Skip to main content

Company Policies

Our policies are intended to ensure a transparent work culture, provide our customers the support and service they need and establish the rules of conduct between the Company and our Customers

Company Policies

Fair Practices Code

Ummeed Housing Finance Private Limited (hereinafter referred to as “the Company” or “HFC” or “UHFPL” or “Ummeed”) is a Private Limited Company incorporated under the provisions of the Companies Act, 2013 and registered as a Housing Finance Company (“HFC”) with the National Housing Bank (“NHB”).

This Code has been formulated by Ummeed Housing Finance Pvt. Ltd (Ummeed), the “company”, pursuant to the Guidelines issued by the National Housing Bank (“NHB”) on Fair Practices Code for Housing Finance Companies vide its circular NHB/ND/DRS/Pol-No.16/2006 dated September 05, 2006, further revised by its circulars NHB/ND/DRS/Pol-No.34/2010-11 and NHB (ND)/DRS/Pol- No.38/4673/2010-11. This amended Code has come into force from June 14, 2011.

With the shifting of regulation of HFCs from NHB to RBI, now Reserve Bank of India’s (“RBI”) Master Direction - Non-Banking Financial Company – Housing Finance Company (Reserve Bank) Directions, 2021, shall apply to all HFCs. Therefore, this Code has been amended by the Company in line with the said RBI Master Directions vide Circular dated February 17, 2021 due to the onset of change in regulations for HFCs.

Objectives:

The primary objective of the code are as below

  • To promote good and fair practices by setting minimum standards in dealing with customers.
  • To increase transparency so that the customer can have a better understanding of the services expected.
  • To promote a fair relationship between the company and the customer.
  • To encourage market forces, through fair competition, to achieve higher operating standards.
  • To foster confidence in the housing finance system overall.
Application of the Code
  • The Code would be applicable to all persons offering the Products and Services of the company as an employee or otherwise in any manner and / or by any mode.
  • The Code is applicable under 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
  • The company 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.
  • It will have literature or communication to Borrowers in multiple languages (English and Hindi or vernacular language or a language as understood by the borrower) and also make every effort to ensure that the terms are clear and not misleading and understood by the customer.
  • Its Sales Officers and Branch Managers (BM) or Officers/ sales representatives of the agency (s) working as Direct Selling /Marketing Agency or Recovery Agents under the approved Sales/ Marketing/ Recovery Arrangements, if any, 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 BMs or Officers/ Representatives of the said Agency(s) will help customers understand the terms and conditions, applicable interest rate / service charges/ all information about fees/ charges payable for processing the loan application, the amount of fees refundable if loan amount is not sanctioned/ disbursed, pre-payment options and charges, if any, penal interest/ penalty for delayed repayment, if any, conversion charges for switching loan from fixed to floating rates or vice-versa, existence of any interest reset clause and any other matter which affects the interest of the borrower and also the benefits that can be availed along with their financial implications.
  • The company will maintain a close relationship with the customer, and keep them informed of the products and services and the changes in interest rates, ‘all in cost’ inclusive of all charges involved in processing/ sanctioning of loan application in a transparent manner.
  • The Company shall give acknowledgement for receipt of all loan applications along with time frame within which loan applications will be disposed.
  • 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 part of the welcome kit given to the customers and also would be prominently displayed at the branches.
  • The company will deal quickly with things that go wrong by correcting the mistakes promptly. It will also provide suitable alternatives in case of technological failure.
  • The company will treat all customer information as private and confidential unless required by law or if waivers have been signed by the customer.
  • 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.
  • The company will not discriminate on the basis of race, caste, gender, marital status, religion or disability unless specific to schemes promoted by the NHB/RBI or by Government to assist weaker sections of society.
Advertising, Marketing and Sales

The company 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, the company will also indicate whether other fees and charges will apply and that full details of the relevant terms and conditions are available on request.
  • The company will ensure proper communication on interest rates, processing fees and charges to the prospective customers by putting up
    • personal discussion with the prospect
    • Notices in its branches;
    • through telephone or help-lines;
    • on the company’s website;
    • providing a written terms or schedule.
  • If the company 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 on 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 his consent to receive such information / service either by mail or by registering for the same on the website or on customer service number.
  • In the event of receipt of any complaint from the customer that the company’s employees or representatives has engaged in any improper conduct or acted in violation of this Code, appropriate steps will be initiated to investigate and to handle the complaint.
Processing the application for Loans
  • All required information 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.
  • The loan application form will give an indicative list of documents, required to be submitted with the form. Given the nature of the company’s customer segment who are mainly from the self-employed and informal segment and may not have normal documentation especially to prove incomes, the company may conduct personal verification and checks subject to relevant guidelines/ directions issued by regulator in this behalf, in addition to collecting available documentation.
  • The company will have a system of giving an acknowledgement for receipt of all loan applications along with time frame within which loan applications will be disposed.
Loan appraisal and terms/conditions
  • Normally, all particulars required for processing the loan application will be collected by the company at the time of application or at the time of personal verification conducted by the company (especially in the case of customers from the informal sector). In case the company needs any additional information, the customer will be told immediately that he would be contacted again.
  • The company 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 rate of interest, EMI Structure, prepayment charges and keep the written acceptance of these terms and conditions by the borrower on its record.
  • The company will furnish a copy of the loan agreement along with a copy of each of the enclosures quoted in the loan agreement to every borrower at the time of sanction/ disbursement of loans against acknowledgement.
  • Company shall mention the penal interest charged for late repayment in bold in the loan agreement.
  • In case Borrower’s application gets rejected for any reason whatsoever, Company shall communicate in writing the reason for rejection.
Processing Fees and Charges
  • All information about fees / charges payable for processing the loan application, prepayment charges if any, penalty for delayed payment if any, or any other matter which affects the interest of the borrower will be disclosed to the applicant by the Sales Officer and Credit Officer at time of application and will also always be printed on the company Sanction Letter.
  • However, the company shall reserve the right to change fees and charges from time to time based on market conditions, customer track record etc. Any changes to the basic charges will be communicated fully and transparently to all customers and would be brought into effect, prospectively.
  • The company requires that all fees are generally to be paid by the Applicant either through a cheque or a demand draft. Only in exceptional cases, the company may permit the applicant to pay fees in cash.
  • The company’s current policy is not to levy any charges other than the processing fee, in terms of legal fees, technical inspection fees, or charges for any other out of pocket expenses. However, the company will charge customers late payment & ECS / cheque bouncing charges.
  • The company’s objective is to support applicants own a primary residence, and the loan is not intentioned to help investment or speculative buyers. Thus, the company shall reserve the right to change the terms and conditions of the loan including but not limited to a 2% increase in the rate of interest if found at a later date that property being purchased from the loan sanctioned by the company is put to use for commercial or rental purposes.
  • Company shall not charge pre-payment levy or penalty on pre-closure of housing loans provided to individual under the following situations:
    • Where the housing loan is on floating interest rate basis.
    • Where the housing loan or any term loan is on fixed interest rate basis and the loan is pre-closed by the borrower out of their own sources. Whereas, the expression “own sources” for the purpose means any source other than by borrowing from a bank/ HFC/ NBFC and/or a financial institution.
  • All dual/ special rate (combination of fixed and floating) housing loans will attract the pre-closure norms applicable to fixed/ floating rate depending on whether at the time of pre-closure, the loan is on fixed or floating rate. In case of a dual/ special rate housing loans, the pre-closure norm for floating rate will apply once the loan has been converted into floating rate loan, after the expiry of the fixed interest rate period. This applied to all such dual/ special rate housing loans being foreclosed hereafter. It is also clarified that a fixed rate loan is one where the rate is fixed for entire duration of the loan.
  • HFCs shall not impose foreclosure charges/ pre-payment penalties on any floating rate term loan sanctioned for purposes other than business to individual borrowers, with or without co-obligant(s).
  • A most important terms and conditions (MITC) in duplicate copies shall be executed between the Company and the Borrower shall be handed over to the borrower under acknowledgement.
Communication of rejection of Loan Application
  • If the company cannot provide the loan to the customer, it will communicate in writing the reasons for rejection for sanctioning / declining the approval or disbursement of loans.
  • Disbursement will be made in stages and in accordance with the disbursement schedule agreed by the customer given in the Loan Agreement or Sanction Letter or per the Agreement for Sale which covers terms of payment by the customer to the builder and based on inspection by the company on the completion of work (in the case of under construction properties) which would need to be confirmed and accepted by the company.
  • The Board shall adopt an interest rate model with appropriate internal principles and procedures in determining interest rates and processing and other charges (including penal interest, if any) taking into account relevant factors such as cost of funds, margin and risk premium and determine the rate of interest to be charged for loans and advances.
  • The Board shall also to put in place an internal mechanism to monitor the process and the operations so as to ensure adequate transparency in communications with the borrowers.
  • The rates of interest and the approach for gradation of risks, and penal interest (if any) shall also be made available on the website of the companies or published in the relevant newspapers and shall be updated whenever there is a change in the rates of interest.
  • The rate of interest and penal interest (if any) must be annualised rate to make the borrowers aware of the exact rates that would be charged by the Company.
  • Instalments collected from borrowers should clearly indicate the bifurcation between interest and principal.
  • The company will give notice to the borrower in English and Hindi or vernacular language or a language as understood by the borrower of any change in the terms and conditions Including, interest rates, processing fee, prepayment charges, other applicable fee/ charges etc. The company will also ensure that changes in interest rates and charges are effected only prospectively and this condition shall be incorporated in Loan Agreement.
  • If such change is to the disadvantage of the customer, he/she may be allowed within 60 days and without any notice to close or switch his account without having to pay any extra charges or interest.
  • In case of receipt of request from the borrower for transfer of borrowal account, the consent or otherwise i.e. objection of the HFC, if any, shall be conveyed within 21 days from the date of receipt of request. Such transfer shall be as per transparent contractual terms under the Loan Agreement and/ or in consonance with law.
  • 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, in consonance with the loan agreement.
  • The company will 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 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 will 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 the company will call on him/her to pay up his/her liability;
  • whether the company 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 the company will notify him/ her about this;
  • the company will keep him informed of any default on the loan by the borrower to whom he stands as a guarantor;
  • In case the guarantor refuses to comply with the demand made by the Company, 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 will be treated as private and confidential (even when the customers are no longer customers), and will be guided by the following principles and policies. The company will not reveal information or data relating to customer accounts, whether provided by the customers or otherwise, to anyone, including other entities in the company’s 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 the company to reveal the information, or with the customer’s permission;
  • If the company is asked to give a reference about customers, it will obtain his written permission before giving it;
  • The customer will be informed the extent of his rights under the existing legal framework for accessing the personal records that the company holds about him;
  • The company will not use customer’s personal information for marketing purposes by anyone including the company unless the customer specifically authorizes the company to do so.

Wherever Company avail of the services of third parties for providing support services, it is required 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 the Company would.

Credit reference agencies:

When a customer opens an account, the company will inform him that it will pass his account details to credit reference agencies and the company 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 payments;
  • the amount owed is in dispute; and
  • the customer has not made proposals that the company is satisfied with, for repaying his debt, following the company’s formal demand.
  • The company 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 the company to a customer, if so demanded.
Collection of Dues:
  • Whenever loans are given, the company 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.
  • The company’s collection policy will be built on courtesy, fair treatment and persuasion, and will be aimed at fostering customer confidence and a long-term relationship. The company’s staff or any person authorized to represent it in collection of dues and / or security repossession will identify himself and display the authority letter issued by the company and upon request, display his identity card issued by the company or under authority of the company. The company 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 authorised to represent the company in collection and / or security repossession will follow Company’s Board approved Collection and Recovery Policy and the guidelines set out below:
    • Customers will be contacted ordinarily at the place of his choice and in the absence of any specified place at the place of his residence and if unavailable at his residence, at the place of business / occupation.
    • Identity and authority to represent the company will be made known to the customer at the first instance.
    • Customer’s privacy will be respected.
    • Interaction with the customer will be in a civil manner.
    • The company’s representatives will contact customers between 0800 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 will be honored as far as possible, unless the company has reason to believe that the customer is avoiding meeting the company representative.
    • All assistance will be given to resolve disputes or differences regarding dues in a mutually acceptable and in an orderly manner.
    • Inappropriate occasions such as bereavement in the family or such other calamitous occasions will be avoided for making calls/visits to collect dues.
Responsibility of Board of Directors:

The Board of Directors of the Company shall -

  • Lay down the appropriate grievance redressal mechanism within the organization to resolve complaints and grievances. Such a mechanism should ensure that all disputes arising out of the decisions of lending institution’s functionaries are heard and disposed of at least at the next higher level;
  • Periodically review a consolidated report on compliances of this Code and the functioning of the grievance redressal mechanism at various levels of management;
  • 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;
  • Approve the Model Code of Conducts for Direct Selling Agents (DSAs)/ Direct Marketing Agents (DMAs) as per RBI Master Directions for adoption of the Company.
14) Complaints and Grievances:

Level 1

In case of any query/ complaint/ grievance with respect to the product and services offered by Ummeed Housing Finance Private Limited, the customer may register the complaint either by writing a letter/ email or visiting the branch office or through telephonic communication. The customer may contact our office through any of the following channels.

  • By telephonic communication at 1800 2126 127 between 10 am – 6 pm (except holidays).
  • Make an entry of query/ complaint in the Complaint Register at the branch.
  • By way of writing an email at customercare@ummeedhfc.com

Level 2

If the customer does not receive any response from the company within 30 days or is not satisfied with the resolution provided by the above channel, the customer may complaint to the Grievance Redressal Officer of by way of writing letter/ Email to:

Mr. Shariq Khan
Grievance Redressal Officer
Ummeed Housing Finance Private Limited,
Unit 809-815, 8th Floor, Tower A, Emaar Digital Greens,
Golf Course Extension Road, Sector 61, Gurugram – 122102
Email ID: shariq.khan@ummeedhfc.com.
Contact No.: 0124-4836480

It is advised to customers to provide Loan details and customer issue in detail for quick redressal. We assure you that your complaint will be looked into at the earliest.

Each customer complaint being unique in nature, can take approximately 30 days for a detailed response to respective customer query or complaint. Once, a query or a complaint is registered with the company, an acknowledgement along with a complaint reference number will be sent to the customer within 7 days. The acknowledgement will contain the name & designation of the official who will deal with the grievance. If the complaint is relayed over phone Company’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. While the concerned team works on the query / complaint towards resolution, an interim response intimating the actual time that will be taken to resolve the issue will be sent to the customer. After examining the matter, the company will send the customer its final response or explain why it needs more time to respond and will endeavour to do so within six weeks of receipt of a complaint and he/she will be informed how to take his complaint further if he/she is still not satisfied.

Level 3

In case your complaint has not been resolved to your satisfaction, you can also approach the Complaint Redressal Cell of National Housing Bank by lodging its complaints in Online mode at the link https://grids.nhbonline.org.in OR in offline mode by post, in prescribed format available at link https://nhb.org.in/citizencharter/Complaint_form.pdf on National Hosing Bank’s website. You may fill and send the form along with letters or enclosures, if any, by post or courier to the following address:

Complaint Redressal Cell
Department of Supervision
National Housing Bank
4th Floor, Core 5-A, India Habitat Centre,
Lodhi Road, New Delhi - 110 003

Publication:

The Company shall display various key aspect such as service charges, interest rates, Penal interest (if any), services offered, product information, time norms for various transactions and grievance redressal mechanism, etc. on various modes including “Notice Board”, “Booklets/ Brochures”, “Website”, “Other Modes of Display” and on “Other Issues’. The Company shall also –

  • 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; and
  • ensure that its Staffs are trained to provide relevant information about the Code & to put the Code into practice.

The Display of Information by the Company & Most Important Terms and Conditions would be made and maintained in the manner as provided in the Annex XII of the RBI’s Master Directions - Non-Banking Financial Company – Housing Finance Company (Reserve Bank) Directions, 2021 vide Circular dated February 17, 2021 or as amended from time to time by RBI.

Review of Code:

The above Policy has been formulated in compliance with the RBI’s Master Directions - Non-Banking Financial Company – Housing Finance Company (Reserve Bank) Directions, 2021 vide Circular dated Feb 17, 2021 and would be reviewed and amended either due to modifications in Directions by the RBI or annually, whichever is earlier. The Operating Procedures for implementation of the Policy, if required at any stage, shall be issued with the approval of the Managing Director.

Read More
1. BACKGROUND:

Ummeed Housing Finance Private Limited (hereinafter referred to as “the Company” or “HFC” or “Lender” or “UHFPL” or “Ummeed” or “Regulated Entity/ RE”) is a Private Limited Company incorporated under the provisions of the Companies Act, 2013 and registered as a Housing Finance Company (“HFC”) with the National Housing Bank (“NHB”).

With the shifting of regulation of HFCs from NHB to RBI, now Reserve Bank of India’s (“RBI”) vide their circular dated May 19, 2020 made Master Direction - Know Your Customer (KYC) Direction, 2016, applicable to all HFCs. Subsequently, RBI vide circular dated February 17, 2021 re-iterated applicability of the above Master Direction - Know Your Customer (KYC) Direction, 2016 in the Master Direction – Non-Banking Financial Company – Housing Finance Company (Reserve Bank) Directions, 2021.

Accordingly, this Policy earlier prepared in terms of the NHB’s Guidelines on KYC & AML, and approved by the Board, is being reviewed in the context of the RBI’s Master Direction - Know Your Customer (KYC) Direction, 2016 as applicable to NBFCs and which has been made applicable to HFCs, also.

2. OBJECTIVES:

The present policy is designed with an objective to evolve the monitoring and reporting system as prescribed in the above said RBI’s Master Directions and other relevant regulations to follow certain customer identification procedures while undertaking a transaction either by establishing an account-based relationship or otherwise and monitor their transactions.

3. SCOPE:

3.1 Applicability

The Know Your Customer and Anti-Money Laundering Policy (the Policy) shall be applicable to Ummeed as notified by the RBI from time to time. The Policy framed thereunder and approved by the Board shall also apply to any third parties relied upon or hired by the Company to perform any of the requirements relating to KYC & Anti-Money Laundering (AML) Program.

This Policy establishes minimum requirements for the Company to establish, implement, and maintain an AML Program that is reasonably designed to (a) implement this Policy and (b) to ensure compliance with applicable AML laws, rules and regulations.

This Policy requires the Company and each Employee to:

  • Protect the Company from being used for money laundering or funding terrorist activities;
  • Conduct themselves in accordance with the highest ethical standards
  • Comply with the letter and the spirit of applicable AML Laws, and the Company’s AML Program and procedures;
  • Be vigilant and escalate AML procedures in respect of individuals/entities who attempt to violate or avoid KYC /AML, procedures or this Policy; and
  • Cooperate with AML-related law enforcement and regulatory agencies fully under applicable laws.
  • Designate official for reporting purposes to Financial Intelligence Unit (FIU).

Failure to adhere to this Policy may subject employees to disciplinary action, including termination of employment. The employees who suspect unethical behavior should refer the matter to appropriate personnel as directed by their businesses’ policies and procedures.

3.2 Annual Review

The Policy shall be reviewed annually by the Board of Directors of the Company, the Principal Officer and, more frequently, if the changes are required due to modifications in applicable directions, rules and regulations.

3.3 Implementation & Monitoring of Policy

The Audit Committee (AC) shall supervise the implementation and monitoring of the Policy. Amongst other matters, the AC would be responsible for:

  • Formulating and periodically reviewing the Policy in line with the applicable regulatory guidelines;
  • Reviewing the reports submitted by the Principal Officer (PO)/ the Money Laundering reporting Officer (MLRO) from time to time;
  • Instituting an KYC/AML training program;
  • Establishing appropriate internal controls, procedures and systems in regard to fraud prevention, KYC/AML etc.

3.4 Policy Approval

The Policy and any significant changes therein shall be approved by the Board of Directors of the Company. Prior to approval by the Board of Directors, the Policy and any significant changes shall also be reviewed by the Audit Committee of the Board, taking into account the feedback of Company’s Principal Officer and also based on internal audit report on implementation of KYC and AML procedures which have been brought under the scope of internal audit.

4. POLICY STANDARDS AND AML PROGRAM STRUCTURE

4.1 The KYC and AML Policy has been prepared considering the following 4 key elements:

  • Customer Acceptance Policy (CAP)
  • Customer identification Procedures (CIP)
  • Monitoring of Transactions, and
  • Risk Categorization

4.2 For the purpose of the Policy, a ’Customer’ is defined as:

  • a person or entity (including an employee) that maintains an account and/or has a business relationship with the Company.
  • one on whose behalf the account is maintained (i.e. the beneficial owner);
  • beneficiaries of transactions conducted by professional intermediaries, such as Stock Brokers, Chartered Accountants, Solicitors etc. as permitted under the law, and
  • any person or entity connected with a financial transaction which can pose significant reputational or other risks to the Company, say, a wire transfer or issue of a high value demand draft as a single transaction.

4.3 Beneficial Owner (BO)

  • Where the customer is a company, the beneficial owner is the natural person(s), who, whether acting alone or together, or through one or more juridical persons, has/have a controlling ownership interest or who exercise control through other means.

    Explanation- For the purpose of this sub-clause-

    • “Controlling ownership interest” means ownership of/entitlement to more than 25 per cent of the shares or capital or profits of the company.
    • “Control” shall include the right to appoint majority of the directors or to control the management or policy decisions including by virtue of their shareholding or management rights or shareholders agreements or voting agreements.
  • Where the customer is a partnership firm, the beneficial owner is the natural person(s), who, whether acting alone or together, or through one or more juridical person, has/have ownership of/entitlement to more than 15 per cent of capital or profits of the partnership.
  • Where the customer is an unincorporated association or body of individuals, the beneficial owner is the natural person(s), who, whether acting alone or together, or through one or more juridical person, has/have ownership of/entitlement to more than 15 per cent of the property or capital or profits of the unincorporated association or body of individuals.

    Explanation: Term ‘body of individuals’ includes societies. Where no natural person is identified under (a), (b) or (c) above, the beneficial owner is the relevant natural person who holds the position of senior managing official.

  • Where the customer is a trust, the identification of beneficial owner(s) shall include identification of the author of the trust, the trustee, the beneficiaries with 15% or more interest in the trust and any other natural person exercising ultimate effective control over the trust through a chain of control or ownership.

4.4 Certified Copy- Obtaining a certified copy by the Company shall mean comparing the copy of the proof of possession of Aadhaar number where offline verification cannot be carried out or officially valid document so produced by the customer with the original and recording the same on the copy by the authorised officer of the Company as per the provisions contained in the Act.

4.5 The Company is aware that availability of sufficient customer information underpins all other AML procedures and should be seen as a critical element in the effective management of Money Laundering (ML) risks

4.6 Customer Acceptance Policy (CAP)

The Company has evolved a Customer Acceptance Policy (CAP) which lays down the criteria for the acceptance of Customers. In line with the RBI’s Master Direction - Know Your Customer (KYC) Direction, 2016, the Company has formulated Customer Acceptance Policy (CAP) which lays down the broad criteria for acceptance of customers which forms an integral part of the Group AML Policy.

The features of the CAP are detailed below:

  • The Company shall not open any account(s) in anonymous, fictitious or 'benami' name(s). Adequate customer due diligence (CDD) is a fundamental requirement for establishing the identity of the customer. Identity generally means a set of attributes which together uniquely identify a natural person or legal entity. CDD Procedure is followed for all the joint account holders, while opening a joint account.
  • Where Permanent Account Number (PAN) is obtained, the same shall be verified from the verification facility of the issuing authority.
  • Where an equivalent e-document is obtained from the customer, Company shall verify the digital signature as per the provisions of the Information Technology Act, 2000 (21 of 2000).
  • In order to avoid fictitious and fraudulent applications of the customers, and to achieve a reasonable degree of satisfaction as to the identity of the customer, the Company shall conduct appropriate basic due diligence.
  • The nature and extent of basic due diligence measures to be conducted at the time of establishment of account opening/relationship, would depend upon the risk category of the customers and involve collection and recording of information by using reliable independent documents, data or any other information. This may include identification and verification of the applicant and wherever relevant, ascertaining of occupational details, legal status, ownership and control structure and any additional information in line with the assessment of the ML risks posed by the applicant and the applicant’s expected use of The Company’s products and services.
  • If allowed by the regulations, the Company may rely upon the KYC procedures conducted by other Banks/ Intermediaries having satisfactory customer identification procedures.
  • For non-face to face customers, appropriate due diligence measures (including certification requirements of documents, if any) will be devised for identification and verification of such customers. With regard to cross border customers, Company may rely on third party certification/introduction. In such cases it shall be ensured that the third party is a regulated and supervised entity and has adequate KYC systems in place.
  • The purpose of commencing the relationship/opening of accounts shall be established and the beneficiary of the relationship/account shall also be identified.
  • The information collected from the customer shall be kept confidential.
  • Appropriate Enhanced Due Diligence (EDD) measures shall be adopted for customers, with a high-risk profile, especially those for whom the sources of funds are not clear, transactions carried through correspondent accounts and customers who are Politically Exposed Persons (PEPs), resident outside India and their family members/close relatives.
  • In respect of unusual or suspicious transactions/applications or when the customer moves from a low risk to a high-risk profile, appropriate EDD measures shall be adopted.
  • The Company shall ensure that the identity of the customer does not match with any person with known criminal background or with banned entities such as individual terrorists or terrorist organizations, etc. For this purpose, the Company shall maintain lists of individuals or entities issued by Reserve Bank, National Housing Bank, United Nations Security Council, other regulatory & enforcement agencies, internal lists as the Company may decide from time to time. Full details of accounts/ customers bearing resemblance with any of the individuals/entities in the list shall be treated as suspicious and reported.
  • The Company shall not open an account where it is unable to apply appropriate customer due diligence measures i.e., it is unable to verify the identity and /or obtain documents required due to non-cooperation of the customer or non-reliability of the data/information furnished to the Company.
  • Where the Company is unable to apply appropriate KYC measures due to non-furnishing of information and /or non-cooperation by the customer, the Company may consider closing the account or terminating the business relationship. However, the decision to close an existing account shall be taken at a reasonably senior level, after giving due notice to the customer explaining the reasons for such a decision.

The aspects mentioned in the CAP would be reckoned while evolving the KYC/AML procedures for various customers/products. However, while developing the KYC/CDD procedures, the Company shall ensure that its procedures do not become too restrictive or pose significant difficulties in availing its services by deserving general public, especially the financially and socially disadvantaged sections of society.

4.7 Customer Identification Procedures

  • The Company shall obtain satisfactory evidence of the identity of the customer in the following cases:
    • If there is any perceived risks at the time of commencement of relationship/opening of account, or
    • when there is a doubt about the authenticity or adequacy of the customer identification data it has obtained, or
    • selling third party products as corporate agents, selling own products and any other product for more than rupees fifty thousand, or
    • when there is a reason to believe that a customer is intentionally structuring a transaction into a series of transactions below the threshold of rupees fifty thousand.

    Such evidences shall be substantiated by reliable independent documents, data or information or other means like physical verification etc.

  • Company shall ensure that introduction is not to be sought while opening accounts.
  • In order to avoid customer inconvenience, under special circumstances, the Company may also rely on certain data/information available with itself or with external reliable sources for the purpose of establishing the identity of the customer. In such cases, a KYC report in a specified format shall be prepared and approved by an appropriate senior official, as may be specified in the KYC/AML procedures. The KYC report shall be stored properly along with other KYC documents.
  • For opening of small value accounts, informal customer segment and smaller/ Semi- urban/ rural location, the Company may, at its discretion, apply differential procedures and provide relaxation in documentation and CDD requirements based on alternate verifications/ documents.
  • Indicative guidelines on Customer Identification requirements are provided in the Annexure 1.

4.8 Money Laundering and Terrorist Financing Risk Assessment

The Company shall undertake, that:

  • Periodic Risk Assessment’ exercise for ‘Money Laundering (ML) and Terrorist Financing (TF);
  • Risk assessment process should consider all the relevant risk factors, level of overall risk & type of mitigation to be applied;
  • Risk assessment process shall be properly documented and be proportionate to the nature, size, geographical presence, complexity of activities/structure, etc. of the Company;
  • Periodicity of risk assessment exercise shall be determined by the Board, which should be reviewed at least annually;
  • Outcome of the exercise shall be put up to the Board/ Audit Committee;
  • Risk Based Approach (RBA) for mitigation and management of the identified risk and should have Board approved policies, controls and procedures in this regard;
  • Monitoring of implementation of the controls and enhance them if necessary.

4.9 Risk Categorization

Ummeed shall categorize its customers into High and Low, based on the perceived AML risk.

  • High Risk from AML perspective- Customers that are likely to pose a higher-than-average risk to the Company may be categorized as high risk depending on customer's background, nature and location of activity, country of origin, sources of funds and his client profile, etc. The Company shall apply enhanced due diligence measures for higher risk customers, especially those for whom the sources of funds are not clear. Such category of customers will include the following:
    • Politically Exposed Persons (PEP’s);
    • Non-Resident Indians;
    • Certain Non-Governmental Organizations (“NGOs”), Trusts and unregulated charities;
    • Money services businesses (“MSBs”), including licensed money transmitters and currency exchangers, and their owners;
    • Dealers in high value or precious goods, such as jewel, gem or precious metal dealers, antique dealers and auction houses, and their owners;
    • Casinos and other gambling businesses, their payment providers, and their owners;
    • Arms and ammunitions manufacturers and dealers;
    • Customers organized, doing business in, or that maintain financial accounts in, jurisdictions that pose a high risk of money laundering, drug trafficking, terrorism, terrorist financing, or corruption or jurisdictions that are not logical for the customer;
    • High Net Worth individuals, with Loan amount of more than Rs.3 crore;
    • Persons (individual or entity) known to the Business Unit to have been convicted of money laundering, drug trafficking, terrorist acts, terrorist financing or other serious crimes.
  • All other customers (other than High Risk category) whose identities and sources of wealth can be easily identified and by and large conform to the known customer profile, may be categorized as low risk. In such cases, only the basic requirements of verifying the identity and location of the customer are to be met.
  • In terms of extant regulatory guidelines, the Company will put in place a system of periodical review of risk categorization of accounts and the need for applying enhanced due diligence measures in case of higher risk perception on a customer. The Company will carry such review of risk categorization of customers at a periodicity of not less than once in six months. The Company shall also introduce a system of periodical updation of customer identification data (including photograph/s) after the account is opened. The periodicity of such updation will not be less than once in five years in case of low-risk category customers and not less than once in two years in case of high risk categories.

4.10 Ummeed shall, inter alia, use the following tools to mitigate AML risk:

  • KYC documentation
  • Customer due diligence
  • Dedupe check
  • CIBIL Checks with credit scores
  • Reference checks
  • Tele verification
  • Field Investigation
  • Limit on amount of loan in cash
  • Suspicious transaction reporting
  • Checking whether amount of jewelry or loan is in line with disclosed sources of income and wealth

4.11 KYC and Customer Due Diligence (CDD)

The Company shall identify the beneficial owner and take all reasonable steps to verify his identity. It shall also exercise on-going due diligence with respect to the business relationship with every client and closely examine the transactions in order to ensure that they are consistent with their knowledge of the customer, his business and risk profile.

For undertaking CDD, following should be obtained from an individual while establishing an account-based relationship or while dealing with the individual who is a beneficial owner, authorised signatory or the power of attorney holder related to any legal entity:

  • the Aadhaar number where,(i) he is desirous of receiving any benefit or subsidy under any scheme notified under section 7 of the Aadhaar (Targeted Delivery of Financial and Other subsidies, Benefits and Services) Act, 2016 (18 of 2016); or he decides to submit his Aadhaar number voluntarily to a bank or any RE notified under first proviso to sub- section (1) of section 11A of the PML Act; or the proof of possession of Aadhaar number where offline verification can be carried out; or the proof of possession of Aadhaar number where offline verification cannot be carried out or any OVD or the equivalent e- document thereof containing the details of his identity and address; and
  • the Permanent Account Number or the equivalent e-document thereof or Form No. 60 as defined in Income-tax Rules, 1962. Where Permanent Account Number (PAN) is obtained, the same shall be verified from the verification facility of the issuing authority; and
  • such other documents including in respect of the nature of business and financial status of the customer, or the equivalent e-documents thereof as may be required:

Provided that where the customer has submitted,

  • Aadhaar number, authentication of the customer’s Aadhaar number using e-KYC authentication facility provided by the Unique Identification Authority of India. Further, in such a case, if customer wants to provide a current address, different from the address as per the identity information available in the Central Identities Data Repository, he may give a self-declaration to that effect.
  • proof of possession of Aadhaar where offline verification can be carried out, the same shall be done.
  • an equivalent e-document of any OVD, then, shall verify the digital signature as prescribed.
  • any OVD or proof of possession of Aadhaar number, where offline verification cannot be carried out, verification to be carried out through digital KYC process as prescribed.

Provided further that in case e-KYC authentication cannot be performed for an individual desirous of receiving any benefit or subsidy under any scheme notified under section 7 of the Aadhaar (Targeted Delivery of Financial and Other subsidies, Benefits and Services) Act, 2016 owing to injury, illness or infirmity on account of old age or otherwise, and similar causes, shall, apart from obtaining the Aadhaar number, perform identification preferably by carrying out offline verification or alternatively by obtaining the certified copy of any other OVD or the equivalent e-document thereof from the customer.

Note 1: where its customer submits a proof of possession of Aadhaar Number containing Aadhaar Number, ensure that such customer redacts or blacks out his Aadhaar number through appropriate means where the authentication of Aadhaar number is not required.

Note 2: Biometric based e-KYC authentication can be done by bank official/business correspondents/business facilitators.

Note 3: The use of Aadhaar, proof of possession of Aadhaar etc., shall be in accordance with the Aadhaar (Targeted Delivery of Financial and Other Subsidies Benefits and Services) Act, 2016 and the regulations made thereunder and as amended from time to time.

Note 4: REs other than banks can only carry out Offline Verification of Aadhaar for identification.

Note 5: For opening an account of a Legal Person who is not a natural person, the beneficial owner(s) shall be identified and all reasonable steps in terms of Rule 9(3) of the Rules to verify his/her identity shall be undertaken keeping in view the following:

  • (a) Where the customer or the owner of the controlling interest is a company listed on a stock exchange, or is a subsidiary of such a company, it is not necessary to identify and verify the identity of any shareholder or beneficial owner of such companies.
  • (b) In cases of trust/nominee or fiduciary accounts whether the customer is acting on behalf of another person as trustee/nominee or any other intermediary is determined. In such cases, satisfactory evidence of the identity of the intermediaries and of the persons on whose behalf they are acting, as also details of the nature of the trust or other arrangements in place shall be obtained.
5. Enhanced Due Diligence (“EDD”)

The Company will include reasonable risk based EDD procedures for its higher risk customers.

The EDD procedures should assist the Company in (a) determining whether the customer appears to be engaged in legitimate business activities and has legitimate sources of funds and (b) anticipating the customer’s usual and expected activity so that suspicious activity can be detected. Higher-risk customers must be approved by a Zonal Credit Manager level or minimum grade of General Manager and the customer’s transactions should be reviewed more closely at account opening and more frequently throughout the term of their relationship.

The Company’s EDD procedures will consider requiring, at account opening stage that additional information and documentation be obtained on higher risk customers, for example, such as:

  • Purpose of the account/ End-use.
  • Source of funds and wealth.
  • Individuals with ownership or control over the account, such as beneficial owners, signatories, or guarantors.
  • Financial statements
  • Banking references
  • Domicile (where the business is organized)
  • Citizenship or nationality for individuals
  • Proximity of the customer’s residence, place of employment, or place of business
  • Description of the customer’s primary trade area and whether international transactions are expected to be routine
  • Description of the business operations, the anticipated types, volumes and frequency of transactions, including currency and total sales, and a list of major customers and suppliers.
  • Explanations for changes in account activity

The Company’s EDD procedures will consider requiring, periodically throughout the relationship that additional information and documentation be obtained on higher risk customers (who have moved from low risk to high risk), such as:

  • Updation of KYC documents in every 2 years.
  • EDD is an ongoing process and the Company should take measures to ensure that information is current, and that appropriate risk-based monitoring occurs to ensure that any suspicious activity is escalated, analyzed, and reported, and that other appropriate action is taking.
6. Politically Exposed Persons (“PEPs”)

Politically exposed persons are individuals who are or have been entrusted with prominent public functions in a foreign country, e.g., Heads of States or of Governments, senior politicians, senior government/judicial/military officers, senior executives of state-owned corporations, important political party officials, etc. The Company shall gather sufficient information on any person/customer of this category intending to establish a relationship and check all the information available on the person in the public domain.

7. Negative List

The branches of Ummeed shall maintain a local negative list of persons, to the extent it is possible, and after a thorough name check of the client base by the respective branches, it will ascertain if there is any such match. In the event of a match against one of the local negative lists that is of credit related nature only (no other negativities associated with the name), the PO/ MLRO or any other person with appropriate authority shall have the discretion to approve acceptance of the client/prospect.

8. Sanctions List

Ummeed will comply with the various statutory/ regulatory requirements with regard to Sanctions List of individuals/ groups. In this regard, Ummeed will also comply with the order issued by the Government of India for implementation of Section 51-A of UAPA, 1967. The Company shall update list of such individuals/ entities from time to time based on the advice received from the Government/ Statutory/ Regulatory authorities.

The Company shall not enter into any transaction with a customer whose identity matches with any person with known criminal background or with banned entities and those reported to have links with terrorists or terrorist organizations identified by the Government/ Statutory/ Regulatory authorities. In case, any match is identified with any entity provided in the Sanctions List, the Company shall strictly follow the procedure required to be followed under the legal/ statutory/ regulatory requirements.

The Company shall also take the reference of updated published list of Financial Action Task Force (FATF) of the jurisdictions not fully /partly complying with the FATF Guidelines and ensuring that credentials of none of the existing /new customers matching with the details of persons/entity falling into non-compliance jurisdictions of FATF.

9. APPOINTMENT OF THE PRINCIPAL OFFICER (PO) / MONEY LAUNDERING REPORTING OFFICER (MLRO) & DESIGNATED DIRECTOR.

A senior official of the Company shall be designated as the Principal Officer of the Company. The Principal Officer shall be responsible for overseeing and managing the AML Implementation ensuring the compliance of the Regulatory Directions. The Principal Officer shall be responsible for the day-to-day functioning of the Company’s AML Implementation and must have the knowledge, sufficient independence, authority, time and resources to manage and mitigate the AML risks of the business.

Also, the MD & CEO of the company shall also be the Designated Director for reporting purposes and the same shall be communicated to the FIU or other regulatory institutions.

Explanation: The term “Senior Official” mean and include an official of the Company not below the rank of General Manager or immediately below the level of MD or CEO.

Key Responsibilities of the Principal Officer (PO)/ MLRO

  • The PO shall develop effective AML programs, including programs to provide AML training to business personnel.
  • The PO must be able to assist the respective business heads to assess the ways in which products (existing or under development) may be abused by money launderers.
  • The PO must be capable of assisting the respective business heads to evaluate whether any activity is suspicious under the Ummeed standard and under any applicable local law.
  • Monitoring the implementation of the company’s KYC/AML policy.
  • Reporting of transactions and sharing of the information as required under the law.
  • Maintaining liaison with regulatory authorities.
  • Ensuring submission of periodical reports to the top Management / Board.
  • Organizing continual training of employees to make them aware and keep them up to date with requirements of PMLA and any amendments thereto.
  • Review all reports required to be submitted to regulatory/law enforcement authorities
  • Reporting to the FIU-IND
  • Monitoring of compliance and exception reporting.

Key Responsibilities of the Designated Director

  • Review the reports to be submitted to FIU.
  • Ensure compliance to guidelines issued.
  • Attend meetings/conferences organized by FIU or other regulatory bodies.
10. REPORTING TO FINANCIAL INTELLIGENCE UNIT-INDIA

Section 12 of PMLA requires every housing finance company to report information of transaction referred to in clause (a) of sub-section (1) of Section 12 read with Rule 3 of the PML Rules relating to cash and suspicious transactions etc. to the Director, Financial Intelligence Unit-India (FIU-IND). Company shall furnish to the Director, Financial Intelligence Unit-India (FIU-IND), information referred to in Rule 3 of the PML (Maintenance of Records) Rules, 2005 in terms of Rule 7 thereof.

The reporting formats and comprehensive reporting format guide, prescribed/ released by FIU-IND and Report Generation Utility and Report Validation Utility developed to assist reporting entities in the preparation of prescribed reports shall be taken note of. The editable electronic utilities to file electronic Cash Transaction Reports (CTR) / Suspicious Transaction Reports (STR) which FIU-IND has placed on its website shall be made use of by the Company, till installation /adoption of suitable technological tools for extracting CTR/STR from live transaction data.

The Principal Officers shall make suitable arrangement to cull out the transaction details from branches which are not yet computerized and to feed the data into an electronic file with the help of the editable electronic utilities of CTR/STR as have been made available by FIU-IND on its website “http://fiuindia.gov.in”.

Principal Officer shall ensure there is no delay in reporting a transaction as delay of each day in rectifying a mis-represented transaction beyond the time limit as specified in the Rule shall be constituted as a separate violation.

Company shall not put any restriction on operations in the accounts where an STR has been filed and ensure that there is no tipping off by officials of the Company to the customer at any level. Officials keep the fact of furnishing of STR strictly confidential.

Robust software, throwing alerts when the transactions are inconsistent with risk categorization and updated profile of the customers shall be put in to use as a part of effective identification and reporting of suspicious transactions.

11. Reporting of Cash Transactions
  • Cash Transaction Report- In accordance with the requirements under PMLA, the Company will file Cash Transaction Report (CTR) for each month to FIU -IND by 15 days of the succeeding month. CTR should include the following:
    • all cash transactions of the value of more than rupees ten lakh or its equivalent in foreign currency;
    • all series of cash transactions integrally connected to each other which have been valued below rupees ten lakh or its equivalent in foreign currency where such series of transactions have taken place within a month and the aggregate value of such transactions exceeds rupees ten lakh
  • Counterfeit Currency Report - In addition to the above, all cash transactions, where forged or counterfeit Indian currency notes have been used as genuine will also be reported by the Company to FIU-IND as Counterfeit Currency Report (CCR) not later than seven working days from the date of occurrence of such transactions. These cash transactions should also include transactions where forgery of valuable security or documents has taken place.
  • According to the revised Master Directions, effective from February 17, 2021, the company shall ensure to furnish a quarterly report to the NHB along the lines of Annexure-VI (copy enclosed) of the Reserve Bank of India (RBI) Master Circular-Detection and Impounding of Counterfeit Notes dated July 01, 2020, as amended from time to time, and similar instructions issued by the Bank. The above report should be furnished to the NHB within 7 days of the end of the quarter. A "nil" report should be sent in case no counterfeit has been detected during the quarter. (Refer to instructions under para 108.2 Chapter XIV – Miscellaneous instructions of the Master Directions.)
12. Suspicious Transactions Monitoring and Reporting-

In accordance with suspicious transactions monitoring and reporting laws the Company will establish risk-based procedures and manual processes or automated systems, for monitoring transactions to identify, investigate, and escalate potentially suspicious activity; report suspicious activity to appropriate government authorities, and take other appropriate action, such as terminating a customer relationship. The Company’s Principal Officer is charged with the responsibility of coordinating and overseeing suspicious activity monitoring, including making reports to the FIU -IND.

The Company will file the Suspicious Transaction Report (STR) to FIU -IND within 7 days of arriving at a conclusion that any transaction, whether cash or non-cash, or a series of transactions integrally connected are of suspicious nature. The Principal Officer should record his reasons for treating any transaction or a series of transactions as suspicious. It should be ensured that there is no undue delay in arriving at such a conclusion once a suspicious transaction report is received from a branch or any other office. The Principal Officer will be responsible for timely submission of CTR and STR to FIU-IND.

An illustrative list of Suspicious Transactions is enclosed as Annexure II of the Policy.

Confidentiality and Prohibition against disclosing Suspicious Activity Investigations and Reports- The Company will maintain utmost confidentiality in investigating suspicious activities and while reporting STR to the FIU-IND/ higher authorities. A Company Employee shall hold in strict confidence and not disclose to any third party a STR, information from or related to a STR, or the fact that a STR has been filed. Internally, only Employees with a need to know, such as investigators, attorneys involved in the investigation, Employees who must review and approve the STR, and auditors, can have access to STR related information.

The Company will ensure that the customer is not tipped off on the STRs made by them to FIU- IND.

However, the Company may share the information pertaining to the customers with the statutory/ regulatory bodies and other organizations such as banks, credit bureaus, income tax authorities, local government authorities etc.

13. RECORDKEEPING REQUIREMENTS

13.1 The Company shall introduce a system of maintaining proper record of transactions as required with reference to provisions of PML Act and Rules, as mentioned below:

  • To maintain all necessary records of transactions between the Company and the customer, both domestic and international, for at least five years from the date of transaction;
  • To make available the identification records and transaction data to the competent authorities upon request;
  • To introduce a system of maintaining proper record of transactions prescribed under Rule 3 of Prevention of Money Laundering (Maintenance of Records) Rules, 2005 (PML Rules, 2005);
  • maintain records of the identity and address of their customer, and records in respect of transactions referred to in Rule 3 in hard or soft format.
  • all cash transactions of the value of more than rupees ten lakh or its equivalent in foreign currency;
  • all series of cash transactions integrally connected to each other which have been valued below rupees ten lakh or its equivalent in foreign currency where such series of transactions have taken place within a month and the aggregate value of such transactions exceeds rupees ten lakh;
  • all transactions involving receipts by non-profit organizations of rupees ten lakhs or its equivalent in foreign currency;
  • all cash transactions where forged or counterfeit currency notes or bank notes have been used as genuine and where any forgery of a valuable security or a document has taken place facilitating the transactions; and
  • all suspicious transactions whether or not made in cash and by way of as mentioned in the Rule 3(1) (D).
  • records of the identity of all clients of the Company shall be maintained for a period of eight years from the date of cessation of transactions between the clients and the Company.

13.2 Records to contain the specified information- The above records, in terms with Rule 3 of the PMLA Rules, to contain the following information:

  • the nature of the transactions;
  • the amount of the transaction and the currency in which it was denominated;
  • the date on which the transaction was conducted; and
  • the parties to the transaction.

13.3 The Company shall take appropriate steps to evolve a system for proper maintenance and preservation of information in a manner that allows data to be retrieved easily and quickly whenever required or when requested by the competent authorities.

14. HIRING & TRAINING OF EMPLOYEES AND CUSTOMER EDUCATION

Implementation of KYC Procedures requires the Company to seek information which may be of personal nature or which has hitherto never been called for. This can sometimes lead to a lot of questioning by the customer as to the motive and purpose of collecting such information. To meet such situation it is necessary that the customers are educated and apprised about the sanctity and objectives of KYC procedures so that the customers do not feel hesitant or have any reservation while passing on the information to the Company.

Employees: The Company shall put in place adequate screening mechanism as an integral part of employee recruitment/ hiring process. The Company shall train its employees (or the functions/groups) on KYC/ AML requirements/ procedures. The training requirements shall have different focus for frontline staff, compliance staff and staff dealing with new customers. The front desk staff should be specially trained to handle issues arising from lack of customer education. Proper staffing of the audit function with persons adequately trained and well-versed in KYC/AML Measures policies of the HFC, regulation and related issues should be ensured.

Customers: To educate the customers and win their confidence in this regard, the Company will arrange literature containing all the relevant information regarding KYC and AML measures. Such literature may be made available to the customers either directly or through the Company’s website. Further, the Company staff will attend to the same promptly and explain reason for seeking any specific information and satisfy the customer in that regard.

15. AUDIT OF THE KYC & AML PROGRAM AND OTHER REPORTING REQUIREMENTS

To provide reasonable assurance that its AML Program is functioning effectively, an audit of its AML Program will be done as part of the internal audit of the Company. The audit will be conducted on a regular basis. The audit will include testing of the effectiveness of elements of the AML Program, compliance with applicable AML Laws, and the Company’s related procedures.

The audit findings and compliance thereof will be put up before the Audit Committee of the Board on quarterly intervals till closure of audit findings.

The Company shall develop a system of audit for the IT framework and compliance with Rules 114F, 114G and 114H of Income Tax Rules.

The books of accounts of persons authorised by Company including brokers/ DSAs or the like, so far as they relate to brokerage functions of the company, shall be made available for audit and inspection whenever required.

16. CONSEQUENCES OF NON-COMPLIANCE

Failure to adhere to this Policy, the Company’s AML Program, shall subject the Company’s employees to disciplinary action, up to and including, termination of employment.

Annexure I

A. CUSTOMER IDENTIFICATION MINIMUM REQUIREMENTS- INDICATIVE GUIDELINES

Trust/Nominee or Fiduciary Accounts

There exists the possibility that trust/nominee or fiduciary accounts can be used to circumvent the customer identification procedures. The Company will determine whether the customer is acting on behalf of another person as trustee/nominee or any other intermediary. If so, The Company will insist on receipt of satisfactory evidence of the identity of the intermediaries and of the persons on whose behalf they are acting, as also obtain details of the nature of the trust or other arrangements in place. While opening an account for a trust, The Company will take reasonable precautions to verify the identity of the trustees and the settlors of trust (including any person settling assets into the trust), grantors, protectors, beneficiaries and signatories. In the case of a 'foundation', steps should be taken to verify the founder managers/ directors and the beneficiaries, if defined.

For opening an account of a trust, one certified copy of each of the following documents or the equivalent e-documents shall be obtained:

  • Registration certificate;
  • Trust deed;
  • Permanent Account Number or Form No.60 of the trust;
  • one copy of an OVD containing details of identity and address, one recent photograph and Permanent Account Numbers of Form 60 of the beneficial owner, managers, officers or employees, as the case may be, holding an attorney to transact on its behalf.

Accounts of companies and firms

The Company will be vigilant against business entities being used by individuals as a ’front’ for maintaining accounts with banks or REs. The Company will examine the control structure of the entity, determine the source of funds and identify the natural persons who have a controlling interest and who comprise the management. These requirements may be moderated according to the risk perception e.g. in the case of a public company it will not be necessary to identify all the shareholders.

For opening an account of a company/ firm, one certified copy of each of the following documents or the equivalent e-documents shall be obtained:

  • Certificate of incorporation/ Registration Certificate;
  • Memorandum and Articles of Association / Partnership deed;
  • Permanent Account Number of the company/ firm;
  • A resolution from the Board of Directors and/ or power of attorney granted to its managers, officers, Partner or employees to transact on its behalf;
  • one copy of an OVD containing details of identity and address, one recent photograph and Permanent Account Numbers of Form 60 of the beneficial owner, the managers, officers, Partners or employees, as the case may be, holding an attorney to transact on the company’s/ Partnership behalf.
  • Client accounts opened by professional intermediaries

    When the Company has knowledge or reason to believe that the client account opened by a professional intermediary is on behalf of a single client, that client will be identified as per procedure listed above or as per this policy.

    Accounts of Politically Exposed Persons(PEPs) resident outside India

    Politically exposed persons are individuals who are or have been entrusted with prominent public functions in a foreign country, e.g., Heads of States or of Governments, senior politicians, senior government/judicial/military officers, senior executives of state-owned corporations, important political party officials, etc. The Company will gather sufficient information on any person/customer of this category intending to establish a relationship and check all the information available on the person in the public domain. The Company will verify the identity of the person and seek information about the sources of funds before accepting the PEP as a customer. The decision to open an account for PEP will be taken by a Zonal Credit Manager level or minimum grade of General Manager. The above norms may also be applied to the accounts of the family members or close relatives of PEPs.

    Accounts of non-face-to-face customers

    In the case of non-face-to-face customers, apart from applying the usual customer identification procedures, there will be specific and adequate procedures to mitigate the higher risk involved. Certification of all the documents presented will be insisted upon and, if necessary, additional documents will be called for as deems required by the Company for effective CDD and Identification per applicable RBI directions or PMLA or Rules made thereunder.

    B. INDICATIVE LIST OF THE NATURE AND TYPE OF DOCUMENTS/ INFORMATION

    For purpose of this policy “Officially Valid Document” (OVD) shall means:

    • Passport;
    • Driving License;
    • Proof of Possession of Aadhaar Number;
    • Voter's Identity Card issued by the Election Commission of India;
    • Job card issued by NREGA duly signed by an officer of the State Government;
  • Letter issued by the National Population Register containing details of name and address;

Provided that:

  • Where the customer submits his proof of possession of Aadhaar number as an OVD, he may submit it in such form as are issued by the Unique Identification Authority of India;
  • Where the OVD furnished by the customer does not have updated address, the following documents or the equivalent e-documents thereof shall be deemed to be OVDs for the limited purpose of proof of address:
    • Utility bill which is not more than two months old of any service provider (electricity, telephone, post-paid mobile phone, piped gas, water bill);
    • property or Municipal tax receipt;
    • pension or family pension payment orders (PPOs) issued to retired employees by Government Departments or Public Sector Undertakings, if they contain the address;
    • letter of allotment of accommodation from employer issued by State Government or Central Government Departments, statutory or regulatory bodies, public sector undertakings, scheduled commercial banks, financial institutions and listed companies and leave and license agreements with such employers allotting official accommodation;
  • the customer shall submit OVD with current address within a period of three months of submitting the documents specified at ’b’ above
  • where its customer submits a proof of possession of Aadhaar Number containing Aadhaar Number, ensure that such customer redacts or blacks out his Aadhaar number through appropriate means.

Explanation: For the purpose of this clause, a document shall be deemed to be an OVD even if there is a change in the name subsequent to its issuance provided it is supported by a marriage certificate issued by the State Government or Gazette notification, indicating such a change of name.

A. KYC DOCUMENTS LIST
Parameters Features
KYC - Know Your Company
  • Norms issued by our regulators (both RBI & NHB) are to be followed as applicable from time to time.
  • The KYC to be completed for all borrowers /co-borrowers.
KYC-Photograph
  • Latest Passport Size colored photographs
  • Self-attested with cross signatures (by all applicants)
KYC - Identity proof (Any one with photo for Individual).

For Individuals:

  • Passport (not expired) Pan Card
  • Aadhar Card Driving License Voters ID Card
  • Identity card issued by Government body Certificate issued by any government authority.
  • Photo debit card issued by a Scheduled Commercial Bank
  • Valid Arms license issued by Central / State government / Union Territory with Name, Photograph and signature (Identity Proof).
  • Letter issued by a gazetted officer with a duly attested photograph of the person.

For Non Individuals/business entities :

  • Shops & Establishment Certificate Trade License Certificate
  • SSI Registration Certificate
  • PAN Card/Sales Tax/ VAT Registration Certificate
  • Partnership Deed (for firms) / Memorandum of Association (MOA) for companies
  • Export-Import Code Certificate
  • Professional qualification Certificate and Degree Certificate for professionals with photo.
  • Last available Income Tax Assessment order. Latest available Wealth Tax Assessment order.
  • Certificate Issued by SEZ, STP, EHTP, DTA and EPZ in the name of the entity mentioning the address allotted.
  • Any other certificate of registration issued by professional bodies such as ICAI / ICSI / ICWAI in the name of the firm.
  • TDS Certificate in the name of entity issued by Scheduled Commercial Banks, FI & FIIs, MFs, PSUs (Central & State), Govt. Dept., Local Self Government (Municipal Corporation etc.) and Government Bodies.
  • Factory Registration Certificate.
Date of Birth Proof (any one)
  • Passport PAN Card Aadhar Card
  • Voter ID Card clearly mentioning the exact date of birth Driving License
  • Birth Certificate (issued by Government body) School Leaving certificate (1Oth)
  • Employee ID (only for PSU/Govt. employees)
  • Letter issued by a gazetted officer with a duly attested photograph of the person
  • High School Mark sheet/High School Passing Certificate
KYC- Residence Address proof (any one)

For Individuals

  • Passport Driving License Voters ID card
  • Aadhar Card subject to positive Residence FI (at the same address as mentioned on Aadhar card)
  • Ration Card
  • Utility bill (any one from latest 3 months from date of application.)
  • Latest post-paid mobile bill (last 2 months).
  • Rent agreement on stamp Paper(registered or notarized)
  • Bank Statements reflecting address of borrowers of any commercial bank (Nationalized / Scheduled commercial bank)
  • Sale Deed of the property, if owned.
  • Certificate issued by ward officer, maintaining election roll certifying address of the applicant.
  • Property tax bill / receipt
  • Letter issued by a gazetted officer with a duly attested photograph of the person

*In case of close relatives, e.g. husband, wife, son, daughter and parents, etc. who live with their wife, husband, father/mother, daughter and son, who do not have officially valid document for address verification, then, in such cases, OVD for proof of address and identity of the relative with whom the prospective customer is living together with a declaration from the relative that the said person (prospective customer) proposing to open an loan account is a relative and is staying with her/him. (Only applicable for low risk profile customers from AML perspective).

**For high risk profile customers (from AML perspective) enhanced customer due diligence is required and relationship proof will not suffice.

Non-Individuals / Business entities

  • Shops & Establishment Certificate/ Trade License Certificate/ SSI Registration Certificate/ Sales Tax/ VAT Registration
  • Certificate/Partnership Deed (for firms)/ Memorandum / of Association (MOA) for companies/ Export-Import Code Certificate / Factory Registration Certificate
  • Letter from existing banker (restricted to a Scheduled Commercial Bank & Scheduled Co-operative Banks). Letter has to be obtained in original on Bank’s letterhead paper bearing the authorizing officers name and signature along with the stamp of the bank. The verification done should be for the name, photograph and address of the individual.
  • Letter issued by a gazette officer with a duly attested photograph of the person
KYC — Office Address Proof (any one)

Individuals

  • Sales tax registration
  • Shops & Establishment certificate Trade License Certificate
  • Utility bill (anyone from latest 3 months from date of application.)
  • Rent agreement on stamp Paper (registered or notarized)
  • Sale Deed of the property, if owned Property tax bill / receipt
  • Non-Individuals / Business entities
  • Shops & Establishment Certificate/Trade License Certificate/SSI Registration Certificate/Sales Tax/ VAT Registration
  • Certificate/Partnership Deed (for firms) / Memorandum of Association (MOA) for companies /Export-Import Code Certificate / Factory Registration Certificate
  • Letter from existing Banker (Scheduled Commercial Bank & Scheduled Co-operative Banks). Letter has to be obtained in original. Existing Banker must verify name and address of the entity on bank’s letterhead.
  • Utility Bill (of last 3 months) in the name of firm/co.
  • Bank Statement mentioning the address in the name of firm/Co.(only scheduled commercial banks)
KYC - Constitution documents

Private Ltd Company/closely Held Public Ltd Company:

  • Certificate of Incorporation
  • MOA & AOA of the company
  • Form 32/ DIR 12
  • Annual return filed with ROC
  • List of Directors & Shareholding pattern duly certified by CA

Partnership firm:

  • Partnership Deed- certified by all partners that it is the latest deed as on date.
  • Dissolution Deed- certified by current partners that it is the latest deed as on date.
  • License issued by the Registering authority like Certificate of Practice issued by ICAI, ICWAI, Institute of Company Secretaries of India, Indian Medical Council, Food and Drug Control Authorities, etc.

If the Proprietorship firm is party to the agreement at least any one of the below documents needs to be mandatorily collected from the firm and a positive FI at the address of proprietary concern is mandatorily required

  • Proof of the name, address and activity of the concern, like registration certificate (in the case of a registered concern), certificate/license issued by the Municipal authorities under Shop & Establishment Act, sales and income tax returns, CST / VAT certificate, certificate / registration document issued by Sales Tax / Service Tax / Professional Tax authorities, License issued by the Registering authority like Certificate of Practice issued by Institute of Chartered Accountants of India, Institute of Cost Accountants of India, Institute of Company Secretaries of India, Indian Medical Council, Food and Drug Control Authorities, etc.
  • Any registration / licensing document issued in the name of the proprietary concern by the Central Government or State Government Authority / Department. NBFCs/RNBCs may also accept IEC (Importer Exporter Code) issued to the proprietary concern by the office of DGFT as an identity document for opening of account.
  • The complete Income Tax return (not just the acknowledgement) in the name of the sole proprietor or where the firm's income is reflected, duly authenticated/ acknowledged by the Income Tax Authorities.
  • Utility bills such as electricity, water, and landline telephone bills in the name of the proprietary concern.

However, in case the FI is not done at firms address then we need to collect two documents out of above-mentioned documents instead of one document as KYC for the sole proprietorship firm.

Signature Verification
  • Signature Verification is mandatory for all applicants or signatories on behalf of applicants like Partnership firm/Pvt Ltd companies.
  • Any one of the following to be considered for signature verification:
    • Banker’s sign. Verification
    • Passport copy
    • PAN card
    • Driving license with photograph & signature.
    • Ration Card with the signature of the customer
    • Debit Card bearing the signature (embossed on the front) of the applicant and should be the same as in the Application Form.
    • Copy of registered sales deed bearing signature of the applicant / co applicant / guarantor / authorised signatory as the case may be.
    • Employee’s Identity Card provided such identity card bears the signature of the employee (only employees of PSU, Scheduled Commercial banks, Insurance Companies, State & Central government)
  • Signature Verification to be taken for borrower/co-borrower for PDC / SPDC issued
  • Banker’s Letter (Banker Verification) - Letter from existing banker (restricted to a Scheduled Commercial Bank & & Scheduled Co- operative Banks). Letter has to be obtained in original on Bank’s letterhead or on plain paper with the seal of the bank affixed on it bearing the authorizing officers name and signature along with the stamp of the bank. The verification done should be for the name and signature of the individual
  • In cases where the co applicant / guarantor is illiterate and is not able to furnish any one of the stipulated signature verification documents, a memorandum duly signed / thumb impression affixed by an illiterate
    person as per the format defined may be accepted as valid signature verification document.
  • A declaration (signed in front of Magma Employee) for sign verification for Co-applicants with no income & who are also not property owner can be accepted.

B. AMLA Documents List As Per Norms Prescribed Under The “Anti Money Laundering Act & Other Applicable Rules”

We have divided our borrower’s under below mentioned two categories

  • “HIGH RISK”- Applicant (whose income is considered) has a net worth of more than Rs 100 lakhs or they are HUF/Trust/Society.
  • “LOW RISK” —Applicant (whose income is considered) has a net worth of less than Rs 100 lakhs.

*Applicant whose income is considered need to sign & submit a declaration/Undertaking confirming his/her net worth.

AMLA requirement are in addition to the KYC requirement and are applicable for all loans — we need to collect any one or more of the following documents to satisfy both ID proof and Address Proof

HIGH RISK

  • Passport (unexpired)
  • Voters’ Identity Card
  • UID (AADHAR card)
  • Job card issued by NREGA duly signed by an officer of the State Government,
  • Valid Driving License (unexpired)
  • PAN Card

We need to collect at least one or more of the above mentioned six documents for AMLA which provides complete ADDRESS and ID PROOF of any one of the APPLICANT. For example, if PAN is collected for ID, another one of the six dox will be required as support for address proof. In case the Applicant or Co- applicant is/ is not individual but firm/Company/trust, then similar documents are required for the authorized signatory. ADDRESS documents for AMLA purpose may be for any address i.e., present, communication or permanent address (without impacting our KYC requirements).

Further we need relationship proof with other co applicant’s so that we don’t need their individual AMLA document, if the relationship does not exist than we need to follow the above-mentioned guideline for all applicants individually.

LOW RISK

  • Passport (unexpired)
  • Voters’ Identity Card
  • UID ( AADHAR card)
  • Job card issued by NREGA duly signed by an officer of the State Government,
  • Valid Driving License (unexpired)
  • PAN Card
  • Identity card with applicant's Photograph issued by Central/State Government Departments, Statutory/Regulatory Authorities, Public Sector Undertakings, Scheduled Commercial Banks, and Public Financial Institutions
  • Letter issued by a gazetted officer, with a duly attested photograph of the person.

In addition to the above-mentioned documents for LOW-RISK Customers, the below mentioned documents(s.no 9-14) can also be taken as Officially Valid document as Address Proof for only LOW Risk Customer.

  • Utility bill which is not more than two months old of any service provider (electricity, telephone, postpaid mobile phone, piped gas (government supply), water bill);
  • Property or Municipal Tax receipt;
  • Bank account or Post Office savings bank account statement;
  • Pension or family pension payment orders (PPOs) issued to retired employees by Government Departments or Public Sector Undertakings if they contain the address.
  • Letter of allotment of accommodation from employer issued by State or Central Government departments, statutory or regulatory bodies, public sector undertakings, scheduled commercial banks, financial institutions, and listed companies. Similarly, leave and license agreements with such employers allotting official accommodation; and
  • Documents issued by Government departments of foreign jurisdictions and letter issued by Foreign Embassy or Mission in India.

We need to collect at least one or more of the above mentioned eight documents for AMLA which provides complete ADDRESS and ID PROOF of any one of the APPLICANT. For example, if PAN is collected for ID, another one of the eight dox will be required as support for address proof. In case the Applicant or Co-applicant is/are not individual but firm/Company/trust, then similar documents are required for the authorized signatory. ADDRESS documents for AMLA purpose may be for any address i.e. present, communication or permanent address (without impacting our KYC requirements).

However, in all cases where Address Proof is taken from document no. 9-14 ; in all such cases a second proof for ID needs to be taken as listed in document no.1-8)

*In case of close relatives, e.g. husband, wife, son, daughter and parents, etc. who live with their wife, husband, father/mother, daughter and son, who do not have officially valid document for address verification, then, in such cases, OVD for proof of address and identity of the relative with whom the prospective customer is living together with a declaration from the relative that the said person (prospective customer) proposing to open an loan account is a relative and is staying with her/him. (Only applicable for low risk profile customers from AML perspective).

**For high risk profile customers (from AML perspective) enhanced Customer Due Diligence is required and relationship proof will not suffice.

c. Digital KYC Process

For the purpose of this section:

“Digital KYC” means the capturing live photo of the customer and officially valid document or the proof of possession of Aadhaar, where offline verification cannot be carried out, along with the latitude and longitude of the location where such live photo is being taken by an authorised officer of our company as per the provisions contained in the Act.

“Equivalent e-document” means an electronic equivalent of a document, issued by the issuing authority of such document with its valid digital signature including documents issued to the digital locker account of the customer as per rule 9 of the Information Technology (Preservation and Retention of Information by Intermediaries Providing Digital Locker Facilities) Rules, 2016.

“Video based Customer Identification Process (V-CIP)”: a method of customer identification by an official of the Company by undertaking seamless, secure, real-time, consent based audio-visual interaction with the customer to obtain identification information including the documents required for CDD purpose, and to ascertain the veracity of the information furnished by the customer. Such process shall be treated as face-to-face process for the purpose of this Policy.

In case a customer apply for digital KYC process then:

  • The original OVD is required to be presented.
  • Live photograph of the customer shall be taken and the same photograph is embedded in the Customer Application Form (CAF).
  • Other guidelines as per the directions of RBI are followed while capturing the Photograph and OVD documents.
  • OTP validation, shall be carried out for successful singing of authorized officer on the declaration.
  • Thereafter, the Application shall give information about the completion of the process and submission of activation request and also generate the transaction-id/reference-id number of the process. Transaction-id/reference-id shall be intimated to the customer for future reference. Verification shall be done by our officer and CAF shall be digitally signed.
Annexure II

ILLUSTRATIVE LIST OF SUSPICIOUS TRANSACTIONS PERTAINING TO HOUSING LOANS:

  • Customer is reluctant to provide information, data, documents;
  • Submission of false documents, data, purpose of loan, details of accounts;
  • Refuses to furnish details of source of funds by which initial contribution is made, sources of funds is doubtful etc.;
  • Reluctant to meet in person, represents through a third party/Power of Attorney holder without sufficient reasons;
  • Approaches a branch/office of a HFC, which is away from the customer’s residential or business address provided in the loan application, when there is HFC branch/office nearer to the given address;
  • Unable to explain or satisfy the numerous transfers in the statement of account/ multiple accounts;
  • Initial contribution made through unrelated third party accounts without proper justification;
  • Availing a top-up loan and/or equity loan, without proper justification of the end use of the loan amount;
  • Suggesting dubious means for the sanction of loan;
  • Where transactions do not make economic sense;
  • There are reasonable doubts over the real beneficiary of the loan and the flat to be purchased;
  • Encashment of loan amount by opening a fictitious bank account;
  • Applying for a loan knowing fully well that the property/dwelling unit to be financed has been funded earlier and that the same is outstanding;
  • Sale consideration stated in the agreement for sale is abnormally higher/lower than what is prevailing in the area of purchase;
  • Multiple funding of the same property/dwelling unit;
  • Request for payment made in favour of a third party who has no relation to the transaction;
  • Usage of loan amount by the customer in connivance with the vendor/builder/developer/broker/agent etc. and using the same for a purpose other than what has been stipulated.
  • Multiple funding / financing involving NGO / Charitable Organisation / Small / Medium Establishments (SMEs) / Self Help Groups (SHGs) / Micro Finance Groups (MFGs)
  • Frequent requests for change of address;
  • Overpayment of instalments with a request to refund the overpaid amount

II. ILLUSTRATIVE LIST OF SUSPICIOUS TRANSACTIONS PERTAINING TO BUILDER/PROJECT LOANS:

  • Builder approaching the HFC for a small loan compared to the total cost of the project;
  • Builder is unable to explain the sources of funding for the project;
  • Approvals/sanctions from various authorities are proved to be fake;
Read More
Grievance Redressal Policy

Ummeed Housing Finance believes in providing efficient and prompt service to its customers. With a view to serve out our customers, the company has come up with the Grievance Redressal Policy.

Level 1

In case of any query/ complaint/ grievance with respect to the product and services offered by Ummeed Housing Finance Private Limited, the customer may register the complaint either by writing a letter/ email or visiting the branch office or through telephonic communication. The customer may contact our office through any of the following channels.

  • By telephonic communication at 1800 2126 127 between 10 am – 6 pm (except holidays).
  • Make an entry of query/ complaint in the Complaint Register at the branch.
  • By way of writing an email at customercare@ummeedhfc.com
Level 2

If the customer does not receive any response from the company within 30 days or is not satisfied with the resolution provided by the above channel, the customer may complaint to the Grievance Redressal Officer of by way of writing letter/ Email to:

Mr. Shariq Khan
Grievance Redressal Officer
Ummeed Housing Finance Private Limited,
Unit 809-815, 8th Floor, Tower A, Emaar Digital Greens,
Golf Course Extension Road, Sector 61, Gurugram – 122102
Email ID: shariq.khan@ummeedhfc.com.
Contact No.: 0124-4836480

It is advised to customers to provide Loan details and customer issue in detail for quick redressal. We assure you that your complaint will be looked into at the earliest. 

Each customer complaint being unique in nature, can take approximately 30 days for a detailed response to respective customer query or complaint. Once, a query or a complaint is registered with the company, an acknowledgement along with a complaint reference number will be sent to the customer within 7 days. The acknowledgement will contain the name & designation of the official who will deal with the grievance. If the complaint is relayed over Company’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. While the concerned team works on the query / complaint towards resolution, an interim response intimating the actual time that will be taken to resolve the issue will be sent to the customer. After examining the matter, the company will send the customer its final response or explain why it needs more time to respond and will endeavor to do so within 30 days of receipt of a complaint and he/she will be informed how to take his complaint further if he/she is still not satisfied.

Level 3

In case your complaint has not been resolved to your satisfaction, you can also approach the Complaint Redressal Cell of National Housing Bank by lodging its complaints in Online mode at the link https://grids.nhbonline.org.in OR in offline mode by post, in prescribed format available at link https://nhb.org.in/citizencharter/Complaint_form.pdf on National Hosing Bank’s website. You may fill and send the form along with letters or enclosures, if any, by post or courier to the following address:

Complaint Redressal Cell
Department of Supervision
National Housing Bank
4th Floor, Core 5-A, India Habitat Centre,
Lodhi Road, New Delhi - 110 003

Read More
Preface

Ummeed Housing Finance Pvt. Ltd. (the “Company”) has adopted the Code of Ethics & Business Conduct, which lays down the principles and standards that should govern the actions of the Company and its employees. Any actual or potential violation of the Code, howsoever insignificant or perceived as such, would be a matter of serious concern for the Company. The role of employees in pointing out such violations of the Code cannot be undermined. Accordingly, this Whistleblower Policy (“the Policy”) has been formulated with a view to provide a vigil mechanism for employees of the Company to raise concerns on any violations of Code of Conduct or legal or regulatory requirements, incorrect or misrepresentation of any financial statements and reports, etc.

This Policy is framed in terms of direction related to constitution of Audit Committee and establishment of vigil mechanism under the provisions of Master Direction Non-Banking Financial Company – Housing Finance Company (Reserve Bank) Directions, 2021 and the relevant provisions under Section 177 (9 & 10) of the Companies Act, 2013 and the rules made thereunder.

Objective

The Company is committed to adhere to the highest standards of ethical, moral and legal conduct of business operations. To maintain these standards, the Company encourages its employees who have concerns about suspected misconduct to come forward and express these concerns without fear of punishment or unfair treatment. This policy aims to provide an avenue for employees to raise concerns on any violations of Company’s code of conduct for employees or legal or regulatory requirements, incorrect or misrepresentation of any financial statements and reports, etc.

Policy

The Whistleblower Policy intends to cover serious concerns that could have grave impact on the operations and performance of the business of the Company.

The policy neither restricts employees from their duty of confidentiality in the course of their work, nor is it a route for taking up a grievance about a personal situation.

Definitions
  • "Audit Committee" means the Audit Committee constituted by the Board of Directors of the Company in accordance with Section 177 of the Companies Act, 2013 and read with relevant directions under Master Direction Non-Banking Financial Company – Housing Finance Company (Reserve Bank) Directions, 2021.
  • "Company" means Ummeed Housing Finance Pvt. Ltd.
  • "Disciplinary Action" means any action that can be taken on the completion of /during the investigation proceedings including but not limited to a warning, imposition of fine, suspension from official duties or any such action as is deemed to be fit considering the gravity of the matter.
  • "Employee" means every employee of the Company.
  • "Protected Disclosure" means a concern raised by a written communication made in good faith that discloses or demonstrates information that may evidence unethical or improper activity. Protected Disclosures should be factual and not fictitious in nature.
  • "Subject" means a person or group of persons against or in relation to whom a Protected Disclosure is made or evidence gathered during the course of an investigation under this Policy.
  • "Whistleblower" is someone who makes a Protected Disclosure under this Policy.
  • "Whistleblower Officer" or "Whistle Committee" or "Committee" means an officer or Committee of persons who is/are nominated/ appointed to conduct detailed investigation of the disclosure received from the whistleblower and recommend disciplinary action. Currently, COO Mr. Sachin Grover is nominated as Whistleblower Officer for the purpose. The Committee, if appointed, should include Senior Level Officers of Personnel & Admin, Internal Audit and a representative of the Division/ Department where the alleged malpractice has occurred. The representative or the officer, being member of the Whistle Committee, shall recuse from the proceedings of the Committee if found allegedly involved in the complaint.
  • "Good Faith": An employee shall be deemed to be communicating in “good faith” if there is a reasonable basis for communication of unethical and improper practices or any other alleged wrongful conduct. Good Faith shall be deemed lacking when the employee does not have personal knowledge on a factual basis for the communication or where the employee knew or reasonably should have known that the communication about the unethical and improper practices or alleged wrongful conduct is malicious, false or frivolous.
  • "Policy or This Policy" means, "Whistleblower Policy."

     

Scope

This Policy is an extension of Company’s Code of Conduct. Various stakeholders of the Company are eligible to make Protected Disclosures under the Policy. These stakeholders may fall into any of the following broad categories and can be called as Whistleblowers:

  • Employees of the Company including Directors, shareholders, etc.
  • Employees of other agencies deployed for the Company’s activities, whether working from any of the Company’s offices or any other location
  • Contractors, vendors, suppliers or agencies (or any of their employees) providing any material or service to the Company
  • Customers of the Company
  • Any other person having an association with the Company

A person belonging to any of the above-mentioned categories can avail of the channel provided by this Policy for raising an issue covered under this Policy. The Whistleblowers role is that of a reporting party with reliable information about any malpractices, illegal acts, breach or violation of the Company’s Policies or Code of Conduct, or unethical acts conducted by any company’ employee.

The Policy covers malpractices and events which have taken place/ suspected to take place involving:

  • Breach of contract including employee’s code of conduct relating to expected ethical conduct, and behavioral aspect.
  • Negligence causing substantial and specific danger to public health and safety
  • Manipulation of company data/records
  • Financial irregularities, including fraud or suspected fraud or Deficiencies in Internal Controls and check or deliberate error in preparations of Financial Statements or Misrepresentation of financial reports
  • Any unlawful act whether Criminal/ Civil
  • Pilferation of confidential/propriety information
  • Deliberate violation of law/regulation
  • Wastage/misappropriation of company funds/assets
  • Breach of Company Policy or failure to implement or comply with any approved Company Policy

This Policy should not be used in place of the Company grievance procedures or be a route for raising malicious or unfounded allegations against colleagues.

Guiding Principles On VIGIL Mechanism

To ensure that this Policy is adhered to, and to assure that the concern will be acted upon seriously, the Company will:

  • Ensure that the Whistleblower and/or the person processing the Protected Disclosure is not victimized for doing so
  • Treat victimization as a serious matter, including initiating disciplinary action on person/(s) indulging in victimization
  • Ensure complete confidentiality
  • Not attempt to conceal evidence of the Protected Disclosure
  • Take disciplinary action, if anyone destroys or conceals evidence of the Protected Disclosure made/to be made
  • Provide an opportunity to hear all persons involved especially the Subject
Anonymous Allegation

Whistleblowers must put their names to allegations as follow-up questions and investigation may not be possible unless the source of the information is identified.Disclosures expressed anonymously will ordinarily NOT be investigated. However, the company shall take cognizance of such matters on merit which are general in character to take corrective course of action in the interest of stakeholders and the public, at large.

Protection to Whistleblower
  • If one raises a concern under this Policy, he/she will not be at risk of suffering any form of reprisal or retaliation. Retaliation includes discrimination, reprisal, harassment or vengeance in any manner. Company’s employee will not be at the risk of losing her/ his job or suffer loss in any other manner like transfer, demotion, refusal of promotion, or the like including any direct or indirect use of authority to obstruct the Whistleblower's right to continue to perform his/her duties/functions including making further Protected Disclosure, as a result of reporting under this Policy. The protection is available provided that:
    • The communication/ disclosure is made in good faith
    • Whistleblower reasonably believes that information, and any allegations contained in it, are substantially true; and
    • Whistleblower is not acting for personal gain

Anyone who abuses the procedure (for example by maliciously raising a concern knowing it to be untrue) will be subject to disciplinary action, as will anyone who victimizes a colleague by raising a concern through this procedure. If considered appropriate or necessary, suitable legal actions may also be taken against such individuals.

  • The Company will not tolerate the harassment or victimization of anyone raising a genuine concern. As a matter of general deterrence, the Company shall publicly inform employees of the penalty imposed and disciplinary action taken against any person for misconduct arising from retaliation. Any investigation into allegations of potential misconduct will not influence or be influenced by any disciplinary or redundancy procedures already taking place concerning an employee reporting a matter under this policy.

Any other Employee/business associate assisting in the said investigation shall also be protected to the same extent as the Whistleblower.

Accountabilities - Whistleblowers
  • Bring to early attention of the Company any improper practice they become aware of.
  • Although they are not required to provide proof, they must have sufficient cause for concern. Delay in reporting may lead to loss of evidence and also financial loss for the Company.
  • Avoid anonymity when raising a concern
  • Follow the procedures prescribed in this policy for making a Disclosure
  • Co-operate with investigating authorities, maintaining full confidentiality
  • The intent of the policy is to bring genuine and serious issues to the fore and it is not intended for petty Disclosures. Malicious allegations by employees may attract disciplinary action
  • A whistleblower has the right to protection from retaliation. But this does not extend to immunity for involvement in the matters that are the subject of the allegations and investigation
  • Maintain confidentiality of the subject matter of the Disclosure and the identity of the persons involved in the alleged Malpractice. It may forewarn the Subject and important evidence is likely to be destroyed
  • In exceptional cases, where the whistleblower is not satisfied with the outcome of the investigation carried out by the Whistle Officer or the Committee, he/she can make a direct appeal to the MD of the Company
Accountabilities - Whistle Officer And Whistle Committee
  • Conduct the enquiry in a fair, unbiased manner
  • Ensure complete fact-finding
  • Maintain strict confidentiality
  • Decide on the outcome of the investigation, whether an improper practice has been committed and if so by whom
  • Recommend an appropriate course of action - suggested disciplinary action, including dismissal, and preventive measures
  • Record Committee deliberations and document the final report
Rights of a Subject
  • Subjects have the right to be heard and the Whistle Officer or the Committee must give adequate time and opportunity for the subject to communicate his/her says on the matter
  • Subjects have the right to be informed of the outcome of the investigation and shall be so informed in writing by the Company after the completion of the inquiry/ investigation process
Management Action on False Disclosures

An employee who knowingly makes false allegations of unethical & improper practices or alleged wrongful conduct shall be subject to disciplinary action, up to and including termination of employment, in accordance with Company rules, policies and procedures. Further this policy may not be used as a defense by an employee against whom an adverse personnel action has been taken independent of any disclosure made by him and for legitimate reasons or cause under Company rules and policies.

Procedure for Reporting & Dealing with Disclosures

For more details, refer to the procedure for reporting & dealing with disclosures given in Annexure-A.

Access to Reports and Documents

All reports and records associated with “Disclosures‟ are considered confidential information and access will be restricted to the Whistleblower, the Whistle Committee and Whistle Officer. “Disclosures‟ and any resulting investigations, reports or resulting actions will generally not be disclosed to the public except as required by any legal requirements or regulations or any other legitimate needs of law and investigation.

Retention of Documents

All Protected Disclosures in writing or documented along with the results of investigation relating thereto shall be retained by the Company for a minimum period of 8 years.

Reports

A quarterly status report on the total number of complaints received during the period, with summary of the findings of the Whistle Committee and the corrective actions taken will be sent to the Mr. Ashutosh Sharma, Managing Director of the Company.

All cases of representations, investigation, recommendation of the Whistle Committee and Whistle Officer thereupon along with the suggested course of action shall be reviewed by the Audit Committee under periodic reporting to the Board. Audit Committee will also take up the matter of appeal for review.

Company's Powers

The Company is entitled to amend, suspend or rescind modify this policy in whole or in part at any time, subject to legal provisions in force. Whilst, the Company has made best efforts to define detailed procedures for implementation of this policy, there may be occasions when certain matters are not addressed or there may be ambiguity in the procedures. Such difficulties or ambiguities will be resolved in line with the broad intent of the policy. The Company may also establish further rules and procedures, from time to time, to give effect to the intent of this policy and further the objective of good corporate governance.

Procedure for Reporting & Dealing with Disclosures
  • How should a Disclosure be made and to whom?

A Disclosure should be made in writing. Letters can be submitted by hand-delivery, courier or by post addressed to the Whistle Officer appointed by the Company.

Emails can be sent to the email id: feedback@ummeedhfc.com. A disclosure should normally be submitted to the Whistle Officer.

Disclosures against any employee in Strategic Job Responsibility Band or the Business Unit Heads or the Executive Directors should be sent directly to Mr. Ashutosh Sharma, Managing Director of the Company.

Only, in exceptional cases, a Whistle Blower can approach to the Chairperson of the Audit Committee.

  • Is there any specific format for submitting the Disclosure?

While there is no specific format for submitting a Disclosure, the following details must be mentioned:

  • Name, address and contact details of the Whistleblower
  • Brief description of the Malpractice, giving the names of those alleged to have committed or about to commit a Malpractice. Specific details such as time and place of occurrence are also important.
  • In case of letters, the disclosure should be sealed in an envelope marked “Whistle Blower” and addressed to the Whistle Officer or Managing Director, depending on position of the person against whom disclosure is made.
  • What will happen after the Disclosure is submitted?

The Whistle Officer shall acknowledge receipt of the Disclosure as soon as practical (preferably within 07 days of receipt of a Disclosure), where the Whistleblower has provided his/ her contact details.

The Whistle Officer will proceed to determine whether the allegations (assuming them to be true only for the purpose of this determination) made in the Disclosure constitute a Malpractice by discussing with MD of the Company (if required). If the Whistle Officer determines that the allegations do not constitute a Malpractice, he/she will record this finding with reasons and communicate the same to the Whistleblower

If the Whistle Officer determines that the allegations constitute a Malpractice, he/she will proceed to investigate the Disclosure with the assistance of the Whistle Committee comprising of Senior Level Officers of Personnel & Admin, Internal Audit and a representative of the Division/ Department where the breach has occurred, as he/she deems necessary. If the alleged Malpractice is required by law to be dealt with under any other mechanism, the Whistle Officer shall refer the Disclosure to the appropriate authority under such mandated mechanism and seek a report on the findings from such authority.

Subjects will normally be informed of the allegations at the outset of a formal investigation and have opportunities for providing their inputs during the investigation.

The investigation may involve study of documents and interviews with various individuals. Any person required to provide documents, access to systems and other information by the Whistle Officer or Whistle Committee for the purpose of such investigation shall do so. Individuals with whom the Whistle Officer or Whistle Committee requests an interview for the purposes of such investigation shall make themselves available for such interview at reasonable times and shall provide the necessary cooperation for such purpose.

If the Malpractice constitutes a criminal offence, the Whistle Officer will bring it to the notice of the Managing Director and take appropriate action including reporting the matter to the police.

The Managing Director of the Company may, at his/her discretion, participate in the investigations of any Disclosure.

The Whistle Committee shall conduct such investigations in a timely manner and shall submit a written report containing the findings and recommendations to the Whistle Officer as soon as practically possible and in any case, not later than 90 days from the date of receipt of the Disclosure. The Whistle Officer may allow additional time for submission of the report based on the circumstances of the case.

Whilst it may be difficult for the Whistle Officer to keep the Whistleblower regularly updated on the progress of the investigations, he/she will keep the Whistleblower informed of the result of the investigations and its recommendations subject to any obligations of confidentiality.

The Whistle Officer will ensure action on the recommendations of the Whistle Committee/ Officer and keep the Whistleblower informed of the same. Though no timeframe is being specified for such action, the Company will endeavor to act as quickly as possible in cases of proved Malpractice.

  • What should I do if I face any retaliatory action or threats of retaliatory action as a result of making a Disclosure?

If you face any retaliatory action or threats of retaliatory action as a result of making a Disclosure, please inform the Whistle Officer in writing immediately. He/ She will take cognizance of each and every such complaint/feedback received and investigate the same accordingly and may also recommend appropriate steps to protect you from exposure to such retaliatory action and ensure implementation of such steps for your protection.

Read More
Most Important Terms and Conditions (MITC)

Ummeed Housing Finance Private Limited

Loan ……………………………… (Name of the specific Loan Product)

Major terms and conditions of the housing loan agreed to between Shri/Smt./Kum. ……………………… ……………………………………………………(the borrower) and the Ummeed Housing Finance Private Limited (hereinafter referred as Ummeed Housing Finance) are as under:

1.Loan

Sanction Amount:

2.Interest
  • i.Type (Fixed or Floating or Dual/ Special Rate):
  • ii.Interest chargeable (……………. i.e. ..... % ( Ummeed Reference Rate (URR) +/- …………) for floating rate loans; and ……% for fixed rate loans)
  • iii.Moratorium or subsidy:
  • iv.Date of reset of interest:
  • v.Modes of communication of changes in interest rate: Any change in interest rate would be duly communicated to the borrower at the contact details available with Ummeed Housing Finance through SMS / E-mail / call on the registered phone or mobile number/ Courier or any other electronic mode prevalent for the time being. The changes will also be updated on Ummeed Housing Finance website and will be displayed at Ummeed Housing Finance branches
3.Installment Types
  • a.Repayment of loan through monthly Instalment.
  • b.Amount: ……………………(In Figures). Subject to change with a change in URR in case of floating rate loans.
  • c.Date of Commencement of EMI:
  • d.Due Date for EMI:
4.Loan Tenure: __________months (Subject to change with a change in Ummeed Reference Rate in case of floating rate loans)
5.Purpose of Loan:
  • a.Home Loan
  • b.Plot Purchase Plus Construction
  • c.Repair & Renovation
  • d.Home Extension Loan
  • e.Construction Refinance
  • f.Purchase Refinance (Non Housing)
  • g.Loan Against Property
  • h.Business Loan
  • i.Small Ticket Business Loan
  • j.Others (Please Specify) ________________________
6.Fee and Other Charges
  • i.On application (all type of fee/ charges, to be specified individually): Please refer table below
  • ii.During the term of loan (all type of fee/ charges, to be specified individually): Please refer table below
  • iii.On foreclosure (all type of fee/ charges, to be specified individually): Please refer table below
  • iv.Fee refundable if loan not sanctioned/disbursed (all type of fee, to be specified individually): Please refer table below
  • v.Conversion charges for switching from floating to fixed interest and vice-versa (type of charges, to be specified individually): Please refer table below
  • vi.Penalty for delayed payments (all type of penalty, to be specified individually): Please refer table below
Tariff Sheet-Schedule of Charges
Particulars Home Loan Non-Home Loan (Loan against Property, Business Loan & Small Ticket Business Loan)
Copy of Welcome Letter & Amortization Schedule NIL NIL
Commitment Fee (at the time of Login the file) Not to exceed Rs.10,000/- Not to exceed Rs.10,000/-
Processing Fee Up to 1% Up to 2%
Document & Service Charges Up to 3% of Sanction Amount Up to 4% of Sanction Amount
CERSAI Charge Up to Rs.750/- or as applicable Up to Rs.750/- or as applicable
Loan Cancellation Charges Rs.5000/- or 1% of Sanction amount whichever is higher Rs.5000/- or 1% of Sanction amount whichever is higher
PDC/ECS/ACH Bounced Charges Rs.600/- per bounce Rs.600/- per bounce
Penal Charges for delay in deposit (applicable on Outstanding EMI/PEMI Due) 2.50% per month 2.50% per month
Switching Fee (Applicable on Outstanding Principal Amount) Up to 0.5% of the POS or Rs.10, 000/- whichever is lower. Up to 0.5% of the POS or Rs.10, 000/- whichever is lower.
Repayment Swap Charges Rs.500/- Rs.500/-
Statement of Accounts/Duplicate NOC/Foreclosure Letter) Rs.500/- per statement Rs.500/- per statement
Retrieval of copy of documents Rs.1000/- Rs.1000/-
List of Documents -Duplicate Copy Rs. 500/- Rs. 500/-
Pre-Closure Charges (Fixed Rate of Interest) by Individual Borrowers NIL Charges - In case of closure through own funds 5% on Principal Outstanding - In case pre-closure of loan is through borrowing from other Bank / HFC / NBFC / any other Financial Institution 5% on Principal Outstanding.
Pre-Closure Charges (Fixed Rate of Interest) by Non-Individual Borrowers 5% on Principal Outstanding. 5% on Principal Outstanding.
Pre-Closure Charges (Floating Rate of Interest) by Individual Borrowers NIL NIL
Pre-Closure Charges (Floating Rate of Interest) by Non-Individual Borrowers 5% on Principal Outstanding. 5% on Principal Outstanding.
Part Payment Charges (Fixed Rate of Interest) by Individual Borrowers NIL 5% on Principal Outstanding
Part Payment Charges (Fixed Rate of Interest) by Non-Individual Borrowers 5% on Part Payment Amount 5% on Part Payment Amount
Part Payment Charges (Floating Rate of Interest) by Individual Borrowers NIL NIL
Part Payment Charges (Floating Rate of Interest) by Non-Individual Borrowers 5% on Part Payment Amount 5% on Part Payment Amount
Collection Charges Rs.500/- per collection from the customer's residence/office Rs.500/- per collection from the customer's residence/office
Differential Interest (any interest accrued due to gap in applicable ROI and existing rate of interest of any loan Refund or charged at any time suitable to customer or Ummeed Housing Finance Refund or charged at any time suitable to customer or Ummeed Housing Finance
Document Custodian Fee (To be charged at the time of loan closure) Rs.200 per month (after first 60 days) Rs.200 per month (after first 60 days)
Property Swapping Charges NA Rs.3000
Applicable Taxes will be charged over and above the charges mentioned above in the Tariff Sheet

Note:

  • a.Fee/Charges mentioned above are excluding applicable taxes and charges, while making payment applicable service tax and other statutory charges to be added as notified by statutory/government bodies.
  • b.We share credit performance details of your loan account with credit information bureau of India limited (CIBIL) and with other bureau agencies.
7. Security / Collateral for the Loan
  • Mortgage (Mention detail of the property to be mortgaged as security for the loan):
    ..........................................................................................................................................
    ..........................................................................................................................................
  • Guarantee (Mention the name of the guarantors):
    ..........................................................................................................................................
    ..........................................................................................................................................
  • Other Security (Mention the details of other securities, if any).
    ..........................................................................................................................................
    ..........................................................................................................................................
8. Insurance of the Property / Borrower: -
  • The borrower/s shall keep the property under security insured with comprehensive Insurance policy equivalent to the loan outstanding at any point of time during the pendency of the loan with Ummeed Housing Finance as the sole beneficiary under said policy/policies.
  • The borrower/s may keep his/her life insured equivalent to the loan outstanding at any point of time during the pendency of the loan with Ummeed Housing Finance as the sole beneficiary under said policy/policies.
9. Conditions for disbursement of the Loan:

Ummeed Housing Finance shall not disburse any loan to the Borrower unless the conditions mentioned in the sanction letter and loan agreement are complied with, to the satisfaction of Ummeed Housing Finance. All the loans at the sole discretion of Ummeed Housing Finance.

  • The borrower must fulfill the Ummeed Housing Finance requirement of credit worthiness.
  • Submission of all relevant documents as mentioned by Ummeed Housing Finance in the sanction letter / Loan agreement.
  • Legal and Technical assessment of the property.
  • Execution of the loan agreement and such other ancillary documents.
  • Submission of Cheques/ACH. any other clearing system in force for the time being towards repayment of installments.
  • Payment of own contribution by the borrower (total cost of flat/house less than the loan amount), as specified in the sanction letter. In case of any alternative arrangement based on a specific product being offered by Ummeed Housing Finance, the same shall be informed to and acknowledged by the Borrower.
10. Repayment of the Loan and Interest:

Repayment of the loan to be by the way of pre-EMI/EMI during the entire tenure of the loan. The installments (EMI) comprises of both principal repayment and interest component calculated on the outstanding principal and PEMI which comprises of interest component calculated on the outstanding principal. Interest shall be calculated on monthly reducing balance.

  • The EMI / PEMI for your Loan is :
  • Numbers of installments to be paid are :
  • Modes of communication of changes in interest rate: through email / SMS / call on the registered phone / mobile number
11.Brief procedure to be followed for Recovery of overdues
  • Telephone/Personal contact and follow up for recovery of installments and interest due.
  • Initiate legal action against the borrower in accordance with provisions of the loan agreement and applicable laws. Before initiating any such legal action, Ummeed Housing Finance shall sent notice to the borrower/s as required under applicable law.
12.Date on which annual outstanding balance statement will be issued:

Ummeed Housing Finance will issue an annual outstanding statement reflecting your repayments and current outstanding as at 31st March every year on or before 31st May.

13.Customer Services
  • Visiting Hours at office / Branch
    Monday to Saturday 10 AM to 6.00 PM
    1st Saturday: 10 AM to 2 PM
    Office will be closed on 2nd Saturday of every month, all Sundays and all public Holiday.
  • Borrowers are requested to contact the Branch manager during working hours for any clarifications/guidance.
  • Borrower can contact our customer service helpdesk at 18002 126 127 / 0124-4836480 during office hours
  • Indicative timelines of common request servicing:
    • Loan Account Statement – 7 working days from the date of request.
    • Photocopy of title documents -15 working days from the date of request.
    • Issuance of foreclosure letter -15 working days from the date of request.
    • Return of Original Documents on Closure/ Transfer of Loan- 15 Working days from the date of request.
14.Grievance Redressal

Level 1

In case of any query/ complaint/ grievance with respect to the product and services offered by Ummeed Housing Finance Private Limited, the customer may register the complaint either by writing a letter/ email or visiting the branch office or through telephonic communication. The customer may contact our office through any of the following channels.

  • By telephonic communication at 1800 2126 127 between 10.00 AM to 06.00 PM (except holidays).
  • Make an entry of query/ complaint in the Complaint Register at the branch.
  • By way of writing an email at customercare@ummeedhfc.com

Level 2

If the customer does not receive any response from the company within 30 days or is not satisfied with the resolution provided by the above channel, the customer may complaint to the Grievance Redressal Officer of by way of writing letter/ Email to:

Mr. Shariq Khan
Grievance Redressal Officer
Ummeed Housing Finance Private Limited,
Unit 809-815, 8th Floor, Tower A, Emaar Digital Greens,
Golf Course Extension Road, Sector 61, Gurugram – 122102
Email ID: shariq.khan@ummeedhfc.com.
Contact No.: 0124-4836480

It is advised to customers to provide Loan details and customer issue in detail for quick redressal. We assure you that your complaint will be looked into at the earliest. 

Each customer complaint being unique in nature, can take approximately 30 days for a detailed response to respective customer query or complaint. Once, a query or a complaint is registered with the company, an acknowledgement along with a complaint reference number will be sent to the customer within 7 days. The acknowledgement will contain the name & designation of the official who will deal with the grievance. If the complaint is relayed over Company’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. While the concerned team works on the query / complaint towards resolution, an interim response intimating the actual time that will be taken to resolve the issue will be sent to the customer. After examining the matter, the company will send the customer its final response or explain why it needs more time to respond and will endeavour to do so within 30 days of receipt of a complaint and he/she will be informed how to take his complaint further if he/she is still not satisfied.

Level 3

In case your complaint has not been resolved to your satisfaction, you can also approach the Complaint Redressal Cell of National Housing Bank by lodging its complaints in Online mode at the link https://grids.nhbonline.org.in OR in offline mode by post, in prescribed format available at link https://nhb.org.in/citizencharter/Complaint_form.pdf on National Hosing Bank’s website. You may fill and send the form along with letters or enclosures, if any, by post or courier to the following address:

Complaint Redressal Cell
Department of Supervision
National Housing Bank
4th Floor, Core 5-A, India Habitat Centre,
Lodhi Road, New Delhi - 110 003

It is hereby agreed that for detail terms and conditions of the loan, the parties hereto shall refer to and rely upon the loan and other security documents executed/ to be executed by them.

The above terms and conditions have been read by the borrower/s / read over to the borrower by Shri/Smt./Kum. ………………………………………………………of the company and have been understood by the borrower/s.

Signature/Thumb Impression
of borrower/s

(Signature of the authorized person of Lender)

Note: Duplicate copy of the MITC should be handed-over to the borrower/s.

Read More
Corporate Governance Mission

Ummeed Housing Finance Private Limited (the "Company") is a housing finance registered with National Housing Bank (NHB) under National Housing Bank Act, to the highest standards of ethical conduct Managed by a team of experienced professionals, work with a common motive of providing home loans and loan against property to & income Indian families doing what we say. We advocate and stream highest of ethical of the industry, reporting results with accuracy and transparency and as an ongoing maintaining full compliance with the laws, rules and regulations that govern the Company's businesses

Board Of Directors

The Board of Directors' primary responsibility is to provide effective governance over the Company's affairs for the benefit of its stockholders, and to balance the interests of its diverse constituencies around the world, including its customers, employees, suppliers and local communities. In all actions taken by the Board, the Directors are expected to exercise their business judgment in what they reasonably believe to be the best interests of the Company. In discharging that obligation, Directors may rely on the honesty and integrity of the Company's senior executives and its outside advisors and auditors.

Details of Board Members
  • The Board of Directors of the Company consists of the following Board Members:
    • Mr. Ashutosh Sharma, Managing Director (DIN: 02582205)
    • Mr. Sachin Grover, Whole-Time Director (DIN: 07387359)
    • Mr. Rajiv Yashwant Inamdar, Non-Executive Director (DIN: 01295880)
    • Mr. Vinayak Prabhakar Shenvi, Nominee & Non-Executive Director (DIN: 00694217)
    • Mr. Inderjit Walia, Independent Director (DIN: 02582205)
    • Ms. Geeta Mathur, Independent Director (DIN: 02139552)
    • Mr. Kartik Srivatsa, Non-Executive Director (DIN: 03559152)
    • Mr. Nirav Mehta, Nominee & Non-Executive Director (DIN: 07504945)

In terms of section 149 of the Companies Act, 2013 each company needs to have a board in place with necessary duties and powers as provided in Section 166 & 179 respectively and various other provisions of Companies Act, 2013 and applicable rules & regulation formed therein. Mr. Ashutosh Sharma is the chairman of the Board and Managing Director of the Company. Further Mr. Sharma along with Mr. Sachin Grover are executive directors on the Board. Mr. Inderjit Walia and Ms. Geeta Mathur have been appointed as Independent Director effective 23rd March 2018 and 27th February 2019 respectively. The Board also constitutes Nominee Directors, Mr. Vinayak Prabhakar Shenvi is the nominee director for M/s CX Alternative Investment Fund and M/s Thyme Private Limited, Mr. Kartik Srivatsa is the nominee director for M/s. Lightstone Fund S.A. Raif acting on behalf and for account of Lightstone Global Fund and Mr. Nirav Mehta is nominee director of M/s NHPEA Kabru Holding B.V. (Morgan Stanley).

One of the Board's most important responsibilities is identifying, evaluating and selecting candidates for the Board of Directors. The Nomination and Remuneration Committee reviews the qualifications of potential director candidate and makes recommendations to the Board. The factors considered by the Committee and the Board in its review of potential candidates include:

  • Whether the candidate has relevant qualifications, expertise, track record, integrity and meets the other ‘fit and proper’ criteria as prescribed by regulatory.
  • Whether the candidate has exhibited behavior that indicates he or she is committed to the highest ethical standards and our shared responsibilities.
  • Whether the candidate has had business, governmental, non-profit or professional experience at the Chairman, Chief Executive Officer, Chief Operating Officer or equivalent policy-making and operational level of a large organization with significant international activities that indicates that the candidate will be able to make a meaningful and immediate contribution to the Board's discussion of and decision-making on the array of complex issues facing a large financial services business that operates on a global scale.
  • Whether the candidate has special skills, expertise and background that would complement the attributes of the existing Directors, taking into consideration the diverse communities and geographies in which the Company operates.
  • Whether the candidate has achieved prominence in his or her business, governmental or professional activities, and has built a reputation that demonstrates the ability to make the kind of important and sensitive judgments that the Board is called upon to make.
  • Whether the candidate will effectively, consistently and appropriately take into account and balance the legitimate interests and concerns of all of the Company's stockholders and our other stakeholders in reaching decisions, rather than advancing the interests of a particular constituency.
  • Whether the candidate possesses a willingness to challenge management while working constructively as part of a team in an environment of collegiality and trust.
  • Whether the candidate will be able to devote sufficient time and energy to the performance of his or her duties as a Director.

Application of these factors involves the exercise of judgment by the Board.

Change in Status or Responsibilities

If a Director has a substantial change in professional responsibilities, occupation or business association he or she should notify the Nomination and Remuneration Committee and offer his or her resignation to the Board. The Nomination and Remuneration Committee will evaluate the facts and circumstances and make a recommendation to the Board whether to accept the resignation or request that the Director continue to serve on the Board.

Committees of the Board

The Board has constituted several committees to deal with specific matters and delegated powers for different functional areas. The Audit Committee, Nomination and Remuneration committee, Asset Liability Committee, Risk Management Committee and Credit Committee been constituted in accordance with the guidelines issued by the National Housing Bank.

Given below is the composition of the Committees and the terms of reference of the Committees:

Audit Committee
  • The company has constituted Audit Committee in terms of section 177 of the Companies Act, 2013 comprising of the following:
    • Ms. Geeta Mathur (Independent director)
    • Mr. Inderjit Walia (Independent director)
    • Mr. Kartik Srivatsa (Nominee director)

The terms of reference of the Audit Committee of the Company, are as per relevant applicable provisions of Companies Act, regulatory directions and includes follows:

  • Reviewing with management/statutory auditors the half yearly and annual financial statements and the draft Auditor’s report before submission to the board, focusing primarily on:
    • Any changes in accounting policies and practices
    • Major accounting entries based on exercise of judgments by management,
    • Qualifications in draft audit report.
    • Significant adjustments arising out of audit.
    • The going concern assumption.
    • Compliance with accounting standards.
    • Any related party transactions and approval/subsequent modification of the same, as the case may be
    • Reviewing with the management, external and internal auditors, the adequacy and compliance of internal control systems and evaluation of the internal financial controls and risk management systems
    • Reviewing the adequacy of internal audit function and to formulate the scope, functioning and methodology for conducting the internal audit
    • Discussion with internal auditors on any significant findings and implementation of their recommendation and follow up there on
    • Review the findings of any internal investigations by the internal auditors into matters where there is suspected fraud or irregularity or a failure of internal control systems of a material nature and reporting the matter to the Board
    • Discussion with Statutory Auditors before the audit commences, nature and scope of audit as well as post-audit discussion to ascertain any area of concern
    • Recommend for appointment, remuneration and terms of appointment of auditors of the Company
    • Review and monitoring of the auditor’s independence and performance, and effectiveness of audit process
    • Approval or any subsequent modification of transactions of the company with related parties
    • Scrutiny of inter-corporate loans and investments
    • Valuation of undertakings or assets of the company in accordance with the provisions of Companies Act, 2013 , wherever it is necessary
    • Establish and review the functioning of the Whistle Blower Mechanism
    • Monitor the end use of funds raised through public offers and related matters
    • Call for the comments of the auditors about internal control systems, the scope of audit, including the observations of the auditors and review of financial statement before their submission to the Board and discussion of related matters with the internal and statutory auditors and the management of the Company
    • Investigate into any matter in relation to the items specified above or referred to it by the Board of Directors
    • Any such other role/function as may be specifically referred to the Committee by the Board of Directors or as may be required under the Companies Act, 2013 or any other law for the time being in force.
Nomination and Remuneration committee
  • The company has also constituted Audit Committee in terms of section 178 of the Companies Act, 2013 comprising of the following:
    • Inderjit Walia (Independent Director)
    • Ms. Geeta Mathur (Independent Director)
    • Mr. Nirav Mehta (Nominee & Non-Executive Director)
    • Mr. Ashutosh Sharma (Founder & Managing Director)
  • The nomenclature and the terms of reference of the Committee are as follows:
    • Identification of persons qualified to become director and senior management personnel (as defined under the Companies Act, 2013), recommendations to the Board for their appointment /removal or filling of vacancies on the Board.
    • Administration and superintendence of the Employee Stock Option Scheme and to that extent the scope of reference to the Committee is not restricted to only particular Stock Option scheme but all Stock Option schemes are to be implemented / administered by the Committee.
    • Formulation, superintendence and administration of:
      • Director’s Appointment & Remuneration Policy;
      • Key Managerial Personnel’s Appointment and Remuneration Policy;
      • Employees Remuneration Policy;
    • Formulation, Superintendence and administration of Annual Performance Evaluation Policy of the Board
    • Any such other role/functions as may be specifically referred to the Committee by the Board of Directors and / or other committees of Directors of the Company or as may be required under the Companies Act, 2013 or any other law for the time being in force.

*As per Section 178(5), “senior management personnel” of a Company means members of the core management team of the Co (excluding Board of directors) comprising all members of management one level below the executive directors, including the functional heads.

Other Committees

In addition to the aforesaid committees constituting the Directors, the Company also has various committees for supervising day to day operations of the company. The company has in place Asset Liability Committee (ALCO), Risk Management Committee and Credit Committee. The meetings of ALCO and Risk Management are conducted on monthly basis and minutes of the same are recorded.

Asset Liability Committee
  • ALCO constitutes of the following members
    • Mr. Alik Prasad (Consultant)
    • Mr. Ashutosh Sharma (Founder & Managing Director)
    • Mr. Sachin Grover (Ummeed's Management)
    • Mr. Bikash Kumar Mishra (Ummeed's Management)
  • The role and functions of the Committee are as follows:
    • To manage liquidity and interest rate risk in a dynamic situation by measuring, monitoring and taking appropriate steps.
    • To put in place the ALM system by making use of specialized software for managing assets and liabilities with respect to maturity mismatch. It shall put in place a comprehensive and dynamic framework to measure, monitor and manage the liquidity and interest rate equity and commodity price risk taking into account the rates of major operators in the financial system by closely integrating it with the business strategy of the company.
    • To evolve suitable strategy through risk policies and tolerance levels to manage the risks.
    • To recommend the board regarding limits of liquidity, interest rate and equity price risk.
    • To monitor fund investment made by the company as per investment policy.
    • Ensuring the adherence to the limits set by the board and in the line with the budget and to decide risk management objectives.
    • To decide the product pricing for the loans, maturity profile and mix of the incremental assets and liabilities.
    • To anticipate the current interest rate view of the company and base its decision for future business strategy on this view. In regard to funding policy it shall decide the source, mix of liabilities or sale of assets.
    • To develop a view on future direction of interest rate movement and decide on funding mixes between fixed vs. floating rate bonds, wholesale vs. retail, money market vs. capital market, domestic market vs. foreign currency funding and to decide the Floating Reference Rate (RFRR) and to amend / change the same from time to time, as required.
    • To review the ALM returns and take suitable remedial measures.
    • To adopt, amend, revise and modify ALM Policy of the Company in compliance with NHB’s norms.
    • To review the progress and implementation of decision made in the previous meetings.
    • To assess the funding and capital planning for the company.
    • To prepare road maps for profit planning and growth projections
Risk Management Committee
  • Mr. Alok Prasad (Consultant)
  • Mr. Ashutosh Sharma (Founder & Managing Director)
  • Mr. Sachin Grover (Ummeed's Management)
  • Mr. Rajendra Gupta (Ummeed's Management)
  • Mr. Bikash Kumar Mishra (Ummeed's Management)

The committee is constituted mainly to discuss credit risk , marketing and liquidity risk, operational risk, Money Laundering risk, Regulatory Compliance, concentration risk, Legal Risk, reputational risk.

  • The terms of reference of Risk Management Committee of the Company are as follows:

    The Risk Management Committee has been assigned the task of guiding the progressive Risk Management System, Policy and Strategy of the Company. It will devise the policy and strategy for Integrated Risk Management containing various risks exposures of the Company (credit risk, market risk and operational risk).

    • The Committee oversees the functioning of the Asset Liability Management Committee, Credit Committee and other risks committees of the Company, if any.
    • To build a strong and profitable portfolio with fair and transparent outlook by taking help of the experience and multidimensional view of the Committee Members.
    • To draft and approve the various policies pertaining to the financing activities of the Company.
    • To find out the reasons for Non-Performing Assets accounts in the Small and Medium Sector.
    • To consider the soundness of way of methods for disbursing the loan.
    • To discuss and review the recovery or collection policy etc.
    • To investigate relevant matter referred to the committee by the Board and report to the Board
    • To adopt, amend, revise, modify various product policies of the Company from time to time
Credit Committee
  • The committee constitutes of following members
    • Mr. Ashutosh Sharma (Founder & Managing Director)
    • Mr. Sachin Grover (Ummeed's Management)
    • Mr. Rajendra Gupta (Ummeed's Management)

The committee functions on day-to-day basis and has the power and authority to approve the loan and issue sanction letters to the customers. The committee constitutes of two executive Directors Mr. Sharma and Mr. Grover. Mr. Gupta is vice president, credit & risk.

Internal Complaint Committee

The committee constitutes of following members

  • Ms. Geeta Mathur (Independent director)
  • Ms. Beenata Lawrence (Ummeed's Management) (Presiding Officer)
  • Ms. Sonia Gabba (Ummeed's Management)
  • Mr. Shariq Khan (Ummeed's Management)
  • Mr. Bikash Kumar Mishra (Ummeed's Management)
  • Mr. Vikas Khandelwal (Ummeed's Management)
  • Mr. Ajitpal Singh (Ummeed's Management)
  • Mr. Salamrik Virk (External Member)
Customer Service & Grievance Redressal Committee

The committee constitutes of following members

  • Mr.Sachin Grover (Ummeed's Management)
  • Mr. Shariq Khan (Ummeed's Management)
  • Ms. Veena Mishra (Ummeed's Management)
Read More
Related Party Transaction Policy
1. BACKGROUND

Ummeed Housing Finance Private Limited (hereinafter referred to as “the Company” or “HFC” or “Ummeed”) is a Private Limited Company incorporated under the provisions of the Companies Act, 2013 (“Act”) and registered as a Housing Finance Company (“HFC”) with the National Housing Bank (“NHB”).

With the shifting of regulation of HFCs from NHB to RBI, now Reserve Bank of India’s (“RBI”) Master Direction - Non-Banking Financial Company – Housing Finance Company (Reserve Bank) Directions, 2021, shall apply to all HFCs. Therefore, this Policy is prepared in line with the said RBI Master Direction due to the onset of change in regulations for HFCs.

The Board of Directors of the Company approved this Policy to define and lay down the procedures based on applicable laws or regulatory directions to be adopted by the Company while dealing with a related party and entering into a transaction with a related party.

2. SCOPE & OBJECTIVES
2.1 Policy Objective

The Policy intends to define a governance framework for proper approval and reporting of transactions between the Company and its Related Parties. This Policy has been framed with the objective of ensuring compliance with the provisions pertaining to Related Party Transactions in the Companies Act, 2013 (“Act”), the Rules made thereunder, INDAS 24 or applicable Accounting Standards issued by the ICAI and the applicable provisions of the Master Direction - Non-Banking Financial Company – Housing Finance Company (Reserve Bank) Directions, 2021 (“Master Directions”). The present policy is designed with an objective to regulate transactions with related parties and ensure adequate systems and procedures to address potential conflict of interest and compliance with the provisions of the Act. This policy seeks to serve the following objectives:

  • To regulate and control related party transactions as intended under Companies Act/ RBI Master Directions;
  • To ensure that there is a proper system of approval for related party transactions;
  • To ensure disclosure of the related party transactions entered between the company and its related parties;
  • To ensure transparency regarding such transactions; and
  • To improve corporate governance by providing required disclosures of related party transactions.
2.2 Review of Policy

The Policy shall be reviewed periodically on such gaps as considered necessary by the Audit Committee of the Board and whenever required under the applicable directions, rules and regulations.

2.3 Policy Approval

The Board of Directors or the Audit Committee of the Board may review and may amend this policy, as and when required by the applicable laws, rules and regulations.

3. POLICY STANDARDS

All Related Party Transactions should be reported to the Audit Committee and referred for approval to the relevant authorities in accordance with this Policy.

4. DEFINITIONS
  • 4.1.1 “Act” means the Companies Act, 2013 and rules made thereunder and includes any amendment or modification thereof.
  • 4.1.2 “Arms’ Length Transaction” means a transaction between two related parties that is conducted as if they were unrelated, so that there is no conflict of interest.
  • 4.1.3 “Audit Committee or Committee” means a committee of the Board of Directors of the Company constituted under provisions of the RBI Directions and the Companies Act, 2013.
  • 4.1.4 “Board” means the Board of Directors of the Company constituted under provisions of the Companies Act, 2013.
  • 4.1.5 “Company” means Ummeed Housing Finance Private Limited.
  • 4.1.6 “Key Managerial Personnel” means key managerial personnel as defined under the Companies Act, 2013 and includes
    • i) Managing Director, or Chief Executive Officer or Manager and in their absence, a Whole-Time Director;
    • ii) Chief Financial Officer; and
    • iii) Company Secretary.
  • 4.1.7 “Material Related Party Transaction” means a transaction with a Related Party shall be considered material if the transaction / transactions to be entered into individually or taken together with previous transactions during a financial year, exceeds ten percent of the annual consolidated turnover of the company as per the last audited financial statements of the Company or such limits as may be prescribed either in the Companies Act, 2013 or other applicable regulatory directions, from time to time. Provided that in case of any amendment to the Act or applicable directions, rules and regulations, definition of Material transactions will be deemed to be changed without any further approval of Audit Committee or Board.
  • 4.1.8 “Related Party”: An entity shall be considered as related to the Company if:
    • i) Such entity/ person is a related party as per Section 2(76) of the Companies Act, 2013, or
      • a) Director or a KMP or their relatives, or
      • b) a Firm, in which a director, manager or his relative is a partner,
      • c) a Private Company in which a director or manager or his relative is a member or director,
      • d) a Public Company in which a director or manager is a director and holds along with his relatives, more than 2% of its paid-up share capital,
      • e) any Body Corporate whose Board of Directors, managing director or manager is accustomed to act in accordance with the advice, directions or instructions of a director or manager and
      • f) any Person on whose advice, directions or instructions a director or manager is accustomed to act as related party transactions.
      • g) any Body Corporate which is:
        • • holding, subsidiary or an associate company of such company
        • • a subsidiary of a holding company to which it is also a subsidiary
        • • an investing company or the venture of the company
      • h) a Director (other than an independent director) or KMP of the holding company or his relative
    • ii) Such entity is a related party under the IND AS 24 or applicable Accounting Standards issued by the ICAI
  • 4.1.9 “Related Party Transaction” shall mean all transactions between the Company on one hand and one or more related party on the other hand including contracts, arrangements and transactions as envisaged in Section 188(1) of the Companies Act, 2013 and/ or IND AS 24 or applicable Accounting Standards issued by the ICAI
  • 4.1.10 “Relative” as per section 2 (77) of the Companies Act, 2013, with reference to any person, shall be deemed to be relative of another, if he or she is related to another in the following manner, namely: -
    i) Father, including step-father;
    ii) Mother, including step-mother;
    iii) Son, including step-son;
    iv) Son’s wife;
    v) Daughter;
    vi) Daughter’s husband;
    vii) Brother, including step-brother;
    viii) Sister, including step-sister;
    ix) are members of a Hindu Undivided Family;
    x) they are Husband and wife.
5. IDENTIFICATION OF POTENTIAL RELATED PARTY TRANSACTIONS
  • 5.1 Every Director and Key Managerial Personnel (KMP) shall, at the time of appointment, annually and whenever there is any change in the information already submitted, provide requisite information (Form MBP-1) about all persons, firms, entities in which he is interested whether directly or indirectly, to the Company Secretary.
  • 5.2 For identification of the Related Parties, a Related Parties (“RP”) list will be prepared basis intimations received from the Directors/ KMPs or changes in management or shareholding structure from time to time. The updated RP List will be shared with all relevant functions and shall be referred for monitoring of the transactions and ensuring compliance at their end.
  • 5.3 Each director and Key Managerial Personnel shall be responsible for providing notice to the Board or Audit Committee of any potential Related Party Transaction involving him or her or his or her Relative, including any additional information about the transaction that the Board/Audit Committee may reasonably request. The Board/Audit Committee will determine whether the transaction does, in fact, constitute a Related Party Transaction requiring compliance with this policy.
  • 5.4 Identify the Ordinary Course of Business in relation to company.
  • 5.5 The Company’s directors and KMP shall endeavor to intimate such notice of any potential Related Party Transaction well in advance so that the Audit Committee/ the Board has adequate time to obtain and review information about the proposed transaction. All Related Party Transactions for the period will be placed for approval / noting / ratification by the Board of Directors/ Audit Committee, in accordance with this Policy. To review a Related Party Transaction, the Board / Audit Committee will be provided with all the relevant information as mentioned in the Act pertaining to the Related Party Transaction, including the name of the related party, the nature of the relationship, nature of the transaction, whether the transaction is in the ‘Ordinary Course of Business’, whether the transaction is at ‘Arm’s Length’ and any other matter, as may be required.
6. APPROVING AUTHORITIES
  • 6.1 Audit Committee: Any transaction or any subsequent modification of transactions of the company with related parties shall require the approval of the Audit Committee at a Meeting of the Audit Committee or by Circulation.
  • 6.2 Board of Directors: All “Related Party Transactions which are not in OCB or not at an Arm’s Length” shall require the prior approval of the Board of Directors at a Meeting of the Board and cannot be passed by Circulation.
  • 6.3 Shareholders: All “Related Party Transactions which are not in OCB or not at an Arms’ Length” and exceeding the prescribed criteria under Section 188 of the Act, shall require prior approval of the Shareholders’ by means of an Ordinary Resolution passed at a General Meeting.
7. PRIOR APPROVAL REQUIRED FOR RELATED PARTY TRANSACTIONS AND OMNIBUS APPROVAL

All Related Party Transactions defined/ stipulated under the Companies Act, 2013 shall require prior approval from the Audit Committee. For any ratification or exception, parameters mentioned in this Policy shall be followed.

The Audit Committee may grant omnibus approval, on an annual basis, for Related Party Transactions proposed to be entered into by the Company subject to the following conditions:

  • a) The Audit Committee shall lay down the criteria for granting the omnibus approval in line with the policy on Related Party Transactions of the Company and such approval shall be applicable in respect of transactions which are repetitive in nature;
  • b) The Audit Committee shall satisfy itself the need for such omnibus approval and that such approval is in the interest of the Company;
  • c) Such omnibus approval shall specify (i) the name/s of the related party, nature of transaction, period of transaction, maximum amount of transaction that can be entered into, (ii) the indicative base price / current contracted price and the formula for variation in the price if any and (iii) such other conditions as the Audit Committee may deem fit;
  • d) The omnibus approval shall be valid for one year as per rule 6A of the Companies (Meeting of Board and its Power) Rules, 2014.

Provided that where the need for Related Party Transaction cannot be foreseen and aforesaid details are not available, Audit Committee may grant omnibus approval for such transactions subject to their value not exceeding Rs.1 crore per transaction.

Omnibus approval shall not be made for transactions in respect of selling or disposing of the undertaking of the company and/or any other transaction the Audit Committee may deem not fit for omnibus approval.

Additionally, other related party transactions prescribed under the IND AS 24 or applicable Accounting Standards issued by the ICAI shall be presented to the Audit Committee for its review and noting.

8. ORDINARY COURSE OF BUSINESS

The phrase “Ordinary Course of Business” has not been defined under the Act or Rules made thereunder. However, the Company will adopt a reasonable approach/ methodology to demonstrate ‘Ordinary Course of Business’ which shall, inter alia, include the Nature of the transaction, the frequency / regularity / length of time the company is engaged such transaction, or transactions permitted by the Object Clause in the Memorandum of Association of the Company or such transaction/ action is consistent with the past practices and was taken in the ordinary course of the normal day-to-day operations of such company, common commercial practice i.e. customarily taken, in the ordinary course of the normal day-to-day operations of other companies that is in the same / similar line of business.

9. ARM’S LENGTH PRICING

For transactions between two related parties to be considered to be at Arm’s Length Pricing, the transaction should be conducted between the two parties as if the parties were unrelated, so that there is no conflict of interest i.e. Arm’s Length Pricing is the condition or the fact that the two related parties transact as independent (un-related) parties and on an equal footing from one or more of the following aspects viz. nature of goods/ services, risk assumed, assets/ resources employed, key terms/ covenants.

10. REVIEW AND APPROVAL OF RELATED PARTY TRANSACTIONS

Related Party Transactions will be referred to the next regularly scheduled meeting of the Audit Committee for review /noting and/ or approval as above. Any member of the Committee who has a potential interest in any Related Party Transaction will recuse himself or herself and abstain from discussion and/ or voting on the approval of the Related Party Transaction. In the event the management determines that it is impractical or undesirable to wait until a meeting of the Committee for the approval of a Related Party Transaction, due to business exigency or otherwise, such transaction may be approved by the Committee by way of circular resolution in accordance with this Policy subject to applicable statutory provisions of the Act for the time being in force and as amended from time to time. Every such transaction as approved through resolution passed by circulation shall be placed within three months from the date of transaction at the Audit Committee meeting for ratification.

To review a Related Party Transaction, the Committee will be provided with all relevant material information of the Related Party Transaction as required under the Act, including the terms of the transaction, business purpose of the transaction, benefits to the Company and to the Related Party, and any other relevant matters. In determining whether to approve a Related Party Transaction, the Committee may consider the following factors, among others, to the extent relevant to the Related Party Transaction:

  • a) Whether the terms of the Related Party Transaction are fair and on arm’s length basis to the Company and would apply on the same basis if the transaction did not involve a Related Party;
  • b) Whether there are any compelling business reasons for the Company to enter into the Related Party Transaction and the nature of alternative transactions, if any;
  • c) Whether the Related Party Transaction would affect the independence of an independent director;
  • d) Whether the proposed transaction includes any potential reputational risk issues that may arise as a result of or in connection with the proposed transaction;
  • e) Whether the Company was notified about the Related Party Transaction before its commencement and if not, why pre-approval was not sought and whether subsequent ratification is allowed and would be detrimental to the Company; and
  • f) Whether the Related Party Transaction would present an improper conflict of interest for any director or Key Managerial Personnel of the Company, taking into account the size of the transaction, the overall financial position of the director, Executive Officer or other Related Party, the direct or indirect nature of the director’s, Key Managerial Personnel’s or other Related Party’s interest in the transaction and the ongoing nature of any proposed relationship and any other factors the Board/ Committee deems relevant.

If the Audit Committee determines that a Related Party Transaction should be brought before the Board, or if the Board in any case decides to review any such matter or it is mandatory under any law for Board to approve the Related Party Transaction, then the considerations set forth above shall apply to the Board’s review and approval of the matter, with such modification as may be necessary. Further, the Audit Committee shall review, at least on a quarterly basis, the details of Related Party Transactions entered by the Company pursuant to each of the omnibus approval given.

11. NOTWITHSTANDING THE FOREGOING, THE FOLLOWING RELATED PARTY TRANSACTIONS SHALL NOT REQUIRE APPROVAL OF THE AUDIT COMMITTEE:
  • i) Any transaction that involves the providing of compensation to a director or Key Managerial Personnel in connection with his or her duties to the Company or any of its subsidiaries or associates, including the reimbursement of reasonable business and travel expenses incurred in the ordinary course of business.
  • ii) Any transaction in which the Related Party’s interest arises solely from ownership of securities issued by the Company and all holders of such securities receive the same benefits pro rata as the Related Party.
12. RELATED PARTY TRANSACTIONS NOT APPROVED UNDER THIS POLICY

In the event the Company becomes aware of a transaction with a Related Party that has not been approved under this Policy prior to its consummation, the matter shall be reviewed by the Audit Committee. The Audit Committee shall consider the relevant facts and circumstances regarding the Related Party Transaction and failure to report RP Transaction. The Committee, while deciding on the matter, shall evaluate all options available to the Company, including ratification, revision or termination of the Related Party Transaction and shall take any such action it deems appropriate including immediate discontinuation or rescission of the transaction. The Audit Committee, while considering a Related Party Transaction, will have authority to modify or waive any procedural requirements of this Policy subject to compliance of applicable statutory provisions for the time being in force.

13. INTERNAL PROCESS FRAMEWORK

The Company shall institute an appropriate internal process framework to ensure requisite approvals/ noting of all Related Party Transactions to comply with this Policy.

14. COMMUNICATION TO ALL THE DIRECTORS AND CONCERNED EMPLOYEES

The relevant aspects of this Policy will be communicated to all the directors and concerned employees/ officials of the Company.

Read More
Corporate Social Responsibility Policy
A. Background:

Ummeed Housing Finance Private Limited (hereinafter referred to as “the Company” or “Ummeed”) is a Private Limited Company incorporated under the provisions of the Companies Act, 2013 and registered as a Housing Finance Company (“HFC”) with the National Housing Bank (“NHB”).

At Ummeed, we intend to make a positive difference to society and contribute our share towards the social cause of betterment of society. We always believe in benefitting the underprivileged and those who have been deprived of even the basics in life. Helping, caring and sharing in whatever way possible is the approach, we follow when it comes to registering our presence beyond the realm of just business. With our efforts of giving back to society, we try to do our best to the society.

In this regard, Company has made this policy which encompasses the Company’s philosophy for describing its responsibility as a good corporate citizen and lays down the guidelines and mechanism for undertaking socially useful programmes for welfare & sustainable development of the community at large, which is titled as the “Corporate Social Responsibility (CSR) Policy” based on provisions of Companies Act, 2013 and rules made thereunder.

As per Section 135 of the Companies Act, 2013 (“Act”) and Companies (Corporate Social Responsibility Policy) Rules, 2014 (“Rules”), Every Company having Net worth of Rs. 500 crore or more, or Turnover of Rs. 1000 crore or more, or a Net profit of Rs. 5 crore or more during any financial year, shall have CSR Committee of the Board consisting of Directors of the Company, adopt a CSR Policy, and draw out a framework for undertaking CSR activities laid out under the said Act. Such Company is also required to ensure that it spends in every financial year at least 2% of average net profit of the Company made during the three immediately preceding financial years.

B. Composition of CSR Committee:

The Committee shall consist of total 3 (three) Directors from the Board, which includes at least 1 (one) Independent Director and other 2 (two) Directors as decided by the Board from time to time.

C. Role and Responsibilities of CSR Committee:
  • To formulate and recommend to the Board the Corporate Social Responsibility policy which shall include the activities to be undertaken by the Company as detailed in Schedule VII of the Companies Act, 2013.
  • To recommend the amount of expenditure to be incurred on activities referred above.
  • To monitor the Corporate Social Responsibility activities of the Company from time to time.
  • Review and reassess the adequacy of CSR Policy periodically and recommend any proposed changes to the Board for approval.
  • To institute a transparent monitoring mechanism for implementation of the CSR projects or programs or activities undertaken by the company.
  • Coordinate with such other agency/ entity for implementing programs and executing initiatives as per CSR policy and shall review the performance of such other agency/ entity periodically.
  • Delegate authority to subcommittees/ any individual when appropriate.
D. CSR Activities to be undertaken by the Company, as detailed in Schedule VII of the Companies Act, 2013 is given below:

The CSR Committee constituted under Section 135(1) of Companies Act, 2013 will work on any or all of the following activities as detailed in Schedule VII of the Companies Act, 2013, relating to:

  • Eradicating hunger, poverty and malnutrition, promoting health care including preventive health care.
  • Promoting education, including special education and employment enhancing vocation skills especially among children, women, elderly and the differently abled and livelihood enhancement projects.
  • Training to promote Rural sports, Nationally recognized sports, Paralympic sports and Olympic sports
  • Contributions to public funded Universities and Institutions;
  • Rural development projects and Slum area development. Explanation.- For the purposes of this item, the term `slum area' shall mean any area declared as such by the Central Government or any State Government or any other competent authority under any law for the time being in force.
E. CSR Reporting:

The disclosure of contents of Corporate Social Responsibility Policy in the Board’s report and on the company’s website, if any, shall be as per Format attached to this policy at Annexure-I.

F. Implementation Vehicle for CSR Activities:

As per the requirement, the CSR activities shall be undertaken by the Company, as per its CSR policy, on various projects or program or activities, as approved by CSR committee, through the registered trust or through registered society or through a Company established under Section 8 of the Companies Act, 2013.

G. CSR Obligation:

There is no maximum ceiling for CSR expenditure by the Company. However, as per clause 135 of the Companies Act, Company is required to spend, in every financial year, at least 2% of the average net profits of the company made during the 3 immediately preceding financial years on CSR activities.

In case the company spends an amount in excess of the aforesaid 2% of average net profits made during previous 3 fiscal, then such excess amount may be set off against the requirement to spend for such number of succeeding financial years and in such manner, as may be prescribed by the Government in this behalf.

At the end of each financial year, the Company shall prepare an annual report on CSR containing the particulars as furnished in Annexure-I.

H. CSR Budget:

The annual budget for Ummeed’ CSR initiative shall be approved by the Board of Directors on recommendation of the CSR Committee of the Company. The allocation of funds to specific projects/ programs will be as decided by the Board.

Any surplus arising out of the CSR Projects or programs or activities shall not form part of the business profit of the Company. CSR expenditure shall include all expenditure including contribution to corpus, or on projects or programs relating to CSR activities approved by the Board on the recommendation of its CSR Committee, but does not include any expenditure on an item not in conformity or not in line with activities which fall within the areas or subjects, specified in Schedule VII of the Act.

I. Monitoring the CSR activities:

Various CSR activities, projects and programs are to be monitored by the Company and progress is to be reported to be CSR committee of the Board at periodical intervals as may be required by the Committee, in the proforma similar to the annual report as furnished in the Annexure I.

J. Display of CSR activities on the website:

The contents of the CSR policy of the Company as approved by the Board shall be displayed in the Companies official website. Further, the annual report as per Annexure-I shall also be displayed in the Company’s website for public view.

K. Amendments in the policy:

Any amendment or modification to the CSR policy shall be approved by the Board on the recommendation of the CSR committee. The contents of this policy shall be disclosed on the website of the Company at: https://www.ummeedhfc.com/

Annexure-I (FORMAT FOR THE ANNUAL REPORT ON CSR ACTIVITIES TO BE INCLUDED IN TIIE BOARD'S REPORT)
  • A brief outline of the company’s CSR policy including overview of projects or programs proposed to be undertaken and a reference to the web-link to the CSR policy and projects or programs
  • The composition of the CSR Committee.
  • Average Net Profit of the company for last 3 financial years.
  • Prescribed CSR expenditure (2% of this amount as in (c) above).
  • Details of CSR spent during the financial year:
    • a) Total amount to be spent for the financial year.
    • b) Amount unspent, if any;
    • c) Manner in which the amount spent during the financial year is detailed below:
      (1) (2) (3) (4) (5) (6) (7) (8)
      Sr. No. CSR project/ activity identified Sector in which the Project is covered Projects/ Programs 1.Local area/others- 2.specify the state and district where projects or program was undertaken Amount outlay (budget) project or program wise Amount spent on the projects or programs Subheads: 1.Direct expenditure on projects or programs, 2.Overheads: Cumulative spend up to to the reporting period. Amount spent: Direct or through implementing agency*
      1              
      2              
        TOTAL            
  • In case the company has failed to spend the 2% of the average net profit of the last three financial years or any part thereof, the company shall provide the reasons for not spending the amount in its Board report.
  • A responsibility statement of the CSR Committee that the implementation and monitoring of CSR Policy, is in compliance with CSR objectives and policy of the Company.

Sd/-
(CEO of the Company/MD)

Sd/-
(Chairman of CSR Committee)

Read More