🇮🇳 100Lesson 4 of 1250 min

Auto Loans

Vehicle financing mechanics for new and used cars. Hypothecation and RTO paperwork (Forms 34 and 35), insurance requirements with bank as financier, selling a car with an active loan via interim NOC, used car loan specifics, default escalation and repossession rights under RBI rules, and loan closure with Vahan portal verification.

What you'll learn
  • Understand the auto loan landscape — banks, NBFCs, captive financiers — and how to compare lenders
  • Navigate the new car purchase process from booking to driving home, including sanction, hypothecation, and RTO paperwork
  • Understand Forms 34 and 35 and what they mean for ownership and sale
  • Execute the interim NOC procedure when selling a car with an active loan
  • Know the specific rules and risks of used car loans vs new car loans
  • Understand the default escalation timeline and your rights under RBI recovery agent rules
  • Complete loan closure correctly — from NOC to Form 35 filing to Vahan portal verification

Auto Loans in India

A car is a depreciating asset. The moment you drive a new car off the showroom lot, it loses 10-15% of its value. Over 5 years it may shed 50-60% of original value. Yet most Indian car buyers finance their purchase with an auto loan, paying interest on top of this depreciation. Understanding auto loan structure helps you make this expense as efficient as possible — buying within your means, choosing the right tenure, securing competitive rates, navigating the RTO paperwork, and handling life events (selling early, defaulting, completing the loan).

Auto loans are secured loans — the vehicle is collateral. This makes the rate substantially lower than personal loans (typically 9-11% vs 12-18%). But unlike home loans where the asset appreciates, the vehicle depreciates faster than the loan principal reduces in early years. By year 2-3, you can be in negative equity (loan owed exceeds car value). This shapes several decisions specific to auto loans.

This lesson covers the auto loan landscape (banks, NBFCs, captive financiers), what determines the loan amount and rate, the universal application process with Pooja's new car journey, hypothecation and the RTO paperwork (Forms 34 and 35), vehicle insurance requirements with bank as financier, the interim sale NOC procedure with Anil's mid-loan sale, used car loan specifics with Manoj's purchase, default and repossession with Ravi's scenario including the recovery agent rules from RBI, and the loan closure process with Ajay including Form 35 filing and CIBIL update. By the end, you should approach auto loans as a standard secured-lending product with predictable touchpoints, and know your rights at every stage.

A reminder on context: this lesson covers Indian auto loans as applicable for FY 2025-26. Specific rates, insurance regulations, and RTO procedures evolve; structural mechanics are stable. This lesson assumes you've read Lesson 1 (Foundation) — concepts like sanction letter, MITC, loan agreement, CIBIL, FOIR, NACH, grievance redressal are not re-grounded here.

The auto loan landscape

Key terms

Captive financier: Lending arm of a vehicle manufacturer. Examples: Maruti Suzuki Finance, Hyundai Motor Finance (HMFCL), Toyota Financial Services, Mahindra Finance, Tata Capital. Lends specifically for that manufacturer's vehicles. Often offers special rates, manufacturer subsidies, faster approval at dealer.

On-road price vs ex-showroom price:

  • Ex-showroom price: Base price + GST + cess. What manufacturer charges to dealer.
  • On-road price: Ex-showroom + RTO charges (registration, road tax) + insurance (first year) + accessories + handling. What you actually pay to drive home.
  • Difference: typically 10-15% of ex-showroom price. Banks typically lend on ex-showroom, but increasingly cover on-road if profile permits.

LTV for auto loans: Loan-to-Value ratio. For new cars: typically 80-90% of ex-showroom price; some lenders 100% with stricter underwriting. For used cars: 70-80% of bank's valuation (not seller's price).

RC book (Registration Certificate): Government-issued document proving ownership of the vehicle. Each RC has owner name, vehicle details (chassis, engine, registration number), and a hypothecation entry if the vehicle is financed. RC books moved fully to digital (DigiLocker) in most states since 2022.

Vahan portal: Central database (parivahan.gov.in) maintaining records of all registered vehicles in India. Hypothecation entries on RC are reflected in Vahan portal.

Lender TypeRate RangeStrengths
Public Sector Banks (SBI, BoB, PNB)9.0-10.5%Lowest rates; strong PSB schemes; slower processing
Private Sector Banks (HDFC, ICICI, Axis)9.5-11%Faster; better digital; competitive for prime borrowers
Captive Financiers8.5-12%Promotional rates; manufacturer-aligned; sometimes lowest
NBFCs (Mahindra Finance, Sundaram Finance)10.5-14%Used cars and lower-tier profiles; rural reach
Cooperative BanksVariesRegional relationships; sometimes very competitive

Captive financier dynamics

When you walk into a Maruti showroom, the salesperson will push Maruti Suzuki Financial Services. They're commission-incentivized. The captive financier may offer:

  • "0% interest" or "low-interest" promotional schemes (often subsidized by manufacturer)
  • Faster paperwork
  • "Special discount" if you finance with them

But verify carefully:

  • "0% interest" usually means lower discount on car price (manufacturer absorbs interest cost into MRP discount foregone)
  • Promotional rates may be valid only for specific models / variants / shorter tenures
  • Bank rates may be lower even after losing the "discount"

Strategic insight: Get a written quote from your bank BEFORE visiting showroom. Walk in with that quote. Negotiate captive financier rate against it. Often you'll get bank rate + manufacturer discount.

RBI Master Direction on Auto Finance; Motor Vehicles Act 1988; banking industry vehicle finance products.

Pooja's new car journey

Pooja, 33, project manager in Pune, ₹95K/month income. Buying her first car — Maruti Brezza, ex-showroom price ₹9 lakh, on-road price ₹10.5 lakh. She has ₹2.5L saved for down payment + costs. Needs ₹8L auto loan.

The 5-day journey

Day 1: Booking + financing decision

Pooja visits Maruti showroom. Test drives. Decides on the variant. Pays ₹25,000 booking advance. Salesperson pushes Maruti Suzuki Financial Services (captive): "9.5% for 5 years, instant approval, all paperwork from showroom" Pooja smartly says she'll evaluate. Goes home. That evening, checks her salary bank (HDFC) auto loan offers: Pre-approved auto loan: 9.25% for 5 years, ₹10L pre-approved limit She gets HDFC's offer in writing via app. Returns to showroom next day with HDFC's quote.

Day 2: Negotiation

Pooja shows HDFC's 9.25% quote. Salesperson counter-offers from captive: 9.15%. Pooja accepts captive (slightly cheaper + paperwork from showroom is convenient + manufacturer discount of ₹15K is retained). She fills auto loan application at the dealer. Submits:

  • PAN, Aadhaar
  • 6 months' salary slips
  • 12 months' bank statement
  • Booking receipt for the car
  • Income tax return (1 year)

Day 3: Sanction

Captive financier sanctions. Pooja reviews sanction letter.

Key terms from the auto loan sanction

Hypothecation: Legal mechanism where movable property (like a vehicle) is used as security for a loan, but possession remains with the borrower. The lender has charge on the asset and can take possession in case of default. Different from:

  • Mortgage: For immovable property (land/building). Created by deposit of title deeds or registered mortgage deed.
  • Pledge: Movable property where possession is given to lender (e.g., gold loan — bank holds the gold).
  • Lien: Right to retain another's property until obligation is paid.

In hypothecation, you drive the car but the lender has a charge on it. You cannot sell without lender's NOC.

IDV (Insured Declared Value): The maximum amount your insurer will pay in case of total loss (theft, irreparable damage). Set at purchase price minus depreciation. Banks require IDV ≥ outstanding loan amount throughout tenure to protect their security interest.

EBLR + Spread for auto loans: Like home loans, auto loans are typically benchmarked to External Benchmark Lending Rate (typically repo rate). Spread varies by borrower profile, loan amount, captive vs bank lender.

What Pooja verifies on her sanction letter

  • Vehicle details match her order ✓
  • Loan amount ₹8L matches application ✓
  • Rate 9.15% matches negotiated quote in writing ✓
  • Floating rate (so NIL prepayment) ✓
  • 5-year tenure (she chose this for lower interest cost) ✓
  • Comprehensive insurance requirement understood ✓
  • Hypothecation procedure mapped ✓

She signs. Loan agreement signed. NACH mandate set up.

Day 4: Hypothecation deed signing

Before disbursement, Pooja signs the hypothecation deed. This is the legal instrument creating the hypothecation charge.

Day 5: RTO registration with hypothecation entry

After dealer takes delivery preparation, vehicle goes to RTO. Pooja's dealer files Form 34 along with the registration application. The form adds the hypothecation entry to the RC book.

The RC book Pooja receives

After 10 working days, RTO issues Pooja's RC book (now mostly digital via DigiLocker).

Pooja's vehicle insurance

Bank requires comprehensive insurance with bank as financier-nominee. Pooja's first-year policy was bundled into the on-road price.

By Day 5, Pooja drives her Brezza home. Total cash outflow: Booking + down payment: ₹2,50,000 Plus on-road components built into financing Total she spent: ₹2,50,000 + ₹16,705/month for 60 months Total cost over 5 years: Loan principal: ₹8,00,000 Loan interest: ₹2,02,300 Plus 4 more years of OD insurance (~₹1L cumulative) Plus fuel, service, road tax renewal etc. (not loan-related) Loan-related cost: ₹10,02,300 vs ₹8L borrowed = ₹2L cost of borrowing.

Motor Vehicles Act 1988; Central Motor Vehicle Rules 1989; IRDAI Master Circular on Motor Insurance; RBI Master Direction on Auto Finance.

Selling car during active loan — Anil's interim NOC

Setup

Anil, 38, sales head in Mumbai. Took a ₹6L auto loan 3 years ago at 9.5% for 5 years. Outstanding balance ₹2.4L. Loan tenure has 2 years left. Now wants to upgrade — selling his current car for ₹4L to buy a bigger car. But the car is hypothecated to ICICI Bank — he cannot legally transfer ownership.

The problem

Anil has three options:

Option A: Pay off the loan first, then sell

  • Foreclose loan with ₹2.4L from own funds (or buyer's deposit)
  • Bank issues NOC + Form 35
  • File Form 35 with RTO
  • RTO updates RC (removes hypothecation)
  • Then sell the now-unencumbered car

Downside: Requires Anil to have ₹2.4L upfront or buyer to advance funds before getting ownership transfer.

Option B: Interim NOC for sale (the smart route)

Anil requests bank for an interim NOC specifically authorizing sale of the hypothecated vehicle to a specific buyer. The mechanic:

  • Bank issues interim NOC stating they'll release the charge once full payment received
  • Buyer is informed and pays the bank directly an amount equal to the loan outstanding
  • Buyer pays the balance (₹4L sale price - ₹2.4L to bank = ₹1.6L) directly to Anil
  • Bank's full payment received → bank issues final NOC + Form 35
  • Anil files Form 35 with RTO → hypothecation removed
  • Vehicle transferred to buyer via Form 29/30

This avoids needing Anil's ₹2.4L upfront.

Option C: Balance transfer to buyer (with their own loan)

Buyer takes own loan from a bank/NBFC, who pays off Anil's loan directly. New hypothecation in favor of buyer's bank.

Anil chooses Option B.

Anil's execution

Day 0 (8 July): Submits interim NOC request to ICICI branch with sale agreement copy. Day 5 (13 July): Bank issues interim NOC valid 30 days. Sends to Anil + buyer Vikas. Confirms outstanding on 25 July value date: ₹2,42,150. Day 17 (25 July): Buyer Vikas transfers ₹2,42,150 directly to ICICI (citing Anil's loan account in narration). Same day transfers ₹1,57,850 to Anil's account. Day 18 (26 July): Bank confirms full loan closure. Issues final NOC + Form 35 to Anil. Day 20 (28 July): Anil and Vikas visit RTO together. Submit Form 35 (hypothecation removal) + Form 29 (notice of transfer) + Form 30 (application for transfer of ownership). Day 35 (12 August): RTO updates Vahan portal — old hypothecation removed, ownership transferred to Vikas, new RC issued in Vikas's name without hypothecation entry.

Anil receives ₹1,57,850 cash from sale Loan closed Vehicle transferred legally No interest paid on Anil's funds (he kept his money for the new car purchase)

FormPurposeFiled By
Form 35Remove hypothecation entry from RCOld owner (Anil) after bank's NOC
Form 29Notice of transferSeller (Anil)
Form 30Application for transfer of ownershipBuyer (Vikas)
Insurance transferUpdate insurance to new ownerNew owner (Vikas)

Without all these filed correctly, the sale is incomplete. Suresh's situation from Lesson 1 (bank not filing Form 35 post-foreclosure) is exactly the failure mode this section illustrates from the proper side.

Motor Vehicles Act 1988 Section 50, 51; Central Motor Vehicle Rules 1989 Form 29, 30, 35; banking industry interim NOC practices.

Used car loan — Manoj's second-hand purchase

Used car loans differ from new car loans in several mechanical ways.

Setup

Manoj, 29, marketing executive in Delhi, ₹70K/month income. Buying a used Honda City 2021 model from individual seller. Negotiated price ₹6.5L. Has ₹2L saved. Needs ₹4.5L used car loan from Mahindra Finance (NBFC).

AspectNew CarUsed Car
Rate9-11%11-15% (higher)
LTV80-90% of ex-showroom70-80% of bank's valuation (not asking price)
Vehicle age limitn/aMax 8-10 years at end of tenure
TenureUp to 7 yearsUp to 5 years typically (depends on vehicle age)
InspectionVehicle inspection at deliveryMANDATORY independent inspection before loan
ValuationStandard ex-showroomBank's panel valuer assesses condition + market
DocumentationCleaner (single owner from showroom)More complex (transfer ownership + create new hypothecation)
InsuranceNew policy, IDV near purchase priceExisting policy transferred or new policy; IDV lower

Why higher rates for used cars

  • Higher risk of mechanical issues (depreciating mechanical condition)
  • Harder to value precisely (no standard MRP)
  • Smaller resale market if repossessed
  • Default rates statistically higher on used car loans

Manoj's specific journey

Step 1: Identifies the Honda City. Seller has clean papers, all OC, valid insurance, RC in seller's name (no hypothecation). Step 2: Pays ₹50K token. Gets photocopies of seller's RC, insurance, tax receipts, PUC. Step 3: Approaches Mahindra Finance for used car loan. Submits standard application + seller's documents + sale agreement. Step 4: Bank's panel inspector visits seller's location, inspects the vehicle: • Engine condition assessed • Body damage checked • Service history verified • Chassis number verified against RC • Valuer's report submitted Step 5: Bank values vehicle at ₹6L (slightly below ₹6.5L asking price). Bank-approved LTV: 75%. Maximum loan: ₹4.5L (exactly what Manoj needs). Step 6: Sanction issued — ₹4.5L at 12.5% for 4 years. EMI ₹11,977. Total interest ~₹1.25L. Step 7: Three-party transaction at RTO — Manoj, seller, and bank's representative meet at RTO: • Form 29 (transfer notice by seller) • Form 30 (transfer application by Manoj) • Form 34 (add hypothecation in favor of Mahindra Finance) • Sale consideration: Bank disburses ₹4.5L directly to seller; Manoj pays balance ₹2L from own funds Step 8: RTO processes within 10 days. New RC issued in Manoj's name with hypothecation in favor of Mahindra Finance. Step 9: Insurance: Existing policy in seller's name transferred to Manoj OR Manoj buys new comprehensive policy. Bank named as financier on policy. Manoj drives home with a used Honda City and a ₹4.5L loan obligation for 4 years.

TrapCostAvoidance
Skipping independent inspectionBuy car with hidden issuesAlways pay ₹2-3K for independent inspection
Trusting seller's word on accident historyCompromised structure invisible visuallyDemand insurance claim history; check on Vahan portal
Buying without checking pending challansInherit traffic violationsVahan portal lookup before purchase
Not verifying RC matches sellerPossible stolen vehicleMatch Aadhaar/PAN exactly with RC name
Ignoring service historyMaintenance arrearsDemand service records from authorized service center
Not factoring imminent insurance renewalSurprise expenseCheck policy expiry; budget renewal
Underestimating road tax differencesBuying inter-state carsSome states require road tax repayment

RBI Master Direction on Auto Finance (used vehicles); Motor Vehicles Act 1988; banking industry used vehicle finance norms.

Default and repossession — Ravi's job loss

Setup

Ravi, 41, lost his job in a startup layoff 4 months ago. Took ₹7L auto loan 2 years ago at 10% for 5 years. EMI ₹14,872. Outstanding ₹4.8L. Last 3 EMIs bounced. He's running through savings looking for new employment. Today (Day 95 since first missed EMI), he receives a repossession notice from his bank.

Days OverdueWhat Happens
1-7EMI debit bounce; bank SMS reminder; ₹500-1000 bounce fee
8-30Bank's collection team calls; reminder letters; opportunity to cure
31-60More urgent collection calls; "SMA-1" status on CIBIL
61-90"SMA-2" on CIBIL; pre-NPA notices; recovery agent introduction
90+Account becomes NPA; CIBIL shows "Sub-Standard"; repossession notice; recovery agent active
91-120Repossession notice with 7-14 day cure window
121+Actual repossession if no cure; vehicle taken
Post-possessionAuction; sale proceeds applied to outstanding; deficit (if any) pursued via civil suit

Ravi's rights during this period

Even in default, Ravi has substantial rights per RBI's Master Direction on Recovery Agents (2022):

RightDetail
IdentificationRecovery agent must identify themselves with bank ID + authorization letter
TimingVisits/calls only 8 AM - 7 PM
FrequencyReasonable; no harassment
ConductNo threats, abuse, public shaming, force
PrivacyCannot discuss loan with family/neighbors/employer without consent
Vehicle seizureCannot use force; cannot enter private property without permission
Police involvementRequired for physical seizure if borrower resists
DocumentationVehicle taken with detailed inventory + receipt to borrower
NotificationBorrower informed of auction venue + time
AuctionMust be fair public auction

What Ravi should do

Wrong response: Ignore the notice. Repossession will happen. Vehicle sold cheap. He'll still owe deficit. CIBIL devastated.

Wrong response: Threaten recovery agent. Criminal complaint possible. Doesn't help.

Wrong response: Hide the vehicle. Bank can register FIR for cheating; criminal trouble.

Right response: Engage immediately.

Ravi visits the bank within 3 days of notice. Frank conversation with branch manager:

  • "I lost my job in May. Three interviews in progress. New offer expected in 4-6 weeks."
  • "I have ₹40K savings. Can pay one EMI immediately as good faith."
  • "Request restructuring: pause for 3 months (or interest-only); resume full EMI from October."

Bank's options for genuine hardship cases:

  • Moratorium: 3-6 month pause; interest accrues but no EMI; restart later
  • Interest-only period: Pay just interest portion for 3-6 months; defer principal
  • EMI reduction with tenure extension: Lower EMI, longer total tenure
  • Top-up restructuring: Combine arrears with new loan at lower EMI

The bank's incentive is to avoid actually repossessing — selling a depreciated car at auction typically recovers less than the outstanding. They'd rather have Ravi pay over time.

For Ravi's case, bank agrees to: 3-month moratorium (Aug-Oct) Interest accrues; added to principal at end Resume regular EMI from November (slightly higher, since 3 months interest added) Vehicle stays with Ravi Repossession notice withdrawn CIBIL stays at "SMA-2" rather than escalating to NPA Ravi finds new job in October. November onwards: pays regular EMI. Eventually fully closes loan. CIBIL recovery takes 18-24 months.

Default is a process, not an event. Engagement at every stage gives options. Silence and avoidance eliminates options. Recovery agents who appear at your door are the END of a long collections process — most situations resolve well before that point if borrower engages.

RBI Master Direction on Recovery Agents (2022); Banking Regulation Act; banking industry recovery norms; SARFAESI Act (applies to certain vehicle finance contexts).

Loan completion — Ajay's Form 35 and NOC journey

When you complete all EMIs (or foreclose), the closure mechanic for auto loans requires careful execution to ensure the RC book is updated.

Setup

Ajay, 36, IT professional in Bangalore. Took ₹5L auto loan 5 years ago at 10% for 5 years. All 60 EMIs paid on time. Last EMI on 5 June 2026 cleared. Now requesting NOC + Form 35.

Day 5 June 2026 — Last EMI paid NACH debit confirms ₹10,624 (final EMI). Loan account balance: NIL.

Day 6 June 2026 — Ajay requests NOC Ajay submits standard NOC request at branch (similar to Lesson 1 + Lesson 2 NOC templates).

Day 15 June 2026 — Bank issues NOC + Form 35 NOC similar to home loan NOC but vehicle-specific. Bank also gives signed Form 35.

Day 18 June 2026 — Ajay files Form 35 with RTO Form 35 is the application to RTO for removing hypothecation from RC.

Day 28 June 2026 — RTO updates RC RTO processes Form 35. Issues updated RC without hypothecation entry. Vahan portal updated.

Day 30 June — Ajay's verification checklist

  • CIBIL report shows loan "Closed" status (verified via cibil.com)
  • Vahan portal shows no hypothecation entry on this RC (verified at parivahan.gov.in)
  • Updated RC card received with no hypothecation entry
  • Bank's NOC kept permanently in his files
  • NACH mandate cancellation confirmed
  • Insurance policy: bank's name as financier removed at next renewal

What if RTO delays Form 35 filing?

This is exactly the Suresh scenario from Lesson 1. If bank or RTO fails to update Vahan portal:

StageAction
Wait 30 days from Form 35 submissionReasonable initial period
Visit RTO + BankInquire status; escalate informally
Stage 1 complaintBranch manager grievance (Lesson 1 covered this)
Stage 2 escalationNodal officer (Lesson 1)
Stage 3 escalationRBI Banking Ombudsman (Lesson 1)
Stage 4 (rare)Consumer forum / civil suit

The Suresh narrative in Lesson 1 is essentially what happens when this normal Form 35 process breaks. Most cases close cleanly within 30 days; some don't.

Motor Vehicles Act 1988; Central Motor Vehicle Rules 1989 Form 35; RBI Master Direction on Fair Practices Code.

Common auto loan mistakes

MistakeCostAvoidance
Accepting first captive financier quotePay 0.5-1% higher rateGet bank quote in writing FIRST
Choosing 7-year tenure for lower EMIPay ~30% more total interest5-year max for personal cars
Ex-showroom price loan but on-road costs not budgetedSurprise ₹1-2L additional outflowCompute on-road price; arrange full funding
Skipping zero-depreciation coverPay ₹50K+ on first claim₹5-7K extra premium saves multiples
Letting insurance lapse mid-loanBank covenant breachAuto-renewal + calendar reminders
Not naming bank on insurance policyInsurance claim issues + covenant breachVerify policy explicitly shows bank as financier
Selling car informally with hypothecation still activeBuyer cannot register; sale stallsAlways get bank's interim NOC first
Buying used car without independent inspectionMajor hidden defects₹2-3K inspection saves ₹50K+ surprises
Skipping pending challan check on used carsInherit traffic violationsVahan portal pre-purchase check
Ignoring repossession noticeVehicle seized + deficit pursuedEngage immediately; restructure
Surrendering vehicle voluntarily thinking loan endsDeficit still owed after auctionNegotiate full closure before surrender
Foreclosing without checking break-evenLose tax benefits or opportunity costCompute net benefit
Not following up Form 35 with RTOHypothecation lingers; sale issues laterVerify Vahan portal within 30 days
Treating verbal commitments from dealer as bindingDisputes on add-ons, accessories, delivery dateGet all in writing on dealer letterhead
Buying car beyond your means using stretched 7-year tenureTotal cost becomes prohibitive5-year EMI should be ≤ 15% of net income

Key Takeaways

  • Auto loans are secured — the vehicle is collateral — making rates lower than personal loans (9-11% vs 12-18%), but hypothecation restricts sale until the bank issues NOC
  • Always get a written bank quote before visiting a showroom; use it to negotiate against the captive financier's offer
  • Hypothecation (vehicle as security with borrower retaining possession) differs from mortgage (immovable property) and pledge (possession transferred to lender); you cannot sell without the bank's NOC and Form 35
  • Used car loans carry higher rates (11-15%), lower LTV (70-80%), mandatory independent inspection, and shorter tenure — because the asset is harder to value and default rates are higher
  • Vehicle default escalates quickly — repossession can begin at 90-120 days; engaging early and requesting restructuring is always better than ignoring notices
  • Loan closure is a four-step process: receive NOC + Form 35 from bank → file Form 35 with RTO → verify Vahan portal shows no hypothecation → confirm CIBIL shows 'Closed'

Quiz — 5 Questions

Answer one at a time
Question 1 of 50 answered

Pooja is buying a car and the showroom's captive financier offers 9.15%. Her bank has pre-approved her at 9.25%. What is the best strategy?

AAccept the captive financier's offer immediately since it is cheaper
BGet the bank's offer in writing first, then use it to negotiate with the captive financier at the showroom
CAlways choose the bank to avoid dealer pressure
DAsk the dealer to match the bank rate without sharing the bank's letter