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GOTHAM CITY RESEARCH LLC

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GOTHAM CITY RESEARCH LLC

EBIX: All Distraction, No Clarity

You can fool some of the people all of the time, and all of the people some of the time, but you cannot fool all of the people all of the time. Former President, Abraham Lincoln

Disclaimer: By reading this report, you agree that use of GOTHAM CITY RESEARCH LLCs (GCR) research is at your own risk. In no event will you hold GCR or any affiliated party liable for any direct or indirect trading losses caused by any information in this report. This report is not investment advice or a recommendation or solicitation to buy any securities. GOTHAM CITY RESEARCH LLC is not registered as an investment advisor in any jurisdiction. You agree to do your own research and due diligence before making any investment decision with respect to securities covered herein. You represent to GCR that you have sufficient investment sophistication to critically assess the information, analysis and opinion in this report. You further agree that you will not communicate the contents of this report to any other person unless that person has agreed to be bound by these same terms of service. You should assume that as of the publication date of this report, GOTHAM CITY RESEARCH LLC stands to profit in the event the issuers stock declines. We may buy, sell, cover or otherwise change the form or substance of its position in the issuer. GCR disclaims any obligation to notify the market of any such changes. Our research and report includes forward-looking statements, estimates, projections, and opinions prepared with respect to, among other things, certain accounting, legal, and regulatory issues the issuer faces and the potential impact of those issues on its future business, financial condition and results of operations, as well as more generally, the issuers anticipated operating performance, access to capital markets, market conditions, assets and liabilities. Such statements, estimates, projections and opinions may prove to be substantially inaccurate and are inherently subject to significant risks and uncertainties beyond GOTHAM CITY RESEARCH LLCs control. Our research and report expresses our opinions, which we have based upon generally available information, field research, inferences and deductions through our due diligence and analytical process. GOTHAM CITY RESEARCH LLC believes all information contained herein is accurate and reliable, and has been obtained from public sources we believe to be accurate and reliable. However, such information is presented as is, without warranty of any kind, whether express or implied. GCR, makes no representation, express or implied, as to the accuracy, timeliness, or completeness of any such information or with regard to the results to be obtained from its use. All expressions of opinion are subject to change without notice, and GOTHAM CITY RESEARCH LLC is not obligated to update or supplement any reports or any of the information, analysis and opinion contained in them. GOTHAM CITY RESEARCH LLC has filed as a whistleblower with the Internal Revenue Service and the Securities Exchange Commission.

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Table of Contents I. II. III. IV. V. VI. VII. Disclaimer Background Ebixs 2010 Singapore Long-lived Assets Still Dont Add No Clarity on the Undisclosed Related Party Loan to Singapore US and India Filings Contradict Rainas Confirmnet Explanation Lies of Omission, Unimportant Facts, and the Unverifiable EBIX All But Admits There is an On-going SEC Investigation

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GOTHAM CITY RESEARCH LLC


a "It is better to be roughly right than precisely wrong." John Maynard Keynes SUMMARY OF FACTS Robin Rainas Inaccurate Claims Ebix Singapore & Ebix Australias financial statements for 2009 do not support Rainas claim that an intercompany loan to Australia was moved to Singapore in 2009. The 2010 Singapore long-lived asset numbers are misstated by at least $67 million (94% of 2011 earnings), contrary to Robin Rainas claim that the numbers did not change. The 2010 Confirmnet acquisition cost inconsistency exceeds $5 million, while Ebixs total capital expenditures for 2010 was only $1.7 million. This falsifies Rainas claim that the irregularity is explained by investments made in Confirmnet by Ebix India. The unbilled receivables/deferred revenue error Raina pointed out doesnt change that (i) unbilled receivables are growing faster than overall receivables, (ii) reserve for doubtful accounts is shrinking and (iii) the inclusion of deferred revenue with receivables is unusual. Rainas Planetsoft & Australian revenue claims cant be verified without more information. Ebix did not file an 8K (nor provide any of the responses in writing), despite the fact that we identified very serious and material concerns relating to the company and the stock. When truth is replaced by silence, the silence is a lie. Yevgeny Yevtushenko SUMMARY OF FACTS Robin Raina Did Not Deny: Ebixs core business is declining, organic growth is negative, and its balance sheet is weak. Also, the company has never generated lasting free cash flow during Rainas tenure as CEO. The 2010 & 2011 10Ks were filed before the Singapore 2010 filing was signed off. None of the members of the board of directors reside in the United States, and none of the audit committee members seem fit to do their jobs. Less than 5% of Singapores intangible assets are IP-related, & the $66 million undisclosed related party loan seems to violate the arms-length principle, invalidating their tax strategy. The Robin Raina Foundations IRS filings are full of material accounting irregularities.

GOTHAM CITY RESEARCHS OPINIONS Ebixs stock should be halted immediately, as (i) the financial statements remain materially unreliable, inaccurate, and incomplete and (ii) Ebixs CEO appears to be intentionally misleading investors, rather than addressing the issues we and others have identified. We stand by all the opinions stated in our prior report. Rainas inaccurate statements, irrelevant story-telling, and lies of omission only serve to strengthen our beliefs. Market participants should avoid buying or holding Ebix shares.

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Background
On Thursday, February 21st, 2013, Gotham City Research released its first report on Ebix. In it, we explained in great detail why we believe (among other things)1: Ebixs financial statements are unreliable, inaccurate, and incomplete. Ebix will restate historical results, likely significantly. Ebixs stated tax strategy is a sham in fact, if not in substance. Cherry Bekaert Holland should not sign off on Ebixs 2012 financials, without Ebix Singapores 2011 and 2012 filings. Ebix shares are worth no more than $5.00/share, & approach $0.00 as the event risks unfold.

The company responded the next day with a weak press release, consisting of no more than a few sentences.2 Then last Tuesday, February 26, 2013, Ebix CEO Robin Raina held a conference call hosted by Craig Hallums Ebix analyst, Jeff Van Rhee3. The call initially sounded promising, as Raina seemed organized, detailed, & full of conviction. Unfortunately for Ebix shareholders, the responses turned out to be lacking both in form and in substance. For example: Rainas 30 second explanation regarding the Singapore loan is not supported at all by the Singapore or Australian filings. Its unsurprising that Raina spent 6 minutes discussing a 2008 intercompany loan to Australia, which is irrelevant to the undisclosed 2009 Singapore loan. He claimed that the presentation of long-lived assets changed, not the numbers. Yet the numbers clearly did change, and the Singapore irregularity alone equals 92% of 2011 earnings.

Not only were Rainas responses inaccurate, misleading, and/or irrelevant, he completely ignored some of the more serious concerns from our original report4: Ebixs core business is deteriorating and its balance sheet is weak. The companys stated tax strategy is a sham, as it is supported by transactions that served no economic purpose other than to minimize taxes. The Robin Raina Foundations IRS form 990 returns are full of material accounting irregularities.

We do acknowledge that Raina was absolutely correct about one thing: we mistakenly copied and pasted the wrong numbers onto the table shown on page 14 of our first report (specifically in the row titled Deferred rev included in A/R). It was an innocent mistake and has been corrected accordingly. This error does not, in any way, change the fact that Ebixs accounts receivables are of dubious quality. Nor does it change that there are a dozen equally, if not more important red flags that Raina did not address. For example, the numbers dont add, their tax strategy is a sham, internal controls are lacking, etc. As Keynes famously said: "It is better to be roughly right than precisely wrong." Please note: we have more, entirely new material in our possession that we may publicly release at any time. We urge all market participants to avoid buying or holding shares at all costs.

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Ebixs 2010 Singapore Long-lived Assets Still Dont Add


One of the main reasons we believe that Ebixs financial statements remain materially unreliable, inaccurate, and incomplete is the very large differences in the 2010 long-lived asset numbers. Namely: Ebixs 2010 long-lived assets dont add up, between the 2010 and 2011 10Ks. The Singapore irregularity alone is $67 million. This variance is nearly equal to Ebixs entire 2011 net income and over 10% of Ebixs market cap.

On the conference call hosted by Craig Hallum, Robin Raina addressed these points. He claimed that the numbers did not change between the 2010 and 2011 filings; only the presentation format changed. As a matter of fact, Mr. Raina is incorrect, as we prove in great detail: There actually is a very large variance in the numbers, between the 2010 and 2011 10Ks. The presentation changed (but this is an irrelevant fact).

Furthermore, Raina completely ignored other concerns we raised, relating to the long-lived assets: Not only do the 2010 numbers not agree between the 2010 and 2011 10Ks, neither match the number found in the Ebix Singapore 2010 filing1. 2011 long-lived assets on the balance sheet show one number, while Note 16 shows another. The 2010 and 2011 10Ks were filed before the 2010 Singapore filings were signed off.

Robin Rainas False Claims On Tuesday, February 26th, 2013, Jeff Van Rhee asked about the long-lived assets2: The point is, the 2010 10K states one number for the 2010 long-lived assets, and then in the 2011 10K, when 2010 is referenced, its a different number for the long-lived assets. Can you walk through how something like that can change, after it has originally been filed in a 10K? Robin Rainas full response: Jeff <laughter>, there is actually no variance in numbers. Just the presentation format changed between the two filings. The 2010 10K filing includes specific amounts for goodwill and intangibles. And then a separate amount for fixed assets and certain other long-lived assets. The 2011 10K had just, uses a different format in which we lump all the above together under the heading long-lived assets, meaning, that we aggregated the sum total of goodwill, intangibles, fixed assets, and some other assets together. The number in the 2010 10K filing, when aggregated together, would be exactly the same as the 2011 10K filing. So the presentation changed, not the numbers.

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The Numbers Changed, Contrary to Rainas Claim Otherwise The 2010 long-lived assets by geographic segment clearly did change between 2010 and 20113:
2010's Long-Lived Assets - As reported in the 2010 10K vs 2011 10K
thousands $ 2010 10K 2011 10K VARIANCE

The Americas Australia Singapore New Zealand India TOTAL

$98,190 $545 $134,993 $0 $0 $233,728

$169,833 $1,525 $67,781 $40 $3,339 $242,518

$71,643 $980 ($67,212) $40 $3,339 $8,790

Note 1: EBIX previously reported "goodwill and intangible assets" in note 16 by geographic segment in the 2010 10K. In the 2011 10K , EBIX reported "long-lived assets" in lieu of "goodwill and intangible assets". Despite the name change, they are substantially equivalent, as there are no material long-lived assets beyond goodwill and intangible assets. Note 2: In the 2010 10K, EBIX reported 'The Americas' whereas in the 2011 10K started to break out by specific region, i.e. US, Canada, & Latin America.

Straight from the 2010 10K (see highlighted):

Straight from the 2011 10K (see highlighted):

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The Change in the Presentation of Long-lived Assets Is Irrelevant While Robin Rainas claim that the numbers did not change is demonstrably false, he is correct in saying that the presentation changed. Unfortunately, it does not matter that the presentation changed. The reason is, most of Ebixs long-lived assets consist of Goodwill + Intangibles, as shown below4:

% Breakdown of Long-lived Assets by Type


2010 2011

Goodwill Intangibles, net Indefinite-lived intangibles SUB-TOTAL Property and equipment, net Deferred tax asset, net Other assets TOTAL

74.5% 9.3% 12.6% 96.4% 3.2% 0.0% 0.4% 100.0%

74.6% 11.1% 8.8% 94.4% 2.5% 2.7% 0.3% 100.0%

Long-lived Assets by Type 2010 thousands $ Goodwill $180,602 Intangibles, net $22,574 Indefinite-lived intangibles $30,552 Property and equipment, net $7,806 Deferred tax asset, net $0 Other assets $984 TOTAL $242,518

2011

$259,218 $38,386 $30,453 $8,834 $9,412 $1,062 $347,365

Possible Reasons Raina is Making False Claims About the Long-lived Assets: Gotham is not entirely sure why Raina made such blatantly false claims. The following express some of the more likely possibilities: Robin Raina is not fit to be CEO or Chairman, as his mathematical and accounting skills are woefully deficient (we doubt this explanation, as we believe Raina is a very intelligent man). The long-lived asset variance is one of the more obvious symptoms of the underlying problems, and Raina is desperately attempting to delay its unraveling. There is an explanation for the variances, and it would unravel Ebixs bogus tax strategy, rendering Ebix liable for over $100 million in back taxes, interest, and penalties. The explanation would reveal massive accounting irregularities, e.g. earnings overstatement.

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No Clarity on the Undisclosed Related Party Loan to Singapore


Gotham City Research has thoroughly examined Robin Rainas claims regarding the undisclosed related party loan to Ebix Singapore Pte Ltd, and believe Mr. Raina provided no answers, and plenty of distractions. We are particularly disturbed by the fact that Raina chose to talk about a 2007/2008 intercompany loan to Australia, rather than the 2009 undisclosed related party loan to Singapore. We believe the purpose of this was to distract investors. The following facts concern us: Rainas rather brief (30 second long) and cryptic claim as to how the 2008 intercompany loan to Australia was transferred to Singapore is not supported by the Singapore or Australian filings. The 2009 Singapore filing clearly shows an in-flow and out-flow of cash, in the statement of cash flows; these in-flows and out-flows, alone, do not support Rainas explanation. The 2009 Australian filing shows no in-flow or out-flow of cash, pertaining to the intangible asset sale to Singapore. This isnt consistent with the 2009 Singapore filing or Rainas claim. The 2007/2008 intercompany loan to Australia was a current liability; the 2009 Singapore loan is a non-current liability. Raina did not address our belief that the 2009 Singapore loan does not fit the criteria for an arms length transaction, rendering Ebixs tax benefits dubious.

As a result of the above mentioned facts, we believe: Raina provided irrelevant information, because the tax and accounting implications of the Singapore loan are just as bad, if not worse, than we originally identified. Raina is intentionally making false statements and providing irrelevant information in hopes that investors who dont verify his claims will buy or hold Ebix stock.

Ebix Singapores Statement of Cash Flows Dont Support Rainas Terse Explanation Robin Raina posed the following question: How did the loan move from Ebix Australia to Ebix Singapore?1 Raina then provided the following explanation: Ebix Singapore purchased certain assets and liabilities associated with the two acquisitions: namely, Hart Consulting and Telstra eBusiness from Ebix Australia. It accordingly acquired both the IP assets and the loan liability of Ebix Australia in October 2009. Does that answer your question? Jeff Van Rhee: <taken aback> Uh, it, it, it, does. I think it does. In more details than I was maybe even looking for I guess if I summarize your answer, youre saying all of the related party here were intercompany, these are not external, outside of the ebix-fold companies, but inter-company transactions. Is that accurate? Robin Raina answered: Jeff youre 100% accurate. Page 9 of 19

Ebix Singapores Statement of Cash Flows Doesnt Support Rainas Terse Explanation Ebix Singapores 2009 filing does not support Rainas explanation as the statement of cash flows from the 2009 financial statements, clearly show in-flows and out-flows of cash2:

Raina makes it seem as if Singapore merely assumed the intercompany loan yet the Purchase of intangible assets (Note 5) within the Cash flow from investing activities shows a clear out-flow of cash. Then the Proceeds from loan from a related company within the Cash flows from financing activity clearly shows an in-flow of cash. The Singapore filings do not show a mere move or transfer of assets and liabilities. It shows a purchase of intangible assets, with cash that originated from a loan. Remember: the size of this undisclosed loan was equal to, if not larger than Ebixs entire tangible assets in 2009.3 Ebix Australias Statement of Cash Flows Doesnt Support Rainas Explanation The Singapore filings clearly show an in-flow & out-flow of cash related to the purchase of intangible assets, & a loan that provided Ebix Singapore with the proceeds to purchase said assets. Oddly, Ebix Australias 2009 financial statements do not show any corresponding in-flow or out-flow of cash. Cash Flow From Operating Activities, for starters, does not show any transactions that support Raina4:

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Cash Flow From Investing Activities, also does not support Rainas claims:

Last, but not least, Cash Flow From Financing Activities, does not support Rainas claims:

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Raina Provides No Details on the $65.8 Million Undisclosed Related Party Loan to Singapore Not only is Mr. Rainas explanation not supported by Ebix Singapore and Ebix Australias filings, he did not provide any details about the undisclosed related party Singapore loan: Raina did not disclose which exact entity lent to Ebix Singapore in 2009. Raina did not explain who exactly received the proceeds of the loan, from Singapore. He did not reveal what the current status of the loan is. Note that the Ebix Singapore subsidiarys 2011 financial filing has yet to be filed5.

Raina Distracts Investors by Talking about the Intercompany Loan to Australia, Not Singapore GCR listened to and measured how much time Raina spent discussing the intercompany loan to Australia in 2008, instead of the undisclosed related party loan to Singapore in 2009. Out of the 6+ minutes he devoted to providing clarity on the Singapore loan, he spent only 30 seconds addressing the Singapore loan. The rest of the time he talked about an intercompany loan to Australia in 20086:

Rain provided: Time spent discussing: % of time spent discussing: When the loan took place:

AUSTRALIAN LOAN DETAILS 6 mins, 20 secs 92.1% 2008

SINGAPORE LOAN NO DETAILS 30 secs 7.9% 2009

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US and India Filings Contradict Rainas Confirmnet Explanation


In our first report, we pointed out the fact that the Confirmnet acquisition cost 30% more according to the India filings than it did according to the SEC filings (a difference that is nearly 10% of 2010 earnings). We expressed our belief that either the US SEC filings are correct, the India filings are correct, or neither are correct. Whatever the case, the clear implication here is that Ebixs financial statements are not reliable, accurate, or complete. Raina addressed our concern, with perceived clarity. Unfortunately, we find his explanation inconsistent with the facts. The following specifically concern us: Robin Raina claims that any variance between the US and India filings is explained by additional investments made in Confirmnet by Ebix india, towards growing their business. Yet Ebixs total capital expenditures for 2010 was only $1.7 million, or only 1/3rd of the variance in Confirmnet related investment spending (~$5 million) between the India and US filings. Raina completely avoided addressing our belief that the acquisition of Confirmnet (a San Diego based corporation) required repatriation of cash, given that Ebix India financed the transaction.

Given all these facts, GCR believes: Raina is not being truthful about the underlying cause of this variance. Ebix improperly avoided paying taxes on the Confirmnet acquisition, and avoided talking about the tax implications to draw attention away from their tax liability.

Robin Raina Claims GCR is Comparing Apples and Oranges Jeff Van Rhee asked Raina1: How about Confirmnet. You acquired Confirmnet and you quote a price in your SEC-based documented as to what you paid for it, but in the Indian documents, financial statements, he said you paid a different price. Hows the difference? Robin Rainas answer: <laughter> Jeff again, Were comparing apples and oranges here. In SEC filings in the US, the disclosure accounts for the acquisition price paid to the Confirmnet shareholders for the acquisition of Confirmnet, plus, additional payments to the former owners of Confirmnet in satisfaction of achieved earnout obligations. That is in-line with all customary SEC filings made for material acquisitions. Whereas, the Indian statutory filings state, the total investment made by Ebix India, in Confirmnet to this date, implying that the Indian filings state the sum total of the acquisition price paid to the Confirmnet shareholders, plus any additional investments made in Confirmnet by Ebix India after the acquisition date, in subsequent years, towards growing their business. This is in-line with local Indian filing requirements as per IFRS and as per Foreign Exchange Regulation Act.

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Ebixs 2010 Total Capital Expenditures of $1.7 Million Contradict Rainas Confirmnet Claims Between the US SEC filings and the India subsidiarys filings, Confirmnet-related spending is remarkably similar for 2008 and 2009. It is only in 2010 that the amounts wildly differ (by $5.2 million, or nearly 10% of Ebixs 2010 earnings2). Raina claims the variance is explained by additional investments made in Confirmnet by Ebix India after the acquisition date, in subsequent years, towards growing their business. Yet Ebixs total capex for 2010 is only $1.7 million, or less than 1/3rd of the variance3:

2008 and 2009 Confirmnet-related Spending Suggests Gotham is Comparing Apples and Apples Raina claims that we are comparing apples and oranges yet 2008 and 2009s numbers are remarkably similar, which suggests that Gotham is actually comparing apples to apples4:

Total Cost of Confirmnet Acquisition: the SEC Filings vs. the Indian Filings 2008 2009 2010 Investment in Confirmnet SEC FILINGS (in 1,000s $) $7,294 $3,279 $2,975 INDIA FILINGS (in 1,000s $) $7,526 $3,310 $8,233 INDIA FILINGS (in 1,000s Rupees) 361,849 153,965 367,532 From India Balance Sheet INDIA FILINGS (in 1,000s $) $7,237 $10,316 $17,667 INDIA FILINGS (in 1,000s Rupees) 361,849 515,814 883,346 Assume the INR USD is 0.0208, 0.0215, and 0.0224 for year end 2008, 2009, and 2010 respectively.

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Lies of Omission, Unimportant Facts, and the Unverifiable


When truth is replaced by silence, the silence is a lie. Yevgeny Yevtushenko As convincing as Robin Raina may have sounded to some listeners, his explanations were inaccurate, irrelevant, unimportant, and/or unverifiable. Rainas inaccurate and irrelevant claims have already been thoroughly dissected in this report. Equally, if not more importantly however, Raina completely avoided talking about the following matters (among other things): Ebixs tax strategy is a sham (in fact or in substance), and was supported by transactions that served no other purpose but to avoid taxes. The 2011 long-lived assets dont add. Ebixs internal controls have weakened even as Ebix has grown in size and complexity, as a result of its serial acquisitions. The Robin Raina Foundations IRS filings are materially unreliable, inaccurate, and incomplete. Ebixs Board of Directors (and specifically its audit committee) is not based in the United States nor are they qualified to do the job.

Instead of providing accurate answers with concrete details, Raina instead ignored the abovementioned and spent most of his time making false, irrelevant, and/or unimportant statements1:

Breakdown of the Conference Call by Topic in minutes and % of time spent Accounts receivable 8 27.6% Robin Raina Foundation 7 24.1% Australian Loan 5 17.2% Jeff Van Rhee Intro 2 6.9% Australian revenues 2 6.9% Confirmnet 2 6.9% Planetsoft cash repatriation 2 6.9% 2010 Long-lived assets 1 3.4% TOTAL 29 100.0%
As shown above, Raina spent nearly 75% of the call talking about irrelevant & unimportant matters: Raina spent nearly 28% of the entire call (i) reciting accounting textbook definitions and (ii) pointing out our copy/paste error. He didnt explain why (i) unbilled receivables have been rising faster than overall receivables, (ii) allowance for doubts is shrinking, and (iii) why the inclusion of deferred revenue within accounts receivable is justified, given how unusual it is. Raina spent nearly 25% of the entire call describing his charitable activities, but did not deny nor address that there are material accounting irregularities found in his Foundations IRS filings . He spent 17% of his time describing an Australian loan, not the undisclosed Singapore loan.

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Ebixs response via the Craig Hallum conference call comes with the following red flags: The Craig Hallum conference call did not accommodate all listeners (many were rejected). Rainas responses were never issued in writing, nor were any supporting documents released. Ebix did not issue an 8K filing or press release, despite the materiality of the events. CFO Robert Kerris & the other members of management did not speak at all during the call.

Planetsoft: No Way to Verify Rainas Claims Without Indian + Singapore Filings As this report clearly shows, Raina made many false statements and provided irrelevant information in lieu of providing clarity and details. As a result, Rainas trustworthiness is questionable. This means that his claims cannot be trusted on his words alone; rather, they must be verified by source documents. We believe the following explanation regarding Planetsoft must be verified2: <laughter> No money was repatriated from the US for the purchase of Planetsoft. Planetsoft owned two companies, one in the US and one in India. Planetsoft was primarily based in India with 500 employees in India, and around 30+ employees in the US. Ebix India directly acquired Planetsoft India through an asset purchase agreement called a business transfer agreement in India. Ebix India directly acquired all the Planetsoft India assets and accordingly directly paid Planetsoft India for the purchase. As is mandated by our agreement with the Singapore governments economic development board, Ebix Singapore directly purchased the IP assets from Planetsoft owners and paid directly for it. Ebix US purchased all the customer contracts and customer relationship by directly paying Planetsoft owners for it. Ebix US funded its part of the purchase by using its internal cash reserve and the bank credit line. We need the following (at least) to verify his above claims: Ebix Singapores 2011 and 2012 filings (Ebix Singapore has yet to file its 2011 filings). Ebix Indias 2011 & 2012 filings. Planetsofts financial statements, both of the parent and the Indian subsidiary.

Robin Raina Claim that the South Asia Times Misquoted Him is Dubious The following is a direct excerpt from the South Asia Times3: South Asia Times: How much you give to the foundation? What is its annual outlay? Robin Raina: I hate to talk about it. But yes, a majority of the money that comes in for the foundation comes from me. In a given year, RRF will typically spend about $2 million. Rainas claim that he meant revenue does not pass the smell test, as it would suggest that not only was his response misquoted, but that he misunderstood the clear and direct, two-part question that the South Asia Times asked him. His claim is particularly dubious considering he never denies our more serious concern (which technically has legal implications): the Robin Raina Foundations tax returns are full of material accounting Irregularities.4 Page 16 of 19

EBIX All But Admits There is an On-going SEC Investigation


Ever since Bloomberg news first broke the story that there is an on-going SEC investigation, there has been debate and controversy over whether there actually is an SEC investigation. The following summarizes the publicly available claims: November 5th 2012: Bloomberg news claims there is an SEC investigation, citing four people1. November 5th 2012: Ebix claims they are unaware of one and had not been advised of one2. February 21st 2013: The SEC investigation is on-going, according to Bloomberg news3. February 22nd 2013: CFO Robert Kerris says the company is not the subject of any investigation related to statements in the Seeking Alpha article4.

Note the following: Neither CFO Kerris nor anyone at Ebix currently denies there is an on-going SEC investigation. CFO Kerris statement does not claim there is no on-going SEC investigation, nor does it suggest that Ebixs management is unaware of one. No one other than CFO Kerris has recently commented on the alleged SEC investigation.

February 22nd, 2013: November 5th 2012: Ebix is being investigated by the U.S. Securities and Exchange Commission for its accounting practices, four people with direct knowledge of the probe said. November 5th 2012: The Ebix senior management team has not been advised of nor is it aware of an any SEC investigation regarding the Companys previous filings. In November, Bloomberg News reported that the SEC had been investigating Ebixs accounting practices. That investigation, conducted by attorneys in the SECs Atlanta office, is continuing, said a person who had been interviewed about Ebix in recent weeks. February 22nd , 2013: Ebix CFO Robert Kerris Says Company is Not the Subject of Any Investigation Related to Statements in Seeking Alpha Article.

Memo to Ebix and Robin Raina: Is there, or isnt there, an SEC investigation, Led by the Enforcement Division (not Corporate Finance) based out in Atlanta, Georgia? Investors deserve a clear answer.

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End Notes
Background 1. THE TRUTH ABOUT EBIX, ROBIN RAINA, AND THE ROBIN RAINA FOUNDATION, Gotham City Research, February 21st, 2013 2. Ebix press release, Ebix responds to Seeking Alpha blog, February 22nd, 2013 3. Ebix, Conference Call Hosted by Craig Hallum, February 26th 2013 http://www2.eintercall.com/moderator/presentation/Playback?id=d3ce21a7-a3e9-4e59-92fd98a83ce7eeab.rpm 4. THE TRUTH ABOUT EBIX, ROBIN RAINA, AND THE ROBIN RAINA FOUNDATION, Gotham City Research, February 21st, 2013 Ebixs 2010 Singapore Long-lived Assets Still Dont Add 1. THE TRUTH ABOUT EBIX, ROBIN RAINA, AND THE ROBIN RAINA FOUNDATION, Gotham City Research, February 21st, 2013 2. Ebix, Conference Call Hosted by Craig Hallum, February 26th 2013 http://www2.eintercall.com/moderator/presentation/Playback?id=d3ce21a7-a3e9-4e59-92fd98a83ce7eeab.rpm 3. Ebix 2010 and 2011 10Ks 4. No Clarity on the Undisclosed Related Party Loan to Singapore 1. Ebix, Conference Call Hosted by Craig Hallum, February 26th 2013 http://www2.eintercall.com/moderator/presentation/Playback?id=d3ce21a7-a3e9-4e59-92fd98a83ce7eeab.rpm 2. Ebix Singapore PTE LTD Report of the Directors and Financial Statements for the financial year ended 31 December 2009, obtained via a Singapore contact via the ACRA website: http://www.acra.gov.sg/ 3. Ebix 2009 10K 4. Ebix Australia (VIC) Pty Ltd, Annual Financial Report for the Financial Year Ended 2009, filed with the ASIC http://www.asic.gov.au/ 5. THE TRUTH ABOUT EBIX, ROBIN RAINA, AND THE ROBIN RAINA FOUNDATION, Gotham City Research, February 21st, 2013, and http://www.acra.gov.sg/ 6. Ebix, Conference Call Hosted by Craig Hallum, February 26th 2013 http://www2.eintercall.com/moderator/presentation/Playback?id=d3ce21a7-a3e9-4e59-92fd98a83ce7eeab.rpm

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US and India Filings Contradict Rainas Confirmnet Explanation 1. Ebix, Conference Call Hosted by Craig Hallum, February 26th 2013 http://www2.eintercall.com/moderator/presentation/Playback?id=d3ce21a7-a3e9-4e59-92fd98a83ce7eeab.rpm 2. THE TRUTH ABOUT EBIX, ROBIN RAINA, AND THE ROBIN RAINA FOUNDATION, Gotham City Research, February 21st, 2013, and Ebix India subsidiarys filings 3. Ebix 2010 10K 4. THE TRUTH ABOUT EBIX, ROBIN RAINA, AND THE ROBIN RAINA FOUNDATION, Gotham City Research, February 21st, 2013, and Ebix India subsidiarys filings Lies of Omission, Unimportant Facts, and the Unverifiable 1. Ebix, Conference Call Hosted by Craig Hallum, February 26th 2013 http://www2.eintercall.com/moderator/presentation/Playback?id=d3ce21a7-a3e9-4e59-92fd98a83ce7eeab.rpm 2. 3. The South Asian Times, Vol. 5 | No. 37 | January 5-11, 2013 4. THE TRUTH ABOUT EBIX, ROBIN RAINA, AND THE ROBIN RAINA FOUNDATION, Gotham City Research, February 21st, 2013 EBIX All But Admits There is an On-going SEC Investigation 1. Greg Farrell, Bloomberg News, Ebix Accounting Practices Said to Be Probed by SEC, Nov 7, 2012 http://www.bloomberg.com/news/2012-11-05/ebix-accounting-practices-said-to-be-probed-bysec.html 2. Ebix press release, Ebix Responds to Bloomberg Article, Nov 5, 2012, http://www.ebix.com/pressrelease_text.aspx?artid=252 3. Greg Farrell, Bloomberg News, Ebix Drops After Report on Singapore Related-Party Loan, February 21, 2013 http://www.bloomberg.com/news/2013-02-21/ebix-drops-after-report-onsingapore-related-party-loan.html 4. Charles Gross, Benzinga, Ebix CFO Robert Kerris Says Company is Not the Subject of Any Investigation Related to Statements in Seeking Alpha Article, http://www.benzinga.com/news/13/02/3358247/ebix-cfo-robert-kerris-says-company-is-notthe-subject-of-any-investigation-relat#ixzz2MJ0DI1Tv

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