Tapstart Capital Private Limited (hereinafter referred to as “Tapstart’ or ‘the Company’ or ‘we’ or ‘us’) is an RBI registered Base Layer (Non-Deposit taking) Non-Banking Financial Company (“NBFC-ND”) . We provide a host of credit services to customers catering to different needs, including personal loans, medical loans, education loans, consumer electronic loans, consumer lifestyle loans and two-wheeler loans. We primarily target undeserved middle and low-income segments with a relatively high credit need. We endeavor to maintain transparency in all our dealings with the customer and impress on the need to transact with customers with utmost professionalism.
The Company believes that the customer must be aware of the end-to-end aspects of the loan products along with the means of redressal available to the customers in case of need. This Fair Practice Code (‘the Code’) has been formulated keeping the abovementioned aspects in mind and is in line with the Company’s objectives and the guidelines outlined in the Master Direction- Reserve Bank of India (Non-Banking Financial Company – Scale Based Regulation) Directions, 2023and updated from time to time along with other relevant circulars issued in this regard. The Code applies to all categories of products offered by the Company as well as to all its customers.
The Code has been duly approved by the Company’s Board of directors and is suitably and periodically reviewed for the purpose of minimizing such complaints in the future.
The Code shall be circulated to all the employees and agents of the Company.
The Code has been framed with the purpose of committing to the following:
The Company shall ensure that all communications to the customers shall be in English or in a vernacular language or a language as understood by the customer. Additionally, the Company shall ensure that all loan application forms include necessary information which affects the interest of the customer.
We shall ensure that an acknowledgement for receipt is generated for all loan applications. This acknowledgement shall be communicated to the customers and will outline the time frame within which loan applications will be disposed of.
Once a loan has been approved, the Company shall convey in writing to the borrower in English or in a vernacular language or a language as understood by the customer, by means of sanction letter or otherwise, the amount of loan sanctioned along with the terms and conditions stipulated therein. The terms and conditions shall, inter alia, include the annualised rate of interest and method of application thereof. The Company shall maintain a record of the acceptance of these terms and conditions by the customer. The rate of interest and the approach for gradations of risk and rationale for charging different rate of interest to different categories of customers shall be communicated to the customer explicitly in the sanction letter.
The Company shall furnish a copy of the loan agreement as understood by the borrower along with a copy each of all enclosures quoted and which form a key component of such loan agreement, to all the customers at the time of sanction / disbursement of loans. With regard to the loan agreement, the Company shall ensure:
Once the loan is approved, a KFS shall be issued to the borrower in a standardised format as per the recent circular issued by the RBI on Key Facts Statement for Loans & Advances dated April 15, 2024.
A KFS is a statement of key facts of a loan agreement, in simple and easier to understand language, provided to the borrower in a standardised format. It shall be provided to the borrower before the execution of the loan agreement. The contents of KFS shall be explained to the borrower and an acknowledgement shall be obtained that he/she has understood the same.
The KFS shall be provided with a unique proposal number and shall have a validity period of at least three working days for loans having tenor of seven days or more, and a validity period of one working day for loans having tenor of less than seven days. The KFS shall, apart from other necessary information, inter alia contains the details of APR, the recovery mechanism, details of grievance redressal officer designated specifically to deal with digital lending/ FinTech related matter and the cooling-off/ look-up period.
Penalty, if charged, for non-compliance of material terms and conditions of loan contract by the borrower shall be treated as 'penal charges' and shall not be levied in the form of 'penal interest' that is added to the rate of interest charged on the advances. There shall be no capitalisation of penal charges i.e., no further interest computed on such charges. However, this will not affect the normal procedures for compounding of interest in the loan account.
The Company shall not introduce any additional component to the rate of interest and ensure compliance to these guidelines in both letter and spirit.
The quantum of penal charges shall be reasonable and commensurate with the non-compliance of material terms and conditions of loan contract without being discriminatory within a particular loan/product category.
The penal charges in case of loans sanctioned to 'individual borrowers, for purposes other than business', shall not be higher than the penal charges to non-individual borrowers for similar non-compliance of material terms and conditions.
The quantum and reason for penal charges shall be clearly disclosed by Company to the customers in the loan agreement and most important terms & conditions/Key Fact Statement (KFS) as, in addition to being displayed on websites of Company under Interest rates and Service Charges.
Whenever reminders for non-compliance of material terms and conditions of loan are sent to borrowers, the penal charges shall be communicated. Further, any instance of levy of penal charges and the reason therefor shall also be communicated.
To ensure transparency, the terms and conditions of the loan agreement entered into between the Company and the customer shall, inter alia, include contain provisions pertaining to:
The Company shall not discriminate in extending products and facilities including loan facilities to physically/visually challenged applicants on grounds of disability. The Company shall render all possible assistance to such persons for availing of the various business facilities. The Comp[any shall include a suitable module containing the rights of persons with disabilities guaranteed to them by the law and international conventions, in all the training programmes conducted for their employees at all levels. Further, the Company shall ensure redressal of grievances of persons with disabilities under the Grievance Redressal Mechanism already set up by them.
The Company shall refrain from interfering in the affairs of the customer except for the purposes provided in the terms and conditions of the loan agreement (unless information, not earlier disclosed by the customer, has been noticed).
In case the customer requests a transfer of the borrowal account, the Company shall convey its consent or objection, if any, within 21 days from the date of receipt of such request. In case of approval of the request, the Company shall ensure that such transfer is as per transparent contractual terms in accordance with the law.
With respect to recovery of loans, the Company shall not resort to undue harassment and shall refrain from persistently bothering customers at odd hours, using muscle power for recovery of loans, etc.
With regard to prepayment of various loans by customers, the Company shall not charge foreclosure charges/ pre-payment penalties on any floating rate term loan sanctioned for purposes other than business to individual customers, with or without co-obligant(s).
The Company will address all complaints/ concerns of customers arising out of activities carried out by the Company as well as those activities that have been outsourced.
For any grievance that the customer may want redressed, he may write to the following persons whose names will be displayed on the Company's website and mobile application:
| Designation | Grievance Redressal Officer |
| Name | Mr. Shaurya Rana |
| Contact No. | +91-8095345443 Calls will be answered between 10.00 am to 7.00 pm on all working days of the Company. |
| Email id | shaurya@tapstart.in |
If the complaint / dispute is not redressed within a period of one month, or if the customer is not satisfied with the response provided, the customer may appeal to the Officer-in-Charge of the Regional Office of Department of Non-Banking Supervision (DNBS) of the RBI. The relevant contact details are provided below:
1) By Post
To,
The Officer-in-charge,
Department of Non-Banking Supervision, Reserve Bank of India
Regional Office of Department of Non-Banking Supervision,
10/3/08, Nrupatunga Road,
P.B.No.5470,
Bangalore-560001
2) By email
cms.cepcbengaluru@rbi.org.in
cepcbengaluru@rbi.org.in
3) Other contact details
Telephone : RBI CEPC Bengaluru - 08022180397/ 398/ 399/ 357
Fax : 080-2223 2199
The grievance redressal mechanism has been outlined in detail in the Company's Grievance Redressal Policy.
The Board of the Company shall lay out and implement an interest rate model taking into account relevant factors such as cost of funds, margin and risk premium and determine the rate of interest to be charged for loans and advances.
The rates of interest and the approach for gradation of risks shall also be made available on the web-site/ mobile application of the Company or published in relevant newspapers, or in any other manner. The information so published will be updated whenever there is a change in the rates of interest. The rate of interest shall be an annualised rate for the benefit of the customer.
In order to maintain fairness and to avoid charge of excessive interest rates, processing charges or any other charges levied against loans sanctioned to customers, the Board of the Company shall lay out an appropriate charge structure with internal principles and procedures in determining all charges to the customers.
It is essential that the Company’s employees, Direct Sales Agents (DSA), Direct Marketing Agents (DMA) and Recovery Agents refrain from action that could damage the integrity and reputation of the Company and that they observe strict customer confidentiality. To achieve this, the Company shall adequately train all its employees, DSAs, DMAs and Recovery Agents to appropriately handle their responsibilities with care and sensitivity, particularly aspects such as soliciting customers, hours of calling, privacy of customer information and conveying the correct terms and conditions of the products on offer, etc. The training programme shall include soft skills and technicalities around appropriate and professional manner of collection of dues and shall inter alia include a module containing the rights of persons with disabilities guaranteed to them by the law and international conventions.
The training shall be formulated to ensure that the Company and its agents shall not resort to rudeness, intimidation or harassment of any kind, either verbal or physical, against any person in their debt collection efforts, including acts intended to humiliate publicly or intrude the privacy of the debtors' family members, referees and friends, making threatening and anonymous calls or making false and misleading representations.
The Company shall display, in English or in a vernacular language or a language as understood by the customer, the Fair Practice Code as well as the contact information of the GRO across its website, mobile applications as well as across all branches/ places where its business is transacted.
The Board of directors shall periodically review the Code and the functioning of the grievances redressal mechanism on a need-basis i.e. in the event of change in regulatory framework or for business or operational need. Such updates / changes to the Code will be communicated to the relevant customers/ staff / relevant stakeholders.
