The Fair Practice Code (FPC) has been formulated, recorded in the minutes of the company by the Board of Directors of Subhkiran Capital Limited (SCL) and in response to the guidelines issued by Reserve Bank of India as per the Circular DNBS.CC.PD.No. 054/03.10.0119/2015-16 dated 1st July, 2015 for ensuring better quality service and bring in transparency in its loan process and the FPC also aims at enhancing customer satisfaction and minimizing customer complaints.
The Fair Practice Code shall be displayed in vernacular language in all branch premises. Field staff shall be trained to make the borrower fully aware of the procedures and the systems related the loan and other products. The KYC guidelines of RBI shall be complied with loan sanction and disbursement shall be conducted at branches.
Loan Application and Process for Different Business Products
l All communications to the borrower shall be in the vernacular language or a language as understood by the borrower.
l Loan application forms shall include necessary information which affects the interest of the borrower and enable the borrower to take an informed decision.
l Proper ID with address proof must be produced by the borrower for availing the loan. (KYC Documents)
l If any additional documents / information are required from the Customer, same shall be communicated to the Customer immediately.
l Credit score check from Credit agencies shall be obtained before considering the loan.
l Sanction /Rejection Order shall be communicated to the applicant immediately after processing.
l Contents of the loan agreement shall be explained to the borrower in vernacular language.
l Disbursement of the loans shall be through their Bank Account.
l Whenever loans are disbursed, borrower shall be explained the repayment process, tenure periodicity.
l The company shall disclose all the relevant information regarding the loan/product such as eligible loan amount, annualized interest rate, charges, penal/overdue interest and method of interest calculation etc of the loan to enable the customer to take an informed decision.
l The company shall ensure that a loan sanction letter (in case of gold loan-Pawn Ticket) is given to the customer containing all the terms and conditions governing the loan facility in the local language or other language as understood by the customer. The loan sanction letter will also mention the loan amount, number, interest rate charges, loan processing fee if any etc. The loan sanction letters will bear the signature of the authorized official of the company.
l The penal interest that shall be charged for late payment shall be mentioned in bold letters in the sanction letter/ loan document.
l There will be notices served to the borrower in the vernacular language or any language as understood by the borrower of any change in the terms and conditions including disbursement schedule, interest rates, service charges, prepayment charges etc.
l The company shall release all the securities, on getting the repayment of its full dues or on realization of the outstanding amount of loan subject to any legitimate right or lien to any other claim the company may have against its borrowers. It has such rights to set off and if it is to be exercised, then the borrower shall be given a notice about the same with full particulars about the remaining claims and conditions under which the company is entitled to retain the securities till the relevant claim is settled/paid.
l An acknowledged copy of the sanction letter shall be kept as part of the documentation.
l The company will not interfere in the affairs of the customers except for the purposes mentioned in the terms and conditions of the loan agreement. The agreement discloses the auction procedures.
l Subject to receipt of all the requisite documentation and information and creation of charge over the security, loan applications shall be disposed of in the normal course on the same day of receipt of the application form complete in all respects. . However, if there is any delay in sanctioning the loan, customer shall be kept informed of the status of his application.
l After taking into account relevant factors such as cost of funds, margin and risk premium, the Company shall frame appropriate internal principles and procedures for determining the interest rates and processing and other charges, if any and they will ensure that these are not excessive. The Company shall, at the time of disbursal, ensure that the interest rate and other charges, if any, on loan and advances are in strict adherence to above referred internal principles and procedures.
l As a measure of customer protection we ensure not to charge any foreclosure/pre payments,
l The rate of interest will be annualized rates so that the borrower is aware of the exact rates that would be charged on the loan.
l The information published in the website shall be updated whenever there is change in the rates.
C. Non Coercive Methods of Recovery
l Recovery shall be made at branches. Field staff shall be allowed to make recovery at the place of residence or work of borrower.
l Procedures as provided in the manuals and with Fair Practice Code covers the Code of Conduct by field staff and systems for their recruitment, training and supervision.
l Training to field staff includes to inculcate appropriate behavior towards borrowers without adopting any coercive debt collection/recovery practices.
l Penalties shall be imposed on cases of non compliance of field staff.
D. GOLD Loans – KYC, Appraisal & Gold Auction
l Customer has to produce the Proof of identity namely, photocopy of election identity card, Aadhaar, passport, driving licence, PAN Card etc.(Any one) and other such documents demanded by the Company. The Company will ensure that the KYC guidelines stipulated by RBI are complied with and will ensure that adequate due diligence is carried out on the customer before extending loan.
l Unless or otherwise specified all gold loans are sanctioned for a period of 12 months.
l Proceeds of Loans above Rs 20000 are routed through their accounts only
l Proper appraisal procedure will be done for jewellery accepted as collateral security.
l In case of Loss of Token, declaration shall be obtained from the borrower confirming ownership of gold jewellery.
l Every borrower is entitled to receive back the securities offered for the loan. However if the borrower has any other liability with the company, the company reserves the right to release the securities. A lien of the above order will be exercised only after giving due notice to the borrower.
l The Company will obtain the declaration of the borrower through pawn ticket confirming ownership of the gold jewellery.
l The jewellery accepted as collateral security shall be appropriately insured.
l All branches shall have proper storage facility of either Strong Rooms or Safes conforming to ISI Standards of approved make to store the jewellery in safe custody. The keys to the strong room/safe shall be held separately by two officials and the operations thereof shall be done jointly. The staff shall be imparted training on a continuous basis to ensure that the guidelines covering security issues are strictly adhered to. The gold items shall be periodically inspected by the internal auditors to ensure quality, quantity and proper storage
l The Company will resort to disposal of security (gold) only as a last resort and that too after adequate and proper notice is served on the customer to repay the dues. Such notice will be as per the terms contained in the sanction letter (pawn ticket) and also in compliance with applicable laws and regulatory guidelines. The disposal of the security (gold) will be taken up through public auction when the customer does not positively respond to the communications sent by the Company to close the loan account along with interest and other charges. The auction procedure shall be transparent. Prior notice will be given to customer by Registered Post/Courier informing about the auction. The auction shall be announced to the public by issuing advertisements in at least two newspapers, one in vernacular language and another in national daily newspaper, describing the date of auction, venue of auction, and the details of gold etc. Auction will be conducted by an approved auctioneer appointed by the Board of Directors of the Company. The amount due to the Company by the customer, being the aggregate of the principal and upto the date of interest as well as other expenses like expenses for conducting auction, will be adjusted against the sale proceeds, whereas the surplus, if any available, will be refunded to the customer, and deficit if any shall have to be paid by him/her. The company or its associate concerns will not participate in the auction
E. Customer Protection Initiatives
CUSTOMER GRIEVANCE REDRESSAL MECHANISM
At Subhkiran Capital Ltd., we believe in providing the best service to our customers. Proper training shall be imparted to staff on an ongoing basis with a view to improving staff behavior and customer service. We provide customers with easy access to information, products and services, as well as the means to get their grievances redressed. If at any stage, if a customer is not satisfied with the service given to him/her, he/she can contact the Company as follows.
Step 1 :
Customer can visit our branch offices and submit complaints/grievance in writing and get the complaint logged in the “Complaint & Grievance Register” maintained at our offices during the working hours (9.30 am to 5:30 pm); Customers will be responded within 7 working days. The contact details of Branch Manager will be displayed in all branch offices.
Step 2 :
If customers are still not satisfied with the resolution received, or did not receive any response within 7 working days he/she can write, mail or call to the Grievance Redressal Officer of the Company whose details are given below; Complaints/Grievance will be addressed within 15 working days.
Details of Our Grievance Redressal Officer :-
Mr. Vibin Gopinath
Subhkiran Capital Limited.
Corporate Office, 1 st Floor, Sunny Towers
North Paravur, Ernakulam District,
Kerala State – 683513
If customers are still not satisfied with the resolution received, or did not receive any response within 15 working days he/she may approach to the regulatory authority of Non- Banking Financial Companies, i.e. Reserve Bank of India for redressal of his/her complaints at below address:
The General Manager,
Reserve Bank of India,
Department of Non- Banking Supervision,
Reserve Bank of India, Saidabad,
HYDERABAD – 500004
The details of the Grievance Redressal Officer and the Regulatory Officer of Reserve Bank of India shall be displayed in all the offices for the benefit of customers. The compliance of the fair practices code as well as the functioning of the Customer Grievances Redressal Cell shall be reviewed by the Chairman & Managing Director on Monthly basis and a consolidated report of such reviews shall be placed before the Board of Directors.
Subhkiran Capital Limited.
Corporate Office, 1 st Floor, Sunny Towers,
North Paravur, Ernakulam District,
Kerala State – 683513
l Company shall display the normal business hours ,list of Holidays etc at respective branches.
l Name and contact details of ( Telephone / mobile number, Email)Grievance Redressal officer shall be displayed.
l Personal information’s of the customer shall not be shared to unauthorized persons/agencies/third parties