1)INTRODUCTION:
Poonawalla Finance Private Limited (“PFPL”), a Systemically Important non-deposit taking Non-Banking Finance Company (“NBFC-ND-SI”) registered with the Reserve Bank of India (“RBI”) is presently engaged in the business of extending financial facility in the form of loans including business loan, loan to professionals and personal loan. The credit facilities are extended to different types of customers, which include individuals, professionals, MSMEs, etc.
PFPL 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 FPC sets out the principles for fair practices/ standards while dealing with its customers.
PFPL has adopted the FPC and has implemented it. The FPC applies to all the categories of products and services offered by PFPL (currently offered and which may be introduced in future).
2) OBJECTIVES:
3) APPLICATION OF THE CODE:
The FPC shall apply to all the employees of PFPL and other persons authorized to represent it in the course of its business, whether the products and services are provided across the counter, over the phone, by post, through interactive electronic device, on the internet or by any other method.
4) COMMITMENTS:
PFPL shall adhere to the FPC to act fairly and reasonably in all dealings, on the ethical principle of integrity and transparency, to meet the standard practices prevalent in the financial and investment services industry.
PFPL would provide clear information, without any ambiguity, to the customers in understanding:
PFPL will deal quickly and sympathetically in correcting mistakes, if any, and attend to customer complaints in light of the objectives of the FPC.
PFPL will ensure that the Penal interest charged for late payment as well as the definition of overdue interest will be highlighted in bold in the loan agreement.
PFPL shall treat all personal information of customers as private and confidential and shall not divulge any information to third person unless required by any law or Government authorities including Regulators or Credit Information Bureaus or where the sharing of information is permitted by the customer.
PFPL would provide, on request, copy of the FPC to the existing borrowers and new customer(s) prior to the commencement of business transaction.
PFPL shall not discriminate its customers on the basis of race, caste, gender, marital status, religion and, or disability. However, the restrictions, if any, as mentioned in the respective loan products shall continue to apply.
PFPL shall refrain from interference in the affairs of the borrowers except for the purposes provided in the terms and conditions of the loan/ master loan agreement (unless new information, not earlier disclosed by the borrower, has come to the notice of PFPL).
PFPL shall ensure that the changes in the interest rates and, or charges are effected only prospectively.
5) DISCLOSURE AND TRANSPARENCY:
PFPL would provide information on the interest rates, common fees and charges, as ay be applicable, through:
PFPL shall not charge foreclosure charges/ pre-payment penalties on any floating rate term loan sanctioned for purposes other than business to individual borrowers, with or without co-obligant(s).
6) ADVERTISING, MARKETING AND SALES:
PFPL shall ensure that all the advertising and promotional material is clear and not misleading. The FPC shall also apply to the sales associates/ representatives of PFPL to the extent of their identification when they approach the customer for selling products personally. In case of any advertisement in any media and promotional literature that draws attention to a service/ product and its interest rate, PFPL shall also provide the details of other fees or charges, if any. Further, on the request of the customer, PFPL shall provide the details of relevant terms and conditions.
7) CREDIT INFORMATION COMPANIES (CICs):
PFPL would give information about the customers to the credit information companies on:
PFPL may give other information about the customer's account, to the CICs, or in case the customer has given his/ her/ its explicit permission to do so, in accordance with such authorization.
8) COLLECTION OF DUES:
Whenever loans are given, PFPL would explain to the customer the repayment process by way of amount, tenure and periodicity of repayment. However, if the customer does not adhere to repayment schedule, a defined process in accordance with the applicable laws shall be followed for recovery of dues. The process will involve reminding the customer by sending him/ her/ them notice or by making personal visits, if any.
PFPL staff or any person authorized to represent PFPL in collection of dues shall identify himself/ herself and display the authority letter issued by PFPL and upon request, display his/ her identity card issued by PFPL or under authority of PFPL. PFPL shall provide the customers with all the information regarding overdue amounts/ loan accounts.
During visits to customer's place by the person authorised by PFPL for dues collection the following guidelines shall be followed:
9) KNOW YOUR CUSTOMER (KYC) GUIDELINES:
PFPL shall 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 and operation. PFPL shall also put the KYC requirements on the website of PFPL www.poonawallafinance.com for the benefit of the customers.
PFPL would obtain such information to meet with PFPL's KYC, Anti-Money Laundering or any other statutory requirements. In case any additional information is required, it will be sought separately and the objective of obtaining such additional information shall be specified.
10) APPLICATIONS FOR LOANS AND ITS PROCESSING:
11)GUARANTORS :
When a person is considered to be a guarantor to a loan, PFPL shall inform him/ her/ them the following under acknowledgement-
12)COMMUNICATION WITH THE CUSTOMER:
Customers should be able to access PFPL through any of the following means:
13)COMPLAINTS :
PFPL would strive for customer satisfaction within the framework of law, adopted policies and procedures.
In case of any grievance, the customer may approach the in-charge of the business location where he/ she/ it had his/ her/ its account and register the complaint in the 'Complaint Register' available with the in-charge. PFPL has in place the recording and resolving process of the customer grievances. The process broadly includes mode of receipt and resolution of complaints and turnaround time for resolution.
On registering the complaint, the customer should obtain complaint number and date for future reference.
The customer may also write/ communicate with the concerned location for redressal of the grievance.
In case the response is unsatisfactory or no response is received, the complaint shall escalate using the escalation matrix intimated to customers so that the customer grievance is resolved speedily.
The Company had disclosed the following at all its branches/ places where business is transacted and on its website
14)PRIVACY AND CONFIDENTIALITY :
15)GENERAL :
PFPL reserves the right to amend/ alter/ modify the codes as mentioned herein above and provide updates from time to time, not affecting/ sacrificing the underlining spirit of the FPC. Such alternation/ amendments may be displayed at the notice boards of the branches/ Corporate Office for the benefit and information of the customer.