1.Introduction

Ramaiah Capital Private Limited (hereinafter referred to as ‘the Company’) has framed the Customer Service Policy (hereafter referred to as “Customer Service Policy” or “the Policy”) in accordance with the regulatory requirements specified by the Reserve Bank of India (RBI).

2.Objectives of the Policy

The objective of the Customer Service Policy is to ensure that:

• All customers are treated fairly and without bias
• Customers are made aware of their rights and available remedies
• Issues raised by customers are attended and dealt with utmost care and resolved within a reasonable time. 

3. Mode of communication with customers.

Communication with customers shall be in writing/ e mail. SMS, or by telephone

It shall be in the vernacular and or language understood by the borrower.

4. Loan Application

The loan applications shall include all required information including list of documents required to be submitted.

The receipt of loan application shall be acknowledged physically or electronically.

The terms and conditions of sanction, interest rate, mode of application of interest  and other charges shall be conveyed in the sanction in unambiguous terms.

5.Interest Rates and Change in Terms and conditions

Any changes in the terms and conditions, or charges or interest rates shall be conveyed to the borrowers.

Changes in charges or interest rates shall apply only prospectively.

The rates of interest shall also be made available on the web-site of the Company.  The information published in the website or otherwise published shall be updated whenever there is a change in the rates of interest.

The rate of interest shall be annualised so that the borrower is aware of the exact rates that would be charged to the account. The type of interest and the method of application shall be made known to the borrowers.

Annual Percentage Rate (APR) - APR as all-inclusive cost of  loans for the borrower and this shall be disclosed upfront and shall also be a part of the Key Fact Statement.

Interest will be charged only from the date of disbursement of funds to the borrower and not from the date of sanction/ date of execution of loan agreement or from the date of issue of cheque to borrower.

In the case of disbursal or repayment of loans during the course of the month, interest will be charged only for the period for which the loan was outstanding.

In case one of more instalments are collected in advance interest will be charged only for the amount disbursed less the advance instalment/s collected and not on the full loan amount.

Penal Interest shall not be charged however Penalty,  for non payment/delayed payment of isntalemnts and / or 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 shall be computed on such charges

The quantum of penal charges shall be reasonable and commensurate with the noncompliance of material terms and conditions of loan contract without being discriminatory within a particular loan / product category. In any case the penal charges shall not exceed 10% of the amount due amount which is not paid by the customer on the due date plus applicable GST.

The penal charges in case of loans sanctioned to ‘individual borrowers, for purposes other than business’, shall not be higher than the penal charges applicable to nonindividual borrowers for similar non-compliance of material terms and conditions.

The quantum and reason for penal charges shall be clearly disclosed  to the customers in the loan agreement and most important terms & conditions / Key Fact Statement (KFS) as applicable, in addition to being displayed website under Interest rates and Service Charges.

Whenever reminders for non payment of intalments and / or non-compliance of material terms and conditions of loan are sent to borrowers, the applicable penal charges shall be communicated. Further, any instance of levy of penal charges and the reason therefor shall also be communicated.

6. Digital Lending

Any Digital Lneidng APP associated with the Company shall be displayed on the Company’s website.

Names of digital lending platforms engaged as agents (Loan Service Providers ) shall be disclosed on the website.

Digital lending platforms engaged as agents (Lendsing Service Providers) shall be directed to disclose upfront to the customer, the name of Ramaiah Capital  on whose behalf they are interacting with the borrowers.

Immediately after sanction but before execution of the loan agreement, the sanction letter shall be issued to the borrower on the letter head of the Company.

A copy of the loan agreement along with a copy each of all enclosures quoted in the loan agreement shall be furnished to all borrowers at the time of sanction/ disbursement of loans.

Effective oversight and monitoring shall be ensured over the digital lending platforms and Lending Service Providers engaged by Ramaiah Capital.

Adequate efforts shall be made towards creation of awareness about the grievance redressal mechanism, by displaying details of tgeh mechanism on the notice board of all Companys offceed asn also on the website

7. Framework for compensation to customers for delayed updation/ rectification of credit information

In case of complaints made by borrowers regarding the information reported by the credit Bureaus or to update the credit information by making an appropriate correction, addition or otherwise, and on such request Ramaiah Capital / CIC shall take steps to update the credit information within thirty (30) days after being requested to do so.

The Complainants shall be entitled to a compensation of ?100 per calendar day in case their complaint is not resolved within a period of thirty (30) calendar days from the date of the initial filing of the complaint by the complainant with Ramaiah Capital/ Credit Information Company.

Ramaiah Capital shall forward the corrected particulars of the credit information to the CIC or complainant within a period of twenty-one (21) days from the date when Ramaiah Capital was informed of the inaccuracy in the credit information. The credit information Company shall update/rectify the same with in the next 9 days.

There shall be an overall limit of thirty (30) days to resolve/ dispose of the complaint. In effect, this would mean that Ramaiah Capital would get twenty-one (21) days and CICs would effectively get the remainder of nine (9) days for complete resolution of the complaint.

Ramaiah Capital shall pay compensation to the complainant if we have failed to send updated credit information to the CICs by making an appropriate correction or addition or otherwise within twenty-one (21) calendar days of being informed by the complainant or a CIC.

A CIC shall pay compensation to the complainant if the CIC has failed to resolve the complaint within thirty (30) calendar days of being informed by the complainant or a CI, despite Ramaiah Capital having furnished the updated credit information to the CIC within twenty-one (21) calendar days of being informed by the complainant or the CIC.

The complainant shall be advised by Ramaiah Capital / CIC of the action taken on the complaint in all cases, including the cases where the complaint has been rejected. In cases of rejection, the reasons for rejection shall also be provided by Ramaiah Capital and CIC.

The date of the resolution of the grievance shall be the date when the rectified Credit Information Report (CIR) has been sent by the CIC or Ramaiah Capital to the postal address or email ID provided by the complainant.

Ramaiah Capital shall make appropriate provision in their complaint submission format (both online and offline) for enabling the complainant to submit the contact details, email ID, and bank account details/ Unified Payment Interface (UPI) ID for crediting the compensation amount. The onus of providing accurate details will lie with the complainant and Ramaiah Capital / CICs will not be held responsible for any incorrect information provided by the complainant.

The compensation amount shall be credited to the bank account of the complainant within five (5) working days of the resolution of the complaint.

The complainant can approach RBI Ombudsman, under the Reserve Bank - Integrated Ombudsman Scheme, 2021, in case of wrongful denial of compensation by Ramaiah Capital or CICs.

Non-Maintainability:

The compensation framework shall not be applicable in following cases :

1. Case of disputes arising amongst, CICs, CIs, borrowers, and clients on matters relating to the business of credit information and for which no remedy has been provided under CICRA,

2. Complaints pertaining to disputes/ grievances regarding the computation of the credit score/ credit score model.

3. Complaints that have been decided by or are already pending in other fora such as Consumer Disputes Redressal Commission, Courts, Tribunals, etc.

8. Loan Agreement

Customer on request shall be furnished with a copy of the loan agreement either physically or electronically along with a copy each of all enclosures quoted in the loan agreement at the time of sanction / disbursement of loans.

In case of receipt of request from the borrower for transfer of borrowal account, the consent or otherwise i.e. objection if any shall be conveyed within 15 days from the date of receipt of request. Such transfer shall be as per transparent contractual terms in consonance with law.

9.Recovery Process

The staff  shall be trained in proper etiquette for recovery process.

Company shall not resort to undue harassment viz; persistently bothering the borrowers at odd hours, use muscle power for recovery of loans etc.

On repayment of full dues the securities shall be released  subject to any legitimate right or lies or any other claim. Before exercising such right of set off borrower shall be informed about remaining claims and conditions under which company is entitled to retain the securities till relevant claim is settled/paid.

The company shall refrain from interference in the affairs of the borrower except as provided in the terms and conditions unless information not earlier disclosed in noticed by the company.

The details of Persons/ Agencies engaged as recovery agents for Ramaiah Capital shall be intimated to the Customers

10.Mechanism for complaints

Customer can lodge his / her grievance through any of the following channels:

Complaint in Person: A customer can lodge a complaint in person during working hours at any of the companies office/branch or with the designated officer.

Complaints through post / mail / email: Customers can also submit their grievances by post at the following address or e mail  by giving full details of the complainant and giving specific instances of the cause of complaint.

Addressed to:

Grievance Redressal Officer,

M/s Ramaiah Capital Private Limited,

No 4/A, “Reshma”,80 feet Road,RMV 2^nd Stage,Ashwathnagar,,Bangalore 560094, E mail: complaints@ramaiahcapital.com

11.Recording and tracking of Complaints

All the complaints received is recorded and tracked for end-to-end resolution. Complaint MIS is shared to the management on monthly basis for monitoring, supervision and quality control.

12.Resolution of Complaints

Any complaint through e-mail / letters / in person shall be acknowledged promptly after receipt.

The Complaints shall be registered in the Customer Complaints Register (CCR) maintained electronically and / or physically, and shall include full details of the complainant and the complaint.

The company shall appoint a designated official as its Grievance Redressal Officer (‘GRO’). The GRO will take steps to redress the grievances with care and diligence, normally within the period of 15 working days from the date of receipt of the complaints.

If the complainant is not satisfied with the reply / action / resolution given by Grievance Redressal Officer (GRO) he / she may directly approach the Chief Executive Officer (CEO), for further action on the same.

The notice indicating following will be prominently displayed in all Branches and offices of the Company.

1. The name and contact details (Telephone / Mobile nos. as also email address) of the Grievance Redressal Officer who can be approached by the public for resolution of complaints against the Company.

2. If the complaint / dispute is not redressed within a period of one month, the customer may appeal to the Officer-in-Charge of the Regional Office of Department of Non-Banking Supervision of the Reserve Bank of India (with complete contact details), under whose jurisdiction the registered office of the applicable NBFC falls.

The Grievance Redressal Officer shall be the Nodal officer for representing the Company under the Ombudsman Scheme.

 Anonymous and pseudonymous complaints will not be entertained.

13. Internal Machineries to handle Customer complaints / grievance

The Company will designate a Grievance Redressal Officer (GRO) who shall have  the   responsibilities of ensuring early resolution of complaints.

The Grievance redressal Officer shall be the point of contact for the customers. He will be responsible to receive the complaint of customers by whatever means, i.e. in person, post, mail etc.

GRO will provide an acknowledgment for the complaint received from the customer within 3 working days of the receipt, and also make necessary entries in the Customer complaints Register (CCR) which shall include full details of the complainant (name, address, and contact details), date of receipt, fact of the complaint, category of complaint etc.

GRO will first examine the nature of the Complaint and initiate necessary action to address the complaint to the satisfaction of the complainant.  He / She will also ensure to record the action initiated or taken in the CCR along with the status of the complaint- resolved / unresolved or escalated to next level, as the case may be.  GRO will circulate the monthly Action Taken Report on all the complaints received, within 7 working days of the next month to the Chief Executive Officer.

14.Time Frame

The Complaints received will be analysed from all possible angles. All efforts will be made to resolve each complaint received generally within the stipulated time as per the following escalation matrix:

There may be some complaints which require deeper analysis from all possible angles which may cause delayed resolution of the complaint. In such cases, the company will try to resolve the grievances at the earliest depending on the nature of the case. Such delay in addressing the complaint beyond the prescribed time limit shall be conveyed to the complainant along with reasons for the same.

If the resolution of the complaint is delayed beyond 30 days of receipt, or the complainant is not satisfied with the reasons of delay conveyed to him / her, he / she may appeal to the Ombudsman at Reserve Bank Of India.

Centralised Receipt and Processing Cell

Reser a Bank of India, 4^th Floor,Sector 17

Central Vista,Chandigarh - 160017

Chief General Manager & RBI ombudsman

Reserve Bank of India

10/3/8, Nrupathunga Road

Bengaluru -560 001

STD Code: 080 Tel. No. 22277660/22180221 Email: crpc@rbi.org.in

15. Reporting to Board of Directors