Home India Reserve Bank of India Fair Lending Practice - Penal Charges in Loan Accounts...
Date: 2023-08-18 Category: Not Applicable State: Union Government Country: India

Fair Lending Practice - Penal Charges in Loan Accounts

Issued by Reserve Bank of India · Not Applicable

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Executive Summary & Key Takeaways

Executive Summary: This Reserve Bank of India (RBI) circular addresses concerns about divergent practices in levying penal charges on loans, aiming to ensure fairness and transparency. It mandates that penalties for non-compliance with loan terms be treated as penal charges, not penal interest, and outlines guidelines for Regulated Entities (REs) regarding policy formulation, disclosure, and quantum of such charges. The instructions are effective from January 1, 2024, requiring REs to revise their policies and implement the changes for new and existing loans. Key Points / Main Content: Penal Charges Guidelines: * Penalties for non-compliance with loan terms must be treated as penal charges, not as penal interest added to the loan's interest rate. * Capitalization of penal charges is prohibited (no further interest can be computed on these charges), but normal compounding of interest is unaffected. * REs cannot add any additional component to the interest rate. Policy and Implementation: * REs must formulate a Board-approved policy on penal charges. * Penal charges must be reasonable, commensurate with the non-compliance, and non-discriminatory within a loan product category. * Penal charges for individual borrowers (non-business purposes) cannot exceed those for non-individual borrowers for similar non-compliance. Disclosure and Communication: * The amount and reason for penal charges must be clearly disclosed in the loan agreement, Key Fact Statement (KFS), and on the RE's website. * Borrowers must be informed of applicable penal charges in reminders for non-compliance and upon levy of such charges. Effective Date and Transition: * These instructions are effective from January 1, 2024. * For new/renewed loans from the effective date, the instructions apply immediately. * For existing loans, switch to the new regime at the next review/renewal or within six months from the effective date, whichever is earlier. Scope and Authority: * The instructions are issued under specific sections of the Banking Regulation Act, the Reserve Bank of India Act, and the National Housing Bank Act. * These instructions do not apply to Credit Cards, External Commercial Borrowings, Trade Credits, and Structured Obligations. Amendments to Master Directions: * Amendments are made to Master Directions regarding interest rates on advances and regulations for Non-Banking Financial Companies (NBFCs), including Housing Finance Companies (HFCs) and Urban Co-operative Banks (UCBs), to reflect the new guidelines on penal charges. Impact Analysis Regulated Entities (REs): * Impact: REs must revise their existing policies on penal charges to align with the new guidelines, ensuring fairness, transparency, and non-discrimination. They need to update loan agreements, Key Fact Statements, and website disclosures. * Action Required: Formulate a Board-approved policy on penal charges, revise systems to avoid capitalization of penal charges, ensure compliance with disclosure requirements, and implement changes by January 1, 2024, for new loans and transition existing loans within six months. Borrowers: * Impact: Borrowers will benefit from greater transparency and fairness in the application of penal charges, with clearer communication regarding the amount and reasons for such charges. Individual borrowers for non-business purposes are protected from higher penal charges compared to non-individual borrowers. * Action Required: Review loan agreements to understand the revised penal charge policies and monitor communications from REs regarding non-compliance and associated charges. Reserve Bank of India (RBI): * Impact: The RBI aims to promote better lending practices and reduce customer grievances related to penal charges, enhancing the integrity and transparency of the financial system. * Action Required: Update relevant Master Directions and Circulars and supervise REs' compliance with the new guidelines.

Key Entities Referenced

Reserve Bank of India: The central bank of India, responsible for regulating the banking sector and issuing guidelines on financial matters. Commercial Banks: Includes Small Finance Banks, Local Area Banks and Regional Rural Banks, excluding Payments Banks Primary Urban Cooperative Banks: A type of cooperative bank that operates in urban areas. NBFCs: Non-Banking Financial Companies, including HFCs (Housing Finance Companies) and All India Financial Institutions. EXIM Bank: Export-Import Bank of India, a financial institution that facilitates international trade. NABARD: National Bank for Agriculture and Rural Development, an apex development bank in India. National Housing Bank Act, 1987: An act of parliament to establish National Housing Bank as the principal agency to promote housing finance institutions. Mumbai, Maharashtra: City in India, location of Reserve Bank of India Central office
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भारतीय ररज़र्व बैंक RESERVE BANK OF INDIA RBI/2023-24/53 DoR.MCS.REC.28/01.01.001/2023-24 August 18, 2023 All Commercial Banks (including Small Finance Banks, Local Area Banks and Regional Rural Banks, excluding Payments Banks) All Primary (Urban) Co-operative Banks All NBFCs (including HFCs) and All India Financial Institutions (EXIM Bank, NABARD, NHB, SIDBI and NaBFID) Madam / Dear Sir, Fair Lending Practice - Penal Charges in Loan Accounts Reserve Bank has issued various guidelines to the Regulated Entities (REs) to ensure reasonableness and transparency in disclosure of penal interest. Under the extant guidelines, lending institutions have the operational autonomy to formulate Board approved policy for levy of penal rates of interest. It has been observed that many REs use penal rates of interest, over and above the applicable interest rates, in case of defaults / non-compliance by the borrower with the terms on which credit facilities were sanctioned. 2. The intent of levying penal interest/charges is essentially to inculcate a sense of credit discipline and such charges are not meant to be used as a revenue enhancement tool over and above the contracted rate of interest. However, supervisory reviews have indicated divergent practices amongst the REs with regard to levy of penal interest/charges leading to customer grievances and disputes. 3. On a review of the practices followed by REs for charging penal interest/charges on loans, the following instructions are issued for adoption. (i) Penalty, if charged, for non-compliance of material terms and conditions of loan contract by the borrower shall be treated as ‘penal charges’ and shall not be levied in the form of ‘penal interest’ that is added to the rate of interest charged on the advances. There shall be no capitalisation of penal charges i.e., no further interest computed on विवियमि विभाग, केंद्रीय कायाालय, 12िी ींऔर 13िी ींमींव़िल, केंद्रीय कायाालय भिि, शहीद भगत व ींह मागा, म ींबई 400001 टेलीफोि /Tel No: 22601000 फैक्स/ Fax No: 022-2270 5670, 2260 5671, 5691 2270, 2260 5692 Department of Regulation, Central Office, 12th & 13th Floor, Central Office Building, Shaheed Bhagat Singh Marg, Mumbai – 400001 Tel No: 22601000 Fax No: 022-2270 5670, 2260 5671, 5691 2270, 2260 5692 बैंक वहींदी में पत्राचार का स्वागत करता है Caution: RBI never sends mails, SMSs or makes calls asking for personal information like bank account details, passwords, etc. It never keeps or offers funds to anyone. Please do not respond in any manner to such offers.such charges. However, this will not affect the normal procedures for compounding of interest in the loan account. (ii) The REs shall not introduce any additional component to the rate of interest and ensure compliance to these guidelines in both letter and spirit. (iii) The REs shall formulate a Board approved policy on penal charges or similar charges on loans, by whatever name called. (iv) The quantum of penal charges shall be reasonable and commensurate with the non- compliance of material terms and conditions of loan contract without being discriminatory within a particular loan / product category. (v) The penal charges in case of loans sanctioned to ‘individual borrowers, for purposes other than business’, shall not be higher than the penal charges applicable to non- individual borrowers for similar non-compliance of material terms and conditions. (vi) The quantum and reason for penal charges shall be clearly disclosed by REs to the customers in the loan agreement and most important terms & conditions / Key Fact Statement (KFS) as applicable, in addition to being displayed on REs website under Interest rates and Service Charges. (vii) Whenever reminders for non-compliance of material terms and conditions of loan are sent to borrowers, the applicable penal charges shall be communicated. Further, any instance of levy of penal charges and the reason therefor shall also be communicated. (viii) These instructions shall come into effect from January 1, 2024. REs may carry out appropriate revisions in their policy framework and ensure implementation of the instructions in respect of all the fresh loans availed/ renewed from the effective date. In the case of existing loans, the switchover to new penal charges regime shall be ensured on next review or renewal date or six months from the effective date of this circular, whichever is earlier. 4. The above instructions are issued under sections 21, 35A and 56 of the Banking Regulation Act, 1949, sections 45JA, 45L and 45M of the Reserve Bank of India Act, 1934, and section 30A of the National Housing Bank Act, 1987 and shall be updated in 2the relevant Master Directions / Master Circulars of the applicable REs. The list of amendments to the Master Directions / Master Circulars has been provided in the Annex. 5. These instructions shall, however, not apply to Credit Cards, External Commercial Borrowings, Trade Credits and Structured Obligations which are covered under product specific directions. Yours faithfully, (Santosh Kumar Panigrahy) Chief General Manager Encl: As above 3Annex I. Amendments to the relevant Master Directions Para Existing Section Amended Section No. A. Master Direction – Reserve Bank of India (Interest Rate on Advances) Directions, 2016 dated March 03, 2016 5 Banks shall formulate a deleted Board approved policy for charging penal interest on advances which shall be fair and transparent. The rate of penal interest shall be decided after taking into account incentive to service the debt and due regard to genuine difficulties of customers. Provided that no penal deleted interest shall be charged on advances mentioned in the circular RPCD.Plan.BC.15/04.09. 01/2001-02 dated August 17, 2001, as amended from time to time. B. Master Direction – Non-Banking Financial Company – Non-Systemically Important Non-Deposit taking Company (Reserve Bank) Directions, 2016 dated September 1, 2016 29 Applicable NBFCs shall Applicable NBFCs shall convey in writing to the convey in writing to the borrower in the vernacular language as understood borrower in the vernacular by the borrower by means of sanction letter or language as understood otherwise, the amount of loan sanctioned along with by the borrower by means the terms and conditions including annualised rate of of sanction letter or interest and method of application thereof and keep otherwise, the amount of the acceptance of these terms and conditions by the loan sanctioned along borrower on its record. As complaints received with the terms and against NBFCs generally pertain to charging of high conditions including interest / penal charges, applicable NBFCs shall annualised rate of interest mention the penalties charged for late repayment in and method of application bold in the loan agreement. thereof and keep the acceptance of these terms and conditions by the borrower on its record. 4As complaints received against NBFCs generally pertain to charging of high interest / penal interest, applicable NBFCs shall mention the penal interest charged for late repayment in bold in the loan agreement. (New section inserted) Penalty, if charged, for non-compliance of material Penal Charges in Loan terms and conditions of loan contract by the Accounts borrower shall be treated as ‘penal charges’ and shall not be levied in the form of ‘penal interest’ that is added to the rate of interest charged on the advances. There shall be no capitalisation of penal charges i.e., no further interest computed on such charges. However, this will not affect the normal procedures for compounding of interest in the loan account. The REs shall not introduce any additional component to the rate of interest and ensure compliance to these guidelines in both letter and spirit. The REs shall formulate a Board approved policy on penal charges or similar charges on loans, by whatever name called. The quantum of penal charges shall be reasonable and commensurate with the non-compliance of material terms and conditions of loan contract without being discriminatory within a particular loan / product category. The penal charges in case of loans sanctioned to ‘individual borrowers, for purposes other than business’, shall not be higher than the penal charges applicable to non-individual borrowers for similar non-compliance of material terms and conditions. The quantum and reason for penal charges shall be clearly disclosed by REs to the customers in the loan agreement and most important terms & conditions / 5Key Fact Statement (KFS) as applicable, in addition to being displayed on REs website under Interest rates and Service Charges. Whenever reminders for non-compliance of material terms and conditions of loan are sent to borrowers, the applicable penal charges shall be communicated. Further, any instance of levy of penal charges and the reason therefor shall also be communicated. These instructions shall come into effect from January 1, 2024. REs may carry out appropriate revisions in their policy framework and ensure implementation of the instructions in respect of all the fresh loans availed/ renewed from the effective date. In the case of existing loans, the switchover to new penal charges regime shall be ensured on next review or renewal date or six months from the effective date of these instructions, whichever is earlier. C. Master Direction - Non-Banking Financial Company -Systemically Important Non- Deposit taking Company and Deposit taking Company (Reserve Bank) Directions, 2016 dated September 1, 2016 29 Applicable NBFCs shall Applicable NBFCs shall convey in writing to the convey in writing to the borrower in the vernacular language as understood borrower in the vernacular by the borrower by means of sanction letter or language as understood otherwise, the amount of loan sanctioned along with by the borrower by means the terms and conditions including annualised rate of of sanction letter or interest and method of application thereof and keep otherwise, the amount of the acceptance of these terms and conditions by the loan sanctioned along borrower on its record. As complaints received with the terms and against NBFCs generally pertain to charging of high conditions including interest / penal charges, applicable NBFCs shall annualised rate of interest mention the penalties charged for late repayment in and method of application bold in the loan agreement. thereof and keep the acceptance of these terms and conditions by the borrower on its record. As complaints received against NBFCs generally pertain to charging of high 6interest / penal interest, applicable NBFCs shall mention the penal interest charged for late repayment in bold in the loan agreement. (New section inserted) Penalty, if charged, for non-compliance of material Penal Charges in Loan terms and conditions of loan contract by the Accounts borrower shall be treated as ‘penal charges’ and shall not be levied in the form of ‘penal interest’ that is added to the rate of interest charged on the advances. There shall be no capitalisation of penal charges i.e., no further interest computed on such charges. However, this will not affect the normal procedures for compounding of interest in the loan account. The REs shall not introduce any additional component to the rate of interest and ensure compliance to these guidelines in both letter and spirit. The REs shall formulate a Board approved policy on penal charges or similar charges on loans, by whatever name called. The quantum of penal charges shall be reasonable and commensurate with the non-compliance of material terms and conditions of loan contract without being discriminatory within a particular loan / product category. The penal charges in case of loans sanctioned to ‘individual borrowers, for purposes other than business’, shall not be higher than the penal charges applicable to non-individual borrowers for similar non-compliance of material terms and conditions. The quantum and reason for penal charges shall be clearly disclosed by REs to the customers in the loan agreement and most important terms & conditions / Key Fact Statement (KFS) as applicable, in addition to being displayed on REs website under Interest rates and Service Charges. 7Whenever reminders for non-compliance of material terms and conditions of loan are sent to borrowers, the applicable penal charges shall be communicated. Further, any instance of levy of penal charges and the reason therefor shall also be communicated. These instructions shall come into effect from January 1, 2024. REs may carry out appropriate revisions in their policy framework and ensure implementation of the instructions in respect of all the fresh loans availed/ renewed from the effective date. In the case of existing loans, the switchover to new penal charges regime shall be ensured on next review or renewal date or six months from the effective date of these instructions, whichever is earlier. D. Master Direction - Non-Banking Financial Company – Housing Finance Company (Reserve Bank) Directions, 2021 dated February 17, 2021 74.2 HFCs shall transparently HFCs shall transparently disclose to the borrower all disclose to the borrower information about fees/ charges payable for all information about fees/ processing the loan application, the amount of fees charges payable for refundable if loan amount is not sanctioned/ processing the loan disbursed, pre-payment options and charges, if any, application, the amount of penal charges for delayed repayment, if any, fees refundable if loan conversion charges for switching loan from fixed to amount is not sanctioned/ floating rates or vice-versa, existence of any interest disbursed, pre-payment reset clause and any other matter which affects the options and charges, if interest of the borrower. In other words, HFCs must any, penal interest/ disclose ‘all in cost’ inclusive of all charges involved penalty for delayed in processing/ sanctioning of loan application in a repayment, if any, transparent manner. It should also be ensured that conversion charges for such charges/ fees are non-discriminatory. switching loan from fixed to floating rates or vice- versa, existence of any interest reset clause and any other matter which affects the interest of the borrower. In other words, HFCs must disclose ‘all in cost’ inclusive of all 8charges involved in processing/ sanctioning of loan application in a transparent manner. It should also be ensured that such charges/ fees are non-discriminatory. 75.2 HFCs shall convey in HFCs shall convey in writing to the borrower in the writing to the borrower in vernacular language or a language as understood by the vernacular language the borrower by means of sanction letter or or a language as otherwise, the amount of loan sanctioned along with understood by the all terms and conditions including annualized rate of borrower by means of interest, method of application, EMI Structure, sanction letter or prepayment charges, penal charges (if any) and otherwise, the amount of keep the written acceptance of these terms and loan sanctioned along conditions by the borrower on its record. with all terms and conditions including annualized rate of interest, method of application, EMI Structure, prepayment charges, penal interest (if any) and keep the written acceptance of these terms and conditions by the borrower on its record. 76.2 The HFCs shall give The HFCs shall give notice to the borrower in the notice to the borrower in vernacular language or a language as understood by the vernacular language the borrower of any change in the terms and or a language as conditions including disbursement schedule, interest understood by the rates, penal charges (if any), service charges, borrower of any change in prepayment charges, other applicable fee/ charges the terms and conditions etc. HFCs should also ensure that changes in including disbursement interest rates and charges are effected only schedule, interest rates, prospectively. A suitable condition in this regard penal interest (if any), should be incorporated in the loan agreement. service charges, prepayment charges, other applicable fee/ charges etc. HFCs should also ensure that changes in interest rates and charges are effected only 9prospectively. A suitable condition in this regard should be incorporated in the loan agreement. 80.1 The Board of each HFC The Board of each HFC shall adopt an interest rate shall adopt an interest model taking into account relevant factors such as rate model taking into cost of funds, margin and risk premium and account relevant factors determine the rate of interest to be charged for loans such as cost of funds, and advances. The rate of interest and the approach margin and risk premium for gradation of risk and rationale for charging and determine the rate of different rate of interest to different categories of interest to be charged for borrowers shall be disclosed to the borrower or loans and advances. The customer in the application form and communicated rate of interest and the explicitly in the sanction letter. The Board of the HFC approach for gradation of shall also have clearly laid down policy for penal risk and rationale for charges (if any). charging different rate of interest to different categories of borrowers shall be disclosed to the borrower or customer in the application form and communicated explicitly in the sanction letter. The Board of the HFC shall also have clearly laid down policy for penal interest/ charges (if any). 80.3 The rate of interest and The rate of interest must be annualised rate so that penal interest (if any) the borrower is aware of the exact rates that would must be annualised rate be charged to the account. so that the borrower is aware of the exact rates that would be charged to the account 81 Though interest rates are Though interest rates are not regulated by the Bank, not regulated by the Bank, rates of interest beyond a certain level may be seen rates of interest beyond a to be excessive and can neither be sustainable nor certain level may be seen be conforming to normal financial practice. HFCs to be excessive and can shall lay out appropriate internal principles and neither be sustainable nor procedures in determining interest rates and be conforming to normal processing and other charges (including penal financial practice. HFCs charges, if any). In this regard the directions in the shall lay out appropriate Fair Practices Code about transparency in respect of 10internal principles and terms and conditions of the loans are to be kept in procedures in determining view. HFCs are also advised to put in place an interest rates and internal mechanism to monitor the process and the processing and other operations so as to ensure adequate transparency charges (including penal in communications with the borrowers. interest, if any). In this regard the directions in the Fair Practices Code about transparency in respect of terms and conditions of the loans are to be kept in view. HFCs are also advised to put in place an internal mechanism to monitor the process and the operations so as to ensure adequate transparency in communications with the borrowers. (New section inserted) Penalty, if charged, for non-compliance of material Penal Charges in Loan terms and conditions of loan contract by the Accounts borrower shall be treated as ‘penal charges’ and shall not be levied in the form of ‘penal interest’ that is added to the rate of interest charged on the advances. There shall be no capitalisation of penal charges i.e., no further interest computed on such charges. However, this will not affect the normal procedures for compounding of interest in the loan account. The REs shall not introduce any additional component to the rate of interest and ensure compliance to these guidelines in both letter and spirit. The REs shall formulate a Board approved policy on penal charges or similar charges on loans, by whatever name called. The quantum of penal charges shall be reasonable and commensurate with the non-compliance of material terms and conditions of loan contract 11without being discriminatory within a particular loan / product category. The penal charges in case of loans sanctioned to ‘individual borrowers, for purposes other than business’, shall not be higher than the penal charges applicable to non-individual borrowers for similar non-compliance of material terms and conditions. The quantum and reason for penal charges shall be clearly disclosed by REs to the customers in the loan agreement and most important terms & conditions / Key Fact Statement (KFS) as applicable, in addition to being displayed on REs website under Interest rates and Service Charges. Whenever reminders for non-compliance of material terms and conditions of loan are sent to borrowers, the applicable penal charges shall be communicated. Further, any instance of levy of penal charges and the reason therefor shall also be communicated. These instructions shall come into effect from January 1, 2024. REs may carry out appropriate revisions in their policy framework and ensure implementation of the instructions in respect of all the fresh loans availed/ renewed from the effective date. In the case of existing loans, the switchover to new penal charges regime shall be ensured on next review or renewal date or six months from the effective date of these instructions, whichever is earlier. 82.3 HFCs shall provide HFCs shall provide information on interest rates, information on interest common fees and charges (including penal charges, rates, common fees and if any) through putting up notices in their branches; charges (including penal through telephone or help-lines; on the company’s interest, if any) through website; through designated staff/ help desk; or putting up notices in their providing service guide/ tariff schedule. branches; through telephone or help-lines; on the company’s website; through designated staff/ help 12desk; or providing service guide/ tariff schedule. 85.9 Display of various key Display of various key aspect such as service aspect such as service charges, interest rates, penal charges (if any), charges, interest rates, services offered, product information, time norms for Penal interest (if any), various transactions and grievance redressal services offered, product mechanism, etc. is required to promote transparency information, time norms in the operations of HFCs. HFCs shall follow the for various transactions instructions on “Notice Board”, “Booklets/ and grievance redressal Brochures”, “Website”, “Other Modes of Display” and mechanism, etc. is on “Other Issues” as per Annex XII. required to promote transparency in the operations of HFCs. HFCs shall follow the instructions on “Notice Board”, “Booklets/ Brochures”, “Website”, “Other Modes of Display” and on “Other Issues” as per Annex XII. II. Instructions in addition to the paragraphs of the related Master Circulars E. Master Circular- Management of Advances – UCBs dated July 25, 2023 Para Existing Paragraph Additional instructions that shall apply No. Penalty, if charged, for non-compliance of material terms and conditions of loan contract by the borrower shall be treated as ‘penal charges’ and shall not be levied in the form of ‘penal interest’ that is added to the rate of interest charged on the advances. There shall be no capitalisation of penal charges i.e., no further interest computed on such charges. However, this will not affect the normal procedures for compounding of interest in the loan account. The REs shall not introduce any additional component to the rate of interest and ensure compliance to these guidelines in both letter and spirit. 13The REs shall formulate a Board approved policy on penal charges or similar charges on loans, by whatever name called. The quantum of penal charges shall be reasonable and commensurate with the non-compliance of material terms and conditions of loan contract without being discriminatory within a particular loan / product category. The penal charges in case of loans sanctioned to ‘individual borrowers, for purposes other than business’, shall not be higher than the penal charges applicable to non-individual borrowers for similar non-compliance of material terms and conditions. The quantum and reason for penal charges shall be clearly disclosed by REs to the customers in the loan agreement and most important terms & conditions / Key Fact Statement (KFS) as applicable, in addition to being displayed on REs website under Interest rates and Service Charges. Whenever reminders for non-compliance of material terms and conditions of loan are sent to borrowers, the applicable penal charges shall be communicated. Further, any instance of levy of penal charges and the reason therefor shall also be communicated. These instructions shall come into effect from January 1, 2024. REs may carry out appropriate revisions in their policy framework and ensure implementation of the instructions in respect of all the fresh loans availed/ renewed from the effective date. In the case of existing loans, the switchover to new penal charges regime shall be ensured on next review or renewal date or six months from the effective date of these instructions, whichever is earlier. 14F. Master Circular - Customer Service in Banks dated July 1, 2015 Para Levy of service charges Penalty, if charged, for non-compliance of material graph terms and conditions of loan contract by the 6 borrower shall be treated as ‘penal charges’ and shall not be levied in the form of ‘penal interest’ that is added to the rate of interest charged on the advances. There shall be no capitalisation of penal charges i.e., no further interest computed on such charges. However, this will not affect the normal procedures for compounding of interest in the loan account. The REs shall not introduce any additional component to the rate of interest and ensure compliance to these guidelines in both letter and spirit. The REs shall formulate a Board approved policy on penal charges or similar charges on loans, by whatever name called. The quantum of penal charges shall be reasonable and commensurate with the non-compliance of material terms and conditions of loan contract without being discriminatory within a particular loan / product category. The penal charges in case of loans sanctioned to ‘individual borrowers, for purposes other than business’, shall not be higher than the penal charges applicable to non-individual borrowers for similar non-compliance of material terms and conditions. The quantum and reason for penal charges shall be clearly disclosed by REs to the customers in the loan agreement and most important terms & conditions / Key Fact Statement (KFS) as applicable, in addition to being displayed on REs website under Interest rates and Service Charges. Whenever reminders for non-compliance of material terms and conditions of loan are sent to borrowers, the applicable penal charges shall be 15communicated. Further, any instance of levy of penal charges and the reason therefor shall also be communicated. These instructions shall come into effect from January 1, 2024. REs may carry out appropriate revisions in their policy framework and ensure implementation of the instructions in respect of all the fresh loans availed/ renewed from the effective date. In the case of existing loans, the switchover to new penal charges regime shall be ensured on next review or renewal date or six months from the effective date of these instructions, whichever is earlier. G. Master Circular - Loans and Advances - Statutory and Other Restrictions dated July 1, 2015 Para Guidelines on Fair The quantum and reason for penal charges shall be graph Practices Code for clearly disclosed by REs to the customers in the loan 2.5 Lenders agreement and most important terms & conditions / Key Fact Statement (KFS) as applicable, in addition to being displayed on REs website under Interest rates and Service Charges. Whenever reminders for non-compliance of material terms and conditions of loan are sent to borrowers, the applicable penal charges shall be communicated. Further, any instance of levy of penal charges and the reason therefor shall also be communicated. 16

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