periods for two different forums; do not carry one over to the other.
• The ATR uploaded on SCORES for a KRA's annual systems audit — sent to SEBI within 3 months — is a different report with the same name. Read which one the question is about.