1. Background:
  2. 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 Systemically Important Non-Deposit taking Non-Banking Financial Company, bearing Registration no. N-13.02129, registered and regulated by the Master Direction – Non-Banking Financial Company – Systemically Important Non-Deposit taking Company and Deposit taking Company (Reserve Bank) Directions, 2016, 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”).

    Since, during the year, Si Creva has become a systemically important NBFC, its compliance obligations have widened.

    Si Creva is in the business of the provision of consumer and personal loans.

  3. Introduction:
  4. In compliance with the said RBI directives, the policy for the determination of Interest rates stands as follows:
    The interest rate charged to the borrower shall be based on the following broad parameters:

    1. Risk profile of the borrower
    2. Tenor of the Loan
    3. Cost of borrowing funds – Internal as well as external
    4. Credit and default risk in the related business segment
    5. Historical performance of similar kind of customers
    6. Prevailing Interest rate trends in the money market
    7. Treasury bill rates and the sovereign yield curve
    8. Spreads between the sovereign and the AAA corporate bonds
    9. Prevailing Base Rate of major commercial banks
    10. Market scenario relating to credit risk premia / default premia including CDS spreads
    11. Internal Cost of doing business
    12. Interest rate offered by other NBFC’s in the industry
    13. Other factors that may be relevant in each case.
  5. Rate of Interest:
  6. • The rate of interest for the same loan product and same tenor availed during the same period by different customers need not be standardized as it can vary for different customers based on consideration of any or a combination of the above parameters.
    • The interest rates offered can be on a fixed or variable basis and can be charged on a flat or reducing balance method.
    • The interest rate could range between zero to thirty-six percent depending upon the risk profile of the customer and other factors. The interest reset period for variable-rate loans would be decided by the NBFC from time to time.
    • The interest could be charged on monthly or quarterly rests for different products/segments.
    • Interest rates would be intimated to the customers at the time of sanction/availing of the loan and EMI apportionment towards interest and principal dues would be made available to the customer.
    • The interest shall be deemed payable immediately on the due date as communicated and no grace period for payment of interest is allowed.
    • Besides normal interest, the NBFC may levy additional/penal interest for delay or default in making payments of any dues. These additional or penal interests for different products or facilities would be decided by the respective business/product heads.
    • The changes in the interest rates and related charges would be prospective in effect and intimation of change of interest or other related charges would be given to customers in a mode and manner deemed fit.
    • Besides interest, other financial charges like processing fees, origination fees, cheque bouncing charges, late payment charges, re-scheduling charges, pre-payment / foreclosure charges, part disbursement charges, cheque swap charges, security swap charges, charges for issue of statement account, customer care, the credit assessment, cash handling, ECS/ Direct Debit/ ACH mandate registration/lodgement/handling or for any other service provided by the NBFC or cost incurred by the NBFC for the provision of services related to the loan granted to the customers. Besides these charges, stamp duty, service tax, and other cess would be collected at applicable rates from time to time. Any revision in these charges would be prospective in effect. These charges for different products or facilities would be decided by the respective business/product heads in consultation with the Finance & Legal heads and the change will be notified on the Company’s website.
    • These fees and charges may vary based on asset/commodity financed, exposure limit, expenses incurred at the point of sale, and customer segment and generally represent the costs incurred in rendering the services to the customer.
    • All such fees and charges shall be clearly communicated to the customer either by way of printing on the sanction letter or by publishing on the website of the NBFC.
    • While deciding the charges, the practices followed by the competitors in the market would also be taken into consideration.
    • The NBFC may also levy and collect charges and penalties for prepayment/ foreclosure of loan by the customer, for delay or late payment of loan installments and other dues to the NBFC, and bouncing of ECS/ Direct Debit/ ACH.

    It is abundantly clarified that in case the Company grants loan to any borrower with an annual family income of upto Rs. 3.00 lakh, the Company will ensure to comply with RBI Circular RBI/DOR/2021-22/89 dated March 14, 2022, as may be updated from time to time.

  7. Additional Covenant:
  8. • The NBFC may, at its sole discretion, allow the prepayment/foreclosure of the Loan Amount subject to certain conditions and on payment of prepayment/foreclosure penalties by the Borrower.
    • The minimum number of installments post which pre-payment/ foreclosure is allowed may vary based on the products & tenure of the loan and shall be specified in the sanction letter.
    • Claims for refund or waiver of charges / penal interest / additional interest would normally not be entertained by the NBFC and it is at the sole discretion of the NBFC to deal with such requests.
    • Any revision in the NBFC’s interest rates applicable to business would be reviewed by the Finance & Legal heads and recommended to the CEO for approval.

  9. Review of the Policy
  10. The policy will be reviewed at yearly intervals or as and when considered necessary by the Board.

    For Si Creva Capital Service Private Limited