Fair Practice Code & Code Of Conduct

Background:

Rang De P2P Financial Services Private Limited (“Rang De”) has adopted this Fair Practices Code (“FPC”) in adherence to the directions issued by the Reserve Bank of India (“RBI”) i.e. Master Directions - Non-Banking Financial Company – Peer to Peer Lending Platform (Reserve Bank) Directions, 2017 (“Directions”). The FPC sets standards for incorporating fair practices in the activities undertaken by Rang De while dealing with the persons who register on its platform (“Participants”). The FPC shall be amended from time to time to ensure consonance with the standards prescribed by RBI.

Applicability:

The Fair Practices Code shall be applicable to all employees, contractors, sub-contractors, escrow agents and service providers of Rang De (“Agents”), who are engaged in facilitating loans from the lenders to the borrowers who are registered on Rang De’s platform.

Objectives:

  1. To ensure that the Participants registered on the platform are treated with respect and courtesy.
  2. To ensure that Rang De and its Agents fairly and equitably deal with the Participants so as to provide them with a hassle-free experience while accessing the platform.
  3. To assist the Participants in understanding the services provided under the platform and educating them on their roles and obligations pursuant to transactions undertaken through the platform, in a language and manner that can be understood by them.
  4. To provide all information as may be necessary, in a language and manner that can be understood by the Participants, to ensure that they make an informed decision before accessing the services provided by Rang De through the platform.
  5. To ensure that all reasonable grievances/ complaints of the Participants are address in a prompt and efficient manner.

Application:

  1. Registration by Participants on the Platform

    • The applicability criteria to be met by the Participants to determine their eligibility to register themselves on the platform either as a borrower or as a lender, shall be displayed on the platform, which should be read and understood by the Participants.
    • The Participants shall be provided with a link containing the terms of use for availing the services provided on the platform, which should be read and understood by the Participants.
    • The terms of use shall establish the nature of the platform and the rights and obligations of Participants vis à vis Rang De. In particular it specifies that Rang De does not guarantee the receipt of a loan by every registered borrower nor does it guarantee the repayment of any loans availed by the borrowers, to the lender.
    • Rang De reserves the right to change the terms of use of the platform, the design and look of the platform at any time and at its sole discretion.
  2. Loan Applications and its Processing

    • The borrower will be provided with a Loan Application Form containing (a) the various types of loans available through the platform; (b) all material terms and conditions governing each of the specified loans including but not limited to the annualised rate of interest and method of calculation of interest, the duration of the loan (not exceeding 36 months), the repayment terms and the penal interest charged for default(s) in repayment, service charges, prepayment charges etc. (“Material Terms of Loan”) and (c) the documents required to be submitted by the borrower (“Ancillary Loan Documents”). The Loan Application Form shall be both in English language and in a vernacular language, which is understood by the borrower, in order to enable the borrower to take an informed decision. All numbers contained in the Material Terms of Loan should in bold font.
    • Upon execution and submission of the Loan Application Form (and other relevant documents as indicated therein) by the borrower, Rang De / its Agents shall issue a loan application acknowledgment number to the borrower.
    • The borrower will be provided with an approximate time frame within which the outcome of the Loan Application Form will be intimated to him/her/it. The borrower will be entitled to track the status of his Loan Application Form through the platform.
  3. Appraisal / Sanction of the Loan Application Form

    • Rang De shall review and process the Loan Application Form along with the ancillary documents submitted by the borrower within a reasonable time-frame and prepare, with the prior permission of the borrower, a credit assessment of the borrower. The credit assessment will help in recognizing the repayment capacity of the borrower.
    • Rang De will upload the Loan Application Form, Ancillary Loan Documents and the credit assessment of the borrower on its platform for lender to review and access.
    • Lenders shall choose the borrowers to whom they wish to provide loans based on the Material Terms of Loan. The lenders shall be required to provide an explicit affirmation that he/ she / it has understood the risks associated with the proposed lending transaction and that there is no guarantee of return and that there exists a likelihood of loss of entire principal in case of default by a borrower.
    • Upon sanction of the loan by a lender, the borrower shall be informed through email and through the platform (both in English and in such vernacular language understood by the borrower), including the amount of loan sanctioned, disbursement schedule and other Material Terms of Loan. The Identity/ personal details of the lender shall not be revealed to the borrower.
    • In the event that no lender sanctions the loan to the borrower within a period of 60 days, the same will be intimated to the borrower via the Impact Partner and the Loan Application Form shall be closed.
    • For loans that are sanctioned, the platform shall generate a loan agreement to be executed by the borrower. The execution of the loan agreement shall be an irrevocable acceptance of the terms and conditions of the loan by the respective lenders and borrowers.
    • A copy of the loan agreement along with any enclosures mentioned therein, shall be made available through email and on the platform to the lender and the borrower.
  4. Disbursement

    • Rang De shall set up an escrow account, operated by a trustee promoted by the bank in the manner provided for under the Directions, for (a) receiving the sanction loans from the lenders and (b) disbursal of the same to the borrowers.
    • The disbursal of the loan to the borrowers shall be made directly from the escrow account to the bank account of the borrower or may way of a crossed cheque issued in the name of the borrower.
  5. Repayment

    • Rang De shall set up an escrow account, operated by a trustee promoted by the bank in the manner provided for under the Directions, for (a) the receiving the repayment amounts of the loans from the borrowers and (b) disbursal of the same to the lenders.
    • The disbursal of the repayment amounts to the respective lenders shall be made directly from the escrow account to the bank account of the lender or may be made by way of a crossed cheque issued in the name of the lender.
  6. Supervision/Monitoring of loans

    • Rang De shall monitor and supervise the activities of the escrow accounts and assist in such other activities as required under applicable laws.
    • Rang De shall communicate all information required to be furnished to Participants in relation to the loan, without any inordinate delay.
  7. Effectuation of changes with respect to the loan

    • In case of receipt of request from the borrower for transfer of borrowal account, the consent or objection of Rang De, if any, should be conveyed to the borrower within 21 (twenty one) days from the date of receipt of such request. Any transfer of borrowal account shall be as per transparent contractual terms in consonance with applicable laws.
    • In the event of any change in the terms and conditions of the loan including Material Terms of Loan which is adverse to the interest of the borrower/ lender, Rang De shall give a notice of 30 (thirty) days to the borrower/ lender, both in English language and in such vernacular language as understood by the borrower/ lender through the platform and via email, prior to effectuating such change. In the event the changes are not adverse to the interests of the borrower / lender, Rang De shall provide written intimation to them.
    • Rang De should communicate unambiguously to the borrower/ lender through its platform any information about –
      1. changes in types of loans available through the platform;
      2. change of its office address;
      3. changes in the Service Providers used by it for facilitating the services available on the platform.
  8. Miscellaneous Provisions

    • Rang De shall not discriminate on the grounds of gender, caste, age, literacy, economic status, physical disability or religion in its policies and activities.
    • Any obligations that cannot be fulfilled to the participants in the given time frame shall be communicated to them within a reasonable period of time.
    • Any decision to recall / accelerate payment or performance under the loan agreement should be in consonance with the loan agreement and reasons for the same shall be intimated to the borrower through the platform.
    • Rang De and its Agents shall ensure that it performs only those functions as required under applicable law and the loan agreement. There shall not be any interference with respect to the affairs of the Participants except (a) as provided under terms and conditions of the loan agreement and (b) in the event new information, not earlier disclosed by the borrower/lender, has come to the notice of the Rang De/ its Agents, which affects the loan transaction in any manner whatsoever.
    • In the matter of recovery of loans, Rang De and its Agents shall follow the Code of Conduct detailed below and shall not resort to undue harassment of the borrowers.
    • In the matter of grievances raised by Participants, Rang De / its Agents shall follow the Grievance Redressal Policy adopted by its Board from time to time.

Confidentiality:

  1. All personal information received and collected by Rang De/ its Agents from its Participants shall treated as private and confidential and shall not be disclosed other than as provided for herein and under applicable laws.
  2. The personal information and details of the interaction of the Participants on the platform and any such transactional details carried out shall not be revealed by Rang De/ its Agents to other persons, except:
    • As required for the performance of the services provided through the platform.
    • Any information required to be furnished to the Participants for making informed decisions relating to the services provided through the platform.
    • As may be required to be disclosed by any applicable law or regulation;
    • In the event, Rang De, in its sole discretion, determines that it is a public duty to reveal such information;
    • Where the explicit consent of the Participant is received to divulge the information.
    • If required to protect the interests of Rang De.
    • If it is for a regulatorily mandated business purpose such as disclosure of default to credit information companies/ debt collection agencies.

Monitoring and Supervision:

  1. The Grievance Redressal Cell of Rang De shall monitor and analyse the implementation of the FPC and Code of Conduct.
  2. The Grievance Redressal Cell of Rang De shall prepare a quarterly summary report of the implementation and adherence to the FPC and Code of Conduct. The summary report shall be placed before the Board of Rang De. 
  3. Rang De may conduct feedback surveys with Participants on their interactions with Rang De and its Agents to ensure adherence to the FPC and Code of Conduct.

Code of Conduct:

  1. A potential Participant / Participant to the platform (“Prospect”) can be called by Rang De/ its Agents (“TME”) only when, he/ she has expressed a desire to avail the services of Rang De available on its platform or where he/she has given consent to be called.
  2. TME should not call a person whose name/number is flagged in any "do not disturb" list.
  3. A Prospect may be called only in between 0930 Hrs and 1900 Hrs., unless express permission is granted by the Prospect to be called outside these hours. However, it may be ensured that a Prospect is contacted only when the call is not expected to inconvenience him/her.
  4. TME should respect a Prospect’s privacy. The Prospect’s interest may normally be discussed only with the Prospect and any other individual/family member (such as Prospect’s accountant/secretary /spouse) authorized by the Prospect.
  5. Only in the event the Prospect is not available over a call, a message may be left for him/her. The aim of the message should be to get the Prospect to return the call or to check for a convenient time to call again, the purpose of the call should be mentioned i.e. to inform the Prospect of the services (or any part thereof) available on the platform.
  6. The TME shall not mislead the Prospect on any service / product offered; about the business or organization's name, or falsely represent themselves, or make any false / unauthorised commitment on behalf of Rang De for any facility/service.
  7. During the call with the Prospect, telephone etiquettes to be followed by the TME are as follows:
    • TME should identify himself/herself and mention that he/she is calling from/ on behalf of Rang De;
    • Request permission to proceed;
    • If denied permission, apologize and politely disconnect;
    • State reason for the call;
    • Always offer to call back on landline, if call is made to a cell number;
    • Never interrupt or argue with the Prospect;
    • To the extent possible, talk in the language which is most comfortable to the Prospect;
    • Keep the conversation limited to business matters;
    • Check for understanding of "Most Important Terms and Conditions" by the Prospect if he plans to avail the services of Rang De through the platform;
    • Reconfirm next call or next visit details;
    • TME should provide his/her telephone no and supervisor's name if asked for by the Prospect.
    • Thank the Prospect for his/her time.
  8. Customers who have expressed their lack of interest for the offering should not be called or contacted again in any manner for the next 3 (three) months.
  9. The TME should provide feedback to Rang De on Prospects who have expressed their desire to be flagged "Do Not Disturb" and such Prospects should not be contacted again, other than if required for recovery of loans availed through the platform.
  10. Participants should never be called and calls should not be entertained from Participants, regarding service already availed. Instead the Participant should be advised to contact the Customer Service Staff / Grievance Redressal Cell of Rang De.
  11. TME's must not accept gifts from Prospects or bribes of any kind. Any TME offered a bribe or payment of any kind by a Prospect must report the offer to his/her management.
  12. On personal interactions with Prospects, the TME should respect personal space - maintain adequate distance from the Prospect.
  13. Not enter the Prospect's residence/office against his/her wishes;
  14. Not visit in large numbers - i.e. not more than one TME and one supervisor, if required.
  15. Respect the Prospect's privacy.
  16. If the Prospect is not present and only family members/office persons are present at the time of the visit, he/she should end the visit with a request for the Prospect to call back. Provide his/her telephone number, supervisor's name, if asked for by the customer.
  17. TME's must be appropriately dressed (meaning for men well ironed trousers and shirts with sleeves preferably buttoned down and for women well ironed formal attire (Jeans, T Shirts, open sandals are not considered appropriate).
  18. Any communication sent to the Prospect should be only in the mode and format approved by Rang De.