Altum Credo Home Finance Private Limited (“ACHFPL” or “the Company”) has adopted the Fair Practices Code (‘the Code’) to provide for transparency in its transactions with the customers, present as well the prospective. ACHFPL, through the Code, intends to extend protection to its customers by explaining how the Company and its representatives are expected to deal with them during day-to-day operations. The Code has been prepared based on the Master Direction – Non-Banking Financial Company – Housing Finance Company (Reserve Bank) Directions, 2021.
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 ACHFPL; and
To foster confidence in the housing finance system.
Application of the code
The Code applies to all the products and services offered by ACHFPL or Digital Lending Platforms (self-owned and / or under an outsourcing arrangement), whether over the phone, across the counter, on the internet or by any other means. It shall also apply to all the employees of ACHFPL.
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
ACHFPL 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.
ACHFPL will make every effort to ensure that the terms are communicated clearly in vernacular language to customers so that it is not misleading.
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
ACHFPL 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, ACHFPL will also indicate whether other fees and charges will apply and that full details of the relevant terms and conditions are available on request.
ACHFPL 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 ACHFPL 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.
Prescribe a Code of Conduct for our Direct Selling Agents (DSAs), 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.
In the event of receipt of any complaint from the customer that our representative or DSA 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.
Applications for loans and their processing
ACHFPL will ensure that all required information such as interest rates applicable, as also the fees / charges, if any, payable for processing the loan application, the amount of fees non-refundable if loan amount is not sanctioned/ disbursed, pre-payment options and charges, if any, penal interest/ penalty for delayed repayment if any and any other matter which affects the interest of the borrower, including 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 informed decision can be taken by the borrower.
It will have a system of giving an acknowledgment for receipt of all loan applications.
Loan applications shall be disposed of within 30 days or such extended time as may be mutually agreed between the borrower and the Company from the date of receipt of the application form complete in all respects.
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.
ACHFPL 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.
ACHFPL 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 ACHFPL 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 inspection by ACHFPL on the completion of work (in the case of under construction properties) which would need to be verified and recommended by empaneled valuer of ACHFPL.
ACHFPL 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. ACHFPL 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
ACHFPL 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.
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 ACHFPL will call on him/her to pay up his liability;
Whether ACHFPL 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 ACHFPL will notify him/her about this.
ACHFPL will keep him/her informed of any default on the loan by the borrower to whom he/she stands as a guarantor.
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. ACHFPL 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 ACHFPL to reveal the information, or with the customer’s permission;
If ACHFPL 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 ACHFPL holds about him/her;
ACHFPL will not use the customer’s personal information for marketing purposes by anyone including ACHFPL unless the customer speciﬁcally authorizes the company to do so.
Credit reference agencies
When a customer opens an account, ACHFPL will inform him that it will pass his account details to credit reference agencies and ACHFPL will make checks with them.
The Company may give information to credit reference agencies about the personal debts the customer owes them if:
- The customer has fallen behind with his/her payments;
- The amount owed is in dispute; and
- The customer has not made proposals that ACHFPL is satisﬁed with, for repaying his debt, following ACHFPL’s formal demand.
- ACHFPL will 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 will be provided by ACHFPL to a customer if so demanded.
Collection of dues
Whenever loans are given, ACHFPL 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 ACHFPL and upon request, display his identity card issued by ACHFPL 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 ACHFPL in the collection and/or security repossession will follow the guidelines set out below:
- 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.
- Identity and authority to represent the HFC should be made known to the customer at the first instance.
- Customer privacy should be respected.
- Interaction with the customer shall be in a civil manner
- ACHFPL’s 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.
- A customer’s request to avoid calls at a particular time or at a particular place will be honored as far as possible unless ACHFPL has reason to believe that the customer is avoiding meeting the ACHFPL representative.
- Time and number of calls and contents of conversation would be documented.
- All assistance will be given to resolve disputes or differences regarding dues in a mutually acceptable and orderly manner.
- Inappropriate occasions such as bereavement in the family or other calamitous occasions will be avoided for making calls/visits to collect dues.
Complaints and grievances
Internal Process: If the customer wants to make a complaint, he / she will be told:
- How and where to make a complaint?
- 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 relevant questions the customer has.
If a complaint has been received in writing from a customer, we will endeavor to send him / her acknowledgement / response containing the name and designation of the official who will deal with the complaint 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 and be kept informed of the progress within a reasonable period of time
After examining the matter, we shall send the customer our final response or explain why it needs more time to respond and shall endeavor 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 grievance redressal procedure (e-mail id and other contact details at which the complaints can be lodged, turnaround time for resolving the issue, matrix for escalation, etc.) for lodging the complaints by the aggrieved borrower shall be made available on the Company’s website. Further, at all the branches / Head Office of the Company, notice will be put up informing the customers that in case the complainant does not receive response from the company within a period of one month or is dissatisfied with the response received, the complainant may approach the Complaint Redressal Cell of National Housing Bank by lodging its complaints online on the website of NHB or through post in prescribed format at the following address:
Complaint Redressal Cell
Department of Supervision National Housing Bank,
4th Floor, Core-5A, India Habitat Centre,
Lodhi Road, New Delhi – 110 003
A periodical review of the Code and the functioning of the grievance redressal mechanism at various levels of management would be undertaken by the Company and a consolidated report of such reviews shall be submitted to the Board of Directors of the Company at regular intervals.
- We shall verify the details mentioned by the customer 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 ACHFPL;
- The customer is expected to co-operate if ACHFPL needs to investigate a transaction on the customer’s account and with the police/ other investigative agencies, if the Company needs to involve them.
- If the customer acts fraudulently, he/she will be responsible for all losses on his/her account and if the customer acts without reasonable care and this causes losses, the customer may be responsible for the same.
- We shall give customers information about our products and services in Hindi, English or the appropriate local language, if requested for.
- We shall not discriminate between our customers on the basis of age, race, caste, gender, marital status, religion, or disability. However, this does not preclude us from instituting or participating in schemes framed for different sections and age groups of the society.
- ACHFPL shall process requests for transfer of a loan account, either from the borrower or from a bank/financial institution, in the normal course. In case of receipt of a request from the borrower for transfer of the borrower account, the consent or otherwise i.e. objection of the Company, if any, shall be conveyed within 30 days from the date of receipt of such request. Such transfer shall be as per transparent contractual terms in consonance with law.