Policies and Codes
|DAY END PROCESS ON||DAYS PAST DUE||SCENARIO||CLASSIFICATION|
|05-01-2023||0||If full dues are not received before the day-end process||SMA 0|
|04-02-2023||30||If full dues are not received before the day-end process||SMA 1|
|06-03-2023||60||If full dues are not received before the day-end process||SMA 2|
|04-07-2023||90||If full dues are not received before the day-end process||NPA|
|05-08-2023||–||Full dues for earlier 4 EMIs are received before the day-end process||STANDARD|
IBL Finance Limited (‘Company’) is a Non-Banking Financial Company (NBFC) registered with the Reserve Bank of India (RBI). The RBI has prescribed the guidelines on Fair Practices Code (‘Code’) under Master Direction – Non-Banking Financial Company – Non-Systemically Important Non-Deposit taking Company (Reserve Bank) Directions, 2016 (‘Directions’). The Directions, inter alia, cover general principles on adequate disclosures on the terms and conditions of a loan, collections/ recovery mechanism, protection of customer’s rights, changes in terms & conditions, grievance redressal etc. This Code has been formulated by the Company pursuant to the above guidelines. The Code has been duly approved by Board of Directors of the Company, along with reviewing the changes made thereto, from time to time.
- The Code has been adopted to:
- A) Promote good and fair practices by setting minimum standards in dealing with customers;
- B) Increase transparency so that the customers can have better understanding of what they can reasonably expect of the services;
- C) Strengthen mechanisms for redressal of customer grievances; and conduct recovery and enforcement where required, in a proper manner as enumerated by law.
- D) Promote a fair and cordial relationship between customers and the Company;
The Code is applicable on all persons of the Company offering the Company’s products or services or interacting with the customers as an employee or such other persons authorized to represent it in the course of its business, either through an outsourcing arrangement or otherwise.
RESPONSIBILITIES OF THE COMPANY
- The Company shall at all times do its best to act fairly, reasonably and meet the standard practices prevalent in the industry.
- The Company shall abide by all the relevant laws, regulations and meet the ethical principles of integrity and transparency during its interaction with customers.
- The Company shall provide a copy of this Code, at request, to the customer. The Code will also be made available on its website and at every branch / office.
- The Company shall not discriminate on the grounds of sex, caste and religion in the matter of lending.
- The Company shall treat the information relating to customers as strictly confidential and shall not share any information, unless required under law or waived or permitted by the customer.
- The Company shall take necessary steps to inform its customers of their right to information regarding their account and the facilities available to them.
- The Company shall not indulge in any act which is discriminatory among equals.
- The Board of Directors of the Company shall lay out appropriate internal principles and procedures in determining interest rates and processing and other charges.
- The Company in the normal course of its business shall endeavor at all times to guide its customers about the process and procedure to be followed for availing a loan.
- The Fair practice code’s latest version shall be made available on the the Company (https://iblfinance.in/) as well as on the mobile app (IBL: Instant Personal Loan app) in English, Hindi and such other vernacular language prevalent in the State of operation of the Company.
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 impaired or physically challenged applicants on the ground of disability in extending products, services, facilities, etc. However, this does not preclude the Company from instituting or participating in schemes framed for different sections of the society.
LANGUAGE OF COMMUNICATION
- The Company shall take all steps as may be required to provide clear information to its customers either in
English or Hindi or the appropriate vernacular language regarding:
- The loan product(s) and service(s) offered by the Company;
- The rates of interest and the penal charges/other charges as levied by the Company
- The terms and conditions of sanction;
- Contact details of the Grievance Redressal Officer;
- Notice of change in terms, if any.
- The Company shall be clear and not misleading in any of its advertising and promotional materials.
- The Company shall inform its customers of all financial information such as rates of interest, charges, method of calculation etc. during the course of meeting with the customers etc. prior to entering into any transaction.
- The Company shall inform its customers of all financial information such as rates of interest, charges, method of calculation etc. during the course of meeting with the customers etc. prior to entering into any transaction.
- The Company shall endeavor to keep its customers informed of any in the terms and conditions of the loan. For this purpose, the Company shall give notice to the borrower through letters or any other form of general or public announcement or displays, in English or vernacular language or any language understood by the borrower of any change in the terms and conditions including disbursement schedule, interest rates, service charges, prepayment charges etc.
- The Company shall communicate to the borrowers, at periodic intervals, through SMS, emails or any other mode of communication, the amount outstanding and the date of repayments.
APPLICATIONS FOR LOANS AND THEIR PROCESSING
- A) The Company disburses loans digitally through its mobile app and all the communication with the borrower is completely digital.
- B) The Loan application form / loan application process (hereinafter referred to as “loan application”) on the mobile app shall include the relevant information such as interest rates, loan tenure, nature of security/collateral required, if any, etc. which affects the interest of the borrower so that a meaningful comparison with the terms and conditions offered by other NBFCs or lenders can be made, and informed decision can be taken by the borrower. The loan application shall indicate the documents required to be submitted by the borrower..
- C) All application shall be judged on the merit of the applicant, and on the scrutiny of all the documents submitted and after following the standard procedure for processing all applications.
- D) Receipt of completed loan application will be duly acknowledged by the Company and will also indicate the approximate time frame within which the customer can expect to hear from the Company regarding his/ her loan application. Further in case the loan is rejected, the customer shall be intimated accordingly –
LOAN APPRAISAL AND TERMS AND CONDITIONS
- A) The Company shall carry out due diligence on the borrower to ascertain the credit worthiness of the borrower, which will be an important parameter in making a decision on the application before sanctioning or rejecting any loan application. For this purpose, the Company shall consider various parameters in accordance with the Loan/Credit Policy or such other relevant policy of the Company.
- B) Upon approval of the loan, a Key Fact Statement (KFS) and Sanction Letter in a standardized format indicating the amount of loan sanctioned, annual percentage rate (APR), recovery mechanism, details of grievance redressal, the applicable annualised rate of interest, method of application of the same, various charges and fees in respect of the loan, EMI schedule along with the most important terms and conditions, shall be conveyed in writing to the customer;
- C)The Company shall mention the penal charges, charged for the late payment in bold in the KFS and Sanction Letter as well as the loan agreement.
ANY INTEREST, CHARGE OR FEE OTHER THAN THOSE SPECIFIED IN THE KFS AND SANCTION LETTER SHALL NOT BE LEVIED AND BINDING UPON THE BORROWER. POLICY FOR DETERMINING INTEREST RATES
- A) To ensure that the customers are not charged excessive interest rates and charges on loans and advances by the Company, the Board of Directors of the Company has adopted a Policy on Interest Rate Model and Policies & Procedures on Determining Interest Rates
- B) The information regarding the Interest Rate Model of the Company will be also disclosed in the loan application, KFS and Sanction Letter and shall be displayed on the website as well as the mobile app.
DISBURSEMENT OF LOANS INCLUDING CHANGES IN TERMS AND CONDITIONS
- A) The Company shall execute a loan agreement on its letterhead with the borrower containing all the terms and conditions relating to the loan before disbursement of the loan.
- B) Unless otherwise permitted or required under applicable laws, the disbursal of the loan amount shall be made directly to the borrower’s bank account without any pass-through accounts or to such specified account, in case of any specific purpose of the loan proceeds. Further, any recovery from the borrower shall also be made to the bank account of the Company directly.
- C) The loan agreement shall include a clause to the effect that any change in the terms and conditions, including the interest rate or any charges, shall be with prospective effect only.
- D) The loan agreement shall clearly specify that the borrower shall have an option to exit digital loan by paying the principal and the proportionate annualized percentage rate (‘APR’) without any penalty during the cooling off period. A cooling off/ look-up period is the time window as determined by the Board of the Company which shall be given to borrowers for exiting digital loans, in case a borrower decides not to continue with the loan. The period so determined shall not be less than 3 days for loans having tenor of seven days or more and 1 day for loans having tenor of less than seven days. In case the borrower continues with the loan even after cooling off period, pre-payment shall continue to be allowed as per extant RBI guidelines and as disclosed to the borrower.
- E) After execution of the loan agreement, the borrowers will be furnished a copy of the loan agreement along with a copy each of all enclosures quoted in the loan agreement.
- F) Any changes in the terms and conditions (which are adverse to the borrower) including rate of interest rate, service charges, prepayment charges, repayment/ disbursement schedule etc. shall be effective only with the explicit consent of the borrower in writing; In any case, any change in the terms and conditions shall be effective prospectively and the customer shall be intimated of such change
- G) Decision to recall any loan shall be done in accordance with the terms and conditions of the loan agreement;
- H) All underlying securities shall be released, as per the request of the borrower, after the full repayment of the loan and all other charges in connection with the loan in terms of the loan agreement is complete and subject to exercise of any right of set off, for which a notice shall be given to the borrower with full details.
- 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 borrower insists on transferring the loan, 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 and collection of loan, the Company will not resort to undue harassment viz. persistently bothering the borrowers at odd hours, use of muscle power for recovery of loans, etc. and the process will be in line with the Board-approved Recovery Policy and Code of Conduct for its agents adopted by the Company;
- D) The Company will comply with the extant regulatory provisions with respect to prepayment of loans by its borrowers.
- E) Company staff or any person or any third party authorized to represent the Company in collection of dues shall identify himself / herself and display the authority letter issued by the Company and upon request, display his/her identity card issued by the Company or an authorized person under authority of the Company. The Company shall ensure that the its employees and recovery agents are adequately trained to deal with the customers in appropriate manner.
- F) Any collection or recovery shall be deposited in the bank account of the Company, without ant pass-through accounts.
DISCLOSURES ON THE WEBSITEThe Company’s website (https://iblfinance.in/) shall contain the following details at all times:
- A) Names of digital lending platforms of lending service providers engaged by the Company under an outsourcing arrangement; In such cases, the digital lending platforms and lending service providers shall adhere to the code of conduct formulated by the Company, including, disclosing upfront to the customer that they are interacting with the customer on behalf of the Company
- B) Features of the loan products offered by the Company, loan limit, costs etc.;
- C) APR shall be disclosed upfront to the customers. APR is the effective annualised rate charged to the borrower of a digital loan. APR shall be based on an all-inclusive cost and margin including cost of funds, credit cost and operating cost, processing fee, verification charges, maintenance charges, etc., and exclude contingent charges like penal charges, late payment charges, etc.;
- D) List of the Digital Lending App(s) (DLAs)of the Company;
- E) List of Lending Service Providers (LSPs) engaged by the Company and DLAs of such LSPs with the details of the activities for which they have been engaged;
- H) Details of the grievance redressal mechanism and the grievance redressal officer.
GRIEVANCE REDRESSAL MECHANISM
A grievance redressal mechanism has been set up by the Company to resolve customer grievance and accept feedback / suggestions. This mechanism will ensure that all the disputes arising out of the decisions of the Company’s officers are heard and disposed of at least at the next higher level. The details of grievance redressal policy and grievance redressal officer is available on the website as well as the mobile app of the Company and shall also be disclosed in the KFS and Sanction Letter.
PRIVACY AND CONFIDENTIALITY
REVIEW OF THE CODEThe Board shall conduct a review of the compliance of the Fair Practice Code and the functioning of the grievance redressal mechanism at various levels of management annually or at reasonable interval.
The Reserve Bank of India (‘RBI’), vide its Master Direction- Non-Banking Financial Company- Non-Systemically Important Non-Deposit taking Company (Reserve Bank) Directions, 2016, (‘NBFC Master Directions’), mandates all NBFCs to ensure that a suitable mechanism exists for receiving and addressing complaints from its customers and resolving such complaints in a fair and expeditious manner.
Accordingly, IBL Finance Limited (‘IBL Finance/Company’) has adopted and put in place the following ‘Policy’ parallel to the Company’s Fair Practice Code (‘FPC’), in accordance with the NBFC Master Directions, as amended from time to time.
This Policy has been formulated to develop a robust framework for addressing and resolving the complaints and grievances raised by the customers. It shall be ensured by the Company that:
- Customers are treated fairly and impartially at all times;
- Complaints raised by customers are dealt with courtesy and in a timely manner;
- Customers are informed of the mechanism to escalate their complaints within the organization, and their rights if they are not satisfied with the resolution of their complaints by the Company;
- Officials of the Company strive towards working in good faith and without prejudice towards the interests of the customers.
- Grievance Redressal Officer and Principal Nodal Officer
3.1. The Board shall nominate an employee/officer of the Company as the Grievance Redressal Officer (‘GRO’) who shall be entrusted with the duty of addressing and resolving the grievances raised by the customers, including complaints and issues relating to digital lending.
3.2. The GRO will be available during office hours to receive the grievances of all customers. In the event the GRO is not available, the immediate senior officer in the Company shall attend to the customer.
3.3. 3.3. The Board shall also appoint a Principal Nodal Officer at their head office who shall not be a rank less than a General Manager or an officer of equivalent rank and shall be responsible for representing the Company and furnishing information on behalf of the Company in respect of complaints filed against the company.
- Grievance Redressal Mechanism
4.1. Lodging of compliant
4.1.1. The Company shall ensure that all locations, where the Company is having its operations as well as through its application/ website, have a dedicated set-up to address customer grievances/ complaints to ensure prompt grievance redressal.
4.1.2. All grievances made by the borrowers will be electronically recorded and maintained by the Company at its principal place of business and in each of its offices/branches(if any).
4.1.3. The Company shall ensure that the customers quote their application number/sanction number/loan account number in all their correspondence with the Company. Anonymous complaints shall not be addressed under this mechanism.
4.1.4. The Company shall endeavour to provide an acknowledgement to complaints received from its customers.
4.2. Resolution process and time frame
4.2.1. If the customer has any grievance in respect of the services provided by the Company, the customer shall contact the Company’s Customer Service Department (‘CSD’) through any of the following channels:
Email at: email@example.com
A letter may be alternatively sent at the address: Office No. 1001, World Trade Centre, Nr. Udhna Darwaja, Ring Road, Surat, Gujrat 395002
4.2.2. If the customers are not satisfied with the resolution received from the above channel or if the customers do not hear from us in 15 (fifteen) days, the customer may escalate the complaint to the GRO through email or contact on the contact number below. The customer may also approach the registered or branch office of the Company, in-person, to lodge a complaint.
Details of the GRO are as follows:
Grievance Redressal Officer
Name: Grievance Redressal Officer
Email ID- firstname.lastname@example.org
Address: off. No. 1001, World Trade Centre, Nr. Udhna Darwaja, Ring Road, Surat, Gujrat 395002
Tel: +91 6352571130
4.3. The Company shall endeavour to resolve the complaints and grievances of customers within reasonable time. The customer shall be kept informed about the status of their complaints.
4.4. Certain types of cases might need additional time due to the nature of the activities involved; for e.g. retrieval of documents. The Company shall inform the customers of such delay and provide expected timelines for resolution of the complaint.
4.5. If the complaint is not resolved within one month of lodging of the complaint, or if the customer is not satisfied with the response of the Company, the customer may lodge their complaint to the Consumer Education and Protection Cell (CEP Cell) on the email id : (email: email@example.com or on their online portal: https://cms.rbi.org.in/.
The complaint shall contain the name and address of the complainant, the department against which the complaint is being made, and facts of the case supported by documents, if any, relied upon by the complainant.
The Officer In-Charge
Consumer Education and Protection Cell
Reserve Bank of India
3rd Floor, Nr. Income Tax
The customer may also lodge their complaint to State Level Coordination Committee (SLCC) on https://sachet.rbi.org.in/home/index
4.6. Alternatively, the customer may also approach the Officer-in-Charge of the Regional Office of Department of Supervision of RBI:
The General Manager,
Department of Non-Banking Supervision, Reserve Bank of India,
Near Gandhi Bridge, Ahmedabad- 380 014.
Tel: 079-2754 3057/ 5651
- In case of outsourcing
5.1. The provisions of this Policy shall also extend to deal with the issue relating to services provided by the outsourced agency, in case the Company has outsourced any of its functions.
5.2. The GRM, in no way, shall be compromised on account of outsourcing.
- Additional requirements in case of digital lending
6.1. In case of digital lending, as defined under the RBI Guidelines on Digital Lending, the Company shall ensure that the GRM and the Lending Service Providers (‘LSPs’)
1 engaged by them shall have a suitable Grievance Redressal Officer to deal with FinTech/ digital lending related complaints/ issues raised by the customers. In this case, the GRO of the Company shall also handle all such issues related with digital lending.
6.2. Contact details of Company’s GRO shall be prominently displayed on Company’s website, as well as on the websites of the LSPs and on the Digital Lending Application (‘DLA’) 2 and also in the Key Fact Statement3 provided to the customer. Further, the facility of lodging complaints shall also be made available on the DLA and on the website as stated above.
6.3. If any complaint lodged by the customer against the Company or the LSP engaged by the Company is not resolved by the Company within one month, he/she can lodge a complaint with the above RBI officers in the same manner as provided in this Policy. In any case, the responsibility of grievance redressal shall continue to remain with the Company.
- Display of details of redressal mechanism
7.1. The Company shall prominently display, on its website/app, details in respect of Grievance Redressal Mechanism, i.e., name and contact details, telephone no., email address of the Customer Service Department and the GRO.
7.2. In addition to the display on the website, the above-mentioned information shall also be displayed in the offices of Company where business is transacted. In this case, the Company may display the information in English as well as a vernacular/regional language.
8.1. The Company follows a strict no-discrimination policy and does not does not discriminate against persons with any disability. In furtherance of the ethos and values of the Company, the Company shall ensure the redressal of grievances of persons with disabilities under the GRM.
8.2. It shall create awareness about the GRM and educate its customers about it.
The Board shall conduct quarterly review of the functioning of the GRM at various levels of management. This Policy shall be reviewed at such periodicity as decided by the Board, subject to at least one review annually.
1,2,3 As defined under the RBI Guidelines on Digital Lending
The Reserve Bank of India (‘RBI’), vide the Master Direction-Non-Banking Financial Company – Non-Systemically Important Non-Deposit taking Company and Deposit taking Company (Reserve Bank) Directions, 2016 (‘NBFC Master Directions’), as amended from time to time, has directed all NBFCs lay out appropriate internal principles and procedures in determining interest rates, processing and other charges. In this regard, RBI further requires NBFCs to adopt an appropriate interest rate model taking into account relevant factors and to disclose the rate of interest, gradations of risk and rationale for charging different rate of interest. With a view to instituting fair and transparent dealings in the lending business, IBL Finance Private Limited (‘IBL Finance/ Company’) has adopted and put in place the following Interest Rate Policy parallel to the Company’s Fair Practice Code, in accordance with the NBFC Master Directions, as amended and updated from time to time. Keeping in view the NBFC Master Directions, and the good governance practices being followed by the Company, the following internal guidelines, policies, procedures and interest rate model have been adopted by the Company. The Board of Directors of the Company (‘Board’), while fixing interest rates chargeable from the customers shall be guided by this Interest Rate Policy (‘Policy’). In addition to cost factors set out hereunder, the Board or the Committee shall be guided by the market conditions and various rules and regulations, if any, prescribed by the RBI or such other authority from time to time
- Financial facilities covered by the Policy
The Company extends various credit facilities to its customers to cater to the needs of different categories of customers. This Policy shall be applicable to all such financial facilities, as listed below:
- Unsecured Personal Loan
- Meaning of rate of interest
Interest rate shall mean the annualized rate on the credit facilities charged to the borrower by the Company, based on the periodicity of payments, for example, monthly quarterly, etc. The interest rate shall not include the following (the exclusion list is inclusive in nature and shall not be only limited to the components
- Processing costs
- Document charges
- Stamp duty
- External Cost
- Penalties, including late penalties
- Contingent charges
- Prepayment charges
- Third party benefits such as subventions, subsidies etc.
- Any other cost as may be determined by the Committee
- Rates of interest
- The Company may charge either fixed rate or floating rate interest rate for its loan products based on various factors discussed below in this Policy.
- In case of fixed interest rates, the spread would be computed based on product specific and customer specific parameters, as may be determined by the Committee. Fixed interest rates shall not be reset and remain fixed.
- In case of a floating interest rate loan, the base rate and the spread shall be recommended by the Committee and shall be approved by the Board. The interest reset period for floating rate lending would be decided by the Committee from time to time, applying the same decision criteria as considered for fixing interest rates.
- The rate of interest for the same product and tenor availed during the same period by different customers need not be standardized. The final lending rate applicable to each customer will be assessed based on various factors as detailed in this Policy.
- Other factors to be considered
The interest rate applicable to each loan account, within the applicable range, shall be determined on a case-to-case basis, based on evaluation of various factors such as:
- Structure of the deal
- Interest rate trend prevailing in the money market
- Nature of lending, such as secured/unsecured and the associated tenure
- Risk profile of the customer- professional qualification, stability in earnings and employment
- Risk premium keeping in mind the inherent credit and default risk in the product and customer per se arising from relevant customer agreement
- Long term prospects of business with the customer
- Past repayment track record of the customer
- Loan specific costs
- Company’s cost of borrowings
- customer negotiations/deviations
- Industry trends- offerings by competition
- Upfront charges
- Outsourcing cost
- Methodology & Approach for gradation risk
- The rate of interest shall be arrived at based on the above-mentioned factors.
- The decision to give a loan and the interest rate applicable to each loan account is assessed on a case-to-case basis, based on multiple parameters such as the type of the asset being financed, borrower profile, and repayment capacity, borrower’s other financial commitments, past repayment track record if any, the security for the loan as represented by the underlying assets, loan to value ratio, mode of payment, tenure of the loan, geography (location) of the borrower, end use of the asset etc. Such information is collated based on borrower inputs, credit bureau and field inspection by the company officials.
- The interest rate charged shall be specifically disclosed in the sanction letter/ key fact statement and other relevant communications with the borrowers.
- Other charges
- Besides interest, other financial charges like processing fees, cheque bouncing charges, foreclosure charges/ prepayment penalties, cheque swapping charges, duplicate repayment schedule and legal, repossession and other related matters would be levied by the Company wherever and in the manner considered necessary. Besides the base charges, goods and services tax would be collected at applicable rates from time to time.
- These charges would be decided upon by respective product heads in consultation with operations, finance, and legal.
- However, the Company shall not charge foreclosure charges/ prepayment penalties on any floating rate loan sanctioned for purposes other than business to individual borrowers, with or without co-obligors.
- Penal interest may be charged on any loan remaining unpaid on due dates at such rates as may be determined by the Company provided in the customer loan agreement. These additional or penal interests for different products or facilities would be decided by the respective functional/ product heads. The penal interest charged for late repayment shall be mentioned in bold in the customer loan agreement for drawing the due attention of the customer.
- The borrower shall be intimated about the loan amount and annualised rate of interest, and if granted through digital lending applications1, annualised percentage rate (‘APR’), at the time of sanction of the loan along with the other
terms of the loan.
- The rate of interest and the approach for gradations of risk and rationale for charging different rates of interest to different categories of borrowers shall be disclosed in the application form and communicated explicitly in the sanction letter.
- The rates of interest and the approach for gradation of risks shall also be made available on the website.
- Any change in the interest rate or other charges shall be made prospectively applicable with the concurrence of the borrower, and this condition shall be incorporated in the loan agreement.
- Administration, Amendment and Review of the Policy
The Board shall be responsible for the administration, interpretation, application and review of this Policy. The Board or the Committee, as the case may be, shall also be empowered to bring about necessary changes to this Policy, if so required at any stage at its own discretion or with concurrence. This Policy may be altered/revised as per changes in the market scenario and/or statutory guidelines. This Policy shall be reviewed at least once in a year or when there are amendments in the applicable guidelines.
The Data/Information We Collect About YouWe collect or use and store personal information about you in connection with providing the services to you, after obtaining your consent. Please note that we only collect and process the minimum necessary details of your personal data or information to provide the services to you. For the purpose of credit risk assessment, we need the following permissions from you.
* Identity and personal data: This includes your first and last name, date of birth, gender, selfie, educational qualifications, income source, monthly income and contact information (including addresses, email IDs and phone numbers).
* KYC data: This includes identification documents issued by the government or other authorities, and includes details of or pertaining to your Aadhaar or PAN card.
* Data from SMSs: We will request permission to collect, transmit and store your SMS messages for the purpose of to verify and analyse your financial position, to determine your cash flow, credits, income, and spending pattern and data from SMSs store on our secured IBL Finance Private Limited(IBLFIN) server. Post collecting all SMSes, IBL Finance Private Limited(IBLFIN) will only store financial SMSes sent by 6-digit alphanumeric senders, which helps us to identify the various accounts held by the user and to help perform an optimal ‘credit risk assessment’ of the user. We will only store messages that are relevant to this purpose and will not store irrelevant or personal messages in any form or manner. The permission is voluntary and can be revoked at any time. However, denying access may lead to an inaccurate assessment of the borrower’s credit assessment on the platform.
* Device data: Collect and monitor specific information about your device including your hardware model, operating system and version, unique device identifiers like IMEI and serial number, user profile information and mobile network information to uniquely identify the devices and ensure that unauthorized devices are not able to act on your behalf to prevent frauds.
* Storage Data(Images Or Documents): We collect and monitor the required KYC images or documents and also take the user’s selfie with the user’s permission, for KYC verification and complete the loan application process.
* Location : We collect location details one time to verify your approximate location, to ensure serviceability and to identify unusual activity to prevent against any fraud, we do not collect live or exact location when the app is in the background.We collect, transmit and store above mentioned all data on our secured IBL Finance Private Limited(IBLFIN) server. We do not access your mobile phone resources such as files and media (except as disclosed above to enable you to upload documents), call logs and telephony functions. We do not collect your biometric data. We are required to collect your personal data to provide you with access to the Platform and Services. In certain cases, we are required to collect personal data as required by law, or under the Terms. If you fail to provide us that data as and When requested by us, we will not be able to perform our obligations under the arrangement we have with you or are trying to enter into with you (for example, to provide you with features of the Services). In this case, we may have to cancel or limit your access to the Services (or part thereof).
Consent of The UsersWhen a user applies for any loan or finance from us, we first obtain the user’s authority/consent (by means of e-signature, ‘I agree’ tick box, one time password, yes/no authentication etc). Users give their consent that his/her customer data will be stored and processed by us for various purposes. A customer has the right to access and correct their customer data by contacting IBL Finance Private Limited(IBLFIN). While using the IBL Finance Private Limited (IBLFIN) website or mobile application, you agree not to engage in illegal or unauthorized activities in any way (including hacking, cracking or defacing any part of the site).
Use of User InformationBy submitting User information to IBL Finance Private Limited(IBLFIN), User expressly acknowledge and consent to use of such information in a manner specified under this Policy. User information can be used for various purposes including without limitation the following:
- * Verifying User identity.
- * To facilitate the user using the IBL Finance Private Limited (IBLFIN) platform.
- * To obtain credit reports and evaluate your creditworthiness for availing the loan / facility from IBL Finance Private Limited (IBLFIN).
- * Extending loans and financial services to the user from regulated entities including but not limited to banks, NBFCs, NBFC-P2P, other financial partners, etc.
- * To ensure compliance of all legal obligations of lending partners for the purposes of facilitating loans / financial services, Know Your Customer, Prevention of Money Laundering, CKYRC requirements etc.
- * For fraud prevention and detection.
- * To diagnose technical problems, provide support and assist users in troubleshooting issues.
- * To send communications, notifications and receive promotional offers.
- * To prepare, review and file reports as required by applicable law.
- * To understand User preferences, requirements.
- * To allow the User to participate in the interactive features offered by the IBL Finance Private Limited (IBLFIN).
- * To improve content and protect the integrity of IBL Finance Private Limited (IBLFIN).
- * To increase / improve the products / services offered on IBL Finance Private Limited (IBLFIN).
- * To ensure compliance with all applicable laws.
* Protection of App: We release personal information when we believe, release is appropriate to comply with the law; enforce or apply our User Terms and Conditions and other agreements; or protect the rights, property or safety of App, our users or others. This includes exchanging information with other companies, organizations, government or regulatory authorities for fraud protection and credit risk reduction.
- * If you are no longer interested in sharing your Personal and Sensitive Information, please e-mail your request at: firstname.lastname@example.org
- * To the Government and other judicial bodies as required under the law in order to comply with the legal obligations (without the prior permission of customers).
SecurityWe value your trust in providing us your Personal Information, thus we are striving to use commercially acceptable means of protecting it. But remember that no method of transmission over the internet, or method of electronic storage is 100% secure and reliable, and we cannot guarantee 100% its absolute security.However, we will do our best to protect and secure your personal information.
Contact UsFor any query or complaint regarding the privacy and sharing of your customer data, including sharing with third parties, or for suggestions for amendments to this policy, you may contact: Grievance Redressal Officer, Customer Care Department, IBL Finance Private Limited, 6025, World Trade Centre, Nr. Udhna Darwaja, Ring Road, Surat-395002, Gujrat, India. E-mail: email@example.com, Tel : +91 93281 16200.
Recovery is an important aspect of the business of a Non-banking Financial Company (‘NBFC’) so as to ensure that the portfolio remains healthy. Ensuring that collections and recovery of loans are carried out in an effective manner is crucial in ensuring that the NBFC has in place, appropriate recovery mechanisms that adhere to and are in accordance with, fair and ethical practices. The Reserve Bank of India (‘RBI’), vide the Master Direction-Non-Banking Financial Company – Non- Systemically Important Non-Deposit taking Company and Deposit taking Company (Reserve Bank) Directions, 2016 (‘NBFC Master Directions’), as amended from time to time, has directed NBFCs to adopt a ‘Fair Practices Code’ which would, inter alia, include, fair practices with respect to collection and recovery from borrowers of the NBFC.
IBL Finance Private Limited (‘IBL Finance/ Company’) believes in following fair practices with regard to collection of dues and thereby fostering a strong, long term relationship with the customer. Therefore, the Company has adopted and put in place the following Recovery Policy (‘Policy’) parallel to the Company’s Fair Practice Code, in accordance with the NBFC Master Directions, as amended and updated from time to time.
The purpose of the Policy is to lay down practices to be followed by the Company in the matter of recovery of dues in the event of default.
- Manner of collection of dues
The Company would adhere to the following guidelines in the matter of recovery of dues from borrowers –
- The Company shall strictly observe the ethical practices and provisions of Fair Practices Code as formulated by Company and other related stipulations by the RBI with respect to recovery of
- Customers would be ordinarily contacted through the contact details registered with the Company and the Company staff would inform the customer with respect to information regarding their dues;
- Normally the Companies’ representatives will contact the borrower during ordinary business hours between 08:00 hours to 19:00 hours, unless the special circumstances of the borrower’s business or occupation requires the Company to contact at a different time;
- The Company is committed to ensure that all written and verbal communication with its borrowers will be in simple business language and the Company will adopt civil manners of communication for interaction with borrowers;
- The Company shall, while protecting its interest, adopt reasonable and lawful measures to recover its dues from defaulting customers, including use of persuasive methods for the purpose of collection of its dues;
- The Company shall not resort to intimidation of customers, either verbal or physical, or undue harassment by persistently bothering customers at odd hours, use of force and violence, , for recovery of loans.
- In case of any default by the customer, the Company shall serve a notice, through such mode of communication as agreed in the loan agreement, to the customer stating the following:
- the total amount outstanding under loan facility;
- the period within which such outstanding amount shall be paid by the customer;
- the actions that the Company shall take in case of non-repayment within the specified grace
- Upon expiry of the grace period specified in the notice and upon being satisfied that there are no other means of recovering the outstanding amount, the Company shall proceed with the invocation of security interest, if any, or other appropriate legal action shall be initiated by the
- Collection staff/ Recovery agents
While engaging and employing personnel in the recovery function of the Company, the Company shall ensure that adequate training is provided. The recovery personnel should be trained to handle their responsibilities with care and sensitivity with due regard to soliciting customers, hours of calling, privacy of customer information and conveying the correct terms and conditions of the products on offer, etc.
Where the Company is outsourcing its recovery function and engaging recovery agents, Company shall be responsible in training the recovery agents for handling recovery procedures.
While outsourcing the recovery function and engaging recovery agents, the Company shall ensure compliance with the outsourcing guidelines issued by RBI in this regard and the Company shall retain ultimate control of the outsourced activity.
A board approved code of conduct for recovery agents has been put in place, and at the time of appointment of any recovery agent, it is ensured to obtain their undertaking to abide by the code.
The Company shall ensure that the staff and recovery agent shall not resort to intimidation or harassment of any kind, either verbal or physical, against any person in their debt collection efforts, including acts intended to humiliate publicly or intrude upon the privacy of the debtors’ family members, referees and friends, sending inappropriate messages either on mobile or through social media, making threatening and/or anonymous calls, persistently calling the borrower and/ or calling the borrower before 8:00 a.m. and after 7:00 p.m. for recovery of overdue loans, making false and misleading representations, etc.
If at all there is a need for an in-person visit by Company’s personnel or recovery agents to a customer, it shall be done during reasonable hours of the day.
The Company shall be responsible for all the acts of the recovery agents.
- Recovery/ Collection in digital lending cases
For the purpose of recovery/ collection in case of digital loans extended by the Company, the ‘Guidelines on Digital Lending’ issued by RBI on September 02, 2022 would also have to be adhered to.
The Key Fact Statement (‘KFS’) provided to the borrower by the Company will contain the details of the recovery mechanism of the Company.
In case Lending Service Providers (‘LSPs’) are engaged as recovery agents for digital lending cases, the Company shall communicate to the borrower, at the time of sanctioning of the loan and also at the time of passing on the recovery responsibilities to an LSP or change in the LSP responsible for recovery, the details of the LSP acting as recovery agent who is authorised to approach the borrower for recovery.
Additionally, the guidelines laid down by the RBI vide circular dated June 24, 2020 ‘Loans Sourced by NBFCs over Digital Lending Platforms: Adherence to Fair Practices Code and Outsourcing Guidelines’ as also incorporated in the NBFC Master Directions, shall be applicable, in case of collection and recovery of digital loans.
The Company shall impart necessary guidance to LSPs acting as recovery agents to discharge their duties responsibly and ensure that they comply with the extant instructions in this regard.
- Administration, Amendment and Review of the Policy
The Board shall be responsible for the administration, interpretation, application and review of this Policy. The Board or the Committee, as the case may be, shall also be empowered to bring about necessary changes to this Policy, if so required at any stage at its own discretion or with concurrence.
This Policy may be altered/revised as per changes in the market scenario and/or statutory guidelines. This Policy shall be reviewed at least once in a year or when there are amendments in the applicable guidelines.
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Creation of User Account for availing ServicesTo obtain the Loan(s) or to avail other services from us from time to time, the User has to create an account (“User Account”) with us by registering himself/ herself. You are solely responsible for maintaining the secrecy of your user id and password for the User Account and shall be responsible for all activities that occur in connection with your User Account. In case of any unauthorized use of your User Account the same shall be intimated to us. You shall not create multiple User Accounts and shall not use your User Account for any purpose that is unlawful, illegal or forbidden by law. As a consideration for availing Loan/ Service through Website, you may be required to pay certain fee, charges, interest or cost as may be applicable as mentioned in our Website or as per the terms for respective products and services as prescribed by us. You understand that application of loan through online means is dependent on technical factors which inter alia includes your connectively to internet, your ability to make payment through online means which in-turn is depended on payment services from your bank or similar service providers, capability of the computer or phone which you use for the purpose, your careful approach in reading the terms, understanding the same and following the process. You have sole responsibility for adequate protection and back up of data and/or equipment and for undertaking reasonable and appropriate precautions to scan for computer viruses or other destructive properties. We make no representations or warranties regarding the accuracy, functionality or performance of any third party software that may be used in connection with the Website. For the purpose of creating the User Account through the Website:
- You shall be an Indian citizen resident in India and minimum 18 years of age
- You shall not be a person either barred or otherwise legally prohibited from taking Loan or availing services offered by us
- You should have an updated UID (Aadhaar) number and Permanent Account Number (PAN) or such other valid identity proof and residential address proof as described by Reserve Bank of India and prescribed by us for Know Your Customer requirements
- You shall not impersonate any person or entity or falsely state or otherwise misrepresent age, identity or affiliation with any person or entity.
- You have valid email address and valid mobile number where you want to receive OTP and other communications from Operator.
- You have a bank account in India (bank name, IFSC, branch and account number) having enabled internet banking facility for the purpose of transfer/ receipt of funds.
- You should be either salaried employee or self-employed or pensioner.
- Your desktop/ mobile device should have:
- Supported Resolutions: 1366 x 768+. Best viewed on 1366 x 768
- A working internet connection having HTML supported Web Browsers: Chrome 55+, Firefox 49+, Edge 38+ or Mobile Browsers: Latest version of Chrome, Firefox, Safari Browser
- Latest version of Adobe Reader: https://get.adobe.com/reader/
- A web camera
Prohibited ConductBy using our Website you agree that you shall not:
- use our Website for spamming or illegally interfere with security, integrity, networks connected therewith and operation related features of our Website or features that enforce limitations on the use of Website;
- Infringe ours or any third party’s intellectual property rights, rights of publicity or privacy;
- post or transmit any message data, image or program which violates any law or which is libelous, defamatory or which discloses private or personal matters concerning any person;
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- upload any content that constitutes negligent advice or contains any negligent statement or instructions, an incitement to commit or promote a crime or criminal activity; or any content which is in contempt of any court, or in breach of any court order or any law for the time being force or threatens the unity, integrity, defense, security or sovereignty of any country, or public order;
- Use the facilities and capabilities of Site to conduct any activity or solicit the performance of any illegal activity or other activity which infringes the rights of others;
- Breach these Terms or any other policies which we have; and
- Use Site to collect or obtain personal information, including without limitation, personal information about other users of our Site.