GRIEVANCE REDRESSAL MECHANISM

1. TITLE, COMMENCEMENT & EXTENT

The Reserve Bank of India, vide circular dated November 15, 2021 advised the NBFC to appoint IO (IO). The Internal Ombudsman (IO) will be working as an independent authority to review complaints that are partly or wholly rejected by FEDFINA.(NBFC) Hereinafter referred to as the NBFC

2. OBJECTIVES OF THE SCHEME

a. To ensure that all complaints, which are rejected or partially accepted by Fedbank Financial Services Ltd (“Fedfina”), are examined by the IO so that escalation of grievances to RBI Ombudsman (BO) at RBI are minimized.

b. To enhance customer confidence in Fedfina grievance redressal system, thereby making it more transparent and acceptable without diluting the TAT.

c. To enable customer grievances to be considered by an independent authority, other than NBFC officials. The presence of IO at the apex level of Grievance Redressal Mechanism of the NBFC would help in establishing the neutrality the mechanism, as the grievance resolution would have to pass through an independent person before submission to the RBI Ombudsman.

3. ESCALATION OF GRIEVANCES TO IO

The grievance escalation matrix of the NBFC is as follows, where- in the customer can approach the NBFC officials from Level 1 to Level 3

       Level 1 (The first point for immediate redressal of grievance)

• Email: Customers can write to the NBFC at email Id “customercare@fedfina.com” for redressal of any grievance from their registered email ID.
• Letter: Customers can write a letter to the NBFC at - Fedbank Financial Services Limited,Unit no.:1101, 11th Floor, Cignus, Plot No. 71A, Powai, Paspoli, Mumbai – 400087, Maharashtra
• Phone Call: Customer can call the NBFC customer care number 7418128882 & 08069291313. between 09.30 AM to 5:30 PM, Monday to Friday and also between 09:30 AM to 05:30 PM on the Last Saturday of each month, except public holidays.
• Branch Walk-in: Customers can visit NBFC branches and submit a letter with complaint details to the Branch Manager or any other branch official. The customer is advised to take an acknowledgment of receipt with date from the branch personnel to whom he/she is handing over the complaint letter.
• Complaints Register at Branch: Customer may record their complaint or concern in the branch complaint register.

        Level 2 – Nodal Officer

• If the customer is not satisfied with the resolution received through the above channels, or if the customer does not hear from the NBFC within 10 working days of receipt of his complaint at the NBFC, the customer may write to the NBFC Nodal Officer of their Zone with loan account number and complete complaint details provided in the earlier interaction.

       Level 3– Principal Nodal Officer

• If the customer is not satisfied with the resolution received or if the customer does not hear from the NBFC in 7 working days of receipt of his complaint made at level 2, the customer can write to Principal Nodal Officer at sougata.roy@fedfina.com/022-68520837 with loan account number and complete complaint details provided in earlier interaction.

       Level 4 – IO

• Customers shall not approach the IO directly. Fedfina will internally escalate all rejected/partially accepted grievances cases to IO for his consideration and final decision. The final communication to the complainant shall mention that the complaint has been examined by the IO and if he is still not satisfied, he can approach the RBI Ombudsman vested with jurisdiction over the area.

       Level 5- RBI Ombudsman

• In case the customer is not satisfied with the resolution received or if the customer does not hear from the NBFC in 30 working days, he/she may lodge their complaint on RBI CMS portal https://cms.rbi.org.in or write them on e-mail id - crpc@rbi.org.in or send complaint form (format available on the website under Ombudsman scheme 2021) to the below mentioned address:
  • Address: Centralised Receipt and Processing Centre, Reserve Bank of India, 4th Floor, Sector 17, Chandigarh – 160017

4. POWER, JURISDICTION AND REPORTING

   4.1 IO shall not handle complaints received directly from the customers or members public.

   4.2 The IO will deal only with the complaints that have already been examined by the NBFC’s Internal Grievance Redressal mechanism and which have remained partly or wholly unredressed.

   4.3 All cases, wherein Fedfina decides to reject the complaint or provides only partial relief to the complainant would be forwarded to IO for further examination and final decision. All such complaints will be escalated to IO within     three weeks of receipt of complaint, before conveying the final decision to the complainant within a period of 30 days, from the receipt of complaint except following:

• Complaints related to frauds, misappropriation etc., except in respect of deficiency of service, if any, on the part of the NBFC.
• Complaints / references relating to a) internal administration, b) human resources, c) pay and emoluments of staff
• References in the nature of suggestions, requests for concessions in rate of interest charged, rejection of loan proposals, modifications in sanction terms and conditions, enhancement in credit limit, waiver / write-off of loans, etc. which are primarily in the nature of commercial decisions.
• Complaints which have been decided by or are already pending in other fora such as consumer fora, Courts, Debt Recovery Tribunals, etc

  4.4 The IO shall periodically analyze the pattern of complaints such as product / category wise, consumer groups wise, based on geographical location, etc. and suggest means for taking actions to address the root cause of complaints of different nature.

  4.5 The IO shall examine the complaints on the basis of records/ documents available with the NBFC and comments / clarifications furnished by the NBFC to specific queries of the IO.

  4.6 The IO may hold meetings with concerned functionaries/ departments of the NBFC and seek any record / document available with the NBFC that is necessary for examining the complaint. To ensure resolution through conciliation, the IO may seek direct feedback / clarifications from the complainant.

  4.7 In, cases of conciliation, where the decision of the IO is accepted by the complainant, the IO shall obtain and keep on record, a statement showing the terms of the agreement duly signed by the complainant.

  4.8 The IO shall not represent Fedfina in legal cases arising out of complaints examined by Fedfina or the IO.

  4.9 The IO shall report to the Managing Director / General Manager of Fedfina handling customer grievances.

  4.10 The IO shall immediately refer back to Fedfina all such complaints which are outside the purview of the Scheme.

  4.11 The contact details of I.O. will not be provided in the public domain, as the I.O. shall not entertain and examine FIRST RESORT complaints, which need to be first examined by Fedfina Internal Grievance Redressal Mechanism. In case the I.O. happens to receive FIRST RESORT complaints, he/she shall forward such complaints to Fedfina Internal Grievance Redressal functionary.

   4.12 The I.O. shall exercise general powers of superintendence and control over his office and shall be responsible for the conduct of business there at.

   4.13 Fedfina shall examine the grievances as per its Internal Grievance Redressal Mechanism and in case Fedfina decides to reject or to provide only partial relief to the complainant, it should invariably forward such cases to the I.O. for further examination. The advice to the complainant after examination by I.O. in such cases should necessarily have a clause that the grievance has also been examined by the I.O.

   4.14 Fedfina shall internally escalate all such complaints to IO, before conveying the final decision to the complainant within a period of three weeks, from the receipt of complaint.

   4.15 The I.O. shall have the right to access Fedfina records relating to the complaints received, seek detailed comments from Fedfina with regard to the complaints, can hold meetings with the functionaries/departments concerned and can also meet the complainants, if required, while examining the complaint for redress. Fedfina will furnish all records/documents sought by the I.O. to enable him/her to discharge his/her duties effectively and redress/resolve customer grievances expeditiously.

   4.16 Fedfina shall provide read only access to the Complaint Management Application so that all complaints are accessible to the IO who shall follow up cases of delayed escalation with the concerned department in Fedfina. Fedfina shall also provide access to IO for adding his/her decisions on complaints escalated to the IO, in Fedfina's Complaint Management Application.

   4.17 IO shall also have read-only access to the Reserve Bank's Complaints Management System to enable the IO to keep track of the cases forwarded by the Offices of RBI Ombudsman and the decisions by the RBI Ombudsman thereon, including the decision of the Appellate Authority, where applicable.
  4.18 The I.O. shall maintain confidentiality of any information or document that may come into his knowledge or possession in the course of discharging his duties and shall not disclose such information or document to any person except with the consent of the person furnishing such information or document, provided that nothing in this clause shall prevent the I.O. from disclosing information or document furnished by a party in a complaint to the other party or parties to the extent considered by him to be reasonably required to comply with any legal requirement or the principles of natural justice and fair play in the proceedings. 

  4.19 The decision of the I.O. shall be binding on Fedfina and Fedfina is required to accept it. In case Fedfina disagrees with the decision of I.O., such cases should be reported to RBI by Fedfina with a copy to respective RBI Ombudsman. In such cases, the reply to the customer should also mention the fact though the IO has upheld the customer’s complaint, the NBFC, through its appropriate authority, has overruled the IO’s decision.

  4.20 The reference made by Fedfina to I.O. for examination should emanate primarily from Fedfina’s Internal Grievance Redressal Machinery/ any other designated officials.

  4.21 Fedfina’s Principal Nodal Officer or nodal officers or any other designated authority, liaising with offices of RBI Ombudsman, shall not act as I.O. or vice-versa even during the temporary absence of either.

  4.22 The I.O. will submit a quarterly report of the cases escalated to him to the Board, which will exercise the oversight on the functioning of I.O. However, aspects relating to fraud, misappropriation etc. shall be reported to Audit Committee of the Board immediately.

  4.23 The I.O. shall not represent Fedfina in legal cases arising out of complaints examined by him/her as he/she does not have operational role

5. OPERATING PROCEDURE

  5.1 The I.O. shall take into account the evidence placed before him by the parties, the principles of banking law and practice, directions, instructions and guidelines issued by the Reserve Bank from time to time and such other factors which in his opinion are relevant to the complaint.

  5.2 Fedfina shall, in their final reply to the complainant after obtaining IO's decision, explicitly mention that the complaint has been examined by Fedfina’s IO. Only under circumstances, where a resolution has been made by agreement and the IO had obtained the resolution in writing duly signed by the complainant and furnished to Fedfina for records, should a reply to the complainant be issued by IO with an endorsement to Fedfina.

  5.3 In case of disagreement with the IO's decision, Fedfina may obtain approval of Managing Director/Chief Executive Officer and the reply forwarded to the complainant shall mention that the decision of Fedfina has the approval of Managing Director/Chief Executive Officer. All such cases shall be subsequently reviewed by the Audit Committee and the Board.

  5.4 Where the complaints falling under RBI Ombudsman Scheme, are not resolved to the satisfaction of the complainant (i.e., partly or wholly rejected complaints) even after examination by IO, Fedfina shall necessarily advise the complainant that he/she can approach the RBI Ombudsman for redressal along with complete details and address of the RBI Ombudsman concerned as well as the link to Reserve Bank's portal (www.rbi.org.in -> Complaints -> RBI Ombudsman Scheme -> Complaint Form) for online filing of customer complaints.

  5.5 The decision of the IO shall be mandatorily included in the information submitted by Fedfina to the RBI Ombudsman, while furnishing documents related to the complaints received in the office of the RBI Ombudsman.

  5.6 In cases where the complainant has approached the RBI Ombudsman before the IO has examined the complaint, Fedfina should obtain the views of IO and include the IO's views in its submissions to RBI Ombudsman.

  5.7 Fedfina shall use the analysis of complaints handled by IO in the training programmes/conferences to raise awareness, inter alia, about the patterns of complaints, among the frontline staff, and facilitate consistency in handling of similar complaints. The IO may also be associated for such trainings, where necessary.

  5.8 While assessing the performance of the IO, in addition to the level of pendency and work done by the IO towards developing uniformity across Fedfina in the redressal of complaints, Fedfina should also keep in mind the number of cases where substantive differences are observed between the decisions of the IO vis-à-vis that given by the RBI ombudsman subsequently.

  5.9 IO shall be placed in HO or any of the Regional Offices.

6. REPORTING TO RBI

  6.1 Fedfina shall put in place a system of periodic reporting of information to RBI as indicated below: 

• On quarterly basis, the total number of complaints received number of partly or wholly rejected complaints and number of complaints escalated to the IO, within 15 days from the end of the quarter;
  • (a) On annual basis, the number of cases where the decision of IO has been rejected with the approval of Managing Director/Chief Executive Officer of Fedfina, to be submitted in April every year; and
  • (b) On annual basis, the number of cases closed by IO and age wise number of cases where Fedfina was yet to implement the decision of IO in April every year.

7. OVERSIGHT

  7.1 Board Oversight: The IO shall furnish periodical reports on his / her activities including the analysis to the Audit Committee and the Board, preferably at quarterly intervals, but not less than bi annually. Fedfina shall put in place a system for discussion of cases by the Audit Committee and the Board where the decision of the IO has been rejected by Fedfina, which is to be done with approval of Managing Director/Chief Executive Officer of Fedfina. The Audit Committee of the board can refer to the IO in respect of cases mentioned.

  7.2 Audit: Fedfina shall conduct an internal audit of the implementation. The audit shall, inter alia, cover aspects relating to the infrastructure (space, information technology, human resources etc.) provided to the IO and implementation of auto escalation of partly or wholly rejected complaints to the IO within the timeframe of three weeks as indicated. Internal audit shall also look at the actions by the IO with regard to analysis of complaints, efforts made by IO and support provided by Fedfina towards raising awareness about types of grievances and developing uniformity of approach in handling of complaints across Fedfina. The scope of internal audit shall exclude the decisions taken by the IO.