Rationale
The Reserve Bank of India, (RBI), vide its notification number DNBS (PD) CC No.80/03.10.042/2005- 06 dated September 28, 2006 and subsequently through various other notifications has prescribed the broad guidelines on fair practices that are to be framed and approved by the Board of Directors of all Non-Banking Financial Companies (NBFCs). All of this has been consolidated in last Master Circular – Fair Practices Code notification number DNBR.(PD).CC.No.054/03.10.119/2015-16 dated July 1, 2015.
The requirement further prescribes that the Fair Practices Code (FPC) so framed and approved by the Board of Directors should be published and disseminated on the web-site of the company, if any, for the information of the public.
As a result, Equentia Financial Service Private Limited(“EFSPL” or “CredAble” or the “Company”) has framed the comprehensive Fair Practice Code which is covered in this document.
Objective of the code
Our key commitments and declarations
A. We shall act efficiently, fairly and diligently in our dealings with all our customers by:
Ensuring that all the financial services meet relevant laws and regulations;
Providing professional, courteous and speedy services; Providing accurate and timely disclosure of terms and conditions, costs, rights and liabilities as regards financial transactions.
B. We shall help the customer understand how our financial products and services work by:
Ensuring that our advertising & promotional literature is clear and is not misleading;
Explaining financial implications of the transactions;
Helping the customer to choose the financial scheme.
C. We shall deal quickly and proactively with things that go wrong by:
Attending to customer complaints quickly;
Telling our customers how to take their complaint forward if the customers are still not satisfied with our assistance;
Reversing any charges that we apply due to our mistake.
Non-discrimination policy
Non-discrimination policy
- All communications to the borrowers shall be made in vernacular language or a language as understood by the borrower.
- The Company will offer credit to eligible qualified applicants who express their need to borrow through their loan request letter or loan application forms.
- Loan application forms issued by the Company shall include necessary information which affects the interest of the borrower so that a meaningful comparison with the terms and conditions offered by other NBFCs can be made and an informed decision can be taken by the borrower.
- The Company shall issue an acknowledgement receipt for all loan applications. Subject to receipt of all the requisite documentation and information, loan applications shall be disposed of within 30 days, from the date of receipt of the application form complete in all respects. In any case the Customer will be kept informed by the sales person with regards to the status of his application from time-to-time. The Customer may also contact TCL’s customer service team at the prescribed toll-free number or email id to obtain an update on the status of application.
- If any additional details/ documents are required, the same shall be intimated to the borrowers immediately.
Loan appriasal and terms / Conditions
Non-discrimination policy
- All communications to the borrowers shall be made in vernacular language or a language as understood by the borrower.
- The Company will offer credit to eligible qualified applicants who express their need to borrow through their loan request letter or loan application forms.
- Loan application forms issued by the Company shall include necessary information which affects the interest of the borrower so that a meaningful comparison with the terms and conditions offered by other NBFCs can be made and an informed decision can be taken by the borrower.
- The Company shall issue an acknowledgement receipt for all loan applications. Subject to receipt of all the requisite documentation and information, loan applications shall be disposed of within 30 days, from the date of receipt of the application form complete in all respects. In any case the Customer will be kept informed by the sales person with regards to the status of his application from time-to-time. The Customer may also contact TCL’s customer service team at the prescribed toll-free number or email id to obtain an update on the status of application.
- If any additional details/ documents are required, the same shall be intimated to the borrowers immediately.
Loan appriasal and terms / Conditions
Notice period before taking possession.
Circumstances under which the notice period can be waived.
Procedure for taking possession of the security.
Provision regarding final chance to be given to the borrower for repayment of loan before the sale/auction of the property.
Procedure for giving repossession to the borrower and
Procedure for sale/ auction of the property.
Disbursement of loans including changes in terms / Conditions
A. The Company shall frame appropriate internal principles and procedures for determining and ensuring that the interest rates and processing and other charges are not excessive. The Company shall, at the time of disbursal, ensure that the interest rate and processing and other charges on loan and advances are in strict adherence to above referred internal principles and procedures.
B. The disbursement will be done immediately upon compliance of all the terms and conditions of the sanction by the borrower.
C. The Company shall give a notice to the borrower in the vernacular language as understood by the borrower, of any change in the terms and conditions including disbursement schedule, interest rates, service charges, pre-payment charges etc. The Company shall also ensure that changes in interest rates and charges are effected only prospectively. A condition to this effect shall be incorporated in the Loan Documents.
Non-discrimination policy
- All communications to the borrowers shall be made in vernacular language or a language as understood by the borrower.
- The Company will offer credit to eligible qualified applicants who express their need to borrow through their loan request letter or loan application forms.
- Loan application forms issued by the Company shall include necessary information which affects the interest of the borrower so that a meaningful comparison with the terms and conditions offered by other NBFCs can be made and an informed decision can be taken by the borrower.
- The Company shall issue an acknowledgement receipt for all loan applications. Subject to receipt of all the requisite documentation and information, loan applications shall be disposed of within 30 days, from the date of receipt of the application form complete in all respects. In any case the Customer will be kept informed by the sales person with regards to the status of his application from time-to-time. The Customer may also contact TCL’s customer service team at the prescribed toll-free number or email id to obtain an update on the status of application.
- If any additional details/ documents are required, the same shall be intimated to the borrowers immediately.
Post disbursal monitoring / Supervision
General
A. The Company shall not interfere in the affairs of the borrower except for the purposes provided in the Loan Documents, unless new information not earlier disclosed by the borrower has come to the notice of the Company.
B. In the matter of recovery of loans, the Company shall not resort to undue harassment like bothering the borrowers at odd hours, use of muscle power for recovery of loans etc. The Company shall ensure that its staff is adequately trained to deal with the customers in an appropriate manner.
C. The Company or its representative will call delinquent customers between 0700 hrs to 2100 hrs unless special circumstances of the borrower’s business require to call them otherwise outside the hours mentioned.
Complaint Redressal Mechanism
A. The toll-free number for recording the grievances of the customers will be intimated the Application Form/Sanction Letter/other document issued to the borrower. In addition, a separate e-mail ID will be created where customer can send their grievances via e-mail.
B. After examining the matter, the Company will endeavor to send the customer its response within four weeks and intimate the customer how to escalate the complaint to higher level, if he is not satisfied with the response. The Company has set up product wise turn-around time (“TAT”) for resolution of customer grievances within the above period of four weeks and shall ensure to resolve the complaints within such defined TATs.
C. At all the branches / Head Office of the Company, notice will be put up informing the customers about the escalation mechanism and the Grievance Redressal Officer (including the name and contact details). If the grievance is not redressed within the Turn-Around-Time (TAT) referred above, the customer may appeal to:
The Officer in Charge,
Department of Non-Banking Supervision,
Reserve Bank of India,
3rd Floor, Opposite Mumbai Central Railway Station,
Byculla, Mumbai – 400 008,
mail id: dnbsmro@rbi.org.in
Policy for determining interest rates, Processing and other charges
A. To ensure that there the Customers are not charged excessive interest rate and charges on loans and advances by the Company, the Board of the Company has adopted a Policy for Determining Interest Rates, Processing and Other Charges (“Interest Rate Policy”) and the same has been put up on the Company’s website credable.in . Further the Board of the Company also undertakes periodical review of the Interest Rate Policy.
B. CredAble has been lending at interest rate based on weighted average cost of funds, operating cost, administrative cost, risk premium, and expected return for stakeholder value on a sustainable basis as approved/revised by the Board as an when required. The rate of interest shall be fixed on the basis of the risk gradation of the client and shall be charged on per annum basis. The risk committee will monitor the rates periodically.
C. The Company intimates the Borrower, the loan amount and Rate of Interest at the time of sanction of the loan along with the tenure.