• श्री कृष्णाय वासुदेवाय नमः

Fair Practices Code

FAIR PRACTICES CODE (FPC) POLICY

Company: Comero Leasing and Financials Private Limited

Approved by: Board of Directors

Effective Date: January 2, 2026

Aligned with: Reserve Bank of India (Non-Banking Financial Companies – Responsible Business Conduct) Directions, 2025

This Fair Practices Code ("FPC" or "Code") is formulated by the Board of Directors of Comero Leasing and Financials Private Limited ("Company", "we", "us", or "our") in compliance with the Reserve Bank of India (RBI) guidelines on Fair Practices Code for Non-Banking Financial Companies (NBFCs).

1. Introduction and Scope

  • Purpose: Establishes fair, transparent practices for all customer interactions in lending operations.
  • Applicability: Covers all loan products, channels (branches, digital, agents), and stages (application to recovery).
  • Governance: Board approves; Senior Management implements; published on website in English and vernacular languages.
  • Review: Annual or on RBI updates.

2. Objectives

  • Ensure equitable, respectful treatment of borrowers.
  • Provide clear disclosures on terms, fees, and risks.
  • Promote ethical recovery without harassment.
  • Facilitate prompt grievance redressal.
  • Build customer trust through compliance.

3. Fair Lending Principles

3.1 Non-Discrimination

  • Decisions based on creditworthiness, income, repayment capacity, and collateral only.
  • No bias on caste, religion, gender, ethnicity, disability, or marital status.

3.2 Transparency and Disclosure

  • Pre-loan disclosure: Annualized interest rate, APR, fees (processing, prepayment, penal), tenure, moratorium.
  • All terms in simple language; borrower acknowledgment mandatory.
  • Post-sanction: Copy of agreement, schedule, and documents handed over.

3.3 Responsible Lending

  • Assess suitability via income proof, credit score, debt burden.
  • No coercive cross-selling; opt-out without penalty.

3.4 Privacy

  • Data used only for lending; no sale for marketing without consent.
  • Disclosure permitted only for legal requirements, fraud detection, or with explicit customer interest.

4. Loan Application and Processing

  • Forms: Comprehensive, with purpose, amount, EMI details, and consent for credit checks.
  • Documents: Checklist provided upfront (KYC, income proof, etc.).
  • Acknowledgment: Issued immediately with processing timeline (max 7-15 days).
  • Rejection: Written reasons provided within 30 days.

5. Loan Appraisal and Sanction

  • Criteria: Repayment capacity (DTI <50%), credit score (>700 preferred), collateral valuation.
  • Sanction Letter: Specifies amount, rate (fixed/reducing), tenure, prepayment terms, and security details.
  • Acceptance: Dated signature/e-sign; no verbal changes.

6. Disbursement

  • Timeline: Disbursed within 7 days of document submission.
  • Mode: Direct to bank account or ECS; conditions precedent confirmed.
  • Changes: 30-day notice for interest rate hikes; reasons documented.

7. Repossession and Enforcement (Secured Loans)

  • Agreement Clauses:
    • Default triggers defined (e.g., 3 EMIs overdue).
    • 30-day demand notice issued before action.
    • Repossession procedure: peaceful, no use of force.
    • Auction/sale: Public notice, fair value, surplus returned to borrower.
  • Redemption: Full payment permitted anytime before final sale.
  • Unsecured Loans: No physical recovery; legal suit only.

8. Recovery Practices

  • Protocols:
    • Calls/SMS: Restricted to 8 AM - 7 PM, max 3/day, no weekends/holidays.
    • No threats, verbal abuse, or public shaming.
    • Settlement offers clearly documented.
  • Escalation: Legal notice sent after 90 days overdue; court action as last resort.
  • Training: Collection agents certified on ethical recovery procedures.

9. Grievance Redressal

9.1 Lodging

  • Channels: Email grievance@xpressloan.in, phone (1800-8890-625), branch, or online portal.
  • Acknowledgment: Provided within 3 working days with reference ID.

9.2 Resolution

  • Simple Complaints: 15 days; Complex Complaints: 30 days.
  • Interim reply issued if delayed; root cause analysis conducted.
  • Unresolved: Escalate to RBI Ombudsman (details provided on website).

9.3 Reporting

  • Quarterly MIS submitted to Board: Volume, resolution rate (>95% target).

10. Customer Rights

  • Right to fair assessment and appeal.
  • Prepayment permitted without undue charges.
  • Information access on own account.
  • No interference in personal matters.

11. Monitoring and Compliance

  • Oversight: Grievance Officer + Internal Audit quarterly checks.
  • Training: Mandatory annual training for all staff/agents (4 hours).
  • Audits: 100% sample audit for high-value loans; mystery shopping.
  • Reporting: Annual Board certification; RBI submissions as required.
  • Penalties: Breach leads to disciplinary action.

12. Miscellaneous

  • Language: Vernacular languages supported for rural borrowers.
  • Amendments: Board-approved modifications only.
  • Override: Statutory rights prevail in all conditions.
  • Contact: GRO - Name: Ms. Babita Joshi, Email: grievance@comero.in, Phone: 1800-8890-625.

This policy ensures RBI compliance while prioritizing customer centricity. All staff must adhere strictly.

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