Q.40: I am an Individual IA and I am having less than 90 clients in the last financial year 2020-2021.

Recently I spoke to Mega Kyal (CA) and she asked for many complicated records to file but I don’t have those records. Usually I have collected Risk profile form (3 pages, Question and Answer tick mark) then KYC form with Pan copy.

After I received a filled risk profile, Kyc and Pan copy I issued Invoice to my clients.

Now, how do I file the compliance report ? Subscribers who were last year no longer have me. How can I get other reports from them?

Response : 

Definitely the Annual compliance audit requires various documents, policies and processes, without which there would be adverse remarks in your audit report.

For the clients who are no longer continuing, but some compliance / signatures missed from them, make an effort to get it streamlined or else, accept the risk of consequences due to such non-compliance.

Note: Try to check with your auditor, if any other compensating control or evidence could make it good.