Restructuring Policy

INTRODUCTION

The breakout of the COVID-19 Pandemic has resulted in unprecedented situation wherein the whole economy had come to a standstill impacting multiple sectors. This has in turn impacted the income of many borrowers and has weakened the capability of customers to repay the borrowed debts. The RBI to provide a further relief to customers at large and to mitigate the burden of debt brought about by disruptions on account of COVID-19 pandemic and to ensure the continuity of viable businesses and provide support to borrowers, has permitted Banks, financial institution and NBFC’s to grant certain relief measures for certain period to the borrowers. Based on RBI policy, Company has adopted this Framework Policy for its Borrowers to provide relief.

Background

The RBI in March’20 published a notification through which it allowed Institutions to provide a moratorium of 3 months to the borrowers, which was further extended by Hon. RBI for a period of another 3 months which ended on 31st August 2020, which was availed by many customers. The RBI later released the Resolution Framework 1.0 for COVID-19 pandemic related Stress dated 6th August 2020 bearing no. RBI/2020-21/16 DOR. No. BP. BC/3/21.04.048/2020-21, for helping customers in stress due to COVID-19 Related stress. Further the RBI released the Resolution Framework 2.0 for COVID-19 pandemic related Stress dated 5th May 2021 bearing No. RBI/2021-22/31 DOR.STR.REC.11/21.04.048/2021-22 where inter alia certain regulatory measures were announced to mitigate the burden of debt servicing brought about by disruptions on account of COVID-19 pandemic. As per the notification released by RBI, all commercial banks (including regional rural banks, small finance banks and local area banks), All Co-operative banks, All-India Financial Institutions, and NBFCs (including housing finance companies) are permitted to implement a Resolution plan for the period of 1st April 2021 to 30th September 2021.

Eligibility

  1. ‘Borrowers’ or ‘Customers’ for the purpose of this policy shall mean all customers of EarlySalary Services Private Limited (“the Company”) who have availed a loan before 31st March 2021.
  2. The Customers with overdue of not more than 30 days on 31st March 2021 will only be eligible under this policy.
  3. Any loans availed post 31st March 2021 shall not be eligible under this policy.
  4. Customers who have availed any Resolution under previous Resolution Framework 1.0 shall only be eligible to extend the Moratorium Period for a maximum cumulative period of 2 years.
  5. All the customers impacted due to COVID-19 Pandemic can apply for the Resolution Plan.
  6. The Customers who submit relevant documents to the satisfaction of the company.
  7. Customer who approach the Company only during ‘Period’ of 1st April 2021 to 30th September 2021 shall be eligible.

Resolution Options

The Company upon assessment of impact and stress faced by customer on account of COVID-19 Pandemic may offer at its sole discretion any of the following resolutions :

  1. Rescheduling of Payment.
  2. Granting of moratorium, maximum for a period of 2 years.
  3. Any other waiver or restructuring of Interest or Charges.
No Compromise settlement can be done under this Policy.

Process

The customer can express his/her intention of availing the resolution under this Policy any time during the Period. The customers can communicate their request either on phone, chat or email or any other mean provided by the Company. Once the request is submitted with the requisite documents and is accepted by the company, the customer will be requested to accept the terms. The Tenor of the loan, pursuant to rescheduling of the payment being offered will be renewed/extended for such further period. The Company shall communicate the customer its decision regarding any resolution under this Policy within 30 (Thirty) days from the receipt of application and all the documents from the Customer.

Pursuant to the Framework Policy, tenor of the loan can be increased by the period of Moratorium granted and the NACH or ECS mandate will not be presented during this period for such eligible customers, however in case of Tenor of the loan being increased pursuant to rescheduling of the payment, NACH or ECS mandate shall continue to be presented for such further extension period for revised EMIs. Granting of any Moratorium Period shall be at sole discretion of the Company, however in no case shall it be more than 2 years.

In case, the customer is willing to make an immediate part-payment pursuant to any resolution under this Policy the Company shall at its sole discretion may provide waiver in any amount.

In case, the customer decides to pre-pay during any resolution plan offered to him/her under this Policy, he/she will be eligible for interest benefit on his/her loans and interest will be charged only till the date of repayment. There will be no prepayment penalty in case he/she decided to prepay his/her loan during the period of this resolution plan.

During the period of any resolution offered under this policy, the interest will continue to be charged at the current rate or revised rate and the new repayment schedule will reflect the new EMI amount and dates.

In case, any facility being provided to the customer under this plan, the borrower will have to execute and provide to the satisfaction of the Company any document deemed necessary by the Company.

Upon successful repayment of loan for which Moratorium or rescheduling of payment has been offered, granting of any new loan shall be at sole discretion of the company and shall be subject to Company’s prevalent terms and conditions.

Reporting to Credit Information Companies

The loans for which any resolution has been given under this Policy will be reported as ‘Restructured due to COVID-19’ to Credit Information Companies (CICs) by the Company and same status shall be reflected on the Credit Reports of the customer.

Any default repayment pursuant to any resolution given under this Policy will qualify as a default for the purposes of supervisory reporting and reporting to Credit Information Companies (CICs) by the Company which will be done in accordance with the ‘Master Circular - Prudential norms on Income Recognition, Asset Classification and Provisioning pertaining to Advances dated 1st July, 2015 published by the Reserve Bank of India.

Implementation and Review of the Policy

The Framework Policy is applicable from 1st April 2021. The Executive Directors are authorized to approve any operational procedures/guidelines as may be required to implement the policy and make any changes to the policy in line with the directions/guidelines issued by RBI from time to time.

The policy shall be reviewed as and when considered necessary by the Board of Directors of the Company.