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Digital Lending & Fintech

Digital Loan APR Not Disclosed — True Cost Hidden

A digital lending app or NBFC gave you a loan but disclosed only a "monthly rate" or "flat rate" without showing you the Annual Percentage Rate (APR). The actual cost of the loan — including processing fees, insurance, platform fees — was not shown before disbursal.

Applies to: All registered NBFCs, digital lenders, and loan appsRBI/2022-23/111 DoR.CRE.REC.66/21.07.001/2022-23

⚖️Your Rights Under RBI Regulations

A Key Fact Statement showing the APR must be provided before any loan disbursal.

APR must include all fees, insurance premiums, and charges — not just the stated interest rate.

If the KFS was not provided before the loan was credited, this is a violation of RBI/2022-23/111.

You can dispute any charge not disclosed in the KFS.

💰 What You Can Recover

Charges not disclosed in the KFS are potentially unenforceable. Excess amounts paid above the disclosed costs can be claimed back.

⏱ Response Deadline

30 days for written complaint.

📋Step-by-Step — What to Do

1

Calculate the true APR using: (Total Finance Charge / Loan Amount) × (365 / Tenure Days) × 100.

2

Write to the lender's Grievance Redressal Officer demanding explanation of all charges and the KFS.

3

File with RBI Ombudsman at cms.rbi.org.in (select NBFC category).

4

For unregistered apps, file at sachet.rbi.org.in and cybercrime.gov.in.

🏛 Where to Escalate If Bank Doesn't Respond

sachet.rbi.org.in + RBI Integrated Ombudsman (for registered NBFCs)

⚖️

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Governing RBI Circular
RBI/2022-23/111 DoR.CRE.REC.66/21.07.001/2022-23
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