MAHAUTKARSH SECURITIES &  
FINANCE PRIVATE LIMITED  
Fair Practice Code  
st  
Approved on 1 April 2025  
Mahautkarsh Securities & Finance P Ltd  
Fair Practice Code  
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Fair Practice Code  
1. INTRODUCTION  
MAHAUTKARSH SECURITIES AND FINANCE PRIVATE LIMITED (“Company” “KishtoPe” or  
“MSFPL”) is a Non Banking Financial Company registered with Reserve Bank of India (RBI).  
The Company endeavours to review and follow the policy guidelines laid down by RBI to set  
up fair business practices while dealing with its borrowers. Accordingly, this Fair Practice  
Code (“FPC” or “Code”) has been amended pursuant to the Master Direction – Reserve Bank  
of India (Non-Banking Financial Company –Scale Based Regulation) Directions, Hence, in  
compliance with the said directions, this Code has been framed, approved, and reviewed by  
Board of the Company from time to time. The Company shall always adopt the best business  
practices from time to time and make appropriate modifications, as necessary to this Code.  
This  
has  
reference  
to  
RBI  
Circular  
No.  
RBI/2015-16/16  
DNBR  
(PD)  
CC.No.054/03.10.119/2015-16 dated 01st July 2015, wherein the Reserve Bank of India (RBI)  
has issued the guidelines on Fair Practices Code for NBFCs to implement the same. All of this  
was consolidated in the Master Direction - Non-Banking Financial Company – Non-  
Systemically Important Non-Deposit taking Company (Reserve Bank) Directions, 2016 which  
is replaced by Master Direction – Reserve Bank of India (Non-Banking Financial Company-  
Scale Based Regulation) Directions, 2023 dated 19th October 2023 as amended from time to  
time.  
The Fair Practices Code, as mentioned herein below, is in conformity with these Guidelines/  
Directions on Fair Practices Code for NBFCs as contained in the aforesaid RBI Circular/  
Direction. This sets minimum Fair Practice standards for the Company to follow when  
dealing with borrowers. It provides information to borrowers and explains how the  
Company is expected to deal with them on a day-to-day basis.  
Mahautkarsh Securities and Finance Private Limited is committed to dealing with its  
borrowers in a fair and transparent manner. As a Non-Banking Financial Company (NBFC),  
the Company has put in place a Fair Practice Code.  
2. OBJECTIVE OF THE CODE  
Primary objectives behind development of this code are:  
A. Promote good, fair and trustworthy practices in dealing with the borrowers;  
B. Increase transparency to enable the borrowers to have a better understanding of  
what they can reasonably expect of the services.  
C. Encourage market forces, through competition, to achieve higher operating  
standards;  
D. Promote a fair and cordial relationship between the borrowers and the Company.  
3. COMPANY’S KEY COMMITMENTS AND DECLARATIONS:  
i.  
To act honestly, fairly and reasonably in conducting financial activities and to deal  
our borrowers on the ethical principles of integrity and transparency.  
ii.  
To not discriminate against clients on the basis of gender, race, caste, religion or  
language and to treat all the clients consistently and fairly.  
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iii.  
iv.  
To prominently display the Fair Practice Code on the notice board at Registered  
Office of company and put systems in place to ensure compliance. Moreover,  
company always welcomes new ideas and suggestions from its clients.  
To ensure transparency in the maintenance of books of accounts and disclosure of  
financial statements by qualified auditor/s.  
The Board of Directors and the management team of MSFPL are responsible for  
implementing the FPC and also to ensure that its operations reflect its strong commitment  
to all the stakeholders for offering in a fair and equitable manner, the various financial  
services and products including lending as MSFPL may provide from time to time and that all  
MSFPL employees/representatives shall be aware of this commitment.  
a. APPLICATIONS FOR AVAILING LOANS AND THEIR PROCESSING  
a. All communications to the borrower shall be provided in the vernacular language  
upon request.  
b. All the Loan agreements shall contain all necessary information, especially the Rate  
of interest, Processing Charges, insurance charges, Penal Charges and such other  
charges which affects the interest of the borrower, so that he can make a meaningful  
comparison with the terms and conditions offered by other NBFCs so that an  
informed decision can be taken by the borrower. The loan application form shall  
indicate the documents required to be submitted with the application form.  
c. MSFPL will offer credit to eligible qualified applicants who express their need to  
borrow through their loan request.  
d. Company shall give acknowledgement for receipt of loan applications and other  
documents. The Company shall inform the party about the pendency of any  
information and document for processing the Loan application. The decision on loan  
application shall be taken not later than 30 days from the date of receipt of  
completed loan application. Loan application will be considered as complete, once  
all information has been duly received and filled in and required documents have  
been submitted and found acceptable. The Loan application and acknowledgment  
shall contain the time frame within which loan applications will be disposed of.  
e. The applicant will be given the contact numbers on the application from whom he  
can enquire about developments in the loan process.  
b. LOAN APPRAISAL AND TERMS/CONDITIONS  
i.  
The company shall convey in writing to the borrower as understood by the borrower  
by means of sanction letter, loan agreement, Key Facts Statement (KFS) or  
otherwise, the amount of annualized rate of interest, Annual Percentage Rate (APR)  
and method of application thereof and keep the acceptance of these terms and  
conditions by the borrower on its record. Company shall mention the penal charges  
charged for late repayment in bold in the loan agreement.  
ii.  
The Company shall disclose all the contingent charges separately in their sanction  
letter.  
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iii.  
Company shall furnish a copy of the loan agreement along with the enclosures if any,  
preferably in the vernacular language if requested by the borrower along with a copy  
each of all enclosures quoted in the loan agreement to all the borrowers at the time  
of sanction / disbursement of loans.  
iv.  
v.  
To reinforce the understanding, company shall reiterate the terms and conditions,  
and responsibilities at the time of application, sanction and disbursement.  
The terms and conditions explained to the borrower include, but are not limited to  
the following:  
a.  
b.  
The manner of repayment of the loan.  
The loan amount and tenure, rate of interest, Annual Percentage Rate,  
Processing fees method of application as well as other charges including  
contingent charges.  
c.  
The frequency of repayment – whether weekly, fortnightly or monthly (at the  
option of the borrower).  
d.  
In case of co- borrower/guarantor(s), their responsibility in case of default.  
vi.  
Company undertakes to give due notice for any change in the conditions of the loan  
specially pertaining to interest rate (prospectively) and periodicity, quantum of  
instalments and tenure of loan/(any changes in the loan process/procedures).  
c. MARKETING AND PRODUCT SYNERGY  
a. All advertising and promotional materials will be meticulously reviewed to ensure  
clarity, fairness, reasonableness, and non-misleading representations. We are  
committed to upholding transparency and integrity in all our marketing endeavours.  
b. Our company is dedicated to providing our borrowers with a comprehensive range  
of financial products for which they are eligible. These offerings will include products  
and services developed internally by our company, as well as those offered by  
affiliated entities or associated companies, and through strategic partnerships with  
external organizations.  
c. It is our aim to foster synergy among the various financial services and products we  
offer by actively promoting cross-selling opportunities to our clientele. Through this  
approach, we endeavour to enhance the overall value proposition for our borrowers  
while maximizing the benefits of our diverse product portfolio.  
d. DISBURSEMENT OF LOANS INCLUDING CHANGES IN TERMS AND CONDITIONS  
a. The company shall give notice to the borrower of any change in the terms and  
conditions including disbursement schedule, interest rates and periodicity, service  
charges, foreclosure charges etc. Company shall also ensure that changes in interest  
rates and charges only prospectively. A suitable condition in this regard shall be  
incorporated in the loan agreement.  
b. Decision to recall / accelerate payment or performance under the agreement shall  
be in consonance with the loan agreement. Before taking a decision to recall /  
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accelerate payment or performance under the agreement or seeking additional  
securities, the Company should give notice to borrowers.  
c. Company shall release all securities on repayment of all dues or on realization of the  
outstanding amount of loan subject to any legitimate right or lien for any other claim  
the Company may have against borrower. If such right of set off is to be exercised,  
the borrower shall be given notice about the same with full particulars about the  
remaining claims and the conditions under which the Company is entitled to retain  
the securities till the relevant claim is settled/paid.  
d. Company shall inform its clients clearly about all the terms and conditions of the  
loan, the advantages of timely repayments and the consequences of defaulting on  
loans.  
e. RECOVERY OF LOANS  
a. Company will ensure that its decision to recall/ accelerate payment based on  
performance is in consonance with the loan agreement.  
b. In the matter of recovery of outstanding dues of its borrower, Company will not  
resort to undue harassment viz. persistently bothering the borrower at odd hours,  
the use of muscle power for recovery of loans, etc. Company shall ensure that the  
staff is adequately trained to deal with the borrowers in an appropriate manner.  
c. While enforcing its rights as a lender strictly, Company believes in polite language  
and abjures the use of abusive and harsh words.  
d. Company undertakes to release all securities if any on repayment of all dues or on  
realization of the outstanding amount of loan, subject to any legitimate right or lien  
for any other claims it may have against the borrower. Company shall provide its  
borrowers information about the penalties liable to be levied in case of non-  
observance, violation of any terms and conditions governing the product/ services  
chosen by them and all details in its tariff schedule of any charges applicable to the  
products and services chosen by them.  
e. If any such right of set off is to be exercised, the company will ensure that the  
borrower is given notice about the same with full particulars about the remaining  
claims and the conditions under which Company is entitled to retain the securities if  
any, till the relevant claim is settled/ paid.  
f. PRIVACY AND CONFIDENTIALITY  
1. Credit reference agencies/credit information companies (CIC’s):  
a. The company may share details of the loan and repayment track records of its  
borrowers to the credit information companies as per the regulatory directions/  
guidelines or the company’s internal policies.  
2. Sharing of information:  
a. The company will treat the personal information of borrowers as private and  
confidential even when the borrowers is no longer associated. Company shall not  
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reveal the data or information of borrowers to anyone except as provided above in  
the following exceptional cases;  
i.  
ii.  
Required by law  
For the purpose of providing services  
iii.  
iv.  
v.  
Duty towards public to reveal information  
The company’s interest requires giving information  
The company has consent/ permission from the borrowers  
b. The company will safeguard personal information of clients, only allowing  
disclosures and exchange of such information to others who are authorized to see it,  
with the knowledge and consent of clients.  
g. GRIEVANCE REDRESSAL MECHANISM  
a. The Company shall lay down the appropriate Grievance Redressal Mechanism within  
the organization. Such a mechanism should ensure that all disputes arising out of the  
decisions of Company’s institutions' functionaries are heard and disposed of at least  
at the next higher level.  
b. The Board of Directors should also provide for periodical review of the compliance of  
the Fair Practices Code and the functioning of the Grievances Redressal Mechanism  
at various levels of management.  
c. The Grievance Redressal policy is available on company website. MSFPL has  
designated an officer for the redressal of grievances of the clients including the  
borrowers, in connection with any matter pertaining to business practices, lending  
decisions, credit management and recovery.  
d. The following information shall be displayed prominently, for the benefit of the  
borrowers, at all branches/places of the Company, where business is transacted:  
i.  
the name and contact details (Telephone / Mobile nos. as also email address)  
of the Grievance Redressal Officer who can be approached for resolution of  
complaints against the Company.  
ii.  
If borrowers complaint/concern is not redressed within a period of 30 days,  
borrower can lodge a complaint on RBI CMS portal - https://cms.rbi.org.in.  
h. REGULATION ON EXCESSIVE INTEREST CHARGED  
a. The Company shall adopt an interest rate model taking into account relevant factors  
such as, cost of funds, margin and risk premium, etc and determine the rate of  
interest to be charged for loans and advances. The rate of interest and the approach  
for gradations of risk and rationale for charging different rate of interest to different  
categories of borrowers shall be disclosed to the borrower in the application form  
and communicated explicitly in the sanction letter.  
b. The rates of interest and the approach for gradation of risks for differential rate shall  
also be made available on the website of the company or published in the relevant  
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newspapers. The information published in the website or otherwise published  
should be updated whenever there is a change in the rates of interest.  
c. The rate of interest should be annualized rates so that the borrower is aware of the  
exact rates that would be charged to the account.  
d. Interest shall be charged from the date of actual disbursement of the funds to the  
customer instead of the date of sanction of loan or date of execution of loan  
agreement.  
e. In the case of loans being disbursed by cheque, where interest is charged from the  
date of the cheque the Company shall avoid delayed handing over of cheque to the  
customer.  
f. In the case of disbursal or repayment of loans during the course of the month,  
interest shall be charged only for the period for which the loan was outstanding  
instead of entire month.  
g. In case where one or more instalments are collected in advance then the advance  
amount shall be excluded from the full loan amount for charging interest.  
h. As per circular issued on RBI/ 2014-15 /12 DNBS (PD).CC.NO. 399/03.10.42/2014-15  
dt. July 14, 2014, the company shall not charge foreclosure charges/ pre-payment  
penalties on all floating rate terms loans sanction to individuals’ borrowers  
i. With respect to penal charges, the company shall be governed by penal charges  
policy.  
LOAN FACILITIES TO THE PHYSICALLY/VISUALLY CHALLENGED  
The Company has designed its loan sanctioning process in such a manner that it prohibits  
any kind of discrimination while extending products and facilities including loan facilities to  
physically/visually challenged applicants on grounds of disability. All branches of the  
Company render all possible assistance to such persons for availing of the various business  
facilities. Appropriate module is also included which contains the rights of persons with  
disabilities guaranteed to them by the law and international conventions, in all the training  
programmes conducted for their employees at all levels.  
j. GENERAL  
a. Company will refrain from interference in the affairs of the borrower except for the  
purposes provided in the terms and conditions of sanction of the loan (unless new  
information, not earlier disclosed by the borrower, has come to the notice of the  
lender).  
b. In case of receipt of request for transfer of borrower account, either from the  
borrower or from a lender, which proposes to take over the account, the consent or  
otherwise i.e., objection of the company if any would be conveyed within 21 days  
from the date of receipt of request. Such transfer shall be as per transparent  
contractual terms in consonance with law.  
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c. The Company will call borrower between 08:00 A.M. to 07:00 P.M., unless special  
circumstances of the borrower’s business require to call them otherwise outside the  
hours mentioned.  
d. The Company may arrange for enforcing security charged to it of the delinquent  
borrower, if required, with an aim only to recover dues, cost and expenses of such  
enforcement action.  
e. The Company shall ensure that the entire process of enforcing its security, valuation  
and realization thereof be fair and transparent.  
k. COMPLIANCE  
a. The Fair Practice Code shall be provide in Vernacular Language if requested by  
borrower.  
b. Fair Practice code shall be put on the Notice Board of all the Branches and offices of  
the company and website of the company if any for information of various stake  
holders.  
l. FEEDBACK AND SUGGESTIONS  
We request our borrowers to provide feedback on our service to help us to improve our  
services.  
m. OVERRIDING EFFECT  
In case any of the clause contained in this policy overrides the applicable RBI guidelines as  
may be issued and amended from time to time, the provisions stipulated in the RBI  
guidelines shall override the contents of this policy.  
n. REVIEW  
The Board of Directors shall be authorized to review and approve any modifications to the  
Fair Practice Code from time to time.  
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