Purpose:
This policy ensures that Wincrust obtains free, informed, and explicit consent from customers before processing any authorization mandates related to loans, repayments, auto-debit instructions, or financial agreements. It is designed to protect customer rights, promote transparency, and comply with applicable financial regulations.
Scope:
This policy applies to:
- Borrowers availing loans from Wincrust
- Co-borrowers and guarantors
- Partners and third-party service providers involved in mandate processing
- Employees responsible for customer onboarding and loan servicing
Guiding Principles:
Informed Consent: Customers must clearly understand what they are authorizing, including repayment methods, auto-debit schedules, and related financial commitments.
Transparency: All terms must be communicated in simple, understandable language before obtaining consent.
Explicit Consent: Authorization mandates shall only be processed after explicit consent is received through signed documents, e-mandate confirmation, or digital authentication.
Voluntary Participation: Consent cannot be obtained under pressure, misrepresentation, or coercion.
Right to Revoke: Customers have the right to withdraw consent or stop an authorization mandate, in line with applicable laws and regulatory guidelines.
Data Confidentiality: Customer consent records and mandates will be securely stored to protect personal and financial information.
Operational Procedure
Pre-Mandate Disclosure:
- Provide customers with detailed information on the purpose, repayment terms, fees (if any), and risks associated with the mandate.
- Ensure disclosures are made in the customer’s preferred language (local or English).
Consent Collection:
- Obtain signed consent in physical or electronic form.
- For e-mandates, ensure two-factor authentication (such as OTP, net banking login, or biometric confirmation).
- Record consent acknowledgments in the company’s secure system.
Verification:
- Confirm customer understanding via verification call, SMS/email confirmation, or acknowledgment slip.
- Only after this step can the mandate be submitted to banks/NBFC partners.
Withdrawal Mechanism:
- Customers can raise a request to cancel or revoke an existing authorization mandate.
- All such requests must be acted upon promptly, and confirmation of cancellation issued in writing.
Record Maintenance:
All consent documents and communications will be retained for regulatory audits and dispute resolution.
Accountability:
- Branch Managers are responsible for ensuring no mandate is processed without explicit consent.
- Compliance & Risk Department will periodically audit customer records.
- Breaches in policy may lead to disciplinary action, regulatory reporting, or penalties.
Review and Amendments:
This policy will be reviewed annually or as required by changes in RBI, NBFC, or other applicable financial guidelines, ensuring Wincrust remains compliant and customer-centric.