The Reserve Bank of India ("RBI") vide its notification DNBS. 204/CGM (ASR)-2009 dated January 2, 2009, and the Master Direction DNBR. PD. 007/03.10.119/2016-17 dated September 1, 2016, and subsequently amended from time to time, advises that the Non-Banking Financial Companies (NBFCs) and their Board of Directors undertake a comprehensive review of their internal principles and procedures and implement an interest rate model that factors in critical elements and relevant factors such as the cost of funds, margin, and risk premium in order to determine the rate of interest to be charged for loans and advances. This model aims to serve as the basis for determining the interest rates applicable to loans and advances, ensuring alignment with RBI guidelines and promoting financial stability and responsible lending practices in the NBFC sector.

Cieco Securities Private Limited (herein after referred to as “Company” or “Cieco”) shall adopt all such guidelines prescribed by RBI from time to time and shall make appropriate modifications if any necessary to this Policy to conform to the standards so prescribed. The Company operates under the brand name “ASAP Finance” hence the name used as “ASAP Finance” shall represent Cieco Securities Private Limited for all purposes. In compliance with these regulatory requirements and the Fair Practices Code adopted by the Company, the Company has adopted this Interest Rate Policy broadly outlining the Interest Rate Model and the Company’s approach of risk gradation in this regard for its lending business.

Disclosure

The interest rate determination process and interest rate shall be disclosed on the Company’s website and shared with the customer in a timely and transparent manner.

Interest Rate

This policy is approved by the Board of Directors of the Company (herein after referred to as “Board”) and the Company has adopted the interest rate model considering all relevant factors such as cost of funds, margin and risk premium in order to determine the rate of interest to be charged for loans and advances. In terms of this policy, the rate of interest and the approach for gradations of risk and the rationale for charging different rates of interest to different categories of borrowers shall be disclosed by the Company to the borrowers/ customers through the Company’s website and/ or through other means in a timely and transparent manner and the information published on the website shall be updated whenever there is any change in the rates of interest. Further, the rate of interest to be charged from every individual borrower shall be communicated individually by way of loan documentation like sanction letter and loan agreements followed by explicit consent in writing from every such borrower prior to the disbursal of loan. The rate of interest shall also be communicated in annualized rate so that the borrower is aware of the exact rates that would be charged to the loan account This policy for the Interest Rate model states that the interest rate or other rates and costs charged to the borrower shall be based on the following broad parameters:

• Risk profile of the borrower;
• Credit score of the borrower;
• Funds raising cost;
• Cost of Equity;
• Operational Expense Ratio;
• Credit loss / Recovery cost;
• Other factors that may be relevant in each case.

The rate of interest and/ or charges for the same loan product and same tenor availed during the same period by different customers need not to be standardized as it can vary for different customers based on consideration of any or a combination of above parameters. Our loans shall range from ₹5,000 to ₹5,00,000 with repayment periods starting from 15 days to 15 months. The maximum annual interest rates shall be 108.0% for Personal loans and 310.25% for Salary Advance loans for the quarter Q4FY2026. The Company shall strive to progressively reduce the average interest rate charged from customers with the increase in focus on growth of business, reduction in credit loss and better operational efficiency. The Company shall cap the maximum annual interest rate to 75.0% for Personal loans and 200% for Salary Advance loans by the end of the quarter Q4FY2027. However, the rates may vary from case to case. Further, all loans are repaid through Equal Monthly Instalments (EMIs) or Bullet repayment and via electronic channels only. Company shall offer only Fixed Rate loans to all its customers. The interest could be charged on monthly or on such rest as communicated in the loan sanction terms. The interest shall be deemed payable immediately on the due date as communicated and no grace period for payment of interest is allowed. Besides normal interest, Company may levy additional/ penal interest for delay or default in making EMI repayments and such interest to be calculated at the contracted default interest rate applicable to the defaulted EMI alone for the number of days of delay in repaying the EMI.

The changes in the interest rates would be prospective in effect and intimation of change of interest or other related charges would be given to customers in a mode and manner deemed fit.

Fees & Charges

Besides interest, Company shall require borrowers/ customers to bear certain financial cost for availing the loan and these are usually in the nature of fees/ charges like processing/ credit assessment fees or origination/ conversion fees. These charges shall not be collected from any customer at the time of loan application but only from those customers who are sanctioned loan and are willing to avail the disbursal of loan and hence customer to be credited with the loan amount net of any fees/ charges that apply to the loan application process. Hence it is decided that the Company shall not charge any fees from customer who apply but are not approved the loan or are approved but do not avail the loan. The burden of fees shall only apply to borrowers/ customers who avail the loan from the Company. Such loan application fees by whatever name called shall be commensurate with the expenses incurred by the Company in processing of all loan applications and range from 5 – 10% of loan amount. In addition to the above, Company shall require borrowers/ customers to bear charges like EMI mandate return charges, ECS/ Direct Debit/ ACH mandate registration/ lodgement/ handling charges, Fees for Rescheduling of loan or any other services provided by the Company or any other cost incurred by the Company for the provision of services related to the loan granted to the customers or as per schedule of charges communicated by the Company from time to time or cost towards any expense incurred by the Company for the recovery of the loan. Besides these charges, service tax and other cesses, if any would be collected at applicable rates from time to time. The Company may also levy and collect charges for loan documentation, portfolio monitoring, recovery of loan or for other facilities and services provided based on market standards. The initial fees for availing the loan details of the charges will be as per the schedule of charges. Any revision in these charges would be prospective in effect. Claims for refund or waiver of charges / penal interest would normally not be entertained by the Company, and it is at the sole discretion of the Company to deal with such requests.

Customer Communication

The Company shall communicate the final fixed interest rate and fees and charges to customers at the time of sanction through Sanction Letter and other acceptable mode of communication. The disbursement loan documentation shall also specify the rate of interest among other loan parameters. A copy of the loan agreement shall be provided to the customer after the disbursal of loan.

Amendment

This policy may be amended or modified in whole or in part, at any time without assigning any reason, whatsoever with the approval of the Board.