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Collection and Recovery Policy



The primary objective of Refyne's Collection and Recovery Policy is to ensure the timely and efficient recovery of outstanding dues while upholding the highest standards of ethical conduct, maintaining customer relationships, and complying with all applicable laws and regulations governing debt collection and recovery in our jurisdiction. Our aim is to strike a balance between safeguarding the interests of NBFC and demonstrating empathy towards our customers facing financial challenges. Through this policy, we seek to establish clear guidelines that foster a transparent, fair, and customer-centric approach to the collection and recovery process.

Legal and Regulatory Compliance

Refyne is dedicated to unwavering compliance with all pertinent laws, regulations, and guidelines governing debt collection and recovery activities. This includes, but is not limited to, “Fair Debt Collection Practices Act”, “Consumer Protection Code”, “Order IV CPC”, “S. 420 IPC”, “S. 421 IPC”, “S. 406 IPC”, “Order 37 CPC”. Our commitment extends to staying informed about any amendments or additions to these regulations, ensuring that our practices consistently align with the legal framework set forth by the regulatory authorities. We strive to operate with the highest level of integrity and transparency, acknowledging the importance of legal compliance in all our collection and recovery endeavors.


At Refyne we recognize the significance of clear and respectful communication in the debt collection and recovery process. Our communication practices adhere strictly to the guidelines outlined in the Fair Debt Collection Practices Act (FDCPA) and other relevant regulations. We are committed to maintaining open and transparent dialogue with our customers throughout the collection process.
Communication channels may include written correspondence, telephone calls, and electronic communication, all of which will be conducted during reasonable hours and in a manner that respects the privacy and dignity of the customer. We emphasize the importance of treating customers with courtesy and professionalism, ensuring that our communications are designed to facilitate understanding and cooperation.

Refyne is dedicated to providing clear and comprehensive information regarding outstanding dues, including details about the principal amount, interest rates, and any applicable fees. Through transparent communication, we aim to empower our customers to make informed decisions and actively participate in the resolution of their financial obligations.

Customer Information and Privacy

At Refyne, safeguarding customer information and upholding privacy standards are paramount principles in our Collection and Recovery Policy. We are committed to ensuring the confidentiality, integrity, and security of all customer data in compliance with relevant data protection laws and regulations.

Customer information collected during the debt collection and recovery process will be used solely for the purpose of facilitating the repayment of outstanding dues and complying with legal requirements. We strictly prohibit the unauthorized disclosure or sharing of customer information with third parties, except as mandated by law or with the explicit consent of the customer.
Refyne employs robust security measures to prevent unauthorized access, disclosure, alteration, and destruction of customer data. Our staff is trained to handle customer information with the utmost care and confidentiality, and access to such information is restricted to individuals with a legitimate need for it in the course of their duties.

Customers have the right to access their personal information, request corrections, and seek clarification about how their data is being used. Refyne is committed to providing customers with transparent information about our data handling practices, reinforcing trust and confidence in our commitment to customer privacy.


Transparency is a foundational principle in Refyne's Collection and Recovery Policy. We are dedicated to providing customers with clear, accurate, and easily understandable information throughout the debt collection and recovery process. Our commitment to transparency extends to all aspects of communication and interactions with customers.

When communicating with customers about their outstanding dues, Refyne will ensure transparency regarding the principal amount, accrued interest, any additional charges, and the total amount owed. This information will be clearly presented in written correspondence, facilitating an informed understanding of the financial obligations involved.

Customers will be informed of their rights and responsibilities during the collection and recovery process. This includes their right to dispute claims, request validation of debts, and receive clear explanations of the terms and conditions associated with their outstanding obligations.

Refyne is dedicated to addressing customer inquiries promptly and providing comprehensive responses to any requests for clarification regarding outstanding debts. We believe that transparency builds trust, and we aim to foster a relationship with our customers that is built on openness, honesty, and mutual understanding.

Through transparent communication, Refyne seeks to empower customers to make well-informed decisions about their financial obligations and actively engage in finding mutually agreeable solutions to resolve outstanding dues.

Customer Assistance

Refyne recognizes that customers may face financial challenges, and we are committed to providing assistance and support during such times. Our Collection and Recovery Policy incorporates proactive measures to help customers navigate their financial difficulties while ensuring a fair and considerate approach.

In situations where customers are experiencing financial hardship, Refyne will work collaboratively with them to explore viable solutions. This may include offering flexible repayment plans, temporary relief measures, or debt restructuring options tailored to individual circumstances.

Customers are encouraged to reach out to Refyne as soon as they anticipate or encounter difficulties in meeting their repayment obligations. Our dedicated customer support team is available to discuss potential solutions, answer queries, and guide customers through the available assistance programs.

Refyne will provide clear and easily accessible information about the available assistance options, eligibility criteria, and the process for requesting assistance. We believe that by offering support and flexibility, we can contribute to the financial well-being of our customers and foster a positive relationship based on mutual understanding and cooperation.

Through our customer assistance initiatives, Refyne aims to demonstrate empathy, understanding, and a commitment to working collaboratively with customers to find sustainable solutions to their financial challenges.

Training and Compliance Monitoring

At Refyne, we recognize the critical role of our staff in ensuring ethical debt collection practices and maintaining compliance with applicable laws and regulations. Our rigorous training programs and robust monitoring mechanisms to uphold the highest standards of professionalism and legal adherence.

Training Programs:
All staff involved in debt collection at Refyne undergo comprehensive training programs. These programs cover ethical practices, legal compliance, customer-centric communication, and the nuances of our Collection and Recovery Policy. Training sessions are conducted regularly to keep our staff updated on changes in regulations, industry best practices, and emerging trends in debt collection.

Compliance Monitoring:
Refyne has established a systematic process for monitoring and evaluating debt collection activities to ensure adherence to our all relevant laws. Regular internal audits and assessments are conducted to verify that staff members are following ethical practices, maintaining transparency in communication, and implementing customer assistance initiatives as outlined in the policy.

Continuous Improvement:
We foster a culture of continuous improvement, where feedback from monitoring activities is used to enhance training programs and refine collection processes. Any identified areas of non-compliance are addressed promptly through corrective actions, with a focus on preventing recurrence and continuously improving our practices.

Adherence to Code of Conduct:
All staff members are expected to adhere to a strict code of conduct that emphasizes professionalism, integrity, and respect in all interactions with customers. Failure to comply with the code of conduct may result in disciplinary actions.

DO’s and DON'Ts

Ongoing Education:
To stay abreast of the dynamic regulatory landscape, staff members receive ongoing education on changes in debt collection laws and regulations. This ensures that our practices remain aligned with the latest legal requirements. 
Through comprehensive training and robust compliance monitoring, Refyne is committed to maintaining a high level of integrity, professionalism, and legal adherence in all aspects of our debt collection and recovery processes.

Dispute Resolution

At Refyne, we understand that disputes may arise during the debt collection process, and we are dedicated to resolving them promptly and fairly. Our Collection and Recovery Policy includes a well-defined dispute resolution process designed to address customer concerns and inquiries with transparency and efficiency.

Designated Point of Contact
Customers with disputes or inquiries will have a designated point of contact within Refyne who will be responsible for handling and facilitating the resolution process. This contact information will be clearly communicated to customers through various channels.

Timely Response
Refyne is committed to providing timely responses to customer disputes. Upon receiving a dispute, we will acknowledge it promptly and initiate an investigation to understand the nature of the concern.

Comprehensive Investigation
Our dispute resolution process involves a thorough and impartial investigation of the customer's claim. This may include a review of communication records, account details, and any relevant documentation provided by the customer.

Communication of Findings
Once the investigation is complete, Refyne will communicate the findings to the customer in a clear and understandable manner. If errors or discrepancies are identified, appropriate corrective actions will be taken promptly.

Appeals Process
Customers dissatisfied with the resolution of their dispute will have the option to appeal the decision. The appeals process will involve a secondary review by a designated authority within Refyne who was not involved in the initial investigation.

Regulatory Compliance​
Refyne ensures that the dispute resolution process aligns with all relevant regulations and legal requirements governing debt collection practices. This includes providing customers with information on their rights and the mechanisms available for dispute resolution.

Continuous Improvement​
Feedback from the dispute resolution process is analyzed to identify areas for improvement in our policies and procedures. This commitment to continuous improvement helps us enhance the effectiveness and fairness of our dispute resolution mechanisms.
Through our dispute resolution process, Refyne aims to uphold the principles of fairness, transparency, and customer satisfaction. We view disputes as opportunities to improve our processes and reinforce our commitment to providing a positive customer experience.


Reporting is a crucial aspect of [Refyne]'s Collection and Recovery Policy, serving as a mechanism to track, document, and analyze debt collection activities. Our commitment to transparency and accountability is reflected in the comprehensive reporting procedures outlined below.

Documentation and Record Keeping
Refyne maintains accurate and detailed records of all debt collection activities, including communication records, repayment agreements, and any relevant customer information. This documentation ensures a transparent and accountable record of interactions.

Regular Reporting
Regular reports on debt collection and recovery activities are generated to provide insights into the performance and effectiveness of our processes. These reports cover key metrics, such as recovery rates, customer satisfaction, and compliance with the Collection and Recovery Policy.

Compliance Reporting
A dedicated compliance report is generated to assess adherence to applicable laws and regulations governing debt collection. This includes an analysis of any identified areas of non-compliance and the actions taken to address them.

Senior Management Oversight
Senior management at Refyne actively oversees the reporting process, ensuring that the information is accurate, relevant, and aligned with the strategic goals of the organization. Regular reviews are conducted to assess the overall effectiveness of the Collection and Recovery Policy.

Regulatory Reporting
Refyne complies with any regulatory requirements related to reporting on debt collection activities. This includes submitting reports to relevant regulatory authorities in accordance with specified timelines and guidelines.
Data Security in Reporting
Measures are in place to secure the confidentiality and integrity of data included in reports. Access to sensitive information is restricted to authorized personnel, and data is transmitted and stored in compliance with data protection laws.

Feedback and Analysis
Reports are not only a tool for compliance but also a source of valuable insights. Feedback and analysis derived from reporting contribute to the continuous improvement of our collection and recovery processes.
Through robust reporting practices, Refyne aims to demonstrate accountability, transparency, and a commitment to continuous improvement in our debt collection and recovery operations.

Record Keeping

Robust record-keeping practices are integral to [Refyne]'s commitment to transparency, accountability, and regulatory compliance in our Collection and Recovery Policy. Thorough documentation ensures a clear and auditable trail of debt collection activities, facilitating effective internal oversight and external scrutiny when required.

Comprehensive Documentation
Refyne maintains comprehensive records of all debt collection activities, including but not limited to communication logs, repayment agreements, and any relevant customer information. These records are stored securely and can be accessed for reference or audit purposes.

Timely Recording
All debt collection activities are recorded in a timely manner to ensure accuracy and completeness. This includes documenting communication with customers, agreements reached, and any other pertinent details related to the debt recovery process.

Data Integrity and Security
Measures are in place to safeguard the integrity and security of customer data. Access to sensitive information is restricted to authorized personnel, and data is stored and transmitted in compliance with data protection laws and industry best practices.

Retention Periods
[Refyne] adheres to defined retention periods for maintaining records related to debt collection activities. This ensures compliance with legal requirements and allows for the retrieval of historical information when necessary.

Accessibility and Retrieval
Records are organized and stored in a manner that facilitates easy retrieval when needed. Authorized personnel have access to the information required for decision-making, reporting, and responding to customer inquiries.

Auditing and Internal Controls
Internal audits are conducted regularly to assess the accuracy and completeness of record-keeping practices. This includes reviewing adherence to the Collection and Recovery Policy, data entry accuracy, and compliance with legal and regulatory requirements.

Legal Admissibility
Refyne ensures that record-keeping practices adhere to legal standards for admissibility. This involves maintaining records in a format that preserves their integrity and authenticity, making them legally acceptable if required in legal proceedings.

Training on Record-Keeping

Staff members involved in debt collection receive training on proper record-keeping practices. This includes guidance on the importance of accuracy, completeness, and timeliness in maintaining records.

Through meticulous record-keeping practices, [Refyne] aims to not only meet regulatory requirements but also to demonstrate a commitment to transparency, accountability, and the highest standards of professionalism in all debt collection and recovery activities.

Regulatory Compliance

Refyne holds a firm stance on ethical conduct and compliance with all applicable laws and regulations in our debt collection and recovery activities. Our Collection and Recovery Policy outlines clear consequences for non-compliance to reinforce a culture of integrity, responsibility, and accountability.

Code of Conduct Violations
Violations of the established code of conduct, which encompasses ethical practices, legal compliance, and adherence to the Collection and Recovery Policy, will result in consequences for the individuals involved.

Disciplinary Actions
Non-compliance with the Collection and Recovery Policy may lead to disciplinary actions, including but not limited to verbal or written warnings, suspension, and termination of employment, depending on the severity and recurrence of the violation.

Training and Re-Education
In cases of non-compliance, individuals may be required to undergo additional training or re-education programs to reinforce understanding of the Collection and Recovery Policy, ethical practices, and legal obligations.

Process Improvement Measures
Instances of non-compliance are thoroughly investigated, and corrective actions are implemented to address systemic issues. This may involve process improvements, revisions to training programs, or other measures to prevent future non-compliance.

Senior Management Oversight
Senior management at [Refyne] is actively involved in overseeing the consequences of non-compliance. This includes ensuring that disciplinary actions are fair, consistent, and aligned with the principles of the Collection and Recovery Policy.

Regulatory Reporting
Serious instances of non-compliance that may have regulatory implications are reported to the relevant regulatory authorities in accordance with legal requirements. [Refyne] is committed to transparently addressing and rectifying any issues that could impact regulatory compliance.

Continuous Monitoring
Refyne maintains continuous monitoring mechanisms to detect and address non-compliance promptly. This proactive approach allows for swift intervention and corrective measures to prevent the recurrence of similar issues.

Whistleblower Protections
Refyne has established mechanisms to protect whistleblowers who report instances of non-compliance. Employees are encouraged to come forward with concerns, and protections are in place to ensure their confidentiality and safeguard against retaliation.
Through a combination of clear consequences for non-compliance, ongoing training, process improvement measures, and senior management oversight, [Refyne] strives to create a work environment that upholds the highest standards of ethical conduct and legal compliance in all debt collection and recovery activities.

Allocation Strategy


Collection Allocation Coordinator -
Responsible for overseeing the entire allocation process, ensuring that allocations are made in accordance with guidelines, and addressing any issues that arise.

Resource Managers/Supervisors -
Responsible for providing inputs regarding the availability and capabilities of resources.

Collections Team -

Individuals who will perform the allocated tasks.



Initiation of Allocation -

  1. Upon receipt of new collections or tasks, the Collection Allocation Coordinator initiates the allocation process.

  2. The coordinator reviews the list of available resources, considering factors such as skills, availability, workload, and expertise.

Resource Assessment -

  1. Resource Managers/Supervisors provide information about the skills, current tasks, and availability of each resource under their supervision.

  2. This information helps in understanding the capacity and capability of each resource to take on additional tasks.

Task Prioritization -

  1. The Collection Allocation Coordinator, in consultation with relevant stakeholders, prioritizes the tasks based on urgency, complexity, and other relevant criteria.

  2. High-priority tasks may require immediate allocation, while lower-priority tasks can be scheduled accordingly.

Allocation Decision -

  1. The coordinator uses the information gathered from resource assessment and task prioritization to make allocation decisions.

  2. Efforts are made to distribute tasks fairly, considering the workload and skill set of each resource.

Communication -

  1. Resources are informed of their allocated tasks, along with clear instructions, deadlines, and any relevant details.

  2. Any concerns or conflicts regarding the allocated tasks should be raised at this stage.

Monitoring and Tracking -

  1. The Collection Allocation Coordinator monitors the progress of allocated tasks regularly.

  2. Updates on task status, completion percentage, and any issues encountered are tracked.

Adjustments and Reallocations -

  1. If unforeseen circumstances arise, such as resource unavailability or changes in task priorities, the allocation plan may need to be adjusted.

  2. The coordinator reviews and reallocates tasks as necessary, ensuring minimal disruption to overall progress.

Completion and Reporting -

  1. Once tasks are completed, the Collection Allocation Coordinator reviews the outcomes and ensures that the goals of the allocation process have been met.

  2. Reports may be generated to provide insights into allocation efficiency, resource utilization, and task completion timelines.


Logic on STU Allocation

Accounts shift from STU to B2B2C based on predefined criteria, optimizing strategies for effective collections by considering customer behavior and payment probabilities.

Allocation Strategy -

  1. For both Terminated(DFS or PTP) and Non Terminated users post the cycle closing date + 45 days if the repayment is not received to be shared for collection calling which is 2nd of every month. 

  2. All the terminated users to be assigned to collection on the monthly file which is on  2nd of every month.

  3. Any account which is less than 45 Days Non terminated users where the liability is greater than 30% of the salary should be part of collection - Welcome call.

  4. Removal of Employee ids to be removed and also the account which are part of Salary care

  5. Any account where the user is active and we have received the payment should not be part of collections.

Format for the STU allocation -

Need to past the format

Payment file Logic -

  1. Accounts which are in collection as per the above logic, if any repayment is received via link, DFS or Promise to Pay, file of the cumulative collected data till the closing cycle that is 1st of every month to be present and shared with the vendors.

  2. Every vendor will receive the payment file in mail for their respective accounts.

  3. Overall payment file to be shared with inhouse team. 

  4. We have to get 3 different type of Payment B2C, B2B and DFS or PTP

  5. B2C is the accounts where we have received the payments from cashfree platform

  6. B2B is of where we have raised the DFS and received the repayment

  7. DFS or PTP the status update will happen as per the report received from the client.

Manual Addition of data -

  1. Agency Name ,  Advisor Name and the TL name to be added against the user id or the STU id every month.

  2. Files for the add of the name will be shared by collection.

  3. Zone data against the users will be provided by collections.

  4. Marking B2C payment for the account will share the Cashfree report.

All collection-associated accounts will carry Days Past Due (DPD) indicators. Targets are established using the last three months' performance trends, allowing for dynamic adjustments that reflect recent successes, optimizing resource allocation, and fostering efficient debt recovery practices.


New Model which is yet to launch Logic on B2C Allocation

B2C disbursal and collection strategy defined; emphasizes targeted allocation based on customer profile, risk assessment, and tailored communication methods, ensuring effective recovery and customer satisfaction.


  1. Allocation based on due date; bounced accounts on due date proceed to collections.

  2. After remittance confirmation, accounts enter Grace calling phase until 100% remittance update (3 days).

  3. DPD movement starts post-due date for bounced EMIs.

  4. Allocation categorizes accounts into buckets based on DPD days for targeted collection strategies.

Collection-tracked accounts adhere to a target-oriented strategy, optimizing efforts for successful debt retrieval. Tailored approaches consider customer behavior, historical data, and due amounts, enhancing the probability of meeting collection goals while maintaining efficient resource allocation and positive customer relations.


Logic on EWA Allocation -

Accounts shift from STU to B2B2C based on predefined criteria, optimizing strategies for effective collections by considering customer behavior and payment probabilities.

  1. Customers who are terminated before 2nd of every month will be part of B2C collections.

  2. Customers who get terminated within the month will be part of inhouse collections.

  3. Customers where the status is transferred after 15 days of DFS received will be part of digital collections.

  4. Customers Terminated and the F&F is more than 30% of the amount he receives will be part of inhouse collections.

Documentation: All allocation decisions, adjustments, and communications are documented for future reference and auditing purposes.

Review and Continuous Improvement: Regular reviews of the allocation process are conducted to identify areas for improvement and ensure that the SOP remains up-to-date and effective.

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