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Introduction

This has reference to the circular NHB(ND)/DRS/REG/MC-03/2019 dated July 1, 2019, wherein the National Housing Bank had revised the guidelines on Fair Practices Code for Housing Finance Companies to implement the same.

Vastu Housing Finance Corporation Limited (VHFCL) has adopted this code to provide transparency in business dealings with its customers.

1. Objective of the code:

The Code has been developed to:

  • promote good and fair practices by setting minimum standards in dealing with customers;
  • increase transparency so that the customer can have a better understanding of what he/she can reasonably expect of the services;
  • encourage market forces, through competition, to achieve higher operating standards;
  • promote a fair and cordial relationship between customer and HFC;
  • foster confidence in the housing finance system.

2. Application of the code

This Code shall apply to all the employees of VHFCL or other persons authorized to represent it in the course of business, whether the products and services are provided by VHFCL or subsidiaries across the counter, over the phone, by post, through interactive electronic devices, on the internet or by any other method. The code will also be displayed on the notice board in all the branches and also on the website of the Company.

3. Disclosure and transparency

VHFCL shall act fairly and reasonably in all dealings with customers, by ensuring that:

  • It meets the commitments and standards in this Code for the products and services we offer and, in the procedures, and practices our staff follows
  • It’s products and services meet relevant laws and regulations in letter and spirit
  • Dealings with customers rest on ethical principles of integrity and transparency

4. Advertising, Marketing and Sales

  • VHFCL shall 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, VHFCL shall also indicate whether other fees and charges will apply and that full details of the relevant terms and conditions are available on request
  • VHFCL will provide information on interest rates, common fees and charges through putting up notices in their branches; through telephone or help-lines; on the company’s website; through designated staff / help desk; or providing service guide / tariff schedule
  • If VHFCL avails the services of third parties for providing support services, it will ensure that such third parties handle customer’s personal information (if any available to such third parties) with the same degree of confidentiality and security as VHFCL would
  • VHFCL may, from time to time, communicate to customers various features of their products availed by them. Information about their 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 by registering for the same on the website or on customer service number
  • VHFCL shall prescribe a code of conduct for their Direct Selling Agencies (DSAs) whose services are availed to market products / services which amongst other matters require them to identify themselves when they approach the customer for selling products personally or through phone.
  • In the event of receipt of any complaint from the customer that VHFCL’s representative / courier 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

5. Loans

aApplications for loans and their processing

  • Loan application forms will include necessary information which affects the interest of the borrower, 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. The loan application form will indicate the list of documents required to be submitted with the application form
  • VHFCL has a devise a system of giving acknowledgement for receipt of all loan applications. Preferably, the time frame within which loan applications will be disposed of shall also be indicated in the acknowledgement

bLoan Appraisal and terms/conditions

  • Normally all particulars required for processing the loan application shall be collected by VHFCL at the time of application. In case it needs any additional information, the customer will be told that he would be contacted immediately again
  • VHFCL will convey in writing to the borrower by means of sanction letter or otherwise, the amount of loan sanctioned along with all terms and conditions including annualized rate of interest, method of application, EMI Structure, prepayment charges and keep the written acceptance of these terms and conditions by the borrower on its record
  • VHFCL shall invariably furnish a copy of the loan agreement along with a copy each of all enclosures quoted in the loan agreement to every borrower at the time of sanction / disbursement of loans

cCommunication of rejection of Loan Application

  • If VHFCL cannot provide the loan to the customer, it shall communicate in writing the reason(s)for rejection

dDisbursement of loans including changes in terms and conditions

  • Disbursement shall be made in accordance with the disbursement schedule given in the Loan Agreement/ Sanction Letter
  • VHFCL will give notice to the borrower for any change in the terms and conditions including disbursement schedule, interest rates, service charges, prepayment charges, other applicable fee/ charges etc. VHFCL will also ensure that changes in interest rates and charges are affected only prospectively. A suitable condition in this regard will be incorporated in the loan agreement
  • 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
  • VHFCL 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 VHFCL 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 VHFCL is entitled to retain the securities till the relevant claim is settled /paid

eGuarantors

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

  • his/her liability as guarantor;
  • the amount of liability he/she will be committing him/herself to the company;
  • circumstances in which VHFCL will call on him/her to pay up his/her liability;
  • whether VHFCL 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 are, they unlimited; and
  • time and circumstances in which his/her liabilities as a guarantor will be discharged as also the manner in which VHFCL will notify him/her about this;
  • In case the guarantor refuses to comply with the demand made by the creditor /lender, despite having sufficient means to make payment of the dues, such guarantor shall be treated as a willful defaulter.

VHFCL 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.

6. Privacy and confidentially

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. VHFCL 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 VHFCL’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 HFC; s to reveal the information, or with the customer’s permission.
  • If VHFCL is asked to give a reference about customers, it shall obtain his / her written permission before giving it
  • The customer shall be informed the extent of his / her rights under the existing legal framework for accessing the personal records that an HFC holds about him /her
  • VHFCL shall not use customer’s personal information for marketing purposes by anyone including HFCs unless the customer specifically authorizes them to do so

7. Credit reference agencies

  • When a customer opens an account, VHFCL shall inform him / her when they may pass his / her account details to credit reference agencies and the checks HFCs may make with them.
  • VHFCL 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 not in dispute; and
    • The customer has not made proposals that the VHFCL is satisfied with, for repaying his / her debt, following HFC’s formal demand;
  • In these cases, VHFCL 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, VHFCL 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
  • VHFCL may give credit reference agencies other information about the customer’s account if the customer has given them his / her permission to do so
  • A copy of the information given to the credit reference agencies shall be provided by VHFCL to a customer, if so demanded.

8. Collection of dues

  • a. Whenever loans are given, VHFCL shall 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.
  • b. VHFCL’s collection policy is built on courtesy, fair treatment and persuasion. VHFCL believes in fostering customer confidence and long-term relationship. VHFCL’sstaff or any person authorized to represent them in collection of dues or / and security repossession shall identify himself / herself and display the authority letter issued by VHFCL and upon request, display his / her identity card issued by VHFCL or under authority of the company. VHFCL shall provide customers with all the information regarding dues and shall endeavor to give sufficient notice for payment of dues.
  • c. All the members of the staff or any person authorized to represent VHFCL in collection or / and security repossession follows the guidelines set out below:
    • 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 VHFCL will be made known to the customer at the first instance.
    • Customer’s privacy shall be respected.
    • Interaction with the customer shall be in a civil manner.
    • VHFCL’s representatives shall contact the customers between 0700 hrs. and 1900 hrs., unless the special circumstances of the customer’s business or occupation require otherwise
    • Customer’s request to avoid calls at a particular time or at a particular place shall be honored as far as possible
    • Time and number of calls and contents of conversation would be documented.
    • All assistance should be given to resolve disputes or differences regarding dues in a mutually acceptable and in an orderly manner.
    • During visits to customer’s place for dues collection, decency and decorum shall be maintained.
    • Inappropriate occasions such as bereavement in the family or such other calamitous occasions will be avoided for making calls/visits to collect dues.

9. Complaints and grievances

At VHFCL, customer service and satisfaction are our prime focus. We believe that providing prompt and efficient service is essential not only to attract new customers, but also to retain existing ones. In order to make VHFCL’s redressal mechanism more meaningful and effective, a structured system has been built. This system would ensure that the redressal sought is just and fair and is within the given frame- work of rules and regulation.

  • a. If a complaint has been received in writing from a customer, VHFCL shall endeavor to send him/her an acknowledgement / response within a week. The acknowledgement shall contain the name & designation of the official who will deal with the grievance. If the complaint is relayed over phone at VHFCL’s 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
  • b. After examining the matter, VHFCL will send the customer its 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
  • c. Complaint which is directly received by corporate office through Email/Calls, will be attended in consultation with the concerned branch by our customer service team. Similarly, if the complaint is received at branch(es), they shall be recorded in the Complaint Register and redressed in consultation with Corporate Office. VHFCL will make available facilities at each of its branches and offices for the customers to lodge and/or submit their complaints or grievances. Alternatively, customers can contact us at 1800 22 0001 or email us at customercare@vastuhfc.com or write to us at:
  • Grievance Redressal Officer:

    Mr. Sujay Patil / Mr. Rohith Balakrishnan

    Email us at/Call us on customercare@vastuhfc.com/1800 22 0001
    Write to us at the below mentioned address: Vastu Housing Finance Corporation Limited A-203, Navbharat Estates, Barrister Nath Pai Marg, Azad Nagar, Sewri, Mumbai, Maharashtra 400015
  • d. Complaints that are received at our end will be seen in the right perspective and would be analyzed from all possible angles. The communication of VHFCL’s stand on any issue will be provided to the customers. Complaints that require some time for examination of issues involved will be acknowledged promptly.
  • e. In case the response is unsatisfactory, or the response is not received from VHFCL within reasonable time (6 weeks) or the customer is dissatisfied with the response received, the customer may approach NHB at the following address / mail id.
  • National Housing Bank

    Email id crcell@nhb.org.in
    Write to the below mentioned address: Department of Regulation and Supervision (Complaint Redressal Cell) 4th Floor, Core 5- A, India Habitat Centre Lodhi Road, New Delhi – 110003

10. General

  • a. VHFCL shall 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
  • b. The customer will be informed to co-operate if VHFCL needs to investigate a transaction on the customer’s account and with the police/ other investigative agencies, if VHFCL needs to involve them
  • c. VHFCL shall 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
  • d. VHFCL shall display about their products and services in any one or more of the following languages: Hindi, English or the appropriate local language
  • e. VHFCL shall not discriminate on grounds of sex, caste and religion in the matter of lending
  • f. VHFCL will process requests for transfer of a loan account, either from the borrower or from a bank/financial institution, in the normal course
  • g. To publicize the code, VHFCL shall:
    • 1. provide existing and 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 every branch and on their website; and
    • 4. ensure that their staff are trained to provide relevant information about the Code and to put the Code into practice.
  • h. The Board of Directors of VHFCL shall provide for periodical review of the compliance of the Fair Practices Code and the functioning of the grievance’s 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
Fair Practice Code