Fair Practices Code

I. Tycoon Credit & Portfolios Limited, operating under the brand name True Rupee (hereinafter referred to as the “Company”), is registered with the Reserve Bank of India (RBI) as a Non-Banking Financial Company (NBFC), classified as a Non-Systemically Important, Non-Deposit Taking NBFC under the Scale Based Regulations, 2023. The Company functions as a digital lender, offering personal loans and other credit facilities to individuals and entities through the True Rupee digital lending platform.

 

This Fair Practices Code (“FPC” or “Code”) has been drawn up by the Company in line with the following regulatory frameworks:

1. Master Direction – Reserve Bank of India (Non-Banking Financial Company – Scale Based Regulation) Directions, 2023, as amended from time to time.
2. RBI Master Circular on Fair Practices Code for NBFCs dated July 01, 2015.
3. Guidelines on Digital Lending issued by the Reserve Bank of India dated September 02, 2022, as amended from time to time.
4. All other applicable circulars, directions, and notifications issued by the Reserve Bank of India from time to time.

Any subsequent amendment, clarification, or direction issued by the RBI will be deemed to stand incorporated into this Code to the extent applicable. In the event of any conflict between this Code and applicable law or regulatory direction, the applicable law or regulatory direction will prevail.

II.  OBJECTIVES

This Fair Practices Code has been drafted with the following objectives:

1. Ethical and Transparent Practices: To institutionalize fair, professional, and responsible conduct in all customer interactions across the entire lending lifecycle, from sourcing and processing to disbursement, servicing, and recovery.
2. Transparency in Disclosure: To ensure that customers receive clear, comprehensible, and adequate information regarding loan terms, applicable charges, interest rates, repayment obligations, and grievance redressal procedures, enabling informed financial decisions.
3. Fair and Respectful Customer Relationships: To build and maintain a respectful, non-discriminatory, and trust-based relationship with all borrowers, underpinned by principles of equity, integrity, and dignity.
4. Financial Literacy and Borrower Awareness: To educate and inform existing and prospective borrowers about the terms and implications of borrowing, their rights and responsibilities, and the mechanisms available for redressal of grievances.
5. Regulatory Compliance: To ensure full and ongoing compliance with all applicable laws, regulations, and directions issued by the Reserve Bank of India and other competent authorities.
   
   
   III.  SCOPE AND APPLICABILITY
   
   

This Code/Policy will apply uniformly across all products and services offered by Tycoon Credit & Portfolios Limited. through the True Rupee platform, including all credit facilities existing as of the date of this Code and those introduced in the future. It will govern all customer interactions conducted:

1. Through True Rupee digital lending platforms and mobile applications.
2. Via telephonic communications, email correspondence, SMS, or any other electronic or digital channel.
3. Through any authorized field representatives or customer service personnel of the Company.

This Code will apply to all categories of borrowers, including prospective borrowers who inquire about the Company’s products, applicants whose loan applications are under process or have been declined, and all existing borrowers at every stage of the loan lifecycle.

IV.  COMMITMENTS

The Company is committed to maintaining the highest standards of integrity, fairness, and professionalism. The following principles govern all its dealings with customers

1. Fairness and Integrity

All business dealings will be conducted with fairness, honesty, and integrity. All customer interactions, whether digital, telephonic, or otherwise, will be carried out in a professional, non-discriminatory, and transparent manner.

1. Regulatory Compliance

The Company will fully comply with all applicable laws, rules, regulations, and directions issued by the Reserve Bank of India and other competent authorities. Every product and service offered will conform to the standards prescribed under this Code and applicable regulatory guidelines.

1. Truthful and Responsible Advertising

All advertising, marketing, and promotional materials issued by or on behalf of the Company will be factual, clear, and free of any misleading claims or ambiguous terms. The Company will not make exaggerated claims regarding loan amounts, processing times, or approval certainty.

1. Transparent Disclosure of Loan Terms

The Company will maintain transparency in all communications relating to its products and services. The following key terms will be clearly disclosed in all loan documentation and on the Company’s official platform:

• Annualized Rate of Interest (ROI) and Annual Percentage Rate (APR).
• Nature of the interest rate (fixed or floating).
• Loan tenure and repayment schedule.
• Frequency, due dates, and number of instalments, including the breakup between principal and interest.
• Processing fees, documentation charges, insurance charges, and any other applicable fees.
• Penal charges for late repayment or default, clearly highlighted in bold in the loan agreement.
• Foreclosure and prepayment terms and applicable charges, if any.
• Any other incidental or service-related fees.

1. Data Privacy and Confidentiality

All personal, financial, and transactional information of borrowers will be collected, stored, processed, and disclosed in strict accordance with applicable laws, including the Information Technology Act, 2000, and the RBI’s digital lending guidelines. Customer information will not be shared with any third party without the customer’s express prior consent, except where required by law or regulatory directive. The term “third party” for this purpose excludes law enforcement agencies, credit information companies, the RBI, and other regulatory or statutory bodies.

1. Staff Training

All customer-facing staff, including personnel engaged in sales, collections, and customer support, will undergo periodic training to ensure that their interactions with borrowers align with the ethical standards, service expectations, and regulatory requirements laid down in this Code.

1. Public Availability of This Code

This Fair Practices Code will be made available on the Company’s official website and on the True Rupee platform. A copy will be provided to any customer upon request, free of charge, in electronic or physical form.


V.  LOAN APPLICATION AND PROCESSING

1. Language of Communication: All communications with borrowers, including loan application forms, sanction letters, Key Fact Statements (KFS), and loan agreements, will be provided in English or Hindi as required under RBI guidelines. Where a borrower explicitly requests communication in another language, the Company will accommodate that preference in all subsequent communications with that borrower.
2. Loan Application Form Disclosures: The loan application form will be designed to disclose all material information affecting the interest of the borrower, including the indicative range of annualized rate of interest applicable to the relevant loan product, the method of interest computation, prepayment options, and all applicable fees and charges. This enables the borrower to compare the Company’s offerings with those of other financial institutions and make an informed decision.
3. Document Requirements: The loan application process will be accompanied by a clear checklist of documents required for verification, underwriting, and KYC and AML compliance. These will include proof of identity, address, income, and any other documents required under applicable regulatory norms.
4. Acknowledgement of Applications: The Company will provide an acknowledgement for every loan application received, along with the indicative timeframe within which the application will be disposed of. Loan applications will ordinarily be disposed of within 60 (sixty) days of receipt.
5. Communication of Application Status: The Company will keep the borrower informed of the status of their loan application as and when required. At the time of accepting an application, the Company will explain the entire loan process from origination through to sanction and disbursement, including the expected timelines for each stage.
   
   VI. LOAN APPRAISAL AND TERMS AND CONDITIONS
   
   

Credit Evaluation: The Company will scrutinize all information and documentation submitted by the applicant. Where additional information is required for credit evaluation or risk profiling, the Company will promptly communicate this requirement to the applicant. Each application will be assessed on the basis of the applicant’s creditworthiness, credit history, income, repayment capacity, and other relevant parameters in line with the Company’s internal credit policy.

Sanction Letter and Key Fact Statement: Upon sanction of a loan, the Company will convey the following in writing to the borrower, by means of a sanction letter and Key Fact Statement (KFS), before execution of the loan agreement:

• The sanctioned loan amount.
• The annualized rate of interest and the Annual Percentage Rate (APR).
• The loan tenure and repayment amount.
• The method of interest computation and application.
• The exact due dates for repayment and the breakup between principal and interest.
• The nature of the interest rate (fixed or floating) and, in the case of floating rate loans, the benchmark rate and the reset mechanism.
• Details of all fees, charges, and taxes applicable to the loan.
• Penal charges for late repayment or default, expressed as a percentage per month or per annum, clearly highlighted in bold.
• Foreclosure and prepayment terms and any applicable conditions.
• The cooling-off period is available to the borrower under the digital lending framework.

The borrower’s written or digitally recorded acceptance of the sanction terms and conditions will be obtained and retained on record by the Company.

Copy of Loan Agreement

The Company will provide every borrower, at the time of sanction or disbursement, a copy of the loan agreement executed along with copies of all enclosures and documents referenced therein. These documents may be shared digitally by email or in electronic format, or in physical form, as per the borrower’s preference and applicable regulatory requirements.

Rejection of Loan Applications

Where the Company is unable to sanction a loan to an applicant, it will endeavor to communicate the reasons for rejection, to the extent permissible under applicable law and internal credit policy.


VII.  PENAL CHARGES

Any penalty imposed on account of the borrower’s non-compliance with the material terms and conditions of the loan agreement will be levied strictly as a “penal charge” and not as “penal interest”. Such penal charges will not be added to the principal outstanding or to the effective rate of interest. There will be no capitalization of penal charges, meaning no further interest will be levied on unpaid penal charges.

The quantum of penal charges will be reasonable and commensurate with the severity of non-compliance, without being discriminatory within a particular loan or product category. Penal charges applicable to individual borrowers for purposes other than business will not exceed those applicable to non-individual borrowers for similar non-compliance.

The quantum and basis of all penal charges will be clearly disclosed in the loan agreement, the KFS, and on the Company’s official website. Whenever a reminder is sent to a borrower for non-compliance, the applicable penal charges will also be communicated. Any instance of levy of penal charges, together with the reasons therefor, will be communicated to the borrower.

 

VIII.  DISBURSEMENT OF LOANS AND CHANGES IN TERMS AND CONDITIONS

Disbursement of the loan will be made in line with the disbursement schedule and terms agreed with the borrower as per the loan agreement and sanction letter.

The Company will give prior written notice to the borrower, in English, of any proposed change in the terms and conditions of the loan, including changes to the disbursement schedule, rate of interest, service charges, or prepayment conditions. All changes in interest rates and charges will take effect only prospectively. A suitable condition for this effect will be incorporated in the loan agreement.

Any decision by the Company to recall a loan, accelerate repayment, or demand early performance under the loan agreement will be taken strictly in line with the provisions of the loan documentation. Adequate prior notice will be given to the borrower before any such action is initiated.


IX.  DIGITAL LENDING NORMS

The Company operates exclusively through the True Rupee digital lending platform. Accordingly, the following norms applicable to digital lending will be complied with at all times:

Key Fact Statement

A Key Fact Statement (KFS) will be provided to every borrower on execution of the loan agreement. The KFS will be in a standardized format as prescribed by the RBI and will contain, at a minimum:

• The Annual Percentage Rate (APR).
• The loan amount, tenure and repayment schedule.
• All fees, charges, and taxes applicable to the loan.
• The details of the Grievance Redressal Officer designated to handle digital lending related complaints.
• The cooling-off or look-up period is available to the borrower.
• The recovery mechanism applicable to the loan.

Cooling-Off Period

Every borrower will be given an explicit option to exit the digital loan by repaying the principal and the proportionate interest without any prepayment penalty during the cooling-off period. The cooling-off period will be Not less than 1 (one) For borrowers who continue with the loan beyond the cooling-off period, prepayment will continue to be permitted in line with the extant RBI guidelines.

Loan Agreement and Communications

The sanction letter will be issued on the letterhead of Tycoon Credit & Portfolios Limited. immediately after sanction and before execution of the loan agreement. An executed copy of the loan agreement will be sent to the borrower as an attachment to the welcome letter or email or promptly following disbursement.

Disclosure on the Platform

The True Rupee platform will prominently display the following information onboarding and during the application process:

• Product features, loan limits, and cost structure.
• The identity of Tycoon Credit & Portfolios Limited. as the lender.
• The applicable KFS for the relevant loan product.
• Details of the Grievance Redressal Officer and the grievance redressal mechanism.
• The Fair Practices Code of the Company.

Reporting of Fraud and Suspicious Activity

In the event any fraud or suspicious activity is detected using the name, identity, or platform of True Rupee or Tycoon Credit & Portfolios Limited, customers are advised to immediately contact the Grievance Redressal Officer and to report such platforms or applications to the RBI through the Sachet portal at https://sachet.rbi.org.in.

 X.  POLICY FOR DETERMINING RATE OF INTEREST AND OTHER CHARGES

The Board of Directors has adopted a Board-approved interest rate model for determining the rate of interest and all other charges applicable to the Company’s loan products. The interest rate model takes into account relevant factors including:

• Cost of funds.
• Margin and target return.
• Risk premium based on the credit risk profile of the borrower category.
• Regulatory requirements and market benchmarks.

The rate of interest, the approach for gradation of risk, and the rationale for charging different rates to different categories of borrowers will be disclosed in the loan application form and communicated explicitly in the sanction letter and KFS.

All rates of interest will be expressed as annualized rates so that borrowers are aware of the exact rates applicable to their loan accounts. The rates of interest and the approach for risk gradation will also be published on the Company’s official website and updated whenever any change is made.

The Company will not levy any hidden charges or unapproved fees under the guise of interest or service charges. All charges will be consistent with the Board-approved interest rate policy.

The Company will not charge foreclosure charges or prepayment penalties on floating rate term loans sanctioned to individual borrowers for purposes other than business.

XI.  COLLECTION OF DUES

At the time of loan origination, the Company will clearly explain to the borrower the repayment process, including the instalment amount, repayment tenure, due dates, bounce charges, and penal charges for late payment.

Where a borrower does not adhere to the agreed repayment schedule, the Company will initiate recovery actions strictly in line with applicable laws and industry best practices. Recovery methods may include:

• Issuance of written or electronic reminders and notices.
• Follow-up through telephonic communication or personal visits by authorized representatives.
• Enforcement of security interest, if applicable, in line with the terms of the loan agreement.

The terms and conditions governing enforcement of security interest and repossession will be clearly set out in the loan agreement and will address:

• The notice period required before initiating possession.
• Circumstances, if any, under which the notice period may be waived.
• The procedure for taking possession of secured assets.
• The borrower’s right to make repayment of all dues before the sale or auction of the secured asset.
• The procedure for handing back repossessed assets to the borrower, where applicable.
• The procedure for sale or auction of the secured property.

The Company, and all people authorized to act on its behalf for recovery purposes, will strictly observe the following standards of conduct:

• Recovery agents will contact borrowers only between 8:00 a.m. and 7:00 p.m., unless the borrower’s specific circumstances require otherwise.
• Customers will be contacted at the place of their choice. In the absence of a specified preference, contact will be made at the borrower’s place of residence or, if unavailable there, at the place of business.
• The identity and authority of the recovery representative will be made known to the borrower at the first instance of contact.
• No recovery representative will use intimidation, coercion, harassment, or abusive language of any kind, whether verbal or in writing.
• No recovery representative will make threatening, anonymous, or persistent calls, or contact the borrower’s family members, referees, or associates in a manner that causes embarrassment or distress.
• No recovery representative will send inappropriate messages via mobile, email, or social media.
• No recovery representative will make false or misleading representations, including misrepresenting themselves as police officers, court officials, or government authorities.
• The borrower’s request to avoid calls at particular times or places will be honored to the extent reasonably possible.
• Visits will not be made on inappropriate occasions such as times of bereavement or other calamitous events in the borrower’s household.
• Confidentiality of borrower information will be maintained at all times.

All recovery personnel, whether internal or outsourced, will receive periodic training to ensure that recovery is conducted in a dignified, civil, and lawful manner. The Company will take appropriate disciplinary action against any representative who violates these principles.


XII.  NON-DISCRIMINATION

The Company will not discriminate against any borrower or applicant on the basis of gender, caste, religion, region, marital status, physical ability, or any other ground. All applicants will be assessed purely on the basis of financial merit, creditworthiness, and risk parameters in line with the Company’s Board-approved credit policy.

XIII.  GENERAL PROVISIONS

The following general principles will apply to all lending activities of the Company:

1. The Company will not interfere in the personal or business affairs of a borrower except as may be required for verifying information provided in the loan application, monitoring repayment performance, complying with statutory obligations, or addressing material information that was not earlier disclosed by the borrower.
2. In the event of a request from a borrower for transfer of the loan account, the Company will communicate its consent or objection within 21 (twenty-one) days of receipt of the request. Any such transfer will be governed by transparent contractual terms in consonance with applicable law.
3. All customer information will be treated as strictly confidential and will not be shared with any third party except as required by law, regulatory direction, or with the prior written consent of the customer.
4. All communications, acceptances, and amendments in relation to the loan facility will be in writing and will be preserved for a minimum period of 10 (ten) years.
5. The Company will give genuine cases of financial difficulty appropriate consideration. Borrowers experiencing repayment difficulties are encouraged to proactively contact the Company at the earliest opportunity.

 

XIV.  GRIEVANCE REDRESSAL MECHANISM

The Company has established a Grievance Redressal Mechanism (“GRM”) with the approval of its Board of Directors. The GRM ensures that all disputes arising from the decisions of the Company’s functionaries are heard and disposed of at the next higher level.

Level 1: In case of any service request / complaints, the customer may contact the customer engagement team at E Mail: care@truerupee.com

On receipt of service request / complaint, an acknowledgement will be given within 3 (Three) working days by the company to the customer via e-mail/ letter by post/ SMS/any other form of legally valid electronic communication including WhatsApp. The Company will endeavor to resolve to the same within a period of 7 (Seven) working days. However, in case where a complaint warrants extensive investigation and/or support of the customer to identify the perpetrator, root cause analysis, or under litigation (incl. pending with local Police authorities), the TAT for responding and resolving such complaints may be more than 7 (seven) working days.

 

In case the customer is not satisfied with the resolution/response provided by the customer engagement team/s as above, then customer will escalate to Level 2 as given below.

Level 2: It may be noted that the customers will approach for resolution of their service request/complaint at the first instance to the customer engagement team as mentioned in Level 1 hereinabove, and if their request / complaint remains unresolved for a period of 7 days or they are dissatisfied with the resolution given, they are required to contact , he may approach the Grievance Redressal Officer (GRO) of the Company at : gro@truerupee.com

 

We will make our best efforts to resolve customers’ complaints at this level in next 7 working days. If the customer is aggrieved by the GRO or rejection of complaint by GRO Office, customer can file an appeal within 30 days of receipt of Award or rejection of complaint to:

Consumer Education & Protection Department Reserve Bank of India

The customer may also lodge a complaint through the RBI Complaint Management System (CMS) portal or the Sachet portal at https://sachet.rbi.org.in, particularly for reporting frauds or unregulated entities.

The Company will ensure full compliance with the Reserve Bank – Integrated Ombudsman Scheme, 2021 (“Scheme”), as amended from time to time. The salient features of the Scheme are set out below for the benefit of the Company’s borrowers.

Complaints under the Scheme may be filed through the following channels:

• Online through the Integrated Ombudsman portal at https://cms.rbi.org.in.
• By email to CRPC@rbi.org.in.
• In physical form at the Centralized Receipt and Processing Centre, Reserve Bank of India, 4th Floor, Sector 17, Chandigarh – 160 017.
• Through the toll-free Contact Centre at 14448 (available from 9:30 a.m. to 5:15 p.m.), which provides assistance in Hindi, English, and regional languages.
  
  XV.  REVIEW OF THE FAIR PRACTICES CODE

This Code will be reviewed and, if necessary, revised by the Board of Directors on an annual basis or upon any change in applicable law, regulatory direction, or the Company’s business operations. Consequent upon any amendments to the RBI Master Directions or other applicable regulatory frameworks, necessary changes to this Code will be incorporated and approved by the Board at the earliest opportunity.

The Board of Directors will also review, on an annual basis, the Company’s compliance with this Code and the functioning of the Grievance Redressal Mechanism. A consolidated report of such review will be submitted to the Board. In the event of any conflict between the provisions of this Code and applicable law or regulatory direction, the applicable law or regulatory direction will prevail.

 

Annexure A – Code of Conduct for Recovery Personnel

The following Code of Conduct will be adhered to by all authorized personnel of the Company, whether internal employees or outsourced agents, engaged in any manner in the collection or recovery of loan dues from borrowers:

1. The Code of Conduct for collections will be followed diligently by all members of the collection team and all authorized agents.
2. Customer confidence, long-term relationships, and the dignity and respect of customers will be maintained at all times.

• Courtesy, fair treatment, and persuasion will be the basis of recovery. Unduly coercive methods will not be adopted under any circumstances.

1. Fairness and transparency will be maintained in all matters of repossession, valuation, and realization of security.
2. Customers will be contacted at the place of their choice. In the absence of a specified preference, contact will be made at the place of residence or, if unavailable, at the place of business or occupation. Decency and decorum will be maintained during all visits.
3. The identity and authority of the recovery representative will be disclosed to the customer at first instance.

• There will be no interference in the personal affairs of the customer. All interaction will be civil and will not involve any use of force or coercion.
• Authorized representatives will contact customers only between 8:00 a.m. and 7:00 p.m., unless the specific circumstances of the customer’s business or occupation require otherwise.

1. The customer’s request to avoid calls at a particular time or place will be honored to the extent reasonably possible.
2. Customers will be provided with all information regarding dues outstanding and will be given necessary notice to enable discharge of dues.
3. Reasonable notice will be given before repossession of security and before its realization.

• Disputes regarding dues will, to the extent reasonably possible, be resolved in a mutually acceptable and orderly manner.
• Inappropriate occasions such as bereavement in the family or other calamitous events will be avoided for making calls or visits.
• Confidentiality of customer information will be maintained at all times.

1. No inappropriate messages will be sent via mobile phone, email, or social media.

• No false or misleading representations will be made to the customer. Recovery personnel will not misrepresent themselves as police officers, court officials, or government authorities, nor falsely claim that legal or criminal proceedings have been initiated unless they actually have been.
• All communication relating to collection or recovery of dues will be conducted only through the contact details provided by the customer.

Disclaimer and Company Information Tycoon Credit & Portfolios Limited. Operating under the brand name: True Rupee Registered NBFC with the Reserve Bank of India | Non-Systemically Important Non-Deposit Taking NBFC | Scale Based Regulations, 2023 This Fair Practices Code is published for informational purposes and is subject to periodic revision. In the event of any conflict between the provisions of this Code and applicable law or regulatory directions issued by the Reserve Bank of India, the applicable law or regulatory directions will prevail. Customers are encouraged to visit the True Rupee platform and the Company’s official website regularly to access the most current version of this Code. Approved by the Board of Directors of Tycoon Credit & Portfolios Limited.