Private placement threshold: companies must offer investor refund option with interest and verified documentation to avoid penal action. Companies that issued securities before April 01, 2014 to more than forty-nine but up to two hundred persons may avoid penal action by offering affected investors the option to surrender securities for a refund not less than the subscription money paid plus interest or any higher promised return; refunds must be effected through banking channels, supported by proof of dispatch/delivery of offer letters, extendable to current holders on transfer, allow adjustment of prior interest/dividend payments, and be certified by an independent peer reviewed practicing Chartered Accountant after documentary verification.