About Us >> Corporate Governance >> Policies & Codes >> Fair Practices Code
Objectives & Application: -
1.1 Objectives of the Code –
The Code has been adopted by the Board of LIC Housing Finance Ltd.:
To promote good & fair practices by setting Minimum Standards in dealing with Customers;
To increase Transparency so that the Customers can have better understanding of what they can reasonably expect of the Services;
To encourage Market forces, to achieve higher Operating Standards;
To promote a fair & cordial relationship between Customer & LICHFL; &
To foster confidence in Housing Finance System.
1.2 Application of the Code –
The Code applies to all the Products & Services offered by LICHFL by any Method, & all Offices & all Employees of LICHFL, including Employees of LIC of India, who are working in LICHFL.
The code also applies to LICHFL Care Homes Ltd. and to all facilities / services offered by LICHFL Care Homes Ltd. by any method, & all offices & all employees of LICHFL Care Homes Ltd, including Employees of LIC of India who are working in LICHFL Care Homes Ltd.
LICHFL’s Commitment to Customers: -
2.1 To act fairly & reasonably in all dealings with Customers by ensuring that –
The Commitments & Standards prescribed in this Code are met for all Products, Services, Procedures, & Practices.
Our Products & Services meet relevant Laws & Regulations in letter & spirit.
Our dealings with Customers rest on the Ethical Principles of Integrity & Transparency.
2.2 To help Customers understand our Financial Products & Services by –
Giving Customers information about our Products & Services in any of the following Languages: Hindi, English or the appropriate local Language.
Ensuring that our Advertising & Promotional Literature is clear & not misleading.
Ensuring that the Customers are given clear information about our Products & Services, the Terms & Conditions, & the Interest Rates / Service Charges, which apply to them.
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 –
Providing them regular & appropriate updates.
Keeping them informed about changes in the Interest Rates, Charges, or Terms & Conditions.
2.4 To deal quickly & sympathetically with things that go wrong by –
Correcting mistakes promptly & canceling any Charges applied due to our mistake.
Handling Customers’ Complaints promptly.
Telling Customers how to take their Complaint forward if they are still not satisfied.
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 –
provide existing & new Customers with a copy of the Code;
make this Code available on request either over the Counter or by Electronic Communication or Mail;
make available this Code at each of our Offices & on our Website; &
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.
Disclosure & Transparency: -
3.1 We should provide Information on Interest Rates, Common Fees, & Charges through any one or more of the following –
Putting up Notices in all our Offices;
Through Telephone or Helplines;
On the Company’s Website;
Through designated Staff / Helpdesk; or
Providing Tariff Schedule.
3.2 In respect of prospective Customers, we shall –
provide clear information explaining the key features of our Products & Services that the Customer is interested in;
provide information on any type of Product & Service offered, that may suit the Customer’s needs;
tell the Customer about the various means through which Products & Services are offered & tell them how to find out more about them;
tell the Customer what information is needed from him / her to prove his / her Identity & Address, for complying with Legal, Regulatory & Internal Policy requirements.
3.3 To those who have become Customers, we shall –
provide more information on the key features of the Products, including applicable Interest Rates / Fees & Charges;
provide extra information on his / her Rights & Responsibilities especially regarding availing of nomination facility offered on all Deposit Accounts;
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.
3.4 Interest Rates –
At the time of Counseling / Disbursement / Opening of Deposit Account , we shall inform the Customer regarding:
the Interest Rates which shall apply to his / her Account (s), both deposit & loan.
when Interest is paid on his / her Deposits, or charged on his / her Loan Accounts.
how Interest is applied to his / her Account & method of Calculation of Interest.
3.5 Changes in Interest Rates –
When the Interest Rates are reviewed, we shall inform all the Customers being affected due to the Review.
3.6 Fees & Charges –
We shall display in our Offices:
a Notice about the Tariff Schedule.
Customers can ask for Tariff Schedule;
a list of Services which are rendered free of Charge.
We shall provide our Customers all details (in our Tariff Schedule) of any Charges applicable to the Products & Services chosen by them.
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.
3.7 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.
3.8 Terms & Conditions –
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.
The Terms & Conditions shall be fair & will set out respective Rights, especially with regard to Nomination Facility in Deposit Account and Liabilities & Obligations clearly, & as far as possible, in plain & simple Language.
3.9 Changes to Terms & Conditions –
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
Normally, changes shall be made with Prospective Effect giving due Notice.
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.
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.
Advertising, Marketing & Sales: -
4.1 We shall –
Ensure that all Advertising & Promotional Material is clear, & not misleading.
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.
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.
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 by registering for the same on the Website or on the Customer Service Number.
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.
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.
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:
If the Information is to be given by Law.
If there is a duty towards the Public to reveal the Information.
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.
If the Customer asks us to reveal the information, or with the Customer’s Permission.
If we are asked to give a reference about a Customer, we 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 we hold about him / her.
We shall not use Customer’s Personal Information for Marketing purposes by anyone including ourselves unless the Customer specifically authorises us to do so.
5.2 Credit Reference Agencies –
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.
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.
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.
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.
A copy of the Information given to the Credit Reference Agencies shall be provided by us to a Customer, if so demanded.
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 endeavour 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:
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.
Identity & Authority to represent the Company shall be made known to the Customer at the first instance.
Customer’s Privacy should be respected.
Interaction with the Customer shall be in a civil manner.
Our representatives shall contact the Customers between 0700 hrs & 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 honoured, as far as possible.
Time & Number of Calls & Contents of Conversation would be documented.
All assistance should be given to resolve disputes or differences regarding dues in a mutually acceptable & in an orderly manner.
During Visits to Customer’s place for Dues Collection, Decency & Decorum shall be maintained.
Inappropriate occasions such as bereavement in the Family or such other calamitous occasions should be avoided for making Calls / Visits to collect Dues.
Complaints & Grievances: -
7.1 Internal Procedures –
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.
Customer will be told where to find details of our Procedure for handling Complaints fairly & quickly.
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.
After examining the matter, we shall send the Customer our Final Response or explain why it needs more time to respond & shall endeavour 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 is still not satisfied.
Know Your Customer (KYC) Guidelines: -
8.1 We shall carry out Due Diligence required under our "Know Your Customer" (KYC) Guidelines before Loan Sanctioning, Account Opening (Deposits) & Operation –
Ask the Customer to submit or provide necessary Documents or Proofs to do so;
Obtain only such information to meet with our KYC, Anti Money Laundering or any other Statutory Requirements. In case any Additional Information is required, it will be sought separately & we will specify the objective of obtaining such additional information.
Provide the Loan Application Form, Account Opening Forms & other Material to the Customer. The same shall contain details of essential information required to be furnished & Documents to be produced for Verification & / or for Record for meeting the KYC Requirements;
explain the Procedural Formalities & provide necessary clarifications sought by the Customer while applying for loan / opening a Deposit Account.
Deposit Accounts: -
9.1 Information –
When a Customer opens a Deposit Account, he / she shall be informed of the Rate at which Interest is paid on his / her Fixed / Recurring Deposit, how it is calculated & its Periodicity. For Deposit Products like Recurring Deposit Account, the Customer should be informed about Charges which will be levied in case of the Delayed Payment of Periodical Instalment/s in the Account by the Customer. Details of the Charges should be included in the Tariff Schedule.
Customer should be informed of different types of Accounts that can be opened with us such as Term Deposits, Recurring Deposits, etc. HFC shall explain the implications of opening Accounts in various Styles, such as Single, Joint, Joint (Either or Survivor), Joint (Former or Survivor), Joint (Latter or Survivor), or in any other Style, or with Nomination Facilities at the time of Account Opening.
9.2 Premature Withdrawal of Deposits –
The procedure pertaining to Premature Withdrawal of Term Deposits should be informed to the Depositor disclosing the Interest Rates Policy for Premature Withdrawal of Term Deposit.
The Brokerage paid to the Broker for mobilizing Deposits, should not be recovered from the Customer if the Customer decides to pre-close his Deposit with us for whatever reason.
9.3 Renewal of Overdue Term Deposits –
We should inform our Customers the Interest Rate applicable in case they renew the Deposits after the Date of Maturity.
9.4 Advances against Deposits –
We should clearly explain the Facility of Loan available against Term Deposits, if any.
9.5 Accounts of minors –
We should tell our Customers, on enquiry, how a Deposit Account can be opened in a Minor’s Name.
9.6 Special accounts –
We shall endeavour to make our best efforts to make it easy & convenient for our special Customers like Senior Citizens, Physically Challenged Persons, & Illiterate Persons to deal with us. This will include making convenient Policies, Products, & Services for such Customers. We shall inform the Procedure for opening of the Account & other Terms & Conditions to Blind / other Physically Challenged Persons provided he / she calls on our Office personally along with a Witness who is known to both such Person & our Office.
9.7 Settlement of claims in respect of deceased account holders –
Accounts with Survivor / Nominee Clause: In case of a Deposit Account of a Deceased Depositor where the Depositor had utilized the Nomination Facility & made a valid Nomination or where the Account was opened with the Survivorship Clause ("Either or Survivor", or "Anyone or Survivor", or "Former or Survivor" or "Latter or Survivor"), the Payment of the Balance in the Deposit Account to the Survivor (s) / Nominee (s) of a Deceased Deposit Account Holder shall be made provided:
the Identity of the Survivor (s) / Nominee (s) & the fact of the Death of the Account Holder, is established through appropriate Documentary Evidence;
there is no Order from a Competent Court / other Statutory Authority restraining the Company from making the Payment from the Account of the Deceased; &
it has been made clear to the Survivor (s) / Nominee (s) that he / she / they would be receiving the Payment from the Company as a Trustee of the Legal Heirs of the Deceased Depositor, i.e., such Payment to him shall not affect the Right or Claim which any Person may have against the Survivor (s) / Nominee (s) to whom the payment is made.
The Payment made to the Survivor (s) / Nominee (s), subject to the foregoing conditions, would constitute a full discharge of the Company’s Liability. In such cases, Payment to the Survivor (s) / Nominee (s) of the Deceased Depositors will be made without insisting on production of Succession Certificate, Letter of Administration or Probate, etc. or obtaining any Bond of Indemnity or Surety from the Survivor (s) / Nominee (s), irrespective of the Amount standing to the credit of the Deceased Account Holder.
Accounts without Survivor / Nominee Clause: In case where the Deceased Depositor had not made any Nomination or for the Accounts other than those styled as "Either or Survivor" (such as Single or Jointly Operated Accounts), we shall adopt a simplified Procedure for Repayment to Legal Heir (s) of the Depositor keeping in view the imperative need to avoid inconvenience & undue hardship to the common Person. Keeping in view our Risk Management Systems, we may fix a Minimum Threshold Limit for the Amount, up to which Claims in respect of the Deceased Depositors could be settled without insisting on Production of any Documentation other than a Letter of Indemnity.
Premature Termination of Term Deposit Accounts: In the case of Term Deposits, we shall incorporate a Clause in the Account Opening Form itself to the effect that in the event of the Death of the Depositor, Premature Termination of Term Deposits would be allowed, subject to the provisions of the Housing Finance Companies (NHB) Directions, 2001. The conditions subject to which such Premature Withdrawal would be permitted may also be specified in the Account Opening Form.
Time Limit for Settlement of Claims: We shall endeavour to settle the Claims in respect of Deceased Depositors & release Payments to Survivor (s) / Nominee (s) within a period not exceeding 15 days from the date of receipt of the Claim subject to the production of Proof of Death of the Depositor & suitable identification of the Claim (s), to the Company’s satisfaction.
Loans:-
10.1 Before we lend any Money, we should assess whether the Customer will be able to repay it –
If we cannot provide the Loan to the Customer, we shall communicate in writing the Reason (s) for Rejection. If the Customer wants us to accept a Guarantee or other Security from someone for his / her Liabilities, we may ask the Customer for his Permission to give confidential information about his Finances to the Person giving the Guarantee or other Security, or to their Legal Advisor. We may also:
a. encourage the Customers to take independent Legal Advice to make sure that they understand their Commitment & the possible consequences of their Decision (where appropriate, the Documents we ask them to sign, will contain this Recommendation as a clear & obvious Notice);
tell the Customers that by giving the Guarantee or other Security they may become liable instead of, or as well as, him; &
tell them what their Liability would be.
10.2 Applications for loans & their processing –
At the time of Sourcing a Loan Product, we shall provide Information about the Interest Rates applicable, as also the Fees / Charges, if any, payable for Processing, Pre-payment Options & Charges, if any, & any other matter which affects the interest of the Borrower, so that a meaningful comparison with those of other HFCs can be made & informed decision can be taken by the Borrower.
We shall follow the System of giving Acknowledgement for receipt of all Loan Applications. Preferably, the Time Frame within which Loan Applications will be disposed of should also be indicated in the Acknowledgement, keeping in mind the level of Authority to which the Loan Proposal would be forwarded for Final Decision.
Normally all particulars required for processing the Loan Application shall be collected by us at the time of Application. In case we need any Additional Information, the Customer should be told that he would be contacted immediately again.
We shall convey to the Customer the Loan Sanction along with the Terms & Conditions thereof.
We shall supply Authenticated Copies of all the Loan Documents executed by the Customer along with a Copy each of all Enclosures quoted in the Loan Document on request;
We shall not discriminate on grounds of Sex, Caste & Religion in the matter of Lending. However, this does not preclude us from instituting or participating in Schemes framed for different Sections of the Society.
We shall process requests for Transfer of a Loan Account, either from the Borrower or from a Bank / Financial Institution, in the normal course.
Before taking a decision to Recall / Accelerate Payment or Performance under the Agreement or seeking Additional Securities, we shall give Notice to Borrowers in consonance with the Loan Agreement.
We shall release all Securities within 15 days of repayment of all Dues or on Realization of the Outstanding Amount of Loan subject to any Legitimate Right or Lien for any other Claim we may have against the 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 & the Conditions under which we are entitled to retain the Securities till the relevant Claim is settled / paid.
10.3 Guarantors –
When a person intends to be Guarantor for a Loan, he / she shall be informed about:
his / her Liability as Guarantor;
the amount of Liability he / she will be committing himself / herself to the Company;
circumstances in which we will call on him / her to pay up his / her Liability;
whether we have 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; &
time & circumstances in which his / her Liabilities as a Guarantor will be discharged as also the manner in which we 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 for whom he / she stands as a Guarantor.
General:-
11.1 We shall give the Customer information –
Explaining the key features of our Loan Products including applicable Fees & Charges while communicating the Sanction of the Loan.
Advise the Customer what Information / Documentation it needs from him / her to enable him / her to apply. The Customer should also be advised regarding what Documentation is needed from him / her with respect to his / her Identity, Address, Employment, etc. & any other Document that may be stipulated by Statutory Authorities (e.g. PAN details) in order to comply with Legal & Regulatory Requirements.
Verify the details mentioned by him / her in the Loan Application by contacting him / her at his / her Residence & / or on Business Telephone Numbers & / or physically visiting his / her Residence & / or Business Addresses through staff or through Agencies appointed for this purpose, if deemed necessary by us.
The Customer shall be informed to co-operate if we need to investigate a Transaction on the Customer’s Account & with the Police / other Investigative Agencies, if we need to involve them.
We shall advise the Customer that if the Customer acts fraudulently, he / she will be responsible for all Losses on his / her Account & that if the Customer acts without reasonable care & this causes Losses, the Customer may be held responsible for the same.