Fair Practice Code
Document Number: TC-FPC-Dated-25th October, 2019
Version : 1.0
True Credits Private Limited
Fair Practice Code
True Credits Private Limited, a Non-Banking Non-Deposit Taking Company registered with Reserve Bank of India (“RBI”) is presently in the business of providing different types of loans which includes Consumer Durable Loans, Personal Loans, to its various customers. Such credit facilities are extended to different types of customers, which include Individuals, Partnership Firms, Companies and other Legal entities.
True Credits Private Limited (“the Company”) has put in place the Fair Practice Code (FPC) as per the RBI directives and it has been duly approved by the Board of Directors. The Fair Practice Code sets out the principles for fair practices/ standards while dealing with its customers.
The Company has adopted this Fair Practices Code (“the Code”) and have implemented it. The Code applies to the all categories of products and services offered by the Company (currently offered and which may be introduced in future).
2. Key Commitments
The Company's key commitments to customers:
a. Act fairly and reasonably in all their dealings with customers by:
Meeting the commitments and standards specified in the Code, for the products and services which the Company offers and, in the procedures, and practices its staff follows;
Making sure that Company's products and services meet relevant laws and regulations;
Company's dealings with customers will rest on ethical principles of integrity and transparency.
b. Help customers understand how company's product work by explaining their financial implications.
c. Deal quickly and sympathetically with things that go wrong by:
Handling customer's complaints;
Telling customers' how to take their complaint forward if they are still not satisfied
d. Publicize the Code, put it on Company's website and have copies available for customer on request.
a. Helping customer choose products and services, which meet their needs and give them clear information explaining the key features of the services and products they are interested in.
b. Inform customers about the documents and information the Company needs from them to establish customer’s true identity and address and, other documents to comply with legal and regulatory requirements.
4. Applications for loans and their processing
a. All communications to the borrower shall be in the vernacular language or a language as understood by the borrower.
b. The Loan application forms of the Company will 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 informed decision can be taken by the borrower. The loan application form will indicate the documents required to be submitted with the application form.
c. The Company will have a system of giving acknowledgement for receipt of loan applications. The time frame within which loan applications will be disposed of will be indicated in the acknowledgement.
5. Loan appraisal and terms/conditions
The Company will convey in writing to the borrower in the vernacular language or a language as understood by the borrower by means of sanction letter or otherwise, the amount of loan sanctioned along with the terms and conditions including annualised rate of interest and method of application thereof and keep the acceptance of these terms and conditions by the borrower on its record. The Company will mention the penal interest which will be charged for late repayment and / or any other default on the part of the customer, in bold in the loan agreement.
The Company will furnish a copy of the loan agreement preferably in the vernacular language as understood by the borrower along with a copy each of all enclosures quoted in the loan agreement to all the borrowers at the time of sanction / disbursement of loans.
6. Disbursement of loans including changes in terms and conditions
a. The Company will give notice to the borrower in the vernacular language or a language as understood by the borrower of any change in the terms and conditions including disbursement schedule, interest rates, service charges, prepayment charges etc. The Company will also ensure that changes in interest rates and charges are effected only prospectively. A suitable condition in this regard will be incorporated in the loan agreement.
b. Decision to recall / accelerate payment or performance under the agreement will be in accordance with the loan agreement.
c. The Company will release all securities 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 the Company 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 is settled/paid.
a. The Company will refrain from interference in the affairs of the borrower except for the purposes provided in the terms and conditions of the loan agreement (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 will not resort to undue harassment viz. persistently bothering the borrowers at odd hours, use of muscle power for recovery of loans, etc. To avoid rude behavior from the staff of the Company, the Company shall ensure that the staff are adequately trained to deal with the customers in an appropriate manner.
8. Grievance Redressal
a. The company shall set up a grievance redressal mechanism within the organisation comprising Business Heads, Heads of Risk and Collections and Heads of Operations to resolve disputes. This Forum will ensure that all the disputes arising out of the decisions of the Company’s functionaries are heard and disposed of at least at the next higher level.
b. There will be a periodical review of the compliance of the Fair Practices Code and the functioning of the grievance redressal mechanism at various levels of management. A consolidated report of such reviews will be submitted to the Board at regular intervals.
c. The following information shall be displayed prominently, for the benefit of the customers, at all branches/ places of the Company, where business is transacted:
the name and contact details (Telephone / Mobile nos. as also email address) of the Grievance Redressal Officer who can be approached for resolution of complaints against the Company.
if the complaint / dispute is not redressed within a period of one month, the customer may appeal to the Officer-in-Charge of the Regional Office of DNBS of RBI under whose jurisdiction the registered office of the Company falls.
The public notice will serve the purpose of highlighting to the customers, the grievance redressal mechanism followed by the Company, together with details of the Grievance Redressal Officer and of the Regional Office of the RBI.
9. Posting on Website
Fair Practices Code, preferably in the vernacular language or a language as understood by the borrower shall be put up on the website of the Company for the information of various stakeholders.
10. Regulation of excessive interest charged
a. The Board of Directors has adopted an interest rate model for determining the rate of interest to be charged on loans and advances, processing and other charges taking into account relevant factors such as, cost of funds, margin and risk premium, etc. The rate of interest and the approach for gradations of risk and rationale for charging 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.
b. The rates of interest and the approach for gradation of risks shall also be made available on the website of the company. The information published in the website or otherwise published shall be updated whenever there is a change in the rates of interest.
c. The rate of interest shall be annualised rate so that the borrower is aware of the exact rates that would be charged to the account.