2019
Fair Practices Code
Enterprise wide-applicable to the entire
company
Fair Practice Code provides the customers an effective
overview of the practices followed by CF in respect of the
financial facilities and services offered to customers.
Contents
Sl No Particulars Page no.
1. Introduction 3
2. Objectives 3
3. Application for Loan and Processing 3
4. Loan Appraisal and Terms & Conditions 3
5. Disbursement of Loans and Changes in Terms & 4
Conditions
6. General 4
7. Grievance Redressal Mechanism 4
8. Regulation of Interest Rates charged by the 5
Company
9. Repossession of Hypothecated Assets Financed by 5
the Company
1
Introduction
Pursuant to RBI vide Circular [Link].266/03.10.01/2010-11
dated March 26, 2012 and vide Circular [Link].320/03.10.01
/2012-13 dated February 18, 2013 (“Guidelines”), issued to Non-
Banking Financial Companies (NBFCs), the Board of Directors have
adopted a Fair Practices Code for Zen Lefin Private Limited (“Company”).
The Fair Practices Code, as adopted herein below, is in conformity with
the Guidelines on Fair Practices Code for NBFCs as contained in the
aforesaid RBI Circular.
The Board had approved the earlier policy on 14th November 2013.
The Company's business will be conducted in accordance with prevailing
statutory and regulatory requirements, with due focus on efficiency,
customer-orientation and corporate governance principles. In addition,
the Company will adhere to the Fair Practices Code in its functioning, the
key elements of which are as follows:
Objectives
To ensure Fair Practice while dealing with the customers;
To enable customers to take informed decisions about our financial
products and services; and
To ensure customer satisfaction.
Application for Loan and Processing
Loan application forms issued to prospective customers includes
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 the borrower can make an
informed decision). Loan application form also clearly indicates
documents required to be submitted along with the application
form.
The Company has a system of acknowledging receipt of all loan
applications.
Loan Appraisal and Terms & Conditions
In accordance with the Company’s appraisal norms, loan application
will be considered and loan amount will be approved after applying
internal credit appraisal norms. The Company shall convey in
writing to the borrower by means of approval letter or otherwise,
the amount of loan approved along with the terms and conditions,
including the annualized rate of interest and method of application
thereof. Additionally, Penal Interest on late repayment is clearly
highlighted in written offer letter and loan agreement. The Company
2
shall keep record of customer’s acceptance of all these terms and
conditions.
Company shall at the time of sanction / disbursement of the loan,
furnish a copy of loan agreements and related enclosures to the
customer.
Disbursement of Loans and Changes in Terms & Conditions
The Company shall give notice to all its borrowers of any change in
the terms and conditions – including disbursement schedule,
interest rates, service charges, prepayment charges etc. The
Company shall also ensure that changes in interest rates and
charges are effected only prospectively. A suitable provision in this
regard is incorporated in the loan agreement.
Decision to recall / accelerate payment or performance under the
agreement shall also be in consonance with the loan agreement.
The Company shall release all securities on repayment of its full
dues or on realization of the outstanding amount of loan subject to
any legitimate right or lien for any other claim the Company may
have against its borrowers. If such right of set off is to be exercised,
the borrower shall 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.
General
The Company will refrain from interference in the affairs of the customer
except for the purposes provided for in the terms and conditions of the
loan agreement (unless new information, not earlier disclosed by the
customer, has come to the notice of the Company).
The Company will not discriminate loan applications based on grounds of
sex, caste and religion.
In case of receipt of request from the borrower for transfer of borrowal
account, the consent or otherwise – i.e., objection of the Company, if any
– shall be conveyed to the borrower within 21 days from the date of
receipt of any request. Such transfer shall be as per transparent
contractual terms in consonance with law.
In the matter of recovery of loans, our Company staffs are adequately
trained to deal with customers and shall not resort to any harassment –
such as persistently bothering the borrowers at odd hours, use of muscle
power for recovery of loans, etc.
3
Grievance Redressal Mechanism
Please refer to the Grievance Redressal Policy.
The Company has a Customer Complaint Helpline number as a first level
complaint mechanism.
The Company has designated Mr. Gaurav Hinduja, and Mr. Sashank R
Rishyasringa as Nodal Officers for receiving and resolving complaints from
customers.
The Company has designated Mr. Gaurav Hinduja, and Mr. Sashank R
Rishyasringa as Nodal Officers for receiving and resolving complaints from
customers.
The contact details of Nodal Officer are:
Mr. Gaurav Hinduja / Mr. Sashank R Rishyasringa
CAPFLOAT FINANCIAL SERVICES PRIVATE LIMITED,
Gokaldas Platinum, New No. 3 (Old No. 211),
Upper Palace Orchards, Bellary Road,
Sadashiva Nagar,
Bengaluru – 560080
Phone: 080-23081800
The customers having grievance/ complaint about our services/ product
may inform in writing to Nodal Officer for immediate resolution of the
same. Nodal Officer will provide the highlights of the complaints received
and redressal to the Board of Directors for their review and compliance at
each subsequent meeting.
In case customers are not satisfied with the resolution provided by the
company, they may further approach:
Regional Director – Bengaluru
Reserve Bank of India,
10/3/8, Nrupathunga Road,
Bengaluru - 560 001, India.
Regulation of Interest Rates charged by the Company
The Company has laid down appropriate internal principles and procedure
in determining interest rates, processing fees and other charges. The
Company has adopted an interest rate model taking into account relevant
factors such as, cost of funds, margin and risk premium, etc. and
4
determine the rate of interest to be charged for loans and advances. The
rate of interest and the approach for gradations of risk and rationale for
charging different rate of interest to different categories of customers
shall be communicated explicitly in the sanction letter.
Repossession of Hypothecated Assets Financed by the Company
The Company has a built in re-possession clause in the loan agreement
with the customer which is legally enforceable. To ensure more
transparency, the terms and conditions of the loan agreement contains
provisions regarding:
notice period before taking possession;
circumstances under which the notice period can be waived;
the procedure for taking possession of the security;
a provision regarding final chance to be given to the borrower for
repayment of loan before the sale/auction of the security;
the procedure for giving repossession to the borrower and
the procedure for sale / auction of the property.