Codes & Policies
Fair Practices Code
Pursuant to the RBI notifications No DNBS (PD) CC No. 286/03.10.042/2012-13 dated July 1, 2012; RBI/2012-13/416 DNBS.CC. PD. No. 320/03.10.01/2012-13 dated February 18, 2013 and updated circular RBI/2015-16/16 DNBR (PD) CC.No.054/03.10.119/2015-16 dated July 1, 2015, we are adopting the following guidelines as prescribed by RBI and approved in the Company’s Board meeting dated 20th August, 2012, amended on 26th March, 2013 and reviewed on 21st June 2016.
A. Applications for loans and their processing
a) The terms & conditions will be explained in the vernacular language or as understood by the borrower. All pertinent loan information as prescribed by the RBI has been made available in the respective Application Form. This information includes the following:
- The applicable terms and conditions
- An indicative list of KYC documents to be submitted, together with the duly completed application form.
b) Loan application forms should include necessary information which affects the interest of the borrower, so that a meaningful comparison with the terms and conditions offered by other NBFCs can be made and informed decision can be taken by the borrower. The loan application form may indicate the documents required to be submitted with the application form.
c) An acknowledgement shall be provided for all loan applications received. The Company shall adopt an internal time frame for processing all loan applications and will also indicate the approximate time frame within which the loan application will be processed post the submission of completed application form.
B. Loan appraisal and terms/conditions
a) Loan applications shall be subject to the company’s credit appraisal process.
b) Upon approval of the loan, an agreement/sanction letter indicating the amount of loan sanctioned, rate of interest applicable, method of interest calculation along with other terms and conditions shall be conveyed to the loan applicant in writing. A written acceptance of such terms and conditions will be taken from the borrower
c) A copy of the loan agreement along with the enclosures will be furnished to all the borrowers.
C. Disbursement of loans including changes in terms and conditions
a) AMPL shall give notice to the Borrowers, of any changes to the terms and conditions, including disbursement schedule, interest rates, service charges, prepayment charges, etc.
b) Changes in the interest rates and other charges shall be effected prospectively other than under circumstances arising from regulatory instructions. Retrospective changes shall as far as possible be avoided and shall be implemented only within the framework define in the Loan Agreements.
c) Decision to recall / accelerate payment or performance under the agreement shall be in accordance with the terms and conditions of the Loan Agreement.
D. General Provisions
a) AMPL will refrain from interference in the affairs of its Borrower except for the purposes provided in the terms and conditions of the respective loan agreement (unless new information, not earlier disclosed by the Borrower, which may come to the notice of AMPL).
b) In case of receipt of request from the borrower for transfer of borrower account, the consent or otherwise, i.e. objection of AMPL, if any, shall be conveyed within 21 days from the date of receipt of request.
c) For recovery of loan, AMPL shall follow procedures as laid down in the internal guidelines and provisions and would remain within the legal framework.
d) AMPL shall ensure that it’s employees are adequately trained to deal with customers in an appropriate manner.
E. Grievance Redressal:
For resolution of complaints against the Company, clients/public may contact the respective branch office of the Company or may call toll free no: 1800 3456706between 9:30 AM and 6.00 PM from Monday to Saturday, or may approach us at the sub section “Grievance Redressal Mechanism” on our website www.ampl.net.in
Grievance Redressal Mechanism
In case the query is not resolved within 15 days’, clients can contact Mr. Suraj Bali Painkra, the Grievance Redressal Officer at Annapurna Finance Private Limited at the following address.
Address: 1215/1401, Khandagiri Bari, Bhubaneswar – 751030
Tel: +91-674-2350253
Mobile: 08280336056
Email: suraj@ampl.net.in
However, if the complaint/ dispute is not redressed within a period of one month, the Client may appeal to Mr. Pintun Sutar, Deputy General Manager Department of Non-Banking Supervision of Reserve Bank of India at the following contact details:
Reserve Bank of India, Pandit Jawaharlal Nehru Marg, Post Box No-16, Bhubaneswar-751001. Tel: +91-674-2350253; Mobile: 0876346704.
F. NBFC-MFIs
I. General
a) The Fair Practice Code in vernacular language shall be displayed by an NBFC-MFI in its office and branch premises.
b) A statement shall be made in vernacular language and displayed by NBFC-MFIs in their premises and in loan cards articulating their commitment to transparency and fair lending practices.
c) Field staff shall be trained to make necessary enquiries with regard to existing debt of the borrowers.
d) Training if any, offered to the borrowers shall be free of cost. Field staff shall be trained to offer such training and also make the borrowers fully aware of the procedure and systems related to loan / other products
e) The effective rate of interest charged and the grievance redressal system set up by the NBFC-MFI should be prominently displayed in all its offices and in the literature issued by it (in vernacular language) and on its website.
f) A declaration that the MFI will be accountable for preventing inappropriate staff behaviour and timely grievance redressal shall be made in the loan agreement and also in the FPC displayed in its office/branch premises.
g) The KYC Guidelines of RBI shall be complied with. Due diligence shall be carried out to ensure the repayment capacity of the borrowers.
h) As specified in the NBFC-MFIs (Reserve Bank) Directions, 2011, all sanctioning and disbursement of loans should be done only at a central location and more than one individual should be involved in this function. In addition, there should be close supervision of the disbursement function.
i) Adequate steps may be taken to ensure that the procedure for application of loan is not cumbersome and loan disbursements are done as per pre-determined time structure.
II. Disclosures in loan Agreement / loan card
a) AMPL shall have a Board approved, standard form of loan agreement. The loan agreement shall preferably be in vernacular language
b) In the loan agreement the following shall be disclosed:-
- All the terms and conditions of the loan.
- The pricing of the loan involves only three components viz; the interest charge, the processing charge and the insurance premium (which includes the administrative charges in respect thereof).
- There will be no penalty charged on delayed payment.
- There will be no Security Deposit / Margin is being collected from the borrower.
- The borrower cannot be a member of more than one SHG / JLG.
- The moratorium between the grant of the loan and the due date of the repayment of the first instalment (as guided by the NBFC-MFIs (Reserve Bank) Directions, 2011).
- An assurance that the privacy of borrower data will be respected.
c) The loan card should reflect the following details as specified in the Non-Banking Financial Company – Micro Finance Institutions (Reserve Bank) Directions, 2011.
- The effective rate of interest charged.
- All other terms and conditions attached to the loan.
- Information which adequately identifies the borrower.
- Acknowledgements by the NBFC-MFI of all repayments including instalments received and the final discharge.
- The loan card should prominently mention the grievance redressal system set up by the MFI and also the name and contact number of the nodal officer.
- Non-credit products issued shall be with full consent of the borrowers and fee structure shall be communicated in the loan card itself.
- All entries in the Loan Card should be in the vernacular language.
III. Non-Coercive Methods of Recovery
As specified in the NBFC-MFIs (Reserve Bank) Directions, 2011, recovery should normally be made only at a central designated place. Field staff shall be allowed to make recovery at the place of residence or work of the borrower only if borrower fails to appear at central designated place on two or more successive occasions.
NBFC-MFIs shall ensure that a Board approved policy is in place with regard to Code of Conduct by field staff and systems for their recruitment, training and supervision. The Code should lay down minimum qualifications necessary for the field staff and shall have necessary training tools identified for them to deal with the customers. Training to field staff shall include programs to inculcate appropriate behaviour towards borrowers without adopting any abusive or coercive debt collection / recovery practices. Compensation methods for staff should have more emphasis on areas of service and borrower satisfaction than merely the number of loans mobilized and the rate of recovery. Penalties may also be imposed on cases of non-compliance of field staff with the Code of conduct. Generally only employees and not out sourced recovery agents be used for recovery in sensitive areas.
Internal Control System
As the primary responsibility for compliance with the Directions rest with the NBFC-MFIs, AMPL has made necessary organizational arrangements to assign responsibility for compliance to designated individuals within the company and establish systems of internal control including audit and periodic inspection to ensure the same.
Annapurna Finance Client Protection Principles
The Client Protection Principles describe the minimum protection clients should expect from Annapurna Finance. These Principles are adopted from the CGAP’s Client Protection Principles. These principles are used to protect the clients and as well as Annapurna Finance’s image, therefore, Annapurna Finance’s staff of all levels should adhere to the following the Client Protection Principles.
1. Appropriate Product delivery and design
Annapurna Finance and its staff will offer loans based on the specific requirements the particular client. The loan shall be disbursed in such a way that it fits the client’s needs.
2. Avoidance of Over-Indebtedness
Annapurna Finance will take reasonable steps to ensure that credit will be extended only if borrowers have demonstrated an adequate ability to repay and loans will not put borrowers at significant risk of over-indebtedness.
3. Transparent Communication
The pricing, terms, and conditions of financial products (including interest charges, penalty, all fees, etc.) will be transparent and will be adequately disclosed in a form understandable to clients. Annapurna Finance will educate and clearly communicate to the clients about the consequences of the over-indebtedness.
4. Appropriate Collections Practices
Debt collection practices will not be abusive or coercive. Debt collection process must follow the collection procedures which are legally correct and binding.
Ethical Staff Behaviour
Annapurna Finance will comply with high ethical standards in their interaction with clients and ensure that adequate safeguards are in place to detect and correct corruption or mistreatment of clients.
6. Mechanisms for Redress of Grievances
Annapurna Finance has in place timely and responsive mechanisms for complaints and problem resolution for its clients.
7. Privacy of Client Data
The privacy of individual client data will be respected, and such data cannot be used for other purposes without the express permission of the client.