BEFORE THE ADJUDICATING OFFICER

SECURITIES AND EXCHANGE BOARD OF INDIA

[ADJUDICATION ORDER NO. RA/DPS/60/2016]

UNDER SECTION 15-I OF SECURITIES AND EXCHANGE BOARD OF INDIA ACT,

1992 READ WITH RULE 5 OF SEBI (PROCEDURE FOR HOLDING INQUIRY AND
IMPOSING PENALTIES BY ADJUDICATING OFFICER) RULES, 1995
In respect of:Capvision Investment Advisor
PAN No. AAJFC0782A
101, Sayaji Plaza, Near Sayaji Hotel,
Scheme Number 56, Vijay Nagar,
Indore 452010

FACTS OF THE CASE

1. Securities and Exchange Board of India (hereinafter referred to as SEBI) received
a complaint from Shri AnanthaChitradurgaVenkatesh against the Capvision
Investment Advisor (hereinafter referred to as the Noticee / Capvision) alleging
that the Noticee was acting as unauthorized Investment Advisor. In view of the
same, SEBI conducted inspection of the books of accounts / records etc. of the
Noticee on September 11, 2014, to verify whether the Noticee was providing
advisory services before submitting its application for registration to SEBI. The
period of inspection was from January 01, 2014 till date of inspection.

2. The inspection, inter alia, revealed that the Noticee was an existing Investment
Advisory for fresh registration, Noticee was directed to stop all his Investment
Advisory related activities till it gets registration from SEBI. Noticee also submitted a
declaration to this effect as well. Further it is alleged that the Noticee only informed
about its HDFC bank account is blocked on April 17, 2014. However the Noticee did
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not informed SEBI about its ICICI Bank account nor submitted any certificate stating
that the said account is blocked or about nil transactions. It is alleged that the
Noticee while submitting his application for registration, submitted CA certificate
mentioning HDFC account only. It is also observed that while perusing client-wise
payment details submitted by the Noticee it is observed that many payments are
received in ICICI bank account No. 144105000618 of the Noticee during April 17,
2014 (date of submitting declaration) till June 11, 2014 (registration date). Thus it is
alleged that the Noticee was providing advisory services when its registration was
pending with SEBI and such act of Noticee is in violation of section 12(1) of the
Securities and Exchange Board of India Act, 1992 (hereinafter referred to as 'SEBI
Act') read with regulation 3(1) of SEBI (Investment Advisors) Regulations, 2013
(hereinafter referred to as IA Regulations).
APPOINTMENT OF ADJUDICATING OFFICER

3. SEBI has, therefore, initiated adjudication proceedings against the Noticee and I
have been appointed as the Adjudicating Officer vide order dated April 1, 2015
under Section 15HBof SEBI Act, to inquire into the aforesaid alleged violations
against the Noticee.

SHOW CAUSE NOTICE, REPLY AND PERSONAL HEARING

4. Show Cause Notice No. EAO/RA/DPS/ 22659 /2015 dated August 12, 2015
(hereinafter referred to as SCN) was issued to the Noticee under rule 4(1) of the
Adjudication Rules to show cause as to why an inquiry should not be initiated and
penalty be not imposed under section 15HBof the SEBI Act for the alleged violation
of section 12(1) of the SEBI Act, read with regulation 3(1) of IA Regulations.

5. It was alleged in the SCN that the Noticee was an existing Investment Advisory
seeking fresh registration, Noticee was directed to stop all his Investment Advisory
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related activities till it gets registration from SEBI. Further it is alleged that the
Noticee only informed about its HDFC bank account is blocked on April 17, 2014.
However the Noticee did not informed SEBI about its ICICI Bank account nor
submitted any certificate stating that the said account is blocked or about nil
transactions. It is alleged that the Noticee while submitting his application for
registration, submitted CA certificate mentioning HDFC account only. It is also
observed that while perusing client-wise payment details submitted by the Noticee it
is observed that many payments are received in ICICI bank account No.
144105000618 of the Noticee during April 17, 2014 (date of submitting declaration)
till June 11, 2014 (registration date).
6. In view of above, it is alleged that the Noticee was providing advisory services when
its registration was pending with SEBI. Allegedly, such acts of Noticee is in violation
of section 12(1) of the SEBI Act, 1992 read with regulation 3(1) of IA Regulations.
The aforesaid regulation is reproduced as under;
IA Regulations:Application for grant of certificate.
3 (1) On and from the commencement of these regulations, no person shall act as
an investment adviser or hold itself out as an investment adviser unless he has
obtained a certificate of registration from the Board under these regulations:
Provided that a person acting as an investment adviser immediately before the
commencement of these regulations may continue to do so for a period of six
months from such commencement or, if it has made an application for a certificate
under subregulation (2) within the said period of six months, till the disposal of such
application.

7. The aforesaid SCN was delivered to the Noticee through Speed Post AD.
Thereafter, the Noticee in response to the SCN, filed its reply datedAugust 24, 2015
received by SEBI on August 26, 2015.

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8. In order to conduct an inquiry in terms of rule 4(3) of the Adjudication Rules, the
Noticee was granted an opportunity of personal hearing on August 30, 2016 vide
notice dated August 10, 2016. Noticeevide email dated August 24, 2016 confirmed
its presence for hearing however vide email dated August 30, 2016 requested for
next date for hearing. As per its request, second and final opportunity of hearing
was granted to the Noticee on September 14, 2016 and Hearing was attended by
the authorized representative (AR) of the Noticee Shri Ravi Prakash Mishra. The
submission made by the Noticee during the course of hearing were recorded and
the noticeereiterated the submissions as made in its reply dated August 24, 2015.
9. The key submissions/ reply of the Noticeein its reply dated August 24, 2015towards
the SCN and submissions made during the course of hearing are produced
hereunder;
i.

Allegation is made on us that we suppressed the fact from SEBI at the time of
application for license that we were continuing one of our bank account with
ICICI Bank.

ii.

In this context, we disagree the allegation that we suppressed the fact from
SEBI at the time of application for license about running our bank account with
ICICI Bank. We accept that our bank account with ICICI Bank was in operation
during the intermission of our application for license of Investment Advisory.
Information regarding all bank accounts operated in the name of firm is reflect in
CIBIL Report of firm. Further we also declared our all bank accounts at the time
of lodging of application for license.

iii.

We were operating our one of the bank account due to following reasons:
(a) Existing Business Setup: M/s Capvision investment advisor was incorporated
on 14/10/2013 and run its business before the compulsion of the license to
run the business of Investment Advisor. More than 30 employees were
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working at the time of application of license. If company suspend its business

for 2 months, it was not possible for the company to pay its employees
(which cost around `3 Lac per month) and retain them. Further if company
fire all employees without any notice, employees could have file sue against
company under labor act.
(b) Fixed Infrastructure Cost: Company run its business at rental premises
whose rent amounts to `50000/- per month with lock-in period of one year.
Further company also took computers and other ancillary infrastructure on
rent. Rent expense of infrastructure was around `30000/- per month.
Company has made deposit against rent agreement of premises and
infrastructure. If company suspend its business, company would have not be
in a position to pay out monthly fixed cost which costs around `80000/- per
month. Further if company pull out from rent agreement, company loses its
deposit and after receiving the license company had no infrastructure to run
the business.
(c) Existing Clients Commitment: Since company was running its business
before for the company to stop their services to existing clients. If company
took such action, goodwill and reputation of the company fall down in the
eyes of clients. Further it was possible that client may file sue against
company in Consumer forum and SEBI for non-providing of services. Some
of existing clients have already made part payment of service before
14/04/2014, and agreed to pay remaining service charge after 17/04/2014.
These clients would not give us new business in future if we disagree to
provide the services committed on time. Therefore, it was necessary to
operate one of our bank account to receive balance payment from such
clients with whom we were to continue basic service.
(d) Compliances of Income tax and other tax laws: As per Income tax act, No
person can make cash payment exceeding `20000/- in a day. If any person
makes a payment exceeding `20000, then such payment will be disallowed
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as expense in the purview of income tax. We have to pay for expenses such
as premises rent, Infrastructure rent, salary and like for which we had to pay
amount exceeding `20000/- to meet out our commitments. To make our
commitment in accordance with statutory act, it was necessary to pay them
through an account payee cheque and for which it was necessary to operate
at least one bank account.
(e) Since due to all above reasons it is necessary for us to operate one account,
we block our all bank account except ICICI Bank. And since ICICI Bank is in
operation, neither we nor Chartered Account certificate mentioning that ICICI
bank account is blocked.
iv.

Further allegation is made that we were providing advisory services when our
registration was pending with SEBI.

v.

In this context we agree with the allegation that we were providing advisory
services when our registration was pending with SEBI. We want you to consider
the following facts:
(a) Procedure followed for granting license: Once the license became
mandatory, key partner of firm Mr. Ravi Prakash Mishra initiated the process
for license application in Jan 2014. During the process of application, key
partner of the firm was hospitalized for 3 months due to which the process
was delayed and we finally applied in April, 2014.
(b) As per regulation 3(1) of IA Regulations Existing company can continue
acting as an investment advisor for a period of six month from such
commencement or, if it has made an application for a certificate under sub
regulation (2) within the said period of six months, till the disposal of such
application.
(c) Since we were incorporated in October 2013 and considering the above
mentioned date SEBI has considered us an existing company and according
to the regulations an existing company can apply for the license within 6
months of the commencement of the act. So we have assumed that we have
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applied for within the stipulated period of 6 months i.e. April 2014. And due to
that wrong interpretation of Existing Company and Calculation of Six
month for Existing Company for application of license, we run our business
with this impression that we are not disobey any regulation of SEBI and the
same time we complied all IA regulation and no major complaint is pending
against us till date after receiving the license.

vi.

We request you to consider the above facts please do not hold any major inquiry
and do not imposed major penalty against us. We assure you that we will
continuously comply all the IA regulations issued by SEBI in future also.

CONSIDERATION OF ISSUES AND FINDINGS:-

10. I have carefully perused the written submissions of the Noticee and the documents
available on record. The issues that arise for consideration in the present case are :
a. Whether the Noticee was providing advisory services without / pending
registration from SEBI under IA Regulations?
b. Whether the Noticeeinformed SEBI about its ICICI Bank account and
blocked the said account to comply with SEBI directions vide letter dated
April 22, 2014 to stop all its Investment Advisory related activities till it
gets registration from SEBI?
c. Whether such act of the Noticee is in violation of section 12(1) of the
SEBI Act, 1992 read with regulation 3(1) of IA Regulations?
d. If yes, then, does the violation, on the part of the Noticee attract monetary
penalty under section 15HBof SEBI Act?
e. If yes, then, what would be the monetary penalty that can be imposed
upon the Noticee?

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11. Taking into consideration and allegations and reply of the Noticee the case is being
decided on merit hereunder.

12. It is an admitted fact that the Noticee was providing advisory services when its
registration was pending with SEBI. Here it is relevant to mention that IA
Regulations were notified on January 21, 2013 and Regulation 1(2) of the IA
Regulations stated that the IA regulations would come into force on the ninetieth
day from the date of their publication in the Official Gazette i.e. come into effect
from April 21, 2013. Noticee vide its reply dated August 24, 2015 has mentioned
that it was incorporated in October 14, 2013 and initiated the process for application
for registration in January 2014 and finally applied for registration in April 17, 2014.
Here I Note that the Noticee was incorporated six months later than the
commencement of the IA Regulations and Noticeealso applied for registration as
Investment Advisor with SEBI only after six months from the date of incorporationi.e
starting its business.
13. In order to justify their failure to seek SEBI registration prior to commencement of
business, the Noticee stated that since it was incorporated in October 2013 and
considering the above mentioned date SEBI has considered it as an existing
company, it assumed that it had applied for registration as Investment adviser well
within the stipulated period of 6 months i.e. April 2014 and continued to run its
business with the impression that it did not disobey any regulations of SEBI. I note
that Noticee applied for certificate ofregistration on April 17, 2014, i.e. 6 months
from commencement of business.As the Noticee was carrying on business as
Investment Advisor prior to applying for registration, SEBI vide its letter dated April
22, 2014 directed the Noticee to stop all Investment Advisory related activities till it
gets registration from SEBI.

14. The IA Regulations commenced only after a period of ninety days from the
notification of the same in the Official Gazette. Hence, from the date of notification
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of the IA Regulations, any person who had been acting as an investment adviser
had nearly nine months to ascertain and decide whether they would like to make an
application for registration to SEBI or discontinue their business/ service of
providing investment advice and those who started investment advisory business
after the commencement of IA Regulations i.e. after April 21, 2013 have to start
investment advisory business only after obtaining certificate of registration from
SEBI in accordance with the IA Regulations. In the instant case, the Noticee started
its business after the commencement of the IA Regulations, thus the Noticee
cannot be treated as an Existing Company as per the IA Regulations and the
contention of the Noticee that once the license became mandatory it initiated the
process for License application in Jan 2014 is not acceptable.

15. I further note that, the Noticee submitted a declaration to SEBI, freezing its current
account with HDFC bank. I cannot overlook the fact that the Noticee was providing
advisory services prior to making an application for registration with SEBI, Noticees
application for registration as Investment Advisory was treated as fresh registration.
16. In respect to the allegations that theNoticee did not inform SEBI about its ICICI
Bank account nor submitted any certificate stating that the said account is blocked
or about its nil transactions. Noticee vide its reply dated August 24, 2015 admitted
that ICICI Bank account was in operation during the intermission of pending
registration, however disagrees that it had suppressed this fact from SEBI at the
time of application for registration. Noticeecontented that the existing business was
setup on October 14, 2013, incurring fixed infrastructure cost, existing clients
commitment, etc. and it was necessary to pay them through an account payee
chequefor expenses exceeding `20000/- and for which it was necessary to operate
at least one bank account.
17. I do not agree with the aforesaid contention of the Noticee on the following
grounds/examination. Firstly, no evidence has been produced by the Noticee to
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show that the said ICICI Bank account was informed to SEBI at the time of its
application for registration. Secondly,nothing stopped the Noticee while giving
declaration to SEBI that it had stopped all its Investment Advisory related
activities,only informed that it had freezed its current account with HDFC bank and
that it was continuing to maintain its ICICI Bank account for administrative purpose.
Further, many payments from its clients were received in ICICI bank account No.
144105000618 of the Noticee during April 17, 2014 (date of submitting declaration)
till June 11, 2014 (registration date).
18. Noticee has contended that it was necessary to pay for expenses such as premises
rent, infrastructure rent, salary,etc, exceeding `20000/- to pay them through an
account payee cheque and for which it was necessary to operate at least one bank
account.However on perusal of the ICICI bank account withdrawal transactions
during the period of direction to stop all its investment advisory services till it gets
registration i.e. from April 22, 2014 till June 11, 2014, only one withdrawal
transaction whose transfer mode was through chequewas observed during the said
period for `1,575/-, further Noticee indicated two transaction transferred through
ATM for `45,000/- towards office rent in its ICICI Bank account and all other
withdrawal was cash withdrawal through ATM mostly. However I note that in its
submission Noticee has stated that it is paying rental premises of `50,000/- per
month and it also submitted rent agreement for it. The contention of the noticee that
the said account was maintained to make payment towards the infrastructure cost
and salary of the employees does not hold good as perusal of the ICICI bank
account reveals that there was minimal use of the said ICICI bank for stated
purpose.

19. This establishes that the Noticeewillfully suppressed the fact from SEBI about its
ICICI Bank account and Noticee was in breach of trust as it was still providing
Advisory services even after giving declaration to SEBI that it had stopped all its
Investment Advisory related activities.Further the certificate of registration was
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issued to the Noticee on June 11, 2014 under IA Regulations, only on the basis of
information submitted in the application, is complete and true. Thus itshows the
Noticee reckless disregard to the regulatory directions / requirements and it is more
serious deliberate lapse/irregularity on the part of the Noticee.

20. Further, it is clear that the Noticee provides the investment advice and I note that
the Noticee has also admitted to the same in his submissions made. Moreover,
Section 12(1) of the SEBI Act mandates that no intermediary who may be
associated with securities market shall buy, sell or deal in securities except under,
and in accordance with, the conditions of a certificate of registration obtained from
the Board in accordance with the regulations made under this Act. Since the
Noticee applied on April 17, 2014 and got certificate of registration on June 11,
2014, i.e. only after the commencement of the IA regulation, I note that the services
provided by the Noticee before June 11, 2014 are deemed to be Unauthorized
Investment Advisory Services.
21. From the above it is established that the Noticee was providing advisory services
prior to making an application for registration as Investment Advisor and continued
to do so even after SEBIs directions to stop all its advisory services. Further, the
Noticee suppressed the fact from SEBI about its ICICI Bank account. Hence, I am
of the view that the Noticee had violated section 12(1) of the SEBI Act, 1992 read
with regulation 3(1) of IA Regulations.
22. I note that the Honble Supreme Court of India in the matter of SEBI Vs. Shri Ram
Mutual Fund [2006] 68 SCL 216(SC) has also held that In our considered opinion,
penalty is attracted as soon as the contravention of the statutory obligation as
contemplated by the Act and the Regulations is established and hence the intention
of the parties committing such violation becomes wholly irrelevant.

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23. In view of the aforesaid observation and established violations against the Noticee,
it is a fit case for imposing monetary penalty upon the Noticees under section 15HB
of SEBI Act. The provision of section 15HB is reproduced below:SEBI Act:
Penalty for contravention where no separate penalty has been provided.
15HB.
Whoever fails to comply with any provision of this Act, the rules or the
regulations made or directions issued by the Board thereunder for which no
separate penalty has been provided, shall be liable to a penalty which may extend
to one crore rupees.
24. While determining the quantum of penalty under section 15HB, it is important to
consider the factors stipulated in section 15J of SEBI Act, which reads as under:15J - Factors to be taken into account by the adjudicating officer
While adjudging quantum of penalty under section 15-I, the adjudicating officer shall
have due regard to the following factors, namely:(a) the amount of disproportionate gain or unfair advantage, wherever quantifiable,
made as a result of the default;
(b) the amount of loss caused to an investor or group of investors as a result of the
default;
(c) the repetitive nature of the default.
25. I note that the Noticee as per his submissions vide email dated September 23, 2016
during the adjudication proceedings submitted that from October 2013 to December
1, 2013 no payment was received, however it had received payment from his
clients to the tune of `15 `16Lakh for rendering Investment Advisory services for
the period December 2, 2013 to June 11, 2014. However as per the details
submitted by the Noticee at the time of inspection for the period December 3, 2013
to May 31, 2014 it had received payment from his clients to the tune of `59 Lakhs.
Therefore the Noticee was asked to recheck and confirm the total payment received
from Investment Advisory Services during the period October 14, 2013 to June 11,
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2014. In this regard, Noticee vide its email dated September 26, 2016 admitted that
it had received payment from his clients to the tune of `63 Lakh for rendering
Investment Advisory services prior to June 11, 2014.

26. Here I note that Noticee applied for registration on April 17, 2014 i.e. only after the
commencement of the IA regulation and as the Noticee was carrying on business
as Investment Advisor prior to applying for registration, SEBI vide its letter dated
April 22, 2014 directed the Noticee to stop all Investment Advisory related activities
till it gets registration from SEBI. However, despite the same Noticee continued to
do Investment Advisory services and Noticee vide its email dated October 4, 2016
admitted that it had received `13.90 Lakhs during the period April 22, 2014 to June
11, 2014. However as per the details submitted by the Noticee at the time of
inspection it is observed that during the period April 23, 2014 to June 11, 2014 it
had received payment from his clients to the tune of `19 Lakhs.Noticee got
certificate of registration on June 11, 2014.Therefore services provided by the
Noticee before June 11, 2014 are deemed to be Unauthorized Investment Advisory
Services. Further it is established that the Noticee defied the Regulators directives.

27. I note that the Honble Securities Appellate Tribunal (SAT )in its Order in the matter
of Saikala Associates Ltd. vs SEBI (Date of Judgment- 21 April, 2005) has opined
that the violation of dealing as unregistered sub-broker and non-segregation of
clients' funds from own funds are serious in nature, since the interest of
investors at large is involved.

In the said matter, the Honble SAT has further also held that the appellant acted unauthorisedly as a sub-broker from 18.7.2000 to
18.1.2001 on the NSE. The amount of commission the appellant would have
earned would not be less than Rs. 3 lakhs. This in our view, is unjust
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enrichment. We feel it appropriate that the appellant should disgorge this

commission.

This order is passed in public interest as a mere warning would not pinch the
pocket of the appellant and penal consequences would in our view, have a
greater deterrent effect on the appellant.

28. SEBI notified the IA Regulations on January 21, 2013 and come into force on the
ninetieth day from the date of publication in the Official Gazette i.e. come into effect
from April 21, 2013. The cutoff date to file application for grant of certificate of
registration under Regulation 3 of IA Regulations for Investment Advisers who were
offering Investment Advisory Services immediately before the commencement of IA
Regulations was October 21, 2013. In the given case, I note that the Noticee
commenced his business as Investment Advisor only from October 14, 2013. Thus,
it becomes, but, obvious that the Noticee was in the know of the fact that it could
not commence business without obtaining a registration from SEBI. However,
despite the same, the Noticee carried out business as Investment Advisor without
even filing an application for grant of registration with SEBI. It was only on April 17,
2014 i.e. after more than six months from commencement of business that the
Noticee filed an application for grant of registration. On noticing that the Noticee
was carrying on business as Investment Advisor prior to applying for registration,
SEBI immediately sent letter dated April 22, 2014 directing the Noticee to stop all
Investment Advisory related activities till it gets registration from SEBI. The Noticee
got certificate of registration on June 11, 2014, only on the basis of information
submitted in the application, is complete and true. I, however, note that the Noticee
as per his submissions vide email dated September 26, 2016 during the
adjudication proceedings has admitted that it had received payment from his clients
to the tune of `63 Lakh for rendering Investment Advisory services prior to June 11,
2014. Out of the same, Noticeehad received payments from his clients to the tune
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of `19 Lakh from April 23, 2014. Thus, it becomes clear that the Noticee did not
even pay heed to SEBIs specific directive directing him to stop all Investment
Advisory related activities till it gets registration from SEBI.

29. I find it pertinent to mention here that registration is with the objective of protecting
the interests of the investors, as it casts accountability and responsibility upon the
registered Investment Advisor to comply with all regulatory requirements applicable
to the conduct of its business activity, so as to promote the best interests of clients
and the integrity of the market. I consider that the act of the Noticee of carrying on
Investment advisory business without seeking registration from SEBI was in itself in
reckless disregard to the regulatory requirement in place, resulting in his unjust
enrichment. Further defying of regulators specific directive to it to stop all
Investment Advisory related activities is a matter of serious concern. I note that the
Noticee has committed a serious offence by providing Unauthorized Investment
Advisory Services to the tune of `63 lakhs in my view is unjust enrichment, of which
`19 lakhs was despite receiving specific directive from SEBI to stop all Investment
Advisory related activities. But, I also cannot ignore the fact that Noticee was in
breach of trust as it continued to provide Advisory services even after giving
declaration to SEBI that it had stopped all its Investment Advisory services and
thereby putting the investors to large risk.Certainly, the instant case involves severe
gravity and taking into account the aforesaid aspects, I am of the view that a
justifiable penalty needs to be imposed upon the Noticee to meet the ends of
justice.
ORDER

30. After taking into consideration all the aforesaid facts and circumstances of the case,
I hereby impose a penalty of `75,00,000/- (Rupees Seventy Five Lakh only) upon
the Noticee, under section 15HBof the SEBI Act.I am of the view that the said
penalty would commensurate with the violations committed by the Noticee.
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31. The Noticee shall remit / pay the said amount of penalty within 45 days of receipt of
this order either by way of Demand Draft in favour of SEBI - Penalties Remittable
to Government of India, payable at Mumbai, OR through e-payment facility into
Bank Account the details of which are given below;
Account No. for remittance of penalties levied by Adjudication Officer
Bank Name
State Bank of India
Branch
Bandra-Kurla Complex
RTGS Code
SBIN0004380
Beneficiary Name
SEBI Penalties Remittable To Government of India
Beneficiary A/c No.
31465271959
32. The Noticee shall forward said Demand Draft or the details / confirmation of penalty
so paid through e-payment to the Regional Director, Western Regional Office,
SEBI. The Format for forwarding details / confirmations of e-payments made to
SEBI shall be in the form as provided at Annexure A of Press Release No.
131/2016 dated August 09, 2016 shown at the SEBI Website which is produced
as under;
1. Case Name :
2. Name of Payee:
3. Date of payment:
4. Amount Paid:
5.Transaction No:
6. Bank Details in which payment is made:
7.Payment
is
made
for:
(like
penalties/disgorgement/recovery/Settlement
amount and legal charges along with order details)
33. In terms of rule 6 of the Adjudication Rules, copies of this order are sent to the
Noticee and also to the SEBI.

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DATE: OCTOBER6, 2016

RACHNA ANAND

PLACE: MUMBAI

ADJUDICATING OFFICER

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