Fair Code Practice

Contact Details for Grievance Collection & Redressal Mechanism (GCRM):

Mr. Lalliensung Amaw
Principal Officer
NERHOFIC Ltd.
Corporate Office
M Block Plot No: 2
Jim Plaza, LSC, Vikaspuri
New Delhi-110 018, INDIA
Email: info@nerhofic.co.in
Phone: 011-25614164/65

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Objectives & Application:

1.1 Objectives of the Code:

The Code has been adopted by the Board of North East Region Housing Finance Company Ltd.:

  1. To promote good & fair practices by setting Minimum Standards in dealing with Customers;
  2. To increase Transparency so that the Customers can have better understanding of what they can reasonably expect of the Services;
  3. To encourage Market forces, to achieve higher Operating Standards;
  4. To promote a fair & cordial relationship between Customer & NERHOFIC; &
  5. To foster confidence in Housing Finance System.

1.2 Application of the Code:

The Code applies to all the Products & Services offered by NERHOFIC by any Method, & all Offices & all Employees of NERHOFIC.

2. NERHOFIC’s Commitment to Customers:

2.1 To act fairly & reasonably in all dealings with Customers by ensuring that:

  1. The Commitments & Standards prescribed in this Code are met for all Products, Services, Procedures, & Practices.
  2. Our Products & Services meet relevant Laws & Regulations in letter & spirit.
  3. Our dealings with Customers rest on the Ethical Principles of Integrity & Transparency.
  4. Our company will disclose to the borrowers all information about fees/charge payable for processing the loan application, the amount of fees refundable if loan amount is not sanctioned/disbursed, pre-payment options and charges, if any, penalty for delayed repayment if any, conversion charges for switching loan from fixed to floating rates or vice versa, existence of any interest re-set clause and any other matter which affects the interest of the borrower. Our company will disclose ‘all in cost’ inclusive of all charges involved in processing/sanction of loan application in a transparent manner. It will also be ensured that such charges / fees are non-discriminatory.

2.2 To help Customers understand our Financial Products & Services by:

  1. Giving Customers information about our Products & Services in any of the following Languages: Hindi, English or the appropriate local Language.
  2. Ensuring that our Advertising & Promotional Literature is clear & not misleading.
  3. Ensuring that the Customers are given clear information about our Products & Services, the Terms & Conditions, & the Interest Rates / Service Charges, which apply to them.
  4. Giving Customers information on what are the benefits to them, how they can avail of the benefits, what are their financial Implications & whom they can contact for addressing their queries & how.

2.3 To help Customers to use the Products & Services by:

  1. Providing them regular & appropriate updates.
  2. Keeping them informed about changes in the Interest Rates, Charges, or Terms & Conditions.

2.4 To deal quickly & sympathetically with things that goes wrong by:

  1. Correcting mistakes promptly & canceling any Charges applied due to our mistake.
  2. Handling Customers’ Complaints promptly.
  3. Telling Customers how to take their Complaint forward if they are still not satisfied.
  4. Providing suitable alternative avenues to alleviate problems arising out of Technological failures.

2.5 To treat all Personal Information of Customers as private & Confidential:

We shall treat all Personal Information as private & Confidential subject to the matters mentioned in paragraph number 5 below.

2.6 To publicize the Code we shall:

  1. provide existing & new Customers with a copy of the Code;
  2. make this Code available on request either over the Counter or by Electronic Communication or Mail;
  3. make available this Code at each of our Offices &
  4. Ensure that our Staff is trained to provide relevant information about the Code & to put the Code into practice.

2.7 To adopt & practice a Non-Discrimination Policy:

We shall not discriminate on the basis of Age, Race, Caste, Gender, Marital Status, Religion, or Disability. However, the restrictions on Age, as mentioned in our Loan Products, shall continue to apply.

3. ADVERTISING, MARKETING & SALES:

3.1 We shall:

  1. Ensure that all Advertising & Promotional Material is clear, & not misleading.
  1. In any Advertising in any Media & Promotional Literature that draws attention to a Service or product & includes a reference to an Interest Rate, we shall also indicate whether other Fees & Charges will apply & that full details of the relevant Terms & Conditions are available on request.
  2. If we avail of the Services of Third Parties for providing Support Services, we shall require that such Third Parties handle Customer’s Personal Information (if any available to such Third Parties) with the same degree of Confidentiality & Security as we would.
  3. We may, from time to time, communicate to Customers various features of the Products availed by them. Information about our 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 either by Mail or on the Customer Service Number.
  4. Prescribe a Code of Conduct for our DSAs / HLAs / CRAs, whose Services are availed to Market Products which, amongst other matters, require them to identify themselves when they approach the Customer for selling our Products.
  5. In the event of receipt of any Complaint from the Customer that our Representative / Courier or DSA / HLA / CRA has engaged in any improper conduct or acted in violation of this Code, appropriate steps shall be initiated to investigate & to handle the Complaint & to make good the loss.

4. LOANS

4.1 We should provide Information on Interest Rates, Common Fees, & Charges through any one or more of the following:

  1. Putting up Notices in all our Offices;
  2. Through Telephone or Help lines;
  3. Through designated Staff / Helpdesk; or
  4. Providing Tariff Schedule.

4.2 In respect of prospective Customers, we shall:

  1. provide clear information explaining the key features of our Products & Services that the Customer is interested in;
  2. provide information on any type of Product & Service offered, that may suit the Customer’s needs;
  1. tell the Customer about the various means through which Products & Services are offered & tell them how to find out more about them;
  2. tell the Customer what information is needed from him / her to prove his / her Identity & Address, for complying with Legal,
  3. Regulatory & Internal Policy requirements.

4.3 To those who have become Customers, we shall:

  1. provide more information on the key features of the Products, including applicable Interest Rates / Fees & Charges;
  2. provide extra information on his / her Rights & Responsibilities for availing loan facilities;
  3. Automatically register the Customer’s Name under a ‘Do Not Call’ Service. We will not inform / extend through Telephone Calls /SMSs / E-mails any new Product / Service unless & until the Customer informs us in writing his / her consent to avail of this Information / Service.

4.4 Interest Rates:

At the time of Counseling / Disbursement, we shall inform the Customer regarding:

  1. The Interest Rates which shall apply to his / her loan account;
  2. When Interest charged on his / her Loan Accounts;
  3. How Interest is applied to his / her Account & method of Calculation of Interest.

4.5 Changes in Interest Rates:

When the Interest Rates are reviewed, we shall inform all the Customers being affected due to the Review.

4.6 Fees & Charges:

a. We shall display in our Offices:

  • Notice about the Tariff Schedule.
  • Customers can ask for Tariff Schedule;
  • List of Services which are rendered free of Charge.

b. We shall provide our Customers all details (in our Tariff Schedule) of any Charges applicable to the Products & Services chosen by them.

c. We shall provide our Customers information about the Penalties liable to be levied in case of non-observance / violation of any of the Terms & Conditions governing the Products / Services chosen by them.

4.7 Changes in Fees & Charges:

If we increase any of these Charges or introduce a New Charge, we will notify it 1 Month prior to the Revised Charges being levied /becoming effective.

4.8 Terms & Conditions:

  1. A Customer availing a Product / Service for the first time shall be advised regarding the relevant Terms & Conditions for the Product / Service he / she has asked us to provide.
  2. The Terms & Conditions shall be fair & will set out respective Rights, and Liabilities & Obligations clearly, & as far as possible, in plain & simple Language.

4.9 Changes to Terms & Conditions:

a. Customers would be informed regarding changes to Terms & Conditions through any one or more of the following channels:

  • Personal Intimation
  • Notice Board at each of our Offices
  • Internet, including E-mail & Website.
  • Newspaper

b. Normally, changes shall be made with Prospective Effect giving due Notice.

c. If any change is made without Notice, the change shall be notified within 30 days. If such change is to the disadvantage of the Customer, he / she may within 60 days & without Notice close his / her Account or switch it without having to pay any extra Charges or Interest.

d. Major change or a lot of minor changes in any one year shall be informed to the Customer on request, & the Customer shall be provided a copy of the new Terms & Conditions or a summary of the changes.

4.10 Guarantors

When a person is considering being a guarantor to a loan, he/she should be informed about

  1. his/her liability as guarantor;
  2. the amount of liability he/she will be committing him/herself to the company;
  3. circumstances in which HFC will call on him/her to pay up his/her liability;
  4. whether HFC has recourse to his/her other monies in the company if he/she fail to pay up as a guarantor;
  5. whether his/her liabilities as a guarantor are limited to a specific quantum or are they unlimited; and
  6. Time and circumstances in which his/her liabilities as a guarantor will be discharged as also the manner in which HFC will notify him/her about this.

We 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.

5. PRIVACY & CONFIDENTIALITY:

5.1 All Personal Information of Customers shall be treated as private & confidential [even when the Customers are no longer Customers], and shall be guided by the following Principles & Policies. We shall not reveal Information or Data relating to Customer Accounts, whether provided by the Customers or otherwise, to anyone, including other Companies / Entities in our Group, other than in the following exceptional cases:

  1. If the Information is to be given by Law.
  2. If there is a duty towards the Public to reveal the Information.
  3. If our interests require us to give the Information (for example, to prevent Fraud) but it should not be used as a reason for giving Information about Customer or Customer’s Accounts [including Customer Name & Address] to anyone else, including other Companies in the Group, for Marketing purposes.
  4. If the Customer asks us to reveal the information, or with the Customer’s Permission.
  5. If we are asked to give a reference about a Customer, we shall obtain his / her written permission before giving it.
  6. The Customer shall be informed the extent of his / her Rights under the existing Legal Framework for accessing the Personal Records that we hold about him / her.
  7. We shall not use Customer’s Personal Information for marketing purposes by anyone including ourselves unless the Customer specifically authorizes us to do so.

5.2 Credit Reference Agencies:

  1. At the time of counseling itself, we shall inform the Customers when we shall pass his / her Account details to Credit Reference Agencies & the checks we shall make with them.
  2. We may give information to Credit Reference Agencies about the Personal Debts the Customer owes us if:
  • The Customer has fallen behind with his / her Payments;
  • The Amount owed is not in dispute; &
  • The Customer has not made proposals that we are satisfied with for repaying his / her Debt, following our formal demand.
  1. In these cases, we shall intimate the Customer in writing that we plan to give Information about the Debts the Customer owes us to Credit Reference Agencies. At the same time, we shall explain to the Customer the role of Credit Reference Agencies & the effect the Information they provide can have on Customer’s ability to get Credit.
  2. We may give Credit Reference Agencies other Information about the Customer’s Account if the Customer has given us his / her Permission to do so.
  3. A copy of the Information given to the Credit Reference Agencies shall be provided by us to a Customer, if so demanded.

6. COLLECTION OF DUES:

6.1 Whenever loans are given, we shall explain to the Customer the Repayment Process by way of Amount, Tenure & 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 / her Notice or by making Personal Visits & / or Repossession of Security, if any.

6.2 Our Collection Policy is built on Courtesy, Fair Treatment & Persuasion. We believe in fostering Customer confidence & long-term relationship. Our Staff or any person authorized to represent us in Collection of Dues or / & Security Repossession shall identify himself /herself & display the Authority Letter issued by Office & upon request, display his / her Identity Card issued by the Company or under Authority of the Company. We shall provide Customers with all the information regarding Dues & shall endeavor to give sufficient Notice for Payment of Dues.

6.3 All the members of the Staff or any person authorized to represent us in Collection & / or Security Repossession should follow the Guidelines set out below:

  1. Customer would be contacted ordinarily at the place of his / her choice & in the absence of any specified place at the place of his/ her Residence & if unavailable at his / her Residence, at the place of Business / Occupation.
  2. Identity & Authority to represent the Company shall be made known to the Customer at the first instance.
  3. Customer’s Privacy should be respected.
  4. Interaction with the Customer shall be in a civil manner.
  5. Our representatives shall contact the Customers between 0700 hrs & 1900 hrs, unless the special circumstances of the Customer’s Business or Occupation require otherwise.
  6. Customer’s request to avoid Calls at a particular time or at a particular place shall be honored, as far as possible.
  7. Time & Number of Calls & Contents of Conversation would be documented.
  8. All assistance should be given to resolve disputes or differences regarding dues in a mutually acceptable & in an orderly manner.
  9. During Visits to Customer’s place for Dues Collection, Decency & Decorum shall be maintained.
  10. Inappropriate occasions such as bereavement in the Family or such other calamitous occasions should be avoided for making Calls / Visits to collect Dues.

7. COMPLAINTS & GRIEVANCES:

7.1 Internal Procedures:

  1. If the Customer wants to make a Complaint, he / she will be told:
    • How to do this?
    • Where a Complaint can be made?
    • How a Complaint should be made?
    • When to expect a Reply?
    • Whom to approach for Redressal?
    • What to do if the Customer is not happy about the outcome?
    • Our Staff shall help the Customer with any questions the Customer has.
  2. Customer will be told where to find details of our Procedure for handling Complaints fairly & quickly.
  3. If a Complaint has been received in writing from a Customer, we must send him / her Acknowledgement / Response within a week. If the Complaint is relayed over Phone at our designated Telephone Helpdesk or Customer Service Number, the Customer shall be provided with a Complaint Reference Number & be kept informed of the progress within a reasonable period of time.
  4. After examining the matter, we shall send the Customer our Final Response or explain why it needs more time to respond & shall endeavor to do so within 6 weeks of receipt of a Complaint & he / she should be informed how to take his / her Complaint further if he / she are still not satisfied.

8.GENERALwe shall give the customer information:

  1. We 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.
  2. The customer is informed to co-operate if we needs to investigate a transaction on the customer’s account and with the police/ other investigative agencies, if we needs to involve them.
  3. We 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. HFCs shall process requests for transfer of a loan account, either from the borrower or from a bank/financial institution, in the normal course.
  5. The Board of Directors of our company provide for periodical review 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.