Fair Practice Code
Fair Practice Code of Sky Rise Credit and Marketing Limited (Quick Cash India)
Background
The Reserve Bank of India (RBI) has, through its Master Directions on Non-Banking Financial Company – Peer to Peer Lending Platform (Reserve Bank) Directions, 2017 dated October 4, 2017, updated on December 29, 2022 (“Master Directions”), mandated every Non-Banking Financial Company – Peer to Peer Lending Platform (NBFC-P2P) to implement a Fair Practices Code. Sky Rise Credit and Marketing Limited (“Company”), operating as a peer-to-peer lending platform under Quick Cash India and in the process of registering with the RBI for NBFC-P2P, is required to implement this Fair Practices Code (“Code”).
The Board of Directors, in their meeting held on November 1, 2017, approved this Code to ensure its implementation across all departments and teams within the Company. The Code will be updated periodically to align with the standards prescribed by the RBI. This Code is made available on the Company’s website (“Platform”) for the benefit of all stakeholders.
Objectives of the Code
Fairness and Transparency
- The Company is committed to fair and transparent dealings with lenders and borrowers (collectively referred to as “Participants”) on the Platform. All dealings
with Participants will adhere to principles of fair dealing and transparency.
- The Company’s policies and terms for transactions on the Platform will align with this Code and the RBI’s regulations.
- Participants will be informed of the terms and conditions of transactions through the Platform.
Seamless Experience
- The Company aims to provide a seamless experience for Participants on the Platform.
- All grievances from Participants will be handled efficiently and effectively.
- An escalation process for complaints and grievances is detailed in the Company’s Grievance Redressal Policy available on the Platform.
- Communication to Borrowers on the Platform will be in English and the vernacular language or a language understood by the Borrower.
Applicability of the Code
This Code applies to the following key functions of the Platform:
- Participant sign-up process
- Loan processing, including terms and conditions of loans
- Disbursement of loans
- Post-disbursement supervision, monitoring, and recovery
- Other miscellaneous provisions
Participant Sign-Up Process
- The Platform will provide clear information on the sign-up process for Participants.
- Participants’ consent will be obtained before sharing their information with any external third party.
- Lenders’ consent will be obtained before disbursing any loan on their behalf.
- Participants will have access to the draft Loan Agreement before disbursing or availing any loan on the Platform.
- Any changes to the Loan Agreement terms will require the concerned Participant’s approval.
Loan Processing
- Lenders will be required to confirm understanding of all risks involved in transactions on the Platform.
- The Company will inform lenders that it does not assure the return of principal or payment of interest.
- Lenders will be made aware of the potential for complete loss of the principal amount in case of borrower default.
- The Platform may assist with loan recovery per its Recovery Policy, but no assurance of recovery will be provided.
- The Company will disclose to lenders:
- Details about borrowers, including loan amount, interest rate, and credit rating.
- All loan terms and conditions, including interest, fees, and taxes.
- The Company will disclose to borrowers details about lenders, including the proposed loan amount and interest rate offered, without disclosing lenders’ personal identities and contact details.
Disbursement of Loans
- The Company will convey the sanctioned loan amount and terms to Borrowers, including the annualized interest rate and its application method. Changes in interest rates and charges will be prospective.
- A copy of the Loan Agreement and all enclosures will be furnished to Borrowers at the time of loan sanction/disbursement.
- The Loan Agreement and annexures will include necessary information for Borrowers to compare similar terms offered by other NBFCs.
- Decisions to recall or accelerate payments will adhere to the loan agreement terms.
- Securities will be released upon full repayment of dues by Borrowers or realization of the outstanding loan amount. Borrowers will be notified of the right to set off with full particulars before retaining securities.
Post-Disbursement Supervision and Recovery
- The Company will ensure staff dealing with loan recovery are adequately trained and do not resort to harassment or coercion.
- Interest rates and complaint regulations:
- Internal principles and procedures for determining interest rates and charges will be devised and communicated to Borrowers and Investors.
- Any grievances regarding excessive interest rates can be addressed to the Grievance Redressal Officer mentioned on the Website.
- The Board will adopt an interest rate model considering factors like cost of funds, margin, and risk premium, and disclose the rate of interest and risk gradation approach on the Website.
- The annualized interest rates will be disclosed to ensure Borrowers are aware of the exact rates charged.
Other Miscellaneous Provisions
- The Company will not discriminate based on gender, caste, profession, ethnicity, or religion when onboarding Participants.
- In loan recovery, the Company will use legally available measures per RBI guidelines and the Company’s Recovery Policy.
Confidentiality
- The Company will treat all Participant information as private and confidential.
- Participant transaction details will not be disclosed without prior consent except:
- As required by law or government, statutory, or regulatory authority orders.
- To associate entities or entities engaged by the Company for ancillary services or products.
Disclaimer
The RBI does not guarantee the correctness of statements, representations, or opinions expressed by the Company, nor does it assure the repayment of loans lent on the Platform. This disclaimer will also be displayed on the Platform.
General
- The Company will not interfere in Borrowers’ affairs except as provided in the Loan Agreement terms.
- Requests from Borrowers for account transfers will be addressed within 21 days, and transfers will comply with transparent contractual terms and applicable laws.
- Disciplinary action will be taken against staff or agents abusing the terms of this Code.
Further Assistance
- A Grievance Redressal Policy with details of the Grievance Redressal Officer and contact number is available to address Participants’ complaints.
- The compliance of the Code and the grievance redressal mechanism will be periodically reviewed at various management levels. A consolidated report will be submitted to the Board for review and suggested amendments.
Important Note
The RBI does not guarantee any returns or principal amounts invested on the P2P platform.