KUBR

SEBI ordered a Rs 7,035 crore refund from an unregistered holiday scheme; SAT upheld it

Pancard Clubs Ltd · Holiday club and resort operator

Misuse of raised fundsRegulatory breach

The case in brief

Visible before detection

    Checks that could have surfaced it, on hindsight

    1

    Regulatory & litigation records

    SEBI registration and order records would show a pooling scheme with no registration.

    Can mislead when: Court records lag and name spellings vary. A clean record can mean the problem has not reached court yet.

    2

    End-use tracing of funds

    Tracing scheme money would show the large flow into hotels and resorts.

    Can mislead when: Kubr sees only the company's own accounts. Once money reaches a third party's bank, Kubr can flag the payee but cannot see the next hop without that party's consent.

    3

    Governance signals

    A tiny capital base against huge public collections would show weak governance.

    Can mislead when: Private companies file late, so these signals are lagging. Kubr uses them to support other flags, not to prove anything alone.

    Where Kubr services would have helped

    Borrower monitor

    Offered in India
    • C6 Tracing scheme money would show the large flow into hotels and resorts.
    • C8 SEBI registration and order records would show a pooling scheme with no registration.
    • C11 A tiny capital base against huge public collections would show weak governance.

    Verified Snapshot

    Offered in India
    • C8 SEBI registration and order records would show a pooling scheme with no registration.
    • C11 A tiny capital base against huge public collections would show weak governance.

    Legal diligence support

    Offered in India
    • C8 SEBI registration and order records would show a pooling scheme with no registration.
    • C11 A tiny capital base against huge public collections would show weak governance.

    Promoter profiles

    Offered in India
    • C8 SEBI registration and order records would show a pooling scheme with no registration.
    • C11 A tiny capital base against huge public collections would show weak governance.

    Mapped from the checks each service runs. A hindsight reading of public records, not a promise that the failure would have been found.

    A summary of public documents. It reports what the sources say. It is not Kubr's finding and not a statement of guilt.