Interest Rate and Charges Policy

 1. Introduction

KPCA GLOBAL LLP extends loans through third-party banks and institutions. These loans may

or may not be backed by mortgages. Interest rates and charges are levied based on partner

bank norms, operating costs, and associated risks to maintain competitiveness.

2. Scope & Application

This policy applies to all loans extended via partner banks/financial institutions, excluding those under the Demand / Call Loan Policy.

3. Purpose

The policy aims to:

• Establish the interest rate and charges framework
• Define interest and charges types
• Outline procedures for review and revision
• Disclose applicable interest rates and charges
• Govern the approval and change mechanism
• Maintain a transparent governance framework

4. Interest Rate Policy

a. Prime Lending Rate (PLR) is based on:

• Cost of Capital
• Marginal/Incremental Borrowing Cost
• Operating Cost
• Credit Loss Provisions
• Risk Premium

b. Spread Considerations

• Credit risk (industry, security, customer profile)
• Internal/External ratings
• Tenor of the loan
• Business strategy
• Additional operational costs

c. Risk-Based Pricing

• Loans priced by customer risk profile
• Spread over PLR is determined by ALCO
• No additional burden for physically/visually challenged individuals

d. Guiding Principles

• As per internal credit policy & delegation matrix
• Sanction leer communicates final rate

5. Bulk Rate Changes

• Option to switch between floang and fixed rates
• Floating rate linked to PLR
• Customers can alter EMI/tenor or prepay with applicable conditions
• Switching fee applicable

6. Charging of Interest

Interest applied from:

• Electronic transfer: Date of credit
• Cheque handover: Date of issue
• Preference for online transfers

7. Risk Review

Risk profile of borrowers may be reassessed periodically, leading to interest rate revision.

Schedule of Charges

a. Onboarding Charges

• Processing fees
• Stamp Duty/Registration
• Mortgage creation charges
• CERSAI/CKYCR fees
• Technical/Valuation fees

b. Life Cycle Charges

Charged upon specific customer requests:

• Duplicate documents (NOC, repayment schedule, etc.)
• Loan foreclosure
• Interest rate conversion
• Document retrieval
• Loan cancellation
• Cheque/NACH bounce

c. Recovery Charges

• EMI bounce (first & second presentation)
• Penal charges
• Repayment mode swap
• Legal/SARFAESI recovery charges

Regulatory Disclosure

Per RBI Master Direction (2021):

1. Interest Rates: Vary by product and customer profile; final rates in sanction letter.

2. Risk Gradation: Based on cost, borrower profile, market comparison, and risk.

3. Penal Charges: Listed in Schedule of Charges.

Grievance Redressal Policy

1. Introduction

KPCA GLOBAL LLP is committed to transparent and responsive customer service. This policy

outlines the framework for timely grievance redressal and feedback handling.

2. Applicability

Applies to all KPCA GLOBAL LLP customers and service interactions, including outsourced

partners.

3. Regulatory Compliance

Follows RBI’s Fair Practices Code (Chapter XIII, Para 77 of 2021 Guidelines). A Board-

approved redressal mechanism is in place.

4. Key Definitions

• GRO: Grievance Redressal Officer appointed by the Board
• Complaint: Dissatisfaction with service or product
• Complainant: Person lodging the complaint
• Disciplinary Action: Penalties arising from investigation

5. Roles & Rights of Complainant

• Right to acknowledgement and status tracking
• Entitled to transparent resolution timelines
• Must support investigation with all necessary information

6. Disqualifications

• Frivolous, malicious, or unsubstantiated complaints
• Abusive or threatening behavior toward employees.

7. Guiding Principles

• Time-bound resolution
• Confidentiality of identity in sensitive cases
• Root cause analysis for systemic fixes
• Equal access for persons with disabilities

8. Service Request vs Complaint

Efforts are made to resolve all queries before they escalate into formal complaints.

9. Exclusions

Complaints not considered:

• Illegible or incomplete
• Internal HR issues
• Court-sub judice matters
• Incidents over one year old lacking evidence

10. Anonymous / Pseudonymous Complaints

• Accepted only with strong supporting evidence
• GRO’s decision is final

11. Grievance Redressal Mechanism (GRM)

Complaints can be submitted via:

• Email
• Website contact form
• Physical mail to the customer service department
• All customers, including differently-abled, receive equal service standards.

12. Record Retention

All complaint records preserved for 3 years post-closure.

13. Grievance Redressal Committee (GRC)

• Board-level Committee reviews grievances quarterly
• Analyzes patterns and proposes policy changes

14. Reporting

• Quarterly reports to GRC
• Unresolved complaints > 4 weeks highlighted
• Half-yearly review by the Board
• Annual root cause analysis

15. Policy Review & Amendments

• Reviewed annually
• Amendments subject to Board approval