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Title: Final Order in the matter of
Reference No.: IRDA/LIFE/ORD/MISC/209/09/2012
Date: 07/09/2012
M/S Kotak Mahindra Old Mutual Life Insurance Company Limited
IRDA/LIFE/ORD/MISC/209/09/2012
Final Order in the matter of
M/S Kotak Mahindra Old Mutual Life Insurance Company Limited
Based on Insurer’s Reply dated 31/3/2012 to the Show Cause Notice dated 22ndFeb, 2012 and Submissions made in Personal Hearing on 10th May, 2012 at 03:00PM at the office of Insurance Regulatory and Development Authority, 3rd Floor, ParishramaBhavanam, Basheerbagh, Hyderabad
Chaired by Sri J. Hari Narayan, Chairman, IRDA
The Insurance Regulatory and Development Authority (hereinafter referred to as “the Authority”) carried out an onsite inspection of M/s. Kotak Mahindra Old Mutual Life Insurance Company Limited (hereinafter referred to as “the Insurer”) from 24th January, 2011 to 29th January, 2011. The Authority forwarded the copy of the Inspection Report to the Insurer under the cover of letter dated 2ndMay, 2011 and sought the comments of the Insurer to the same. Upon examining the submissions made by the Insurer vide letter dated 30thMay, 2011, the Authority has issued a Show Cause Notice on 22nd Feb, 2012 which was responded to by the Insurer vide replies dated 31st March, 2012. As requested therein, a personal hearing was given to the Insurer by Chairman of the Authority on 10th May, 2012. Mr.Gaurang Shah, Director, Mr. G Murlidhar, MD & CEO, Mr. Andrew Cartwright, Appointed Actuary, Mr. Sunil Sharma, Executive Vice President – Actuarial, Mr. Cedric Fernandes, CFO, Mr. R Mahesh Kumar Vice President – Legal and Compliance and Company Secretary and Mr.CheruvuMuralikrishna Associate Vice President of the insurer were present in the hearing. On behalf the Authority, Mr.SriramTaranikanti, FA, Mr.KunnelPrem, CSO (Life), Mr.SN Jayasimhan, JD (Investments), Ms MamataSuri, JD (F & A), Mrs.J.Meena Kumari, HOD (Actuarial), Mr.SatishHegde, OSD, were present in the personal hearing.
The submissions made by the Insurer in their written reply to Show Cause Notice as also those made during the course of the personal hearing were taken into account.
The findings on the explanations offered by the Life Insurer to the issues raised in the Show Cause Notice dated 22nd February, 2012 are as follows.
Charge No 1:Violation of Regulation 5 of IRDA (Investment) regulations, (Fourth Amendment), 2008
Inspection Observation No. 1: Non Adherence to the exposure/prudential norms at ‘Investee Company’ level, at segregated fund level in respect of ULIP funds.
Inspection Observation No 2(a) & (b) : Non Adherence to the ceilings prescribed as to investments in different Industrial Sectors in respect of ULIPs at segregated fund level.
Decision: Insurer submits that they have adhered to the exposure/prudential norms in most of the funds except for 5 small sized funds aggregating to Rs.15.61 Cr which works out to 0.29% of total UL funds as at 31st March 2010. Insurer has denied the violation mentioned in observation no 2 (a).Insurer submits that their exposure to Banking and Financial sector was 18.65% and stated that the exposure to financial sector of 29.29% has been calculated by inadvertently including the exposure to Manufacturing and other Sectors which if excluded is coming within the ceiling of 25%.Taking into account the submissions made by the Insurer, the Charges are not pressed.
Charge No 2: Violation of the provisions as mentioned in Sec 29(1) of Insurance Act, 1938
Inspection Observation No 8: Emergency loans were granted to Managers / Officers of the company. The total quantum of loans so granted outstanding as at 31.03.2010 was to the tune of Rs. 4 Cr
Decision: Insurer submitted that they have not violated Section 29(1) of Insurance Act, 1938 confirming that none of the officers/ Managers as stated in the said Section, read with Section 2(24) and Section 2(30) of the Companies Act has been granted a loan at any point of time. The loans granted were Staff loans for the purposes of medical emergencies and personal exigencies to 806 of the lower level employees. Taking into account the submissions made by the Insurer, the Charges are not pressed.
Charge No 3:Violation of the provisions as mentioned in schedule A-Part 1-Reg. 2 of IRDA (Preparation of Financial Statements and Auditor’s Report)
Inspection Observation No 11: While preparing financial statements it is observed that the insurer has
a) Recognized only 85% of the full premium due on Non-Linked Policies
b) Treated interest receivable on premiums as Outstanding Premiums
Thus the Insurer has not created correct provision in case of “outstanding premiums” as at 31st March, 2010.
Decision: Insurer submits that based on their experience of lapses and the past conservation ratio, 15% of the Premium Income due is not normally received. Hence, keeping in line with the normal accounting principle of prudence under the Accounting Standards and as a matter of conservatism they have recognized only 85% of the due premiums after allowing for the above referred factors like lapsation, claims etc. Insurer states that the above policy has been consistently followed in the preparation of Financial Statements. This is in compliance to Point 1 of Sch. A-Part 1-Reg. 2 of IRDA (Preparation of Financial Statements and Auditor’s Report) which requires the company to comply with the Accounting Standards (AS) issued by the ICAI. Taking into account the submissions made by the Insurer, the Charges are not pressed.
Charge No 4: Violation of the provisions mentioned in C-7 & C-11 of Guidelines on Group Insurance Policies dated 14th July, 2005
Inspection Observation No 25: It is observed that while paying Death claims under non employer-employee Group Policies, Insurer is making payments in favour of the Master Policyholder and sending the same to the Master policyholder. It is also observed that the Insurer has neither carried out any surprise inspection of the books and records of the group organizers nor obtained a certificate from their auditors about compliance to group Insurance guidelines.
Decision: Insurer has agreed that the payments are made through master policyholders both in case of SEWA and Credit Life policies which are in violation of the group guidelines. Insurer further states that all the claims referred are small value claims and are paid through SEWA as there was a genuine difficulty for nominees to have a bank account due to their very poor economic condition and that they had obtained confirmation from policyholder.
However by sending the claim cheques to the master policyholder insurer has violated provisions mentioned in point no.C-7 of Group Guidelines, 2005 and a penalty of
Rs. 1, 00,000 (Rupees One lakh only) is imposed under Section 102(b) of Ins Act, 1938.
Charge No 5: Violation of the provisions mentioned in Clause B-2 and Clause C-4 of Group Guidelines, 2005
Inspection Observation No 23: It is observed that the insurer is remunerating the Master Policyholders towards the Administrative Expenses.
Decision: Insurer stated that they have not violated the requirements of Clause B-2 of Group Guidelines, 2005 and further submitted that these MOU’s are not marketing arrangements and do not envisage the Master Policyholder distributing the group products. The payments made are towards the ancillary services to be provided and other facilities across various locations where they do not have presence and is the best & cost effective way of providing these services. The above amount was on fixed cost basis.
On examining the observation and the submissions it is noticed that insurer has made the following payments in the name of reimbursement of administrative expenses to the master policyholders, many of whom are also corporate agents of the insurer.
| Sl. No | Name of the Master policy holder | Master Policy No | 2009-10 (Rs) | 2010-11 (Rs) |
| 1 | KMBL – HF(Corp Agent of Kotak Life Ins Co. Ltd) | F8 | 86,50,000 | - |
| 2 | Sundaram Finance Ltd (Corp Agent of LIC of India) | F18 | 4,00,000 | - |
| 3 | GIC Housing Finance Ltd | F22 | 1,91,23,500 | 3,20,68,200 |
| 4 | Allahabad Bank (Corp Agent of LIC of India) | F30 | 16,54,200 | 5,64,120 |
| 5 | Bank of Baroda (Corp Agent India First) | F31 | 2,01,700 | 10,78,000 |
| 6 | UCO Bank (Corp Agent of LIC of India) | A3 | 2,04,600 | 5,37,200 |
| 7 | Indian Bank (Corp Agent of HDFC Std.Life) | A7 | 5,71,050 | 31,70,150 |
| 8 | Tata Capital Ltd – Auto Loan | F34 | - | 12,43,780 |
While all the above payments are in violation of C-4 of Group Guidelines, three payments made to KMBL-HF (1) and GIC Housing Finance Limited (2) are considered as very serious and a penalty (3X5 lakhs) of Rs.15 Lakhs is imposed under Section 102(b) of Insurance Act, 1938.
The penalty referred herein is to be paid by insurer without prejudice to the action which the AUTHORITY would take against the Corporate Agents who have by receiving such payments also violated the regulatory instructions, the onus of which would equally lie on insurer.
Charge No 6: Violation of the provisions as mentioned in Regulation 8 of Protection of Policyholders’ Interests Regulations, 2002
Inspection Observation No 27(a) & (b): It is observed that the insurer is repudiating death claims for non-submission of requirements.
Decision: Insurer submitted that the numbers of such cases constitute only 0.19% of total claims and that they were very early death claims where the insurer found material non disclosures, fraud etc on detailed investigation. Insurer also submitted that while repudiating such claims they write to the claimant that their claim will be considered if the required document/information is provided in future.
The submissions are not accepted as the basis of claim repudiation cannot be non submission of additional documents called for by the Insurer. The Insurer is however free to protect its genuine interests and that of other policy holders by repudiating non-genuine claims utilizing the permissible provisions of Section 45 of Insurance Act etc.
Hence, it is held that the claim repudiations on the basis of non-submission of requirements called for is violation of Section 8 of PPHI Regulations,2002 and a penalty of Rs. 1,00,000 (Rupees one lakh only) is imposed under Section 102(b) of Ins Act. The Insurer is further advised to revise its claim manual procedures in line with this directive and provisions of Section 8 of PPHI Regulations, 2002.
Charge No 7: Violation of the provisions as mentioned in 8 (3) of Protection of Policyholders’ Interests Regulations 2002
Inspection Observation No 30: It is noticed that there is a delay of more than 30 days in settlement of annuities.
Decision: Insurer submitted that the main reason for the delay is the non-receipt of exercised option from the customer due to limited availability of immediate annuity plans in the market coupled with the fact that the annuity pay outs in such cases are less than Rs.400 per month. The insurer confirmed that there are only 10 cases which are unpaid having maturity pay outs of less than Rs.50000/- each. Taking into account the submissions made by the Insurer, the Charges are not pressed.
Charge No 8: Violation of the provisions as mentioned in Regulation 6(2) of Protection of Policyholders’ Interests, Regulations, 2002
Inspection Observation No 31 (b) & (c): It is observed that the insurer has allowed Free look cancellations for personal reasons, financial problems, buying property, fund transfer etc. Further it is also observed that free look option is used for cancellation of policies within ULIP lock in period there by circumventing the lock-in period stipulated for ULIPs.
Decision: Insurer submitted that as a policy, they allow free look cancellation to the customers within the free look period irrespective of reasons (including not agreeing to terms and conditions under the policy). The 111 cases cited in the report translate to 1% of the total cancellations of 10087 UL policies during the year 2009-10. From the submissions it appears that the cancellations have been done on the insistence of the policyholders and to mitigate the concerns posed by policyholders. Taking into account the submissions made by the Insurer, the Charges are not pressed. However, Insurer is advised to apply prudence while considering Free Look Cancellations on exceptional grounds and comply the provisions of Regulation (6) (2) of IRDA (Protection of Policyholders’ Interests) Regulations.
Charge No 9: Violations of the provisions as mentioned in ULIP Guidelines, issued vide Cir no. 032/IRDA/ACTL/ Dec, 2005 dated 21/12/2005
Inspection Observation No 6: It is observed that while computing NAV Insurer is
a) Using fixed transaction cost factor and weighted average cost of equity and debt portfolio instead of expenses incurred on any particular day.
b) No regular reviews of the transaction costs so assumed.
c) Calculating 2 NAVs, one with expropriation and appropriation and the other without the same – publishing the former in Newspaper and using the latter for actual accounting of unit transactions.
Decision: Insurer submitted that the method followed by their company is in line with regulation stating that now their company is following the instructions issued vide Circular IRDA/F&I/CIR/INV/187/08/201 dated August 17, 2011 in which the appropriation / expropriation NAV is withdrawn and hence requested the authority not press charges. Taking into account the submissions made by the Insurer, the Charges are not pressed. However, the procedure followed by the Insurer in calculating two NAVs; disclosing one in Newspapers and unitising the other is not in order. Insurer is warned for these practices and advised to adopt the best business practices while making public disclosures.
Charge No 10: Violation of the provisions as mentioned under Clause -2 & 3 of part 1 of Schedule A of IRDA (Preparation of Financial Statements and Auditor’s report of Insurance Companies) Regulations, 2002
Inspection Observation No 12 ( c ): It is observed that the insurer has set off the profit commissions which were in arrears from the financial year 2002-03 (which is settled during the year 2009-10), on re-insurance arrangements with RGA against the premiums payable to RGA.
Decision: Insurer submitted that the amount of Rs. 4.04 cr. being profit commission cannot be accounted as premium and the profit commission is not an acquisition cost but a benefit which contractually flows back in the subsequent period depending upon favourable claims experience. It can only be computed with a lag as per the agreed methodology. Insurer further submitted that as a note under the Schedule 2 that “The Profit / Commission , if any, are to be combined with the reinsurance accepted or reinsurance ceded figures. The company has strictly followed this and has combined the profit commission of Rs 4.04 Crs. with the “Commission on Reinsurance ceded” and arrived at the balance figure of Rs. 6.10 Crs. for the year 2009-10. Insurer further submits that out of the total amount of Rs.4 Crs. receivable, Rs.1.93 Crs. was for the year 2009-10 and the balance related to the immediately preceding years. Taking into account the submissions made by the Insurer, the Charges are not pressed.
Charge No 11: Violation of the provisions as mentioned in the clause 7.1 of Corporate Governance Guidelines
Inspection Observation No 12 (d): It is observed that the fact of not calculating and reporting the group credit business re-insurance premiums has neither been brought out in the Audit Reports of the company nor it was reported to the Audit Committee of the company.
Decision:Insurer has denied that there has been violation to clause 7.1 of the Corporate Governance norms. Insurer submitted that the issue being referred to was in respect of Group single premium credit policy. The method was changed after discussion with the reinsurers to an annual method. The above fact was informed to the Authority via the quarterly reinsurance reports – LR8, for quarter ended 30th June 2009. Insurer has also confirmed that this matter was reported to its senior management. Taking into account the submissions made the charges are not pressed. However insurer is advised to strictly follow the provisions as mentioned in 7.1 of corporate governance in future.
Charge No 12: Violation of the provisions as mentioned in Authority’s Directions P1101/IRDA/ACTL/KotakOM/08-09/AVR/29868dated 06/04/2009 and misrepresenting the facts to the Authority as well as policy holders
Inspection Observation No 15 ( c) ): It is observed that that the insurer has incorrectly stated in web-site that the change in fund composition is a consequence of Authority’s circular dated 27-10-2008 while in reality it is the insurer which requested for the change in the fund composition. By this act, the insurer suppressed the correct facts from the policyholders.
Inspection Observation No 15 ( d): It is observed that the insurer has changed the policy contract terms (with respect to the fund composition) unilaterally without informing all the existing policyholders as directed by the Authority vide letter dated 06-04-2009.
Decision: Insurer has agreed that the wordings were not appropriate but submitted that it was unintentional. Insurer further stated that that they have obtained prior approval of Authority before carrying out the changes and requested the Authority not to press any charges. Taking into account the submissions made by the Insurer, the Charges are not pressed.
However the insurer is cautioned to desist from such actions in future.
Charge No 13: Violation of the provisions as mentioned in File & Use procedure
Inspection Observation No. 21: It is observed that insurer has modified the policy terms of Complete Cover group plans(UIN 107NO18V01 & V02) after the clearance of the product i.e., inserted a clause denying the death claim if occurring within 90 days from the Date of Commencement of risk.
Decision: Insurer submitted that Kotak Credit Term Group Plan was introduced in 2003-04. Initially this plan was introduced without the lien clause. However after their bad experience during 2004-05 when the company received many suspicious early death claims within the first 90 days to reduce the anti selection, lien clause was introduced as an underwriting decision. Insurer further submits that out of 75 group credit policies they have inserted this lien clause in 38 group credit policies only. However insurer submits that the lien clause was applicable only to early natural deaths and not to accidental death claims. Insurer further states that they have informed this to the Authority vide letter dated 29 October 2010.
On scrutiny of the submissions of the insurer it is noticed that insurer has mentioned this lien clause even in COI (certificate of Insurance which is generally issued to individual member under a group policy). By this insurer has ensured that each & every member under the group plan where he has introduced the lien clause is aware of this fact.
By introducing such clause without obtaining the prior permission of the regulator insurer has violated the F & U procedure and a penalty of Rs.5, 00,000/- (Rupees five lakhs only) is imposed under Section 102(b) of the Insurance Act, 1938. The insurer is directed to reopen all such claims which are repudiated because of inclusion of this lien clause and examine and decide on the same. The action taken be confirmed to the IRDA.
Inspection Observation No 22: It is observed that the insurer is settling extra benefits (like enhanced sum assured) in respect of death claims under group policies where the Master policyholder is their Promoter group company (MMFSL & KMBL). Provision for these extra benefits was not as per the approved File & Use version of the products.
Decision: Insurer has confirmed that MMFSL & KMBL are not their promoter group companies. However Insurer has agreed that on the specific request of the policyholder they have agreed to pay additional amount as part of Sum Assured. This is given to cover the additional cost involved for delayed payment and delay in submission of claim forms which will result in late claim payments. Insurer during the personal hearing informed that these additional pay outs were factored in pricing and by taking into the submissions made the charges are not pressed. However insurer is advised to strictly follow the F & U guidelines in future and if any extra benefits are to be offered to any customer company should seek the prior approval of the authority.
Charge No 14: Violation of the provisions as mentioned in circular 01/IRDA/Actl/MC/2006-07 dated 12/7/2006
Inspection Observation No 48: It is observed that the Insurer is not taking corrective action on the deviations noticed in products from approve versions of file& use.
Decision: Insurer submitted that 9 deviations observed were from the approved file & use version of products and they are being monitored regularly and are being reported to the Board on quarterly basis as envisaged under IRDA circular 01/IRDA/ACTL/MC/2006-07, dated12-07-2006. It is further submitted that all the 9 deviations were classified as minor in nature and all of them stand corrected. Taking into account the submissions of the insurer, the charges are not pressed. However the insurer is advised to reduce the time lag in correcting the deviations and strictly follow the provisions of the circular referred.
Charge No 15:Violation of the provisions as mentioned in the F&U provisions
Inspection Observation No 24: It is observed that your company is collecting charges towards Professional Charges, Compliance preparation charges (per annum), Trust Deed drafting charges (one time) and Approval from Income Tax charges (one time) from the Master Policyholders under the Group Gratuity Schemes, over and above the File & Use notified rates of Risk Premium and Gratuity contributions.
Decision: Insurer submitted that the valuation of Gratuity/Superannuation benefits considered being a service rendered to customer and it is not a product feature and it was not disclosed in product F & U. Insurer further submits that this was done in only four cases out of 26 cases and the cost involved was only Rupees 55,000 and confirmed that the practice has since been discontinued. Taking into account the submissions made by the Insurer, the Charges are not pressed.
Charge No 16: Violation of the provisions as mentioned in IRDA (Sharing of Data Base for Distributions of Insurance Products) Regulations, 2010
Inspection Observation No 16: It is observed that your company has entered into agreements with individuals and entities for lead generation activity in violation of the IRDA (Sharing of Data Base for Distributions of Insurance Products) Regulations, 2010.
Decision:Insurer submitted that it entered into agreements to provide various marketing and promotional activities such as, “Road Shows”, “Mailer Campaign”, “Lead Generation” & “Customer Meet”and that there was no agreement for purchase of database or leads from these vendors. It also submitted that payment of any remuneration was not linked to success of sales in any manner with these vendors. These vendors are merely material/service providers; the outcome of the activity was used by Kotak Life Insurance staff for follow up & closure. Insurer further submits that no amount has been paid for lead generation activity as envisaged under the above regulations. All our promotional activities are purely vendor arrangements on fixed payment basis.
Taking into account the submission of the insurer that the agreements were not in the nature of sharing of database or referral providers, the charges are not pressed.
Charge No 17: Violation of the provisions as mentioned in Clause 21 of Corporate Agency Guidelines, 2005, 40(A) of Insurance Act, 1938, and F&U provisions
Inspection Observation No 17: It is observed that the insurer has entered into agreements with the related parties of the Corporate agents and brokers and paid them for conducting Insurance related activities-thus routing extra payouts to the corporate agents (CAs) and Brokers through these related parties, over and above the prescribed limits in the Insurance Act, 1938 and File & Use of the respective products.
Inspection Observation 7: It is noticed that the insurer has spent an amount of Rs. 48.82 Cr and 87.59 Cr under the head “Advertisement and Publicity during the year 2009-10 and 2008-09 respectively. Out of this an amount of Rs.29.93 Cr and 67.47 Cr respectively was spent under the sub head “Advertisement-others”. These payments are made to various entities which are related to intermediaries engaged by insurer which are into services related to distribution of financial products.
Decision: The observation 7 mainly relates to proper categorization of payments made under the head “Advertisements-Others” as per Cir No 067/IRDA/F&A/CIR/Mar-08. The Insurer has submitted that in the absence of definition of terms- Business development expenses and Marketing Support Expenses , they have disclosed under the two heads- expenses incurred to promote the company’s image , its sales and sales force across the country; and payments to external parties to create awareness of company’s products as well as product promotion. The submissions of the Insurer in this regard are accepted and the charges are not pressed.
The observation 17 relates to payments made to Corporate Agents, related parties of licensed intermediaries (corporate agents and brokers). The Insurer submitted that no agreements were made with licensed intermediaries and no extra pay-outs were made to these entities which violate Clause 21 of Corporate agency guidelines or Section 40A of Ins Act or Regulation 19 of Brokers Regulations. They submitted that agreements were indeed entered into with related parties of the licensed intermediaries for lead generation activity, business promotion related activities and that it need not be construed as Insurance activity. An examination of the detailed account of payments made to related parties of licensed intermediaries is made and it is noticed that the following other payments (towards promotional expenses etc.) were made during 2009-10 to the Corporate Agents referred hereunder.
(Rs in Thousands)
| Name of the Corporate Agent | FYP | SP | Other payments (Promotional Expenses) to Corp Agents | % of Other Payments on FYP |
| Dombivalli Nagari Sahakari Bank | 13300 | 1109 | 1145 | 8.61 |
| Encode Financial Services | 31 | | 34 | 109.68 |
| Ratnakar Bank Limited | 83446 | 1292 | 1039 | 1.25 |
| Kotak Mahindra Bank | 1964459 | 946605 | 117008 | 5.96 |
On analytically examining the submissions of the Insurer, I conclude that the marketing expenses paid by the Insurer to the Corporate Agents referred herein are in violation of Clause no. 21 of Corporate Agents’ Guidelines (Circular No. 017/IRDA/Circular/CA Guidelines/2005 dated 14th July, 2005)of which there are four instances as above . However, one of the payments made , ie, toEncode Financial Services constituted 109.68% of First Year Premium but is not significant in absolute volume. Hence no charges are pressed on this count.
Charge No 18:Violation of the provisions as mentioned in Regulation 2 (9) of IRDA (Assets, Liabilities and Solvency Margin of Insurers) Regulations, 2000
Inspection Observation No. 14: It is noticed that across various funds, the duration gap between the insurer’s liabilities and assets is huge and there has been not much progress in reducing the gap between March 2010 and September 2010. Also, while arriving at the valuation interest rates for the respective portfolios the duration mismatch was not discussed in the asset liability management committee by the Appointed Actuary.
Decision: Insurer submitted that they have assessed the adequacy of Economic Capital in the event of various shocks. They state that the capital was more than adequate as at end of 31st March 2011 including a 2% fall in interest rates from current levels. Insurer further submitted that they have since revisited their methodology (with effect from March 2011) and confirm that all relevant liability cash flows will be taken into account when calculating Macaulay’s duration and not just spikes in net outgo that are in excess of a certain minimum which would resolve the duration mismatch effectively complying with ALSM Regulation requirements. Taking into account the submissions made by the Insurer, the Charges are not pressed.
Accordingly, in exercise of the powers conferred upon me under the Section 102(b) of the Insurance Act, 1938, I hereby direct the Insurer to remit the penalty of Rs 22 lakhs (Rupees twenty two lakhs only) by debiting share holder’s account , within a period of 15 days from the date of receipt of this order through a crossed demand draft drawn in favour of Insurance Regulatory and Development Authority, Hyderabad, payable at Hyderabad, which may be sent to Mr.V. Jayanth Kumar, Joint Director(Life) at the Insurance Regulatory and Development Authority, III Floor, Parishrama Bhavanam, Basheerbagh, Hyderabad – 500004.
Place: Hyderabad (J.Hari Narayan)
Date: 07th September, 2012 Chairman
