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ENN ENN CAPITAL

KYC Policy

KYC documentation Policy

A. KYC Documents for Customer Due Diligence (CDD)

SR NO. DOCUMENT PARTICULARS MANDATORY IDENTITY PROOF ADDRESS PROOF
1) PAN or the equivalent e-document thereof or Form 60 (in case of PAN not available).

Note: In case where only Form 60 is provided the same can be accepted as ID proof along with the one of OVD’s (officially valid document) as mentioned below containing the details of identity and address.

Note: For loan amount > 5 lacs, PAN card is mandatory. 		Yes Acceptable Not Acceptable
2) The Aadhar Number (Proof of possession of Aadhaar number) or any one of the Officially valid documents (OVD) or equivalent e- documents* given below for proof of identity and proof of address (in case offline verification is not possible): Yes Acceptable (Only if documents thereof contain the details of identity) Acceptable

Category (2) mentioned above explained further in detail in this policy.

*Equivalent e-document” means an electronic equivalent of a document, issued by the issuing authority of such document with its valid digital signature including documents issued to the digital locker account of the customer as per rule 9 of the Information Technology (Preservation and Retention of Information by Intermediaries Providing Digital Locker Facilities) Rules, 2016

B. CDD for Individual

“OFFICIALLY VALID DOCUMENT” WOULD MEAN AND INCLUDE FOLLOWING DOCUMENTS:

IDENTITY PROOF ADDRESS PROOF
Passport (OVD) Acceptable Acceptable
Driving Licence (OVD) Acceptable Acceptable
Proof of possession of Aadhaar number (To be submitted in such form as are issued by the Unique Identification Authority of India) Acceptable Acceptable
Voter ID card issued by the Election Commission of India (OVD) Acceptable Acceptable
Job card issued by NREGA duly signed by an officer of the State Government (OVD) Acceptable Acceptable
Letter issued by the National Population Register containing details of name and address (OVD) Acceptable Acceptable

IN CASE WHERE OVD IS FURNISHED WHICH DOES NOT HAVE CURRENT ADDRESS FOLLOWING SHALL BE OBTAINED AS DEEMED OVD AND WILL BE CONSIDERED FOR PROOF OF ADDRESS *

DEEMED OVD* IDENTITY PROOF ADDRESS PROOF
Utility bill which is not more than two months old of any service provider (electricity, telephone, post-paid mobile phone, piped gas, water bill) Not acceptable Acceptable
Property or municipal tax receipt Not acceptable Acceptable
Pension or family pension payment orders (PPOs) issued to retired employees by Government Departments or Public Sector Undertakings, if they contain the address Not acceptable Acceptable
Letter of allotment of accommodation from employer issued by State /Central Government Departments, statutory/regulatory bodies, public sector undertakings, scheduled commercial banks, financial institutions and listed companies and leave and licence agreements with such employers allotting official accommodation Not acceptable Acceptable

Note: BELOW ADDITIONAL DOCUMENTS, IF AVAILABLE, CAN BE TAKEN AS AN ADDITIONAL PROOF TO THE ABOVE MENTIONED OVD ON BEST EFFORT BASIS.

  • Physical bank statement with current address not older than 3 months.
  • Rent agreement with remaining validity of at least 3 months. (Stamp or franked with date of registration)
  • Life insurance policy receipt.
  • Ration Card.
  • E Statement with current address or Bank passbook with latest month transaction in it.

*If deemed OVD is taken as mentioned above for limited proof of address, customer will have to submit updated OVD within a period of 3 months of submitting the same.

Note: If the OVD submitted does not have the current residence address of customer and deemed OVD as mentioned above is not available, branch to perform E-KYC through Biometric Verification and collect a “current address declaration” from borrower.

CDD for Non-Individual

Sr. No. KYC Document to be obtained for carrying CDD
Sole Proprietorship Any two of the following documents or the equivalent e-documents thereof in the name of the proprietary concern needs to be obtained as a proof of business/activity if the loan is in the name of Proprietorship Firm (Main Applicant):

1. Registration certificate including Udyam Registration Certificate (URC) issued by the Government
2. Certificate / licence issued by the municipal authorities under Shop and Establishment Act.
3. Sales and income tax returns.
4. CST/VAT/GST certificate
5. Certificate/registration document issued by Sales Tax/Service Tax/Professional Tax authorities.
6. IEC (Importer Exporter Code) issued to the proprietary concern by the office of DGFT / Licence/certificate of practice issued in the name of the proprietary concern by any professional body incorporated under a statute.
7. Complete Income Tax Return (not just the acknowledgement) in the name of the sole proprietor where the firm's income is reflected, duly authenticated/acknowledged by the Income Tax authorities.
8. Utility bills (electricity, water, and landline telephone bills)
9. Bank account Statement of last six months in the name of the entity (not from a non-scheduled cooperative bank) along with positive Field investigation report.

Note: In case one document is collected instead of two; Contact Point Verification (CPV) is mandatory and cannot be waived.
Companies Certified copy of each of the following documents or the equivalent e-documents shall be obtained:

- Certificate of incorporation;
- Memorandum and Articles of Association;
- Permanent Account Number of the Company;
- A resolution from the Board of Directors and power of attorney granted to its managers, officers or employees to transact on its behalf;
- Documents to be obtained from beneficial owner, managers, officers or employees holding an attorney to transact on behalf of company;
- KYC Template / information in prescribed format for uploading data with Central KYC Record Registry;
- The names of the relevant persons holding senior management position; and
- The registered office and the principal place of its business, if it is different.
Partnership Firms Certified copy of each of the following documents or the equivalent e-documents shall be obtained:

- Registration certificate;
- Partnership deed;
- Permanent Account Number of the partnership firm;
- KYC Template / information in prescribed format for uploading data with Central KYC Record Registry;
- Documents from beneficial owner, person holding an attorney to transact on behalf of the Partnership Firm;
- The names of all the partners; and
- Address of the registered office, and the principal place of its business, if it is different.
Trusts and Foundations Certified copy of each of the following documents or the equivalent e-documents shall be obtained:

- Registration certificate;
- Trust deed;
- Permanent Account Number or Form 60 of the trust;
- KYC Template / information in prescribed format for uploading data with Central KYC Record Registry;
- Documents from beneficial owner, person holding an attorney to transact on behalf of the Trust;
- The names of the beneficiaries, trustees, settlor and authors of the trust;
- The address of the registered office of the trust; and
- List of trustees and documents, as specified, for those discharging the role as trustee and authorised to transact on behalf of the trust.
Unincorporated Association or a Body of Individuals Certified copy of each of the following documents or the equivalent e-documents shall be obtained:

- Resolution of the managing body of such association or body of individuals;
- Power of attorney granted to him to transact on its behalf;
- Permanent Account Number or Form 60 of the unincorporated association or a body of individuals;
- Documents from beneficial owner, person holding an attorney to transact on behalf of the unincorporated association/body of individuals;
- KYC Template / information in prescribed format for uploading data with Central KYC Record Registry.

Explanation: Unregistered trusts/partnership firms shall be included under the term ‘unincorporated association’.
Explanation: Term ‘body of individuals’ includes societies.
Customer who is a Juridical Person (not specifically covered earlier) Certified copy of each of the following documents or the equivalent e-documents shall be obtained:

- Document showing name of the person authorised to act on behalf of the entity;
- Documents from person holding attorney to transact on behalf of the entity;
- Such documents as may be required by the Company to establish the legal existence of such an entity/juridical person;
- KYC Template / information as prescribed by the Reserve Bank of India for uploading data with Central KYC Record Registry;
- Such other documents as may be prescribed from time to time.

Notes (for non-individual category):

  • For non-profit organizations, the details of such customers have to be registered on the DARPAN Portal of NITI Aayog. If the same are not registered, EECPL shall register the details on the DARPAN Portal and shall also maintain such registration records for a period of five years after the business relationship between the customer and the company has ended or the account has been closed, whichever is later.
  • KYCs of all beneficial owners shall be collected which means–
    i. Ownership of more than 10% shares in a company or
    ii. More than 10% of ownership in other forms of entities (LLP / Partnership firms etc.)
    iii. Where the customer or the owner of the controlling interest is a company listed on a stock exchange, or is a subsidiary of such a company, it is not necessary to identify and verify the identity of any shareholder or beneficial owner of such companies.
    iv. In cases of trust/nominee or fiduciary accounts whether the customer is acting on behalf of another person as trustee/nominee or any other intermediary is determined. In such cases, satisfactory evidence of the identity of the intermediaries and of the persons on whose behalf they are acting, as also details of the nature of the trust or other arrangements in place shall be obtained.

C. General Rules (for all categories of borrower):

  1. Self-attested Photograph of the applicant & all Co-applicant is mandatory, however digitally captured live photograph is acceptable.
  2. All KYC documents/ Officially Valid documents shall be self-attested by the customer and shall be verified (OSV) only by the EECPL employees.
  3. Where a person submits his/her Aadhaar Number for the purpose of proof of identity and / or address, the first 8 digits of Aadhaar number have to be redacted or blacked-out through appropriate means (marker pen etc).
  4. The acceptance, use and storage of Aadhaar, proof of possession of Aadhaar etc., shall be in accordance with the Aadhaar (Targeted Delivery of Financial and Other Subsidies Benefits and Services) Act, the Aadhaar and Other Law (Amendment) Ordinance, 2019 and the regulations made thereunder, the RBI KYC Master directions and other circulars, notification, guidelines issued by the Reserve Bank of India in this regard.
  5. KYC details / application form is required to be in line with prescribed format (CKYC template) for uploading data with Central KYC Record Registry
  6. In case of any update in the documents submitted by the customer at the time of account establishment / thereafter, Customers shall submit the updated documents to the Company within 30 days.
  7. Change in name on account of marriage or otherwise: A document shall be deemed to an “officially valid document” even if there is a change in the name subsequent to its issuance, provided it is supported by a marriage certificate issued by the State Government or a Gazette notification, indicating such a change of name”. Accordingly, a copy of marriage certificate issued by the State Government or Gazette notification indicating change in name together with a certified copy of the ‘officially valid document’ (as indicated above) in the existing name of the person while establishing an account-based relationship or while undergoing periodic updation exercise may be accepted.
  8. For the purpose of verifying the identity of customers at the time of commencement of an account-based relationship, Company shall at their option, rely on customer due diligence done by a third party, subject to the following conditions:
    • Records or the information of the customer due diligence carried out by the third party is obtained within two days from the third party or from the Central KYC Records Registry.
    • Adequate steps are taken by EECPL to satisfy themselves that copies of identification data and other relevant documentation relating to the customer due diligence requirements shall be made available from the third party upon request without delay.
    • The third party is regulated, supervised or monitored for, and has measures in place for, compliance with customer due diligence and record-keeping requirements in line with the requirements and obligations under the PML Act.
    • The third party shall not be based in a country or jurisdiction assessed as high risk.
    • The ultimate responsibility for customer due diligence and undertaking enhanced due diligence measures, as applicable, will be with EECPL.
  9. Video based Customer Identification Process (V-CIP):
    V-CIP is an alternate method of customer identification with facial recognition and customer due diligence by an authorised official of the EECPL by undertaking seamless, secure, live, informed-consent based audio-visual interaction with the customer to obtain identification information required for CDD purpose, and to ascertain the veracity of the information furnished by the customer through independent verification and maintaining audit trail of the process. Such processes complying with prescribed standards and procedures as per RBI shall be treated on par with face-to-face CIP for the purpose of KYC verification. All other regulatory changes in this regard will stand updated in the policy from time to time.
  10. CKYC mode of verification:
    The company would first give the choice to the customer to opt for CKYC mode of verification. If any new customer opts for verification through CKYC mode, company shall seek the KYC Identifier from the customer or retrieve the KYC Identifier, if available, from the CKYCR and proceed to obtain KYC records online by using such KYC Identifier and shall not ask customer to submit any other KYC documents unless– (i) there is a change in the information of the customer as existing in the records of CKYCR; or (ii) the KYC record or information retrieved is incomplete or is not as per the current applicable KYC norms; or (iii) the validity period of downloaded documents has lapsed; or (iv) company considers it necessary in order to verify the identity or address (including current address) of the customer, or to perform enhanced due diligence or to build an appropriate risk profile of the customer. If the customer does not give consent for verification through CKYC mode, company shall perform due diligence as per verification through any one of the other modes as explained in this policy.
  11. Existing Customer: A fresh KYC will not be required from the existing customer if the customer applies for a new loan unless there is a change in the information of the customer as existing in the records of EECPL.
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