Effective Date: [16/02/2026]
Company Name: [Kal Mass Media LLP ]
Website: [fractional.kalmassmedia.com]
Registered Office: [Partap Nagar, Patiala]
1. Purpose
This Escrow & Payment Handling Policy establishes procedures for the collection, management, and disbursement of funds received from investors for fractional property units.
Objectives:
- Ensure investor funds are securely managed
- Comply with Indian property, banking, and regulatory laws
- Promote transparency and trust with investors
- Reduce financial and operational risks
2. Scope
This policy applies to:
- Investor payments for fractional property units
- Refunds, cancellations, and loyalty payments
- Internal fund management and accounting
- Third-party payment gateways or banks
It covers both:
- Resident Indian investors
- Non-Resident Indian (NRI) investors
3. Fund Collection
- Accepted Payment Methods:
- Bank transfer (NEFT/RTGS/IMPS)
- Online payment gateway (UPI, debit/credit card, net banking)
- Cheque or demand draft (if permitted)
- Escrow Requirement:
- All investor funds are held in a segregated escrow account maintained with a scheduled Indian bank.
- No funds are co-mingled with LLP operating accounts.
- Funds are released only as per pre-defined milestones in the Co-Ownership Agreement and SPA.
- Investor Identification:
- All payments must be accompanied by KYC documentation.
- No payment is accepted without complete KYC & AML verification.
4. Fund Allocation & Milestone Release
Funds are released from escrow only after the following conditions:
| Milestone | Conditions for Release | Approval |
|---|---|---|
| Unit Allocation | Completion of KYC & AML verification, SPA signed | Compliance Officer |
| Property Registration | Registration of fractional unit in investor’s name | Legal Counsel |
| Maintenance / Loyalty Payments | Deduction for maintenance fees or agreed loyalty | Finance Head |
| Refund / Cancellation | Verification of refund eligibility under Refund Policy | Compliance Officer & Finance Head |
Note: Funds may be held in escrow until legal documentation is complete.
5. Refund & Cancellation Handling
- Refunds are processed only from the escrow account.
- Refunds follow the Refund & Cancellation Policy.
- Refunds are issued to the original payment source where possible.
- All deductions (processing fees, bank charges) are transparently communicated to the investor.
6. Security & Risk Management
- Escrow account is maintained in a scheduled bank regulated by RBI.
- Dual authorization required for fund release (Compliance Officer + Finance Head).
- Regular internal audits are conducted to verify fund integrity.
- All digital transactions are encrypted and logged.
7. Investor Fund Reporting
Investors will receive periodic updates:
- Payment confirmation
- Fund allocation status
- Unit registration confirmation
- Loyalty or rental income credited (if applicable)
Reports are sent via email and accessible in the investor dashboard.
8. Third-Party Payment Gateway Use
- Authorized payment gateways comply with RBI and PCI-DSS standards.
- Investor funds are temporarily held by the gateway and immediately transferred to the escrow account upon verification.
- Gateway fees, if any, are disclosed upfront.
9. NRI Investor Fund Handling
- NRI payments are processed through NRE/NRO accounts in compliance with FEMA.
- Exchange rate conversions and applicable bank charges are borne by the investor.
- All funds must comply with Indian laws governing foreign remittances.
10. Loyalty / Incentive Payments
- Loyalty or referral incentives are disbursed only from escrow or LLP operating funds approved by Compliance.
- Incentive calculations and payouts are transparent and documented.
- Incentives are not guaranteed and are subject to agreement terms.
11. Record-Keeping & Audit
- All transactions are logged and archived for at least 10 years.
- Escrow reconciliation is conducted monthly.
- Annual internal audits verify compliance with:
- KYC & AML policy
- RERA requirements
- Co-Ownership Agreements
- Refund & Cancellation Policy
12. Compliance & Legal Safeguards
- Escrow management aligns with RBI guidelines, PMLA, and applicable property laws.
- Fund misuse or misallocation is strictly prohibited.
- Any breach triggers immediate internal investigation and potential regulatory reporting.
13. Investor Acknowledgment
By proceeding with a fractional unit investment, the investor acknowledges:
- Funds will be held in escrow until legal and compliance conditions are met
- No investment is complete until SPA and Co-Ownership Agreements are executed
- Refunds and cancellations are subject to escrow and Refund Policy
- Investor has read and understood this Escrow & Payment Handling Policy
Website Checkbox Example:
☐ I acknowledge that my funds will be held in escrow and that I have read the Escrow & Payment Handling Policy.