Fair Practice Code

01. INTRODUCTION

The Fair Practices Code aims to provide to all those who will be associated with FFPL Finance Private Limited (‘FFPL or ‘the Company’) with the information about the  practices that FFPL follows in respect of the financial facilities, loans and services provided,  which will facilitate its customers/borrowers to take informed decisions in respect of the  financial facilities and services to be availed of by them. The Fair Practices Code will apply  to any loan that FFPL may sanction and disburse.

FFPL has adopted the Fair Practices Code (the ‘FPC’) pursuant to Reserve Bank of India’s  (‘RBI’) Master Direction – Non-Banking Financial Company – Systemically Important Non Deposit Taking Company and Deposit Taking Company (Reserve Bank) Directions, 2016  updated from time to time. The Company would update the FPC to conform with the standards that may be prescribed by the RBI from time to time. The Company would abide  by this FPC following the spirit of the Code and applicability to its business.

The FPC has been approved by the Board of Directors of the Company and it will be  disclosed on the Company’s website.

02 . KEY OBJECTIVES

a) The Company will conduct its business in accordance with prevailing rules and  regulations and corporate governance principles.
b) The Company’s dealings with its customers will rest on the principles of fairness,  transparency and honesty.
c) The Company will assist its customers in understanding the broad features of its  financial products and will provide them with key terms and conditions governing  sanction of credit facilities.
d) The Company will promote fair and cordial relations with its customers/borrowers.

03. DOCUMENTATION BY WAY OF ELECTRONIC/DIGITAL/APP BASED OR OTHER MEANS

a) All communication will be made in a language understood by the customers/borrowers  or in a vernacular language, wherever required.
b) The loan documentation set would, inter alia, include the broad features and the terms  and conditions governing the loan 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 customers /borrowers.
c) The loan application form would indicate the documents required to be submitted by  the borrower. It would also indicate the rate of interest that will be charged to different  categories of borrowers.
d) An acknowledgement would be provided for all loan applications received along with  completed documents. The Company will indicate the approximate time frame within  which the loan application will be processed post the submission of a completed loan  application form and the borrowers will be informed about the status of their loan  applications within reasonable time. In case of specific app-based/paperless loans  provided, the Company would convey the details through email to the registered email  address of the borrower.

04. LOAN APPRAISAL AND TERMS & CONDITIONS

a) The loan applications would be subject to the Company’s credit appraisal process and  a due diligence on the creditworthiness of the customers/borrowers, which will form  an important parameter for taking a decision on a loan application.
b) FFPL would convey in writing to the customers/borrowers by means of a sanction letter,  the amount of loan sanctioned along with the terms and conditions including the  annualized rate of interest and method of application thereof. In case of specific  app based/paperless loans provided, the Company would convey the details mentioned above through email to the registered email address of the borrower.
c) FFPL would keep on its record the acceptance by the customers/borrowers of the terms  and conditions governing the sanction of the loan. In case of app-based/paperless  loans, a request by the borrower to disburse the sanctioned loan amount or  part  thereof would be deemed to be acceptance by the borrower of the terms and conditions governing sanction of loan.
d) At the time of sanction/disbursement of loans, FFPL would furnish to all  customers/borrowers a copy of the loan agreement / terms and conditions (if any) along with a copy of all enclosures mentioned in the loan agreement.
e) The loan agreement shall expressly stipulate the penal interest chargeable for late  payment / repayment of dues by the borrower, in bold.

05. DISBURSEMENT OF LOANS INCLUDING CHANGES IN TERMS AND CONDITIONS

a) FFPL would frame internal guidelines and procedures for determining and ensuring that  the interest rates and processing and other charges levied on the borrowers are not  excessive.
b) The disbursement will be initiated upon compliance with all the terms and conditions  of sanction of loan by the customers/borrowers. FFPL would give notice to the  customers/borrowers in the vernacular language or a language as understood by the  customers/borrowers of any change to the terms and conditions, including the disbursement schedule, interest rates, service charges, pre-payment charges, etc.
c) Changes in the interest rates and other charges would be effected prospectively other  than under circumstances arising from regulatory instructions.
d) The decision to recall/accelerate payment or performance under the agreement would  be in consonance with the terms and conditions of the loan agreement.

06. RELEASE OF SECURITIES

FFPL would release securities (if any) lying with it on repayment of all dues or on realisation  of the outstanding amount of loan subject to any legitimate right or lien for any other  claim that FFPL may have against the customers/borrowers. If such right of set off is to be  exercised, the customers/borrowers would be given notice about the aforesaid with full  particulars about the remaining claims and the conditions under which FFPL is entitled to retain the securities till the relevant claim is settled/paid.

07. GENERAL

a) The Company would refrain from interference in the affairs of the  customers/borrowers, except for the purposes provided in the terms and conditions  of the loan agreement (unless new information, not earlier disclosed by the  customers/borrowers  has come to the notice of the Company).
b) In case of a request from the borrower for transfer of the loan account to another  NBFC, bank or financial institution, the Company would convey its decision within 21  days from the date of receipt of request. Such transfer would be in accordance  with  the contractual terms entered into with the borrower and in consonance with law.
c) In the matter of recovery of loans, FFPL would not resort to undue harassment, i.e.  persistently bothering the borrower at odd hours, using muscle power for recovery  of loans, etc. The Company would ensure that its employees / recovery agent(s) are  properly trained to deal with customers in an appropriate manner.
d) The Company may arrange to enforce the security provided, if any, by delinquent  customers/borrowers. In all such instances, the Company would ensure that the  entire process of enforcing its security, valuation and realization thereof is fair and  transparent.
e) Cooling off/look-up period means the time window which shall be given to  borrowers for exiting digital loans, in case a borrower decides not to continue with  the loan.

The Cooling off/look up shall be three days for loans having tenor of seven days or  more and one day for loans having tenor of less than seven days. For borrowers  continuing with the loan even after look-up period, pre-payment shall continue to be  allowed as per extant RBI guidelines.

The Company will give option to borrower to exit digital loan by paying principal and  proportionate Annual Percentage Rate (APR) without any penalty during Cooling  off/look up period.

08. INTEREST RATE

a) The Company would lay down appropriate internal guidelines and procedures for  determining interest rates and processing and other charges, keeping in view the  guidelines indicated in the Fair Practices Code.
b) The Company will ensure that it does not unduly charge excessive interest rates to its  borrowers. The interest rate for its customers/borrowers would be arrived at taking  into account the broad parameters such as the risk profile of the   customers/borrowers, interest rate trends prevailing in the money market, cost of borrowings, primary and collateral security offered by customers/borrowers,  structure of the deal, interest rate charged by competitors and the historical track  record of the customers/borrowers with FFPL.
c) Interest rates would be intimated to the customers/borrowers at the time of sanction / availing of the loan. The rate of interest would be annualized so that the borrower  is aware of the exact rates that would be charged to the account.
d) The Company would not charge foreclosure charges / pre-payment penalties on all  floating rate term loans sanctioned to individual borrowers.

09. GRIEVANCE REDRESSAL MECHANISM

a) At present, there is a competitive lending business; hence, excellent customer service  is an important tool for sustained business growth.
b) At FFPL, customer service and satisfaction are the prime areas of focus. The company  believes that providing prompt and efficient service is essential not only to attract new  customers, but also to retain existing ones.FFPL has come up with a lot of initiatives  that are oriented towards providing a better customer experience and an efficient  grievance redressal mechanism with a view to providing an enhanced experience to  customers. In order to make the Company’s grievance redressal mechanism more  meaningful and effective, a structured system has been built. This system would ensure  that the grievance redressal sought is just and fair and is within the given framework  of rules and regulations.

The following is the Grievance Redressal Mechanism for customers:

Escalation of complaints: First Level

If you are raising a complaint for the first time, we request you to kindly do any of the following:

            Write to us at [email protected]

            Or call us at +91-9076057809

Escalation of complaints: Second Level

Please note escalation of complaint can only be valid if you have already used the above email or number to register your complaint. Incase, you have not heard back from the support team on your above mentioned email or phone number, you can contact:

Grievance Redressal Officer: Ms.Adv. Varsha Manoharan

Email Id:  [email protected]

Contact: +91-9076058709

Escalation of complaints: Third Level

In case a complaint is not redressed within a period of one month or if you are not satisfied with the response/solution received, you may approach the Reserve Bank of India (RBI) for grievance redressal.

                Complaints can be filed online on : https://sachet.rbi.org.in/home/index

10. OMBUDSMAN FOR NBFCs

(1) Reserve Bank – Integrated Ombudsman Scheme, 2021 

FFPL covered under the Reserve Bank – Integrated Ombudsman Scheme, 2021 shall  appoint Nodal Officer and Principal Nodal Officer in accordance with directions  provided under the said Scheme.

(2) Appointment of Internal Ombudsman 

FFPL may upon fulfillment of the criteria laid down under the circular on  “Appointment  of Internal Ombudsman by Non-Banking Financial  Companies” dated November 15,  2021 shall appoint the Internal Ombudsman and adhere to the corresponding  guidelines as and when applicable.

11. REGULATION OF EXCESSIVE INTEREST CHARGED

(1) The rate of interest and the approach for gradation of risk and the rationale for  charging a different rate of interest to different categories of borrowers shall be  disclosed to the borrower or customer in the application form and communicated  explicitly in the sanction letter.

(2) The rates of interest and the approach for gradation of risks shall also be made  available on the website of the company or published in the relevant newspapers. The  information published on the website or otherwise published shall be updated  whenever there is a change in the rates of interest.

12. CONFIDENTIALITY AND DISCRIMINATION

FFPL shall treat all personal information of customers as private and confidential and shall  not divulge any information to a third person unless required by any law or government  authorities including regulators or a credit agency or where the sharing of information is  permitted by the customer.

FFPL shall not discriminate its customers on the basis of race, caste, gender, marital  status, religion or disability. However, the restrictions (if any) as mentioned in the loan  products shall continue to apply.

13. KYC

FFPL would explain the requirements of KYC Guidelines to its customers and inform them  about the documents required for establishing the identity of the customer before loan  sanctioning, account opening and operation.

FFPL would obtain only such information that is required to meet with the company’s  KYC, anti-money laundering or any other statutory requirements. In case any additional  information is asked for, it will be sought separately and shall specify the objective of  obtaining such additional information.

14. GUARANTORS

When a person is considered to be a guarantor to a loan, FFPL shall inform him/her of the  following under acknowledgement:

            Letter/Deed of Guarantee stating the terms of liability as a guarantor.

            FFPL shall keep him/her informed of any default in servicing of the loan by the  borrower to whom he/she stands as a guarantor.

15. COMPLIANCE WITH THE FPC

An annual review of the compliance with the FPC and the functioning of the grievance  redressal mechanism would be conducted. A consolidated report of such review would  be submitted to the Board of Directors every year.