01 Objective
The objective of the Digital Lending Policy is to establish a transparent, responsible, and technology-enabled lending framework for sourcing, processing, approving, disbursing, servicing, and monitoring loans through digital channels while ensuring compliance with applicable RBI regulations and customer protection requirements.
02 Scope
The policy applies to:
- Digital lending platforms operated by Allen's Housing and Finance Limited.
- Loan Service Providers (LSPs).
- Loan applications and digital interfaces used for customer onboarding and servicing.
- Employees, agents, technology partners, and third-party service providers involved in digital lending activities.
Allen's Housing and Finance Limited states that it uses Loan Service Providers and Loan Service Applications for sourcing and servicing loans, with digital loans being approved, disbursed, and managed under applicable RBI guidelines and internal policies.
03 Regulatory Compliance
The Company shall ensure compliance with:
- Reserve Bank of India digital lending guidelines.
- Fair Practices Code requirements.
- KYC and AML requirements.
- Data protection and privacy obligations.
- Customer grievance redressal requirements.
Allen's Housing and Finance Limited is an RBI-registered NBFC and has adopted policies covering fair lending practices, customer communication, and regulatory compliance.
04 Customer Onboarding and KYC
Digital borrowers shall be onboarded through secure processes including:
- Customer identification and verification.
- Digital KYC procedures.
- Credit assessment.
- Consent-based collection and use of customer information.
The Company's AML/KYC policy is designed around RBI requirements for customer identification and prevention of misuse of financial services.
05 Loan Application and Credit Assessment
The digital lending process shall include:
- Collection of borrower information.
- Assessment of repayment capacity.
- Credit bureau checks where applicable.
- Risk-based loan approval decisions.
Allen's Credit Risk Policy identifies credit appraisal, approval, post-approval monitoring, and enforcement as key elements of its lending framework.
06 Transparency in Lending
Before loan acceptance, borrowers should receive:
- Loan amount.
- Interest rate.
- Processing fees and other charges.
- Repayment schedule.
- Key loan terms.
- Applicable penalties.
The Company's Interest Rate Policy provides for transparent determination of interest rates and related costs.
07 Data Privacy and Security
The Company shall ensure:
- Collection of only necessary customer data.
- Obtaining customer consent before data usage.
- Secure storage and transmission of information.
- Restricted access to borrower information.
- Compliance with applicable data protection requirements.
08 Role of Loan Service Providers (LSPs)
LSPs shall:
- Act only within the scope authorized by Allen's Housing and Finance Limited.
- Follow Company policies and RBI requirements.
- Maintain customer confidentiality.
- Avoid misleading marketing or unauthorized practices.
Allen's Housing and Finance Limited has disclosed certain LSP arrangements for digital loan sourcing and servicing.
09 Loan Disbursement and Repayment
Digital lending transactions shall ensure:
- Proper documentation of loan approval.
- Direct and transparent movement of funds as required by regulations.
- Clear repayment instructions.
- Digital payment options.
10 Customer Grievance Redressal
Customers shall have access to:
- Complaint registration channels.
- Timely resolution mechanisms.
- Escalation procedures as per applicable RBI requirements.
11 Monitoring and Audit
The Company shall periodically review:
- Digital lending operations.
- LSP performance.
- Data security controls.
- Customer complaints.
- Regulatory compliance.
12 Policy Review
The Digital Lending Policy shall be reviewed periodically and updated based on:
- RBI regulatory changes.
- Technology developments.
- Operational requirements.
- Risk management considerations.