Fair Practice Code

Background

Innofin Solutions Private Limited(hereinafter referred to as “LenDenClub”) is registered as a peer-to-peer lending non-banking financial company (“NBFC-P2P”) with the Reserve Bank of India (“RBI”).. LenDenClub operates as a web-based marketplace through its website and app (collectively, the “Platform”) to bring together investors who intend to lend (“Investors”) and individual Borrowers who intend to borrow virtually (“Borrowers”) in India. These fair practices code which is approved by the Board of Directors of LenDenClub is based on the broad guidelines prescribed by the RBI (“Code”).

Objective of the Code

This Code sets the minimum fair practice standards to be followed by all the employees and representatives of LenDenClub while dealing with the Borrowers and the Investors on the Platform. The Code also provides information to the Borrowers and the Investors on the Platform and details the manner in which LenDenClub and its employees and representatives are to deal with the Borrower and Investors on a day-to-day basis. The primary objectives of the Code are as follows:

Ensure fair practices while dealing with the Borrowers and Investors on the Platform.

Ensure that all the governing laws are complied with utmost integrity.

Provide greater transparency in all transactions and cost structures, thereby enabling customers to have a clear understanding of the products and services (including the terms and conditions of such products and services) offered by LenDenClub and make informed decisions.

Build the confidence of the Borrower and the Investor in LenDenClub’s Platform.

Ensure no violent methods are used for recovery options.

Communicate this code by uploading it on the official website, in office branches publicly and further email upon request.

Adequately train the employees of the LenDenClub on how to deal with the customers and further how to meet the minimum standards relating to grievance redressal and loan recovery as prescribed under the Master Directions – Non-Banking Financial Company – Peer to Peer Lending Platform (Reserve Bank) Directions, 2017 (P2P Master Guidelines).

Application of the Code

This Code shall apply to all the employees of LenDenClub and such other persons authorized to represent LenDenClub in respect of all categories of products and services offered by LenDenClub.

Declaration from Investor

In accordance with the P2P Master Guidelines, LenDenClub shall inform and obtain explicit declaration from the Investor stating that he/she has understood all the risks associated with the lending transactions and that P2P platform does not assure return of principal/payment of interest.

Applications for loans and their processing

LenDenClub shall ensure that all communication to the Borrowers on the Platform shall be in English as well as the vernacular language or a language as understood by the Borrower. For this purpose, LenDenClub shall obtain the Borrower’s language preference at the time of collecting the preliminary information of the Borrower on the Platform.

The loan application form and annexures shall include necessary information which affects the interest of the Borrower to enable the Borrower to compare similar terms and conditions offered by other NBFCs and take an informed decision. In addition to the loan application form, details regarding products and services offered by LenDenClub shall be specified on the Platform.

The loan application form shall also indicate the list of documents required to be submitted by the Borrower along with the application form which shall be acknowledged by LenDenClub by way of information displayed in the website/app. To the extent administratively practical, such acknowledgement shall provide the time frame within which LenDenClub will dispose the loan application.

Loan appraisal and terms/conditions

LenDenClub shall convey to the Borrower in writing, either in the vernacular language or a language as understood by the Borrower, by way of a sanction letter or otherwise, the amount of limit sanctioned along with all the terms and conditions including but not limited to the annualized rate of interest, method of application and interest chargeable for late repayment, if any.

At the time of sanction and/or disbursement of the loan amount, LenDenClub shall furnish a copy of loan agreement along with all enclosures quoted in the loan agreement to the Borrower and the Investors to the registered email address provided by the Borrower and the Investors.

Disbursement of loans including changes in terms and conditions

In the event of any change in the terms and conditions of the loan, (including disbursement schedule, interest rates, service charges, prepayment charges etc.) LenDenClub shall give notice to the Borrower in the vernacular language or language as understood by the Borrower. Such change shall be communicated to the Borrower on the registered email address provided by the Borrower in the loan application form. Any and all changes in the interest rates and charges shall be affected only prospectively.

LenDenClub shall ensure that any decision to recall and/or accelerate payment or performance shall at all times be in consonance with the terms and conditions of the loan agreement executed with the Borrower.

LenDenClub shall release all securities of the Borrower only on repayment of all dues by such Borrower, or on realization of the outstanding amount of the Borrower’s availed loan. If such right of set off is to be exercised, the Borrower will be given a notice about the same with full particulars about the remaining claims and conditions under which LenDenClub shall be entitled to retain the securities till the relevant claim is settled or paid by the Borrower.

LenDenClub shall issue a ‘no-objection certificate’ to the Borrower upon closure of loan within 15 (fifteen) working days from the completion of all related formalities.

General

LenDenClub shall merely facilitate the transactions contemplated on its Platform as per the terms and conditions of the loan agreement executed between LenDenClub, the Investors and the Borrowers.

In case of receipt of request from the Borrower for transfer of Borrower account, the consent or otherwise, i.e., objection of LenDenClub, if any, shall be conveyed to such Borrower within 21 (twenty-one) days from the date of receipt of the Borrower’s request. Such transfer will be as per transparent contractual terms in consonance with all the applicable laws.

In the matter of recovery of outstanding dues of its Borrower, LenDenClub shall not resort to undue harassment, that is, persistently bothering the Borrowers at odd/late hours or behaving rudely or aggressively, or use of muscle power for recovery of loans etc. LenDenClub shall take necessary steps to ensure that its employees and other representatives are adequately trained to deal with the Borrowers in an appropriate manner.

Interest Rate and Other Charges

LenDenClub shall devise appropriate internal principles and procedures for determining interest rates and processing and other relevant charges and inform the same to the Borrowers and the Investors on a case-to-case basis.

Privacy and Confidentiality

All personal information of the customers shall be treated as private and ial and shall be led by the following norms and principles. All the private information disclosed by customers or otherwise, will not be revealed to anyone including our affiliates except in the following scenarios:

We shall not reveal information or data relating to Borrower accounts, whether provided by the customers or otherwise, to anyone, including our affiliates other than in the following exceptional cases:

If the LenDenClub is required to provide the information to any statutory or regulatory body or bodies or otherwise required under any law;

If arising out of a duty towards the public to reveal the information;

If our interests require us to give the information (for example, to prevent fraud) but it shall not be used as a reason for giving information about the Borrower or Borrower’s accounts (including customer name & address) to anyone else for marketing purposes;

If the Borrower has authorized LenDenClub to provide such information to its group / associate/ entities or companies or any such person/ entity as specifically agreed upon;

If we are asked to give a reference about a Borrower, we shall obtain his / her written permission before giving it;

The Borrower shall be informed the extent of his / her rights under the existing legal framework for accessing the personal records that we hold about him / her;

We shall not use Borrower’s personal information for marketing purposes by anyone including ourselves unless the customer specifically authorizes us to do so.

Grievance Redressal Mechanism

LenDenClub acknowledges the importance of efficient service to the Borrowers and the Investors on the Platform. At LenDenClub satisfaction of the Borrowers and the Investors is the prime focus. For this reason, LenDenClub has established a grievance redressal mechanism. This system will ensure that the redressal sought is just and fair and is in accordance with the applicable laws.
The board of directors of LenDenClub shall periodically review the compliance of this Code and the functioning of the grievance’s redressal mechanism at various levels of management.
LenDenClub shall ensure that following details are displayed prominently in its offices including branch offices and on the Platform:

Procedure for receiving and addressing complaints and suggestions.

Name, address, contact number and e-mail address of grievance redressal officer, who can be approached for redressal of the complaint, along with the details of the officer-in-charge of the Regional Office of Department of Non-Banking Supervision of RBI under whose jurisdiction the registered office of LenDenClub falls.

Time frame for resolving complaints by the Borrower or the Investors together with escalation matrix for escalating the complaint, in case the complaint is not resolved to the satisfaction of the Borrower or Investor within the specified time period. In any event, that Borrower or the Investor may file an appeal with the officer-in-charge of the Regional Office of India, Department of Non-Banking Supervision of RBI under whose jurisdiction the registered office of LenDenClub falls if the complaint/dispute is not redressed within a period of 1 (one) month.

Please refer to Grievance Redressal for details

Changes to the Code
Any amendments or change in this Code shall be uploaded on the Platform from time to time.