Constitutional Compliance & Consumer Fair Practices

As a corporate Lending Service Provider (LSP) and Corporate DSA, our entire origination architecture is hardcoded to comply with the 2025 RBI guidelines:

• 100% Direct Disbursals: Funds move strictly from the Regulated Entity (RE) bank account to the borrower's verified bank account without any third-party pool or escrow accounts.
• Standardized Key Fact Statement (KFS): Mandatory disclosure of Annual Percentage Rate (APR), processing fees + 18% GST, penal interest, and total cost of credit prior to contract execution.
• 3-Day Look-Up / Cooling-Off Window: Borrowers can exit sanctioned facilities within 3 days without any prepayment penalty by returning the principal plus proportionate interest.
• Statutory Grievance Redressal: Designated Principal Nodal Officer with 30-day SLA and escalation route to RBI Integrated Ombudsman Scheme (RB-IOS).

As a designated Data Fiduciary, H&M Assets safeguards borrower and partner privacy under the DPDP Act 2023:

• AWS Mumbai Sovereign Residency: All database clusters, Aadhaar XML tokens, and KYC assets reside exclusively within India (AWS Region ap-south-1).
• No Mobile Harvesting: Explicit prohibition of accessing borrower contact address books, gallery photos, or location logs. Camera is used exclusively for one-time live KYC selfies.
• Data Principal Rights: Full right to access data summaries, request correction, or request erasure once statutory loan audit retention expires.
• Consent Manager: Purpose-specific, granular opt-in consent for bureau checks and Account Aggregator pulls.

Architected from Day-1 to be NBFC-core compatible for seamless transition into an own-book financial institution:

• DLG 5% Regulatory Cap: Full support for Default Loss Guarantee (DLG) / First Loss Default Guarantee (FLDG) compliance capped at 5% of portfolio volume.
• CIC Credit Bureau Reporting: Automatic monthly reporting to CIBIL, Experian, CRIF High Mark, and Equifax.
• DPD / NPA Asset Classification: Daily DPD tracking with SMA-0 (1-30 DPD), SMA-1 (31-60 DPD), SMA-2 (61-90 DPD), and NPA classification at 90+ DPD.
• Fair Debt Recovery Code: Calling hours restricted to 08:00 AM - 07:00 PM. Zero intimidation or harassment of borrower relatives.

Distribution of retail, motor, health, and term loan protection insurance follows IRDAI guidelines:

• No Compulsory Loan Bundling: Insurance purchase is completely voluntary and never made a pre-condition for loan sanction or interest discounts.
• Section 41 Insurance Act, 1938: Strict prohibition of rebates — no commission sharing or illegal cashbacks given to prospective policyholders.
• 15 / 30-Day Free-Look Period: Policyholders maintain the statutory right to review terms and return policies for full refund within the free-look window.
• POSP & Agent Accreditation: Certified Point-of-Sale Persons adhere to standardized training, fit-and-proper criteria, and digital proposal execution.