Seo Title

INTEREST RATE POLICY

INTEREST RATE POLICY
01
INTRODUCTION

This Interest Rate Policy (“Policy”) is formulated by Samraat Finlease Private Limited (“Company”), a Non-Banking Financial Company registered with the Reserve Bank of India (“RBI”), in accordance with the applicable regulatory framework governing NBFCs, including the Fair Practices Code issued by the RBI, as amended from time to time. The Policy establishes a transparent and robust framework for determining interest rates and other applicable charges in respect of the Company’s lending activities. It also sets out the principles for risk-based pricing, ensuring that interest rates are determined based on the borrower’s risk profile, cost of funds, operational costs, and prevailing market conditions. This Policy aims to ensure consistency, transparency, and fairness in the Company’s interest rate practices, while maintaining compliance with regulatory requirements and safeguarding the Company’s financial and risk management objectives.

02
OBJECTIVE OF THE POLICY

The objective of this Policy is to establish a clear, consistent, and transparent framework for determination of interest rates and other applicable charges for the Company’s lending activities.

The Policy sets out the methodology for arriving at benchmark interest rates and the principles for applying appropriate spreads based on the borrower’s risk profile, cost of funds, operational costs, and prevailing market conditions, in order to determine the final interest rates charged to customers.

The Policy further aims to ensure that the Company’s interest rate practices are fair, non-discriminatory, and in compliance with applicable regulatory requirements.

The Company shall ensure that interest rates are applied in a non-discriminatory manner, except to the extent justified by risk-based pricing principles.

03
REVIEW OF THE POLICY

This Policy shall be reviewed at least annually, or earlier if required, to ensure its continued relevance and effectiveness.

An earlier review may be undertaken in the event of any regulatory changes, changes in market conditions, modifications in the Company’s business strategy, or any other material developments impacting the Company’s lending practices.

Any amendments to this Policy shall be subject to approval in accordance with the Company’s internal governance framework.

04
ORGANISATION STRUCTURE

Board of Directors The Board of Directors shall have overall oversight of this Interest Rate Policy of Samraat Finlease Private Limited (“Company”) and shall approve the broad framework governing the determination of interest rates, including the Interest Rate Model and the risk gradation approach.

The Board shall also ensure that the Policy is implemented in compliance with applicable regulatory requirements and aligned with the Company’s risk management framework.

Management The Management shall be responsible for the implementation and operationalization of this Policy in accordance with the framework approved by the Board. This includes the determination of benchmark interest rates, application of appropriate spreads, and adherence to risk-based pricing principles.

Business Units The business units may determine lending rates within the approved framework of this Policy, subject to the internal delegation of authority and control mechanisms of the Company, including application of appropriate spreads over benchmark rates based on the borrower’s risk profile and other relevant factors.

Any deviations from the principles or framework specified under this Policy shall require prior approval in accordance with the Company’s internal governance and delegation of authority framework.

05
INTEREST RATE MODEL

  • Interest rates shall be determined in accordance with this Policy and applicable regulatory requirements, and shall be reviewed periodically.
  • Interest rates shall be based on relevant product features, including tenor, repayment structure, payment frequency, and any moratorium or structured terms.
  • Pricing shall be driven by cost and risk considerations, including cost of funds, market conditions, operational costs, and applicable margins.
  • Risk-based pricing shall be adopted, considering the borrower’s credit profile, repayment capacity, income stability, past track record, and overall creditworthiness.
  • The Company may charge differential interest rates for the same product and tenor, based on the above factors.
  • Interest rates may be fixed or floating. Floating rates shall be linked to an internal benchmark rate, the methodology of which shall be periodically reviewed and documented, and rates may be reset at such intervals as determined by the Company.
  • Interest shall be computed on the daily outstanding balance and applied at such rests as may be specified.
  • The annualised interest rate shall be disclosed at the time of sanction, along with key repayment terms, and the Company shall ensure transparency in the overall cost of borrowing, including disclosure of all applicable charges forming part of the total cost of credit, in accordance with applicable regulatory requirements.
  • Any change in interest rates shall be prospective and communicated to the customer.
  • Structured repayment options may be provided with appropriate pricing adjustments.
  • In case of staggered disbursements, the applicable interest rate shall be determined at each disbursement in accordance with the pricing framework specified under this Policy.

06
Approach for Gradation of Risk

The Company shall adopt a structured approach for gradation of risk for borrowers, which shall form the basis for risk-based pricing.

Risk categorisation shall be based on various parameters, including but not limited to:

  • Credit score and credit history
  • Repayment track record and existing obligations
  • Income level, employment profile, and stability of income
  • Nature and tenure of employment/business
  • Industry risk and geographical considerations
  • Behavioural and portfolio-level risk indicators
Based on the above parameters, borrowers may be classified into appropriate risk categories, and corresponding spreads over the benchmark rate shall be applied.

The risk gradation framework shall be reviewed periodically in line with the Company’s risk management practices and regulatory expectations.

07
Additional Interest, Penal Charges and Other Fees

  • Penal charges (and not penal interest) shall be levied for delay or default strictly in compliance with applicable regulatory requirements, and shall be reasonable, non-compounding, non-capitalised, and not used for revenue enhancement.
  • All penal charges and other fees shall be clearly disclosed in the sanction letter and loan agreement.
  • The Company may levy processing fees, documentation charges, and other applicable charges (including cheque bounce, prepayment/foreclosure, remittance, commitment, and NOC/NDC or security-related charges) as specified in the loan documents, along with applicable taxes (including GST) at prevailing rates.
  • Charges shall be determined based on product structure, customer risk profile, cost of servicing, and prevailing market practices, and may vary on a case-to-case basis in accordance with the Board-approved policy.
  • Interest rates and charges shall be reviewed periodically; any revisions shall be applied prospectively and communicated to customers as per the loan documents.
  • Any waiver or refund of charges shall be at the sole discretion of the Company and shall not be claimed as a matter of right.

08
Website Disclosure

The Company shall disclose this Interest Rate Policy, including the approach for gradation of risk and rationale for charging differential interest rates, on its website, in accordance with applicable regulatory requirements.