Fair Practice Code
This document provides details of the practices which need to be followed by the Company to ensure fair and transparent dealings with its customers who approach it for obtaining a home loan and for transactions with customers after the loan has been granted. This code will enable employees to provide better customer service and maintain transparency in business dealings with its customers. The Code has the following key elements.
Objectives of the Code
- to promote good and fair practices by setting minimum standards in dealing with customers;
- to increase transparency so that the customer can have a better understanding of what he/she can reasonably expect of the services;
- to encourage market forces, through competition, to achieve higher operating standards;
- to promote a fair and cordial relationship between the customer and the Company;
- to foster confidence in the housing finance system.
Application of the Code
This code shall apply to all employees of the company and other persons authorized to represent it in the course of its business with respect to all products and services. Copy of the fair practice code shall be displayed at all the offices/branches of the Company. A copy of FPC shall also be displayed on the website of the company.
Company shall adhere to this code to act fairly and reasonably in all dealings, on the ethical principle of integrity and transparency, to meet the standard practices prevalent in the housing finance industry.
- The Company will provide clear and transparent information to customers so as to enable them to understand:
- Terms and conditions of the products and services offered including the interest rate and service charges.
- Benefits available to customers
- Products and services of the company will meet relevant laws and regulations in both letter and in spirit.
- The Company will act quickly in correcting the mistakes and attend to complaints lodged by its customers in light of objectives of this code.
- The Company shall not discriminate amongst its prospective/existing customers on the basis of age, race, caste, gender, marital status, religion or disability. However the restrictions, if any, as mentioned in the housing loan products, shall continue to apply.
- A copy of the code may be provided on request to any prospective or existing customer.
Disclosure and Transparency
Company would provide information on interest rates, common fees and charges through:
- Putting up notices in branches;
- Providing tariff schedule as and when requested.
- Through the company’s website
- Through designated staff
The Company shall collect personal information that it believes to be relevant and required to understand the customer’s profiles and conduct its business. The Company shall treat all personal information of customers as private and confidential and shall not divulge any information to a third person unless required by any law or Government authorities including Regulators or Credit agencies or where the sharing of information is permitted by the customer. If company shall avail services of any third party for providing support services, Company shall require that such third parties handle customers’ personal information with the same degree of confidentiality.
Advertising, Marketing And Sales
- The Company shall ensure that all advertising and promotional material is clear, and not misleading. The code shall apply to Sales Associates/ representative of the company in dealing with customers to the extent it is applicable.
- The Company may, from time to time, communicate to customers various features of their products availed by them. Information about their other products or promotional offers in respect of products / services may be conveyed to customers only if he / she has given his / her consent to receive such information / service.
- In the event of receipt of any complaint from the customer that representative/ DSA of the company has engaged in any improper conduct or acted in violation of this Code, appropriate steps shall be initiated to investigate and to handle the complaint and to make good the loss.
- Whenever the services of any third party is used for providing support services, the Company shall ensure that such third party handles customer’s personal information ( if any available to such third parties) with the same degree of confidentiality and security as the Company would.
- Company would prescribe a code of conduct to the Direct Selling Agencies ( DSAa) whose services Company may avail to market products/services which amongst other matters require them to identify themselves when they approach the customer for selling products personally or through phone.
- The loan agreement discloses the rate of interest charged from customer as also the other charges pertaining to the loan like processing fee, cheque bounce charges etc.
- Acknowledgement will be given for receipt of all loan applications.
- The Company would verify the loan applications within a reasonable period of time
- Normally all particulars required for processing the Loan Application will be collected by the Company at the time of application. In case it needs any additional information, the customer will be informed to provide the same.
- The Company will convey in writing to the borrower by means of sanction letter or otherwise, 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 its record.
- In case of rejection of loan sanction/disbursement, the decision will be communicated to the borrower in writing. The reason for rejection in the opinion of the Company after due consideration, which has led to rejection of the loan applications would also be communicated in writing. In case the proposal does not meet the internal product parameters of the Company, the borrower would be intimated accordingly.
- Before taking a decision to recall/accelerate payment or performance under the agreement or seeking additional securities, the Company shall give notice to the borrower(s) in consonance with the Loan Agreement.
- Borrower shall be entitled to a copy of the Loan Agreement along with a copy each of all enclosures quoted in the Loan Agreement at the time of sanction / disbursement of loans.
- Company at its discretion shall process requests for transfer of a loan account, either from the borrower or from a bank/financial institution, in the normal course.
- The Company shall give notice 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 Company will ensure that changes in interest rates and charges are effected only prospectively. If such change is to the disadvantage of the customer, he/she may within 60 days and without notice close his / her account or switch it.
- The Company shall release all securities on repayment of all dues or on realization of the outstanding amount of housing finance and 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 considered to be a guarantor to a loan, the Company shall inform him/her the following under acknowledgement:
- Letter/ Deed of Guarantee stating the terms of liability as guarantor.
- The Company shall keep him/her informed of any default in the servicing of the loan by the borrower to whom he/she stands as a guarantor.
- The Company shall keep him/her informed of any material adverse change/s in the financial position of the borrower whom he/she stands as a guarantor.
Credit Bureau/ Reference agencies
The Company may give information to Credit Bureau/ Reference agencies about the personal debts, the customer owes to it if:
- The customer has fallen behind with his / her payments;
- Legal proceedings have been initiated against the customer to recover the dues.
- Debts settled through legal recourses against the customer.
- It is mandated by law to provide the information of all such customers to such agencies. A clause to this effect has been included in the Loan Agreement seeking the customer’s consent to share information on his loan with Credit Bureaus approved by NHB.
- At the same time, Company 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.
- Company may give credit reference agencies other information about the customer’s account based on the consent given.
- A copy of the information given to the credit reference agencies shall be provided by the Company to a customer, if so demanded.
Collection of Dues
- Whenever home loans or small business loans are given, the Company shall explain to the customer the repayment process by way of amount, tenure and periodicity of repayment. However if the customer does not adhere to repayment schedule, a defined process in accordance with the laws of the land and the customer’s contract with the Company will be followed for recovery of dues. The process will involve reminding the customer by sending him / her a notice or by making personal visits and / or repossession of security if any.
- The Company staff or any person authorized shall identify himself through ID card or by any other medium while representing the company for collection of dues or / and security repossession.
- The Company shall provide customers with all the information regarding dues and shall endeavour to give sufficient notice for payment of dues.
- All assistance shall be given to resolve disputes or differences regarding dues in a mutually acceptable and in an orderly manner.
- During visits to customer's place for dues collection, decency and decorum shall be maintained.
- In the matter of recovery of loans, the Company would not resort to undue harassment or use of force.
- 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.
- Company’s representatives shall contact the customers between 0700 hrs and 1900hrs, unless the special circumstances of the customer’s business or occupation require otherwise.
- Customer’s request to avoid calls at a particular time or at a particular place shall be honoured as fas as possible.
- Inappropriate occasions such as bereavement in the family or such other calamitous occasions, if they come to the knowledge of the Company, shall be avoided for making calls/visits to collect dues unless the same is required for meeting legal compliance.
Complaints and Grievances
- The Company would strive for customer satisfaction within the framework of law, adopted policies and procedures.
- In case of any grievance, the customer may approach the In-Charge of the business location where he / she had his / her account and register the complaint in the 'Complaint Register' available with the In-Charge. On registering the complaint, the customer should obtain complaint number and date for future reference.
- All offices/branches shall display the office address, e mail id, phone no etc where a complaint can be made and the authority to whom the complaint can be made.
- Company shall endeavour to resolve the complaint within 6 weeks of receipt of complaint.
- In case the response is unsatisfactory or no response is received, the complaint should be escalated to the following –
- If a complaint has been received in writing from a customer, the Company shall endeavourer to send him/her an acknowledgment/response within a week.
- If the complaint is relayed over phone, the customer shall be provided with a complaint reference number and be kept informed of the progress within a reasonable period of time.
- Any dispute arising out of the decisions of the Company’s functionaries shall be disposed by Head Customer Serives
The Customer Service Head
Shubham Housing Development Finance Company Ltd.
425, Jwala Mill Road Udyog Vihar Phase IV
Privacy and Confidentiality
All personal information of the customers shall be treated as private and confidential (even when the customers are no longer customers), and shall be guided by the following principles and policies. Company shall not reveal information or data relating to customer accounts, whether provided by the customers or otherwise, to anyone, other than in the following exceptional cases.
- If the information is to be given by law or by the direction of the regulator.
- If there is a duty towards the public to reveal the information
- If the Company’s interest require them to give the information ( for example, to prevent fraud) but the same shall not be used as a reason for giving information about customer or customer accounts to anyone else.
- If the customer asks the Company to reveal the information or with the customer’s permission.
- The customer shall be informed the extent of his/her rights under the existing legal framework for accessing the personal records that holds about him/her.
- The Company shall use the personal information only to the extent authorised by the customer under the loan agreement.
- The Company may verify the details mentioned by the customer in the home finance 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.
- The customer will be informed to co-operate if the Company needs to investigate a transaction on the customer’s account and with the police/other investigative agencies. 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.
- The Company will be reviewed annually for Compliances to the Fair Practices Code and the functioning of the grievances redressal mechanism at the various level of management. A consolidated report of such reviews may be submitted to the Board.