Introduction
This Fair Practice Code has been prepared in compliance with the
“Master Direction - Non-Banking Financial
Company (Reserve Bank) Directions, 2016” as issued by the Reserve
Bank of India (“RBI”) and aims to provide our borrowers an effective overview of the practices
followed by the Company and to enable borrowers to take informed decisions in respect of the
financial facilities and services offered by the Company. The Code covers the general principles
on adequate disclosures on the terms and conditions of the loan and the procedures to be
followed when dealing with the borrowers. The Code applies to all categories of products and
services offered by AARAMBH SECURITIES LIMITED (“AARAMBH” or “Company’’).
If at any point a conflict of interpretation / information between
this Policy and any Regulations, Rules, Guidelines, Notifications, Clarifications, Circulars,
Master Circulars/ Directions by the RBI arise then, interpretation of such Regulations, Rules,
Guidelines, Notification, Clarifications, Circulars, Master Circulars / Directions issued by RBI
shall prevail.
Objectives of the Code
The following are the primary objectives of this Code:
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To make
all our financial products available to all eligible qualified applicants, without
discrimination on the basis of race, caste, colour, religion, sex, marital status, age,
sexual orientation or handicap.
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Promote
fair and transparent practices by setting minimum standards in dealings with
borrowers.
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Foster a
fair and cordial relationship between the borrowers and the Company. The Company will
also communicate its FPC to its customers by making it available to everybody on its
website and displaying on all the branches of Company.
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To
ensure compliance with regulatory requirements with regard to customer interface.
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To
strengthen mechanisms for redressal of customer grievances.
Key Commitments
The Key Commitments which the Company promises to follow in its
dealings with its customers are:
The Company will communicate its FPC to its customers by making it
available to everybody on its website and displaying the FPC at all of its branches. A copy of
the said FPC would be made available on request and would be provided in English and/or in the
local language prevalent in the particular state in which the Company operates.
The Company’s Board of Directors and the management team are
responsible for implementing the fair practices hereinafter detailed and ensuring that its
practices reflect its strong commitment to all the stakeholders for offering in a fair and
equitable manner, the various financial services and products and that all employees are aware
of this commitment.
The Company will make every attempt to ensure that its customers
have a trouble-free experience in dealing with it; but in the case of errors of commission and
omission, the Company will deal with the same quickly and sympathetically.
Applications for loans and their processing
The Company is in the business of lending and offers various
products (loan and loan related products). Application forms for each of the products offered by
the Company would be different depending on the requirement for information for each
product.
All communications to the borrower shall be in English and/or in
the language as understood by the borrowers. The borrowers will have the option to receive all
the correspondences, loan documents, recall notices etc relating to loan in English or a
language understood by the borrowers. For this purpose, the borrowers need to indicate his/her
preference in the loan application form by selecting the appropriate option.
At the time of any application for loan product, the Company will
provide information about the interest rates applicable, as also the fees/charges, if any,
payable for processing, pre-payment options & charges, if any, and any other matter which
affect the interests of the borrower.
All relevant information pertaining to the loan/loan facility
which affects the interest of the borrowers with regard to the financial facility that is being
applied for will be made available in the relevant loan application form(s) or through term
sheet/ sanction letters, 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 loan
application form will also indicate the details of the various documents required to be
submitted together with the duly completed application form.
The rate of interest applicable to the borrowers shall be based on
a number of factors such as profile of the borrowers, loan amount loan category, financial
strength of the borrowers, security/collateral offered, Company’s cost of funds, etc. The Board
of the Company shall lay out appropriate internal principles and procedures in determining
interest rates and processing and other charges for loans and advances taking into account
relevant factors such as cost of funds, margin, competition landscape and risk premium. 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.
The rate of interest would be annualized rate so that the
borrowers are aware of the exact rates that would be charged to the account.
The Company shall give an acknowledgement for receipt of all loan
applications. Applicants are required to insist for an acknowledgement in this regard. The
acknowledgement would also indicate the approximate timeframe within which the applicant should
contact the Company at its registered office to ascertain the status of the loan
application.
The Company shall verify the loan applications within a reasonable
period of time and if additional details / documents are required, it shall inform the borrowers
accordingly.
Loan appraisal and terms/conditions
Normally, all particulars required for processing the Loan
Application shall be collected by the Company at the time of application. In case the Company
needs any additional information, the borrower shall be informed appropriately.
The Company shall ensure that there is proper assessment of credit
applications made by the borrowers. The assessment would be in line with the Company's internal
credit policies, norms and procedures.
The Company will convey in writing to the borrower by means of
sanction letter or otherwise in English and/or in the language as understood by the borrower,
the amount of loan sanctioned along with the terms and conditions including annualized rate of
interest, and method of application thereof including EMI structure, if any, prepayment charges
and keep the acceptance of these terms and conditions by the borrower in Company’s record. The
Company will furnish a copy of the loan agreement in English and/or in the language as
understood by the borrower along with a copy each of all enclosures quoted in the loan agreement
at the time of sanction/disbursement of the loan.
The rate of interest applicable to customers is dependent on
factors such as cost of funds, loan amount margin and risk premium plus a spread which is
determined on the risk profile of the case which vary on account of a number of factors such as
borrowers background, industry risk profile, financial strength of the co-borrower, loan
repayment capability, credit history, collateral offered or not, costs associated with
underwriting and servicing the loan, etc. The penal charges, if any, to be charged by the
Company for late repayment, etc shall be mentioned in bold in the loan agreement, sanction
letter, etc. A written acceptance of such terms and conditions shall be retained by the
Company.
Disbursement of loans including changes in terms and
conditions
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The
Company will give notice to 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
Sanction letter/loan agreement.
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The
Company will furnish a copy of the loan agreement, either electronically or physical
paper copy, to all the borrowers upon disbursement of the loan. In case customer does
not receive a copy electronically or by post then customer will be informed to collect
from the local branch
Applicant with Disability (ies)
The Company shall not discriminate in extending products and
facilities including loan facilities to the physically / visually challenged applicants on the
grounds of disability. They shall be treated at par with the other applicants and their
application shall be dealt on merit as per the credit process and policy of the Company. All
possible assistance will be provided to the applicants with the disability (ies) to enable them
to understand, select and avail appropriate product or loan facility.
General :
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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 / been
noticed by the Company).
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In case
of receipt of a request from the borrower for transfer of the loan account, the consent
or otherwise i.e. objection of Company, if
any, shall be conveyed within 21 days from the date of such receipt of request. Such
transfer shall be as per transparent contractual terms in consonance with
law.
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In the
matter of recovery of loans, the Company will resort only to remedies which are legally
and legitimately available to it and will not resort to undue harassment viz.
persistently bothering the borrowers at odd hours, use of muscle power for recovery of
loans, etc.The Company will make all efforts so that its staff is adequately trained to
deal with customers in an appropriate manner.
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As a
measure of customer protection and in order to bring in uniformity with regard to
prepayment of various loans by borrowers of banks and NBFCs, the Company shall not
charge foreclosure charges/ pre-payment penalties on all floating rate term loans
sanctioned for the purpose other than business to “Individual borrowers” with or without
co-obligant.
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The
Company shall not discriminate on grounds of sex, caste and religion including
physically/visually challenged applicants on grounds of disability in the matter of
lending. However, this does not preclude the company from participating in credit –
linked schemes framed for weaker sections of the society.
Responsibility of Board of Directors towards an effective
Grievance Redressal Mechanism
The Board of Directors of the Company will also lay down an
appropriate grievance redressal mechanism within the organization.
Such a mechanism shall ensure that all disputes arising out of the
decisions of its functionaries are heard and disposed of at least at the next higher
level.
Review of the Fair Practices Code
Compliance with respect to all aspects of the FPC and the
Grievance Redressal Mechanism shall be reviewed by the Board annually unless regulatory changes
requires a review of the policy sooner.
Force Majeure
The various commitments outlined and made by the company are
applicable under a normal operating environment. In the event of Force Majeure, the Company may
not be able to fulfill its commitments under the FPC to the entire satisfaction of its customers
or the other stakeholders.
Outsourcing
Outsourcing of any activity by the Company does not diminish its
obligations, as the onus of compliance with regulatory instructions rests solely with the
Company. Wherever the Company engages digital lending platforms as their agents to source
borrowers and/ or to recover dues, Company must follow the following instructions:
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Names of
digital lending platforms engaged as agents shall be disclosed on the website of the
Company.
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Digital
lending platforms engaged as agents shall be directed to disclose upfront to the
customer, the name of the Company on whose behalf they are interacting with him.
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Immediately after sanction but before execution of the
loan agreement, the sanction letter shall be issued to the borrower on the letter head
of the Company.
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A copy
of the loan agreement along with a copy each of all enclosures quoted in the loan
agreement shall be furnished to all borrowers afterdisbursement of loans
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Effective oversight and monitoring shall be ensured over
the digital lending platforms engaged by the Company.
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Adequate
efforts shall be made towards creation of awareness about the grievance redressal
mechanism.
Grievances Redressal Mechanism
The implementation of the FPC shall be the responsibility of the
Company. The Company shall make every effort to ensure that its dealing with borrowers /
customers is smooth and hassle free. Any complaint brought to the notice of the Company by a
borrower / customer will be handled expeditiously.
All disputes / complaints arising out of the decisions of the
Company’s functionaries would be heard and disposed of at least at the next higher level after
it is brought to their notice. Therefore, the following 'Grievances Redressal Mechanism' is put
in place.
Step 1: Branch/Place (where Business is transacted) Level
Review
A customer should either make a written complaint addressed to the
relevant Branch Manager (contact details for the Company’s branches / Place where business is
transacted are on the Company’s website, call the Company at 7208960333 during office
hours (9:30 a.m. to 6:00 p.m.) ], or email the Company at grievance@aarambhloans.com with:
The Branch/ place where Business is transacted will strive to
provide an initial response to the customer’s complaint within 7 days of the complaint being
lodged.
Step 2: Grievance Redressal Officer Review
In case the customer is not satisfied with the response received
at Step 1, i.e. the Branch/place where business is transacted, he /she can escalate the
complaint to AARAMBH’s Grievance Redressal Officer, whom the Company has appointed for the
implementation of customer service and complaint handling. The Grievance Redressal Officer’s
complete contact details are given on the following page:
Mr. Manjeet Singh – Grievance Officer
Address (office): AARAMBH SECURITIES LIMITED,
1019 C Wing, 215 Atrium, Next To Courtyard Marriott,
A. K. Road, Andheri East, Mumbai - 400093
Email id: grievance@aarambhloans.com
Mob No - 7208960333
The Grievance Redressal Officer can be contacted during office
hours (9:30 a.m. to 6:00 p.m.) on any of the working days of the Company.
Once the complaint is escalated, the complaint will receive a
response within 7 working days of it reaching the Grievance Redressal Officer.
Step 3: Joint Chief Executive Officer Review
In case the customer is still not satisfied with the response or
has not received a response from the Company within 15 days from the date of his/her initial
complaint, he/she may contact the Company’s Chief Executive Officer at the email id nodal@aarambhloans.com or phone number +91 86570
00105 during office hours (9:30 a.m. to 6:00 p.m.)
After examining the matter, it would be our endeavour to provide
the borrower / applicant with our final or other response, within a period of two (2) weeks and
within a maximum period of four (4) weeks from receipt of such complaint/grievance.
If the complaint does not receive a response from the Company
within a period of 1 month or if a customer is dissatisfied with the response received at all
levels, the complainant may approach the Reserve Bank of India at the following address:
The General Manager
Reserve Bank of India
DNBS, Mumbai Regional Office,
RBI Building, 3rd Floor,
Opp. Mumbai Central Railway Station, Mumbai-400 008.
Tel: - 022 23084121/2302 8436
e-mail- helpdnbs@rbi.org.in
Integrated Ombudsman Scheme
The Integrated Ombudsman Scheme, 2021 is effective from November
12, 2021. The Scheme adopts ‘One Nation One Ombudsman’ approach by making the RBI Ombudsman
mechanism jurisdiction neutral. It integrates the existing three Ombudsman schemes of RBI
namely, (i) the Banking Ombudsman Scheme, 2006; (ii) the Ombudsman Scheme for NonBanking
Financial Companies, 2018; and (iii) the Ombudsman Scheme for Digital Transactions, 2019.
Relevant details are published in the Company’s website https://www.aarambhloans.com/
The Board shall review the compliance with the FPC and the
functioning of the grievance redressal mechanism at periodic intervals. A consolidated report of
such reviews shall be submitted to the Board of Directors at regular intervals.