Recovery Policy
1. Purpose
This policy outlines the framework for recovering dues from borrowers in a fair, transparent, and legally compliant manner while preserving the dignity and rights of the borrower.
2. Regulatory Framework
This policy is framed in accordance with:
- RBI Master Directions for NBFCs
- RBI Digital Lending Guidelines (2022 & 2023)
- Consumer Protection Act, 2019
- Indian Contract Act, 1872
- The Code of Civil Procedure, 1908
3. Principles of Recovery
- Recoveries shall be carried out in a dignified and non-coercive manner.
- Borrower communication shall be clear, respectful, and professional.
- Recovery efforts shall be well-documented and traceable.
4. Pre-Delinquency Measures
- Automated reminders: SMS, email, and app notifications before due date.
- Pre-due-date call: Friendly reminder by recovery agent (if needed).
- Customer Support Availability: Borrowers may contact support for clarification or payment assistance.
5. Post-Due Recovery Process
Day 1–5 (Early Bucket)
- Daily SMS and call reminders.
- Offer of flexible repayment, if requested.
- No penalties unless past 5 days.
Day 6–15 (Late Bucket)
- Flat penalty (e.g., 10% of principal) applied as per loan terms.
- Escalation to internal recovery team.
- Reminder of legal consequences and impact on credit score.
Day 16–30 (Critical Bucket)
- Final demand notice served via email and WhatsApp.
- Loan may be marked as NPA.
- Option of One-Time Settlement (OTS) if borrower shows intent.
- Civil/legal recovery process initiated if borrower is non-responsive.
6. One-Time Settlement (OTS) Guidelines
- Minimum recovery must cover full principal amount.
- Settlement must be approved by senior recovery manager.
- Settled loans marked as “Settled” with appropriate credit bureau reporting.
7. Legal Recovery Process
- Notice under Indian Contract Act (default of contractual obligation).
- Civil Suit for Recovery through Small Causes Court or Civil Court.
- Arbitration (if clause included in agreement).
- Cheque bounce cases under Section 138, if applicable.
8. Recovery Agent Conduct
All recovery agents must:
- Be trained in soft skills and RBI's Fair Practice Code.
- Carry valid ID and authorization letter.
- Make calls only between 8:00 AM and 7:00 PM.
- Avoid public shaming, coercion, or threatening behavior.
9. Record-Keeping & Audit
- All recovery communications must be digitally recorded and logged.
- Regular internal audits of recovery activity.
- Grievance redressal mechanism for borrower complaints.
10. Grievance Redressal
Borrowers may escalate disputes to the Grievance Officer via email or helpline. All complaints will be resolved within 7 working days.