ADOPTED BY THE BOARD OF DIRECTORS ON 22nd OCTOBER 2024

1. PREAMBLE:
In accordance with Chapter VII Fair Practices Code of the Master Direction – Reserve Bank of India (Non- Banking Financial Company – Scale Based Regulation) Directions, 2023 dated October 19, 2023 issued by the RBI (as
amended from time to time) (“RBI Master Directions”), Non-Banking Financial Companies (“NBFCs”) having customer interface are required to adopt the
guidelines on Fair Practices Code (‘’FPC’’) prescribed in the RBI Master Directions. Regency Fincorp Limited (“RFL” or “the Company”), being a NBFC having customer interface, has formulated and adopted this Fair Practice Code (“FPC”)
for the lending business in accordance with Chapter VII (Fair Practices Code) of the RBI Master Directions. The FPC also seeks to incorporate various disclosure requirements prescribed by the RBI vide its ‘Guidelines on Digital Lending’ (“Digital
Lending Guidelines”) dated September 02, 2022, as amended from time to time and as applicable to the Company’s lending business.

2. PURPOSE AND ITS APPLICABILITY:

The purpose of FPC is mentioned belowa. To promote good & fair practices and to ensure transparency in dealing with
customers;
b. To promote a fair relationship between the customer and Company;
c. To ensure reasonableness and transparency in disclosure of penal charges;
d. To ensure compliance with legal norms in matters relating to recovery of
advances;
e. To strengthen mechanisms for redressal of customer grievances; This FPC shall apply across all aspects of the Company’s lending business operations including digital lending, marketing, loan origination, processing,
servicing, collection activities etc.

3. DEFINITIONS:

a. “Annual Percentage Rate” is the annual cost of credit to the borrower which includes interest rate and all other charges associated with the credit facility.
b. “Board” means Board of Directors of the Company.
c. “Complaint” means any representation made in writing or through other modes alleging deficiency in service on the part of the Company, and/ or
seeking relief.
d. “Company” means Regency Fincorp Limited (“RFL”)
e. "Director” means individual Director or any of the Directors on the Board of the
Company.
f. “FPC” means Fair Practices Code.
g. “Key Fact Statement” or “KFS” means a statement of key facts of a loan agreement, in simple and easier to understand language, provided to the borrower in a standardized format.

4. NORMS APPLICABLE TO ALL LOAN PRODUCTS OF THE COMPANY:

i. Applications for loans and their processing:

a. All communications to the borrower will be in the vernacular language or a language as understood by the borrower.
b. Loan application forms would include necessary information including but not restricted to processing fees/ charges, if any, non-refundable fees in case of rejection of loan proposal, pre-payment options etc. which affects the interest of
the borrower, so that a meaningful comparison with the terms and conditions offered by other NBFCs can be made and informed decision can be taken by the borrower. The loan application form would indicate the documents required to be submitted with the application form.
c. The Company will have a system of giving acknowledgement for receipt of all
loan applications. Time- frame within which loan applications will be processed would be indicated in the acknowledgement of such applications.
d. The Company, at loan application stage, shall indicate all the documents
required to be submitted along with the application form.

ii. Loan appraisal and terms/conditions:

a. The Company will ensure that there is proper assessment of credit application made by borrowers. The assessment would be in line with Company’s credit
policies and procedures.
b. The Company shall convey key terms and conditions of the proposed loan in writing in vernacular language or a language as is understood by the borrower, by means of Sanction letter and the same shall include:
 the amount of loan sanctioned along with the terms and conditions including annualized rate of interest;
 details of the annualized penal charges and the charges payable by the customers in relation to their loan account and method of application thereof;
 Penal charges for late repayment of loan would be expressly mentioned in
bold in the loan agreement;
 The customer shall be required to provide acceptance of terms and
conditions of the sanction if he/ she intends to avail the loan either in writing
to proceed further with the process of loan sanction and disbursement and
the Company shall keep the same in its record.
c. The Company will furnish a copy of the loan agreement preferably in the
vernacular language or a language as understood by the borrower along with a copy each of all enclosures quoted in the loan agreement to the borrowers 
at the time of sanction/disbursement of loans.
d. In case the Company cannot provide/sanction loan to the customer, it shall be communicated in writing to the customer.
e. Key Fact Statement (“KFS”):
 The Company shall provide a KFS to all retail, MSME term loans and digital
loans borrowers to help them take an informed view before executing the loan contract, as per the standardised format provided under the regulations. The KFS shall be provided to the borrowers in the language
preferred by the borrower.
 Contents of KFS shall be explained to the borrower and an acknowledgment shall be obtained that he/she has understood the same.
 The KFS shall be provided with a unique proposal number/application number and shall have a validity period of at least three working days or more 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 RFL shall be bound by the terms of the loan indicated in the KFS, if agreed to by the borrower during the validity period.
 The KFS shall include a computation sheet of APR and the amortization schedule of the loan over the loan tenor. APR will include all charges levied by the Company.
 Charges recovered from the borrowers by the Company on behalf of thirdparty
service providers on an actual basis, such as insurance charges, legal charges etc., shall also form part of the APR and shall be disclosed separately. In all cases wherever the Company is involved in recovering
such charges, the receipts and related documents shall be provided to the borrower for each payment, within a reasonable time.
 Any fees, charges, etc. which are not mentioned in the KFS, cannot be
charged by the Company to the borrower at any stage during the term of the loan, without explicit consent of the borrower.
 The KFS shall also be included as a summary box to be exhibited as part of the
loan agreement.

iii. Penal Charges in Loan Accounts:

a. The Company has adopted Board approved policy on Pricing Policy (which
includes Schedule of Charges for all products that encompassing penal charges
as well).
b. Penalty 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. The Company shall not capitalise penal charges.
c. The Company shall not introduce any additional component to the rate of interest.
d. The Company will keep the quantum of penal charges reasonable and commensurate with the non- compliance of material terms and conditions of loan contract without being discriminatory within a particular loan / product category.
e. 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 non-individual borrowers for similar non- compliance of material
terms and conditions.
f. The quantum and reason for penal charges shall be clearly disclosed by the Company in the loan agreement and most important terms & conditions / Key Fact Statement (KFS) as applicable, and on its website under Interest rates and
Service Charges.
g. Whenever reminders for 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.

iv. Disbursement of loans including changes in terms and conditions:

a. The Company will ensure timely disbursement of loans sanctioned in conformity with the terms and conditions governing such sanction. The Company will give
notice to the borrower in the vernacular language or in a language as understood by the borrower of any change in terms and conditions, including disbursement
schedule, interest rates, service charges, prepayment charges etc.
b. The Company will ensure that changes in interest rates and charges are affected
only prospectively. A suitable condition in this regard should be incorporated in
the loan agreement.
c. Decision to recall / accelerate payment or performance under the agreement will be in consonance with the loan agreement.
d. The Company will release all securities on repayment of all dues or on realization of the outstanding amount of loan subject to any legitimate right or lien for any
other claim the Company may have against borrower. If such right of set off is to be exercised, the borrower will be given notice about the same with full particulars
about the remaining claims and the conditions under which the Company is
entitled to retain the securities till the relevant claim is settled / paid.

5. Responsible Lending Conduct- Release of movable/immovable property documents on repayment/ settlement of personal loans:

a. The Company will release all the original movable / immovable property  days after full repayment/settlement of the loan account.
b. The borrower will be given the option of collecting the original movable/ immovable property documents either from the Company’s office where the loan
account was serviced or any other office of the Company where the documents are available, as per her/his preference.
c. Timeline and place of return of original movable/immovable property documents shall be mentioned in the loan sanction letters issued on or after the effective
date.
d. In case of contingent event of demise of the sole borrower or joint borrowers, the original movable/immovable property documents of the sole borrower or joint
borrower shall be returned to the legal heir(s) as per the duly approved procedure
as displayed on the website of the Company.

Compensation for delay in release of movable/immovable property documents:

a. In case of delay in releasing of original movable/immovable property documents or failing to file charge satisfaction form with relevant registry beyond 30 days after
full repayment/ settlement of loan, reasons for such delay shall be communicated to the borrower.
b. In case where the delay is attributable to the Company, compensation at the rate of Rs. 5,000 for each day of delay shall be provided to the borrower.
c. In case of loss/damage to original movable/immovable property documents,
either in part or in full, the Company shall assist the borrower in obtaining duplicate/certified copies of the movable/immovable property documents and shall bear the associated costs, in addition to paying compensation as indicated
at clause (b) above. In such cases, an additional 30 days timeline will be available to the Company to complete the procedure and delayed period penalty will be calculated after 60 days.

6. Reset of Floating Interest Rate on Equated Monthly Instalments (EMI) based Personal Loans:

a. In case of EMI based floating rate loans, the Company, at time of sanction will
take into account the repayment capacity of borrowers to ensure that adequate headroom/ margin is available for elongation of tenor and/ or increase in EMI, in
the scenario of possible increase in the interest rates during the tenor of the loan.
b. At the time of sanction, the Company shall clearly communicate to the borrowers about the possible impact of change in benchmark interest rate on the loan
leading to changes in EMI and/or tenor or both. Subsequently, any increase in the EMI/ tenor or both on account of the above shall be communicated to the
borrower immediately through appropriate channels.
c. The Company will ensure that the elongation of tenor in case of floating rate loan does not result in negative amortization.
d. At the time of reset of interest rates by the Company, the Company shall provide the option to the borrowers to switch over to a fixed rate. Such switch over from
Floating rate to fixed rate and vice versa shall be available to the borrower twice during the tenure of the loan viz once from floating to fixed and second from fixed to floating.
e. At the time of reset of interest rates, the Company shall provide the option to the borrowers to switch over to a fixed rate.
f. The borrowers will have a choice to opt for (i) enhancement in EMI or elongation
of tenor or for a combination of both options; and, (ii) to prepay, either in part or in full, at any point during the tenor of the loan.
g. All applicable charges for switching of loans from floating to fixed rate and any
other service charges/ administrative costs incidental to the exercise of the
above options to be disclosed in the sanction letter and also at the time of revision of such charges/ costs by the Company from time to time.
h. The Company will share / make accessible to the borrowers, through appropriate channels, a statement at the end of each quarter which will, enumerate the
principal and interest recovered till date, EMI amount, number of EMIs left and
annualized rate of interest / Annual Percentage Rate (APR) for the entire tenor of the loan. 

The Company will ensure that the statements are simple and easily understood by the borrower.

*Personal Loans- Personal loans refers to loans given to individuals and consist of (a)
**consumer credit, (b) education loan, (c) loans given for creation/ enhancement of immovable assets (e.g., housing, etc.), and (d) loans given for investment in financial
assets (shares, debentures, etc.)
**Consumer Credit- Consumer credit refers to the loans given to individuals, which
consists of (a) loans for consumer durables, (b) credit card receivables, (c) auto loans
(other than loans for commercial use), (d) personal loans secured by gold, gold
jewellery, immovable property, fixed deposits (including FCNR(B)), shares and bonds,
etc., (other than for business / commercial purposes), (e) personal loans to
professionals (excluding loans for business purposes), and (f) loans given for other consumptions purposes (e.g., social ceremonies, etc.). However, it excludes (a) education loans, (b) loans given for creation/ enhancement of immovable assets
(e.g., housing, etc.), (c) loans given for investment in financial assets (shares,
debentures, etc.), and (d) consumption loans given to farmers under Kisan Credit Card (“KCC”).

7. General:

a. The Company will not interfere in the affairs of the borrower except for the
purposes provided in the terms and conditions of the loan agreement (unless new information, not earlier disclosed by the borrower, has come to the notice of the
Company.)
b. In case of receipt of request from the borrower for transfer of borrower’s account,
the consent or otherwise i.e. objection of the Company, if any, will be conveyed within 21 days from the date of receipt of request. Such transfer shall be as per
transparent contractual terms in consonance with law.
c. In the matter of recovery of loans, consistent with its policy over the years, the
Company will not resort to undue harassment viz. persistently bothering the borrowers at odd hours, use of muscle power for recovery of loans etc. To avoid
rude behavior from the staff of the Company, the Company will ensure that the staff is adequately trained to deal with customers in an appropriate manner.
d. The Company shall not charge foreclosure charges/ pre-payment penalties on any floating rate term loan sanctioned for purposes other than business to
individual borrowers, with or without co-obligant(s).

8. Responsibility of Board of Directors:

a. The Company, with the approval of its Board of Directors, has laid down Policy on rievance Redressal Mechanism (“GRM”) within the organization. Such a mechanism ensures that all disputes arising out of the decisions of the Company’s
functionaries are heard and disposed-off at least at the next higher level.
b. The Board of Directors shall review the compliance of the Fair Practice Code
atleast on an annual basis post senior management review and recommendations, if any. Further, the functioning of the grievances redressal mechanism shall be performed quarterly and a consolidated report of the same
shall be reviewed by the senior management and then submitted to the Board.

9. Language and mode of communicating Fair Practice Code:

The Company, in accordance with the RBI Master Directions, has put in place the FPC in English language and in vernacular languages as understood by the borrowers. The FPC is also available on the website of the Company at
www.regencyficorp.co.in.

10. Regulation of Rate of Interest:

a. Pursuant to RBI Master Directions, the Board of Directors has duly adopted interest rate model and pricing policy. for determining the rate of interest to be charged on loans and advances, processing and other charges after taking into account
relevant factors such as, cost of funds, margin and risk premium, etc.
b. The rate of interest and the approach for gradations of risk and rationale for charging different rate of interest to different categories of borrowers shall be
disclosed to the borrower or customer in the application form and communicated explicitly in the sanction letter.
c. The rates of interest and the approach for gradation of risks shall also be made available on the web-site of the companies. The information published on the website or otherwise published should be updated whenever there is a change
in the rates of interest.
d. The rate of interest should be annualized rates so that the borrower is aware of the exact rates that would be charged to the account.

11. Repossession of vehicles financed:

The Company should include a built-in re-possession clause in the loan agreement with the borrower which must be legally enforceable.
To ensure transparency, the terms and conditions of the loan agreement should also contain provisions regarding:
(a) Notice period before taking possession;
(b) Circumstances under which the notice period can be waived;
(c) The procedure for taking possession of the security;
(d) A provision regarding final chance to be given to the borrower for repayment of loan before the sale/ auction of the property;
(e) The procedure for giving repossession to the borrower and;
(f) The procedure for sale / auction of the property.
A copy of such terms and conditions must be made available to the borrower.
The Company shall invariably furnish a copy of the loan agreement along with acopy each of all enclosures quoted in the loan agreement to all the borrowersat the time of sanction/ disbursement of loans, which forms a key component of
such contracts/ loan agreements.

12. Loan facilities to the physically/visually challenged by the Company:

The Company shall not discriminate in extending products and facilities including loan facilities to physically/visually challenged applicants on grounds of disability. All service delivery unit of the Company shall render all possible assistance to such
persons for availing of the various business facilities.

13. GENERAL:

a. The Company shall refrain from interference in the affairs of the borrower except
for the purposes provided in the terms and conditions of the loan agreement (unless information, not earlier disclosed by the borrower, has been noticed).
b. In case of receipt of request from the borrower for transfer of borrowed account, the consent or otherwise i.e. objection of the Company, if any, shall
be conveyed within 21 days from the date of receipt of request. Such transfer shall be as per transparent contractual terms in consonance with law.

14. ADDITIONAL NORMS FOR DIGITAL LENDING OR THE LOANS SOURCED OVER A DIGITAL LENDING PLATFORM:

i. Provisions for Loans Sourced by the Company over Digital Lending Platform/ Apps
(“DLAs”):
In case, the Company sources borrowers and/ or to recover dues over digital lending platform (irrespective of whether they lend through their own digital lending platform or through an outsourced lending platform), the Company shall
abide by the provisions of this FPC in letter and spirit and in the manner, it may be applicable to its business.
Further, the Company shall adhere to the following instructions in respect of digital lending:
a. Names of digital lending platforms engaged as agents shall be disclosed on
the website of the Company.
b. Digital lending platforms engaged as agents shall be directed to disclose upfront to the customer, the name of the Company on whose behalf they
are interacting with the customer.
c. Effective oversight and monitoring shall be ensured over the digital lending platforms engaged by the Company.
d. Sanction letter must be issued to borrower on the letter head of the
Company, immediately after sanction of loan and prior to execution of loan agreement. Further, a copy of loan agreement, along with all enclosures quoted therein must be furnished to all borrowers at the time of
sanction/disbursement of loans.
e. Adequate efforts shall be made towards creation of awareness about the
grievance redressal mechanism.
ii. Provisions to be followed by the Company with respect to Digital Lending Loans:
The Company shall comply with the provisions of Guidelines on Digital Lending dated 02, 2022 issued by RBI and Frequently Asked Questions (“FAQ”) on Digital
Lending issued by RBI on February 14, 2023 to the extent applicable (as amended from time to time).

15. Master Direction – Reserve Bank of India (Credit Information Reporting) Directions,2025:

The Company shall comply with the provisions of Master Direction – Reserve Bankof India (Credit Information Reporting) Directions, 2025 to the extent applicable (as amended from time to time).

16. Review of the Policy:

The FPC shall be amended or modified with approval of the Board. The FPC shall be reviewed by the Board on an annual basis. Consequent upon any
amendments in RBI Master Directions or any change in the position of the Company, necessary changes in this FPC shall be incorporated and approved by the Board.Notwithstanding anything contained in this FPC, in case of any contradiction of
the provision of this FPC with any existing legislations, rules, regulations, laws or
modification thereof or enactment of a new applicable law, the provisions under such law, legislation, rules, regulation or enactment shall prevail over this FPC.
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