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.