Fair Practice Code

VALLABHI CAPITAL PRIVATE LIMITED
:: FAIR PRACTICE CODE ::
::2023-24::

1. PREAMBLE:

It is, and shall be, the policy of VALLABHI CAPITAL PVT LTD. (VCPL) CoR No. N-14.03588 (the “Company”) to treat all its clients consistently and fairly. The Company will offer assistance and service in a fair, equitable and consistent manner. It shall also communicate its Fair Practices Code (“FPC”) to its clients by uploading the FPC on its website. The Company will ensure that the implementation of the FPC is the responsibility of the entire organization. The Company’s fair lending practices shall apply across all aspects of its operations including origination of the loan proposal, collection of information, appraisal and due diligence, approval, disbursement and collection. The Company Board of Directors and VPCL are responsible for implementing the fair practices hereinafter detailed, and also to ensure that its operations reflect to its various stakeholders, the Company’s strong commitment to offering various financial services in a fair and equitable manner.

Boards Approval:

VCPL adopted a Fair Practices Code (FPC) for its lending business pursuant to RBI directives on Non-Banking Financial Company (NBFC), Fair Practices Code (FPC) issued from time to time. The RBI has last issued NBFC FPC guidelines in its master direction DNBR.PD.007/03.10.119/2016-17 DATED September 1, 2016 updated on December 29, 2022. Accordingly, following Fair Practices Code has been approved and adopted by Board of the VCPL. Objectives of the Code:
(i) Ensuring fair practices while dealing with customers.
(ii) Ensuring fair practices while dealing with customers.
(iii) Greater transparency enabling customers in having a better understand?ing of products, and
(iv) Taking informed decisions.

A. Loans Applications and their Processing:

a) All communications by VCPL to the prospective borrower shall be made in vernacular language or a language understood by the borrower.
b) The Loan application form of VCPL shall contain necessary information to facilitate the borrower in making a meaningful comparison with the terms and conditions offered by other NBFCs and taking an informed decision based on the comparison. The form shall contain a list of documents required to be submitted by the borrower along with the duly filled up form for processing the application.
c) VCPL will have a mechanism of issuing acknowledgement (off line/online mode) for receipt of the duly filled up loan application along with necessary documents to the borrower. The decision of VCPL regarding acceptance or rejection of application will be conveyed to the borrower within a reasonable period of time from the date of receipt of the required information from the borrower in full.

B. Loan Appraisal and Terms & Conditions:

a) VCPL will process the loan application in accordance with the Board approved Lending Policy that provides for internal credit scoring of the borrower based on risk profile and loan pricing. On sanction of loan VCPL shall convey to the borrower in writing (online/Offline), the terms & conditions of loan sanctioned including amount, annualized rate of interest and the method of its application, penal interest applicable in case of default etc. by means of sanction letter in vernacular language or a language understood by the borrower. A copy of the sanction letter bearing acceptance of the borrower of the terms thereof will be put on record by VCPL.
b) The loan agreement shall specify the penal interest applicable in case of late payment or default by the borrower.
c) VCPL shall at the time of sanction / disbursement furnish a copy of the loan agreement and each of the other loan documents executed to the borrower for ready reference.

C. Disbursement of loans including changes in terms and conditions:

VCPL shall communicate any change in the terms and conditions of loan including disbursement schedule, interest rates, service charges, prepayment charges etc. through its published website/public notice or by issuing appropriate notice if specific to a borrower, in vernacular language or a language understood by the borrower.
a) Changes in interest rates and service charges/levies will be effected prospectively. A suitable provision in this regard shall be incorporated in the loan agreement.
b) Decision of VCPL, if any, to recall/accelerate payment or performance under the loan agreement shall be in consonance with the agreement.
c) VCPL shall release all securities created for the loan upon repayment of all dues by the borrower or on realisation by VCPL of the outstanding amount of loan in full, subject to any legitimate right or lien for any other claim that VCPL may have against the borrower. If such right of set off is to be exercised, the borrower shall be given due notice with particulars of the claim of VCPL and the conditions under which VCPL will be entitled to retain the securities till the relevant claim is settled/paid.

D. Other General Provisions

a) VCPL shall refrain from interference in the affairs of the borrower except for the purposes provided in the terms and conditions of the loan agreement (unless information not earlier disclosed by the borrower, has come to the notice of VCPL). However, this does not imply that the commitment will encroach the right of VCPL to recovery and enforcement of security under law, whatsoever.
b) In case of receipt of request from the borrower for transfer of his account, the consent or otherwise, i.e., objection of VCPL, if any, shall be conveyed to the borrower within 21 days from the date of receipt of request. Such transfer shall be as per transparent contractual terms in consonance with law.
c) VCPL shall not resort to any harassment, such as persistently bothering the borrower at odd hours, use of muscle power for recovery of loan, etc. To ensure this, the staff will be adequately trained to deal with the customers in an appropriate manner.
d) As a measure of customer protection and also in order to bring in uniformity with regard to prepayment of various loans by borrowers, VCPL shall not charge foreclosure charges/prepayment penalties on floating rate term loans sanctioned to individual borrowers for the loans sanctioned for other than business purpose.

E. Grievance Redressal Mechanism:

a) In case of any feedback/ dispute arising out of the decisions of any functionary, the borrower can raise complaint on company’s website (under construction) in case the complaint remained unresolved for more than 7 days, the customer can raise a written complaint addressed to Manager, Customer Services, SF-2, Second Floor, IPEX Mall, IP Extension, Patparganj, Delhi 110092. The authority will issue an acknowledgement and resolve the issue fully and send relative reply to the complainant through fastest mode within 7 working days of receipt of the grievance.
(Till the construction of web site of the company, the borrower can send its complaint at the above given address of the company)
b) The name and contact details viz Telephone Number, Mobile No, Email ID and complete Postal Address of grievance redressal should be displayed prominently in the office premises of the company and on its web site.
c) In case the complaint is not resolved within one month, the complainant may appeal to the officer-in-charge of the Regional Office of DNBS of RBI Parliament Street New Delhi.

F. Interest Rate Model:

In compliance of guidelines of the RBI VCPL has adopted an Interest Policy duly approved by its Board.

G. Review of Compliance of the Fair Practice Code and Grievance redressal Mechanism:

A review of compliance of Fair Practice Code and Grievance Redressal Mechanism shall be submitted by the management to the Board in its annual meetings every year.

Director
Date: 15.05.2023
Place: Delhi

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