BOARD APPROVED FAIR PRACTICES CODE FOR THANVIR BROS. PVT. LTD.

Revision Date 03.06.2024

Pursuant to Reserve Bank of India (RBI)'s direction RBI/DNBR/2016-17/44 Master Direction No.  NBR.PD.007/03.10.119/2016-17 dated 01/09/2016 and RBI/DoR/2023-24/106  DoR.FIN.REC.No.45/03.10.119/2023-24 dated 19/10/2023 (as updated from time to time) issued to Non-Banking Financial Companies (NBFCs), the Board of Directors have adopted the Fair Practices Code vide its Board Meeting dated 03/06/2024.

The Fair Practices Code, as adopted herein below by Thanvir Bros. Pvt. Ltd. (The Company), is in conformity with the Guidelines on Fair Practices Code for NBFCs as prescribed by the Reserve Bank of India and as contained in the aforesaid RBI Circular. It provides information to customers and explains how the Company is expected to deal with them on a day to day basis.

This policy applies to all customers including those with any complaints / enquiries as posted on social / any other media.

OBJECTIVES & APPLICATION

  • To promote good & fair practices by setting reasonable Standards in dealing with Customers.
  • To increase transparency so that the Customers can have better understanding of what they
    can reasonably expect of the Services and take informed decisions.
  • To encourage market forces, to achieve higher Operating standards.
  • To promote a fair & cordial relationship between Customer & the Company.
  • To promote Customer first and provide better Customer Satisfaction and Services.
  • Building customer confidence in the company  

APPLICATION OF THE FPC

The Code applies to all the Products & Services offered by The Company and all the offices and all employees of The Company or its associates or agents (as per respective applicability).

TO ACT FAIRLY AND IN A TRANSPARENT MANNER

  • The Company shall act fairly and reasonably in all dealings with Customers by ensuring that:
    • The commitments and standards prescribed in this Code are met for all Products, Services, Procedures, & Practices.
    • Company’s Products & Services meet relevant Laws & Regulations in letter & spirit.
    • Company’s dealings with Customers rest on the Ethical Principles of Integrity & Transparency
  • Company will transparently disclose to the applicants/borrower all information including fees / charges payable for processing the loan application, the amount of fees refundable if loan amount is not sanctioned / disbursed, pre-payment options and charges, if any, penalty for delayed repayment, if any, conversion charges for switching loan from fixed to floating rates or vice-versa, existence of any interest reset clause and any other matter which affects the interest of the borrower. Presently the company will not charge any non-refundable loan application fees incase the customer don’t accept the sanction terms offered by the company.
  • The Company will disclose ‘all in cost’ inclusive of all charges involved in processing / sanction of loan application and charges applicable thereafter in a transparent manner. The Company ensures that such charges/ fees are non-discriminatory.
  • The company can engage Direct Sales Agents / Agencies/ Collection Agents/Agencies/ IT vendors for smooth customer sourcing, management and collections, however no outsourcing agencies can guarantee any loan amount and underwriting can be done by the company alone. Further customer will be made aware about all such engagement for their respective loans.
  • The company may assign/ sale the qualifying loans to allow Companies.

The company follows the following procedure in true spirit:

  • All the communications with the proposed customer/borrower will be either in English or the vernacular language as understood/preferred/agreed by the proposed customer /borrower.

I.             Applications for loans and their processing

a)            The Application Form of the company for products/services offered by the Company is different depending upon the requirement of each product/services and will indicate list of information/documents that is required to be submitted by the Borrower with loan application based on product selected by the customer. Loan application forms will include necessary information which affects the interest of the borrower (so that a meaningful comparison with the terms and conditions offered by other Bank/NBFC/FI’s can be made) and informed decision can be taken by the borrower.

b)            Acknowledgement receipt of all loan applications will be issued with indicative time frame for disposal of application being received.

II.            Loan appraisal and terms/conditions

  1. The company will convey in writing to the borrower by means of sanction letter or otherwise, the amount of loan sanctioned along with terms and conditions including Annualized rate of interest (ROI) and method of application of ROI. Also all the fees are mentioned on Annualised Percentage Rate and the contingent payments like the Panel Charges applicable on default will be mentioned in bold in the loan agreement.
  2. All major fixed fees , Rate of Interest and Contingent event based fees like delay charges and panel charges will be also mentioned on Annualised Percentage Rate  (wherever possible) in Key Fact Statement (as per Annexure 1) and Sanction letter & also loan agreement.
  3. All the Contingent charges will be calculated on outstanding / default amount whichever is lower.
  4. A copy of the loan agreement as understood/agreed by the borrower along with a copy each of enclosures quoted in the loan agreement will be furnished to all the
    borrowers at the time of disbursement of loans by email/same mode used for application of loan.
  5. The company will send a communication of rejection of Loan Application to the customer along with the reason(s) for rejection.

III.           Loan Sanction / Disbursement and changes in terms and conditions

  1. Sanction letter along with Key Fact Statement (KFS) shall be communicated to the borrower in the language accepted / understandable by the borrower and will be valid for the days mentioned thereon.
  2. Loan disbursement will be made in accordance with the disbursement schedule as per sanction terms and as agreed/accepted by the borrower.
  3. All loan disbursements and repayments shall be executed strictly between the bank accounts of the borrower and the Company, without any pass-through or pooling account of any third party.
  4. Customers would be informed regarding changes to Terms & Conditions including disbursement schedule, interest rates, service charges, prepayment charges, other applicable charges etc.
  5. Notice to the borrower of any change in the terms and conditions including disbursement schedule, interest rates, processing charges, prepayment charges, etc. will be furnished by same mode by which borrower was communicated Sanction / Disbursement / Loan Agreement.
  6. Any changes in interest rates and charges are affected only prospectively giving due notice.  Suitable condition in this regard will be incorporated in the loan agreement of customers.  If such change is to the disadvantage of the Customer, he / she may within 60 days & without Notice close his / her Account or switch it without having to pay any extra charges or interest
  7. Decision to recall / accelerate payment or performance under the agreement
    will be in consonance with the respective loan agreement.
  8. In cases where company holds Security documents/ Interest, the Company will release all securities on repayment of all dues or on realization of the outstanding amount of the loan subject to any legitimate right or lien for any other the company claim may have against borrower. If such right of set off is to be exercised, the borrower will be given notice about the same with full particulars about the remaining claims and the conditions under which the Company is entitled to retain the securities till the relevant claim/all dues of the Company is settled/ paid.
  9. No objection certificate will be issued to the borrower/customer on repayment of all dues within 30 workings days of completion of payment including all charges/fees, if applicable, as per the product type and will be sent to borrower though medium used for application of loan/email, unless otherwise requested by borrower/customer.
  10. Release of Original Property Documents and Charges :
    1. All the original movable / immovable property documents and charges from registry will also be removed within a period of 30 days after full repayment/settlement of the loan account.
    1. The borrower to be given the option of collecting the original movable/ immovable property documents either from the branch where the loan account was serviced or any other office of the NBFC where the documents are available, as per her/his preference and will be mentioned on the sanction letter.
    1. In order to address the contingent event of demise of the sole borrower or joint borrowers, company have a well laid out procedure for return of original movable/immovable property documents to the legal heirs. Such procedure is displayed on the website of the company under policies tab, along with other similar policies and procedures for customer information.
    1. Compensation for delay in release of movable/immovable property documents

(i) In case of delay in releasing of original movable/immovable property documents or failing to file charge satisfaction form with relevant registry beyond 30 days after full repayment/ settlement of loan, we shall communicate to the borrower reasons for such delay. In case where the delay is attributable to us, we shall compensate the borrower at the rate of Rs. 5,000 for each day of delay.

(ii) In case of loss/damage to original movable/immovable property documents, either in part or in full, we shall assist the borrower in obtaining duplicate/certified copies of the movable/immovable property documents and shall bear the associated costs, in addition to paying compensation as indicated at clause (ii) above. However, in such cases, an additional time of 30 days will be available to the us to complete this procedure and the delayed period penalty will be calculated thereafter (i.e., after a total period of 60 days).

(iii) The compensation provided under these directions shall be without prejudice to the rights of a borrower to get any other compensation as per any applicable law.

IV.          General terms and condition of loan

a)            The Company will refrain from interference in the business affairs of the borrower except for the purposes provided in the terms and conditions of the loan agreement. However, the company may enquire/call for information to its satisfaction/ interfere incase new information, not earlier disclosed by the borrower and has come to the notice of the Company post sanction / disbursement of loan.

b)            In case of receipt of request from the borrower for transfer of borrower
account, the consent or otherwise i.e. objection shall be conveyed within 21 days from the date of receipt of request. Such transfer will be as per transparent contractual terms in consonance with all the applicable laws.

c)            In the matter of recovery of loans, the Company will not resort to undue
harassment viz. persistently bothering the borrowers at odd hours, use of muscle
power for recovery of loan, etc. The staffs will be adequately trained to deal with
the customers in an appropriate manner. Steps will be taken to ensure adherence to the same and number of complaints received towards harassment or rude behaviour or similar bad recovery processes will be brought to notice of the senior management of the company.

d)            The Company will not charge foreclosure / pre-payment penalties on all floating rate loans sanctioned to individual borrowers for purposes other than business with or without co-obligant(s) and such terms will be clearly be spelled out in the sanction/disbursement documents. 

V.            Board Approved policy towards Grievance Redressal Mechanism & Grievance Redressal Officers:

In the present competitive scenario, excellent customer service is an important tool for sustained business growth. Customer complaints are part of the business life in any corporate entity.

At the company, customer service and satisfaction are our prime focus. We believe that providing prompt and efficient service is essential not only to attract new customers, but also to retain existing ones. The Company has come up with a lot of initiatives that are oriented towards providing a better customer experience and an efficient complaints redressal mechanism with a view to providing enhanced experience to our customers.

To make the companies redressal mechanism more meaningful and effective, a structured system has been built. This system would ensure that the redressal sought is just and fair and is within the given frame-work of rules and regulation.

a)            The Company has laid down the appropriate grievance redressal mechanism within the organization to resolve disputes arising out of various lending decisions/customer complaints. Such a mechanism ensures that all disputes/complaints arising are heard and disposed of at least at the next higher level.

b)            The Board of Directors will also periodically review the compliance of the Fair Practices Code and the functioning of the grievance’s redressal mechanism at various levels of management. A consolidated report of such reviews will be submitted to the Board of Directors at regular intervals, once in a year or as may be prescribed by it from time to time.

c)            Response to a complaint would be given within a period of one month from the date of complaint, unless the nature of complaint requires verification of facts and figures.

d)            The company will ensure that the following Grievance Redressal Mechanism with Officers details is being displayed at a prominent location of the company for benefit of the customers including its website:

Customers including persons with disabilities are free to bring any Grievance against the company, its employees or its authorised agents to the notice of the following officers which will be dealt in best possible manner.

Customers who wish to provide feedback or send in their complaint may use the following channels:

  • Call on 94776 64928
    • Email us on cc@ thanvirbros.in
    • Write to us at the below mentioned address

Grievance Redressal Team
Thanvir Bros. Pvt. Ltd.

Flat No 43, 1st Floor, Palace court, 1 kyd street, Kolkata 700016

In case the complaint is not resolved within a period of one month or if he/she is not satisfied with the solution provided by the Company, the customer can approach the Complaints Redressal Officer as per followings:

First Level of Grievance Redressal Officer/ Fintech Grievance Officer:

a) Name of Grievance Redressal Officer/ Fintech Grievance Officer – Sumit Bhansali

b) Telephone Number –94776 64928

c) Email Id – cc@thanvirbros.in 

In case the complaint is not resolved within a period of one month or if he/she is not satisfied with the solution provided, the customer can approach

Second Level Grievance Redressal Officer:

a) Name of Grievance Redressal Officer/ Nodal Officer - Binod

b) Telephone Number –94776 64928

c) Email Id – escalation1@ thanvirbros.in

In case the complaint is not resolved within a period of 15 days or if he/she is not satisfied with the solution provided, the customer can approach

Final Level: Nodal Officer –94776 64928/ nodal@ thanvirbros.in

If the complaint/ dispute is not resolved within 1 month customer may prefer appeal at:

  1. The Officer In-Charge, Consumer Education and Protection Cell

Reserve Bank of India 15, Netaji Subhas Road Kolkata-700 001           

The grievance redressal mechanism will also resolve issues related to services provided by outsourced agencies. The process of the complaint’s redressal unit will ensure closure of all complaints to the customers’ satisfaction. They will ensure that the complaint is escalated to the appropriate levels in case it is not possible to resolve at his/her level. Whilst the ultimate endeavour is to ensure we reach a situation where our customers don’t have to complain to senior management to get an effective redressal, we have put in a robust mechanism to handle these complaints, review them from a point of view of understanding reasons for the complaint and for the escalation and working on prevention of recurrence thereof.

VI.          Regulation of Interest to be charged from the borrower.

  • At the time of availing of a loan, the Company will provide the borrowers with information on the annualised interest rate payable by them and adhere to it.
  • The loan agreement will contain sufficient information about interest, charges, approach followed by the company towards grading of risks and rationale and other important information.
  • If Company increases any charges or introduces a new charge, shall notify the same to the borrowers and will also be placed on the website of the company and it will be applicable prospectively.
  • The company will not charge excessive interest than allowed by the regulator at any point of time.
  • Copy of Board approved policy document adopting the interest rate model taking into account the relevant factors such as cost of funds, margin and risk premium to determine rate of interest to be charged for loans, Interest rate application as per gradation of risk and rationale for charging different rate of interest to different categories of borrowers are mentioned on interest rate model followed the company and is communicated to the borrower along with Sanction letter and also available on website of the NBFC.
  • Unpaid Interest will be compounded based on period rest mentioned in the agreement, and incase it’s not mentioned it will be with monthly rests.
  • No component in name of Interest of any type will be brought for non-adhering to terms and condition of loan.
  • Reset on floating interest rate on Equated Monthly Instalments (EMI) based loans
    • At the time of sanction of EMI based floating rate loans, the company will consider the repayment capacity of borrowers to ensure that adequate headroom/margin is available for elongation of tenor and/or increase in EMI, in the scenario of possible increase in the external benchmark rate during the tenor of the loan. Further the following terms will be ensured in sanction:

(i) At the time of sanction, we shall clearly communicate to the borrowers about the possible impact of change in benchmark interest rate on the loan leading to changes in EMI and/or tenor or both. Subsequently, any increase in the EMI/ tenor or both on account of the above shall be communicated to the borrower immediately through appropriate channels.

(ii) At the time of reset of interest rates, we shall provide the option to the borrowers to switch over to a fixed rate as per our Board approved policy including specification for the number of times a borrower will be allowed to switch during the tenor of the loan.

(iii) The borrowers shall also be given the choice to opt for (a) enhancement in EMI or elongation of tenor or for a combination of both options; and, (b) to prepay, either in part or in full, at any point during the tenor of the loan. Levy of foreclosure charges/ pre-payment penalty shall be subject to agreement at the time of sanction.

(iv) All applicable charges for switching of loans from floating to fixed rate and any other service charges/ administrative costs incidental to the exercise of the above options shall be transparently disclosed in the sanction letter and at the time of revision of such charges/ costs from time to time.

(v) It will be ensured that the elongation of tenor in case of floating rate loan does not result in negative amortisation.

(vi) Company shall share/ make accessible to the borrowers, through appropriate channels, a statement at the end of each quarter, enumerate the principal and interest recovered till date, EMI amount, number of EMIs left and annualized rate of interest/Annual Percentage Rate (APR) for the entire tenor of the loan. All the statements will be simple and easily understood by the borrower.

  • Apart from the equated monthly instalment loans, these instructions would also apply to all equated instalment-based loans of different periodicities.
    • the instructions should be extended to the existing as well as new loans. All existing borrowers shall be sent a communication, through appropriate channels, intimating the options available to them.

VII.         Other Terms

  1. Panel/Other Charges on Loan account:
    1. Any contingent charges, for non-compliance of material terms and conditions of loan contract by the borrower will be treated and charged as penal charges and such charges will not be capitalised or no further interest will be charged on such fees or charges.
    1.  The quantum of penal charges will be reasonable and commensurate with the non-compliance of material terms and conditions of loan contract without being discriminatory within a particular loan/product category.
    1. The penal/other charges in case of loans sanctioned to Individual borrowers, for purposes other than businesses, shall not be higher than the penal charges to non-individual borrowers for similar non-compliance of material terms and conditions.
    1. All the panel charges and fees will be communicated to customer beforehand and written in Sanction Letter and KFS.
    1. Any fees, charges, etc. which are not mentioned in the KFS, will not be charged to the borrower at any stage during the term of the loan, without explicit consent of the borrower.
    1. Whenever reminders for non-compliance of material terms and conditions of loan are sent to borrowers, the penal/other charges /fees shall be communicated. Further, any instance of levy of penal/other charges and the reason therefor shall also be communicated to borrower.
    1. Present Fair Practice Code will be inclusive of policy on panel / other fees and charges charged and no additional policy for the same will be made.
    1. The KFS shall also be included as a summary box/annexure to be exhibited as part of the loan agreement.
  2. The Company is not yet financing loan again vehicles. Once the company starts vehicle finance product, it shall immediately update the FPC and include the terms and condition and procedure for repossession of vehicle against financed loan.
  3. The company is not yet lending to individual against gold as security, once any such                 loan product is announced by the company, it shall adopt gold lending guideline in the FPC.
  4. Loan facilities to the physically/visually challenged:

Company shall not discriminate in extending products and facilities including loan facilities to physically/visually challenged applicants on grounds of disability. All branches of NBFCs shall render all possible assistance to such persons for availing of the various business facilities. Company will include a suitable module containing the rights of persons with disabilities guaranteed to them by the law and international conventions, in all the training programmes conducted for their employees at all levels.

VIII.        Customer’s Data Confidentiality

The company might collect data from customer which it feels are necessary for processing the loan based on nature of product it offers. The Loan Application process/ Form will capture details of all such requirement and copy of such data being taken/captured with company from customer will be made available as part of loan agreement/ annexure thereon. All personal information of present and past customers will be treated as private and confidential. The Company will not reveal information or data relating to customer accounts, whether provided by the customers or otherwise, to anyone, other than in the following exceptional cases:

  1. If the information is to be given by law
  2. If there is a duty towards the public to reveal the information.
  3. If Company’s interests require them to give the information to prevent fraud etc. Customer’s information shall not be given to anyone for marketing purposes except with his/her permission.
  4. If the Customer asks Company to reveal the information, or with the Customer’s permission.
  5. If Company is asked to give a reference about a Customer, the Company will obtain his / her written permission before giving it.
  6. If the Customer account is due / in default than his data will be shared with respective Collection Agent / Agency/Loan Service Provider hired by the NBFC on need to know basis. Information of such agent / agencies who are / will be authorised by the NBFC will be sent to the customer by email/sms/whatsapp/letter and list of all such agencies will also be made available on the website of the nbfc i.e. www.thanvirbros.in
  7. NBFC will share Customer data and information including Loan, repayment track and history with Credit Bureaus. Any default / due amount will also be informed which may impact the credit score / customer’s ability to get credit from others. Customer can seek information being sent to credit bureau agencies from NBFC by writing to customer care email id. 

IX.           Collection of Dues

  1. Whenever loans are given, the Company will inform to the customer and also include in Sanction letter the repayment process by way of amount, tenure and periodicity of repayment.
  2. The Company will also inform to the customer that on non-adherence to repayment schedule, all the actions in accordance with the laws of the land for recovery of dues such as reminding the customer by sending him / her notice or by making personal visits and / or take all legal steps for repossession of security (if any).
  3. Company’s Collection Policy is built on courtesy, fair treatment & persuasion. Company believes in fostering customer confidence & long-term relationship. Company’s Staff or any person authorized to represent in collection of dues or / & security repossession shall identify himself / herself & display the Authority Letter issued by Company & upon request, display his / her Identity Card issued by the Company or under authority of the Company. Company shall provide Customers with all the information regarding dues & shall endeavour to give sufficient Notice for payment of dues.
  4. The Company will provide customers with all the information regarding dues and on case to case basis give sufficient notice for payment of dues.
  5. All the members of the staff or any person authorized to represent the Company in collection or / and security repossession should follow the guidelines set out below:
  6. Customer would be contacted ordinarily at the place of his / her choice and in the absence of any specified place at the place of his / her residence and if unavailable at his / her residence, at the place of business / occupation, from reference if customer is not reachable on contact details available with the Company.
  7. Identity and authority to represent the Company would be made known to the customer at the first instance.
  8. Customer’s privacy would be respected.
  9. Interaction with the customer shall be made in a civil manner
  10. Company’s or authorised representatives shall contact the customers between 08.00 hrs and 19.00 hrs, unless the special circumstances of the customer’s business or occupation require otherwise or he has specially requested to connect on other time.
  11. Customer’s request to avoid calls at a particular time or at a particular place shall be honoured as far as possible.
  12. Time and number of calls and contents of conversation would be documented.
  13. All assistance should be given to resolve disputes or differences regarding dues in a mutually acceptable and in an orderly manner.
  14. During visits to customer’s place for dues collection, decency and decorum would be maintained.
  15. Inappropriate occasions such as bereavement in the family or such other calamitous occasions would be avoided for making calls/visits to collect dues.
  16. In the matter of recovery of outstanding dues of its borrower(s), the company and its agents / agency partners does not resort to intimidation or undue harassment of any kind either verbal or physical, against any person in their debt collection efforts, including acts intended to humiliate publicly or intrude upon the privacy of the debtors' family members, references and friends, sending inappropriate messages either on mobile or through social media, making threatening and/ or anonymous calls, use of muscle power for recovery of loans/overdue amount, making false and misleading representations, etc. Training is imparted to the company staff and Collection agents / agency employees to ensure that they are adequately trained to deal with customers in an appropriate manner. Agents are strictly prohibited from accessing the borrower's contact lists, photo galleries, or any other private data on their mobile devices to shame or threaten the borrower.

Further apart from above, our person and agents abide by the following Do’s and Don’ts to help serve our customers better

DosDONTs
Appearance,  dress codeWell Groomed Clean & TidyNo long unkempt hair Shirt sleeves rolled up
SpeechFormals Introduce yourself with identity card Use formal address Tone should be polite yet assertive and firmNo chappals or sandals Do not get tough or aggressive or abusive Do not lose temper, get angry or even irritated irrespective of reason Pitch should not be high
BelongingsDecency and decorum to be maintained Identity Card, Letter of authority Diary for writing the information gatheredShould not get personal Collector should not make any verbal or written promises to customer on matters outside his preview or on product features No personal dealings with customers
EthicsFair and ethical in your dealings with customersUnauthorized information written or verbal cannot be divulged to any customer / competitor / any other person No information on the customers to be shared with other customers
Information and ConfidentialityCollection interaction should be based on courtesy, fair treatment and persuasion Present all the information required to by the customer in an orderly fashion Loan details should be shared with the customer or the person authorized by the customer only in writingDo not share the Loan details other than customer without customer consent For Agencies only specific information to be shared which is required for collection of dues.
Process, DisciplineCollectors will perform their duties within the framework of the instructions issued to them.No physical contact with the customer
TimingEarliest : 08:00 hours , Latest : 19:00 hoursInteract with customer on other time unless customer has specifically requested any other timing.
Mode of Payment /ReconciliationCustomers should be advised to pay through electronic mode, using respective lenders virtual account / UPI links/ Payment Gateway / on Bank Account in name of Company.No payment should be collected without issuing an authorized receipt
Contact NumberCorrect contact number needs to be captured while submitting the proof of payment received. Reference no to be captured and used to get updated contact no of customerIncorrect contact number should not be captured Contact number of self/other executives should not be captured
KYC NormsAll documents of KYC should be correct & latest details need to be providedDo not provide any Fake / Incorrect KYC
LeaveAn ID Card needs to return to the agency in case of a planned leave more than three days.
Call RecordingsEach & every call made to the customer should be through the recorded phones only & recording need to be store as per normsDo not call the customer from numbers where a recording facility is not available
Self-IntroductionIntroduce yourself & the organization before starting the customer communication during a visit or callDo not hide your/organization name while making collection visit/call
MiscommunicationAll waiver / Settlement approval should be communicated to the customer in written only after taking approval from competent authority from Company.Do not make a wrong commitment to the customer
Data SecurityAll sensitive customer-related data should be in safe custody. Customer data will Agencies / others will be shared on need to know basis onlyDo not share customer information through unauthorized mediums.

X.            General Terms

  1. To verify the details mentioned in the Loan Application company may check about applicant by contacting them at their residence & / or on business telephone numbers & / or physically visiting their residence & / or business addresses through staff or through Agencies appointed for this purpose, if deemed necessary.
  2. The customer shall be informed to co-operate if the Company need to investigate a transaction on the customer’s Account & with the police / other Investigative Agencies, if Company need to involve them.
  3. Company shall advise the customer that if the customer acts fraudulently, he / she will be responsible for all Losses on his / her Account & that if the customer acts without reasonable care & this causes losses, the customer may be held responsible for the same.
  4. Giving Customers information about Products & Services in any of the following Languages English or the appropriate vernacular Language as agreed by customer during application.
  5. Company will not discriminate on the basis of Age, Race, Caste, Gender, Marital Status, Religion, or Disability. However, the restrictions on Age/ or any other product based distinction, if any, will be mentioned on Loan Products application form beforehand.
  6. Each application shall be considered independently on merit, upon scrutiny of all the information, documents required for verifying identity/ entity and the security to be offered, including guarantees, fetching reports from Bureau’s, etc.
  7. Company shall process requests for transfer of a loan account, either from the borrower or from a bank / financial institution, in the normal course.

FORCE MAJEURE

The Various commitments outlined and made by the company are applicable under the normal operating environment. In the event of Force Majeure, the Company will not be able to fulfil the commitments under the Fair Practice Code to the entire satisfaction of the customer/s and the public in general.

The Board of Directors reserves all the right to amend the code from time to time and updated copy of FPC will always be available on the website of the company.

CONFIDENTIALITY

• Unless authorized by the customer the company will treat all personal information as private and confidential.

• Unless authorized by the customer the company will not reveal transaction details to any other entity other than the following exceptional cases:

-  To provide the information by statutory or regulatory laws

- If there is a duty to the public to reveal this information.

- The company will not use this as a reason for giving information about customers to anyone else for marketing purposes.

Annexure 1

Key Fact Statement
LOAN ………. (NAME OF THE SPECIFIC LOAN PRODUCT)

Definitions:
- Equated Periodic Instalment - Equated Periodic Instalment (EPI) is an equated or fixed amount of repayments, consisting of both the principal and interest components, to be paid by a borrower towards repayment of a loan at periodic intervals for a fixed number of such intervals; and which result in complete amortisation of the loan. EPIs at monthly intervals are called EMIs

- Key Facts Statement (KFS) is a statement of key facts of a loan agreement, in simple and easier to understand language, provided to the borrower in a standardised format

- Annual Percentage Rate (APR) is the annual cost of credit to the borrower which includes interest rate and all other charges associated with the credit facility.

Language – The customer hereby confirms and give consent that “English”/language selected by them during location application is well understood by them and all content and communication with them will be in the same language.


Part 1 (Interest rate and fees/charges)

Sr NoParameterDetails
1Application / Loan Account / Proposal No. 
2Type of Loan 
3Sanction Loan amount (in Rupees)(A)
4Disbursal schedule 
 (i) Disbursement in stages or 100% upfront. 
 (ii) If it is stage wise, mention the clause of loan agreement having relevant details 
5Loan term/Tenure (year/months/days) 
6Instalment details 
 Type of instalments Number of EPIs EPI (Rs.) Commencement of repayment, post sanction            
7Interest type applicable on the loan account(fixed or floating or hybrid)
8Interest rate (%) 
9Additional Information in case of Floating rate of interest
Reference Benchmark Benchmark rate (%) (B) Spread (%) (S) Final rate (%) R = (B) + (S) Reset Periodicity (Month) Impact of change in the reference benchmark (for 25 bps change in ‘R’, change in)         B S EPI (Rs.) No. of EPIs                    
10Fee/ Charges 
    Payable to the NBFC (A) Payable to a third party through NBFC (B)     One-time/ Recurring Amount (in Rs) or Percentage (%) as applicable One-time/ Recurring Amount (in Rs.) or Percentage (%) as applicable / Frequency, if recurring i Processing fees         ii Insurance charges         iii Valuation fees         iv Any other (please specify)            
11Applicable Interest in % per Annum 
12Annual Percentage Rate (APR) for all in Cost of loan (including interest and fees) (%) 
13Details of Contingent Charges (in Rs. or %, as applicable)
iPenalty/ Penal charges, if any, in case of delayed payment 
iiOther penal charges, if any 
iiiForeclosure charges, if applicableFor Individual Borrower for any purpose except Business - Nil 
For all other borrowers 4% of outstanding loan amount
ivCharges for switching of loans from floating to fixed rate and vice versa 
vFee refundable if loan not sanctioned/disbursed (No fees being charged)NA
viConversion charges for switching from floating to fixed interest and vice-versa4% of outstanding loan
viiCheque / Nach Bounce Charges (in Rupees) 
viiiAny other charges (specify, if any) 
14Out of above total charges / fees collected from customer upfront before disbursement(B)
15Net disbursed amount (in Rupees)(A-B)
16Total interest charge during the entire tenure of the loan (in Rupees) 
17Total amount to be paid by the borrower (in Rupees) 
18Repayment frequency by the borrower (Monthly / yearly/ no of days, etc.) 
19EMI payable /Amount of each instalment of repayment (in Rupees) 
20Date of reset of interest (for floating rates)Yearly, March every year
21Mode of communication of changes in interest rates Email/SMS/ Whatsapp
22Details of security/collateral obtained 
23Date on which annual outstanding balance statement will be issued 
24Cooling off/look-up period (period during which borrower shall not be charged any penalty on prepayment of loan)Minimum 3 days

Validity period for Sanction - validity period of at least three working days for loans having tenor of seven days or more, and a validity period of one working day for loans having tenor of less than seven days
Part 2 (Other qualitative information)

 Clause of Loan agreement relating to engagement of recovery agents 
 Clause of Loan agreement which details grievance redressal mechanism 
 Phone number and email id of the nodal grievance redressal officer 
 Whether the loan is, or in future maybe, subject to transfer to other REs or securitisation (Yes/ No)Yes
 In case of lending under collaborative lending arrangements (e.g., co-lending/ outsourcing), following additional details may be furnished:
 Name of the originating RE, along with its funding proportion Name of the partner RE along with its proportion of funding   Blended rate of interest            
6In case of digital loans, following specific disclosures may be furnished:
(i)Cooling off/look-up period, in terms of RE’s board approved policy, during which borrower shall not be charged any penalty on prepayment of loan 
(ii)Details of LSP acting as recovery agent and authorized to approach the borrower 
7Date on which annual outstanding balance statement will be issuedApril 30
8Details of Loan Service Provider (LSP) authorised for sourcing / servicing or acting as recovery agent and authorized to approach the borrower 
9(a) Details of fintech nodal Grievance Redressal Officer of LSP 
10(a) Details of fintech nodal Grievance Redressal Officer of the NBFC / company 
Note : The font size of Key Fact Sheet would be minimum Arial-12

Detailed Repayment Scheduled

Instalment No.Total Loan Amount including all charges at time of disbursementPrincipal (in Rupees)Interest (in Rupees)Instalment (in Rupees)Outstanding Principal (in Rupees)
      


Annexure 1a

Illustration for computation of APR for Retail and MSME loans on Hypothetical Loan Amount

Sr. No.ParameterDetails
1Sanctioned Loan amount (in Rupees) (Sl. No. 3 of the KFS, Annexure 1)20,000
2Loan Term (in years/ months/ days) (Sl. No. 5 of the KFS, Annexure 1) 
aNo. of instalments for payment of principal, in case of non- equated periodic loans-
bType of EPI Amount of each EPI (in Rupees) and nos. of EPIs (e.g., no. of EMIs in case of monthly instalments) (Sl. No. 6 of the KFS, Annexure 1)Monthly 970 24
cNo. of instalments for payment of capitalised interest, if any-
dCommencement of repayments, post sanction (Sl. No.6 of the KFS, Annexure 1)30 days
3Interest rate type (fixed or floating or hybrid) (Sl. No.7 of the KFS, Annexure 1)-
4Rate of Interest (Sl. No.8 of the KFS, Annexure 1)15 %
5Total Interest Amount to be charged during the entire tenor of the loan as per the rate prevailing on sanction date (in Rupees)3,274
6Fee/ Charges payable (in Rupees)400
aPayable to the RE (Sl. No. 10a of the KFS, Annexure 1)240
BPayable to third-party routed through RE (Sl. No. 10b of the KFS, Annexure 1)160
7Net disbursed amount (1-6) (in Rupees)19,600
8Total amount to be paid by the borrower (sum of 1 and 5) (in Rupees)23,274
9Annual Percentage rate- Effective annualized interest rate (in percentage) (Sl. No. 11 of the KFS, Annexure 1) (Computed on net disbursed amount using IRR approach and reducing balance method)17.07%
10Schedule of disbursement as per terms and conditionsDetailed schedule to be provided
11Due date of payment of instalment and interestDDMMYYYY

Annexure 1b

Illustrative Repayment Schedule under Equated Periodic Instalment for the hypothetical loan illustrated in Annex 1a

Instalment No.Outstanding Principal (in Rupees)Principal (in Rupees)Interest (in Rupees)Instalment (in Rupees)
120,000720250970
219,280729241970
318,552738232970
417,814747223970
517,067756213970
616,310766204970
715,544775194970
814,769785185970
913,984795175970
1013,189805165970
1112,384815155970
1211,569825145970
1310,744835134970
149,909846124970
159,063856113970
168,206867103970
177,33987892970
186,46188981970
195,57290070970
204,67291158970
213,76192347970
222,83893435970
231,90494624970
2495895812970