This Code has been drafted by NABKISAN Finance Limited (NABKISAN) as per the Guidelines issued by the Reserve Bank of India on Fair Practices Code for Non-Banking Finance Companies vide its Circular No.RBI / 2006-07 / 138 / DNBS (PD) CC No.80 / 03.10.042 / 2005-06 dated September 28, 2006. This Code sets minimum Fair Practice standards for NABKISAN to follow when it is dealing with the customer. It provides information to customers and explains how NABKISAN is expected to deal with the customers on day-to-day basis. This Code will come into force from the date of approval and adoption by the Board for implementation by NABKISAN.

The Code has been developed with an object to:

• Promote good, fair and transparent business practices by setting minimum standards in dealing with the customer which NABKISAN shall follow.
• Increase transparency so that the customer can have a better understanding of what type of service level can be expected from NABKISAN.
• NABKISAN will interact with the customers in such manner so as to promote cordial relationship.
• NABKISAN shall endeavour to achieve, through fair means, higher operating standards and foster customer confidence in NABKISAN in the financing undertaken.

The Code applies to all products, offered by NABKISANas envisaged in its Memorandum of Association.

To help borrower/customer to understand how NABKISAN's financial products and services work by:

• Ensuring that the customer is given clear information about NABKISAN's products and services, the terms and conditions and interest rates/ service charges, which apply to them.
• Keeping customer informed about changes in the interest rates, charges, terms and conditions.

To act fairly and reasonably in all dealings with the customer by,

• Meeting the commitments and standards in this Code for products and services offered by NABKISAN.
• Making sure that products and services meet relevant principles of integrity and transparency.
• Informing customer about the time limit by which loan application will be processed and informing them of the status at regular intervals.
• Handling customer complaints promptly.
• Informing customers about the process to take their complaints forward to higher authorities.

To treat personal information of customers as private and confidential.

Application for Loan

• Loan application forms will be designed and implemented depending upon the loan products offered.
• The loan application forms will clearly indicate the details required to be submitted with the application form.
• All loan applications received from the borrowers will be duly acknowledged.
• All loan proposals received would be placed before the Board /Loan Committee /competent authority after the receipt of the loan application.
• The acceptance / rejection of the loan application shall be intimated to the borrower in writing, irrespective of the loan amount sought.
• In case of rejection, the reasons for rejection shall also be intimated to the concerned borrower.

Loan appraisal and terms/conditions

The rate of interest on loan products will be reasonable in relation to market conditions. The sanction letter will convey the amount to be financed and the rate of interest and the method of application thereof, mode and time at which the interest will be debited and other terms and conditions applicable to loan. This will be in duplicate. One copy would be handed over to the customer and one copy will be retained in customer’s file after due acceptance of the terms and conditions by the borrower.

• A copy of the loan agreement along with a copy each of all enclosures quoted in the loan agreement will be furnished to the borrower at the time of sanction of loan.
• Any change in terms of conditions like change in interest rate, tenure, all charges / fees would be communicated to the borrower in writing. The Company will ensure that changes are effected only prospectively.
• Any decision to recall or to accelerate payment would be communicated to the borrower in writing as per the terms of the loan agreement.
• NABKISAN will release all securities on repayment of all dues or on realization of the outstanding amount of loan subject to any legitimate right or lien for any other claim NABKISAN may have against the borrower. If such right of set off is to be exercised, the borrower shall be given notice about the same with full particulars about the remaining claims and the condition under which NABKISAN is entitled to retain the securities till the relevant claim is settled / paid.

• NABKISAN would not discriminate on grounds of sex, caste and religion in the matter of lending. However, this does not preclude the Company from participating in credit linked schemes for the weaker sections of the society and in respect of schemes formulated by NABARD/ other Government Agencies, implemented through NABKISAN.
• NABKISANwill take recourse / actions only through legally permissible remedies as per the terms and conditions of loan agreement entered into with the borrower.
• Only written request from customers for transfer of liabilities will be evaluated by the Company and written confirmation/ rejection will be intimated to the customer within 21 days after due diligence. Such transfer shall be as per transparent, contractual terms in consonance with the law.
• Any agency to whom various activities are outsourced/ entrusted will have to be short listed and empanelled as per the Company policies issued from time to time.
• NABKISAN shall refrain from interference in the affairs of the borrower except for the purpose provided in terms and conditions of the loan agreement (unless new information not earlier disclosed by the borrower has come to the notice of NABKISAN).
• NABKISAN shall treat customer information as private and confidential.
• The information shall be parted by NABKISAN only in the following circumstances:
  • Information required to be given under law or as demanded or required by statutory authorities.
  • Information is given with customer's specific written permission.

• In the matter of recovery of loans, NABKISAN shall not resort to undue harassment viz., persistently bothering the borrowers at odd hours, use of muscle power for recovery of loans, etc.
• NABKISAN's collection policy shall be built on courtesy, fair treatment and persuasion. Efforts will be made in building customer confidence and long-term relationship.
• The staff deputed to make recovery calls shall identify themselves and shall provide details with regard to outstanding claims to the customer.

• Complaint register would be maintained. If complaint is received in writing, complaint number would be given which would be referred to in future.
• NABKISAN will endeavour to sort out the matter within 15 days of receipt of a complaint.
• In case the complaint requires more time, then, the same would be informed to the customer. Customer would be updated at regular intervals regarding the status of the same.
• The grievance redressal mechanism within the organisation will be explained to the customer to resolve any dispute, such a mechanism would ensure that all disputes arising out of decisions of NABKISAN’s functionaries are heard and disposed off at least at the next higher level.
• A complaint of misconduct against an official of NABKISAN shall be redressed by the next level of authority.
• The officials of NABKISAN shall ensure that the grievances of the borrowers are brought to the notice of the Board. A consolidated report will be submitted to the Board on a quarterly basis.

The Board of Directors of NABKISAN will periodically review the compliance of the Fair Practices Code and the functioning of the grievance redressal mechanism at various levels of management.

Reserve Bank of India (RBI) had advised all NBFCs to follow certain customer identification procedure for opening of accounts and monitoring transactions of a suspicious nature for the purpose of reporting it to appropriate authority. These ‘Know Your Customer’ guidelines have been revisited by RBI in the context of the Recommendations made by the Financial Action Task Force (FATF) on Anti Money Laundering (AML) standards and on Combating Financing of Terrorism (CFT). Detailed guidelines based on the Recommendations of the Financial Action Task Force and the paper issued on Customer Due Diligence (CDD) for NBFCs by the Basel Committee on Banking Supervision, with indicative suggestions wherever considered necessary, have been issued by RBI vide their letter no. DNBS (PD)/CC No. 339/03.10.42/2013-14 dated 01 July 2013.

In view of the same, NABKISAN Finance Limited (NKFL) has adopted the said KYC guidelines with suitable modifications depending on the activity undertaken by it. The Company has ensured that a proper policy framework on KYC and AML measures be formulated in line with the prescribed RBI guidelines and put in place duly approved by its Board of Directors.

The objective of KYC guidelines is to prevent the Company from being used, intentionally or unintentionally, by criminal elements for money laundering activities or terrorist financing activities. KYC procedures shall also enable the Company to know and understand its Customers and its financial dealings better which in turn will help it to manage its risks prudently. Thus, the KYC policy has been framed by the Company for the following purposes:

• To prevent criminal elements from using NKFL for money laundering activities
• To enable NKFL to know/ understand its customers and their financial dealings better which, in turn, would help the Company to manage risks prudently
• To put in place appropriate controls for detection and reporting of suspicious activities in accordance with applicable laws/laid down procedures.
• To comply with applicable laws and regulatory guidelines.
• To ensure that the concerned staff are adequately trained in KYC/AML/CFT procedures.

This Policy includes four key elements:

• Customer Acceptance Policy (CAP)
• Customer Identification Procedures (CIP)
• Monitoring of Transactions and
• Risk management

For the purpose of NKFL KYC policy a ‘Customer’ means a person as defined under KYC policy of RBI (and any amendment from time to time by RBI) which are at present as under:-

• A person or entity that maintains an account and/or has a business relationship with NKFL;
• One on whose behalf the account is maintained (i.e. the beneficial owner)
• Beneficiaries of transactions conducted by professional intermediaries such as Stock Brokers, Chartered Accountants, Solicitors etc. as permitted under the law
• Any other person or entity connected with a financial transaction which can pose significant reputation or other risks to NKFL, say a wire transfer or issue of high value demand draft as a single transaction.

4.1.Customer Acceptance Policy (“CAP”)

NKFL’s Customer Acceptance policy(CAP) lays down the criteria for acceptance of customers. The guidelines in respect of the customer relationship in NKFL broadly includes the following:

• No account is to be opened in anonymous or fictitious / benami name(s) / entity(ies)
• Accept customers only after verifying their identity, as laid down in Customer Identification Procedures. Necessary checks before opening a new account are to be ensured so that the identity of the customer does not match with any person with known criminal background or with banned entities such as individual terrorists or terrorist organizations, etc.
• Classify customers into various risk categories and, based on risk perception, apply the acceptance criteria for each category of customers. Parameters of risk perception are clearly defined in terms of nature of business activity, location of customer and his clients, mode of payments, volume of turnover, social and financial status etc., to enable categorization of customers into low, medium and high risk. Customer requiring very high level of monitoring, e.g. Politically Exposed Persons (PEPs – as explained in Annexure I) may, if considered necessary, will be kept in the High Risk Category.
• Documentation requirements and other information to be collected in respect of different categories of Customers depending on perceived risk and compliances with Prevention of Money Laundering Act, 2002 (PMLA) and RBI guidelines/instructions.
• Not to open an account or close an existing account where the company is unable to apply appropriate customer due diligence measures i.e. company is unable to verify the identity and / or obtain documents required as per the risk categorisation due to non cooperation of the customer or non reliability of the data/information furnished to the company. It may, however, be necessary to have suitable built in safeguards to avoid harassment of the customer. For example, decision to close an account may be taken at a reasonably high level after giving due notice to the customer explaining the reasons for such a decision;
• Circumstances, in which a customer is permitted to act on behalf of another person/entity, would be clearly spelt out in conformity with the established law and practice of banking as there could be occasions when an account is operated by a mandate holder or where an account may be opened by an intermediary in the fiduciary capacity and
• Necessary checks before opening a new account so as to ensure that the identity of the customer does not match with any person with known criminal background or with banned entities such as individual terrorists or terrorist organizations etc.

The Company shall prepare a profile for each new customer during the credit appraisal based on risk categorization as mentioned in this policy. The customer profile shall contain the information relating to the customer’s identity, social/financial status, nature of business activity, information about his clients’ business and their location, etc. The nature and extent of due diligence will depend on the risk perceived by NKFL. At the time of credit appraisal of the applicant the details are recorded along with his profile based on meeting with the applicant (by the NKFL representative) apart from collection of applicable documents, this will be as per the Credit/ products norms as may be in practice. However, while preparing customer profile, the Company shall seek only such information from the customer which is relevant to the risk category and is not intrusive. The customer profile will be a confidential document and details contained therein shall not be divulged for cross selling or for any other purposes.

For the purpose of risk categorisation, individuals (other than High Net Worth) and entities whose identities and sources of wealth can be easily identified and transactions in whose accounts by and large conform to the known profile, will be categorised as low risk. These customers include salaried employees whose salary structures are well defined, people belonging to lower economic strata of the society whose accounts show small balances and low turnover, Government departments & Government owned companies, regulators and statutory bodies etc. In such cases, only the basic requirements of verifying the identity and location of the customer are to be met.

Customers that are likely to pose a higher than average risk to the company will be categorized as medium or high risk depending on customer's background, nature and location of activity, country of origin, sources of funds and his client profile etc. NKFL will apply enhanced due diligence measures based on the risk assessment, thereby requiring intensive ‘due diligence’ for higher risk customers, especially those for whom the sources of funds are not clear. Examples of customers requiring higher due diligence include (a) non- resident customers, (b) high net worth individuals, (c) trusts, charities, NGOs and organizations receiving donations, (d) companies having close family shareholding or beneficial ownership, (e) firms with 'sleeping partners', (f) politically exposed persons (PEPs) of foreign origin, (g) non-face to face customers, and (h) those with dubious reputation as per public information available, etc.

The adoption of customer acceptance policy by NKFL and its implementation shall not become too restrictive and must not result in denial of banking services to general public, especially to those, who are financially or socially disadvantaged.

4.2. Customer Identification Procedures (“CIP”)

Customer identification means identifying the customer and verifying his/her identity by using reliable, independent source documents, data or information. NKFL shall obtain sufficient information necessary to verify the identity of each new customer along with brief details of its promoters and management, wherever applicable, whether regular or occasional and the purpose of the intended nature of Business relationship. The requirement as mentioned herein may be moderated according to the risk perception like in the case of a public listed company it will not be necessary to identify all the shareholders.

Besides risk perception, the nature of information/documents required would also depend on the type of customer (individual, corporate etc). For customers that are natural persons, NKFL shall obtain sufficient identification data to verify the identity of the customer, his address/location, and also his recent photograph. For customers that are legal persons or entities, the Company shall -

• (i) verify the legal status of the legal person/ entity through proper and relevant documents
• verify that any person purporting to act on behalf of the legal person/entity is so authorized and identify and verify the identity of that person,
• understand the ownership and control structure of the customer and determine who are the natural persons who ultimately control the legal person. Customer identification requirements keeping in view the provisions applicable of Prevention of Money Laundering & its Rules and as per guidance note issued in this respect are indicated in Annexure
  • An indicative list of the nature and type of documents/information that may be relied upon for customer identification is given in Annexure
  • The Company will frame internal guidelines based on its experience of dealing with such persons/entities, normal prudence and the legal requirements.

The Company will formulate and implement a Client Identification Programme to determine the true identity of its clients keeping the above in view. The policy shall also cover the identification procedure to be carried out at different stages, i.e. while establishing a relationship; carrying out a financial transaction or when there is a doubt about the authenticity/veracity or the adequacy of the previously obtained customer identification data.

As per Rule 9(IA) of the Prevention of Money Laundering Rules, 2005, NKFL is required to identify the beneficial owner and take all reasonable steps to verify his identity. The term "beneficial owner" has been defined as the natural person who ultimately owns or controls a client and/or the person on whose behalf the transaction is being conducted, and includes a person who exercises ultimate effective control over a juridical person. Government of India has since examined the issue and has specified the procedure for determination of Beneficial Ownership. The procedure as advised by the Government of India is as under:

• Where the client is a person other than an individual or trust, NKFL shall identify the beneficial owners of the client and take reasonable measures to verify the identity of such persons, through the following information:
  • The identity of the natural person, who, whether acting alone or together, or through one or more juridical person, exercises control through ownership or who ultimately has a controlling ownership interest.
  • In cases where there exists doubt under (i) as to whether the person with the controlling ownership interest is the beneficial owner or where no natural person exerts control through ownership interests, the identity of the natural person exercising control over the juridical person through other means.
  • Where no natural person is identified under (i) or (ii) above, the identity of the relevant natural person who holds the position of senior managing official.
• Where the client is a trust, NKFL shall identify the beneficial owners of the client and take reasonable measures to verify the identity of such persons, through the identity of the settler of the trust, the trustee, the protector, the beneficiaries with 15% or more interest in the trust and any other natural person exercising ultimate effective control over the trust through a chain of control or ownership.
• Where the client or the owner of the controlling interest is a company listed on a stock exchange, or is a majority-owned subsidiary of such a company, it is not necessary to identify and verify the identity of any shareholder or beneficial owner of such companies.

4.3.Monitoring of transactions:

Ongoing monitoring is an essential element of effective KYC procedures. Monitoring of transactions and its extent will be conducted taking into consideration the risk profile and risk sensitivity of the account. NKFL shall make endeavors to understand the normal and reasonable activity of the customer so that the transactions that fall outside the regular/pattern of activity can be identified, Special attention will be paid to all complex, unusually large transactions and all unusual patterns, which have no apparent economic or visible lawful purpose. NKFL will prescribe threshold limits for a particular category of accounts and pay particular attention to the transactions which exceed these limits. Transactions that involve large amounts of cash inconsistent with the normal and expected

activity of the customer shall particularly attract the attention of the company. Higher risk accounts shall be subjected to intense monitoring. NKFL shall set key indicators for such accounts basis the background of the customer, country of origin, sources of funds, the type of transactions involved and other risk factors which shall determine the extent of monitoring. NKFL shall carry out the periodic review of risk categorization of transactions/customer’s accounts and the need for applying enhanced due diligence measures at a periodicity of not less than once in twelve months. NKFL shall explore the possibility of validating the new account opening applications with various watch lists available in public domain, including RBI watch list.

NKFL shall ensure that a record of transactions in the accounts is preserved and maintained as required in terms of section 12 of the PML Act, 2002. It may also be ensured that transactions of suspicious nature and/ or any other type of transaction notified under section 12 of the PML Act, 2002, is reported to the appropriate law enforcement authority

4.4.Risk Management

The Management under the supervision of the Board of Directors of the Company shall ensure that an effective KYC programme is put in place by establishing appropriate procedures and ensuring their effective implementation. It will cover proper management oversight, systems and controls, segregation of duties, training and other related matters. Responsibility will be explicitly allocated within the Company for ensuring that the policies and procedures as applicable to NKFL are implemented effectively. The Company shall devise procedures for creating Risk Profiles of their existing and new customers and apply various Anti Money Laundering measures keeping in view the risks involved in a transaction, account or business relationship

5.0 Training Programme

NKFL shall have an ongoing employee training programs so that the members of the staff are adequately trained in KYC/ AML/ CFT procedures. Training requirements shall have different focuses for frontline staff, compliance staff and officer/ staff dealing with new customers so that all those concerned fully understand the rationale behind the KYC policies and implement them consistently

6.0 Internal Control System

The Company’s internal audit and compliance functions have an important role in evaluating and ensuring adherence to the KYC policies and procedures. As a general rule, the compliance function should provide an independent evaluation of the company’s own policies and procedures, including legal and regulatory requirements. NKFL shall ensure that their audit machinery is staffed adequately with individuals who are well versed in such policies and procedures. Concurrent/ Internal Auditors shall specifically check and verify the application of KYC procedures and comment on the lapses observed in this regard. The compliance in this regard shall be put up before the Audit Committee of the Board on quarterly intervals.

7.0 Record keeping

7.1 Maintenance of records of transactions:

The Company shall maintain proper record of the transactions as required under Section 12 of the Prevention of Money Laundering Act, 2002 (PMLA) read with Rules 3 of the PML Rules as mentioned below:

• All cash transactions of the value of more than Rs. 10 lakhs or its equivalent in foreign currency, though by policy the Company does not accept cash deposits in foreign currency.
• All series of cash transactions integrally connected to each other which have been valued below Rs 10 lakhs or its equivalent in foreign currency where such series of transactions have taken place within a month.
• All transactions involving receipts by non-profit organizations of Rs. 10 lakhs or its equivalent in foreign currency.
• All cash transactions where forged or counterfeit currency notes or bank notes have been used as genuine and where any forgery of a valuable security has taken place.
• All suspicious transactions whether or not made in cash and in manner as mentioned in the Rule framed by the Government of India under PMLA.

7.2 Information to be preserved:

NKFL shall maintain the following information in respect of transactions referred to in Rule 3 of PMLA –

• the nature of the transactions;
• the amount of the transaction and the currency in which it was denominated;
• the date on which the transaction was conducted;
• the parties to the transaction.

7.3 Maintenance and preservation of records

Section 12 of PMLA requires the Company to maintain records as under:

• records of all transactions referred to in clause (a) of Sub-section (1) of section 12 read with Rule 3 of the PML Rules is required to be maintained for a period of ten years from the date of transactions between the clients and NKFL.
• records of the identity of all clients of NKFL is required to be maintained for a period of ten years from the date of cessation of transactions between the clients and NKFL. NKFL shall take appropriate steps to evolve a system for proper maintenance and preservation of information in a manner (in hard and soft copies) that allows data to be retrieved easily and quickly whenever required or as/ when requested by the competent authorities.

NKFL shall designate a senior employee as ‘Principal Officer’ (PO) who shall be responsible for monitoring and reporting of all transactions and sharing of information as required under the law. PO shall maintain close liaison with enforcement agencies, NBFCs and any other institution which are involved in the fight against money laundering and combating financing of terrorism.

• In the matter of recovery of loans, NABKISAN shall not resort to undue harassment viz., persistently bothering the borrowers at odd hours, use of muscle power for recovery of loans, etc.
• NABKISAN's collection policy shall be built on courtesy, fair treatment and persuasion. Efforts will be made in building customer confidence and long-term relationship.
• The staff deputed to make recovery calls shall identify themselves and shall provide details with regard to outstanding claims to the customer.

The Principal Officer shall report information relating to cash and suspicious transactions, if detected, to the Director, Financial Intelligence Unit India (FIUIND) as advised in terms of the PMLA rules, in the prescribed formats as designed and circulated by RBI at the following address:

Director, FIU–IND,
Financial Intelligence Unit India,
6th Floor, Hotel Samrat, Chanakyapuri New Delhi110021

The employees of NKFL shall maintain strict confidentiality of the fact of furnishing/ reporting details of suspicious transactions.

10.1 Customer Education

NKFL shall educate the Customer on the objectives of the KYC programme so that customer understands and appreciates the motive and purpose of collecting such information.

10.2 Introduction of new technologies

NKFL shall pay special attention to any money laundering threats that may arise from new or developing technologies including online transactions that may favour anonymity, and take measures, if needed, to prevent their use in money laundering. NKFL shall ensure that any remittance of funds by way of demand draft, mail/telegraphic transfer or any other mode for any amount is affected by cheques and not against cash payment.

10.3 Applicability to Branches and Subsidiaries outside India

The above guidelines shall also be applicable to the branches and majority owned subsidiaries located abroad, especially, in countries which do not or insufficiently apply the FATF Recommendations, to the extent local laws permit as and when the Company opens overseas branches. When local applicable laws and regulations prohibit implementation of these guidelines, the same will be brought to the notice of Reserve Bank of India.

10.3 Applicability to Branches and Subsidiaries outside India

The above guidelines shall also be applicable to the branches and majority owned subsidiaries located abroad, especially, in countries which do not or insufficiently apply the FATF Recommendations, to the extent local laws permit as and when the Company opens overseas branches. When local applicable laws and regulations prohibit implementation of these guidelines, the same will be brought to the notice of Reserve Bank of India.

10.4 Closure of Accounts / Termination of Financing / Business Relationship

Where NKFL is unable to apply appropriate KYC measures due to non furnishing of information and/or non-operation by the customer, NKFL shall terminate Financing/Business Relationship after issuing due notice to the customer explaining the reasons for taking such a decision. Such decision shall be taken with the approval of Chairman & Managing Director or key managerial persons authorized for the purpose.

10.5 KYC for the Existing Accounts:

While the KYC guidelines will apply to all new customers, the same would be applied to the existing customers on the basis of materiality and risk. However, transactions with existing customers would be continuously monitored for any unusual pattern in the operation of the accounts.

10.6 Updation in KYC Policy of Company

PO after taking the due approval from the Board of Directors of NKFL shall make the necessary amendments/modifications in the KYC/ AML/ CFT Policy or such other related guidance notes of Company, to be in line with RBI or such other statutory authority’s requirements/updates/ amendments from time to time.

There exists the possibility that trust/nominee or fiduciary accounts can be used to circumvent the customer identification procedures. NKFL shall determine whether the customer is acting on behalf of another person as trustee/nominee or any other intermediary. If so, NKFL shall insist on receipt of satisfactory evidence of the identity of the intermediaries and of the persons on whose behalf they are acting, as also obtain details of the nature of the trust or other arrangements in place. While opening an account for a trust, NKFL shall take reasonable precautions to verify the identity of the trustees and the settlors of trust (including any person settling assets into the trust), grantors, protectors, beneficiaries and signatories. Beneficiaries should be identified when they are defined. In the case of a 'foundation', steps should be taken to verify the founder managers/ directors and the beneficiaries, if defined.

NKFL shall be vigilant against business entities being used by individuals as a ‘front’ for maintaining accounts with banks. NKFL shall examine the control structure of the entity, determine the source of funds and identify the natural persons who have a controlling interest and who comprise the management. These requirements may be moderated according to the risk perception e.g. in the case of a public company it will not be necessary to identify all the shareholders.

Politically exposed persons are individuals who are or have been entrusted with prominent public functions in a foreign country, e.g., Heads of States or of Governments, senior politicians, senior government/judicial/military officers, senior executives of state-owned corporations, important political party officials, etc. NKFL shall gather sufficient information on any person/customer of this category intending to establish a relationship and check all the information available on the person in the public domain. NKFL shall verify the identify of the person and seek information about the sources of funds before accepting the PEP as a customer. The decision to open an account for PEP shall be taken at a senior level which shall be clearly spelt out in Customer Acceptance policy. NKFL shall also subject such accounts to enhanced monitoring on an ongoing basis. The above norms will also be applied to the accounts of the family members or close relatives of PEPs.

Customer Identification Procedure Features to be verified and Documents that may be obtained from Customers

An Indicative List of Suspicious Activities Transactions Involving Large Amounts of Cash

Company transactions, that are denominated by unusually large amounts of cash, rather than normally associated with the normal commercial operations of the company, e.g. cheques,

Transactions that do not make Economic Sense

Transactions in which assets are withdrawn immediately after being deposited unless the business activities of the customer's furnishes a plausible reason for immediate withdrawal.

Activities not consistent with the Customer's Business

Accounts with large volume of credits whereas the nature of business does not justify such credits.

Attempts to avoid Reporting/Record-keeping Requirements

• A customer who is reluctant to provide information needed for a mandatory report, to have the report filed or to proceed with a transaction after being informed that the report must be filed.
• Any individual or g group that coerces/induces or attempts to coerce/induce a NBFC employee not to file any reports or any other forms.
• An account where there are several cash transactions below a specified threshold level to a void filing of reports that may be necessary in case of transactions above the threshold level, as the customer intentionally splits the transaction into smaller amounts for the purpose of avoiding the threshold limit.

Unusual Activities

Funds coming from the countries/centers which are known for money laundering.

Customer who provides Insufficient or Suspicious Information

• A customer/company who is reluctant to provide complete information regarding the purpose of the business, prior business relationships, officers or directors, or its locations.
• A customer/company who is reluctant to reveal details about its activities or to provide financial statements.
• A customer who has no record of past or present employment but makes frequent large transactions.

Certain NBFC Employees arousing Suspicion

• An employee whose lavish lifestyle cannot be supported by his or her salary.
• Negligence of employees/willful blindness is reported repeatedly.

Some examples of suspicious activities/transactions to be monitored by the operating staff-

• Large Cash Transactions
• Multiple accounts under the same name
• Placing funds in term Deposits and using them as security for more loans
• Sudden surge in activity level
• Same funds being moved repeatedly among several accounts

NABKISAN Finance Limited (NKFL) (Formerly “Agri Development Finance (Tamilnadu) Limited”) is a subsidiary of National Bank for Agriculture and Rural Development (NABARD) and was incorporated on 14th February 1997 with the objective of carrying on the business of providing credit and other facilities to enterprises engaged in agriculture and allied activities and for promoting the social and economic welfare of the public in rural area, in the state of Tamilnadu. Subsequently, with the change in name, the operations were expanded to pan India basis with focus on financing Producer Organisations (POs).

NKFL meets the criteria for undertaking the mandatory CSR activities corresponding to the provisions specified in the Companies Act, 2013 coming to effect from April 01, 2016.

The CSR policy aims to lay down norms to enable the Company to contribute to the society through the activities it envisages from time to time.

The policy framed hereunder may be called as “NABKISAN Corporate Social Responsibility Policy”.

It shall come into force with effect from April 01, 2016.

• “Act” means the Companies Act, 2013.
• “Rules” means the Companies (Corporate Social Responsibility) Rules, 2014 and any modifications and /or re-enactment made thereof from time to time.
• “CSR Policy” means a policy framed by the Company under the provisions of Section 135 of the Companies Act,2013, the Companies (Corporate Social Responsibility) Rules, 2014, Schedule VII to the Companies Act, 2013 and any other applicable provisions of the Companies Act, 2013 and any modifications and /or re-enactment made thereof from time to time “NABKISAN” means NABKISAN Finance Limited.
• “The Company” / “Company” means NABKISAN.
• “Board” means the Board of Directors of NABKISAN.
• “CSR” / “Corporate Social Responsibility” means the projects or programs relating to activities undertaken by the Board of the Company in pursuance of recommendations of the CSR Committee of the Board as per declared CSR Policy of the Company.
• “CSR Committee” means the Committee of the Board on CSR constituted under the provisions of Section 135 of the Companies Act, 2013 and includes any reconstitution thereof from time to time.
• “Net Profit” means the net profit of the Company as per its financial statement prepared in accordance with the applicable provisions of the Companies Act, 2013.

CSR activities taken up by the Company shall include the activity / activities amongst and relating to the list provided under the Companies Act or any relevant act / provisions as envisaged by the Government of India from time to time.

The activities according to Schedule VII of the Companies Act, 2013 are:

• Eradicating hunger, poverty and malnutrition, promoting preventive health care and sanitation and making available safe drinking water
• Promotion of education including special education and employment enhancing vocation skills especially among children, women, elderly and the differently abled and livelihood enhancement projects
• Promoting gender equality, empowering women, setting up homes and hostels for women and orphans; setting up old age homes, day care centres and such other facilities for senior citizens and measures for reducing inequalities faced by socially and economically backward groups
• Ensuring environmental sustainability, ecological balance, protection of flora and fauna, animal welfare, agroforestry, conservation of natural resources and maintaining quality of soil, air and water
• Protection of national heritage, art and culture including restoration of buildings and sites of historical importance and works of art; setting up public libraries; promotion and development of traditional arts and handicrafts
• Measures for the benefit of armed forces veterans, war widows and their dependents
• Training to promote rural sports, nationally recognized sports, Paralympic sports and Olympic sports
• Contribution to the Prime Minister’s National Relief Fund or any other fund set up by the Central Government for socio-economic development and relief and welfare of the Scheduled Castes, the Scheduled Tribes, other backward classes, minorities and women
• Contribution or funds provided to technology incubators located within academic institutions which are approved by the Central Government
• Rural development projects.

• The identified CSR activities will be implemented as per Section 135 of the Companies Act, 2013 and the rules framed thereunder.
• Company shall give preference to the local areas and areas around which it operates.
• The CSR expenditure would be on activities permitted under Section 135 read with Schedule VII of the Companies Act, 2013.
• The company can collaborate with other companies for undertaking CSR activities.
• Contributions to corpus of a trust /society / Section 8 companies, etc., will qualify as CSR expenditure as long as such entity is created exclusively for undertaking CSR activities or where corpus is created exclusively for a purpose directly relatable to a subject covered in Schedule VII of the Companies Act, 2013.
• It will be ensured that CSR activities are beneficial to the community and benefits are available on long term basis

CSR Committee of the company will be responsible for the monitoring of various CSR projects or programs undertaken by the company directly or indirectly. The Committee shall ensure that:

• Company undertakes the CSR activities as provided in the CSR Policy.
• The projects / programs are implemented as per the program approved by the Board of Directors.
• The budget allocated for each of the project is utilized for the projects as per the approved plans.
• The objective of the project / program is achieved as per the plans.
• Wherever projects /programs are undertaken in partnership with one or more organisations, the part of the project undertaken by the company shall be distinguishable and necessary supporting documents in respect of the same shall be obtained from the other partners / implementing agency on an annual basis.
• A quarterly report on implementation shall be submitted to the Board by the CSR Committee.

The company shall report the details of CSR program or projects undertaken under its CSR Policy to the CSR Committee of the Board and thereafter for disseminating the same to the Members of the Company together with the Annual Report in the format prescribed in the Companies (CSR) Rules, 2014. Progress under CSR will be placed before the Board at regular intervals.

The fund for the CSR should be allocated based on at least two percent of the average net profits of the company made during the three immediately preceding financial years. The net profits shall be computed as per Section 198 of the Companies Act, 2013. In case the company could not spend the envisaged amount on CSR activities during the relevant financial year, the Board shall specify the reasons thereof in its Annual Report. The corpus would include (a) 2% of the average net profits, and (b) surplus arising out of CSR activities.

• Any surplus arising out of the CSR projects/programs or activities shall not form part of the business profits of the company.
• If it is observed that any CSR Activity taken up for implementation is found not properly implemented, the CSR Committee may, with approval of the Board, may discontinue funding the project at any time during the course of implementation and use such funds for any other project.
• The CSR Committee shall have the power to clarify any doubts or rectify any anomalies that may exist in connection with the effective execution of this CSR Policy.

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The objective of Vigilance policy is to frame guidelines to structure efficient and effective vigilance system in the Company in the larger interest of all stake holders. Vigilance policy will be a useful tool for reference and guidance to the staff of the Company, discharging their duties/responsibilities in whichever capacity. It will also be of assistance to the Management of the Company, to be fully compliant with vigilance related instructions/guidelines and also for maintaining better corporate governancestandards.

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Corporate Governance is a set of systems and practices to ensure that the affairs of the Company are being managed in a way which ensures accountability, transparency and fairness in all transactions in the widest sense and meet the stakeholder’s aspirations and social expectations. Corporate Governance is a journey for constantly improving sustainable value creation and is an upward moving target.

The Company has set itself the objective of achieving excellence in its business. As a part of its growth strategy, the Company believes in adopting the ‘best practices’ that are followed in the area of Corporate Governance. The Company emphasizes the need for full transparency and accountability and conducting its business in a highly professional and ethical manner, thereby enhancing trust and confidence of all its stakeholders. The Company believes in pursuing holistic growth and realizes its responsibility towards its stakeholders and environment.

The comprehensive Corporate Governance practices ensures that the Company always works optimally, protecting the best interests of the stakeholders and withholding the reputation and status of the Company.

The Board of Directors play a pivotal role in ensuring that the good corporate governance practices are followed within the Company. The Board of Directors along with its Committees oversees the functioning of the Company and that of its management; and ensures that every decision taken is in the best interest of the stakeholders of the Company. The Directors shall possess the requisite qualifications and experience in general corporate management, banking, finance, marketing and other allied fields which enable them to enhance their contribution effectively to the Company in their capacity as Directors of the Company. The Board of Directors of the Company shall have an optimum combination of Executive, Non-Executive, Independent and Woman Directors (where the paid-up capital is Rs.100 Crore or more), as per the Guidelines/ Regulations applicable to the Company. All the Directors shall meet the ‘fit and proper’ criteria as prescribed by the RBI. None of the Directors of the Company are related to each other. All the Directors on the Board (except Independent Directors and NABARD Nominee Directors) are liable to retire by rotation and one third of such Directors shall retire at every Annual General Meeting of the Company. The Directors who are longest in office shall retire and in accordance with the provisions of applicable laws shall be eligible for re-election All the Directors shall make the necessary annual disclosure regarding their change in concern or interest in any company or companies or bodies corporate, firms, or other association of individuals including shareholding, directorships and committee positions and shall intimate changes as and when they take place. The Board of Directors shall lay down a Code of Conduct for Senior Management of the Company. Senior Management Personnel shall affirm compliance with the code on an annual basis. The Directors shall not disclose any confidential information, including commercial secrets, technologies, advertising and sales promotion plans, unpublished price sensitive information, during their term or following termination (by whatever means) to third parties unless expressly approved by the Board or required by law.

Meetings of the Board:

At least four Board Meetings shall be held in a year. The maximum time gap between any two meetings shall not be more than one hundred and twenty days. The minimum information to be statutorily made available to the Board shall be furnished to the Directors before the meeting. The Quorum for a Meeting of the Board shall be one-third of the total strength of the Board, or two Directors, whichever is higher and the same shall be maintained for the entire meeting.

The Independent Directors of the Company shall meet at least once in a year without the presence of Non-Executive Directors and the Management in terms of Schedule IV of the Companies Act, 2013.

The Current Board comprises of the following members:

• SMT.P V BHARATHI, Chairman cum Nominee Director
• Shri Nilay Dharmanarain Kapoor, Nominee Director
• SHRI.G IMMANUVEL, Nominee Director & CFO
• Shri Sibi Adhithya Senthil Kumar, IAS, Nominee Director
• Shri Deepak Singhal, Independent Director
• Shri Arindom Datta, Independent Director
• Shri Alok Bhargava, Independent Director
• Shri Emmanuel Murray, Independent Director
• Shri Satyanarayana Jonnalagadda, Independent Director
• SHRI.SRINIVASAN RAMESH, Managing Director & CEO

For operational convenience and to focus effectively on the issues and ensure expedient resolution of diverse matters, the Board has constituted several committees to deal with specific matters and for operational convenience, delegated powers for different functional areas to different Committees in accordance with the applicable laws. The Audit Committee, Nomination and Remuneration Committee, ALM Committee, Risk Management Committee, Corporate Social Responsibility Committee, Share Transfer Committee and other Committee(s) have been constituted in accordance with the provisions of the Companies Act, 2013, guidelines / directions issued by the RBI as applicable to the Company and for internal requirements and operational convenience. These Board Committees have specific terms of reference/scope to focus effectively on the issues and ensure expedient resolution of diverse matters. All decisions pertaining to the constitution/re-constitution/dissolution of Committees, appointment of members and fixing/modification of terms of reference of the various Committees shall be made by the Board of Directors.

Details of the Various Committees are as under:

1. AUDIT COMMITTEE

The Company has in place an Audit Committee constituted under the provisions of Section 177 of the Companies Act, 2013.

The Audit Committee comprises of:

• Shri Deepak Singhal, Independent Director - Chairman
• Shri Nilay Dharmanarain Kapoor, Nominee Director
• Shri Alok Bhargava, Independent Director
• Spl Invitee: Managing Director & CEO of NABKISAN

Role and Responsibilities (Terms of Reference):

• To make the recommendation for appointment, remuneration and terms of appointment of auditors of the company.
• To review and monitor the auditor’s independence and performance, and effectiveness of audit process.
• To examine the financial statement and the auditors’ report thereon.
• To approve transactions of the company with related parties.
• To scrutinise inter-corporate loans and investments.
• To make the valuation of undertakings or assets of the company, wherever it is necessary.
• To evaluate internal financial controls and risk management systems.
• To monitor the end use of funds raised through public offers and related matters.

2. NOMINATION AND REMUNERATION COMMITTEE:

The Company has in place a nomination and remuneration committee constituted under the provisions of Section 178 of the Companies Act, 2013. The Nomination and Remuneration Committee shall meet as and when required to discuss matters. The Committee shall meet at least once in every financial year. The Nomination and Remuneration Committee shall comprise of at least three directors and all Directors of the Committee shall be Non- Executive Directors. At least fifty percent of the Members shall be Independent Directors. The quorum shall comprise of any two Directors.

The Nomination & Remuneration Committee comprises of:

• Shri.Nilay Dharmanarain Kapoor, Director - Chairman
• Shri Emmanuel Murray, Independent Director
• Shri Deepak Singhal, Independent Director

Role and Responsibilities (Terms of Reference):

• The Nomination and Remuneration Committee shall identify persons who are qualified to become directors and who may be appointed in senior management in accordance with the criteria laid down, recommend to the Board their appointment and removal and shall carry out evaluation of every director’s performance.
• The Nomination and Remuneration Committee shall formulate the criteria for determining qualifications, positive attributes and independence of a director and recommend to the Board a policy, relating to the remuneration for the directors, key managerial personnel and other employees.
• The Nomination and Remuneration Committee shall, while formulating the policy ensure that—

(a) the level and composition of remuneration is reasonable and sufficient to attract, retain and motivate directors of the quality required to run the company successfully;

(c) remuneration to directors, key managerial personnel and senior management involves a balance between fixed and incentive pay reflecting short and long-term performance objectives appropriate to the working of the company and its goals:

• The policy formulated shall be disclosed in the Board's report.

3. CORPORATE SOCIAL RESPONSIBILITY (CSR) COMMITTEE

The constitution and the terms of reference of the Corporate Social Responsibility Committee shall be in compliance with the provisions of section 135(1) of the Companies Act, 2013 (“the Act”) and the Rules framed thereunder and Schedule VII of the Act. The Corporate Social Responsibility Committee shall consist of three or more Directors, out of which at least one Director shall be an Independent Director.

The CSR Committee comprises of:

• Shri Arindom Datta, Independent Director - Chairman
• Shri. Nilay Dharmanarain Kapoor, Director
• Shri. Alok Bhargava, Independent Director
• MD & CEO of NABKISAN
• CFO of NABKISAN

Role and Responsibilities (Terms of Reference):

• To formulate and recommend to the Board, a CSR policy which shall indicate the activities to be undertaken by the Company as per the Companies Act, 2013;
• To review and recommend the amount of expenditure to be incurred on the activities to be undertaken by the company;
• To monitor the CSR policy of the Company from time to time;
• Any other matter as the CSR Committee may deem appropriate after approval of the Board of Directors or as may be directed by the Board of Directors from time to time.

4. RISK MANAGEMENT COMMITTEE

The Risk Management Committee comprises of:

• SMT.P V BHARATHI, Additional Director & Chairperson - Chairperson of the committee
• Shri.Nilay Dharmanarain Kapoor, Director
• Shri Arindom Datta, Independent Director
• Spl invitee from RMD, NABARD as a domain expert

The Risk Management Committee is required to manage the integrated risk and inform the Board from time to time the progress made in putting in place a progressive risk management system, risk management policy and strategy followed by the Company.

5. ASSET LIABILITY MANAGEMENT COMMITTEE (ALCO)

The ALM Committee comprises of:

• Managing Director & CEO of NABKISAN
• CFO of NABKISAN
• COO of NABKISAN

The constitution and the terms of reference of the Asset Liability Committee shall be in compliance with the Guidelines issued by RBI. The ALCO's primary goal is to evaluate, monitor and approve practices relating to risk due to imbalances in the capital structure.

6. SHARE TRANSFER COMMITTEE

The Share Transfer Committee comprises of:

• Shri.Nilay Dharmanarain Kapoor,Director
• Managing Director & CEO of NABKISAN
• CFO of NABKISAN

The Share Transfer Committee was constituted to deal with various matters relating to share transfer/transmission, issue of duplicate share certificates, approving the split and consolidation request and other matters relating to transfer and registration of shares.

7. IT Strategy Committee

The IT Strategy committee comprises of:

• Shri Alok Bhargava,Independent Director - Chairman
• Managing Director & CEO of NABKISAN
• CFO of NABKISAN
• COO of NABKISAN
• Shri Sameer Kumar Prayaga, VP/CTO, NABKISAN
• Spl invitee from DIT, NABARD as a domain expert

Role and Responsibilities (Terms of Reference):

• Approving IT strategy and policy documents and ensuring that the management has put an effective strategic planning process in place;
• Ascertaining that management has implemented processes and practices that ensure that the IT delivers value to the business;
• Ensuring IT investments represent a balance of risks and benefits and that budgets are acceptable;
• Monitoring the method that management uses to determine the IT resources needed to achieve strategic goals and provide high-level direction for sourcing and use of IT resources;
• Ensuring proper balance of IT investments for sustaining NBFC’s growth and becoming aware about exposure towards IT risks and controls;

8. INTERNAL COMPLAINTS COMMITTEE FOR PREVENTION OF SEXUAL HARASSMENT (POSH) AT WORKPLACE

The POSH Committee comprises of:

• COO of NABKISAN, Chairperson
• Smt.Sheba Sangeetha, SVP
• Smt.VASUMATHI KRISHNAN, Sr. AVP
• Ms.Snehal Verkar – External Member

Role and Responsibilities (Terms of Reference):

• The Complaints Committee should consist of four members headed by a Senior lady Officer and not less than half of its members should be women. The Managing Director (MD) will nominate the members on the Committee;
• The Complaints Committee should have one member from a third party either a NGO or association committed to the cause of women or a person familiar with the issues relating to sexual harassment;
• The Complaints Committee would meet if the situation warrants;
• The role of the Complaints Committee is recommendatory for further necessary action by the Competent Authority;
• The Complaints Committee should ensure time bound disposal of the Complaints;
• The Complaints Committee should ensure strict maintenance of confidentiality;
• The Complaints Committee should maintain a Complaints Register;
• The Internal Complaint Committee against Sexual Harassment will prepare an annual report relating to the number of cases filed, if any, and their disposal details;
• The above report shall be included in the Annual Report;

Other Committees: In addition to the aforesaid Committees, the Company has also constituted the following Committees to oversee specific areas and/ or for the smooth functioning of business/ functional operations.

• Loan Committee
• Investment Committee
• Business Development Committee

Pursuant to the guidelines on Fair Practices Code issued by Reserve Bank of India, the Company has adopted a policy on Fair Practices Code which is posted on the website of the Company.

The Company has adopted a code of conduct for Directors and Senior Management of the Company and due care is taken that the Directors and Senior Management adhere to it.

The Company shall adopt such policies, as may be required to adopt under the Companies Act, 2013, the RBI Guidelines / Directions applicable to the company, and such other laws and regulations as may be applicable. The policies adopted may be reviewed by the Board from time to time.

The Company is committed to make adequate disclosures based on the principles of transparency, timeliness, fairness and continuity. The Board of Directors and employees of the Company shall ensure and make necessary disclosures to the Company, the Regulator(s) / Statutory Authorities, the Shareholders, Investors, Members or other stakeholders as may be required by the applicable laws and the codes / policies of the Company.

Smt.M.Bhuvaneswari, Company Secretary appointed in terms of Section 203 of the Companies Act, 2013, shall act as the Compliance Officer of the Company. The Compliance Officer shall, inter-alia, be responsible for setting forth policies / procedures and ensuring conformity with the applicable laws/ regulations/ guidelines including Companies Act and RBI Directions/guidelines, issued from time to time.

The Board of Directors of the Company reserves the right to add, amend, modify the Guidelines, as and when it deems appropriate.

Your appointment is subject to the following:

• During your tenure as an Independent Director, you will have to submit a declaration at the beginning of every Financial Year under Section 149 (7) of the Companies Act, 2013 (“Act”) stating that you meet the criteria of Independence.
• So long as you are an Independent Director of the Company, the number of companies in which you hold office as a Director or a chairman or committee member will not exceed the limit stipulated under the Act.
• So long as you are an Independent Director of the Company, you will ensure that you do not get disqualified to act as a Director pursuant to the provisions of Section 164 of the Act.
• You will ensure compliance with other provisions of the Act as applicable to you as an Independent Director.

Your Appointment is for a term of _____ years commencing from your date of appointment.

Your Appointment is for a term of _____ years commencing from your date of appointment.

• You will abide by the guidelines of professional conduct, role, function and duties as an Independent Directors provided in Schedule IV of the Companies Act, 2013.
• You will not hold office as a Director or any other office in a competing firm/entity.
• You are expected to stay updated on how best to discharge your roles, responsibilities, and duties and liabilities, as an Independent Director of the Company under applicable law, including keeping abreast of current changes and trends in economic, political, social, financial, legal and corporate governance practices.
• You are expected to:
  • take decisions objectively and solely in the interests of the Company;
  • facilitate Company’s adherence to high standards of ethics and corporate behavior;
  • guide the Board in monitoring the effectiveness of the Company’s governance practices and to recommend changes, required if any;
  • guide the Board in monitoring and managing potential conflicts of interest of Management, Board Members and Stakeholders, including misuse of corporate assets and abuse in related party transactions;
  • guide the Board in ensuring the integrity of the Company’s accounting and financial reporting systems, including the independent audit, and that appropriate systems of control are in place, in particular, systems for risk management, financial and operational control, and compliance with the law and relevant standards.

As may be fixed by the Board of Directors.

You will have access to confidential information, whether or not the information is marked or designated as “confidential” or “proprietary”, relating to the Company and its business.

You shall use reasonable efforts to keep confidential and to not disclose to any third party, such Confidential Information.

If any Confidential Information is required to be disclosed by you in response to any summons or in connection with any litigation, or in order to comply with any applicable law, order, regulation or ruling, then any such disclosure should be, to the extent possible, with the prior consent of the Board.

RBI circular no. RBI/2021-2022/125 DOR.STR.REC.68/21.04.048/2021-22 on ‘Prudential norms on Income Recognition, Asset Classification and Provisioning, pertaining to Advances – Clarifications’ dated Nov. 12, 2021

An amount is to be treated as overdue if it is not paid on the due date fixed by the Lender (before the Lender runs the day-end process for that day). Due Date is the date as specified in the Repayment Schedule on which the instalment is due to be paid.

The below Illustration covers the concepts of date of overdue, classification as Special Mention Account (“SMA”) and Non-Performing Asset (NPA), upgradation of loan account etc.

Accordingly, the date of SMA/NPA shall reflect the asset classification status of an account at the day-end of that calendar date. An illustration of such classification is given below:

Customer classified as NPAs may be upgraded as ‘standard’ only if entire arrears of interest and principal are paid by the customer. Further, in case of borrowers, having more than one credit facility from the Company, loan accounts shall be upgraded from ‘NPA’ to ‘Standard Asset’ category only upon repayment of entire arrears of interest and principal pertaining to all the credit facilities

For example, ABC company has availed a loan from financial institution and failed to pay interest & principal for 2 installments for a continuous period of 90 days or more. In this case, his account will be marked as ‘NPA’. To upgrade his account from ‘NPA’ to ‘Standard Asset’, he should repay the overdue amount in full.

Classification of borrower accounts as NPA shall be done as part of day-end process for the relevant date and NPA classification date shall be the calendar date for which the day-end process is run.

Any delinquency in the loan account as mentioned above is reported to Credit Information Companies and credit score of the customer shall get impacted adversely. Paying your instalments on time which helps you build your Credit Score. Higher Credit Score may help you get higher loan value with lower interest rates.