IndiaSEBI Compliance

What to Tell Research Analyst Clients When the Market Falls 10%

A 10% fall is when clients decide whether you are worth the fee. Silence loses them. Panic messages lose them faster, and can also lose you your compliance record.

October 5, 2026 ยท 7 min read ยท By Aktai Team

Note: This describes communication practice for registered Research Analysts. It is not investment advice and says nothing about where any market is going. The record-keeping rule is from SEBI's January 2025 RA guidelines. Check for later circulars.

When the index drops 10%, your phone fills with the same three questions: what happened, is my money safe, and what should I do. You will be tempted to answer each client individually over WhatsApp, fast and from memory. That is exactly how an undocumented, inconsistent, possibly non-compliant message gets sent. The fix is a plan you write before the fall.

Send one message early, to everyone

Clients who hear nothing for three days assume you have nothing to say. Send a single, factual note to the whole book within one trading day of the move. Same text, same time, logged on your official channel. It does not need to be long. It needs to exist.

A structure that stays compliant

  1. State what happened, descriptively. How far the index and the relevant sectors moved, over what period, and the stated drivers from public sources. Facts only. No forecast.
  2. Say where your published research stands. Point to what you have already published and its dates. If you are updating a recommendation, issue the update through your normal research channel with a timestamp and a rationale. Do not change a prior call quietly.
  3. Say what you do not know. A line such as "we cannot predict the short-term path" is honest and protects you. It also builds trust.
  4. Tell them when you will write next. A date. "Next update Friday before market open" removes the pressure to answer every anxious message in real time.
  5. Repeat the standard disclosures. Registration number, the market-risk disclaimer, and your grievance contact. Every communication carries them, calm markets or not.

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What never goes in the message

Any promise of recovery

"The market will bounce back" is a prediction dressed as comfort. Assured or implied returns are what the advertisement and conduct rules are written to stop.

Fresh calls to individuals over chat

A new recommendation sent to one client on WhatsApp, outside your research process, is the classic archive failure. Put calls in the official channel with a rationale, for every client in the same service tier.

Blame

Do not blame other analysts, the regulator or the client's timing. It reads as defensive and it sits in your records for years.

Performance spin

Do not cite your best trades to offset the fall. Selective disclosure is a compliance problem in its own right. See advertising past performance.

Handle the individual calls

Some clients will still phone you. Keep the call to what you have already published and note it afterwards. If a client asks you to trade, remind them that you publish research and do not execute or manage their account. If a client wants out of the service, follow the terms in their agreement, and see why clients churn before you assume it is about the market.

Keep the record

SEBI's January 2025 guidelines say an RA must keep records of interactions with all clients and prospects, from the first interaction until the research service ends. The retention period is five years, or longer if a dispute is open or SEBI asks. Every message you send in a volatile week is part of that record. Keep the logged copy, the timestamp and the list of who received it. If you ever have to show what you told clients on a given day, you want to produce it in minutes. Our recommendation tracking guide covers the record side in more detail.

FAQ

How fast should a Research Analyst message clients after a market fall?

Within one trading day is a sensible target. A single factual note to the whole book, sent through your logged channel, beats individual replies sent from memory.

Can a Research Analyst tell clients the market will recover?

No. Predicting recovery or implying assured returns breaks the conduct and advertisement rules. Describe what happened and what you have published, and say plainly that you cannot predict the short-term path.

Should I send new recommendations to clients during a fall?

Only through your official research process, with a timestamp and rationale, to every client entitled to that service. Do not send one-off calls to individuals over chat.

How long should I keep client messages?

Five years under SEBI's January 2025 guidelines, counted from the first interaction, and longer if a dispute is open or SEBI asks you to keep them. Email from your registered address, recorded calls, SMS records and signed physical records all count.

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Not financial advice. Aktai is software for SEBI-registered Research Analysts. It is not a financial adviser, broker, Investment Adviser, or Research Analyst, and is not registered with SEBI or any other financial regulator. It surfaces public filings and news and drafts factual notes for the registered analyst to review, edit, and sign. Aktai does not author research, make recommendations, or decide what any security is worth. The view, the recommendation, and the regulatory responsibility stay with the registered analyst who sends the note. Full disclaimer โ†’