FAIR PRACTICE CODE

Background and introduction

Tapstart Capital Private Limited (hereinafter referred to as “Tapstart’ or ‘the Company’ or ‘we’ or ‘us’) is an RBI registered NBFC-ND-NSI. We provide a host of credit services to customers catering to different needs, including medical loans, education loans, consumer electronic loans, consumer lifestyle loans and twowheeler 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 RBI Master Direction - Non-Banking Financial Company – Non-Systemically Important Non-Deposit taking Company (Reserve Bank) Directions, 2016 and 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.


Key commitments

The Code has been framed with the purpose of committing to the following:

  • To ensure that all customers are treated fairly and in a professional manner;
  • To provide in detail about the features of the products and services to the customer so that they can make an informed decision;
  • To ensure that customers are not discriminated on the basis of gender, race or religion;
  • To quickly and efficiently address customer concerns;
  • To ensure that the Company’s products, practices and procedures confirm to the relevant laws and regulations;
  • To appropriately train all staff, employees and agents to deal with customers in a professional and kind manner;
  • To establish a transparent charge structure;
  • To ensure that all customers are made aware of all the terms and conditions around interest rates, costs, penalties and other important aspects of the loans disbursed to them.

Applications for loans and their processing

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.


Loan appraisal and terms & conditions

1) Sanction Letter

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.

2) Loan agreement and disbursement of loans

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:

  • To give notice to the borrower in English or in a vernacular language or a language as understood by the customer, of any change in the terms and conditions including disbursement schedule, interest rates, service charges, prepayment charges etc., the Company shall:
  • To ensure that the penal interest charged for late repayment is mentioned in ‘bold’.
  • To incorporate a suitable condition in the loan agreement that all changes pertaining to interest rates and charges are effected only prospectively.
  • That the decision to recall / accelerate payment or performance under the agreement shall be in consonance with the loan agreement.
  • To release all securities on repayment of all dues or on realisation of the outstanding amount of loan subject to any legitimate right or lien for any other claim they may have against customer.
  • That if the Company decides to exercise its right of set off, with respect to security, the Company shall give the customer notice about the same with full particulars about the remaining claims and the conditions under which the Company is entitled to retain the security till the relevant claim is settled/paid.
3) Repossesstion of vehicles financed by Tapstart

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:

  • Notice period before taking possession;
  • Circumstances under which the notice period can be waived;
  • The procedure for taking possession of the security;
  • A provision regarding final chance to be given to the customer for repayment of loan before the sale / auction of the property;
  • A legally enforceable repossession clause
  • The procedure for sale / auction of the property

General Fair Practices

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 foreclosurecharges/ pre-payment penalties on any floating rate term loan sanctioned for purposes other than business to individual customers, with or without co-obligant(s).


Complaint Redressal Mechanism

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 Kshama Kottachery
Contact No. +916366916645
Calls will be answered between 10.00 am to 7.00 pm on all working days of the Company.
Email id kshama@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:

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

1) By email

cepcbengaluru@rbi.org.in
cms.cepcbengaluru@rbi.org.in


2) Other contact details

Telephone: 08022180397/ 398/ 399/ 357   |   Fax: 080-2223 2199


The grievance redressal mechanism has been outlined in detail in the Company’s Grievance Redressal Policy.


Transparency in computation of interest rate and charge structure

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.


Training of employees and agents

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.


Mandatory Display requirements

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.


Review of the Code

The Board of directors shall periodically review the Code or 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.