Marcellus Investment Managers Private Limited

Includes form instructions and options. Options shown in this text do not identify which boxes were selected.

GENERAL INSTRUCTIONS
This Disclosure Reporting Page (DRP ADV) is an 
INITIAL OR
AMENDED response used to report details for affirmative responses to Items 11.C., 11.D., 11.E., 11.F. or 11.G. of Form ADV.
Regulatory Action
Check item(s) being responded to:
11.C(1)
11.C(2)
11.C(3)
11.C(4)
11.C(5)
11.D(1)
11.D(2)
11.D(3)
11.D(4)
11.D(5)
11.E(1)
11.E(2)
11.E(3)
11.E(4)
11.F.
11.G.
Use a separate DRP for each event or proceeding . The same event or proceeding may be reported for more than one person or entity using one DRP. File with a completed Execution Page. 
One event may result in more than one affirmative answer to Items 11.C., 11.D., 11.E., 11.F. or 11.G. Use only one DRP to report details related to the same event. If an event gives rise to actions by more
than one regulator, provide details for each action on a separate DRP.
PART I
A.  The person(s) or entity(ies) for whom this DRP is being filed is (are):
You (the advisory firm)
You and one or more of your advisory affiliates
One or more of your advisory affiliates
If this DRP is being filed for an advisory affiliate, give the full name of the advisory affiliate below (for individuals, Last name, First name, Middle name). 
If the advisory affiliate has a CRD number, provide that number. If not, indicate "non-registered" by checking the appropriate box.
ADV DRP - ADVISORY AFFILIATE
CRD Number:
7469815
This advisory affiliate is 
a Firm
an Individual
Registered:
Yes
No
Name:
Mukherjea, Saurabh, Prasanta
(For individuals, Last, First, Middle)
This DRP should be removed from the ADV record because the advisory affiliate(s) is no longer associated with the adviser.
This DRP should be removed from the ADV record because: (1) the event or proceeding occurred more than ten years ago or (2) the adviser is registered or applying for registration with the SEC or
reporting as an exempt reporting adviser with the SEC and the event was resolved in the adviser's or advisory affiliate's favor.
If you are registered or registering with a state securities authority , you may remove a DRP for an event you reported only in response to Item 11.D(4), and only if that event occurred more than ten
years ago. If you are registered or registering with the SEC, you may remove a DRP for any event listed in Item 11 that occurred more than ten years ago.
This DRP should be removed from the ADV record because it was filed in error, such as due to a clerical or data-entry mistake. Explain the circumstances: 
B.
If the advisory affiliate is registered through the IARD system or CRD system, has the advisory affiliate submitted a DRP (with Form ADV, BD or U-4) to the IARD or CRD for the event? If the answer is
"Yes," no other information on this DRP must be provided.
 Yes
 No
NOTE: The completion of this form does not relieve the advisory affiliate of its obligation to update its IARD or CRD records.

PART II
1.  Regulatory Action initiated by:
SEC   
Other Federal   
State   
SRO
Foreign
(Full name of regulator, foreign financial regulatory authority, federal, state, or SRO) 
SECURITIES EXCHANGE BOARD OF INDIA (SEBI)
2.
Principal Sanction:
Civil and Administrative Penalt(ies) /Fine(s)
Other Sanctions: 
3.
Date Initiated (MM/DD/YYYY): 
05/29/2019
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
SEBI/HO/EAD-3/JS/OW/P/13577/1/2019
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
AMBIT CAPITAL PRIVATE LIMITED
6.
Principal Product Type:
Equity Listed (Common & Preferred Stock)
Other Product Types: 
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
THE SEBI ALLEGED THAT ON MARCH 18, 2013, MR. MUKHERJEA AND OTHER AMBIT PERSONNEL, IN A MEETING WITH MR. I. UNNIKRISHNAN AND MR. SACHIN AGRAWAL OF MFL, RECEIVED UNPUBLISHED
PRICE SENSITIVE INFORMATION ("UPSI") AND COMMUNICATED THAT UPSI THROUGH A RESEARCH REPORT TO AMBIT'S CLIENTS TWO DAYS BEFORE THE UPSI WAS MADE PUBLIC. THE SEBI ALLEGED THAT
THE COMMISSIONING AND RELEASING OF THE RESEARCH REPORT VIOLATED SEBI REGULATIONS BECAUSE THE CONFIDENTIALITY OF THE UPSI WAS NOT MAINTAINED, RESULTING IN LOSS ON INVESTORS
WHO WERE NOT PRIVY TO THE UPSI AND WHO DEALT IN THE STOCK OF MFL DURING THE 19TH AND 20TH OF MARCH, 2013.
8.
Current Status?      
 Pending
 On Appeal
 Final
9.
If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and Date Appeal Filed:
If Final or On Appeal, complete all items below. For Pending Actions, complete Item 13 only.
10. How was matter resolved:
Settled
11. Resolution Date (MM/DD/YYYY):
09/29/2020
 Exact
 Explanation
If not exact, provide explanation:
12. Resolution Detail:
A.  Were any of the following Sanctions Ordered (check all appropriate items)?
 Monetary/Fine Amount: $ 180,000.00
 Revocation/Expulsion/Denial
 Disgorgement/Restitution
 Censure
 Cease and Desist/Injunction
 Bar
 Suspension
B.
Other Sanctions Ordered:
Sanction detail: if suspended, enjoined or barred, provide duration including start date and capacities affected (General Securities Principal, Financial Operations Principal, etc.). If requalification by
exam/retraining was a condition of the sanction, provide length of time given to requalify/retrain, type of exam required and whether condition has been satisfied. If disposition resulted in a fine,
penalty, restitution, disgorgement or monetary compensation, provide total amount, portion levied against you or an advisory affiliate, date paid and if any portion of penalty was waived: 
MR. MUKHERJEA PAID THE FULL AMOUNT OF INDIAN RUPEES OWED (EQUIVALENT TO $180,000) PRIOR TO THE ISSUING OF SETTLEMENT ORDER NO. SO/VV/NK/2020-21/6153 ON OCTOBER 29,
2020.
13. Provide a brief summary of details related to the action status and (or) disposition and include relevant terms, conditions and dates (your response must fit within the space provided).
THE ACTION IS RESOLVED. THE SEBI ACCEPTED MR. MUKHERJEA'S SETTLEMENT ON SEPTEMBER 25, 2020, AND ISSUED SETTLEMENT ORDER NO. SO/VV/NK/2020-21/6153 ON OCTOBER 29, 2020,
DISPOSING OF ADJUDICATION OF THE SHOW CAUSE NOTICE PROCEEDINGS AGAINST MR. MUKHERJEA.