Policy

Fair Practices Code

Our commitment to fair, transparent and responsible dealings with customers.

Draft skeleton — requires compliance approval. RBI expects NBFCs to adopt a Board-approved Fair Practices Code. The sections below are a starting outline only; your final FPC must be Board-approved and aligned with the latest RBI Master Directions before publishing.

Last updated: [TODO] · Approved by the Board on: [TODO]

1. Applications & processing

All communications to the borrower will be in a language understood by the borrower. Loan application forms will disclose the information that affects the borrower's interest, and we will provide acknowledgement for all applications received.

2. Loan appraisal & terms

We will convey, in writing, the sanctioned amount, annualised rate of interest, and terms and conditions including fees and charges, and keep the borrower's acceptance of these terms on record.

3. Disbursement & changes to terms

Any change in terms and conditions, including disbursement schedule, interest rates, service charges and prepayment terms, will be notified to the borrower. Changes will be applied prospectively.

4. Interest rates

Interest rates and the approach for gradation of risk will be determined as per our Board-approved Interest Rate Policy and disclosed to the borrower. [Reference the Interest Rate Policy here.]

5. Responsible recovery

We will not resort to undue harassment in recovery. Staff and recovery agents will be trained to deal with customers appropriately and within the bounds of law.

6. Grievance redressal

A grievance redressal mechanism with a designated officer is published on our Disclosures page, including escalation to the RBI Ombudsman.

7. Confidentiality & data protection

Customer information will be treated as confidential and handled in line with applicable law, including the Digital Personal Data Protection Act, 2023, and applicable RBI directions.

This outline is not legal advice. Emar Fiscal Services must adopt a Board-approved Fair Practices Code reviewed by qualified compliance/legal professionals.