- KNAB Finance Advisors Private Limited (hereinafter referred to as “Company”) is a private limited company incorporated under the provisions of the Companies Act, 2013, and is a non-deposit taking non-banking financial company (“NBFC”) registered with the Reserve Bank of India (“RBI”).
- This Fair Practices Code (“Code”) has been prepared by the Company taking into account the “Guidelines on Fair Practices Code for NBFCs” issued by the RBI that requires all NBFCs to put in place a fair practices code based on the said guidelines that needs to be followed by them while doing lending business.
- This Code sets the minimum fair business and corporate practice standards for the Company that needs to be followed by it while dealing with its customers. The Code also provides information to the customers in relation to the terms of its loan products and explains how the Company is expected to deal with the customer on a day to day basis and it applies across all aspects of the Company’s operations including marketing, loan origination, processing, servicing and collection activities.
- The Company provides unsecured and secured loans to its various customers from to time. Such credit facilities are extended to different types of customers, which include individuals, proprietorships, partnership firms, companies, and other form of legal entities. This Code is applicable to all categories of products and services currently offered (or which may be introduced at a future date) by the Company.
2. OBJECTIVES OF THE CODE
- The key objectives of the Code are-
- To provide the customers an effective overview of practices followed by the Company in respect of financial facilities and services offered by the Company.
- To ensure fair practices and promote good and ethical practices by setting minimum standards in dealing with customers.
- To increase transparency so that the customer is well aware of the terms and conditions of products/services and can make an informed decision prior to entering into a transaction with the Company.
- To promote a fair and cordial relationship between the customer and the Company.
- To ensure compliance of applicable regulations prescribed by the RBI relating to fair practices.
- The Company shall adhere to this Code to act fairly and reasonably in all its dealings and follow the ethical principle of integrity and transparency to meet the standard practices prevalent in the finance industry.
4. LOAN APPLICATION AND ITS PROCESSING
- The Company shall convey to its customers through email or such other mode of communication as adopted by it in accordance with its policies, the loan application form. The Company in order to maintain utmost transparency ensures that the loan application form contains all terms and conditions governing the loan, including the rate of interest and such additional terms and information that affects the interests of the customer, so that a meaningful comparison with the terms and conditions offered by other NBFCs can be made and the customer can make an informed decision.
- The Company will request the customer to submit requisite documents including KYC documents along with the loan application. If needed, the Company will inform the customers about any other document that the Company needs from them to establish their identity, address, credit assessment, and such other information about them as required to comply with legal / regulatory requirements and assessment of the application.
- Upon receipt of the loan application forms the Company will provide its customers acknowledgment of the receipt of such loan application forms. The time frame within which loan applications will be disposed of from the date of receipt of duly completed loan application forms together with the requisite documents customer will be indicated in the acknowledgement.
- All communications to the customer by the Company shall be made in English as it is understood by all customers of the Company.
5. LOAN APPRAISAL AND TERMS AND CONDITIONS
- The Company shall appraise loan applications considering the risk based approach and credit policy/ies of the Company.
- The customers shall be given in English a loan sanction letter and a copy of the loan agreement along with a copy of all the enclosures that relate to such loan agreement at the time of sanction/disbursement of the loan which shall include the details of the loan such as amount sanctioned, annualized interest rate and method of application thereof, service charges, prepayment charges and other relevant terms and conditions.
- The acceptance of the terms and conditions communicated by the customer shall be preserved by the Company on its record.
- The penal interest that will be charged for late payment shall be mentioned in bold letters in the sanction letter / loan agreement.
6. DISBURSEMENT OF LOAN AND CHANGES TO THE TERMS AND CONDITIONS
- Disbursement of the amount of loans sanctioned may be made available to the customers on demand subject to completion of all formalities including the execution of loan documents and submission of all documents complying with prevailing rules and regulations.
- The Company shall give notice in English to its customer of any change in the terms and conditions including disbursement schedule, interest rates, service charges, prepayment charges, etc.
- The Company shall ensure that changes in interest rates and charges are effected only prospectively and shall include a suitable condition in this regard in the loan agreement.
- The Company shall ensure that any decision to recall/accelerate or delay payment or performance under the agreement shall be undertaken in a transparent manner according to the terms set out in the agreement executed by the Company with its customers.
- 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 the customer. If such right of set off is to be exercised, the customer 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.
- The Company will refrain from interference in the affairs of its customers except for the purposes provided in the terms and conditions of the loan agreement (unless information, not earlier disclosed by the customer, has been noticed).
- In case of receipt of a request from the customer for transfer of customer loan’s account, the consent or otherwise (objection of the Company), if any, shall be conveyed within 21 (twenty one) days from the date of receipt of such request. Such transfer shall be as per transparent contractual terms entered into with the customer and in consonance with statutes, rules, regulations and guidelines as may be applicable from time to time.
8. RATE OF INTEREST
- The Company had laid down appropriate internal principles and procedures in determining interest rates and processing fees and other charges.
- The Company has adopted an interest rate model taking into account relevant factors such as its cost of funds, interest rate trends prevailing in the money market, margin, and risk premium and this is used to determine the rate of interest to be charged for loans and advances for a customer.
- The rate of interest and the approach for gradations of risk and rationale for charging different rates of interest to different categories of customers is disclosed to the customer and the same is published and disseminated on the website of the Company and the information published on the website is updated whenever there is a change in the rates of interest.
- The rate of interest to be charged depends much upon the risk profile of the customer (its financial strength, business, collateral security offered, past history, etc.). The rate of interest for a customer would be communicated explicitly in the sanction letter.
- The rate of interest will be calculated on a flat or on reducing balance as mentioned in the loan agreement. It will be annualised so that the customer is aware of the exact rates that would be charged to the account.
- The Company shall, at the time of disbursal, ensure that the interest rate and other charges, if any, on loans and advances are in strict adherence to above referred internal principles and procedures.
- The Company will not discriminate between its customers on the basis of their gender, race, or religion. The Company’s policy is to treat all its customers fairly. The Company will offer assistance, information, and service in a fair, equitable, and consistent manner.
10. COLLECTION OF DUES
- Whenever loans are given, the Company shall explain to the customer the repayment process by way of amount, tenure, and periodicity of repayment.
- If the customer does not repay in accordance with the agreed repayment schedule, the Company will undertake necessary steps for recovery of dues in accordance with applicable law and terms of the loan agreement as executed with such customer. The process may involve reminding the customer by sending a notice or by making personal visits.
- Company shall provide customers with all the information regarding dues and shall endeavour to give sufficient notice for payment of dues.
- All assistance shall be given to resolve disputes or differences regarding dues in a mutually acceptable and in orderly manner.
- During visits to customer’s place for dues collection, decency and decorum shall be maintained.
- The Company shall follow a defined process in accordance with the laws of the land for recovery of dues. In the matter of recovery of loans, the Company would not resort to undue harassment such as persistently bothering the customers at odd hours, or use of force or muscle power for recovery of loans, etc. To avoid rude behaviour from the staff of the Company, the Company shall ensure that the staff is adequately trained to deal with the customers in an appropriate manner.
- A copy of the terms and conditions would be made available to the customer. The Company shall furnish a copy of the loan agreement along with a copy of each of enclosure quoted in the loan agreement to the customer at the time of sanction / disbursement.
11. GRIEVANCE REDRESSAL
- The Board of Directors (“Board”) of the Company has laid down grievance redressal mechanism within the organization. Such a mechanism ensures that all disputes arising out of the decisions of the Company’s functionaries are heard and disposed of at least at the next higher level.
- Customers who wish to provide feedback to the Company may use any of the following mediums between 10 AM and 5 PM from Monday to Friday on all working days to communicate the same to the Company.
|Address:||KNAB Finance Advisors Pvt. Ltd., L-127, 4th Main, 14th Cross, HSR Layout, Sector 6, Bangalore, India – 560102|
|Customer Service Helpline No:||+91-9310637483|
- In case the customer has any complaint against the Company the customer can approach the Grievance Redressal Officer of the Company. The Grievance Redressal Officer appointed by the Company can be reached out at:
|Name:||Mr. Atul Tiwari|
|Address:||KNAB Finance Advisors Pvt. Ltd., L-127, 4th Main, 14th Cross, HSR Layout, Sector 6, Bangalore, India – 560102|
- If the complaint/dispute is not redressed within a period of one month, the customer may appeal to Officer-in-Charge of the Regional Office of Department of Non-Banking Supervision (“DNBS”) of RBI at Bangalore. The details of the DNBS regional office are given below:
|Address:||DGM, Department of Supervision Reserve Bank of India, Bangalore Regional Office 10/3/8, Nrupthunga Road, Bengaluru – 560 001, India|
- For the benefit of its customers, the Company displays the name and contact details of the Grievance Redressal Officer and the Officer-in-Charge of the Regional Office of DNBS, RBI in all its branches/offices and the website of the Company.
- The Company shall collect personal information that it believes to be relevant and required to conduct of its business. The Company 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 credit agencies or where the sharing of information is permitted by the customer.
13. ADVERTISING, MARKETING AND SALES
- The Company shall ensure that all advertising and promotional material is clear, and not misleading. Should the customers choose to receive, the Company may, from time to time, communicate to customers various features of the Company’s products that are availed by them. Information about their other products or promotional offers in respect of products / services may be conveyed to customers, should the customers choose to receive them.
- In the event of receipt of any complaint from the customer that a representative of the Company has engaged in any improper conduct or acted in violation of this Code, appropriate steps shall be initiated to investigate and address the complaint in accordance with the Company’s policy existing at that point of time.
14. REVIEW AND PUBLICATION
- The Company shall do a periodic review of the compliance of the Code and the functioning of the grievances redressal mechanism at various levels of management. A consolidated report of such reviews shall be submitted to the Board of the Company at regular intervals.
- The latest Code shall be displayed at all the branches / offices of the Company and shall be published on the web-site of the Company for the information of various stakeholders.