This code is proposed to be implemented by Home First Finance Company India Private Limited (Home First) pursuant to the guidelines issued by the National Housing Bank on Fair Practices Code for Housing Finance Companies.
1. Objectives and Application
- Promote fair practices by setting minimum standards in dealing with customers
- Increase transparency to ensure that customer has a better understanding of services being provided
- Achieve higher operating standards by encouraging market forces and fair competition
- Promote a fair and cordial relationship between customers and housing finance companies
- Foster confidence in the housing finance system.
1.2 Application of the code
All parts of this code will apply to all products and services offered by HFFC through employees or other channels, through any mode.
2. Home First to act fairly and in a transparent manner
HFFC will act fairly in all dealings with customers by ensuring that:
- All information about fees/charges for processing a loan application, refund applicable in case the loan is not sanctioned or disbursed, pre-payment options and charges, penalty for delayed payment, charges for switching from fixed to floating rate or vice-versa and information regarding re-set of interest rate as per loan agreement, will be disclosed in a transparent manner to the customers. HFFC will not discriminate on grounds of sex, caste and religion with respect to the above charges.
- All commitments and standards in this code are adhered to.
- All products and services meet relevant laws and regulations in letter and spirit.
- Dealings with customers are conducted on ethical principles of integrity and transparency.
3. Advertising, marketing, and sales
HFFC will ensure that:
- Relevant information is provided to customers in English, Hindi or their local language.
- Advertisements and promotional literature is clear and unambiguous.
- Customers are informed about interest rates and other charges without any ambiguity, through notices in branches, telephone helplines, or on the company’s website.
- Confidentiality is maintained with respect to customer information. If third parties are involved in handling customer information, they will ensure the same level of confidentiality.
- Customers are informed about the features of their product from time to time. Information about other products or promotional offers may be conveyed to customers, only if the customer has given their consent through an email, website, or customer service number.
- A code of conduct will be prescribed for Direct Selling Agents (DSAs).
- Any complaints received from customers with respect to any representative, courier, or DSA of HFFC will be dealt with in a satisfactory manner.
4.1 (i) Applications for loans and processing
- At the time of sourcing a loan, prospective customers will be provided all necessary information along with the application form to enable the customer to take an informed decision.
- All loan applications will be provided an acknowledgement. The timeframe for processing the loan will be indicated in the acknowledgement.
4.1 (ii) Loan appraisal and terms and conditions
- Home First will convey in writing to the customer, the sanction of the loan along with the terms and conditions
- Home First will provide to the customer on request, the loan documents and other enclosures executed by the customer
4.1 (iii) Communication of rejection of loan application
- If Home First is unable to provide a loan to any customer, it shall communicate in writing the reason for the same.
4.1 (iv) Disbursement of loans including changes in terms and conditions
- Disbursement should be made in accordance with the disbursement schedule given in the Loan Agreement/ Sanction Letter
- Home First will 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. Changes in interest rates and charges will be 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 without having to pay any extra charges or interest.
- Decision to recall / accelerate payment or performance under the agreement or seeking additional securities, will be in consonance with the loan agreement.
- Home First 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 Home First 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 Home First is entitled to retain the securities till the relevant claim is settled /paid.
When a person is considering being a guarantor to a loan, he will be informed about:
- His liability as guarantor
- The amount of liability he will be committing to the company
- Circumstances in which Home First will call on him to pay up the liability
- Whether Home First has recourse to his other monies in the company if he fail to pay up as a guarantor
- Whether his liabilities as a guarantor are limited to a specific quantum or are they unlimited
- In case a default is made in making repayment by the Customer, the Home First will be able to proceed against the guarantor even without exhausting the remedies against the Customer (principal debtor). If the said guarantor refuses to comply with the demand made by Home First, despite having sufficient means to make payment of the dues, such guarantor would also be treated as a wilful defaulter.
- Time and circumstances in which his liabilities as a guarantor will be discharged as also the manner in which Home First will notify him about this
Home First shall keep him informed of any material adverse change/s in the financial position of the borrower to whom he/she stands as a guarantor.
4.3 Privacy and confidentiality
Home First will keep personal information of customers confidential and will not reveal it to anyone unless:
- Such information is required to be given by law
- There is a duty towards the public to reveal the information
- If Home First’s interests require them to give the information
- Customer has given his/her consent for the same
4.4 Credit reference agencies
- When a customer opens an account, Home First shall inform him when they may pass his account details to credit reference agencies
- Home First may give information to credit reference agencies if:
- The customer has fallen behind with his payments
- The amount owed is not in dispute
- The customer has not made proposals for repaying his debts that are satisfactory
- In these cases, Home First shall intimate the customer in writing that they plan to give information about the debts the customer owes them to credit reference agencies. At the same time, Home First 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.
- Home First may give credit reference agencies other information about the customer’s account if the customer has given them his permission to do so.
- A copy of the information given to the credit reference agencies shall be provided by Home First to a customer, if so demanded.
4.5 Collection of dues
- Home First will 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 shall be followed for recovery of dues. The process will involve reminding the customer by sending him a notice or by making personal visits and / or repossession of security if any.
- Home First collection policy will be built on courtesy, fair treatment and persuasion. Home First staff or any person authorized to represent them in collection of dues or / and security repossession shall identify himself and display the authority letter issued and upon request, display his identity card.
- Personnel involved in recovery process will follow the enclosed guidelines:
- Customers will be contacted at a place of their choice, the residence or office in that order of priority
- Personnel contacting the customer for recovery will display/declare his identity at the first instance.
- Interactions with customers will be civil, with respect for their privacy. Contact timings will be between 0700 and 1900 hours unless special circumstances require otherwise. Contact time and interaction will be documented.
- Assistance will be provided to resolve disputes in a mutually acceptable manner.
- Inappropriate occasions such as bereavement in the family or such other calamitous occasions will be avoided for making calls/visits to collect dues.
4.6 Complaints and grievances
- Home First will ensure that customers are made aware of the process for recording a complaint.
- Written complaints will be acknowledged within a week. Complaints received over phone will be given a reference number and responded to within a reasonable timeframe.
- Final response to complaints will be provided within 6 weeks of receipt unless requiring additional time to resolve, in which case the customer will be kept informed of the same.
Complaints can be made through following channels:
Toll-free number: 1800 3000 8425
Letter: 511, Acme Plaza, Andheri Kurla Road, Andheri East, Mumbai – 400059
- Home First shall process requests for transfer of a loan account, either from the borrower or from a bank/financial institution, in the normal course.
- Home First will not discriminate on grounds of sex, caste and religion in the matter of lending. However, this does not preclude Home First from instituting or participating in schemes framed for different sections of the society.
- Home First will advise the customer that if the customer acts fraudulently, he will be responsible for all losses caused by this.
- The customer will be informed to co-operate if Home First needs to investigate a transaction on the customer’s account and with the police/ other investigative agencies, if required
- Home First shall verify the details mentioned by the customer in the loan application by contacting him at his residence or business telephone numbers and/or through a visit at his residence or business address through agencies appointed for this purpose if required.
- To publicise this code Home First shall:
- Provide existing and new customers with a copy of the Code
- Make this Code available on request either over the counter or by electronic communication or mail
- Make available this Code at every branch and on the website
- Ensure that staff are trained to provide relevant information about the Code and to put the Code into practice.
- The Board of Directors will provide for periodical reviews of the compliance of the Fair Practices Code and the functioning of the grievances redressal mechanism at various levels of management. A consolidated report of such reviews may be submitted to the Board at regular intervals, as may be prescribed by it.