Donation Handling & Disbursement Policy

Module: CrowdFunding (UTSAV DAAN™)
Document Type: Hybrid — Plain English + Legal Reinforcement
Trademark: UTSAV DAAN™ is a registered trademark of MyMahotsav Futuretech Ltd
Jurisdictions: Global (with India, UK, US, EU, Singapore, South Africa addendums)
Version: 1.0
Effective Date: [INSERT DATE]

PART A: PLAIN ENGLISH SUMMARY #

How We Handle Your Donations and Disburse Funds #

When you donate to a UTSAV DAAN™ Campaign, your money goes into a special protected account—separate from company funds. This policy explains exactly what happens to your money from the moment you donate until it reaches the beneficiary.

The Simple Truth #

• Your money is protected: All donations sit in a segregated Escrow Account. We never mix Campaign funds with our operating money.

• Funds are held safely: Money stays in escrow until Campaign conditions are met (target reached, duration ended, verification complete).

• Disbursement happens after verification: Before releasing funds, we verify beneficiary details and ensure compliance.

• Fees are deducted before disbursement: Platform fees, payment gateway charges, and transfer costs come off the top—beneficiaries receive net proceeds.

• Timelines are clear: We aim to disburse quickly but must balance speed with security checks.

• Delays happen sometimes: Bank processing times, compliance checks, or international transfers can cause delays—we keep you informed.

• You can track your donation: Beneficiaries must provide updates on fund utilisation.

PART B: LEGAL TERMS AND CONDITIONS #

1. DEFINITIONS #

For purposes of this Policy:

2. FUND FLOW ARCHITECTURE #

2.1 Donation Journey #

Contributor Makes Payment
        ↓
Payment Gateway Processes (2-5 days settlement)
        ↓
Funds Credited to UTSAV DAAN™ Escrow Account
        ↓
Funds Held in Escrow During Campaign Duration
        ↓
Campaign Ends (Target/Date based)
        ↓
Verification & Compliance Checks
        ↓
Deduction of Fees
        ↓
Disbursement to Beneficiary

2.2 Escrow Account Structure #

2.2.1 UTSAV DAAN™ maintains Escrow Accounts in key currencies and jurisdictions:

2.2.2 Segregation Certification: UTSAV DAAN™ obtains quarterly certification from its bankers confirming that Escrow Accounts contain only client funds and are not subject to lien or charge for company liabilities.

3. RECEIPT OF DONATIONS #

3.1 Payment Methods Accepted #

3.2 Transaction Confirmation #

3.2.1 Upon successful Contribution, Contributors receive:

• Email confirmation with transaction ID

• Contribution receipt (tax receipt where applicable)

• Campaign page updated with contribution (anonymized per preference)

• Option to download contribution certificate

3.2.2 Failed transactions receive notification with reason and resolution steps.

3.3 Pending and Failed Transactions #

3.3.1 Contributions showing as “pending” in Contributor’s account are not considered received until:

• Funds settle in Escrow Account; AND

• Transaction status confirmed by Payment Gateway

3.3.2 Failed transactions are automatically reversed. No funds are held for failed transactions.

4. HOLDING PERIOD AND FUNDS MANAGEMENT #

4.1 Holding Period Duration #

Funds remain in Escrow Account during:

4.2 Interest on Held Funds #

4.2.1 Any interest accrued on funds held in Escrow Account:

• Shall be retained by UTSAV DAAN™ as part of Platform operational costs

• Beneficiaries have no claim to interest earned during holding period

• Contributors have no claim to interest on their Contributions

4.2.2 This provision is disclosed to comply with applicable laws regarding client money and escrow arrangements.

4.3 Fund Protection Measures #

4.3.1 During holding period, UTSAV DAAN™ ensures:

• No access to funds by any party except for authorized disbursement

• Regular reconciliation of Escrow Account balances

• Segregated accounting records per Campaign

• Independent audit trail for all transactions

4.3.2 Funds are protected against UTSAV DAAN™ insolvency through statutory trust arrangements where available (UK Client Money rules, India SEBI escrow norms, etc.).

5. DISBURSEMENT PROCESS #

5.1 Pre-Disbursement Verification #

Before any disbursement, UTSAV DAAN™ conducts:

5.2 Fee Deduction Calculation #

5.2.1 From Gross Proceeds, UTSAV DAAN™ deducts:

5.2.2 All fees are disclosed on Campaign page before Contributions are accepted.

5.3 Disbursement Timeline #

5.4 Disbursement Methods #

5.5 Disbursement Confirmation #

5.5.1 Upon disbursement:

• Beneficiary receives confirmation with transaction reference

• Campaign page updated with “Funds Disbursed” status

• Contributors notified of milestone completion

5.5.2 Beneficiary must confirm receipt within [7] days. Unconfirmed receipts trigger follow-up.

6. DISBURSEMENT FAILURES AND UNCLAIMED FUNDS #

6.1 Disbursement Failure Reasons #

6.2 Unclaimed Funds Protocol #

6.2.1 If Net Proceeds remain undisbursed for [90 days] due to Beneficiary unavailability:

• UTSAV DAAN™ makes reasonable efforts to contact Beneficiary and Support Group

• Notice published on Campaign page

• Funds held for additional [90 days]

6.2.2 After [180 days] total, if Beneficiary cannot be located:

• UTSAV DAAN™ may donate unclaimed funds to a similar charitable cause

• Contributors notified of alternative disposition

• Records maintained for audit purposes

6.2.3 Beneficiary may claim funds up to [3 years] from disbursement failure. After 3 years, funds irrevocably applied per 6.2.2.

7. TAX COMPLIANCE #

7.1 Tax Deduction at Source (TDS) – India #

7.1.1 Under Indian Income Tax Act, 1961:

• TDS applicable on Platform Fees (as applicable)

• TDS on payments to Beneficiaries under Section 194C/194J where threshold exceeded

• TDS certificates issued to Beneficiaries

7.1.2 UTSAV DAAN™ provides Form 16A/26AS for TDS deducted.

7.2 GST (Goods and Services Tax) – India #

7.2.1 Platform Fees attract GST at applicable rate (currently 18%).

7.2.2 Tax invoices issued to Fundraisers/Beneficiaries.

7.3 International Tax Compliance #

7.4 Donor Tax Benefits #

7.4.1 UTSAV DAAN™ does not provide tax advice. Contributors should consult tax professionals.

7.4.2 Where Beneficiary is registered under Section 80G (India), receipts provided for donor tax benefit.

8. AUDIT AND RECONCILIATION #

8.1 UTSAV DAAN™ conducts:

• Daily reconciliation of Escrow Account vs. Platform records

• Monthly internal audit of disbursements

• Quarterly external audit of client money handling

• Annual statutory audit including Escrow verification

8.2 Audit reports available to regulators upon request. Not publicly available due to confidentiality.

PART C: JURISDICTION-SPECIFIC ADDENDUMS #

INDIA ADDENDUM #

RBI Guidelines:

• Escrow Accounts governed by RBI Master Direction on Escrow Accounts

• FCRA compliance mandatory for foreign contributions to Indian entities

• FEMA regulations for cross-border transfers

Tax Deduction:

• TDS under Section 194C for contracts, 194J for professional services

• Section 80G receipts only for registered beneficiaries

Payment Aggregator Guidelines:

• UTSAV DAAN™ complies with RBI guidelines on Payment Aggregators and Payment Gateways

UK ADDENDUM #

Client Money Rules:

• UTSAV DAAN™ complies with FCA Client Assets Sourcebook (CASS) for client money handling

• Statutory trust over client funds protects against insolvency

• Monthly client money reconciliation and reporting

Charity Commission:

• Campaigns for registered charities must comply with Charity Commission guidance on fundraising

US ADDENDUM #

State Disbursement Requirements:

• Certain states require professional fundraisers to register and file financial reports

• UTSAV DAAN™ monitors thresholds and registers where required

IRS Reporting:

• Form 1099-K for payment settlement entities (if thresholds met)

• Charitable organizations must provide donor acknowledgments for tax purposes

EU ADDENDUM #

PSD2 Compliance:

• Strong Customer Authentication (SCA) for electronic payments

• SEPA Instant Credit Transfer where available

AML Directives:

• Funds frozen pending enhanced due diligence where required

PART D: ENTERPRISE INTERNAL MANUAL #

For UTSAV DAAN™ Finance & Operations Teams #

A. Disbursement Approval Matrix #

B. Daily Reconciliation Checklist #

• Download Escrow Account statement

• Match all settled transactions to Platform records

• Investigate discrepancies > 0.1%

• Flag unreconciled items to Finance Manager

• Update Campaign escrow balances

• Document reconciliation sign-off

C. Disbursement Processing Schedule #

D. Fee Matrix (Internal Reference) #