Grievance Redressal Policy & SOP
1. Purpose and Scope
Caply Fintech LLP (“Caply”) is committed to fair, transparent and timely resolution of customer grievances. This Policy and SOP set out how customers may raise concerns relating to Caply’s services as a Lending Service Provider (LSP) / Digital Lending Application (DLA) operator for the Loan Against Mutual Funds (LAMF) programme, and how such concerns are acknowledged, investigated, resolved, escalated and recorded. It is issued in accordance with the RBI Digital Lending Directions and applies to all Caply personnel and channels (web and, on go-live, the DLA).
As LSP, Caply provides customer-acquisition and facilitation services; the loan is provided by the Regulated Entity (“RE”). Grievances relating to lending decisions, loan terms, servicing and recovery are coordinated with, and where applicable owned by, the RE. Caply owns the grievance interface and ensures every complaint is routed to the right party and tracked to closure.
2. Principles
- Every complaint is treated with fairness, courtesy and confidentiality, and at no cost to the customer.
- Complaints are acknowledged promptly and resolved within defined turnaround times.
- Complaints tagged as “Grievance” are treated as top priority and given expedited handling.
- Customers are kept informed of progress and of the next level of escalation if they remain dissatisfied.
3. How to Raise a Complaint
Customers may lodge a complaint through any of the following channels:
- In-application: ‘Help / Raise a complaint’ feature (on DLA go-live)
- Email: grievance@caply.in
- Website: The grievance section of www.caply.money / www.caply.in
- Telephone: 9585551544 (business hours)
To help resolve the matter quickly, customers are requested to provide their name, registered mobile/email, loan/application reference (if any) and a description of the concern.
4. Three-Level Escalation Framework
Level 1: Customer Support
First point of contact for all queries and complaints. Acknowledgement within 24 hours.
Contact Information
Email: grievance@caply.in
Phone: 9585551544
Resolution targeted within 3–5 business days.
Level 2: Grievance Redressal Officer (GRO)
If unresolved or the customer is dissatisfied at Level 1, the matter is escalated to the GRO.
Mr. Emmatty Sijo Paul
Email: grievance@caply.in
Phone: 9585551544
Resolution targeted within 14 business days, and in any case within 30 days overall.
Level 3: Regulated Entity (Lender) & RBI
For matters concerning the loan/lender, or if unresolved within 30 days, the customer may approach the RE via its grievance channel, and thereafter the RBI Ombudsman.
- RBI CMS: Reserve Bank - Integrated Ombudsman Scheme (RB-IOS). (cms.rbi.org.in)
- Sachet Portal: Available for reporting in line with RBI Digital Lending Directions. (sachet.rbi.org.in)
5. Complaint-Handling SOP and Turnaround Times
- Receipt – the complaint is logged in the Complaint Register with a unique reference and date/time.
- Acknowledgement – acknowledged to the customer within 24 hours, with the reference number.
- Classification – categorised (e.g., application, servicing, charges, data/privacy, grievance) and prioritised; ‘Grievance’-tagged items are treated as top priority.
- Routing – lender/loan matters are routed to the RE; Caply-side matters are handled internally.
- Investigation & resolution – resolved within the applicable turnaround time; the customer is informed of the outcome.
- Escalation – if unresolved at a level or the customer remains dissatisfied, the matter moves to the next level.
- Closure & record – the resolution and closure date are recorded; complaints are retained for audit and regulatory reporting.
| Stage | Target Turnaround | Owner |
|---|---|---|
| Acknowledgement | Within 24 hours | Customer Support |
| Level 1 resolution | 3–5 business days | Customer Support |
| Level 2 (GRO) resolution | 14 business days (max 30 days overall) | GRO |
| Grievance-tagged items | Expedited / top priority | GRO |
6. Escalation to the RBI
If a complaint is not resolved within 30 days, or the customer is not satisfied with the resolution, the customer may escalate to the Reserve Bank of India:
- RBI Ombudsman under the Reserve Bank – Integrated Ombudsman Scheme (RB-IOS), 2021, via the RBI Complaint Management System portal (cms.rbi.org.in).
- The RBI ‘Sachet’ portal (sachet.rbi.org.in) is displayed on Caply’s website(s) and DLA, in line with the RBI Digital Lending Directions.
The details of the Regulated Entity’s Grievance Redressal Officer and its regulatory disclosures are also displayed to the customer for escalation specific to the lending partner.
7. Coordination with the Regulated Entity
- For grievances involving the loan, lending decision, servicing or recovery, Caply coordinates with the RE, keeping the RE informed via its designated grievance contact and adhering to the RE’s grievance SOP.
- Where a customer contacts the Regulated Entity directly, the RE’s SOP is followed and Caply is kept in copy for all communications.
- Caply shares grievance MIS with the RE as agreed, to support the RE’s own regulatory reporting.
8. Records, Reporting and Governance
- All complaints are recorded in the Complaint Register and retained for audit and regulatory purposes.
- The GRO reviews complaint trends periodically and reports to the Designated Partners; recurring issues feed process improvement.
- GRO particulars are prominently displayed on Caply’s website(s) and DLA and furnished to the RE for onward RBI reporting.
- This Policy is owned by the GRO and reviewed at least every 12 months, or upon material change or regulatory update.
9. Approval
Approved and adopted by the Designated Partners of Caply Fintech LLP.
Anusha Manohar Karanath
Designated Partner
Selestin Thomas
Designated Partner
Emmatty Sijo Paul
Designated Partner (GRO)