Credit Policy for Digital Lending
AFI Dhanvridhi
1. OBJECTIVEThis policy is framed by AFI Dhanvridhi to ensure regulatory compliance, manage risks associated with digital lending, protect customer interests through fair and transparent practices, and promote responsible lending.
The policy has been amended to incorporate the provisions/guidelines issued by the Reserve Bank of India through RBI’s Digital Lending Directions, 2025 dated 8th May, 2025.
2. SCOPEThis policy applies to all unsecured loans sourced via AFI Dhanvridhi's Digital Lending Apps or third-party platforms involving a default loss guarantee.
3. DEFINITION- Default Loss Guarantee (DLG): A contractual arrangement, called by whatever name, between AFI Dhanvridhi and another entity, under which the latter guarantees to compensate AFI Dhanvridhi, for the loss due to default up to a certain percentage of the loan portfolio of AFI Dhanvridhi, specified upfront. Any other implicit guarantee of similar nature, linked to the performance of the loan portfolio of the Company and specified upfront, shall also be covered under the definition of DLG.
- Digital Lending: A remote and automated lending process, largely by use of seamless digital technologies for customer acquisition, credit assessment, loan approval, disbursement, recovery, and associated customer service.
- Lending Service Provider (LSP): Facing as an agent of the Company (including another Companies or NBFCs) who carries out one or more of NBFCs digital lending functions, or part thereof, in customer acquisition, services incidental to underwriting and pricing, servicing, monitoring, recovery of specific loan or loan portfolio on behalf of RE in conformity with extant outsourcing guidelines issued by the Reserve Bank.
- Days Past Due (DPD): The number of days a loan payment has been delayed beyond its original due date.
- NACH: In the context of banking, stands for National Automated Clearing House. It is a centralized, web-based system developed by the National Payments Corporation of India (NPCI) to facilitate high-volume, recurring interbank electronic transactions. NACH streamlines processes like salary payments, loan EMIs, and utility bill payments by automating the debit or credit of funds between different bank accounts.
AFI Dhanvridhi offers the Insta Loan – Salaried (SL) product, with loan amount ranging from ₹5,000 to ₹50,000.
5. ELIGIBILITY CRITERIA- Age: 21 to 60 years (at loan maturity)
- Sourcing: LLP (case-wise approval), Pvt Ltd, Ltd Companies, MNCs
- Not Eligible: Proprietorships, Partnerships, Defence/Police (Govt.), Lawyers, Self-employed
- Company Vintage: Minimum 2 years
- Paid-up Capital: ₹1 lakh+ (if <2 years, case-wise approval)
- Residence Stability:
- Rented: Minimum 6 months at the same address, 1 year in the same city
- Owned: No restriction
- Job Stability:
- ≥ 6 months: Acceptable
- < 6 months: Continuity proof required (salary credit, offer/release letter, Form 16/26AS)
- Employment Checks:
- Fresh Loans: Sing3, EPFO, Whois, Zauba, MCA, Form 16/26AS
- Re-loans: Same checks + office CPV if needed
- Minimum Salary: ₹18,000/month
- Salary Continuity: Regular; delays >30 days = avoid
- Incentive Calculation: Average of last 3 months (added to Net Take Home if consistent)
- Fixed Obligations to Income Ratio: Decision-based through underwriting
- Salary Mode: Bank transfer only (Cash/UPI not allowed)
- ID Proofs: Aadhar & PAN (name must match), Employee ID (if available)
- Address Proof: OVD in applicant's name (DL, Passport, Voter ID, etc.)
- Permanent address proof mandatory for rented cases
- Ownership Proof: Utility bills, loan sanction letter, etc.
- Relationship proof if owned by parent/spouse
- Salary Slips: Last 3 months (avoid delays >30 days)
- Bank Statement: Last 6 months, original PDF (max 2–3 days old at login)
- Photograph: 1 live photo
- References: 2 – One family (18+), one colleague
- EMI Bounce: Must be clarified
- DPD: Maximum 90+ allowed in last 12 months
- Multiple Short Term Personal Loans: Mitigation required (e.g., Personal Loan, Home Loan, Auto Loan)
- CIBIL Score: 0/-1 not allowed; to be reviewed as portfolio evolves
- ROI: Daily @ 1%
- Processing Fees: 9.91% (as per new PF grid)
- Foreclosure: NIL
- Bouncing Charges (NACH): ₹1,000
- Late Payment Interest: 2%
- CIBIL Reporting: Yes
- BSA (Banking Statement Analysis): Mandatory
Old PF Grid: Flat 10%
New PF Grid Effective: 1st April 2025
| Charge Component | Rate |
|---|---|
| Processing Charges | 5% |
| Document Charges | 2% |
| Online Convenience Fees | 1.40% |
| Total (before GST) | 8.4% |
| GST (Included) | 18% |
| Total Including GST | 9.91% |
At present, the Company has not appointed any LSP. In case Company engages LSP for the purpose of digital lending activities, the Company shall:
- Carry Due Diligence of the LSP
- Enter into a contractual agreement with LSP which shall include roles and responsibilities of both the parties
- Carry out periodic review of the conduct of the LSP, and shall take action against LSP, in case of failure
- Establish monitoring mechanisms for loan portfolios originated through LSPs
AFI Dhanvridhi shall:
- Provide a Key Fact Statement (KFS) including Annual Percentage Rate, penal charges, and other terms and conditions of the loan
- Share digitally signed loan documents to Borrowers for their record through email/sms after execution
- Mention Default Loss Guarantee in KFS
- Include identity of DLG provider and guarantee cap in KFS
- Clarify that DLG does not reduce borrower repayment obligation
- Disbursal must be made only to the borrower’s bank account.
- Repayments shall be credited directly to the AFI Dhanvridhi's account.
- Pass-through accounts or third-party fund control is not permitted.
- No LSP fee shall be charged to the borrower.
- A minimum cooling-off period of one day shall be provided, allowing the borrower to exit the loan without penalty.
- Longer periods may be considered with the Board approval.
- Max DLG cap: 5% of total loan portfolio
- Not eligible for credit enhancement classification
- No influence on credit decisioning
- Full disclosure in KFS and loan agreement
- Cash collateral
- Assigned fixed deposits
- Bank guarantees
- Escrow accounts for loss coverage
Guarantee on Default can be made only when the lending is through LSP.
- Legally binding between AFI Dhanvridhi & LSP/DLA
- Max liability: 5% of disbursed portfolio
- Trigger: DPD > 90 days
- Defined responsibilities & timelines
- Annual review and audit
Entirely independent of DLG; underwriting guided solely by internal risk standards.
19. RISK MONITORING & REPORTING- Maintain MIS for DLG-backed portfolios
- Track performance and escalate to Risk Committee
AFI Dhanvridhi shall ensure that the consent of borrowers is obtained before sharing their personal data with any third party, except where such sharing is mandated by law or regulation.
21. STORAGE OF DATAAFI Dhanvridhi shall not store borrowers’ personal information.
22. AUDIT & REVIEW- Annual internal audits
- Review compliance
- Exceptions to be Board-approved
Only Board-approved exceptions allowed. No operational deviation permitted under DLG influence.
24. REPORTING REQUIREMENTSAFI Dhanvridhi shall report:
- Digital loan details to Credit Information Companies (CICs).
- Details of the DLAs deployed by AFI Dhanvridhi or by its Lending Service Provider to the RBI on CIMS portal.
AFI Dhanvridhi has appointed Nodal officer to resolve the grievance of the borrowers. His contact details are provided in KFS.
26. CONCLUSIONAFI Dhanvridhi upholds credit autonomy and transparency, ensuring DLG is a risk-sharing tool, not a substitute for borrower due diligence.
| Function | Responsibility |
|---|---|
| Credit & Risk | Independent underwriting and monitoring |
| Legal & Compliance | Contract management, regulatory compliance |
| Finance | Monitor DLG instruments and provisioning |
| Internal Audit | Annual audit and compliance validation |
BOARD APPROVAL
Approved by the Board of Directors of AFI Dhanvridhi.