The Paid Influencer Reel

Conclusion: Yes, she is a person associated with research services, and the contract label does not insulate the RA.

Reasoning: She is making a public appearance that includes a specific BUY recommendation, a target and a stop-loss, and she is distributing the RA's research to attract subscriptions. That is more than generic marketing. The substance of the relationship, not the label 'independent marketing partner', determines her status. The RA has engaged her, pays her per post and per lead, and allows use of its logo. The RA remains responsible for the acts of persons associated with its research services and cannot contract out of that responsibility. The 'do your own research' line does not cure the specific call, especially when she has not read the report. The RA should treat the influencer as an associated person for compliance purposes, with pre-approval, training and record-keeping.

The reel adds a target and stop-loss that were not in the approved one-line brief, so it is unauthorised research content. It also fails to disclose the paid relationship, the RA's identity and the risks. The ₹300 per lead payment creates an incentive to produce attention-grabbing calls and to generate subscriptions, regardless of suitability. The viewer's question about a 'guaranteed return' shows the communication is being understood as a promise, which is prohibited. The RA should not rely on the influencer's disclaimer; it should require pre-approval of the exact script and visuals, prohibit changes to target or rating, require disclosure of the paid relationship and the RA's registration, and monitor the posts. The payment structure should be reviewed so that it does not reward specific recommendations or lead volume without quality controls.

The RA should suspend the campaign and review all posts already published. It should preserve the reels, the brief, the contract and the lead records; correct or delete the misleading reel; and respond to the viewer who asked about a guarantee with a clear statement that no return is guaranteed. It should revise the influencer agreement to include compliance obligations, pre-approval of every post, a prohibition on adding targets or ratings, disclosure requirements and audit rights. The influencer should be trained on what she may say and should not use the RA's logo unless authorised. The RA should also monitor leads and complaints for signs of misunderstanding. Only after these steps, and after the registered research analyst has approved the content, should the campaign resume. The RA should document the review and consider whether the conduct requires regulatory notification.