Last updated on: 27th June 2024
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Background
Si Creva Capital Services Private Limited is a private limited company, incorporated under the provisions of the Companies Act, 2013, having Corporate Identification Number (CIN) U65923MH2015PTC266425 (“Si Creva”/“Company”). Si Creva is a Middle Layer Non-Deposit taking Non-Banking Financial Company, bearing Registration no. N- 13.02129, registered and regulated by the RBI Master Direction – Reserve Bank of India (Non-Banking Financial Company – Scale Based Regulation) Directions, 2023, as amended from time to time and such other rules, regulations, directions, circulars, notifications, and orders issued in this regard from time to time (“RBI Directions”).
Si Creva is in the business of the providing secured and unsecured business loans and personal loans. As per RBI guidelines as applicable from time to time, the board of Non-Banking Financial Company (“NBFC”) after recommendation from the Board committee shall approve an interest rate model for the Company, taking into account relevant factors such as Weighted Average Cost of Funds (W-CoF), Risk Premium and Margin etc. to determine the Rate of Interest (RoI) to be charged for loans and advances. Further, the directives states that the rate of interest and the approach for gradation of risk and the rationale for charging different rates of interest for different category of borrowers should be communicated to the borrowers / customers in the sanction letters to them. This policy intends to provide a broad framework for interest rate model of the Company. This policy supersedes all prior written interest rate policies and would be implemented from immediate effect.
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Objective
To arrive at the Rate of Interest to be used for loans to different types of customer segments and to decide on the principles and approach of charging spreads to arrive at final rates charged from customers. Accordingly, the objective of the policy is to determine the rate of interest charged on the loans provided to the customers.
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Review of Policy
Board shall review the policy at least once every 6 months or earlier as may be required for changes in the interest rate structure of the loans.
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Governance Structure
The Board of Directors oversees the Company’s interest rate policy. Operational responsibilities for modifications within defined parameters are delegated to the Asset Liability Management Committee (“ALCO”) and Risk Management Committee (“RMC”) and presented to the Board for consideration and ratification. Any changes outside the established policy guardrails will be submitted to the Board for approval through the RMC, as proposed by the ALCO.
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Interest Rate Model
The rate of interest rate is calculated based on various factors such as the Weighted Average Cost of Funds (W-CoF) of the company, operational expenditure, risk premium and desired RoA/RoE, elaborated below:
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Weighted Average Cost of Funds (W-CoF): The cost of borrowing includes interest cost, arranger fees, processing fees, etc. directly apportioned to such borrowings. Cost of Borrowing also includes any cost incidental to those borrowings. Further factors such as tenure of borrowing, market liquidity, financing avenues, interest rate methodology and covenants stipulated by the lenders also impact cost of borrowing. In addition, the cost of equity is to be added based on reasonable margin for shareholders, i.e. desired RoE.
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Operational Expenditure: This includes various costs such as maintaining the technology platform, offering good customer service and handling payment gateway expenses for disbursements and collections.
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Risk premium: This covers the credit and default risk on the individual product and overall portfolio.
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Rate of Interest
We give loans to our customers through a fixed rate loan. We lend money through various products to cater to needs of different category of customers. The products offered by us and the interest rate charged on different products are as follows:
Unsecured Loans
Tenure RoI 3m – 5m 28% 6m – <36m 33% 36m – <48m 32% 48m -60m 28% Secured Loans
Rate of interest 28% -
Risk Gradation
The rate of interest for the same loan product and same tenor availed during the same period by different customers may be different as it can vary for different customers based on risk gradation. Factors affecting calculation of spreads to arrive at final rate are as follows:
- Risk profile of the borrower
- Credit or default risk in the related business segment
- Tenor of the Loan
- Historical performance of similar segment of customers
- Internal cost / opex of doing business
- Interest rate offered by other NBFCS’ in the industry
- Other factors that may be relevant in each case.
The individual assessment criteria for the customer credit grading can be classified based on these aspects. All applicants are classified into two categories: “A” – Superior, “B” – Normal.
The annualised rate of interest (APR) will comprise of
- Rate of Interest and
- Processing Fee.
Besides interest, other charges* would be levied by the Company wherever considered necessary. Besides these charges, stamp duty, documentation charges, GST and other cess would be collected at an applicable rate from time to time, as communicated in the documentation provided. Any revision in these charges would have a prospective effect and will be communicated to the borrower.
* e.g. processing fees, late payment charges, legal charges, pre-payment / foreclosure charges, etc.
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Communication Framework
Interest rates would be intimated to the customers at the time of sanction / availing of the loan.
- The amount of loan sanctioned along with the terms and conditions including annualized rate of interest and method of application thereof along with the acceptance of these terms and conditions by the borrower shall be kept on record by the Company.
- The penal charges shall not be levied in the form of ‘penal interest’ that is added to the rate of interest charged on the advances.
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The Company shall not introduce any additional component to the rate of interest.
Interest Rate Policy would be uploaded on the website of the company and any change in the rate of interest would be uploaded on the website of the Company. - Any changes in the rate of interest shall be affected prospectively only.Any changes in the rate of interest for existing customers would be communicated to them through a notice or other agreed modes of communication.