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CODE OF CONDUCT
This has reference to RBI Circular No. 2012-13/416/DNBS. CC. PD No. 320 /03.10.01/2012-13 dated 18th February, 2013, wherein the Reserve Bank of India (RBI) has revised the guidelines on Fair Practices Code for NBFCs to implement the same.
The Fair Practices Code, as mentioned herein below, is in conformity with these Guidelines on Fair Practices Code for NBFCs as contained in the aforesaid RBI Circular. This sets minimum Fair Practice standards for the Company to follow when dealing with customers. It provides information to customers and explains how the Company is expected to deal with them on a day to day basis. Capital Trust will ensure that the implementation of the FPC is the responsibility of the entire organization.
This Fair Practice Code applies to all Loans, guarantees and other products in the nature of financial assets irrespective of whether the same is provided physically, over the phone, on the internet or by any method whatsoever, existing or futuristic.
Objectives of the Code
The code has been developed with an objective of:
♦ Ensuring fair and reasonable practices in all dealings with our customers
♦ Assisting customers in understanding how our financial products and services work and taking informed decisions
♦ Ensuring our products and services meet relevant laws and regulations as applicable
♦ Ensuring our dealings with its customers rest on ethical principles of honesty, integrity and transparency
Applications for Loans and their processing
Before offering any kind of fund based or non fund based non- banking facility Capital Trust will assess the ability of customers (prospective borrower) to repay. The Application Form for each of the products offered by the Company is different depending upon the requirement of each product and will include all information that is required to be submitted by the Borrower. Loan application forms issued to prospective customers includes necessary information, which affects the interest of the borrower, so that a meaningful comparison with the terms and conditions offered by other NBFCs can be made. Loan application form also clearly indicates documents required to be submitted along with the application form. The company would inform the Borrower about its decision within reasonable period of time from the date of receipt of all the required information in full. The Company will not discriminate loan applications based on grounds of sex, caste and religion.
Loan Appraisal and Terms / Conditions
The Company shall convey in writing to the borrower in the agreement itself, the amount of loan approved along with the terms and conditions, including the rate of interest and method of application thereof. Additionally, Penal Interest on late or non repayment is clearly highlighted in the loan agreement. The acceptance of the terms and conditions communicated by the borrower shall be preserved by the company.
Disbursement of Loans including changes in Terms and Conditions
The Company shall give notice to all its borrowers of any change in the terms and conditions – including disbursement schedule, interest rates, service charges, prepayment charges etc. The Company shall also ensure that changes in interest rates and charges are effected only prospectively. The loan agreement shall contain a specific clause to this effect. The Company shall release all securities on repayment of its full 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 its borrowers.
Regulation of Interest rate charged by the Company
The Company has laid down appropriate internal principles and procedure in determining interest rates, processing fees and other charges. The Company has adopted an interest rate model taking into account relevant factors such as, cost of funds, margin and risk premium, etc. and determine the rate of interest to be charged for loans and advances.
Responsibility of Board of Directors
The Board of Directors of the company shall lay down the appropriate grievance redressal mechanism within the organization to ensure that all disputes arising out of the decisions of the company’s functionaries are heard and disposed of at least at the next higher level. The Board of Directors shall also provide for periodical review of the compliance of the Fair Practices Code and the functioning of the grievances redressal mechanism at various levels of management.
The Company will refrain from interference in the affairs of the customer except for the purposes provided for in the terms and conditions of the loan agreement (unless new information, not earlier disclosed by the customer, has come to the notice of the Company). In the matter of recovery of loans, Capital Trust shall resort only to remedies which are legally and legitimately available to it and shall avoid using recovery measures during odd hours of the day.
Grievance Redressal Mechanism
Customers who wish to provide feedback or send in their complaint may use the following channels between 9:00 am and 6:00 pm from Monday to Saturday (except on national holidays).
♦ Call on +91 9999074312
♦ Email us at email@example.com
♦ Write to us at the below mentioned address:
Capital Trust Limited
366 Sultanpur, MG Road, New Delhi IN 110030
In case the complaint is not resolved within the given time or if he/she is not satisfied with the solution provided by the company, the customer can approach the Complaints Redressal Officer. Name and details of Compliant Redressal Officer is as follows:
Mr. Nitesh Verma
Tel. No: 9999074312
Email Id: firstname.lastname@example.org
If the complaint/dispute is not redressed within a period of one month, the customer may appeal to Officer-in-Charge of the Regional Office of Department of Non-Banking Supervision of RBI under whose jurisdiction the Registered Office of the Capital Trust falls.
The details of DNBS is as given below
Dy. General Manager,
Department of Non-Banking Supervision,
Reserve Bank of India,
6, Sansad Marg
New Delhi – 110 001
Tel. No.: +91-79-2754 0581
Email id: email@example.com
The various commitments outlined and made by Capital Trust are applicable under the normal operating environment. In the event of Force Majeure, Capital Trust will not be able to fulfil the commitments under the Fair Practices Code to the entire satisfaction of the customer/s, the other stake holders, and the public in general.