FAIR PRACTICES CODE - RULEMUDRA (ALIGNED WITH DECIMUS AGREEMENT)

1. Introduction

This Fair Practices Code (“FPC”) is adopted by RuleMudra operated by Twominutes Fintech Pvt Ltd., in its capacity as a Loan Service Provider (LSP)/Technical Services Provider (TSP) in partnership with Decimus Financial Limited (“NBFC”).

This FPC is framed in accordance with guidelines issued by the Reserve Bank of India, including Digital Lending Guidelines.

2. Role & Responsibility Framework (STRICT AS PER AGREEMENT)

• RuleMudra acts only as an LSP / Technology Partner
• Decimus Financial Limited is the sole lender
• All core lending functions are performed exclusively by the NBFC:
• Credit underwriting
• Loan approval/rejection
• Disbursement
• Loan servicing
• RuleMudra:
• DOES NOT lend
• DOES NOT take credit decisions
• DOES NOT assume credit risk
• DOES NOT represent itself as a lender

3. Loan Sourcing & Customer Onboarding

RuleMudra shall:

• Provide technology platform for sourcing customers
• Conduct initial data collection (with consent)
• Perform preliminary checks as per NBFC-defined parameters

NBFC shall:

• Verify KYC
• Conduct credit assessment
• Approve or reject loans

4. Transparency & Key Fact Statement (KFS)

• Borrowers will receive a Key Fact Statement (KFS) in a clear and transparent manner before loan execution
• KFS will include APR (Annual Percentage Rate), Processing fees, All applicable charges and Net disbursal amount.
• No loan will be disbursed without explicit customer acceptance

5. Loan Disbursement & Repayment (CRITICAL RBI POINT)

• All disbursements Shall be made directly from NBFC bank account to borrower.
• All repayments Shall be made only to NBFC accounts.
• No fund flow through RuleMudra accounts and Any third-party accounts.

6. Customer Data Privacy & Storage

• Data collected only with customer’s explicit consent.
• Data used strictly for Loan processing and Risk assessment.
• Data storage Within India (as per law)
• No access to Contacts, Photos and Irrelevant personal data.
• Compliance with IT Act, 2000 and DPDP Act, 2023.

7. Customer Disclosure (Pre-Loan)

Before execution, customer will be informed of:

• NBFC name (Decimus as lender)
• Loan terms & conditions
• APR and charges
• Recovery mechanism
• Grievance process

8. Fair Lending Practices

• Loans shall be offered based on objective credit parameters.
• No discrimination based on Gender, Religion, Caste or Geography.
• Standardized and transparent eligibility criteria.

9. Recovery & Collection Practices

• Recovery conducted only by NBFC or its authorized agents
• RuleMudra shall not perform recovery unless explicitly authorized and compliant

Strictly prohibited to Harassment or coercion, Contacting unrelated third parties, Misuse of customer data.

10. Cooling-Off Period

• Borrowers shall be provided a cooling-off period
• During this period:
  • Loan can be exited without penalty
  • Only principal + proportionate APR payable

11. DLG / FLDG Compliance

• Any risk-sharing arrangement:
• Will comply with RBI guidelines
• Will not transfer credit risk ownership from NBFC
• RuleMudra:
• Does not act as guarantor
• Provides only permitted performance support within regulatory limits

12. Grievance Redressal Mechanism

RuleMudra is committed to addressing customer concerns in a fair, transparent, and timely manner

Level 1 – RuleMudra Support

Customers may contact RuleMudra support for queries, complaints, or assistance relating to the platform, application process, communication, or service experience:

Email: [email protected]

All complaints filed with RuleMudra shall be acknowledged within 24-48 business hours from the time of receipt and the final resolution shall be provided within 30 days

Level 2 – NBFC Escalation

Where the complaint relates to loan sanction, disbursement, repayment, charges, KYC, recovery, or any lender-controlled activity, the matter may be escalated to Decimus Financial Limited

Email: [email protected].

Level 3 – Regulatory Escalation

If the complaint is rejected wholly or partly, the customer is not satisfied with the response, or no response is received within 30 days customers may approach Reserve Bank of India

13. Ethical Marketing & Communication

• No misleading claims (e.g., “guaranteed approval”)
• All communications shall be Transparent, Accurate, Non-coercive.

14. Audit & Regulatory Compliance

• RuleMudra shall:
• Maintain records
• Cooperate with NBFC audits
• Allow regulatory inspection (RBI, etc.)

15. Outsourcing Compliance

• RuleMudra acts as outsourced service provider.
• NBFC retains Full control and regulatory responsibility.