Investors Grievance Division

Sometimes a broker lets an investor down. A contract note never arrives. Margin money is not refunded. A position is squared off (closed) without consent. The first formal stop is usually the exchange where that broker is a member.

The workbook says investors can approach the Investors Grievance Division (IGD) of the exchange to sort out their grievances. The exchange settles disputes by working with both the member and the complainant.

Handling grievances is not a favour. The workbook calls the grievance system a key regulatory function of SEBI. SEBI uses it to keep watch on exchanges under the SECC Regulations, 2012. A proper grievance system is also an ongoing condition for staying eligible as a member of the exchange. That rule comes from the Brokers Regulations, 2026. A broker who fails to resolve investor complaints can face a penalty, or suspension of his registration.

Complaints exchanges generally entertain against trading members (Chapter 10, section 10.4):

1. Non-receipt of documents — member-client agreement, contract notes, settlement of accounts, order trade log
2. Non-refund of margin money
3. Trades executed without adequate margins
4. Delay or non-receipt of funds
5. Squaring up without consent, or not squaring up leading to settlement at an unfavourable FSP
6. Unauthorised transactions
7. Trades not as per the price limit directed over phone
8. Trading errors — timing of order entry, missing favourable prices, error in trades
9. Servicing issues — online or offline transactions, trade confirmations, accounts, gain calculations in statements

Guidelines for filing:

• Send the complaint first to the exchange with which the member is registered, then to SEBI.
• It may be written in English, Hindi or any regional language, and must be signed by the client.
• No fee is charged.
• Frivolous or vexatious complaints — vague, anonymous or pseudonymous, or trivial — are not entertained.

Beyond the exchange. If the response is not satisfactory, the investor can approach SEBI through SCORES, which gives a unique complaint number; the entity uploads an Action Taken Report and must resolve the complaint within 21 days of intimation. If still unresolved, the ODR Portal takes over: MII review within 21 calendar days, conciliation within 21 calendar days, then online arbitration, with any award paid within 15 calendar days.

Exception. Grievances about algo trading are the broker's sole responsibility; SEBI and the exchange will not entertain them.

An illustrative complaint, following the workbook's process.

What happened. Kavita, a client in Nagpur, had Rs 2,40,000 as margin with her broker. After she closed all her positions she asked for a refund. Six weeks later she has received nothing, and she has also not received contract notes for three trades.

Step 1 — the exchange's Investors Grievance Division. Her grievance falls in two of the workbook's categories: non-refund of margin money and non-receipt of documents (contract notes). She writes a signed complaint — in Marathi if she prefers — to the exchange where the broker is registered. No fee. The IGD coordinates with the broker and with her.

Step 2 — SCORES. If the exchange's response is not satisfactory, she files on SCORES. The broker must upload an Action Taken Report and resolve it within 21 days.

Step 3 — ODR. If she is still unsatisfied, she initiates dispute resolution on the ODR Portal:

What would not be entertained. An unsigned complaint sent under a made-up name — anonymous or pseudonymous — would be rejected as frivolous or vexatious.

A sequencing difference in the workbook. The IGD guidelines say to complain first to the exchange, then SEBI; the ODR section says the investor should first take the grievance up directly with the market participant, then SCORES, then ODR. Both orders appear in Chapter 10, section 10.4.

Chapter 10, section 10.4 (Investors Grievance Redressal Mechanism), names the Investors Grievance Division, lists the nine categories of complaints exchanges entertain, the four filing guidelines, SCORES and the ODR process. Chapter 6, section 6.6, excludes algo trading complaints from SEBI and exchanges, and Chapter 8, section 8.3, lists failure to resolve complaints as a ground for penalty or suspension. Expect questions on the complaint categories, "no fee", anonymous complaints, and the 21-day timelines.

• No fee is chargeable on complaints to the exchange.
• Anonymous or pseudonymous complaints are not entertained.
• Complaints may be in English, Hindi or any regional language — not English only — and must be signed.
• Exchange first, then SEBI under the IGD guidelines; SCORES is the escalation, not the first stop.
• SCORES: 21 days for the entity to resolve. ODR: 21 + 21 calendar days, then arbitration; 15 days to pay an award.
• Algo trading grievances go to the broker only; SEBI and the exchange will not entertain them.