Digital Lending Guidelines

Finbros Finance is a Lending Service Provider (LSP) — a technology platform that facilitates digital lending by connecting borrowers with RBI-regulated banks and NBFCs (Regulated Entities / REs).

• •Company Name: Finbros Capital Advisory Pvt Ltd.
• •Brand Name: Finbros Finance
• •Website: https://finbrosfinance.com
• •Email: care@finbros.com
• •Address: 901, 9th Floor, Dev Corpora, Eastern Express Hwy, opp. Cadbury Junction, Thane West, Thane, Maharashtra 400601
• •Finbros does not lend money, does not hold borrower funds, and does not charge any fees to borrowers.
• •All loan processing, underwriting, disbursal, and repayment is handled exclusively by the partnered RE.

As mandated under RBI's Digital Lending Directions, 2025 (Para 8), every borrower must receive a Key Fact Statement (KFS) before executing any loan contract. The KFS includes:

• •Loan amount to be disbursed
• •Annual Percentage Rate (APR) — all-inclusive cost of the loan
• •Repayment schedule and EMI amount
• •Processing fees and other charges
• •Penal charges on overdue instalments
• •Cooling-off / look-up period details
• •Foreclosure and pre-payment charges
• •Recovery mechanism
• •Details of the Grievance Redressal Officer

The KFS is digitally signed and automatically sent to the borrower's registered email/SMS upon execution of the loan contract. Any charges not mentioned in the KFS cannot be levied on the borrower at any stage during the loan tenure.

The APR represents the true, all-inclusive annual cost of borrowing and is disclosed prominently in the KFS before the borrower accepts any loan offer. The APR includes:

• •Rate of interest (on reducing balance basis)
• •Processing and documentation fees
• •Insurance charges (if part of the loan product)
• •Any other mandatory charges included in the loan

For variable rate loans, the APR shown is as of the date of loan origination and is updated each time the applicable rate changes. No hidden charges are permitted beyond those disclosed in the KFS.

• •All loan disbursals are made directly into the borrower's bank account by the RE.
• •Finbros Finance does not receive or hold any loan funds at any point.
• •All repayments (EMIs) are made directly to the RE's bank account via NACH/auto-debit mandate.
• •Finbros Finance has no control over the flow of funds between the borrower and the RE.
• •Fees payable to Finbros as an LSP are paid exclusively by the RE and are never charged to the borrower.

As per RBI Digital Lending Directions, 2025 (Para 10), every borrower is entitled to a cooling-off period during which they may exit the loan without penalty.

• •Minimum cooling-off period: 1 day (as per updated 2025 Directions)
• •During this period, the borrower may repay the principal and proportionate APR to exit the loan.
• •A reasonable one-time processing fee (as disclosed in the KFS) may be retained by the RE.
• •No additional penalty is levied for exercising the cooling-off option.

Finbros Finance is committed to protecting your personal and financial data in accordance with the Digital Personal Data Protection (DPDP) Act, 2023 and RBI guidelines.

• •Only need-based data is collected from borrowers — with explicit, prior, and informed consent.
• •Borrowers may withdraw consent at any time and request erasure of their data.
• •No sensitive data (contact lists, media files, biometrics) is collected without valid legal reason.
• •All data is stored in India. Any temporary processing outside India is deleted and transferred back within 24 hours.
• •Personal data is shared with the partnered RE solely for loan processing purposes.
• •Finbros does not sell or rent borrower data to any third party.
• •A comprehensive privacy policy is available at: https://finbrosfinance.com/privacy-policy

• •Right to receive a KFS before loan execution — no loan contract is binding without prior KFS delivery.
• •Right to a cooling-off period — exit the loan within the prescribed period without penalty.
• •Right to withdraw data consent and request data erasure at any time.
• •Right to be informed of any recovery agent assigned before any contact is made.
• •Right to fair and unbiased presentation of loan offers — Finbros does not promote any single lender.
• •Right to lodge a complaint with the Grievance Officer and receive resolution within prescribed timelines.
• •Right to escalate unresolved complaints to RBI's Complaint Management System (CMS) after 30 days.
• •Credit limit can only be enhanced upon explicit request by the borrower — no automatic enhancement.

As an LSP partnering with multiple Regulated Entities, Finbros Finance complies with RBI's multi-lender arrangement requirements (Para 6, effective November 1, 2025):

• •All eligible loan offers are displayed in a neutral, unbiased manner.
• •Each offer displays: RE name, loan amount, tenure, APR, monthly repayment, penal charges, and a link to the KFS.
• •No dark patterns or deceptive design is used to steer borrowers toward any specific lender.
• •If offers are ranked, the ranking methodology is publicly disclosed and applied uniformly.
• •Finbros does not receive any incentive to promote one RE over another to borrowers.

The following Regulated Entities (REs) are currently partnered with Finbros Finance for digital lending services:

This list is updated periodically. REs are solely responsible for loan sanction, disbursal, and repayment.

For privacy concerns, data rights requests (access, correction, erasure, consent withdrawal), or any complaints related to our digital lending services, please contact our Grievance Officer:

We acknowledge grievances promptly and resolve them within the timelines prescribed under the DPDP Act and RBI guidelines. If dissatisfied with our resolution, you may escalate to the RBI Complaint Management System or the Sachet Portal.

Escalation Channels:

• •Reserve Bank of India (RBI): Submit your complaint via the RBI Sachet Portal at https://sachet.rbi.org.in or the RBI Complaint Management System (CMS) at https://cms.rbi.org.in
• •HDFC Bank: For issues related to HDFC Bank services, use the HDFC Bank Grievance Redressal Portal at https://www.hdfcbank.com/personal/customer-centre/grievance-redressal

• •RBI (Digital Lending) Directions, 2025 — effective May 8, 2025
• •RBI Guidelines on Digital Lending — September 2, 2022 (superseded by 2025 Directions)
• •KFS Circular — RBI, April 15, 2024
• •Digital Personal Data Protection (DPDP) Act, 2023
• •Reserve Bank – Integrated Ombudsman Scheme, 2021
• •Information Technology Act, 2000 (as amended)
• •Banking Regulation Act, 1949

The following links are provided for regulatory compliance and borrower reference, as required under RBI Digital Lending Guidelines: