Fair Practice

Fair Practice

1.  Preamble

In order to establish guidelines for fair business and corporate practices when interacting with their customers, the Reserve Bank of India (RBI) has released guidelines in its circular “Master circular – fair practice code” dated on July 1, 2011 on the Fair Practices Code for Non- Banking Financial Companies (NBFCs). Based on the RBI's guidelines, Lion lender Finance Private Limited (hereinafter referred to as "the Company") hereby provides the Fair Practices Code (also known as "the FPC"). The FPC is mandatory for all non-bank financial institutions (NBFCs) to implement while conducting lending business.

2.  Applicability

The FPC is applicable to the business and all of the goods and services it provides, whether via phone, online via its website, or through any other channel. It will also be applicable to all of the company's directors and employees. All facets of the business' operations, including marketing, loan origination, processing, servicing, and collection activities, must adhere to the company's fair lending practices.

3.  Objectives
In an effort to achieve synchronization of best practices when the company interacts with its stakeholders, the company implemented the FPC. The following are the main goals for implementing the FPC:
a.  To encourage moral behavior by establishing minimal requirements for customer service;
b.  To improve transparency in order to give the client a clearer idea of what to expect from the services;
c.  To encourage a just and friendly relationship between the client and the business:
d.  To guarantee that the products and services offered abide by all applicable laws and rules that are in effect in India;
e. To promote trust in the financial services sector.
Establishing procedures to make sure that the company's operations demonstrate a strong commitment to fair lending and that all employees are aware of that commitment is the responsibility of the management and the Board of Directors of the company.
4.  Fair Practices Code Guidelines applicable on the Company
Applications for loans and their processing

· The company is a lender and provides its clients with unsecured loans.

· Prospective borrowers will have access to loan application forms upon request.
· The loan application includes information that could impact the borrower's interests, allowing the borrower to make an informed decision by meaningfully comparing the terms and conditions offered by other NBFCs and financial institutions.
· The platform for loan applications provides a list of the documents that the borrower must submit with their loan application. ·         The additional information that borrowers and their families must provide in order for the company to build the database may also be listed on the loan application form.
· The business will provide the acknowledge receipt of each successfully submitted loan application and provide a timeline for loan application processing.
· The Company will promptly notify the borrowers if any additional information or documents are needed after verifying the loan applications, which it will do in a reasonable amount of time. If the Company rejects the loan application, it will notify the borrower via the digital platform of the reason(s) for the denial.
· All correspondence with the borrowers must be in a language that they have confirmed they understand.
Loan Appraisal and Terms & Conditions

·  The Company will evaluate each loan application in light of its adopted risk-based assessment procedures. Prior to approving a loan, the Company will determine the borrower's ability to repay the loan.

·  A Sanction Letter will be used to notify the borrowers in writing of the loan's approval. As a sign of their acceptance of the terms and conditions governing the loan, the borrowers must acknowledge in writing. The general terms and conditions of the loan, including the annualized interest rate and how it will be applied, will be included in the Sanction Letter.

· The borrower will receive a copy of all loan documentation, including the loan agreement and any appendices.

· The loan agreement contains a bold mention of the penal interest that the company charges for late repayment. When loans are sanctioned or disbursed, the Company will provide each borrower with a copy of the loan agreement as understood by them and a copy of every enclosure mentioned in the loan agreement.

· When lending under a consortium arrangement, the participating banks and NBFCs would determine when to finish the proposal appraisal and communicate the outcome. The Consortium's decision will be followed by the Company.

Disbursal of loans including change in Terms & Conditions

· If all requirements are met, including signing loan documents, the borrowers may be given access to the entire amount of loans that have been approved.

· If there are any changes to the terms and conditions, such as interest rates, fees, or other charges, the Company will notify the borrower. Only prospective changes to interest rates and fees may be made, and the loan agreement must contain a special provision about them. The borrowers will also receive written notice of any such changes.

Post Disbursement Supervision

· The terms and conditions of the Loan Agreement shall govern the Company's decision, if any, to recall or speed up loan performance or payment. Before recalling the loan or requesting an acceleration of the payment or performance.

· The Company will give the borrowers a reasonable amount of time, subject to the terms and conditions outlined in the Loan Agreement and any other relevant documents.

· When the loans are fully repaid, the collateral held by the company may be released, subject to any applicable lawful rights or liens, and used as collateral for any further claims the company may have against the borrowers. However, the collateral may be kept by the company for operational convenience and to safeguard its interest in the event that the borrower has taken advantage of the facility that permits him to borrow or draw money within the total amount sanctioned as and when needed by him.

5.  Privacy and Confidentiality

The Company will maintain the privacy and confidentiality of borrowers' personal information even after they have repaid the loan. Unless mandated by law, government authorities, including regulators, or a credit agency, the Company shall not disclose any information about a customer to any third party without the customer's written consent.

Unless the borrower gives express permission, the company is not permitted to use the borrower's personal information for marketing purposes.

6.  Collection of Dues
Employees of the Company or any contracted agency involved in loan collection will receive the necessary training to enable them to carry out their duties with tact and consideration, taking into account things like contacting customers, the privacy of their personal information, and communicating the accurate terms and conditions of the products, among other things. Courtesy, equitable treatment, and persuasion shall be the cornerstones of the Company's collection policy and procedure.

The business is committed to building enduring relationships with its customers and their confidence.

When collecting debts, all employees of the company or outside recovery agents must adhere to the rules outlined below:

· The customer will be contacted as usual at his registered mobile number, at the location of his/her choice, or, in the event that no location is specified, at the place of residence.
· The customer shall be informed in the first instance of the identity and authority of the person representing the Company. ·         The privacy of the customer will be honored.
· Communication with the client must be courteous, and calls to the client shouldn't be made at strange times.
· Customers' requests to not receive calls at specific times or locations will, to the greatest extent feasible, be complied with. ·         The duration, quantity, and subject matter of calls must all be documented.
· Every effort should be made to settle disagreements or conflicts about payments in a fair and systematic way that is acceptable to both parties.
· Decency and decorum must be upheld when collecting debts from customers at their homes. In the course of their debt collection efforts, the Company and its agents shall not use any form of intimidation or harassment, either verbal or physical, against any person. This includes actions meant to violate the privacy or cause public embarrassment to the customers' friends, family, and referees, as well as making anonymous or threatening phone calls or making false and misleading statements.
7.  Other General Provisions

· Except as specified in the loan documents' terms and conditions, the Company will not become involved in the borrowers' affairs (unless it becomes aware of new information that the borrower has not previously disclosed).

· In general, the Company will grant its approval to any requests from the borrower to move their loan account to another bank, financial institution, or NBFC within a reasonable amount of time. This transfer must comply with the terms of the agreement that was made with the borrower as well as any applicable laws, rules, regulations, and guidelines at any given time.

· In its lending practices and policies, the Company shall not discriminate on the basis of gender, caste, or religion.

· When it comes to loan recovery, the Company will follow established procedures and legal guidelines while adhering to the law. It will also take all customary actions that are lawfully and properly within its power.

· Upon request from the borrower, the company will furnish the terms and conditions pertaining to its lending activities or services.

· If the borrower requests that his loan account be closed, the request will be fulfilled within 21 days of being received, provided that all outstanding payments have been paid and all company-mandated procedures have been fulfilled. The borrower may be informed if the request is unable to be fulfilled within the specified time frame for any reason.