ECSIN - When Form DIR-12 not filed

Amended regulation says about, Employed whether as CS or OTHERWISE,Now otherwise can be understood in two way -one ,who has been appointed as Compliance officer /Group CS for which GNL-2 filed or any kind of post even Executive , as per my view, you should generate ECSIN, for more clarification email to ecsin @ icsi.edu ,However ICSI should come up with proper guideline, that up-to what extent "Otherwise " can be extended...