Comero Leasing and Financials Private Limited (“Company”):
Fair Practices Code Policy (“Code”) This is with reference to the guidelines issued by the Reserve Bank of India on Fair Practice Code for all Non-Banking Financial Companies (NBFCs) vide RBI circular RBI/2015-16/16 DNBR (PD) CC.No.054/03.10.119/2015-16 dated July 1, 2015.
This Code is aimed to provide to all the stake holders, including but not limited to the Company’s customers, an effective overview of the practices followed, in respect of the services offered by the Company.
The objectives of this Code are::
- To implement and promote industry standard practices in dealing with customers;
- To promote a fair relationship between the customer and the Company;
- To ensure compliance with applicable laws and regulations in matters relating to recovery of loan amount;
- To create and maintain adequate mechanisms for redressal of customer grievances;
Loan Application
- The Company shall provide the borrower the information, required in relation to the services, so that the borrower can make a meaningful comparison with the terms and conditions offered by other NBFCs and make an informed decision.
- The Company shall give an acknowledgement of receipt for all loan applications. The Company shall endeavor to provide the time frame within which loan applications shall be processed.
- The loan application form shall indicate the documents required to be submitted along with the application form.
- If any additional details/ documents are required, the same shall be reasonably intimated to the borrowers.
Loan Appraisal and Terms & Conditions
- The Company shall convey in writing to the customer, by means of a sanction letter or any other document, the amount of loan sanctioned along with the terms and conditions including applicable rate of interest and shall maintain, in its record, the acceptance of these terms and conditions by the customer
- Company shall mention the charges and penal interest charged for late repayment or prepayment in bold in the loan agreement to be executed between the customer and the Company.
- Upon the execution of the loan agreement, the Company shall furnish a copy of the loan agreement along with a copy of all annexures attached to the loan agreement, to the customer.
Disbursement of loans including changes in terms and conditions
- The Company shall give notice in English, for any change in the terms and conditions – including disbursement schedule, interest rates, service charges, prepayment charges etc. In case the customer has given a declaration in the vernacular language that he/she does not understand English, he/she will be communicated to in the vernacular language.
- The Company shall, in the loan agreement to be executed between the Company and the customer, ensure that changes in interest rates and charges are effected only prospectively.
- Any decision to recall/accelerate payment or performance under the loan agreement shall be inconsonance with the respective loan agreement.
- The Company shall, subject to the respective loan agreement, release all securities pertaining to the loan on receipt of full and final payment of the loan amount, other than any legitimate right or lien, and set-off for any other claim that the Company may have against the customer. 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 until the relevant claim is settled / paid.
Interest Charged
- The Company has laid down appropriate internal principles and procedures in determining interest rates and processing and other charges.
- The Company would adopt an interest rate model taking into account relevant factors such as, cost of funds, margin and risk premium, and determine the rate of interest to be charged for loans and advances.
- The rates of interest and the approach for gradation of risks shall also be made available on the Company’s website. The information published in the website or otherwise published should be updated whenever there is a change in the rates of interest.
- The rate of interest should be an annualized rate so that the customer is aware of the rates that would be charged to the account.
Grievance Redressal Mechanism
The Company believes in speedy redressal of grievances of the borrower and guides its borrowers who wish to lodge a complaint and also provide guidance on what to do in case the borrower is unhappy with the outcome.
After examining the matter, the Company sends a response as soon as possible;
The Company has laid down the Grievance Redressal Mechanism for the speedy disposal/ remedy of its Customer’s Complaints/ Grievance.
The Grievance Redressal Mechanism adopted, approved and laid down by the Board and is laid down in detail under the Grievance Redressal Policy.
Force Majeure
The various commitments outlined and made by the Company shall be applicable under the normal operating environment. In the event of any Force Majeure circumstances, the Company may not be able to fulfil the objectives under the FPC to the entire satisfaction of the borrowers, the stakeholders and the public in general.
Periodic Review
In order to enhance the value and relevance to the borrowers, the Board of Director of the Company shall annually review the compliance with this Fair Practice Code.