SEBI
Topic72 PYQ Analysis SEBI Grade A 2018 2024
PYQ Analysis — Securities Laws in SEBI Grade A Exam (2018–2024)
Topic 72 — Pattern Analysis, High-Frequency Topics, Question Types & Strategic Exam Preparation | SEBI Law Officer
The SEBI Grade A (Officer Grade) examination is the primary recruitment mechanism for SEBI Law Officers. The Phase 2 paper includes a dedicated Securities Laws paper — typically 100 marks — covering all six laws in this series. Analysis of papers from 2018 to 2024 reveals consistent patterns in question types, high-frequency topics, and the level of technical detail expected. This topic synthesises those patterns to guide last-mile exam preparation.
1. SEBI Grade A Exam Structure — Phase 2 Paper 2
Component | Details |
|---|---|
Paper name | Securities Laws (Paper 2 of Phase 2) |
Total marks | 100 marks |
Sections | Part A: Objective MCQs (typically 50-60 questions × 1 mark each); Part B: Descriptive questions (typically 3-4 questions × 10-15 marks each) |
Time | Approximately 60-90 minutes for the objective section; additional time for descriptive |
Negative marking | Typically 0.25 marks negative marking for incorrect MCQ answers |
Coverage | All six securities laws: SCRA 1956, SEBI Act 1992, Depositories Act 1996, PFUTP 2003, SAST 2011, PIT 2015 |
2. Topic-Wise Weightage — Based on PYQ Pattern Analysis (2018-2024)
Law / Topic Area | Approximate MCQ Weightage | Approximate Descriptive Weightage |
|---|---|---|
SEBI Act 1992 (Sections 11-24, SAT, penalties) | 25-30% | 1 full question often from SEBI Act enforcement framework |
PIT Regulations 2015 (UPSI, insider, SDD, trading window) | 20-25% | 1-2 questions from PIT — definitions + case law typically |
SAST Regulations 2011 (25% trigger, offer price, exemptions) | 18-22% | 1 question on takeover procedure or offer price calculation |
PFUTP Regulations 2003 (fraud definition, Reg 4(2), cases) | 12-15% | Often integrated with PIT — combined insider trading question |
Depositories Act 1996 (demat, pledge, fungibility, rights) | 8-12% | Shorter descriptive or MCQ-only |
SCRA 1956 (definitions, derivatives, recognition) | 5-8% | Rarely full descriptive — mostly MCQs |
3. High-Frequency MCQ Topics — Tested in 3+ Years
Topic | Law | What is Tested |
|---|---|---|
Section 15G penalty quantum (min ₹10 lakh; max ₹25 crore or 3× profit) | SEBI Act | The mandatory minimum + the dual maximum formula |
25% SAST trigger vs 5% creeping limit | SAST | Arithmetic; method restriction for creeping (open market only) |
SAT limitation period (45 days from order) | SEBI Act Section 15T | Exact timeline + condonation of delay |
UPSI definition — six categories | PIT Regulation 2(1)(n) | Which specific information qualifies; what does NOT qualify |
GAI definition — non-discriminatory access | PIT Regulation 2(1)(e) | Exchange filing = GAI; analyst briefing ≠ GAI |
Insider definition — two categories | PIT Regulation 2(1)(g) | Connected person OR possessor of UPSI — EITHER qualifies |
Connected person six-month look-back | PIT Regulation 2(1)(d) | Former employee/adviser remains connected for 6 months |
SDD mandatory requirements | PIT Regulation 3(5) | Who must maintain; what data; technical requirements |
Regulation 4(2)(a) PFUTP — misleading appearance | PFUTP | Circular trading, wash trades — the most tested PFUTP provision |
Section 11B orders (types) | SEBI Act | Five types: C&D; debarment; disgorgement; impounding; refund |
Section 15J factors (mandatory — three) | SEBI Act | Gain; investor loss; repetitiveness — AO MUST consider all three |
Beneficial owner vs registered owner (depository) | Depositories Act Sections 2(a), 2(j), 9, 10 | Depository = registered owner; investor = beneficial owner; Section 10 rights |
Fungibility — Section 9A Depositories Act | Depositories Act | No distinctive numbers; ISIN-based; practical implications |
SAST offer price formula (Regulation 8(1)) | SAST | Highest of four parameters — numerical questions |
Voluntary open offer minimum size | SAST Regulation 6(2) | 10% minimum (vs 26% mandatory) — frequently tested distinction |
4. High-Frequency Descriptive Topics
Year (Approx.) | Descriptive Questions Asked |
|---|---|
2024 | UPSI definition and application; trading window and pre-clearance mechanism; SAST offer price formula with calculation |
2023 | Section 11B orders (types and natural justice); PIT reversal of burden (Explanation to Reg 4(1)); PFUTP Reg 4(2) — enumerate and explain 5 prohibited practices |
2022 | Insider definition and categories; SAST exemptions under Regulation 10 (5 exemptions); SDD requirements and SEBI investigation |
2021 | SEBI enforcement mechanism (investigation to prosecution); HUL v. SEBI significance; SAST mandatory open offer procedure and timeline |
2020 | Connected person definition and six-month look-back; PFUTP fraud definition (Reg 2(1)(c)) vs IPC fraud; SAST creeping acquisition |
2019 | SAT — constitution, jurisdiction, powers; PIT Code of Conduct (Schedules B and C); PFUTP legitimate purpose vs insider trading |
2018 | SEBI Act functions (Section 11(2)); Depositories Act beneficial owner rights; SAST definition of control |
5. Common MCQ Traps — Know These Before the Exam
Trap | Correct Answer | Law / Section |
|---|---|---|
DPS within '5 WD' not '7 WD' | DPS = 5 WD from PA; PA = 2 WD from trigger | SAST Regulations 13 & 14 |
Voluntary offer minimum is 10%, not 26% | Mandatory = 26%; Voluntary = 10% | SAST Regs 6(2) and 7(1) |
Section 15G has mandatory MINIMUM of ₹10 lakh | ₹10 lakh minimum; ₹25 crore or 3× max | SEBI Act Section 15G |
Insider = EITHER connected person OR possessor of UPSI | NOT both required — either independently qualifies | PIT Regulation 2(1)(g) |
Connected person six-month look-back, NOT three months | SIX months preceding the concerned act | PIT Regulation 2(1)(d) |
SDD retention = 8 years, NOT 5 years | 8 years as per SEBI circular | PIT Regulation 3(5) + SEBI Circular |
SAST 52-week look-back for VOLUNTARY offer (not mandatory) | 52-week restriction is only for voluntary offer under Regulation 6(3) | SAST Regulation 6(3) |
SAST annual disclosure = April 7 (7 WD of March 31) | NOT April 15 or April 30 | SAST Regulation 28 |
PFUTP Reg 4(2)(a) creates 'misleading appearance' — covers circular trading AND wash sales | Both are sub-types of Reg 4(2)(a) | PFUTP Regulations |
Trading plan cooling-off = 6 months, NOT 3 months | MINIMUM 6 months before first trade under plan | PIT Regulation 5 |
6. Recommended Last-Week Revision Strategy
Days Before Exam | Focus Area |
|---|---|
Day 7 | Complete reading of all six laws' critical sections (Topic 71 Quick Revision Chart). Focus on section numbers and exact content. |
Day 6 | PIT Regulations 2015 — all definitions; Regulation 3 (communication); Regulation 4 (trading); SDD; Code of Conduct. Do Topic 68 MCQ set. |
Day 5 | SAST Regulations 2011 — triggers (3(1), 3(2), 4); offer price formula (Reg 8(1)); exemptions (Reg 10); disclosures. Do Topic 55 MCQ set. |
Day 4 | PFUTP Regulations 2003 — Regulation 4(2) all sub-clauses; cases (Rakhi Trading; Kanaiyalal Patel; Kishore Ajmera). Do Topic 43 MCQ set. |
Day 3 | SEBI Act enforcement framework — Sections 11-15Z; Section 11B orders; AO adjudication; SAT. Cross-topic comparison (Topic 70). |
Day 2 | Depositories Act — Sections 2, 8, 9, 9A, 9B, 10, 11, 16. SCRA — Sections 2(h), 13, 18A, 23, 26. Case law review. |
Day 1 | Full mock test (Topic 74). Review wrong answers. Final revision of 'trap' questions (Topic 72 Section 5). |
🎯 EXAM POINTERS — Topic 72: PYQ Analysis
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← Topic 71: Quick Revision Chart — All 6 Laws | Next → Topic 73: 500 MCQ Bank — All Securities Laws
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