The Fair Practices Code of Repco Home Finance Limited (herein after called the Company) is being drafted in accordance with National Housing Bank ‘s Circular No. NHB (ND)/DRS/Pol.No.34/2010-11 dated October 11, 2010. The intent of the Code is to promote transparency in transactions between the Company and its Customers and to ensure that the development of well informed business relationships.
- i) Promotion of Good and Fair Practices by setting minimum standards for customer relationships;
- ii) Increased transparency so that the customer fully comprehends what he/she can reasonably expect of the services;
- iii) Encouragement of Market forces, through competition, to achieve higher operating standards;
- iv) Promotion of a Fair and Cordial Relationship between customer and the Company; and
- v) Fostering confidence in the housing finance system.
II. APPLICATION OF THE CODE :
This code applies to all products and services offered by the Company.
III. The Company shall act fairly and reasonably in all dealings with customers, by ensuring that:
- a. The commitments and standards in this Code for the products and services that the Company offers and in the procedures and practices that the staff follow.
- b. Our products and services meet relevant laws and regulations in letter and spirit.
- c. Our dealings with customers rest on ethical principles of integrity and transparency.
IV. ADVERTISING , MARKETING AND SALES:
- a. The advertising and promotional material pertaining to the products of the Company shall be clear and there shall be utmost credibility
- b. Any advertisement that has a reference to any interest rate shall also contain details of any relevant fees and charges that may be applicable and that such details would be made available on request
- c. The Company would at specific time intervals communicate to the customers about the various features of their products availed by them. The Company would communicate such information about the products or promotional offers only if the customer has given his / her consent to receive such information / service either by mail or by registering for the same on the website or on customer service number.
i) Applications for loans and their processing
- a. The Loan application forms will contain all necessary information which affects the interest of the borrower, so that a meaningful comparison with the terms and conditions offered by other HFCs can be made and informed decision can be taken by the borrower. The list of documents required to be submitted with the application form would also be mentioned .
- b. An acknowledgement for receipt of all loan applications shall be given loan applications would be disposed off within 3 weeks. This shall be indicated in the acknowledgement.
ii) Loan appraisal and terms/conditions
- a. Normally all particulars required for processing the loan application would be collected by the Company at the time of application. In case any additional information is required ,the customer would be told that he/she would be contacted immediately again.
- b. The Company will convey in writing to the borrower by means of sanction letter , the amount of loan sanctioned along with all terms and conditions including annualized rate of interest, method of application, EMI Structure, prepayment charges and keep the written acceptance of these terms and conditions by the borrower on the record.
- c. A copy of the loan agreement along with a copy each of all enclosures quoted in the loan agreement would be provided to every borrower at the time of sanction / disbursement of loans.
iii) Communication of rejection of Loan Application
- The Company would communicate in writing as regards the reason(s) for rejection of a loan application.
iv) Disbursement of loans including changes in terms and conditions
- a. The Disbursement will be made in accordance with the disbursement schedule given in the Loan Agreement/ Sanction Letter.
- b. Notice would be given to the to the borrower of any change in the terms and conditions including disbursement schedule, interest rates, service charges, prepayment charges, other applicable fee/ charges etc. The changes in interest rates and charges would be effected only prospectively.
- c. If any change is to the disadvantage of the customer, he/she may within 60 days and without notice close his / her account or switch it without having to pay any extra charges or extra interest.
- d. Any Decision to recall / accelerate payment or performance under the agreement or seeking additional securities, should be in consonance with the loan agreement.
- e. The Company will release all securities on repayment of all dues or on realization of the outstanding amount of loan subject to any legitimate right or lien for any other claim that the Company may have against borrower. If such right of set off is to be exercised, the borrower shall be given notice about the same with full particulars about the remaining claims and the conditions under which the Company is entitled to retain the securities till the relevant claim is settled /paid.
When a person is considering to be a guarantor to a loan, he/she would be informed by the Company about
- a. his/her liability as guarantor;
- b. the amount of liability he/she will be committing him/herself to the company;
- c. circumstances in which he/she may be called upon to pay up his/her liability;
- d. whether the Company has recourse to his/her other monies in the company if he/she fail to pay up as a guarantor;
- e. whether his/her liabilities as a guarantor are limited to a specific quantum or are they unlimited; and
- f. time and circumstances in which his/her liabilities as a guarantor will be discharged as also the manner in which the Company will notify him/her about this
The Company shall keep him/her informed of any material adverse change/s in the financial position of the borrower to whom he/she stands as a guarantor.
VI. PRIVACY AND CONFIDENTIALITY
All personal information of customers would be treated as private and confidential even when the customers are no longer customers, and shall be guided by these following principles and policies. The Company will not reveal information or data relating to customer accounts, whether provided by the customers or otherwise, to anyone, including other companies entities in their group, other than in the following exceptional cases:
- a. If the information is to be given by law
- b. If there is a duty towards the public to reveal the information
- c. If the Company’s interest requires giving the information (for example, to prevent fraud)
- d. If the customer asks the Company to reveal the information, or with the customer’s permission
- e. If Company is asked to give a reference about customers, their written permission shall be obtained before giving it.
- f. The customer shall be informed of the extent of his / her rights under the existing legal framework for accessing the personal records that the Company holds about him/her.
- g. The Company will not use customer’s personal information for marketing purposes by anyone including HFCs unless the customer specifically authorizes them to do so.
Credit reference agencies
- a. When a customer opens an account, the Company will inform him/ her as to when such information would be passed on to credit reference agencies and the checks that the Company would make with them as required from case to case.
- b. The Company would give information to credit reference agencies about the personal debts the customer owes if:
- 1. The customer has fallen behind with his / her payments;
- 2. The amount owed is not in dispute; and
- 3. The customer has not made proposals that the Company is satisfied with, for repaying his / her debt, following HFCs’ formal demand
- c. In these cases, the Company will intimate to the customer in writing that it plans to give information about the debts the customer owes to the Company to credit reference agencies. The Branch Staff shall explain to the customer the role of credit reference agencies and the effect the information they provide can have on customer’s ability to get credit.
- d. The Company would give the credit reference agencies other information about the customer’s account only if the customer has given them his / her permission to do so.
- e. A copy of the information given to the credit reference agencies shall be provided by the Company to any customer, if specifically demanded.
VII. COLLECTION OF DUES
- i) Whenever loans are given, the Company would explain to the customer the repayment process by way of amount, tenure and periodicity of repayment. Incase the customer does not adhere to repayment schedule, a defined process in accordance with the laws of the land shall be followed for recovery of dues. This process will involve reminding the customers by sending them notice(s) or by making personal visits and / or repossession of security if any.
- ii) The Company’s collection policy is built on courtesy, fair treatment and persuasion. The Company believes in fostering customer confidence and long-term relationships. The Company’s staff or any person authorized to represent them in collection of dues or / and security repossession shall identify himself / herself and display the authority letter issued by the Company and upon request, display his / her identity card issued by the Company. The Company will the provide customers with all the information regarding dues and shall endeavor to give sufficient notice for payment of dues.
- iii) All the members of the staff or any person authorised to represent the Company in collection or / and security repossession will adhere to the guidelines set out below:
- a. Customer would be contacted ordinarily at the place of his / her choice and in the absence of any specified place at the place of his / her residence and if unavailable at his / her residence, at the place of business / occupation.
- b. Identity and authority to represent the Company would be made known to the customer at the first instance.
- c. Customer’s privacy will be respected.
- d. Interaction with the customer shall be in a civil manner
- e. Company’ representatives shall contact the customers between 0700 hrs and 1900 hrs, unless the special circumstances of the customer’s business or occupation require otherwise.
- f. Customer’s request to avoid calls at a particular time or at a particular place shall be honored as far as possible.
- g. Time and number of calls and contents of conversation would be documented.
- h. All assistance should be given to resolve disputes or differences regarding dues in a mutually acceptable and in an orderly manner.
- i. During visits to customer’s place for dues collection, decency and decorum should be maintained.
- j. Inappropriate occasions such as bereavement in the family or such other calamitous occasions should be avoided for making calls/visits to collect dues.
VIII. COMPLAINTS AND GRIEVANCES
- a. The Company has a system and a procedure for receiving, registering and disposing of complaints and grievances in each of its offices. The grievance redressal would be monitored by the Corporate Office. The mechanism for this purpose is in accordance with the guidelines laid down by the Board.
- b. Customers would be told as to where to they can find details of the Company’s procedure for handling complaints fairly and quickly.
- c. If the customer wants to make a complaint, he/she would be told:
- I. How to do this
- II. Where a complaint can be made
- III. How a complaint should be made
- IV. When to expect a reply
- V. Whom to approach for redressal
- VI. What to do if the customer is not happy about the outcome.
- VII. The Company’s staff shall help the customer with any questions the customer has.
- d. If a complaint has been received in writing from a customer, the Company would send him/her an acknowledgement / response within a week. The acknowledgement would contain the name & designation of the official who will deal with the grievance. If the complaint is relayed over phone at HFC’s designated telephone helpdesk or customer service number, the customer shall be provided with a complaint reference number and be kept informed of the progress within a reasonable period of time.
- e. After examining the matter, the Company shall send the customer its final response or explain why it needs more time to respond and shall endeavourer to do so within six weeks of receipt of a complaint and he/she should be informed how to take his/her complaint further if he/she is still not satisfied.
The Company shall give the customer information:
- 1. In order to verify the details mentioned by him/her in the loan application by contacting him/her at his/her residence and / or on business telephone numbers and / or physically visiting his/her residence and/or business addresses through agencies appointed for this purpose, if deemed necessary by the HFC.
- 2. If the Company needs to investigate a transaction on the customer’s account and with the police/ other investigative agencies and if the Company needs to involve them.
- 3. The Company would advise the customer that if the customer acts fraudulently, he/she will be responsible for all losses on his/her account and that if the customer acts without reasonable care and this causes losses, the customer may be responsible for the same.
- 4. About the products and services provided by the Company in any one or more of the following languages: Hindi, English or the appropriate local language.
- 5. The Company will not discriminate on grounds of sex, caste and religion in the matter of lending.
- 6. The Company shall process requests for transfer of a loan account, either from the borrower or from a bank/financial institution, in the normal course.
- 7. The Company shall publicise:
- a) provide existing and new customers with a copy of the Code
- b) make this Code available on request either over the counter or by electronic communication or mail;
- c) make available this Code at every branch and on their website; and
- d) ensure that their staff are trained to provide relevant information about the Code and to put the Code into practice.
- 8. The Board has provided for a half yearly review of the compliance of the Fair Practices Code and the functioning of the grievances redressal mechanism. The consolidated report of such reviews may be submitted to the Board every half year.