Fair Practice Code and Grievance Redressal Policy

1. Introduction, Background and Objectives

The Reserve Bank has prescribed the Directions on Fair Practices Code applicable to Non-Banking Financial Companies (NBFCs). 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.

Pursuant to the Notification issued by the Reserve Bank of India by its Circular No. Master Direction DNBR.PD.007/03.10.119/2016-17 dated September 01, 2016 amended from time to time, X10 FINANCIAL SERVICES LIMITED, (hereafter referred to as ‘X10/The Company’) has formulated this Fair Practices Code and Grievane Redressal Mechanism to lay down the below mentioned procedures/practices in dealing with the Borrowers of the Company.

2.Applicability

The Code shall apply to all employees of the Company and other persons authorized to represent it in the course of its business.

3.Non-Discrimination Policy

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.

4.Language of the Communication

All required communications by the Company to the borrower will be in English or the language as understood by the borrower.

5.Applications for Loans and their Processing

  • Loan application forms will include the relevant information which affects the interest of the borrower so that informed decision could be taken by the borrower. The loan application form will also indicate the documents required to be submitted with the application form.
  • Receipt of completed application forms 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.
  • Company will also accept loan applications through electronic means like Websites and Mobile Applications where all the fields will be caputured and customer conformation will happen through electronic means.

6. Loan Appraisal and Terms & Conditions

  • All loan applications will be assessed as per the Company’s internal credit policies and appraisal process.
  • After examining the matter, X10 will send a response as soon as possible; X10 will also guide a customer on how to take the complaint further if the customer is not satisfied.
  • Upon approval of the loan a sanction letter indicating the amount of loan sanctioned, the applicable annualized rate of interest rate method of application of the same along with other important terms and conditions will be conveyed in writing to the borrower.
  • The Company will mention the penal interest charged for the late payment in bold in the loan agreement. A suitable provision in this regard shall be incorporated in the loan agreement.
  • After the execution of the loan agreement, a copy of the loan agreement (along with a copy each of all enclosures quoted in the loan agreement) will be furnished to the borrowers.
  • All above documents can also be furnished in an acceptable electronic mode.

7. Disbursement of Loans including changes in Terms & Conditions

  • 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 informed to the borrower in writing.
  • Changes in interest rates and other charges (which are adverse to the borrower) shall be with prospective effect only.
  • Decision to recall any loan shall be done in accordance with the terms and conditions of the loan agreement.
  • All underlying securities, if any, will be released after the full repayment of the loan and all other charges in 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.

8. General Provisions with respect to dealing with the Customers

  • 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);.
  • 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.
  • For recovery of loan, the Company will not resort to undue harassment and will follow procedures adopted internally by the Company within the applicable legal framework.
  • The Company will comply with the extant regulatory provisions with respect to prepayment of loans by its borrowers.
  • We will ensure that the staff is adequately trained to deal with the customers in appropriate manner.

9. Rate of Interest and other Charges

  • 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 will adopt a Policy on Rate of Interest and other charges, has been put up on the Company’s website for the benefit of its customers.
  • The information regarding the Rate of Interest and other charges of the Company will be also disclosed in the application form and sanction letter.

10. Repossession of vehicles/assets

  • The Company shall have a built in re-possession clause in the loan agreement or the Hypothecation Agreement to be signed with the borrower, which shall be legally enforceable. To ensure transparency, the terms and conditions of the loan agreement or Hypothecation Agreement shall also contain provisions regarding:
    • a) notice period before taking possession
    • b) circumstances under which the notice period can be waived
    • c) the procedure for taking possession of the security
    • d) provision regarding final chance to be given to the borrower for repayment of loan before the sale / auction of the property
    • e) procedure for giving repossession to the borrower
    • f) procedure for sale / auction of the property.

11. Periodical Review

The Board of Directors or a committee constituted by the Board will conduct periodic review of the compliance of the Fair Practices Code and the functioning of the grievances redressal mechanism within the Company.

12. Grievance Redressal (GR) Mechanism

Any customer having a grievance/ complaint/ feedback with respect to the product and services offered by the Company may write to the Company’s Customer Service Department through any of the following channels:

How a complaint should be made

The customers will be requested to necessarily provide necessary loan details i.e. Loan Account Number, Details of Feedback/ Suggestion/ Complaint and valid Contact Information including phone no. & e-mail ID while providing their feedback or lodging complaint with the Company.

When should customer expect a reply

Each customer query/ complaint being unique in nature, the resolution of complaint may take up to 4 weeks after investigation. The customer will be made aware regarding the same.

Whom to approach for redressal

For escalation of grievances, the customer may contact the Grievance Redressal Officer of the Company whose details are as under:
  • Name: Gauarv Dutt Dogra
  • Call at: +91 813 069 9205
  • e-mail: info@x10corp.com
  • Address: Third Floor, Khasara No 385, Opp Corporation Bank, M.G. Road, Ghitorni, New Delhi -110030

Escalation to the Reserve Bank of India

If the Customer does not receive any response from the Company within 4 weeks or is dissatisfied with the response received, he/ she may approach the Reserve Bank of India at the following address
  • Department of Supervision Reserve Bank of India
  • 3rd Floor, RBI Building Opposite Mumbai Central
  • Railway Station, Near Maratha Mandir Byculla, Mumbai -4000018

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