How Western Fintrade ensures fairness, transparency and ethical conduct across every step of the lending journey — applications, sanction, disbursement, servicing and recovery.
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