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Friday, May 22, 2015

Disclosed Factoring and Principle of Debtor Protection in the Factoring Regulation Act, 2011 of India



In the earlier posts (Introduction and Types of Factoring), we talked about the basics relating to factoring, types of factoring and important definitions relating to factoring under the Indian law. In the present post, we shall discuss the concept of disclosed factoring and the principle of debtor protection. Additionally, important amendments in other laws of India that took place because of the enactment of the Factoring Regulation Act, 2011 shall also be discussed in this post.

Disclosed Factoring


Factoring as envisaged under the Factoring Act must be disclosed factoring. Disclosed factoring means that the debtor, who is liable to make the payment to the assignor must be informed by way of intimation in writing that receivables from the customer are being factorized. Prior to the commencement of the Factoring Act, the assignment of receivables was governed by the Transfer of Property Act, 1882 which does not make prior notice to the debtor before the assignment of receivables. Thus, it was open to the parties to decide whether they wanted to undertake disclosed or undisclosed factoring. However, as per the provisions of the Factoring Act, prior notice to the debtor is mandatory for the assignment of receivables to the Factor.[1]

Principle of Debtor Protection


The Factoring Act embodies the principle of debtor protection under Section 15 and contains various safeguards in relation to the rights of a debtor in a factoring transaction. Some of the important ones are:[2]

a. In the event no notice of assignment of receivables is given by the assignor or under his authority by the assignee to the debtor and any payment is made by the debtor in respect of such receivables to the assignor, then the assignor is under a statutory obligation to fold such payments in trust for the benefit of the Factor which shall immediately be paid to such Factor. 

b. The Factoring Act restricts the modification of the contracts entered between the debtor and the assignor (barring a few exceptions) and states that any assignment of the receivable shall not affect the rights and obligations of the debtor (including the terms and conditions of the contract), without the express consent of the debtor in writing.

c. In the event a claim is made by the assignee against the debtor for payment of the assigned receivable, the debtor may raise the right of set-off against the assignee which was available under the original contract entered into between the assignor and debtor or any other contract that was part of the same transaction, as if the assignment had not been made.

d. The assignee would, unless otherwise agreed between the parties, be entitled to recover any loss suffered by it as a result of any such defences and right of set off being exercised by the debtor from the assignor.

Important Amendments in Other Laws


1. An important amendment that has been made in accordance with the Factoring Regulation Act is with respect to the Code of Civil Procedure, 1908. Rule 1(2)(b)(iv) has been inserted in Order XXXVII of the Code of Civil Procedure, 1908, whereby suits for recovery of receivables instituted by an assignee shall be subject to the summary procedure prescribed under the Code. Basically, the provisions relating to the summary suits are made applicable to claims of Factors to facilitate speedy recovery of receivables.[3]


2. An important change is insertion of section 8D in the Indian Stamp Act, 1899, granting exemption from stamp duty on documents executed for the purpose of assignment of receivables in favour of Factors notwithstanding anything to the contrary contained in any other law in force. In view of such exemption, assignment of receivables in favour of Factors becomes a viable proposition and is expected to give a boost to factoring.[4]


These amendments provide an impetus to the factoring business and would aid in speedier disposal of litigation and reduce the cost of entering and enforcing factoring transactions. In the next post, we shall conclude the discussion on the Factoring Regulation Act, 2011 by talking about the registration of factors and receivables as envisaged under the scheme of the said Act.

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