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Grievance Redressal Policy.

The Grievance Redressal Policy (GRP) is a mandatory regulatory requirement that ensures customers have a formal, time-bound channel to voice concerns. For an ND-NBFC, the framework is now governed by the RBI (Non-Banking Financial Companies - Internal Ombudsman) Directions, 2026 and the Integrated Ombudsman Scheme. 

 

 

  1. Existing Regulatory Norms (2026) 

Before drafting the policy, you must understand the "Three-Tier" escalation ladder mandated by the RBI: 

Tier 1: Internal Grievance Redressal (GRO) 

  • Designated Officer: Every NBFC must appoint a Grievance Redressal Officer (GRO). 

  • Display Requirements: The name and contact details of the GRO and the Nodal Officer must be displayed in all branches and on the website. 

  • Timeline: The NBFC must provide a final response within 30 days. 

 

Tier 2: Internal Ombudsman (IO) 

  • Applicability: Mandatory for NBFC-NDs with an asset size $\geq$ ₹5,000 Crore (as per the Jan 2026 update). Smaller NBFCs are encouraged but not mandated to have an IO. 

  • Auto-Escalation: If a complaint is "Partially Resolved" or "Wholly Rejected" by the GRO, it must be auto-escalated to the Internal Ombudsman before a final rejection letter is sent to the customer. 

 

Tier 3: RBI Integrated Ombudsman (RB-IOS) 

  • External Escalation: If the customer is dissatisfied with the Tier 1/2 response or receives no response within 30 days, they can approach the RBI Ombudsman via the CMS portal (cms.rbi.org.in). 

  • Mandatory Clause: Every rejection letter from the NBFC must mention the customer's right to approach the RBI Ombudsman. 

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MASTER POLICY: CUSTOMER GRIEVANCE REDRESSAL (CGR) 

DEFINITIONS & SCOPE 

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"Deficiency in Service": Any shortcoming, fault, or inadequacy in the quality, nature, and manner of performance which is required to be maintained by or under any law for the time being in force. 

  • "Complainant": Any customer, borrower, or prospective applicant who has a business relationship with the NBFC. 

  • "Lending Service Provider (LSP)": Any third-party agent or digital platform used by the NBFC for sourcing or recovery. The NBFC assumes absolute responsibility for grievances against LSPs. 

 

 

PURPOSE AND PHILOSOPHY 

This policy aims to minimize instances of customer complaints through proper service delivery and review, and to ensure that when a complaint arises, it is handled with Courtesy, Transparency, and Fairness. 

SFT FINANCE follows the "Right to Grievance Redressal" as a fundamental consumer right, ensuring that: 

  • Customers are fully informed of their avenues for escalation. 

  • Complaints are treated as feedback for systemic improvement. 

  • Resolution is reached within the Statutory 30-day Window. 

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THE THREE-TIER ESCALATION FRAMEWORK 

Tier 1: Front-end Redressal (Level 1 & 2) 

Level 1 (Touchpoints): Customers may lodge complaints via the Mobile App, Website (Helpdesk), or Physical Complaint Book at branches. 

Level 2 (Grievance Redressal Officer - GRO): If the touchpoint fails to resolve the issue within 7 days, it is automatically pushed to the GRO. 

Mandate: The GRO is responsible for a detailed investigation and must issue a "Reasoned Decision" in writing. 

 

Tier 2: The Internal Ombudsman (IO) Mechanism 

The "Safety Net": As an ND-NBFC (especially those scaling toward Systemic Importance), the IO acts as an independent reviewer. 

Mandatory Referral: The GRO cannot reject a complaint or offer a partial settlement without the IO’s concurrence. 

Operational Independence: The IO shall not be part of the Sales or Credit departments. They report directly to the CEO or the Board Committee. 

 

Tier 3: The Reserve Bank Integrated Ombudsman (RB-IOS) 

Final Escalation: If the complaint remains unresolved for 30 days, or the customer is unhappy with the IO's decision, the "Right to Appeal" to the RBI kicks in. 

The "CMS" Link: The NBFC must provide a direct, clickable link to the RBI CMS Portal in every email footer and rejection letter

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SCOPE OF "DEFICIENCY IN SERVICE" (GROUNDS FOR GRIEVANCE) 

To be comprehensive, the policy defines specific triggers for a grievance: 

 

  • Interest & Charges: Non-transparency in Annual Percentage Rate (APR), hidden processing fees, or usurious penal interest. 

  • Asset Security: Delay in returning original Title Deeds/Vehicle NOCs beyond 15 days of loan closure (subject to ₹5,000/day penalty as per latest RBI norms). 

  • Third-Party Conduct: Harassment by Recovery Agents or Lending Service Providers (LSPs). 

  • Credit Reporting: Incorrect data submission to CIBIL/Experian and failure to rectify within 30 days. 

  • Digital Fraud: Unauthorized transactions or data breaches on the NBFC's Fintech platform.

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STANDARD OPERATING PROCEDURE (SOP) FOR REDRESSAL 

Acknowledgment & Tracking 

Every complaint (verbal or written) must be logged in the Centralized Complaint Management System (CCMS). 

A Unique Ticket ID is sent via SMS/Email within 24 hours. 

 

Investigation & Interaction 

The GRO must examine the loan documents, call recordings (in case of collection complaints), and system logs. 

The customer must be given an opportunity to present their case if the amount in dispute exceeds a certain threshold. 

 

Resolution & Communication 

Acceptance: If SFT Finance is at fault, immediate redressal (refund of charges, correction of credit score) is initiated. 

Rejection: If SFT Finance rejects the claim, the letter must contain: 

The specific facts of the case. 

The IO’s observations. 

The mandatory "RBI Ombudsman Clause." 

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​RECOVERY AGENT CONDUCT & GRIEVANCES 

Given the sensitivity of rural marketing and fintech collections, this section is critical: 

 

  • Time of Call: Strictly between 08:00 AM and 07:00 PM. 

  • Privacy: No calling of relatives/friends unless they are co-applicants/guarantors. 

  • Zero Tolerance: Any physical threat or public shaming results in immediate suspension of the agent and an auto-resolution of the customer's grievance in their favor. 

 

​BOARD OVERSIGHT & REPORTING 

Quarterly Disclosure to the Board: 

The Board shall review a "Grievance Heatmap" containing: 

 

  • Ageing Analysis: Number of complaints pending for >15, >21, and >30 days. 

  • Category Analysis: Which products (e.g., Personal Loans vs. Business Loans) attract the most complaints. 

  • IO Disagreement: Instances where the Board/Management disagreed with the Internal Ombudsman. 

 

Annual Disclosure: 

In the Annual Report, the NBFC shall publish a summary of complaints as per the format prescribed in the RBI Master Directions. 

 

​MANDATORY CONTACT DISPLAY (FOR SFT Finance) 

To be compliant with 2026 display norms, the following must be in a 12-point font on the website footer: 

Grievance details

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Comprehensive Customer Grievance Redressal Policy and Charter 

 

1. Policy Statement 

 

SFT Finance affirms that Customer Grievance Redressal is both a statutory obligation and a strategic priority. This policy ensures compliance with the Reserve Bank of India’s Integrated Ombudsman Scheme (2026) and establishes a transparent, fair, and time‑bound mechanism for handling customer complaints. Grievance redressal is not only about compliance but also about building trust, improving service delivery, and strengthening the reputation of the Non‑Banking Financial Company (NBFC). 

 

2. Objectives 

  • Courtesy, Transparency, and Fairness: Every complaint must be handled with respect and openness. 

  • Multi‑Tier Escalation: Customers have clear avenues to escalate unresolved issues. 

  • Systemic Feedback: Complaints are treated as opportunities to improve processes. 

  • Zero Tolerance for Misconduct: Any harassment or unethical conduct is acted upon immediately. 

  • Regulatory Disclosure: Periodic reporting to the Board and regulators ensures accountability. 

 

Each objective is measurable: acknowledgment within the timeframe as guided by the regulator from time to time, including quarterly Board review, and annual public disclosure. 

 

 

3. Governance Framework 

  • Board Oversight: The Board reviews a grievance heatmap quarterly, analyzing complaint categories, resolution timelines, and systemic issues. 

  • Chief Executive Officer Accountability: The Internal Ombudsman reports directly to the CEO or a designated Board Committee. 

  • Independent Internal Ombudsman: The Ombudsman is operationally independent, not part of sales or credit, ensuring impartiality. 

  • Compliance Integration: Grievance data feeds into enterprise risk management and compliance audits. 

 

4. Escalation Ladder 

  • Tier 1 – Grievance Redressal Officer (GRO) 

  • Complaints can be lodged via mobile application, website helpdesk, or physical complaint book. 

  • GRO must issue a reasoned decision within 30 days. 

  • Tier 2 – Internal Ombudsman (IO) 

  • Mandatory referral before rejection or partial settlement. 

  • IO concurrence is required for closure. 

  • Tier 3 – Reserve Bank of India Ombudsman 

  • Customers may appeal via the RBI CMS portal (cms.rbi.org.in). 

  • Rejection letters must include the RBI clause and CMS link. 

This ladder ensures no complaint is prematurely closed without independent review. 

 

5. Scope of Grievances 

Grievances may arise from: 

  1. Interest and Charges: Hidden fees, non‑transparent Annual Percentage Rates, or excessive penal interest. 

  1. Title Deeds and No Objection Certificates: Delay in returning documents beyond 15 days of loan closure, subject to ₹5,000/day penalty. 

  1. Recovery Agent Conduct: Harassment, threats, or contacting relatives not linked to the loan. 

  1. Credit Bureau Reporting: Incorrect data submission to CIBIL/Experian and failure to rectify within 30 days. 

  1. Digital Fraud: Unauthorized transactions or breaches on fintech platforms. 

Illustrative examples are included in annexures for clarity. 

 

6. Standard Operating Procedure for Redressal 

  • Acknowledgment: Every complaint is logged in the Centralized Complaint Management System. A unique ticket ID is sent within 24 hours. 

  • Investigation: GRO examines loan documents, call recordings, and system logs. Customers are given hearings for disputes above a threshold. 

  • Resolution: 

  • If fault is confirmed, immediate redressal (refund, correction of credit score) is initiated. 

  • If rejected, the letter must cite facts, IO’s observations, and the RBI clause. 

This SOP ensures transparency and fairness at every stage. 

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7. Recovery Agent Conduct 

  • Calls restricted to 08:00–19:00 hrs. 

  • No contact with relatives unless they are co‑applicants or guarantors. 

  • Zero tolerance for threats or public shaming. Violations result in immediate suspension and auto‑resolution in the customer’s favor. 

  • Agents undergo annual certification and training on ethical conduct. 

 

8. Mandatory Contact Display 

Website footer (12‑point font) must display: 

  • Grievance Redressal Officer: Name, designation, address, phone, email. 

  • Principal Nodal Officer: Name, email.  

  • Reserve Bank of India Ombudsman: CMS link + Toll‑Free 14448. 

Branches must display the same information prominently. 

 

Customer Charter  Our Commitment 

SFT Finance commits to uphold the highest standards of customer service and grievance redressal. Customers are entitled to clear information, respectful treatment, timely resolution, and escalation rights. 

Service Standards 

  • Transparency: All charges and terms disclosed upfront. 

  • Responsiveness: Acknowledgment within 24 hours; resolution within 30 days. 

  • Fairness: Independent review by Internal Ombudsman. 

  • Accountability: Board oversight and public disclosure. 

Customer Rights 

  • Right to lodge complaints via multiple channels. 

  • Right to receive a unique complaint ID. 

  • Right to appeal to the RBI Ombudsman. 

  • Right to privacy and protection against harassment. 

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