Fair Practice Code

Preamble

The Fair Practice Code is being formulated as per the directives issued by National Housing Bank (NHB)

Objective

The objectives of the code are

   To promote good and fair practices by setting standards in customer dealing;

   To provide transparency in systems, procedures, policies, terms & conditions so that the customers can have a better understanding of the services expected;

   To encourage market forces through competition to achieve higher operating standards;

   To promote a fair and cordial relationship between the customer and ALTUM CREDO; and

   To foster confidence in the housing finance system.

Application of the code

   The Code would be applicable to all persons offering the Products and Services of ALTUM CREDO as an employee or otherwise in any manner and/or by any mode.

   The Code is applicable under a normal operating environment except in the event of any force majeure.

   The Code is based on ethical principles of integrity and transparency and all actions and dealings will follow the spirit of the Code.

Commitment to customers

   ALTUM CREDO will to the best of its ability, act fairly and reasonably in all dealings with the customer, meeting ethical principles of integrity and transparency and always following the relevant laws and regulations in letter and in spirit.

   The company will make sure that all its products and services are explained to its customers fully and ensure complete understanding.

   ALTUM CREDO will make every effort to ensure that the terms are communicated clearly in vernacular language to customers so that it is not misleading.

   Its sales officers and branch managers will be the first point of contact for all the queries of the customer and contact information of the branches will also be posted on the company’s website

   The sales officers and branch managers will help customers understand the terms and conditions, applicable interest rate/service charges, and also the benefits that can be availed along with their financial implications.

   The company will handle customer complaints promptly and help its customers in taking complaints forward if not satisfied.

   Every customer would be provided with the details of contact persons, in case of a grievance and complaint. This would be prominently displayed at the branches and on the company’s website.

   The company will provide a copy of this Code, at request, to the customer. The Code will also be displayed and made available on its website and at its head and branches.

Advertising, marketing and sales

ALTUM CREDO will ensure that

   All advertising and promotional material is clear, and not misleading.

   In any advertising in any media and promotional literature that draws attention to a service or product and includes a reference to an interest rate, ALTUM CREDO will also indicate whether other fees and charges will apply and that full details of the relevant terms and conditions are available on request.

   ALTUM CREDO will ensure proper communication on interest rates, processing fees, and charges to the prospective customers by putting up Notices in its branches; through telephone or help lines; on the company’s website; through designated staff; or by providing a service guide or tariff schedule.

   If ALTUM CREDO avails of the services of third parties for providing support services, like insurance, the company will inform and require them to handle customer’s personal information (if any made available to such third parties) with the same degree of confidentiality and security as the company would.

   The company may, from time to time, communicate to customers about additional products and other features of their products availed by them. Information about its other products or promotional offers in respect of products/services may be conveyed to customers only if he has given their consent to receive such information/service either by mail or by registering for the same on the website or on the customer service number.

   In the event of receipt of any complaint from the customer that the Company’s representatives have engaged in any improper conduct or acted in violation of this Code appropriate steps will be initiated to investigate and handle the complaint and to make good the loss.

Applications for loans and their processing

   ALTUM CREDO will ensure that all required information including a list of documents required to be submitted would be provided along with the Loan application forms so that a meaningful comparison with the terms and conditions offered by other HFCs can be made and an informed decision can be taken by the borrower.

   It will have a system of giving an acknowledgment for receipt of all loan applications.

Loan appraisal and terms/conditions

   Normally all particulars required for processing the loan application will be collected by ALTUM CREDO at the time of application or at the time of personal verification as conducted by the Company. In case of any additional information, the customer will be told that he would be contacted immediately again.

   ALTUM CREDO will convey in writing to the borrower by means of a sanction letter or otherwise, the amount of loan sanctioned along with all terms and conditions including rate of interest, and EMI Structure, and keep the written acceptance of these terms and conditions by the borrower on its record.

   ALTUM CREDO will furnish a copy of the loan agreement along with an acknowledgment of the list of documents provided to every borrower after the disbursement of loans.

Communication of rejection of loan application

If ALTUM CREDO cannot provide the loan to the customer, it will communicate in writing that the loan has been declined and to the extent possible explain to the customers the reasons for the decline.

Disbursement of loans

   Disbursement will be made in accordance with the disbursement schedule agreed by the customer or per the Agreement for Sale which covers terms of payment by the customer to the builder and based on an inspection by ALTUM CREDO on the completion of work (in the case of under-construction properties) which would need to be confirmed and accepted by ALTUM CREDO.

   ALTUM CREDO will give notice to the borrower of any change in the terms and conditions Including, interest rates, processing fees, prepayment charges, other applicable fees/ charges, etc. ALTUM CREDO will also 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 be allowed with or without any notice to close his account without having to pay extra charges or interest.

   The company would be free to take any decision to request the customer to close or accelerate payment or seek additional securities to the loan, which will be in consonance with the loan agreement

   ALTUM CREDO will release all securities on repayment of all dues or on the realization of the outstanding amount of loan subject to any legitimate right or lien for any other claim the company may have against the borrower. If such right of set-off is to be exercised, the borrower will 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.

Guarantors

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

   His/her liability as guarantor;

   The amount of liability he will be committing himself/herself to the company;

   Circumstances in which ALTUM CREDO will call on him/her to pay up his liability;

   Whether ALTUM CREDO has recourse to his/her other monies in the company if he/she fails to pay up as a guarantor;

   Whether his/her liabilities as a guarantor are limited to a specific quantum or whether unlimited;

   Time and circumstances in which his/her liabilities as a guarantor will be discharged as also the manner in which ALTUM CREDO will notify him/her about this.

   ALTUM CREDO will keep him/her informed of any default on the loan by the borrower to whom he/she stands as a guarantor.

In case the guarantor refuses to comply with the demand made by the ALTUM CREDO, despite having sufficient means to make payment of the dues, such guarantor would also be treated as a wilful defaulter.

Privacy and confidentiality

All personal information of 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. ALTUM CREDO shall 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

   If the information is to be given by law;

   If there is a duty towards the public to reveal the information;

   If the Company’s interests require them to give the information (for example, to prevent fraud but it will not be used as a reason for giving information about customer or customer accounts (including customer name and address) to anyone else, including other companies in the group, for marketing purposes;

   If the customer asks ALTUM CREDO to reveal the information, or with the customer’s permission;

   If ALTUM CREDO is asked to give a reference about customers, it will obtain his written permission before giving it;

   The customer will be informed of the extent of his/her rights under the existing legal framework for accessing the personal records that ALTUM CREDO holds about him/her;

   ALTUM CREDO will not use the customer’s personal information for marketing purposes by anyone including ALTUM CREDO unless the customer specifically authorizes the company to do so.

Credit reference agencies

   When a customer opens an account, ALTUM CREDO will inform him that it will pass his account details to credit reference agencies and ALTUM CREDO will make checks with them.

   The Company may give information to credit reference agencies about the personal debts the customer owes them if:

  1. The customer has fallen behind with his/her payments;
  2. The amount owed is in dispute; and
  3. The customer has not made proposals that ALTUM CREDO is satisfied with, for repaying his debt, following ALTUM CREDO’s formal demand.
  4. ALTUM CREDO will give credit reference agencies other information about the customer’s account if the customer has given them his permission to do so.
  5. A copy of the information given to the credit reference agencies will be provided by ALTUM CREDO to a customer if so demanded.
Collection of dues

   Whenever loans are given, ALTUM CREDO will explain to the customer the repayment process by way of amount, tenure, and periodicity of repayment. The Company will also make efforts to remind the customers about their repayments every month, days before it falls due.

   However, if the customer does not adhere to the repayment schedule, a defined process in accordance with the laws of the land will be followed for recovery of dues. The process will involve reminding the customer by sending him notice or by making personal visits and/or repossession of security if any.

   Staff or any person authorized to represent it in the collection of dues and/or security repossession will identify himself and display the authority letter issued by ALTUM CREDO and upon request, display his identity card issued by ALTUM CREDO or under the authority of the company. They will provide customers with all the information regarding dues and will endeavor to give sufficient notice for payment of dues.

   All the members of the staff or any person authorized to represent ALTUM CREDO in the collection and/or security repossession will follow the guidelines set out below:

  1. The 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.
  2. Identity and authority to represent the HFC should be made known to the customer at the first instance.
  3. Customer privacy should be respected.
  4. Interaction with the customer shall be in a civil manner
  5. ALTUM CREDOs’ representatives shall contact the customers between 09:00 hrs and 19:00 hrs unless the special circumstances of the customer’s business or occupation require otherwise.
  6. A customer’s request to avoid calls at a particular time or at a particular place will be honored as far as possible unless ALTUM CREDO has reason to believe that the customer is avoiding meeting the ALTUM CREDO representative.
  7. Time and number of calls and contents of conversation would be documented.
  8. All assistance will be given to resolve disputes or differences regarding dues in a mutually acceptable and orderly manner.
  9. Inappropriate occasions such as bereavement in the family or other calamitous occasions will be avoided for making calls/visits to collect dues.
Bribery & corruption:

   Altum Credo does not condone any form of bribery or corruption. No Altum Credo employee or associated persons have the authority to act contrary to provisions of this Policy.

Complaints and grievances

ALTUM CREDO will make available a Compliant register at each of its branches and offices for the customers to lodge and/or submit their complaints or grievances if any. Alternatively, customers can contact Company at 020-27293709 or email us at customercare@altumcredo.com or write to us at:

Head – Collections
Altum Credo Home Finance Pvt Ltd.
CTS No. 1074/1, Plot No. 426/1,
Gokhale Road, Model Colony, Shivajinagar,
Pune – 411 016

If a complaint has been received in writing from a customer, ALTUM CREDO will endeavor to send an acknowledgment / a response within a week. The acknowledgment will contain the name & designation of the official who will deal with the grievance. If the complaint is relayed over the phone at ALTUM CREDO’s number, the customer will be provided with a complaint reference number and be kept informed of the progress within a reasonable period of time.
After examining the matter, ALTUM CREDO will send the customer its final response or explain why it needs more time to respond and will endeavor to do so within Fifteen days of receipt of a complaint and he will be informed how to take his complaint further if he is still not satisfied.