Fair Practices
Fair practices Code – Integro Finserv P Ltd
Objectives Of The Fair Practices Code
The Code has been adopted:
a) To promote good and fair practices by setting minimum standards in dealing with customers;
b) To increase transparency so that the customers can have better understanding and take an informed decision.
c) To encourage market forces through competition, to achieve higher industry standards;
d) To promote a fair and cordial relationship between customers and the Company;
Background
The Reserve Bank has prescribed the Directions on Fair Practices Code applicable to Non-Banking Financial Companies (NBFCs). The Directions, inter alia, cover general principles on adequate disclosures on the terms and conditions of lending and related matters such as , collections/ recovery mechanism and process, protection of customer’s rights, Grievance Redressal etc.
Applicability
The Code shall apply to all employees of the Company and other persons authorized to represent it in the course of its business.
Non-Discrimination Policy
The Company will not discriminate between its customers on the basis of gender, physical ability, race or religion. The Company will also not discriminate visually or physically challenged applicants in extending products, services, facilities, etc.
Language Of The Communication
All required communications by the Company to the borrower will be in the language as understood by the borrower (English or Vernacular language).
Applications For Loans And Their Processing
a) Loan application forms will include the relevant and necessary information which affects the interest of the borrower so that a meaningful comparison with the terms and conditions offered other NBFCs can be made and informed decision could be taken by the borrower. The loan application form will also indicate the documents required to be submitted with the application form.
b) Receipt of completed application forms will be duly acknowledged by the Company. The acknowledgement will contain details regarding the time frame within which loan application will be disposed of.
Loan Appraisal and Terms / Conditions
a) All loan applications will be assessed as per the Company’s internal credit policies and appraisal process as approved by the Board.
b) Upon approval of the loan a sanction letter indicating the amount of loan sanctioned, the applicable annualised rate of interest rate, method of application thereof, along with other terms and conditions will be conveyed in writing to the borrower. The penal interest charged will be incorporated in bold letters in the loan agreement. The acceptance copy of the sanction letter will be kept on record.
c) After the execution of the loan agreement, all the borrowers will be furnished a copy of the loan agreement along with a copy each of all enclosures quoted in the loan agreement. A copy of the loan agreement will be furnished to the applicant with a copy each of all enclosures quoted in the loan agreement at the time of disbursement
Disbursement Of Loans Including Changes In Terms And Conditions
a) Any changes in the terms and conditions including disbursement schedule, rate of interest rate, service charges, prepayment charges, repayment etc. shall be informed/ notified to the borrower in writing;
b) Changes as indicated in a) above shall beaffected prospectively. A suitable condition in this regard will be incorporated in the loan agreement.
c) Decision to recall / accelerate payment or performance under the agreement will be in consonance with the agreement.
d) All underlying securities shall be released, on repayment of all dues or on realisation of the outstanding amount of loan subject to legitimate right or lien for any other claim the company may have against the borrower. Any such right of setoff will be exercised after the borrower has been given about the same with full particulars of the remaining claims and the conditions under which the company is entitled to retain the securities till the relevant claim is settled/ paid.
Privacy and Confidentiality
9.1 Credit Reference Agencies/ Credit Information Companies (CICs)
a) The Company may share details of the loan and repayment track record of its borrowers to the Credit Information Companies as per the regulatory directions/ guidelines or the Company’s internal policies.
b) The Company may share information with the Credit Information Companies about the personal debts the customer owes it if:
i) The customer has fallen behind his/her payments
ii) The amount owed is not in dispute
iii) The customer has not made proposal following our formal demand for repayment of dues.
c) At the same time, the Company representatives will explain to the customers the role of the CICs and the effect the information they provide can have on customer’s ability to get credit.
d) The Company will give information about the customer’s account to the CICs if the customer has given his/her permission to do so OR the statutory/ regulatory requirements prescribe so.
e) The Company will provide relevant information given to the CICs if demanded by the customer.
9.2 Sharing of information
a) The Company may provide such information to its group/associate entities or companies for which it has obtained consent/ permission from its customer under loan application/ sanction letter/ loan agreement.
b) The Company will treat the personal information of customer even when the customer is no longer a customer as private and confidential. The company shall not reveal the data or information of customer to anyone except as provided above and in the following exceptional cases:
i) Required by law;
ii) Duty towards public to reveal information;
iii) The Company’s interest requires giving information;
iv) The Company has consent/ permission from the customers;
v) The Company’s representatives will inform the customer about his rights/ liabilities under the Laws of India for accessing the personal records that the Company holds about him/her;
vi) The Company will not use customer’s personal information for marketing purposes unless the customer specifically authorizes us to do so.
General Provisions
a) The Company shall refrain from interference with the business of the borrowers except under the terms and conditions of the loan agreement (unless new information, not disclosed earlier, by the borrower has come to the notice of the Company);
b) Where the company receives a request from the borrower for transfer of borrowalaccount, the consent or otherwise the objection if any, would be conveyed within 21 days from the date of receipt of such request of the borrower. Such transfer will be as per the terms and conditions of the loan in consonance with law;
c) For recovery of loan, the Company shall not resort to undue harassment and will follow procedures adopted internally by the Company within the applicable legal framework; The company shall train the staff adequately to deal with the customers in appropriate manner.
d) The Company will comply with the extant regulatory provisions with respect to prepayment of loans by its borrowers.
Grievance Redressal Mechanism
Any customer having a grievance/ complaint/ feedback with respect to the product and services offered by Integro Finserv Private Limited may write to the Company’s Customer Service Department through any of the following channels:
Email : [email protected] / [email protected]
Or
You may write a letter at the address
1006, Ellora Fiesta, 10th Floor, Plot No 8, Sector 11, Sanpada, Navi Mumbai, 400705
How a complaint should be made:
Customers are requested to necessarily provide necessary loan details i.e. Loan Account Number, Details of Feedback/ Suggestion/ Complaint and valid Contact Information including phone no. & e-mail ID while lodging communicating with the Company.
When to expect a reply
The Company shall endeavour to address/respond to all queries/grievances within reasonable time and keep the customer in informed about the status of their complaints. Each customer query/ complaint being unique in nature, may take up to 4 weeks for complete resolution after investigation.
Whom to approach for redressal
Customers are requested to first raise their concerns through any of channels mentioned above. In case of delayed or no response from the respective channel within the specified timelines, such complaint may be escalated to the Grievance Redressal Officer of the Company whose details are as given below:
Grievance Redressal Officer Name:
Jaspal Alhuwalia
Email : [email protected]
Dinoop Sathyanath
Email : [email protected]
Escalation to the Reserve Bank of India
If the Customer does not receive any response from the Company within 4 weeks or is dissatisfied with the response received, he/ she may approach the Reserve Bank of India at the following address:
The General Manager,
Department of Non-Banking Supervision
Reserve Bank of India,
Shahid Bhagat Singh Road,
Kala Ghoda, Fort , Mumbai 400001
Tel: 022-22704715
+91 8169868523