1. Intimation on fraud incidents
It may be noted that in the instance of a fraud being detected, intimation (details in brief) shall be provided to the Compliance Dept (compliance@pinwheelfinance.com, frauds@pinwheelfinance.com) within 2 days of such detection or conclusion of the incident as fraud, by the concerned RMs where the fraud has occurred at the regional/branch level and in the case of fraud detected at HO or in other business verticals by the concerned departments at HO/Vertical Heads. Further, a detailed report in the prescribed format shall be submitted within 10 days of such detection.2. Filing of Police Complaint
In all incidents where the commitment of fraud has been detected/ confirmed, police complaint should compulsorily be filed against those involved in the following instances. Amount involved in fraud is above Rs. 10,000, committed by the staff. Amount involved in fraud is Rs. 50,000 and above, committed by customers/external parties. The above instructions are in line with the RBI’s Directions/Circular (Master Direction: “Monitoring of Frauds in NBFCs (Reserve Bank) Directions, 2016” DNBS. PPD.01/66.15.001/2016-17, dated September 29, 2016 and Master Circular : “Future approach towards monitoring of frauds in NBFCs”, DNBR (PD) CC.No.058/03.10.119/2015-16) on reporting requirement concerning fraud.