Fair Practice Code
Fair Practice Code(Reviewed) with respect to Lending Business of The Company Approved by the Board of Directors of the Company in their meeting held on 8th April 2022
SREERAGH GENERAL FINANCE LTD.
Introduction
The Company has s reviewed its Fair Practice Code with respect to their lending Business at the meeting of
the Board of Directors held on 08th April 2022 as per the directions of Master Circular No. DNBR (PD) CC No.054/03.10.119/2015-16 dated 1st July 2015, M/s Reserve bank of India has consolidated all the circulars/instructions issued by them so far with respect to the guidelines required to be considered in formulating a well defined Fair Practice Code by all the NBFCs. Based on the guidelines given in the said circular the Company decided to review its earlier Code approved by them in their meeting held on 9th January,2016. These guidelines give due importance for the adequate disclosure of the terms and conditions of the lending and also regarding the steps to b e taken for recovery of the loans without resorting to any corrosive methods. Based on the said guide lines the fair Practice Code of the Company has been reviewed and will continue it until further reviewed without change. These Codes shall be followed by the Company hereafter in all their lending activities.
These Code will be applicable to all financial lending activities of the Company .
They are
1. Hire Purchase Finance
2. Loan against Deposit.
3. Vehicle /Machinery and equipment Purchase Loan.
4. Gold Loan
5. Personal Loan
The Company shall not do any other lending business other than the above before framing and adopting suitable amendment to the existing Fair Practice Code with respect to such lending. For the time being the Company has stopped the Hire Purchase Finance until decided otherwise. However the existing scheme will continue till the recovery is completed in all branches.
Objects
1. The Borrower should gain adequate information about the terms and
conditions of every scheme of finance the company has framed before entering into any loan agreement with the Company.
2. The Credit Department of the Company will be conversant with the details of all the loan schemes
and will be in a position to provide clarity to all the prudent doubts that may be raised by any of the prospective borrowers.
3. The Supervisory bodies of the Company may be in a position to evaluate whether adequate transparency has been brought in by the Company to their lending business as expected.
4. The depositors should know the terms and conditions for availing loan against their deposit.
Wall Display
The main particulars of the Scheme will be always displayed in a prominent position in all the branches of the Company.
1. Application form for all kinds of loans
The Company will have printed loan application forms in Malayalam vernacular for all the loan schemes.
2. The leaflets regarding the details of every type of loan schemes shall be available at the counters and in the website.
Leaflets provided at the counters shall be in Malayalam Vernacular for all types of loans which will render the complete details regarding such loans to the customer like the interest rates, its method of application, effective annual interest rates, down Payment, documentation / processing charges, premature closing conditions and additional interest charges for late payment of the dues etc.
3. Display shall be made in all counters regarding the necessity for compliance of KYC norms for every customer and how it can be accomplished before they enter into any business transaction with the Company.
4. For all loans except gold loan following are the documents required to be submitted along with the application in order to comply with the KYC norms
a) Photo identity card such as Voters ID or Adhar card or PAN card or Pass Port and
b) Address proof of both permanent and currently residing place for communication. It includes copy of the relatively latest Service Charge bills having address of the customer, Bank manager’s certificate or similar proof.
5. Documents Regarding the Item of Purchase
Performa invoice of the item to be purchased from any of the approved registered supplier shall be obtained through the prospective borrower.
6. Documents to prove the Annual Income of the borrower
a. Copy of Income tax Returns of the latest two immediately previous years or
b. the latest Salary Certificate from the employer if any with whom the borrower has been working for the immediately past six months or
7. Borrower who is Agriculturist: if the borrower is an agriculturists latest land tax receipt showing the extent of land under his cultivation or by his family or
8. Borrower who is not an income tax assesse: A borrower who is not an Income Tax Assessee, latest six month’s bank statement or such other documents that could be used by the Company to determine the annual income of the borrower.
9. Documents by the Guarantor:
All the documents shown under 4 to 8 required by the borrower will be equally applicable to the guarantor.
10. Oral Request for Loan:
The Company shall not entertain any oral request from the borrower for a loan.
11. Memorandum of Information about the Company: The application form shall have an attachment of the memorandum of information which will give necessary information about the Company and also the general terms and conditions stipulated by the Company to all borrowers for availing the finance and such other particulars which the borrower needs to know for taking an informed decision before applying for the finance.
12. Receipt for the Application:
A receipt will be issued for every loan application which will show the time before which the borrower will be orally communicated whether his application has been accepted or rejected. The Company will take such decision only after the field verification is completed at the place of work and residence of the borrower.
13. Sanction Letter:
The borrower will be issued a sanction letter in Malayalam Language if the loan is sanctioned and it will contain the following information.
a) Amount of Finance: This is the loan amount sanctioned and it will be paid directly to the vendor if it is a vehicle loan along with the margin collected as Down payment from the borrower. Down payment will vary with the scheme opted by the borrower.
b) Rate of interest: Rate of interest for loan mentioning the effective annual interest rate.
c) Documentation Charge: The sanction letter will disclose the documentation charges
d) Period of loan scheme.
e) EMI for the entire period of the Loan Scheme mentioning the portion of interest and principal in each EMI
f) Need for having the cover of Comprehensive insurance throughout the tenure of the loan period with endorsement clause in favour of the Company.
g) Need for hypothecation clause in the case of vehicle to be noted by the Motor Vehicle Department in favour of the Company.
h) Collection of Advance EMI and its mode of adjustment.
i) Rate of Additional finance charges in case of delay in paying the EMI on the due date.
j) Description regarding the various documents to be executed after receiving the margin money, documentation charges, EMI’s and the Premium for the first year insurance.
K) Other terms and conditions regarding premature closing, seizing of vehicle in case of continuous default, wilful default and other malpractice such as using the vehicle for illegal activities, the borrower being alleged with criminal charges etc.
l) Premature Closing Chart: The amount to be paid for premature closing shall be provided to the borrower in the form of a chart. The working will be explained to the borrower by the marketing executive.
m) The sanction letter shall contain specific clause to intimate the borrower any change in the terms and conditions which the Company intends to make subsequent to the sanction of the loan.
The sanction letter shall specify the foreclosure charges that will be imposed on the borrower if he intends to close the loan before the completion of its tenure.
The sanction letter shall be communicated to the borrower in the appropriate manner and obtain his acceptance of the terms and conditions stated in the sanction letter in writing before disbursing the loan.
14. Execution of the Loan Documents:
Format of printed agreement is made available to the borrower for verification purpose before the execution
The following documents will be executed by the borrower.
a) Stamped pre printed Loan agreement with blanks to be filled in at the time of the execution will be signed by both the borrower and the authorised signatory of the Company.
b) If vehicle loan, other documents required for registration of the vehicle with Motor Vehicles Department, endorsement of hypothecation clause, application for insurance with endorsement clause in favour of the Company shall be obtained from the borrower.
c) Duplicate key and the Copy of the Registration Certificate after noting the endorsement clause for hypothecation shall be obtained from the borrower and the duplicate key will be kept in safe custody till it is returned to the borrower immediately after the loan is closed by the borrower.
15. Payment to the Dealer:
The cost of the vehicle is given to the dealer directly by the Company with instruction to deliver the vehicle directly to the Customer after completing all the formalities regarding registration with Motor Vehicle Department.
16. Recovery Policy:
The entire EMI amount with due dates will be issued to the customer in writing and each due dates of the EMI will be informed the customer in advance through mobile alert. In case of over dues in EMI, the customer will be contacted over telephone by the Company staff during office hours. If the over dues are more than two or the Company suspects that any will full default on the part of the customer regarding repayment he may be contacted by the manager of the recovery cell of the Head Office at times other than office hours but seldom at extreme odd hours. The office staff who are dealing in recovery exercise will be properly trained and the Company will never indulge any rude behaviour with the customer in carrying out the recovery exercise of the over dues.
17. Repossession of the goods given under Hire Purchase Scheme:
The repossession of goods from the defaulted borrower will be as per the conditions agreed upon. The Company always encourage voluntary surrender of the goods as a matter of policy and refrain from the use of force or muscle power for recovery of loans. The Company and its employees will stay away from unnecessary interference in the affairs of the borrower except for the purposes provided in the loan agreement.
18. Auction Policy of Repossessed Goods:
The repossessed vehicles in the case of H P Agreement will be auctioned to recover the arrears from the borrower. The auction procedure shall be transparent and carried out in such a manner that the interest of the borrower shall be protected to the maximum extent possible. The borrower shall be informed the minimum auction price fixed and will be given a final chance to repay the arrears and retake the vehicle .The sale price will be determined on the basis of public auction or otherwise as to get two maximum possible quotes for the proposed item. The balance in the loan remaining outstanding after adjusting the auction/sale proceeds will be recovered from the borrower as per regular laws. The auction will be announced to the public by issuing advertisements in newspaper in vernacular language having circulation in the concerned region.
19. Transfer/ Takeover of Loans
Any request of the borrower to transfer the borrowers account to another person will be duly considered and the transfer proceedings shall be transparent and in terms of the contract agreement. Any objection on transfer will be conveyed within a period of twenty one days to the original borrower from the date of receipt of the transfer request. All communication to the borrower shall be in Malayalam Language.
20. Grievance Redressal Mechanism.
The Company has a well defined grievance redressal mechanism for addressing the customer complaints at various stages. Any deviation from the loan policy guidelines and transactions or irregularities may be taken up with the branch in charge who will attend to the needs of the customer. All branches shall be provided with complaint books wherein the customer can record their complaints. All complaints will be looked into within three days of its receipt in normal course. Where ever the branches are unable to resolve the complaint, the customer will be suitably advised the reasons and further course of action to be initiated. The customer can also approach the Grievance Redressal Officer at the Head Office for any of their complaints which are not resolved properly at the branch level.
21. Policy regarding Loan against Deposit
Application: Any application for loan against deposit should be in the prescribed form issued by the Company.
The applicant should bring the Fixed Deposit receipt along with the application fully discharged and deposit with
the Company. The maximum amount of loan should not be more than what has been mentioned in the Deposit application. The
Company shall note lien on the face of the Deposit certificate with respect to the loan given and it should
be also noted in the Deposit register. The Company shall follow all the directions issued by the Reserve
Bank of India regarding the disbursal of loan against deposit and the loan period shall not exceed the
maturity period of the deposit.
22 GOLD LOAN
Loan application and Gold article will be verified before sanctioning the loan.
Special care will be taken to verify the KYC document and also checking the purity of gold .
KYC Documents required
a) Original Photo Identity Card such as Aadhar card/ PAN Card /Passport/Driving Licence
b) Address proof of both permanent and currently residing place for communication purpose.
c) It includes copy of the electricity bills,latest service charge bill having address of the customer or his parents .Bank Managers certificate where the customer has bank account will also be accepted.
d) No other documents are required for gold loan purpose.
e) Ones gold ornaments are allowed to pledge sanction will be immediate. No separate sanction letter will be issued.
f) A token will be issued to the customer which has the following information. This token must be brought to the bank when coming for closing the loan and to collect ornaments.
g) This token will have the following information
1.Date of loan
2.Name and address of the borrower
3.Gold loan Account Number of the borrower
4. Description of the ornaments
5. Gross weight of the ornament.
6.Net weight
7. Loan amount
8.Interest rate
Auction of Gold loans
Pledge ornaments of over due loans will be auctioned asper procedure given in the Master direction.
Customer will be intimated through phone call ,sending ordinary letter and two registered letter ( from the branch itself and other from Head office showing date of auction) .
News paper advertisement will be given in vernacular language paper and an English News paper.
Auction will be executed after getting the highest quotes from the bidders.
23. Review of the FPC
A periodical review of the Fair Practice Code and its functioning regarding the grievance redressal mechanism at various levels of management would be undertaken by the Company at regular intervals and a consolidated report of such reviews shall be submitted to the Board of Directors immediately.
24. General:
a. The Company shall refrain from interfering in the affairs of the borrower except for the purposes provided in the terms and conditions of the loan agreement
( No interference shall be from the part of the Company unless any new information , not any earlier disclosed by the borrower, has come to the notice of the Company.)
b. In the matter of recovery of loans, the Company shall not resort to any undue practices viz. Persistently bothering the borrowers at odd hours, use of muscle power for recovery of loans etc. The staff of the Company shall be adequately trained to deal with the customer in an appropriate manner so as to ensure proper behaviour.
c. Any fraud noticed in the functioning of the Company shall be enquired into by the appropriate authority and suitable punitive measures shall be taken by the appropriate disciplinary authority
For Sreeragh General Finance Ltd.
Mg. Director
R Badri Narayanan