ORANGE RETAIL FINANCE INDIA PRIVATE LIMITED

CIN: U65191TN1989PTC018026

MORATORIUM POLICY

This Policy was approved by the Board of Directors on 9th July 2020 through resolution by circulation.

Brief Background:

The World Health Organization recently declared COVID 19 to be a pandemic. It is predicted that Indian Economy will have a severe impact and it would lead to various issues including delayed salary credits for the salaried segments and deferred cash inflow for self-employed etc, wherein it would directly impact the repayment of almost all finance facilities lent by Bank/NBFCs and FIs. In this regard the Reserve Bank of India vide its Notification RBI/2019-20/186 – DOR No.BP.BC.47/21.04.048/2019-20 dated March 27, 2020 announced certain regulatory measures to mitigate the burden of debt servicing brought about by disruptions on account of the COVID 19 pandemic and to ensure the continuity of viable businesses. The Board of Directors (“Board”) of Orange Retail Finance India Private Limited (“Company”) had approved the Policy on Moratorium
due to financial stress caused by COVID-19 and agreed to provide moratorium to all its customers up to a maximum of 3 months from 1st March 2020 to 31st May 2020 with respect to loans outstanding as on 1st March 2020.

In view of the extension of lockdown and continuing disruption on account of COVID-19, the Reserve Bank of India issued a notification vide RBI/2019-20/244 DOR.No.BP.BC.71/21.04.048/2019-20 dated 23rd May 2020, permitting NBFC’s to extend the Moratorium by another 3 months, i.e. from June 1, 2020 to August 31, 2020. In this regard, the Board of Directors of the Company agrees to extend the moratorium to its customers till August 31, 2020 subject to the eligibility criteria, terms and conditions as mentioned below:-

Eligibility Criteria:-

  • 6 months moratorium i.e. from 1st March 2020 to 31st August 2020 is applicable to all the customers of the Company who has not paid their EMI (component of Interest and
    Principle) dues for the month of March 2020. Customers need to specifically opt-out if they don’t need the moratorium
  • Customers who have cleared their dues for the month of March 2020 and fails to clear the EMI dues for the month of April 2020, May 2020, June 2020, July 2020, August 2020 will be eligible for a moratorium of five months, i.e., for the months of April, May June, July and August 2020. Customers need to specifically opt-out if they don’t need the moratorium
  • Customers who have cleared their dues for the month of March 2020 and April 2020 and fail to clear the EMI dues for the month of May 2020, June 2020, July 2020, and August 2020 will be eligible for a moratorium of four months, i.e., for the month of May, June, July and August 2020 alone. Customers need to specifically opt-out if they don’t need the moratorium.
  • Customers who have cleared their dues for the month of March 2020, April 2020 and May 2020 and fail to clear the EMI dues for the month of June 2020, July 2020, and August 2020 will be eligible for a moratorium of 3 months, i.e., for the month of June, July and August 2020 alone. Customers need to specifically opt-out if they don’t need the
    moratorium.
  • Customers who have cleared their dues for the month of March, April 2020, May 2020 and June 2020 and fail to clear the EMI dues for the month of July 2020, and August 2020 will be eligible for a moratorium of 2 months, i.e., for the month of July and August 2020 alone. Customers need to specifically opt-out if they don’t need the moratorium.
  • Customers who have cleared their dues for the month of March 2020, April 2020, May 2020, June 2020 and July 2020 and fail to clear the EMI dues for the month of August
    2020 will be eligible for a moratorium of 1 month, i.e., for the month of August 2020 alone. Customers need to specifically opt-out if they don’t need the moratorium.
  • In addition to the above at the discretion of the Board and on the merits of the respective customers, Moratorium may be granted to customers requesting for the same through
    formal written communication. Format of request letter is available in the website of the Company www.orangeretailfinance.com.

Terms and Conditions

  • Moratorium is granted to the EMI (a component of Interest and Principal that falls due during the month of March 2020 to August 2020 (up to a maximum of 6months) in respect of all loans that were outstanding as on 1st March 2020, as per the above logic.
  • Payments will continue to be accepted during the moratorium period for all the loans irrespective of extension of moratorium or not. Hence NACH / Auto debit Mandates for
    EMIs falling due shall be presented as per schedule for those customers who have not opted for Moratorium.
  • In respect of the customers to whom the moratorium is granted by the Company, the residual tenor of the loan will be extended by such moratorium period or higher as per the method of moratorium being adapted.
  • The methodology for applying moratorium has been arrived at based on consultative discussions with Board, Management and Co-lenders.
  • Overdue interest / late payment charges shall not be applicable during the moratorium period for customers who have availed moratorium only. For customers who have not
    availed moratorium these charges will be applicable.
  • Since the moratorium/deferment is being provided specifically to enable the borrowers to tide over economic fallout from COVID-19, the non-payment of EMI dues during the
    month of 1st March 2020 to 31st August 2020 will not be treated as concession or change in terms and conditions of loan agreements. Consequently, the asset classification shall be determined based on revised due dates and the revised repayment schedule.
  • The rescheduling of payments, including interest, will not qualify as a default for the purposes of supervisory reporting and will not be reported to the Credit Information
    Companies (CICs).
  • The Company has securitised/assigned its loan receivables to Banks / Trustees / Institutions and the Company is appointed as servicer for collection of instalments from
    the borrowers and remittance of the same to Banks/Trustees/Institutions. The Company has also availed Term Loans/Cash Credits from Banks/Institutions. Hence the Company will seek consent and obtain approval from the concerned Banks/Trustees/Institutions for grant of moratorium for the purpose of securitization/assignment instalments/amounts falling due between 1st March 2020 to 31st August 2020. The Company will also seek and avail moratorium for payment of principal and / or Interest from the lending Banks/Institutions to the Company falling due between 1st March 2020 to 31st August 2020.
  • The Key Management personnel of the Company shall ensure that the above instructions are properly communicated down the line for implementation to all the operations and
    branch executives of the Company.
  • This policy shall be displayed on the web site of the Company www.orangeretailfinance.com

While this policy outlines the broad internal guidance that the Company will follow to take decisions regarding moratorium, 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 regulations.