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B P Securities India Pvt Ltd Repay Loan

Fair Practice Code

B P Securities (India) Private Limited — in accordance with the Chapter III – Responsible Business Conduct Directions, 2025 issued by the Reserve Bank of India

1. Introduction and Objective

B P Securities (India) Private Limited ("the Company" or "BPS") is a Non-Banking Financial Company registered with the Reserve Bank of India ("RBI") as an Investment and Credit Company ("ICC") and classified under the Base Layer pursuant to the Scale Based Regulatory Framework issued by the RBI.

The Fair Practice Code ("FPC") has been formulated in accordance with the Chapter III – Responsible Business Conduct Directions, 2025 issued by the Reserve Bank of India ("RBI") dated November 28, 2025 from time to time with the objective of promoting fair, transparent, and ethical practices in all dealings with borrowers and customers.

The Company is committed to ensuring responsible lending practices, transparency in communication, protection of customer interests, and fair treatment of borrowers throughout the lending lifecycle, including loan application, appraisal, sanction, disbursement, servicing, recovery, and grievance resolution.

The objective of this Fair Practices Code is to:

  • Ensure fair and transparent dealings with customers and provide adequate information regarding loan products, terms, conditions, charges, and obligations;
  • Promote responsible lending practices and ensure that customers are treated with dignity, fairness, and respect;
  • Establish appropriate standards for customer communication, confidentiality, grievance redressal, and recovery practices;
  • Ensure compliance with applicable regulatory requirements and foster trust and confidence among customers.

The provisions of this Fair Practices Code shall be read in conjunction with other applicable policies of the Company, including the Interest Rate Policy, Recovery Policy, Outsourcing of Financial Services Policy, Grievance Redressal Mechanism, and other internal policies approved by the Board of Directors, as amended from time to time.

2. Scope

This Code applies to all lending activities undertaken by the Company and shall govern every stage of the customer relationship.

The provisions of this Code shall apply to:

  • all applicants, prospective customers, existing customers and borrowers of the Company;
  • all loans originated through the Company's digital lending application, website and other authorised channels;
  • all the employees, directors, officers and management personnel involved in lending operations;
  • outsourced service providers, Collection agencies and other third parties acting on behalf of the Company, to the extent applicable; and
  • any other person authorised to represent the Company in relation to customer-facing activities.

3. Definitions

Shall mean any individual who approaches the Company for availing a loan facility or any individual who has obtained or is in the process of obtaining a loan facility from the Company.

For this Code, Customer shall include:

  • prospective borrowers;
  • existing borrowers;
  • co-applicants, wherever applicable;
  • authorised representatives of customers; and
  • persons interacting with the Company in relation to its lending services.

Means the annualised cost of credit to the borrower, expressed as an annual percentage, which includes the interest rate and all other charges directly associated with the credit facility, excluding contingent charges, in accordance with the applicable directions issued by the Reserve Bank of India.

Means an individual to whom a loan facility has been sanctioned or disbursed by the Company pursuant to execution of applicable loan documentation and completion of required regulatory and internal processes.

Means the period specified by the Company, in accordance with the applicable directions issued by the Reserve Bank of India, during which the borrower may exit the digital loan by repaying the principal amount and the proportionate Annual Percentage Rate (APR), without any penalty, subject to such terms and conditions as may be specified by the Company.

Means any complaint, concern, dissatisfaction or dispute expressed by an applicant, customer or borrower relating to the Company's products, services, lending practices, customer service, recovery practices, conduct of its employees or authorised representatives, or any other matter connected with the Company's business, whether received in writing, electronically, telephonically or through any other recognised communication channel.

Means a statement containing the key facts of the loan in a standardised format, provided to the borrower before the execution of the loan agreement, enabling the borrower to make an informed financial decision, in accordance with the applicable directions issued by the Reserve Bank of India.

Means any credit facility or financial assistance provided by the Company to an eligible customer, including unsecured personal loans, through the Company's authorised digital lending application, website or any other approved distribution channel, in accordance with applicable laws and regulatory requirements.

Means the legally binding agreement executed between the Company and the borrower, whether in physical or electronic form, setting out the terms and conditions governing the loan facility, including the loan amount, interest rate, repayment obligations, applicable fees and charges, rights and obligations of the parties, events of default and other applicable provisions.

Means the charges levied by the Company on a borrower for non-compliance with the material terms and conditions of the loan agreement, including default or delay in repayment, in accordance with the applicable directions issued by the Reserve Bank of India. Penal Charges shall not be levied in the form of penal interest and shall be reasonable, transparent, non-discriminatory and duly disclosed to the borrower.

Means the communication issued by the Company to an applicant conveying the approval of a loan, setting out the principal terms and conditions of the loan facility, including the sanctioned amount, rate of interest, Annual Percentage Rate (APR), tenure, repayment schedule, applicable fees and charges, security requirements (if any), penal charges, and such other terms as may be required under applicable laws and the directions issued by the Reserve Bank of India.

4. Commitment of the Company

The Company is committed to maintaining the highest standards of fairness, transparency and ethical conduct in all customer interactions.

Accordingly, the Company shall endeavour to:

provide clear and understandable information regarding its products and services;

avoid misleading, unfair or coercive business practices;

ensure that loan decisions are based on objective and documented criteria;

maintain confidentiality of customer information;

establish accessible grievance redressal mechanisms;

treat customers with dignity and respect at all stages of the lending relationship;

continuously improve operational processes and customer service standards;

comply with all applicable laws, RBI directions, regulatory guidelines and internal governance standards relating to lending operations; and

periodically review this Code to ensure alignment with evolving regulatory requirements and industry best practices.

5. Non-Discrimination Policy

6. Loan Application and Processing

All loan applications shall be made through BPS's approved digital channels (website/app). The application interface shall clearly list the document checklist, processing fees (if any), indicative interest rate, applicable APR, service charges, and other material terms. This enables borrowers to compare BPS's offering with others. Application materials (form or online form) will also highlight the Grievance Redressal mechanism and eligibility criteria.

All loan application materials, questions and communications shall be in English or in a language understood by the applicant. (BPS may provide Hindi or other vernacular versions as needed.)

BPS shall issue an acknowledgement of receipt to every applicant immediately upon receiving a completed application (via SMS/email/portal notification). The acknowledgement shall include an application reference number, date/time of receipt, and (where possible) an estimated timeline for processing.

BPS will process and dispose of loan applications within a reasonable period in accordance with approved policies. If processing takes longer than expected, BPS will update the applicant with reasons and expected timeline.

7. Loan Appraisal and Sanction

  • Objective Credit Appraisal: BPS shall appraise loan applications by objectively assessing the borrower's creditworthiness (repayment capacity, income, credit history, etc.) based on a Board-approved credit policy. All appraisals will be non-discriminatory and consistent with applicable laws.
  • Sanction Letter: If the loan is approved, BPS shall communicate this in writing to the borrower (Sanction Letter or equivalent electronic message). This communication shall specify, in simple terms: sanctioned amount, tenure, annualised interest rate and its calculation method (APR), monthly/daily repayment schedule, security (if any), all fees and charges (processing fee, service charges, etc.), penal charges for default, and prepayment terms. It shall also state that acceptance of the terms is required.
  • Borrower Acceptance: The borrower must acknowledge acceptance of the loan terms in writing (signed or electronic acknowledgement) before disbursement. A record of this acceptance will be kept in BPS's files.
  • Loan Documents: Prior to or at disbursement, BPS will furnish the borrower with a copy of the fully executed Loan Agreement along with Key Facts Statement and all schedules/annexures. The Loan Agreement shall clearly identify any default interest rate or penal charge for late payment in bold. This ensures the borrower has a complete set of loan documents.
  • Interest Calculation: The interest rate shall be calculated on an annualised basis. Any default (penal) interest or charges shall be separately mentioned and calculated only on the overdue amount (not on the entire loan).

8. Disbursement and Changes in Terms

  • Disbursement: Disbursement of the sanctioned loan amount shall occur only after the borrower has completed all documentation and acceptances. Funds will be transferred to the borrower's bank account.
  • Notice of Changes: BPS will give prior notice to the borrower (via SMS/email and posting on customer portal) of any changes to material terms, including interest rate, repayment schedule, fees, service charges, prepayment/foreclosure charges. All changes will be made prospectively only. A suitable clause for this effect will be included in the Loan Agreement.
  • Prospective Application: Any revision in interest rates or service charges shall be applied prospectively only.

9. Key Facts Statement (KFS)

  • Provision of KFS: In line with RBI guidelines, BPS shall provide every prospective borrower a Key Facts Statement before execution of the Loan Agreement. The KFS will be in RBI's standard format and written in simple language understood by the borrower.
  • Contents of KFS: The KFS will include all key loan details: principal, tenure, all-inclusive APR (with computation example), daily installment schedule, break-up of principal and interest in an amortisation schedule, all fees and charges (processing fees, penalty charges, prepayment charges, etc.).
  • Unique Reference & Validity: Each KFS will have a unique reference number. For short-tenor loans (e.g. tenors less than 7 days), the KFS shall be valid for at least 1 working day. For loans equal or more than 7 days, validity shall be at least 3 working days.
  • Acknowledgement: BPS will explain the KFS content to the borrower's satisfaction before sanction. The borrower's acknowledgement (digital or signed) that they have understood the KFS must be obtained and filed.
  • No Undisclosed Charges: No prepayment or other charges not specifically disclosed in the KFS (and loan documents) shall be levied.

10. Rate of Interest

  • Board-Approved Model: BPS shall follow a Board-approved interest-rate model taking into account cost of funds, operational costs, credit risk, loan tenor, and margin. Different risk segments (e.g. credit scores or employment profiles) may have different rates under a transparent risk-based pricing approach.
  • Disclosure: The Company shall disclose the basis of its interest rate determination to borrowers. The borrower will be informed of the annualised interest rate applicable to their loan in the application acknowledgement, sanction letter and KFS. The methodology for any differential rates will be explained.
  • Website Publication: BPS will publish its current lending rates (or rate ranges), risk grading approach and interest-rate formula on its website for reference. This website disclosure will be updated promptly whenever rates change.
  • Annualised Rate: All interest rates shall be expressed in annualised terms (APR) so the customer knows the true cost of credit.

11. Penal Charges

Penal Charges may be levied only for non-compliance with the material terms and conditions of the Loan Agreement, including default or delay in repayment or any other material breach by the borrower. Penal Charges shall not be imposed for technical, procedural or non-material defaults.

Penal Charges shall be levied only as charges and shall not be imposed in the form of Penal Interest. Such charges shall not be capitalised, compounded or added to the outstanding principal for the purpose of charging further interest.

The quantum of Penal Charges shall be reasonable, proportionate to the nature and gravity of the default, transparent and non-discriminatory among similarly placed borrowers. The Company shall periodically review the framework governing Penal Charges to ensure continued compliance with applicable regulatory requirements.

The applicable Penal Charges, the circumstances under which they become payable and the manner of their computation shall be clearly disclosed to the borrower in the Sanction Letter, Key Fact Statement (KFS), Loan Agreement and such other loan documents as may be applicable. The schedule of Penal Charges shall also be displayed on the Company's website.

Whenever Penal Charges are levied, the Company shall promptly inform the borrower of the nature of the default, the amount of Penal Charges imposed and the manner of recovery through appropriate communication channels.

12. Prepayment and Foreclosure

13. Recovery Practices

BPS is committed to fair, respectful and lawful recovery of dues. All recovery actions will comply with applicable RBI guidelines and the law. In particular:

No Harassment

BPS and its agents will not use coercion, abuse or intimidation. No calls at odd hours. They will not use profanity, threats of violence, or public shaming.

Trained Staff

All recovery personnel (employees or agents) will be trained in courteous collection practices. They will treat borrowers with dignity and explain outstanding dues and implications of default.

Legal Compliance

All legal steps (e.g. demand notices, repossession) will be strictly in accordance with the Loan Agreement and law. BPS will only employ agents registered under RBI/DoT guidelines subject to the applicability and will monitor them for compliance.

Third-Party Agents

Any third-party recovery agency engaged by BPS must sign a deed of "non-abuse". BPS remains fully responsible for acts of its agents.

14. Grievance Redressal Mechanism (GRM)

At BPS, customer satisfaction forms an integral part of our lending philosophy. The Company believes that an effective grievance redressal framework is essential for maintaining transparency, fairness and long-term customer trust. Every complaint received from a customer is treated with due importance and is resolved in a fair, objective and time-bound manner.

The grievance redressal mechanism has been established to ensure that concerns arising at any stage of the customer relationship—including loan application, onboarding, credit assessment, sanction, documentation, disbursement, servicing, repayment, collections, closure of loan accounts or any other service rendered by the Company or its authorised service providers—are addressed promptly and efficiently.

No customer shall be subjected to discrimination or unfair treatment for raising a complaint. Filing a grievance shall not adversely affect the customer's relationship with the Company or the consideration of any future service request.

14.1 Modes for Lodging Grievances

Customers may register their complaints through any of the following channels:

  • Customer Care Email
  • Customer Support Helpline
  • In-app / Website Contact Form
  • Written communication to the Registered Office
  • Any other communication channel officially notified by the Company from time to time

The Company encourages customers to provide adequate details, including their registered mobile number, loan account/reference number (where applicable), nature of grievance and supporting documents to facilitate timely resolution.

14.2 Complaint Resolution Process

Upon receipt of a complaint, the Company shall:

  1. register the complaint in its internal grievance management system;
  2. provide an acknowledgement along with a reference number;
  3. examine the matter independently and obtain necessary information from relevant departments or authorised service providers, wherever required;
  4. communicate any additional information required from the customer; and
  5. provide a reasoned response after completion of the review.

Complaints involving operational errors, system issues, service deficiencies or conduct of employees, collection agencies or outsourcing partners shall be investigated objectively and corrective action shall be initiated wherever necessary.

14.3 Resolution Timelines

14.4 Escalation Matrix

For any queries, requests, or complaints, customers may contact our Customer Care Team through the following channels:

If you are not satisfied with the response received from Customer Care or if your complaint remains unresolved within the above timeline, you may escalate the matter to our Grievance Officer.

  • Name: Mr. Rajeev
  • Designation: Grievance Officer
  • Email: grievance@myinstafunds.com
  • Resolution Timeline: The Grievance Officer shall review the complaint and endeavour to provide a final response within 15 working days from the date of escalation.

If the grievance remains unresolved after review by the Grievance Officer, you may escalate the matter to the Management of B P Securities (India) Private Limited.

  • Escalation Authority: Board-designated Nodal Officer
  • Email: Compliance@myinstafunds.com
  • Resolution Timeline: The matter shall be reviewed and an appropriate response shall be provided within 30 working days from receipt of the complaint.

If your grievance remains unresolved after exhausting the Company's internal grievance redressal mechanism, or if you are not satisfied with the resolution provided, you may approach the Reserve Bank of India under the RBI Integrated Ombudsman Scheme, 2021, subject to the eligibility conditions and procedure prescribed under the Scheme.

Details of the RBI Integrated Ombudsman Scheme are available on the official website of the Reserve Bank of India at www.rbi.org.in.

Customers may lodge complaints with the Reserve Bank of India through the Complaint Management System (CMS), after exhausting the Company's internal grievance redressal mechanism or where no response has been received within the prescribed period under the RBI Integrated Ombudsman Scheme.

14.6 Monitoring and Continuous Improvement

The Company shall maintain records of all grievances received, actions taken and timelines for resolution. Periodic analysis of complaints shall be undertaken to identify recurring issues, improve operational processes, strengthen internal controls and enhance customer experience.

The Board of Directors and senior management shall receive periodic reports on customer grievances, significant trends, root causes and corrective measures implemented, enabling continuous improvement of the Company's service standards.

14.7 Conduct Expectations

Employees and authorised representatives shall:
  • communicate politely and professionally;
  • provide accurate and complete information;
  • avoid making misleading commitments or assurances;
  • maintain confidentiality of customer information;
  • escalate complaints requiring higher approval without unnecessary delay; and
  • comply with this Policy and all applicable regulatory requirements.
Employees and authorised representatives shall not:
  • misrepresent facts or suppress material information;
  • discourage customers from lodging complaints;
  • delay resolution without reasonable cause;
  • disclose confidential customer information except as permitted under applicable law; or
  • engage in any unfair, coercive or discriminatory conduct while addressing grievances.

15. General Provisions

The Company shall refrain from interfering in the affairs of the applicant, customer or borrower except for the purposes provided under the Loan Agreement or where such action is warranted under applicable laws, regulatory directions, or where any material information, not previously disclosed by the borrower, comes to the notice of the Company.

Where the Company receives a request from a borrower for transfer of the loan account to another lender, the Company shall communicate its decision, including its consent or objection, if any, within 21 days from the date of receipt of such request or within such period as may be prescribed under applicable laws or regulatory directions. Any such transfer shall be processed in accordance with the terms of the Loan Agreement and applicable law.

This Fair Practices Code, as approved by the Board of Directors, shall be published on the Company's website for the information of applicants, customers, borrowers and other stakeholders. The Company may make the Code available in additional regional languages, wherever considered appropriate.

16. Review and Amendment

This Code shall be reviewed periodically by the Board of Directors to ensure its continued adequacy, effectiveness and compliance with applicable laws and regulatory requirements.

The Company may amend, modify or update this Code from time to time to give effect to changes in applicable laws, regulations, directions or business requirements. Any material amendment to this Code shall be subject to the approval of the Board of Directors.

The latest approved version of this Code shall be hosted on the Company's website and shall supersede all previous versions.