Aligned with RBI's Fair Practices Code guidelines for lending, adapted for AI-assisted loan origination.
Effective Date: January 1, 2025 | Last Updated: February 1, 2025 | Paaw Innovations Pvt. Ltd. ("Augmen")
Augmen provides AI-powered loan origination technology to banks and Non-Banking Financial Companies (NBFCs). While we are a technology provider and not a lender ourselves, we recognize that our systems interact directly with borrowers during the loan process. We are committed to ensuring that these interactions uphold the spirit of the Reserve Bank of India's Fair Practices Code for lenders (RBI Master Direction — Regulatory Framework for Microfinance Loans, and Fair Practices Code for NBFCs).
All loan-related information communicated through our AI systems is available in the borrower's preferred language. Our systems support 22 scheduled Indian languages for speech and 10+ Indian scripts for document processing. No borrower should be disadvantaged because they don't speak English. Loan terms, interest rates, fees, and repayment obligations are communicated clearly in the language the borrower understands best.
Borrowers are informed at the start of every interaction that they are speaking with an AI-powered system. We do not disguise AI as human. The borrower is always given the option to speak with a human agent if they prefer. During V-CIP sessions, the interaction is always with a trained human official of the regulated entity — never with an AI alone.
Our AI systems are configured to clearly communicate all relevant loan terms as provided by the lending institution, including the rate of interest (annualized), processing fees, penal charges (if any), total amount payable, cooling-off period, and grievance redressal mechanism. This information is presented before the borrower provides consent, not buried in fine print.
Our AI systems are trained to be informative, not persuasive. The AI does not use high-pressure tactics, create artificial urgency, or emotionally manipulate borrowers into taking loans. If a borrower expresses hesitation or wishes to end the conversation, the AI respects that immediately. Our DPO alignment training specifically optimizes for respectful, clear, non-coercive communication.
If our AI systems are used for any post-disbursement communication (payment reminders, etc.), they follow RBI's guidelines on non-coercive recovery practices. No threatening language, no calls outside permitted hours, no communication with third parties about the borrower's loan. Our TTS voice synthesis is configured to use a calm, professional tone — never aggressive or intimidating.
Our systems do not discriminate on the basis of gender, caste, religion, ethnicity, disability, sexual orientation, or any protected characteristic. We actively monitor our AI outputs for discriminatory patterns (see our Ethical AI commitment). Every borrower who meets the lending institution's eligibility criteria deserves equal quality of service through our platform.
Before collecting any personal information, our systems obtain explicit, informed consent from the borrower. For Aadhaar-based verification, consent is obtained separately as per UIDAI requirements. Consent is recorded in an auditable, tamper-proof manner. Borrowers can withdraw consent at any point during the interaction.
We collect only the information necessary for the loan origination process. We do not harvest additional data for unrelated purposes. Aadhaar numbers are masked immediately. Voice recordings are processed on the client's infrastructure. Biometric data for liveness detection is processed on-device and not retained.
All borrower information processed through our systems is treated as strictly confidential. We do not share borrower data with any party other than the regulated entity (bank/NBFC) on whose behalf we are processing the loan application, and only to the extent necessary for the loan origination process.
If a borrower has a complaint about their experience with our AI system during the loan origination process, they can:
We acknowledge all grievances within 48 hours and aim to resolve technology-related complaints within 15 working days. For complaints that pertain to lending decisions (approval, rejection, interest rates), borrowers are directed to the lending institution's grievance mechanism, as these decisions are made by the lender, not by Augmen.
If a borrower is not satisfied with the resolution, they may escalate to:
Augmen's AI does not approve or reject loan applications. All credit decisions are made by authorized officers of the regulated entity. Our AI assists by structuring information, extracting documents, and presenting data — but the final decision is always human.
When our AI extracts information from documents or flags potential issues (name mismatch, expired document, insufficient data), the reasoning is transparent and explainable. The system shows what it found, where it found it, and why it flagged it — so the human officer can verify and make an informed decision.
Every interaction through our platform — every conversation, every document processed, every KYC session — is logged with complete audit trails. These records are maintained for a minimum of 5 years and are available for regulatory audit at any time. This traceability ensures accountability for every step of the loan origination process.
This Fair Practice Code is aligned with the following RBI directions and guidelines:
For questions about our Fair Practice Code or to report a concern:
Compliance Officer
Paaw Innovations Pvt. Ltd.
SINE IIT Bombay, Powai, Mumbai 400076
Email: compliance@augmen.io