Policies
All regulatory policies, compliance documents and regional language resources mandated by the Reserve Bank of India.
Interest Rate Policy
Tapstart Capital Private Limited (hereinafter referred to as “Tapstart” or ‘the Company’ or ‘we’ or ‘us’) is an RBI registered Non-systemically important Non-deposit taking Non-banking Financial company (NBFC-ND-NSI). It provides credit facilities to underserved middle and low income segment customers catering to different needs, including personal loans, medical loans, education loans, consumer electronic loans, consumer lifestyle loans and two-wheeler loans.
The Reserve Bank of India (RBI) has advised Boards of NBFCs to lay out appropriate internal principles and procedures in determining interest rates, processing and other charges. This interest rate policy has been framed 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. The policy has been duly approved by the Company’s Board of directors and is suitably and periodically reviewed.
The policy has been framed with the purpose to enable customers to know and understand the methodology for determining the lending rates charged to them and for the Company to maintain transparency in this regard at all times.
The rate of interest under each product charged to different customers is decided from time to time, based on the following parameters:
The annualised rate of interest** charged to borrowers at the time of sanctioning loans shall be within the range as below:
| Sr.No. | Loan Products | Range of Interest Rate* |
|---|---|---|
| 1. | Short term Personal Loan | Up to 36% |
| 2. | Education Loan | 0% to 36% |
| 3. | Consumer Durable Loan | 0% to 36% |
*Based on the Risk Profile of the Borrower
**In exceptional cases, the rate may fall outside the abovementioned range basis the credit assessment of the borrower.
The abovementioned range shall be reviewed periodically or as and when required by the Board of Directors, keeping in view regulatory guidelines/directives, intensity of competition in the market, net interest margin target, etc.
- The interest rates offered is on fixed rate basis
- The interest rate will be annualized so that the borrower is aware of the exact rate that would be charged to him
- The annualized interest rate, loan amount and the tenor will be communicated to the borrower in the sanction letter
- The changes in interest rates and other charges will be effected only prospectively
- Interest would be charged, and recovered on a monthly, quarterly basis or such other periodicity as may be determined by the appropriate authority
The charges currently levied on the customer include:
Claims for refund or waiver of the aforementioned charges or penal interest will be at the sole discretion of the Company.
This Interest Rate policy will be displayed on the Company’s website in accordance with the requirement of the RBI guidelines.
The Board of directors shall periodically review the policy 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 policy will be communicated to the relevant staff/relevant stakeholders.
Policy on Restructuring 2.0
Tapstart Capital Private Limited is an RBI registered Non-systemically important Non-deposit taking Non-banking Financial company (NBFC-ND-NSI). The Reserve Bank of India (RBI) vide its circular on Resolution Framework – 2.0: Resolution of Covid-19 related stress of Individuals and Small Businesses, dated May 05, 2021 (“RBI Circular”), has directed lending institutions including NBFCs to frame Board approved policies for providing the reliefs mentioned in the RBI Circular to all eligible borrowers.
Considering the economic fallout on account of the COVID-19 pandemic and significant financial stress for borrowers nationwide, the RBI provided a window under the Prudential Framework and enabled the lenders to provide a resolution framework to the eligible borrowers for repayment of their loan by way of restructuring the loan or extending the tenure for repayment of the debt.
| Term | Definition |
|---|---|
| Lending Institution | Tapstart Capital Private Limited / the Company. |
| Board | The Board of Directors or any authorized committee(s) of the board of the Company. |
| COVID-19 | Coronavirus Disease declared as a global pandemic by World Health Organization on 11 March 2020. |
| Date of Invocation | The date on which both the borrower and lender have agreed to proceed with a resolution plan. In no case shall the Date of Invocation be later than September 30, 2021. |
- Individuals who have availed of personal loans, excluding the credit facilities provided by lending institutions to their own personnel/staff;
- Individuals who have availed of loans and advances for business purposes and to whom the lending institutions have aggregate exposure of not more than ₹50 crore as on March 31, 2021;
- Borrowers whose loan account was classified as Standard as on 31st March, 2021.
Non-Eligible Borrowers shall mean the personnel or staff of the Company to whom it has extended credit facility or personal loans. The following categories shall also not be eligible:
- MSME borrowers whose aggregate exposure to lending institutions collectively is ₹25 crore or less as on March 1, 2020;
- Farm credit as listed in relevant RBI Master Directions;
- Loans to Primary Agricultural Credit Societies (PACS), Farmers’ Service Societies (FSS) and Large-sized Adivasi Multi-Purpose Societies (LAMPS) for on-lending to agriculture;
- Exposures of lending institutions to financial service providers;
- Exposures of lending institutions to Central and State Governments; Local Government bodies and body corporates established by an Act of Parliament or State Legislature.
- Only borrower accounts classified as standard as on March 31, 2021 shall be eligible;
- The resolution process shall be treated as invoked when the Company and the borrower agree to proceed with efforts towards finalising a resolution plan;
- Resolution plans may include rescheduling of payments, conversion of accrued interest into another credit facility, revisions in working capital sanctions, granting of moratorium etc. However, compromise settlements are not permitted;
- The moratorium period, if granted, may be for a maximum of two years. The overall cap on extension of residual tenor, inclusive of moratorium period, shall be two years.
Only COVID-19 impacted borrowers (financial/medical impact) shall qualify. Accordingly, any borrower facing financial stress on account of the following shall be eligible:
- Income/employment uncertainty;
- Impact on business; or
- Health issues arising from COVID-19.
The decision on the application shall be communicated in writing to the applicant by the Company within 30 days of receipt of such applications.
The resolution plan shall be invoked latest by September 30, 2021 and must be implemented within 90 (Ninety) days from the Date of Invocation.
A restructuring of loan would be treated as implemented upon fulfilment of all of the following conditions:
- All related documentation, including execution of necessary agreements between Lender and Eligible Borrower are completed;
- The new loan amount and/or changes in the terms and conditions of the existing loan account get duly reflected in the books of accounts of the Lender;
- The Eligible Borrower is not in default with the Lender as per the revised terms and conditions.
- If a resolution plan is implemented in adherence to the circular provisions, the asset classification of borrowers’ accounts classified as Standard may be retained as such upon implementation;
- Borrowers’ accounts which may have slipped into NPA between invocation and implementation may be upgraded as Standard as on the date of implementation of the resolution plan;
- Lending institutions shall keep provisions higher of: the provisions held as per extant IRAC norms immediately before implementation, or 10 percent of the renegotiated debt exposure post implementation (residual debt);
- Half of the above provisions may be written back upon the borrower paying at least 20% of the residual debt without slipping into NPA post implementation, and the remaining half upon the borrower paying another 10% of the residual debt.
- Financial Statement: The Company shall make appropriate disclosures about restructured accounts in its annual financial statements under “Notes to Accounts”;
- Credit Reporting: Credit bureau reporting shall reflect the “restructured due to COVID-19” status of the account.
The Company shall address all grievances of Borrowers who have applied for or are undergoing resolution under this window. Customers can register/lodge grievances via:
- Email: hello@tapstart.in
- Post: Customer Services Team, Tapstart Capital Private Limited, Unit No G408, 4th Floor, Gamma Block, Varthur Hobli, Sigma Soft Tech Park, No. 7, Whitefield Road Bangalore – 560066
In case of any further clarifications issued by RBI from time to time, the same shall override/amend this policy as applicable. In order to ensure immediate implementation keeping in view the importance of extending relief due to the impact of COVID-19, any further changes to this policy based on the notifications from the RBI in this regard, can be done with approval from MD and CEO ABFL, CRO. Any significant changes will be informed to the Board.
Loan Application Form in Regional Languages
Download the TapStart Personal Loan Application Form in your preferred regional language.
Grievance Redressal Policy
Tapstart Capital Private Limited (hereinafter referred to as “Tapstart” or ‘the Company’) is an RBI registered NBFC-ND-NSI and NBFC-BL. It provides credit facilities to underserved middle and low income segment customers catering to different needs, including personal loans, medical loans, education loans, consumer electronic loans, consumer lifestyle loans and two-wheeler loans.
Tapstart places utmost importance on customer satisfaction and endeavors to provide prompt and efficient customer service. The Grievance Redressal Policy has been framed in line with the Company’s objectives and the guidelines outlined in the RBI Master Direction – Reserve Bank of India (Non-Banking Financial Company – Scale Based Regulation) Directions, 2023 and updated from time to time. The policy has been duly approved by the Company’s Board of directors and is suitably and periodically reviewed.
- To ensure that all customers are treated fairly and in a professional manner;
- To provide redressal of customer grievances and complaints in a time-bound manner; and
- To ensure that all customers are fully informed of the grievance redressal mechanism including the mode of lodging complaints, escalation matrix with all the contact details, and timelines for redressal at every level.
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 including digital lending through Mobile Applications of Lending Service Provider (LSP). Customers can register/lodge complaints via:
- Email: hello@tapstart.in — looked into by the Company’s operations/back-end team internally.
- Post: Customer Services Team, Tapstart Capital Private Limited, Unit No G408, 4th Floor, Gamma Block, Varthur Hobli, Sigma Soft Tech Park, No. 7, Whitefield Road Bangalore – 560066
A step-by-step flow showing how you can raise and escalate a complaint with Tapstart. Each level has a defined contact, response time, and escalation path.
All complaints against the Company or the Lending Service Provider engaged by the Company shall be initiated through/directed to any of the channels mentioned above. At this level, the Company will strive to address the customer complaint within 7 days.
If any such complaint is not addressed to the satisfaction of the customer, the customer shall be given the option to escalate the complaint to the Grievance Redressal Officer (‘GRO’) who will be a senior level officer appointed by the Company. After examining the matter, the Company will endeavor to respond or address the customer complaint within 15 days of receipt of the complaint/grievance.
The customer can lodge a complaint related to unauthorized acceptance of deposits/schemes of various kind and fake emails at https://sachet.rbi.org.in/home/index
If any complaint lodged by the borrower is rejected wholly or partly, or the borrower is not satisfied with the reply, or has not received any reply within 30 days of receipt of complaint, the said borrower can lodge a complaint via:
- (i) The Complaint Management System (CMS) portal https://cms.rbi.org.in/ under the Reserve Bank Integrated Ombudsman Scheme (RB-IOS);
- (ii) Physical complaint to “Centralised Receipt and Processing Centre, 4th Floor, Reserve Bank of India, Sector-17, Central Vista, Chandigarh – 160017”;
- (iii) Email: cms.cepcbengaluru@rbi.org.in, cepcbengaluru@rbi.org.in
- (iv) Telephone: RBI CEPC Bengaluru – 08022180397 / 398 / 399 / 357 | Fax: 080-2223 2199
The Company shall prominently display the escalation matrix of the internal Grievance Redressal Mechanism, the name of the GRO along with all the contact details, and the details of the Officer-in-Charge DNBS, RBI over its website, mobile applications as well as across all branches/places where its business is transacted.
The Company shall adequately train all its employees and agents to appropriately address customer concerns and complaints in a professional manner. The training programme shall include soft skills and technicalities around nature of complaints and shall inter alia include a module containing the rights of persons with disabilities guaranteed to them by law and international conventions.
- To approve the policy as well as any revisions/modifications made therein;
- To lay down the appropriate grievance redressal mechanism within the organization and effective implementation thereof;
- To periodically review the functioning of the grievance redressal mechanism at various levels of management;
- To prescribe a consolidated report of such reviews to be submitted to it at regular intervals;
- To prescribe and review a complaint MIS/register on a periodic basis.
The Board of directors shall periodically review the policy 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 policy will be communicated to the relevant staff/relevant stakeholders.
Fair Practice Code
Download the Fair Practice Code in your preferred regional language.
Tapstart Capital Private Limited (hereinafter referred to as “Tapstart” or ‘the Company’) 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 underserved middle and low-income segments with a relatively high credit need. We endeavor to maintain transparency in all our dealings with the customer.
This Fair Practice Code (‘the Code’) has been formulated 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, 2023 and updated from time to time. 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 shall be circulated to all employees and agents of the Company.
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.
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.
An acknowledgement for receipt shall be generated for all loan applications, communicating 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 the amount of loan sanctioned along with the terms and conditions stipulated therein. The terms and conditions shall 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 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, to all 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 of any change in the terms and conditions including disbursement schedule, interest rates, service charges, prepayment charges etc.;
- To ensure that the penal charges for late repayment is mentioned in ‘bold’;
- To incorporate a suitable condition 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;
- If the Company decides to exercise its right of set off, it shall give the customer notice about the same with full particulars about the remaining claims.
Once the loan is approved, a KFS shall be issued to the borrower in a standardised format as per the RBI circular 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.
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 inter alia contain 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.
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.
The quantum and reason for penal charges shall be clearly disclosed to customers in the loan agreement and Key Fact Statement (KFS), in addition to being displayed on the Company’s website under Interest rates and Service Charges.
To ensure transparency, the terms and conditions of the loan agreement shall inter alia 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.
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 Company shall include a suitable module containing the rights of persons with disabilities guaranteed by law and international conventions in all training programmes. Further, the Company shall ensure redressal of grievances of persons with disabilities under the Grievance Redressal Mechanism.
- 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;
- 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;
- With respect to recovery of loans, the Company shall not resort to undue harassment and shall refrain from persistently bothering customers at odd hours or using muscle power for recovery of loans;
- 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 including any complaints against the Lending Service Provider (LSP) engaged by the Company.
If any complaint lodged by the borrower is rejected wholly or partly, or the borrower is not satisfied with the reply, or has not received any reply within 30 days, the said borrower can lodge a complaint via:
- (i) The Complaint Management System (CMS) portal https://cms.rbi.org.in/ under the Reserve Bank Integrated Ombudsman Scheme (RB-IOS);
- (ii) Physical complaint to “Centralised Receipt and Processing Centre, 4th Floor, Reserve Bank of India, Sector-17, Central Vista, Chandigarh – 160017”;
- (iii) Email: cms.cepcbengaluru@rbi.org.in, cepcbengaluru@rbi.org.in
- (iv) Telephone: RBI CEPC Bengaluru – 08022180397 / 398 / 399 / 357 | Fax: 080-2223 2199
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 website/mobile application of the Company or published in relevant newspapers. 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.
The Company shall adequately train all its employees, Direct Sales Agents (DSA), Direct Marketing Agents (DMA) 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.
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.
Sanction Letter in Regional Languages
Download the TapStart Sanction Letter in your preferred regional language.
Consumer Education Literature
Reserve Bank of India (RBI) vide its circular dated November 12, 2021 on Prudential norms on Income Recognition, Asset classification and provisioning pertaining to Advances (IRACP norms) has harmonized/clarified certain aspects of the extant regulatory guidelines applicable to NBFCs in order to ensure uniformity in the implementation of IRACP norms across all lending institutions.
Tapstart Capital Private Limited (Tapstart or “the Company”), is a Base – Layer, non-deposit taking, Non-Banking Financial Company (“NBFC-BL”) and will follow the above norms.
With a view to increase an awareness among the borrowers, RBI requires the NBFCs to frame Consumer Education Literature explaining with examples the concepts of date of overdue, SMA and NPA classification and upgradation, with specific reference to day-end process.
Any amount due to the Company under any credit facility shall be treated as overdue if it is not paid on the due date fixed by the Company. Borrower accounts shall be flagged as overdue by the Company as a part of the day-end process for the due date and date of overdue shall be calendar date for which the day-end process is run.
Classification of the borrower accounts as SMA shall be done as part of day-end process for the relevant date and the SMA classification date shall be the calendar date for which the day-end process is run.
The basis for classification of SMA categories shall be as follows:
| SMA sub-categories | Basis for classification – Principal or interest payment or any other amount wholly or partly overdue |
|---|---|
| SMA-0 | Upto 30 days |
| SMA-1 | More than 30 days and upto 60 days |
| SMA-2 | More than 60 days and upto 90 days |
Classification of the borrower accounts as NPA shall be done as part of day-end process for the relevant date and the NPA classification date shall be the calendar date for which the day-end process is run.
NPA means:
- an asset, in respect of which, interest has remained overdue for such period as may be prescribed by RBI from time to time;
- a term loan inclusive of unpaid interest, when the installment is overdue for such period as may be prescribed by RBI from time to time;
- a demand or call loan, which remained overdue for such period as may be prescribed by RBI from time to time;
- a bill which remains overdue for such period as may be prescribed by RBI from time to time;
- the interest in respect of a debt or the income on receivables under the head ‘other current assets’ in the nature of short term loans/advances, which facility remained overdue for such period as may be prescribed by RBI from time to time;
- any dues on account of sale of assets or services rendered or reimbursement of expenses incurred, which remained overdue for such period as may be prescribed by RBI from time to time;
- the lease rental and hire purchase installment, which has become overdue for such period as may be prescribed by RBI from time to time; and
- in respect of loans, advances and other credit facilities (including bills purchased and discounted), the balance outstanding under the credit facilities (including accrued interest) made available to the same borrower/beneficiary when any of the above credit facilities becomes nonperforming asset.
- It is said that loan accounts classified as NPAs may be upgraded as ‘standard’ asset only if entire arrears of interest and principal are paid by the borrower.
- In case if the borrower is having more than one credit facilities, the loan account will be upgraded from NPA to standard category only when entire principal and interest outstanding amount pertaining to all credit facilities is paid by the borrower.
- No delinquency should be present in any of the credit facilities availed by the borrower from the Company.
NACH Mandate Cancellation Form
Download the NACH (National Automated Clearing House) Mandate Cancellation Form to cancel your existing NACH mandate with TapStart Capital Private Limited.