RESTRUCTURING POLICY

Dated- August -2020

ATD Financial Services Private Limited

ATD Financial Services Private Limited (hereinafter referred to as “the Company” or “NBFC” or “Lender”) is a Private Limited Company incorporated under the provisions of the Companies Act, 1956 and registered as a non-deposit accepting Non-Banking Financial Company (“NBFC”) with the Reserve Bank of India (“RBI”).

The RBI on August 06, 2020, vide its circular no. RBI/2020-21/16 DOR. No. BP. BC/3/21.04.048/2020-21 has released guidelines for NBFCs on implementation of resolution framework for COVID-19 related stress.

However, the economic fallout on account of the COVID-19 pandemic has led to significant financial stress for borrowers nationwide and the resultant stress can potentially impact the long term viability of many Companies, otherwise having a good track record, due to their debt burden becoming disproportionate relative to their cash flow generation abilities.

Considering the above, the RBI provided a window under the Prudential Framework and enabled the lenders to provide a resolution framework to the eligible borrowers for repayment of their loan by way of restructuring the loan or extending the tenure for repayment of the debt.

Objective of the Policy:

The objective of the Policy is to facilitate the overall revival of and to save the individual from having an impact on its financial stability risks due to its debt burden becoming disproportionate relative to its cash flow generation abilities by implementing resolution plans for the eligible borrowers.

Definitions:

For the purposes of this policy, the below terms shall have the meaning as provided herein under:

1. a) Board: The Board shall mean the Board of Directors or any authorized committee(s) of the board of the Company.
2. b) COVID-19: Coronavirus Disease or COVID-19 is an infectious disease, which was declared as a global pandemic by World Health Organization on 11 March 2020.
3. c) Eligible Borrower/s: For the purpose of resolution plan under this Policy, eligible borrower shall mean:
   ➢ the borrowers whose accounts were not in default for more than 30 (thirty) days with the Company as on March 01, 2020 and were classified as standard assets; and
   ➢ the borrowers having stress on account of COVID-19; and in respect of whom the Company is willing to consider the resolution under this Policy.
4. d) Non-Eligible Borrower/s: Non-Eligible Borrowers shall mean the personnel or staff of the Company to whom it has extended credit facility or personal loans.
5. e) Standard Assets: Standard asset shall mean the asset in respect of which, no default in repayment of principal or payment of interest is perceived and which does not disclose any problem or carry more than normal risk attached to the business.
6. f) Personal Loans: Personal loans refers to loans given to individuals and consist of (a) Payday Loan, (b) Business Loan.
7. g) Date of Invocation: The date of invocation means the date on which both the borrower and lender have agreed to proceed with a resolution plan for the Eligible Borrower in terms of this Policy.

Eligibility for resolution under this Policy:

The Company shall take into consideration only the Eligible Borrowers for the purpose of considering and implementing the resolution plans. However, it is necessary that the Eligible Borrowers account is classified as Standard Asset as on the Date of Invocation.
Keeping in view the RBI guidelines issued from time to time, the Board will consider and provide suitable resolution/restructuring plans for the Eligible Borrowers, provided the same shall not exceed a period of one year from the date of original maturity of the personal loans/credit facility.

Implementation of resolution

A restructuring of loan would be treated as implemented upon fulfillment of all of the following conditions:

1. a) All related documentation, including execution of necessary agreement(s), if any, between Lender and Eligible Borrower are completed;
2. b) The new loan amount and/ changes in the terms and conditions of the existing loan account get duly reflected in the books of accounts of the Lender
3. c) The Eligible Borrower is not in default with the Lender as per the revised terms and conditions.

Due Diligence Process

The Company on receipt of a written request application/email from the Eligible Borrower shall evaluate the proposal for restructuring of the personal loan account(s) including evaluation of necessary documents.
On due evaluation of the request submitted by the Eligible Borrower, the concerned team shall execute with the Eligible Borrower necessary amendment agreement or other necessary documents in order to record the revised terms and implement viable resolution plan(s), as provided herein above.

Prudential Norms:

❑ Disclosure in the Financial Statement: The Company shall make appropriate disclosures about the restructured accounts in terms of this Policy in its annual financial statements under the “Notes to Accounts”.
❑ Credit Reporting by the Company: The restructuring of loan granted to the Eligible Borrowers under this Policy will be treated as new restructured loan account and the credit history of the Eligible Borrowers shall consequently be governed by the respective policies of the credit information companies as applicable to accounts that are restructured.

Miscellaneous:

1. Display on Website: The Board approved policy on restructuring of stressed assets will be hosted on the Company’s website for our customers information and benefit.
2. Effective date: This Policy shall be effective from the date of approval of this Policy by the Board.
3. Review of Policy: The Policy shall be reviewed as and when required by the applicable rules and regulations.
4. While Policy outlines the broad internal guidance that the Company will follow to take decisions regarding this restructuring of stressed assets/loan, the Company retains the discretion to take decisions regarding this Policy depending on case specific issues or nuances.

The Company reserves the right to amend the Policy within the framework of RBI guidelines.