FAIR PRACTICES CODE


OBJECTIVES

  1. To promote good and fair practices by setting minimum standards in dealing with customers;
  2. To increase transparency so that the customer can have a better understanding of what they can reasonably expect of the services;
  3. To encourage market forces, through competition, to achieve higher operating standards;
  4. To promote a fair and cordial relationship between customer and India Infoline Housing Finance Limited; and to foster confidence in the housing finance system.

APPLICATION OF THE CODE

This code shall apply to all employees of India Infoline Housing Finance Limited and other persons authorized to represent it in the course of its business, whether the products and services are provided across the counter, over the phone, by post, through interactive electronic device, on the internet or by any other method.

COMMITMENTS

India Infoline Housing Finance Limited 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.

India Infoline Housing Finance Limited would provide clear information, without any ambiguity, to the customer in understanding:

  1. Products and services together with its terms and conditions including interest and service charges.
  2. Benefits available to customer.

India Infoline Housing Finance Limited will deal quickly and sympathetically in correcting mistakes if any, and attend to customer's complaints in light of the objectives of this code.

India Infoline Housing Finance Limited shall treat all personal information of customers as private and confidential and shall not divulge any information to third person unless required by any law or Government authorities including Regulators or Credit agency or where the sharing of information is permitted by the customer.

India Infoline Housing Finance Limited would provide, on request, copy of the Code to the existing borrowers and new customer prior to commencement of business transaction.

India Infoline Housing Finance Limited shall not discriminate its customers on the basis of race, caste, gender, marital status, religion or disability. However the restrictions, if any, as mentioned in the loan products shall continue to apply.

DISCLOSURE AND TRANSPARENCY

India Infoline Housing Finance Limited would provide information on interest rates, common fees and charges through:

  1. Putting up notices in branches;
  2. Through telephones or help lines;
  3. Through designated staff/help desk;
  4. Providing service guide/tariff schedule;
  5. Providing Fees/charges payable for processing the loan application;
  6. Providing amount of fees refundable if amount is not sanctioned or disbursed;
  7. Providing structure of prepayment options and charges;
  8. Providing details of penalty payable on delayed repayment;
  9. Providing details on conversion charges for switching loan from Fixed to Floating rates and vice versa;
  10. Provide details on Interest reset clause;
  11. Disclose “all in cost” to the client which shall include charges involved in processing and sanctioning of Loan Applications;

India Infoline Housing Finance Limited shall provide payment of Charges which shall be non discriminatory to its customers.

ADVERTISING, MARKETING AND SALES

India Infoline Housing Finance Limited shall ensure that all advertising and promotional material is clear and not misleading. The Fair Practice Code shall also apply to sales Associates / representatives of the Company to the extent of their identification when they approach the customer for selling products personally. In case of any advertisement in any media and promotional literature that draws attention to a service/product and its interest rate, India Infoline Housing Finance Limited shall also provide the details of other fees or charges, if any. Further, on the request of the customer, India Infoline Housing Finance Limited shall provide the details of relevant terms and conditions.

CREDIT REFERENCE AGENCIES

India Infoline Housing Finance Limited would give information about customers to credit reference agencies on:-

  1. Opening of an account.
  2. The customer having fallen behind with his/her payments and the performance of loan account which includes how much loan has been sanctioned and the subsequent performance.
  3. Legal proceedings that have been initiated against the customer to recover the dues.
  4. Debts settled through legal recourses against the customer.

India Infoline Housing Finance Limited may give credit reference agencies other information about the customer's account if law requires it or the customer has given them his/her permission to do so.

COLLECTION OF DUES

Whenever loans are given, India Infoline Housing Finance Limited would 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/her notice or by making personal visits and / or repossession of security, if any.

India Infoline Housing Finance Limited staff or any person authorized to represent the company in collection of dues or/and security repossession shall identify himself / herself and display the authority letter issued by the India Infoline Housing Finance Limited and upon request, display his/her identity card issued by the India Infoline Housing Finance Limited or under authority of the India Infoline Housing Finance Limited. India Infoline Housing Finance Limited shall provide the customers with all the information regarding overdue.

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 by the person authorised by India Infoline Housing Finance Limited for dues collection or/and security possession/repossession the following guidelines shall be followed:

  1. Customer would be contacted ordinarily at the place of his / her choice absence of any specified place at the place of his / her residence and if at his / her residence, at the place of business / occupation.
  2. Identity and authority to represent the Company shall be made known at the first instance.
  3. Customer’s privacy should be respected.
  4. Interaction with the customer shall be in a civil manner.
  5. The Company representatives shall contact the customers between 0700 hrs and 1900 hrs unless the special circumstances of the customer’s business or occupation otherwise.
  6. Customer’s request to avoid calls at a particular time or at a particular place honored as far as possible.
  7. Time and number of calls and contents of conversation would be documented.
  8. All assistance should be given to resolve disputes or differences regarding mutually acceptable and in an orderly manner.
  9. During visits to customer’s place for dues collection, decency and decorum be maintained.

Inappropriate occasions such as bereavement in the family or such other occasions should be avoided for making calls/visits to collect dues.

KNOW YOUR CUSTOMER (KYC) GUIDELINES

India Infoline Housing Finance Limited shall explain the requirements of KYC guidelines to its customers and inform them about the documents required for establishing the identity of the customer before loan sanctioning, account opening and operation.

India Infoline Housing Finance Limited would obtain only such information to meet with company's KYC, Anti-Money Laundering or any other statutory requirements. In case any additional information is asked for, it will be sought separately and shall specify the objective of obtaining such additional information.

LOANS

Assessment of Loan Repayment Capacity by India Infoline Housing Finance Limited

All loan application received by India Infoline Housing Finance Limited will be processed inline with the internal policies and criteria’s. If India Infoline Housing Finance Limited cannot provide the loan to the customer, it shall communicate the same to the customer through its appointed representatives or directly to the customer verbally. In case customer requires the same in writing the reason(s) for rejection can be provided.

Applications for Loans and its Processing

  1. At the time of sourcing a loan product, India Infoline Housing Finance Limited shall provide information about interest rates applicable, as also the fees/charges, if any, payable for processing, pre-payment options and charges, if any, and any other matter which affects the interest of the borrower.
  2. All particulars required for processing the loan application shall be submitted to India Infoline Housing Finance Limited at the time of application. In case it needs any additional information, India Infoline Housing Finance Limited would contact the customer.
  3. India Infoline Housing Finance Limited shall convey to the customer the loan sanction along with the terms and conditions thereof.
  4. The customer is entitled to one set of authenticated loan documents on execution of the same.
  5. India Infoline Housing Finance Limited shall not discriminate on grounds of sex, caste and religion in the matter of lending. However, this does not preclude India Infoline Housing Finance Limited form instituting or participating in schemes framed for different sections of the society.
  6. India Infoline Housing Finance Limited shall process requests for transfer of a loan account, either form the borrower or from a bank/financial institution, in the normal course.
  7. Before taking a decision to change any terms and conditions including disbursement schedule, interest rate, service charges, recall/accelerate payment or performance under the agreement or seeking additional securities or any other charges, India Infoline Housing Finance Limited shall give notice to borrowers in consonance with the loan agreement.
  8. India Infoline Housing Finance Limited shall 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 that India Infoline Housing Finance Limited 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.

Guarantors

When a person is considered to be a guarantor to a loan, India Infoline Housing Finance Limited shall inform him/her the following under acknowledgement-

  1. Letter/ Deed of Guarantee stating the terms of liability as guarantor.
  2. India Infoline Housing Finance Limited shall keep him/her informed of any default in servicing of the loan by the borrower to whom he/she stands as a guarantor.

Branch Closure/ Shifting

India Infoline Housing Finance Limited shall inform the customer in the event of closure/shifting of its branch office.

GRIEVANCE REDRESSAL PROCEDURE

Communication with the customer

Customers should be able to access the Company through any of the following means:

  1. Walk In to branches (as mentioned in Company brochure/website/any other leaflet)
  2. Telephone, Fax and Email ID (as mentioned in Company brochure/website/any other leaflet)

Complaints

India Infoline Housing Finance Limited 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.

Customer may also write / communicate with the concerned location for redressal of the grievance to Reach@iihfl.com.

Designated toll free Phone no. for submission of complaints : 180030001155.

India Infoline Housing Finance Limited would acknowledge receipt of complaint within 3 days and would ensure that a response is provided within a period of 15 days from the date of lodging of complaint. Delays in closure of complaint beyond 15 days on account would be communicated to the applicant/borrower.

ESCALATIONS MATRIX

LEVEL I

In case of response not being received within 15 days of lodging the complaint at reach e-mail i.d. or response being unsatisfactory from above mentioned sources the complaint may be further escalated to:

Ms. Rakhi Narain, Customer Service Manager and Grievance Redressal Officer; on rakhi.narain@indiainfoline.com

IIFL Tower, 98, Udyog Vihar,
Phase-IV, Near Maruti Gate no-3,
Gurgaon, Haryana -122016

LEVEL II

In case of response not being received within 15 days of escalation of complaint to Level I or the response being unsatisfactory from the above mentioned sources the complaint may be further escalated to

Mr. Ajay Jaiswal, Head - Compliance on ajay.jaiswal@indiainfoline.com

IIFL Tower, 98, Udyog Vihar,
Phase-IV, Near Maruti Gate no-3,
Gurgaon, Haryana -122016

LEVEL III

In case of response not being received or the response being unsatisfactory from the above mentioned sources the complaint may be further escalated to:

National Housing Bank,
Department of Regulation and Supervision,
(Complaint redressal Cell),
4th Floor, Core-5A, India Habitat Centre,
Lodhi Road,
New Delhi- 110003

The complaint can also be emailed to crcell@nhb.org.in

PRIVACY AND CONFIDENTIALITY

India Infoline Housing Finance Limited shall ensure all personal information of customers are treated as private and confidential [even when the customers are no longer customers], and shall be guided by the following principles and policies. India Infoline Housing Finance Limited shall not reveal information or data relating to customer accounts, whether provided by the customers or otherwise, to anyone, including other companies or entities in their 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 the Company's interests require them 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 accounts [including customer name and address] to anyone else, including other companies in the group, for marketing purposes.
  4. If the customer asks the Company to reveal the information, or with the customer's permission.
  5. If India Infoline Housing Finance Limited is asked to give a reference about customers, they 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 an India Infoline Housing Finance Limited holds about him /her.

India Infoline Housing Finance Limited shall not use customer's personal information for marketing purposes by anyone including India Infoline Housing Finance Limited unless the customer specifically authorizes them to do so.

GENERAL

India Infoline Housing Finance Limited reserves the right to amend /alter /modify the codes as mentioned herein above and provide updates from time to time, not affecting/sacrificing the underlining spirit of the code. Such alternation/amendments may be displayed at the notice boards of the branches /Corporate Office for the benefit and information of the customer.

For India Infoline Housing Finance Limited
Sd/-
Director
Place: Mumbai