Question: A research analyst published a research report recommending the shares of a listed company on 20th of August. The analyst had purchased shares of the same company on 18th of July, believing the purchase was made well before the report was published. As per SEBI (Research Analysts) Regulations, 2014, does this trade comply with the prescribed trading restrictions?
Answer: The trade compiles with the prescribed trading restrictions. Research analyst are prohibited from trading in securities they recommend within 30 days before the publication of a research report. Here, the analyst purchased the shares 33 days before the report was published which is outside the restricted period. Therefore, the trade is consistent with the SEBI ( Research Analyst ) Regulations.

Supporting evidence:
title: sebi.gov.in/securities-and-exchange-board-of-india-research-analysts-regulations-2014-last-amended-on-august-03-2021-_34615.html
quote: Independent research analysts, individuals employed as research analyst by research entity or their associates shall not deal or trade in securities that the research analyst recommends or follows within thirty days before and five days after the publication of a research report
context: (iii) preventing the use of research report or research analysis to manipulate the securities market.
(2) Research analyst or research entity shall have in place appropriate mechanisms to ensure independence of its research activities from its other business activities.

Limitations on trading by research analysts.

16 . (1) Personal trading activities of the individuals employed as research analyst by research entity shall be monitored, recorded and whereever necessary, shall be subject to a formal approval process.
(2) Independent research analysts, individuals employed as research analyst by research entity or their associates shall not deal or trade in securities that the research analyst recommends or follows within thirty days before and five days after the publication of a research report.
(3) Independent research analysts, individuals employed as research analysts by research entity or their associates shall not deal or trade directly or indirectly in securities that he reviews in a manner contrary to his given recommendation.
(4) Independent research analysts, individuals employed as research analysts by research entity or their associate shall not purchase or receive securities of the issuer before the issuer's initial public offering, if the issuer is principally engaged in the same types of business as companies that the research analyst follows or recommends.
(5) Provisions of sub-regulations (2) to (4) shall apply mutatis mutandis to a research entity unless it has segregated its research activities from all other activities and maintained an arms-length relationship between such activities.
(6) Notwithstanding anything contained in sub-regulations (2) to (4), such restrictions to trade or deal in securities may not apply in case of significant news or event concerning the subject company or based upon an unanticipated significant change in the personal financial circumstances of the research analyst, subject to prior written approval as per the terms specified in the approved internal policies and procedures.

Compensation of research analysts.

17 . (1) Research entity shall not pay any bonus, salary or other form of compensation to any individual employed as research analyst that is determined or based on any specific merchant banking or investment banking or brokerage services transaction.
(2) The compensation of all individuals employed as research analyst shall be reviewed, documented and approved annually by