Fair Practice Code

Thirumeni Finance Private Limited

Thirumeni Finance Private Limited (Hereinafter referred to as Company or Varthana) is a Non Deposit Taking NBFC registered with the Reserve Bank of India. It uses the brand name Varthana to communicate with its customers. This document provides details of the practices which Varthana follows to ensure fair and transparent dealings with its customers and is compliant with the RBI Circular DNBS CC No 320/03.10.001/2012-13 dated February 18, 2013. Further the RBI has extended the coverage of Ombudsman Scheme for Non-Banking Financial Companies (NBFCs), 2018 (the Scheme) to eligible Non Deposit Taking Non Banking Financial Companies (NBFC-NDs) having asset size of Rupees 100 crore or above with customer interface vide Notification dated April 26, 2019. This code will enable employees to provide better customer service and maintain transparency in business dealings with its customers.

This Fair Practice Code supersedes all previous versions.

Application of the Code

This code shall apply to all employees of the company and other persons authorized to represent it in the course of its business with respect to all products and services.

Commitment

Company shall adhere to this code to act fairly and reasonably in all dealings, on the ethical principle of integrity and transparency, to meet the standard practices prevalent in the finance industry.

  1. The Company will provide clear and transparent information to customers in the language of their preference so as to enable them to understand:
    1. Terms and conditions of the products and services offered including the interest rate and service charges.
    2. Benefits available to customers
  2. Products and services of the company will meet relevant laws and regulations in both letter and in spirit.
  3. The Company will act quickly in correcting mistakes and attending to complaints lodged by its customers.
  4. The Company shall not discriminate amongst its prospective/existing customers on the basis of age, race, caste, gender, marital status, religion or disability.
  5. A copy of the code will be posted on the Company’s website and in a visible location at each branch office.
  6. A copy of the code may be provided on request to any prospective or existing customer.

 

  1. Application for loans and their processing
    1. All communication to the borrower shall be explained to the borrower in the language understood by the borrower.
    2. Loan application forms shall include necessary information that affects the interest of the borrower and an informed decision can be taken.
    3. Acknowledgment for receipt of all loan applications will be given to the borrower.
    4. Normally, all particulars required for processing the Loan Application will be collected by the Company at the time of application. In case it needs any additional information, the customer will be informed to provide the same.
    5. The Company may verify the details mentioned by the customer in the loan application by contacting him/her at his/her residence and/or on business telephone numbers and/or physically visiting his/her residence and/or business addresses through agencies appointed for this purpose, if deemed necessary.
  2. Loan appraisal and terms/conditions
    1. Every loan approval shall be communicated to the borrower by way of a Sanction Letter which shall include the key terms and conditions of the loan including the loan amount approved, processing fees, annualized rate of interest, the tenor of the loan, penal charges, etc. Contents shall be explained to the borrower in a language understood by the borrower.
    2. A copy of the loan agreement shall be given to the borrower for records and the contents explained in a language understood by the borrower.
  3. Disbursement of loans including changes in terms and conditions
    1. Should there be any changes in the terms and conditions, a notice shall be given in a language understood by the borrower indicating the change of terms. Changes in the interest rates and charges shall be effected only prospectively.
    2. Any decision to recall/accelerate payment or performance shall be in consonance with the loan agreement.
    3. All securities shall be released on repayment of all dues or on realization of the outstanding amount as long as the Company’s legitimate right or lien for any other claim is not violated. If such set-off is to be exercised, the Company shall give notice about the same with full particulars to the borrower.
  4. General
    1. Varthana will not interfere in the affairs of the borrower except for the purposes provided in the terms and conditions of the Sanction Letter and Loan Agreement unless new information, not earlier disclosed by the borrower comes to the notice of the Company.
    2. For any request for Balance Transfer received from the borrower, the consent or otherwise shall be communicated within 21 days of receipt of request. Such transfer shall be as per transparent contractual terms in consonance with the law.
    3. Varthana shall not resort to undue harassment for recovery of dues. Proper training shall be given to the field staff to ensure that borrowers are dealt in an appropriate manner.
    4. The Board of the Company shall review the redressal of grievances at regular intervals. The management shall place before the board the status of all complaints at regular intervals.
    5. The details of the Grievance Redressal Officer (including name, address, contact number, email ID, etc) shall be prominently displayed at the branches and also posted on the website.
    6. In case the complaint is not redressed within a period of one month, the borrower may appeal to the Officer in Charge of the Regional Office of the Department of Non-Banking Supervision, Bengaluru under whose jurisdiction the registered office of the Company falls.

Confidentiality

The Company shall collect personal information that it believes to be relevant and required to understand the customer’s profiles and conduct its business. The Company shall treat all personal information of customers as private and confidential and shall not divulge any information to a third person unless required by any law or Government authorities including Regulators or Credit agencies or where the sharing of information is permitted by the customer. If the company shall avail services of any third party for providing support services, Company shall require that such third parties handle customers’ personal information with the same degree of confidentiality.

Advertising, Marketing and Sales

  1. The Company shall ensure that all advertising and promotional material is clear, and not misleading.
  2. The Company may, from time to time, communicate to customers various features of their products availed by them. Information about their other products or promotional offers in respect of products/services may be conveyed to customers only if he/she has given his/her consent to receive such information/service.

Guarantors

When a person is considered to be a guarantor to a loan, the company shall inform him/her the following under acknowledgment:

  1. Letter/ Deed of Guarantee stating the terms of liability as guarantor.
  2. Company shall keep him/her informed of any default in the servicing of the loan by the borrower to whom he/she stands as a guarantor.

Credit Bureau / Reference Agencies

The Company may give information to Credit Bureau/ Reference agencies about the personal debts, the customer owes to it if:

  1. The customer has fallen behind with his/her payments.
  2. Legal proceedings have been initiated against the customer to recover the dues.
  3. Debts settled through legal recourses against the customer.
  4. It is mandated by law/arrangement with Credit Bureau to provide the information of all such customers to such agencies. A clause to this effect has been included in the Loan Agreement seeking the customer’s consent to share information on his loan with Credit Bureaus.

Grievance Redressal

The Company for this purpose, has framed different levels for addressing and solving the Customer’s Complaints by appointing Grievance Redressal Officer & Compliance Officer, the details of which is indicated below:

Grievance Redressal Officer:

Mr. P. Vinayagam,

Thirumeni Finance Private Limited
‘Varasiddhi’, 3rd Floor, No. 5BC – 110 Service Road
3rd Block, HRBR Layout
Bengaluru 560043
Karnataka, India

Email: vinayagam.p@varthana.com

Grievance Redressal Officer, so appointed by the Company shall take all necessary steps to redress and resolve the grievance and to send a response as soon as possible and, in any case, not later than a maximum period of 21 working days from the receipt of customer complaint by him.

The department heads are responsible jointly and severally for resolution provided by their teams and for closure of customer issues.

Escalation Matrix:

In case the complaint is not resolved within the given time (i.e. 21 working days) or if the customer is dissatisfied with the response received from the Company, the customer may escalate the complaint to the Primary Level – I as indicated below –

A. Primary Level I:

Compliance Officer:

Name: Brajesh Mishra

Thirumeni Finance Private Limited
‘Varasiddhi’, 3rd Floor, No. 5BC – 110 Service Road
3rd Block, HRBR Layout
Bengaluru 560043
Karnataka, India
Email: brajesh@varthana.com

B. Secondary Level II:

If the complaint/grievance is not resolved within a period of 30 working days from the receipt of escalation, the applicant/borrower may appeal to the Officer-in-Charge of the Regional Office of the Reserve Bank of India at the following address:

Reserve Bank of India
Department of Non-Banking Supervision (DNBS)
Regional Office
10/3/8, Nrupathunga Road
Bengaluru 560001
Karnataka, India

Email: dnbsbangalore@rbi.org.in

The customer can also approach the office of NBFC ombudsman, the detailed scheme i.e. “The Ombudsman Scheme for Non-Banking Financial Companies, 2018” is attached as Annexure – 1

Address and Area of Operation of NBFC Ombudsman

SN  Centre       Address of the Office of NBFC Ombudsman Area of Operation                            

1.      Chennai                C/o Reserve Bank of India,                                       Tamil Nadu, Andaman and Nicobar Islands, 

                                           Fort Glacis, Chennai 600 001                                  Karnataka, Andhra Pradesh, Telangana, 

                                           STD Code: 044                                                            Kerala, Union Territory of Lakshadweep and 

                                           Telephone No: 25395964                                          Union Territory of Puducherry

                                           Fax No: 25395488 

                                           Email: nbfcochennai@rbi.org.in

2.        Mumbai               C/o Reserve Bank of India,                                          Maharashtra, Goa, Gujarat, Madhya 

                                          RBI Byculla Office Building,                                        Pradesh, Chhattisgarh, Union Territories 

                                          Opp. Mumbai Central Railway Station Byculla,      of Dadra and Nagar Haveli, Daman and Diu

                                           Mumbai-400 008

                                          STD Code: 022 

                                          Telephone No: 23028140 

                                          Fax No: 23022024 

                                          Email: nbfcomumbai@rbi.org.in

3.       New Delhi            C/o Reserve Bank of India                                                 Delhi, Uttar Pradesh, Uttarakhand, 

                                          Sansad Marg, New Delhi -110001                                    Haryana, Punjab, Union Territory of 

                                          STD Code: 011                                                                      Chandigarh Himachal Pradesh, and 

                                          Telephone No: 23724856                                                  Rajasthan and State of Jammu and 

                                          Fax No : 23725218-19                                                         Kashmir

                                          Email: nbfconewdelhi@rbi.org.in

4.         Kolkata               C/o Reserve Bank of India,                                                West Bengal, Sikkim, Odisha, Assam, 

                                          15, Netaji Subhash Road,                                                    Arunachal Pradesh, Manipur, 

                                          Kolkata-700 001                                                                   Meghalaya, Mizoram, Nagaland, 

                                          STD Code: 033                                                                      Tripura, Bihar and Jharkhand

                                          Telephone No: 22304982 

                                          Fax No: 22305899 

                                          Email: nbfcokolkata@rbi.org.in

 

Revision in Schedule of Charges