Channel Partner Code of Conduct
A note on the title: this document is deliberately not called a "Fair Practices Code." Under RBI's Master Directions – Non-Banking Financial Company – Peer to Peer Lending Platform (Reserve Bank) Directions, 2017 (as amended), a Fair Practices Code is a specific regulatory instrument that an NBFC-P2P itself must adopt. Lendcord is not an NBFC-P2P — Transactree Technologies Private Limited (operating as Lendbox) holds that license. Calling Lendcord's document a "Fair Practices Code" would misleadingly suggest Lendcord carries that regulatory status. This is titled a Code of Conduct instead, describing Lendcord's own commitments as a channel partner.
1. Background
1.1. Lendcord is a brand operated by Capicord Technologies Pvt Ltd ("Company").
1.2. The Company acts as a channel partner sourcing and screening prospective borrowers for listing on the peer-to-peer lending platform operated by Transactree Technologies Private Limited ("Lendbox"), an NBFC-P2P registered with the Reserve Bank of India ("RBI").
1.3. Loans facilitated through this arrangement are funded by individual retail lenders on the Lendbox platform. The Company does not lend on its own account, does not hold or disburse lender funds, and is not itself an RBI-regulated lending entity. Lendbox, as the licensed NBFC-P2P, is the platform of record for loan agreements, disbursement, and repayment collection infrastructure.
1.4. This Code sets out the standards the Company commits to in its dealings with prospective borrowers ("Borrowers") during sourcing, screening, and onboarding, consistent with Lendbox's Fair Practices Code, the RBI's Digital Lending Directions (to the extent applicable to loan sourcing/service arrangements), and the Digital Personal Data Protection Act, 2023.
1.5. This Code will be made available on the Company's website (lendcord.in) and reviewed periodically as regulatory requirements or the terms of the channel partner agreement with Lendbox evolve.
2. Objective
2.1. Fairness and transparency. The Company's dealings with Borrowers during sourcing and onboarding shall be fair, transparent, and free of misrepresentation about loan terms, approval likelihood, or the identity of the lending entity.
2.2. Clarity of role. The Company shall ensure Borrowers understand, before proceeding, that: (a) Lendcord sources and screens applications but does not sanction or fund loans; (b) actual lenders are individual retail investors on the Lendbox platform; (c) final loan sanction, disbursement, and the binding loan agreement are governed by Lendbox as the NBFC-P2P.
2.3. Trouble-free experience. The Company shall provide a clear application process and route grievances promptly, including escalation to Lendbox's Grievance Redressal Officer where the complaint concerns matters outside the Company's control (e.g., final sanction decisions, fund disbursement, lender conduct).
3. Applicability
This Code applies to the Company's conduct across:
3.1. Borrower sourcing and lead generation
3.2. Application intake and preliminary screening/underwriting inputs
3.3. Disclosures made to Borrowers prior to handoff to the Lendbox platform
3.4. Data handling and consent during sourcing
3.5. Grievance handling for complaints arising from the Company's own conduct, and escalation of complaints outside its scope
4. Borrower Sourcing and Onboarding
4.1. The Company shall provide Borrowers with clear, unambiguous information about the application process, including that final approval and loan terms are determined through the Lendbox platform and its lenders, not by the Company.
4.2. The Company shall obtain explicit Borrower consent before collecting personal or financial information, and before sharing that information with Lendbox or any third party (e.g., credit bureaus, KYC/verification vendors), in accordance with the Digital Personal Data Protection Act, 2023.
4.3. Borrowers shall be informed, in English and in a vernacular language they understand, of the key facts about the loan product before they submit an application — including that interest rates, fees, and final terms are set through the Lendbox platform and may vary based on lender-side risk assessment.
4.4. The Company shall not guarantee loan approval, a specific interest rate, or disbursement timeline to any Borrower during sourcing.
4.5. Before a Borrower accepts any loan offer surfaced through this channel, the Borrower shall have access to the Key Fact Statement (KFS) and loan agreement issued via the Lendbox platform, setting out full terms.
5. Disclosures
5.1. The Company shall disclose to Borrowers, prior to or at the point of application:
- 5.1.1. That Lendcord is a loan sourcing/screening channel partner, not the lender or the licensed NBFC-P2P.
- 5.1.2. The identity of Lendbox (Transactree Technologies Private Limited) as the RBI-registered NBFC-P2P operating the lending platform.
- 5.1.3. That individual retail lenders — not the Company, and not a single institutional lender — fund approved loans.
5.2. The Company shall not make representations about interest rates, credit assessment outcomes, or recovery practices on behalf of Lendbox; such disclosures are Lendbox's responsibility once the Borrower is on its platform.
6. Confidentiality and Data Handling
6.1. The Company shall treat all Borrower information collected during sourcing as private and confidential, and shall not disclose it to any party other than Lendbox (for the purpose of loan processing) or as required by law, without the Borrower's consent.
6.2. Data sharing with Lendbox and any sub-processors shall be limited to what is necessary for loan sourcing, screening, and onboarding, consistent with the Company's data retention and cascading account deletion practices.
6.3. The Company shall not sell or use Borrower data collected in this process for unrelated marketing or third-party purposes without separate, explicit consent.
7. Grievance Redressal
7.1. Borrowers may raise complaints about the Company's own conduct (e.g., sourcing process, data handling, misrepresentation during onboarding) with the Company's Grievance Redressal Officer, whose contact details shall be published on lendcord.in.
7.2. The Company shall acknowledge and resolve grievances within its control within a defined SLA (target: 30 days), consistent with standard RBI grievance redressal timelines for regulated and partner entities.
7.3. Complaints concerning matters outside the Company's control — loan sanction decisions, disbursement, interest rates, repayment, or lender conduct — shall be promptly redirected to Lendbox's Grievance Redressal Officer, with the Borrower informed of Lendbox's grievance channel and, where applicable, the RBI Ombudsman for Digital Lending as the next escalation level.
7.4. The Company shall not obstruct or delay a Borrower's ability to escalate a complaint directly to Lendbox or RBI.
8. Non-Discrimination
8.1. The Company shall not discriminate against any Borrower on the grounds of gender, caste, religion, ethnicity, or profession during sourcing or screening.
9. Disclaimer
9.1. The Company does not guarantee loan approval, disbursement, or specific terms. Final lending decisions rest with individual lenders on the Lendbox platform, subject to Lendbox's credit and risk policies.
9.2. RBI does not accept responsibility for the correctness of statements made by the Company and provides no assurance regarding loans facilitated through this channel. This disclaimer shall be displayed on the Company's website.
9.3. The Company is not a party to the loan agreement executed between the Borrower and lenders on the Lendbox platform.
10. General
10.1. The Company shall not interfere in matters governed exclusively by the Lendbox platform's terms (loan servicing, recovery, fund transfer) except where the channel partner agreement with Lendbox assigns it a defined role.
10.2. The Company shall take disciplinary action against staff or agents who violate this Code, including any staff engaged in Borrower-facing sourcing or collections-adjacent activity.
10.3. This Code shall be reviewed periodically, and updated to reflect changes in the Lendcord–Lendbox channel partner agreement or applicable RBI/DPDP regulation.
Open Items for Legal Review
- Confirm exact scope of Lendcord's role under the signed channel partner agreement with Lendbox (does Lendcord's role extend beyond sourcing/screening into any servicing or collections activity?).
- Confirm grievance SLA figure (30 days used here based on general RBI practice — verify against the channel partner agreement and current Digital Lending Directions).
- Confirm whether Lendcord needs its own registered Grievance Redressal Officer or can initially route all complaints to Lendbox's.
- Confirm data-sharing clauses (Section 6) align with the actual data processing agreement with Lendbox.