About this policy. (Approved by the Board of Directors)

1. OBJECTIVE

This Fair Practices Code (“FPC”) has been adopted by Western Fintrade Private Limited (“the Company”) with the following objectives:

  • a. To promote fair, transparent, ethical, and professional practices in all lending operations.
  • b. To ensure that borrowers clearly understand the terms and conditions of financial products offered by the Company.
  • c. To establish confidence and trust in dealings between the Company and its customers.
  • d. To comply with applicable directions, circulars, and guidelines issued by the Reserve Bank of India for NBFCs.
  • e. To establish an effective grievance redressal mechanism.

2. APPLICATIONS FOR LOANS AND THEIR PROCESSING

2.1 Loan Applications

All communications with borrowers shall be in English, Hindi, or any other language understood by the borrower.

The loan application form shall contain:

  • Loan product details
  • Eligibility criteria
  • Documentation requirements
  • Applicable charges and fees
  • Interest rate methodology
  • Security / collateral requirements

2.2 Acknowledgment

Upon receipt of a complete loan application, the Company shall issue an acknowledgment mentioning:

  • Application reference number
  • Date of receipt
  • Indicative processing timeline

2.3 Documentation Required

The borrower may be required to submit:

  • Individual Borrowers:
  • Aadhaar Card
  • PAN Card
  • Passport (where applicable)
  • Admission letter / university offer letter (for education finance)
  • Income proof / bank statements
  • Credit bureau consent
  • Business Borrowers:
  • PAN
  • GST Registration
  • Incorporation documents
  • Board / Partner Resolution
  • Bank statements
  • Financial statements
  • Security documents

3. LOAN APPRAISAL AND SANCTION

3.1 Credit Assessment

The Company shall evaluate applications based on:

  • Credit bureau reports
  • Repayment capacity
  • Banking behavior
  • Income / cash flow assessment
  • Business financials
  • Security cover (where applicable)
  • Fraud and AML screening

3.2 Sanction / Rejection

The Company shall communicate its decision within a reasonable period after receipt of complete documentation.

If approved, the borrower shall receive a written sanction letter containing:

  • Loan amount
  • Tenure
  • Annualized rate of interest
  • Processing fees and other charges
  • Security details
  • Repayment schedule
  • Penal charges (if any)
  • Prepayment conditions
  • Other material terms
  • If declined, the borrower may be informed appropriately.

4. LOAN AGREEMENT AND DISCLOSURES

Before disbursement, the Company shall provide:

  • Loan Agreement
  • Schedule of charges
  • Repayment schedule
  • Security documentation (if applicable)
  • Borrowers shall receive copies of executed loan documents.

5. DISBURSEMENT OF LOANS

Disbursement shall be subject to:

  • Execution of loan documentation
  • Completion of KYC and compliance checks
  • Creation/perfection of security (where applicable)
  • Verification of end use
  • Disbursement may be made:
  • To borrower account
  • To university/institution
  • To designated escrow/virtual account
  • To vendor/service provider as per sanctioned purpose

6. CHANGES IN TERMS & CONDITIONS

The Company shall notify borrowers of any change relating to:

  • Interest rates
  • Charges
  • Repayment schedule
  • Security requirements
  • Such changes shall be implemented prospectively.

7. RECOVERY PRACTICES

The Company follows ethical recovery practices.

The Company and its authorized representatives shall not:

  • Use harassment or intimidation
  • Contact borrowers at inappropriate hours
  • Use abusive language
  • Use coercive recovery tactics
  • All recovery shall be in accordance with law and contractual rights.

8. SECURITY RELEASE

Upon full repayment of all dues, the Company shall release all securities, subject to:

  • No outstanding dues
  • No lawful lien or set-off rights

9. INTEREST RATE POLICY

The Board of Directors shall approve the interest rate model based on:

  • Cost of funds
  • Credit risk
  • Operating costs
  • Security coverage
  • Product segment
  • The borrower shall be informed of:
  • Annualized interest rate
  • Method of computation
  • Penal charges (if any)

10. DIGITAL / ESCROW / VIRTUAL ACCOUNT TRANSACTIONS

For student finance, cross-border remittances, escrow, or virtual account structures:

  • Funds shall move only through authorized banking channels.
  • Virtual accounts may be created solely for transaction tracking and reconciliation.
  • Escrow accounts may be subject to lien or restricted operational rights.
  • Refunds/rejections shall be routed only through the original source account, subject to applicable FEMA, AML, and banking regulations.

11. CUSTOMER CONFIDENTIALITY

Customer information shall not be disclosed except:

  • With customer consent
  • Under statutory or regulatory requirement
  • To credit bureaus, lenders, banks, or authorized service providers

12. GRIEVANCE REDRESSAL MECHANISM

In case of complaints, customers may contact:

Grievance Redressal Officer

Compliance OfficerWestern Fintrade Private LimitedHSR Layout, Sector-6, L-148, 5th Main Road,Bengaluru – 560102

Email: compliance@westernfintrade.com (to be updated)Contact: +91-9606919599

If the complaint is not resolved within 30 days, the customer may approach the appropriate office of Reserve Bank of India.

13. REVIEW OF POLICY

This Fair Practices Code shall be reviewed annually or earlier if required by regulatory changes.

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