INTRODUCTION
The Fair Practices Code aims to provide to all those who will be associated with Ricavi Finance Private Limited (“NBFC” or “the Company”) RBI classification as NBFCInvestment and Credit Company (NBFC-ICC)-NBFC-base Layer (NBFC-BL) with the information about the practices that Ricavi Finance Private Limited follow in respect of the financial facilities, loans and services provided, which will facilitate its customers/borrowers to take informed decisions in respect of the financial facilities and
services to be availed of by them.
The Fair Practices Code will apply to any loan that Ricavi Finance Private Limited may sanction and disburse. Ricavi Finance Private Limited has adopted the Fair Practices Code (the “FPC”) pursuant to as per Master Direction – Reserve Bank of India (Non-Banking Financial Company – Scale Based Regulation) Directions, 2023 (the Directions), as amended from time to time.
The Company would update the FPC to conform to the standards that may be prescribed by RBI from time to time. The Company would abide by this FPC following the spirit of the Code and applicability to its business. The FPC has been approved by the Board of Directors of the Company and the same will be disclosed on the Company’s website.
REGULATORY REQUIREMENT
The Reserve Bank of India has issued its extant guideline in respect of Fair Practice code, to be followed by an NBFC, by defining and setting standards, which are expected to comply with, while dealing with its existing or prospective customers, vide master circular. DNBR (PD) CC. No. 054/03.10.119/2015-16 dated July 01, 2015 and Master Direction – Reserve Bank of India (Non Banking Financial Company – Scale Based Regulation) Directions, 2023 as amended from time to time. These guidelines are issued under section 45 IC of Reserve Bank of India Act, 1934.
The Company has put in place the best practices to be followed while operating (which has been set out forth in this document) and implemented a “Fair Practice Code”.
KEY OBJECTIVES
• The Company will conduct its business in accordance with prevailing rules and regulations and corporate governance principles.
• The Company’s dealings with its customers will rest on the principles of fairness, transparency and honesty.
• The Company will assist its customers in understanding the broad features of its financial products and will provide them with key terms and conditions governing sanction of credit facilities.
• The Company will promote fair and cordial relations with its customers/borrowers.
APPLICATION FOR LOANS AND THEIR PROCESSING
• All communications will be made in a language understood by the customers/borrowers or in a vernacular language, wherever required.
• The loan documentation set would, inter alia, include the broad features and the terms and conditions governing the loan. so that a meaningful comparison with the terms and conditions offered by other NBFCs can be made and an informed decision can be taken by the customers /borrowers.
• The loan application form would indicate the documents required to be submitted by the borrower. It would also indicate the rate of interest that will be charged to different categories of borrowers.
• An acknowledgement would be provided for all loan applications received. The Company will indicate the approximate time frame within which the loan application will be processed post the submission of a completed loan application form and the borrowers will be informed about the status of their loan applications within a time period not exceeding 21 days.
LOAN APPRAISAL AND TERMS & CONDITIONS
• The loan applications would be subject to the Company’s credit appraisal process and a due diligence on the creditworthiness of the customers/borrowers, which will form an important
parameter for taking a decision on a loan application.
• Ricavi Finance Private Limited would convey in writing to the customers/borrowers by means of a sanction letter, the amount of loan sanctioned along with the terms and conditions including the annualised rate of interest and method of application thereof. In case of specific app based/paperless loans provided, the Company would convey the details mentioned above through email
to the registered email address of the Borrower.
• Ricavi Finance Private Limited would keep on its record the acceptance by the customers/borrowers of the terms and conditions governing the sanction of the loan. In case of app based/paperless loans, request by the borrower to disburse the sanctioned loan amount or part thereof would be deemed to be acceptance by the borrower of the terms and conditions governing sanction of loan.
• At the time of sanction/disbursement of loans, Ricavi Finance Private Limited would furnish to all customers/borrowers a copy of the loan agreement/terms and conditions, if any, along with a copy of all enclosures mentioned in the loan agreement.
• The Company shall provide a Key Facts Statement (KFS) to the borrower before execution of the loan agreement, in the format prescribed by the Reserve Bank of India, containing all material information including the Annual Percentage Rate (APR), rate of interest, processing fees, penal charges, foreclosure/prepayment charges, tenure, repayment schedule, and any other applicable charges.
• The KFS shall be acknowledged by the borrower and shall form part of the loan documentation. No charges other than those disclosed in the KFS shall be levied on the borrower.
DISBURSEMENT OF LOANS INCLUDING CHANGES IN TERMS AND CONDITIONS
• Ricavi Finance Private Limited would frame internal guidelines and procedures for determining and ensuring that the interest rates and processing and other charges levied to the borrowers are not excessive.
• The disbursement will be made upon compliance of all the terms and conditions of sanction of loan by the customers/borrowers. Ricavi Finance Private Limited would give notice to the customers/borrowers of any change to the terms and conditions, including disbursement schedule, interest rates, service charges, prepayment charges, etc.
• Changes in the interest rates and other charges would be effected prospectively other than under circumstances arising from regulatory instructions.
• Decision to recall / accelerate payment or performance under the agreement would be in consonance with the terms and conditions of the loan agreement.
RESPONSIBLE LENDING CONDUCT – RELEASE OF MOVABLE/IMMOVABLE PROPERTY DOCUMENTS ON REPAYMENT/ SETTLEMENT OF PERSONAL LOANS
Ricavi Finance Private Limited would release securities, if any lying with it on repayment of all dues or on realisation of the outstanding amount of loan subject to any legitimate right or lien for any other claim that Ricavi Finance Private Limited may have against the customers/borrowers. If such right of set off is to be exercised, the customers/borrowers would be given notice about the same with full particulars about the remaining claims and the conditions under which Ricavi Finance Private Limited is entitled to retain the securities till the relevant claim is settled/paid.
GENERAL
In case of rejection of loan applications, the Company shall communicate the decision to the borrower within a reasonable timeframe. Reasons for rejection shall be provided wherever required
under RBI guidelines.
• The Company would refrain from interference in the affairs of the customers/borrowers, except for the purposes provided in the terms and conditions of the loan agreement (unless new information, not earlier disclosed by the customers/borrowers, has come to the notice of the Company).
• In case of a request from the borrower for transfer of the loan account to another NBFC, bank or financial institution, the Company would convey its decision within 21 days from the date of receipt of the request. Such a transfer would be in accordance with the contractual terms entered into with the borrower and in consonance with the law.
• In the matter of recovery of loans, Ricavi Finance Private Limited would not resort to undue harassment, i.e., persistently bothering the borrower at odd hours, using muscle power for recovery of loans etc. The Company would ensure that its employees/recovery agent(s) are properly trained to deal with customers in an appropriate manner.
• The Company may arrange for enforcing security provided by delinquent customers/borrowers. In all such instances, the Company would ensure that the entire process of enforcing its security, valuation and realization thereof is fair and transparent.
• Where loans are sourced or serviced through digital platforms or Lending Service Providers (LSPs), the Company shall comply with applicable RBI guidelines on digital lending, including explicit borrower consent, data privacy, data security, and disclosure of all loan terms
GRIEVANCE REDRESSAL MECHANISM
At Ricavi Finance Private Limited, Customer service and satisfaction are our prime focus. We believe that providing prompt and efficient service is essential not only to attract new Customers, but also to retain existing ones. Ricavi Finance Private Limited has come up with a lot of initiatives that are oriented towards providing a better Customer experience and an efficient grievance redressal mechanism with a view to providing an enhanced experience to our Customers. In order to make the redressal mechanism more meaningful and effective, a structured system has been built. This system would ensure that the redressal sought is just and fair and is within the given framework of rules and regulations.
Following is the Grievance Redressal Mechanism for customers:
Level 1:
Customers may lodge their complaints by writing to:
Email: info@ricavifinance.com / ca@ricavifinance.com / cs@ricavifinance.com
Level 2:
If the complaint is not resolved within 15 days, the customer may escalate the matter to the
Grievance Redressal Officer (GRO):
Name: Kiran Desai
Designation: Grievance Redressal Officer
Contact No.: +91-9173809830
Address: 801-802, Arista Business Space, Sindhu Bhavan Road, Bodakdev, Ahmedabad380054
The Company shall endeavour to resolve all complaints within 30 daysfrom the date of receipt.
Ricavi Finance Private Limited –
801-802, Arista Business Space, Sindhubhavan Road, Bodakdev, Ahmedabad-380054
Ricavi Finance Private Limited shall endeavour to respond to each complaint within
one month from the date of receipt of the Complaint.
Email: info@ricavifinance.com / ca@ricavifinance.com/cs@ricavifinance.com
Escalation of complaints: Third Level
For the complainants who are not satisfied with the response or do not receive a response from Compliance Officer within 30 days of receiving the complaint. If more time is required, the Company will inform the customer expected timeline. The Reserve Bank of India has introduced a web based mechanism “Complaint Management System (CMS)”, for lodging Complaints / Grievances by Citizens of India which may include the customers as well. This is known as Public Grievance portal (https://cms.rbi.org.in/). Customers may make use of the said Portal to communicate their grievances to the Company.
The complaint may also be submitted through electronic or physical mode to the Centralised Receipt and Processing Centre as notified by the Reserve Bank. The complaint, if submitted in physical form, shall be duly signed by the complainant or by the authorised representative. The complaint shall be submitted in electronic or physical mode in such format and containing such information as may be specified by RBI on below address:
Department of Non-Banking Financial Institutions,
4th Floor, Riverfront House
Behind H.K Arts Collage
Between Gandhi Bridge & Nehru Bridge
Pujya Pramukh Swami Marg (Riverfront Road-West)
Ahmedabad – 380014.
REGULATION OF EXCESSIVE INTEREST CHARGED BY THE COMPANY
The Company follows a risk-based pricing model for the determination of interest rates. The interest rate applicable to a borrower is determined after taking into account factors such as cost of funds, operating costs, margin, risk premium, customer profile, tenure of the loan, type of security, and creditworthiness of the borrower.
The Interest Rate Policy, including the rationale for differential pricing, is approved by the Board of Directors and is available on the Company’s website for reference of borrowers.
All interest rates shall be communicated to the borrower on an annualised basis in the sanction letter / welcome letter. Penal charges, if any, shall be reasonable, non-compounded, and non-capitalised, and shall not be levied as a means of revenue enhancement.
Penal charges shall be imposed only as a deterrent for non-compliance with material terms and conditions of the loan agreement. Penal charges shall be disclosed separately in the sanction letter, Key Facts Statement, and loan agreement. The Company shall not levy penal interest in any form.
The rate of interest mentioned are annualised basis so that the borrower is aware of the exact rates that would be charged to the account. The same is mentioned on the sanction letter/welcome letter, also the limit of our Rate of interest is as per the internal rate model Policy .
DETAILS REGARDING REPOSSESSION OF VEHICLES
Loan agreements have a built-in re-possession clause with the borrower, which is legally enforceable. The terms and conditions of the contract/loan agreement shall contain provisions regarding:
• Notice period before taking possession;
• Circumstances under which the notice period can be waived; The procedure for taking possession of the security.
• A provision regarding a final chance to be given to the borrower for repayment of the loan before the sale/auction of the property;
• The procedure for giving repossession to the borrower and
• The procedure for the sale/auction of the property.
The Company shall ensure that recovery of loans is carried out in a fair, transparent, and lawful manner, with due regard to the dignity and privacy of the borrower. The Company shall not resort to harassment, intimidation, or coercion, and shall ensure that its employees and recovery agents adhere to the code of conduct prescribed by the Reserve Bank of India.
A copy of such terms and conditions shall be made available to the borrowers.
COMPLIANCE WITH THE FPC
The board shall review and amend this Code as and when required. If at any point a conflict of interpretation / information between the Code and anyregulations, rules, guidelines, notification, clarifications, circulars, master circulars/ directions issued by relevant authorities (“Regulatory Provisions”) arises, then interpretation of the Regulatory Provisions shall prevail.
In case of any amendment(s) and/or clarification(s) to the Regulatory Provisions, the Code shall stand amended accordingly from the effective date specified as per the Regulatory Provisions.
FOR AND ON BEHALF OFRICAVI FINANCE PRIVATE LIMITED FORMERLY KNOWN AS RICAVI FINANCE LIMITED
NAME: CHIRAG DESAI
WHOLE TIME DIRECTOR
DIN: 08178002