Frequently Asked Questions - Fair Practice

The Company has laid down an appropriate grievance redressal mechanism within the organization to resolve disputes arising in this regard.

The Company shall display the following information prominently, for the benefit of its customers, at its branches / places where business is transacted:

• The name and contact details (Telephone / Mobile no. and email address) of the Grievance Redressal Officer/ Principal Nodal Officer who can be approached by the public for resolution of complaints against the Company.
• Reserve Bank - Integrated Ombudsman Scheme, 2021 (‘Scheme’)
• Salient features of the Scheme in English, Hindi and the regional language
• If the complaint / dispute is not redressed within a period of one month, the customer may appeal to the Reserve Bank of India through the complaint lodging portal: https://cms.rbi.org.in.

The Company has appointed Principal Nodal Officer in accordance with the directions provided under the Reserve Bank – Integrated Ombudsman Scheme, 2021.

The Company has appointed the Internal Ombudsman under the RBI circular on ‘Appointment of Internal Ombudsman by Non-Banking Financial Companies’ dated November 15, 2021.

The Company has a built-in re-possession clause in the contract/ loan agreement with the borrower which is legally enforceable. To ensure transparency, the terms and conditions of the contract/ loan agreement contains provisions regarding:

1. notice period before taking possession;
2. circumstances under which the notice period can be waived;
3. the procedure for taking possession of the security;
4. a provision regarding final chance to be given to the borrower for repayment of loan before the sale/ auction of the property;
5. the procedure for giving repossession to the borrower; and
6. the procedure for sale/ auction of the property.

A copy of such terms and conditions is made available to the borrower in the Loan Agreement executed between the Company and the borrower.

The Company will, irrespective of whether they lend through their own digital lending platform or through an outsourced lending platform, adhere to this Fair Practices Code.

RBI vide its circular dated September 2, 2022, has issued “Guidelines on Digital Lending” (“RBI Guidelines”). As per RBI Guidelines, the Company will make following disclosure to borrowers or all digital lending products of the Company:

1. Annual Percentage Rate (APR) will be disclosed as a part of the Key Fact Statement (KFS).
2. The Company will provide a KFS to the borrower before the execution of the contract. Any fees, charges, etc., which are not mentioned in the KFS will not be charged by the Company to the borrower at any stage during the term of the loan.
3. The Company will ensure that digitally signed documents will automatically flow to the borrowers on their registered and verified email/ SMS upon execution of the loan contract/ transactions.
4. The Company will prominently publish the list of their Digital Lending Apps/ Platforms (DLAs), Lender Service Provider (LSP) and DLAs of LSPs with the details of the activities for which they have been engaged, on its website.
5. The Company will ensure that its DLAs or DLAs of its LSPs at on-boarding/sign-up stage, prominently display information relating to the product features, loan limit and cost, etc., so as to make the borrowers aware of these aspects.
6. The Company will communicate to the borrower, at the time of sanctioning of the loan and also at the time of passing on the recovery responsibilities to an LSP or change in the LSP responsible for recovery, the details of the LSP acting as recovery agent who is authorised to approach the borrower for recovery.
7. The Company will ensure that DLAs of the Company and LSPs have links to Company’s website where further/ detailed information about the loan products, the lender, the LSP, particulars of customer care, link to Sachet Portal, privacy policies, etc. is available.
8. The Company will ensure that it and its LSPs have a suitable nodal grievance redressal officer to deal with FinTech/ digital lending related complaints/ issues raised by the borrowers.

This code would be reviewed annually taking into account the various amendments to guidelines and regulations (if any), business models and would be placed to the Board for their approval.