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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

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.

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 in multiple languages (English and Hindi) 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) 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 will help customers understand the terms and conditions, applicable interest rate / service charges 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, charges or terms and conditions.
  • 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 age, race, caste, gender, marital status, religion or disability unless specific to schemes promoted by the NHB 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;
    • and or 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 in addition to collecting available documentation.
  • The company will have a system of giving an acknowledgement for receipt of all loan applications.
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 that he would be contacted immediately 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 an acknowledgement of the list of documents provided to every borrower after the disbursement of loans.
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 communicated fully and transparently to all customers.
  • 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
Communication of rejection of Loan Application

If the company cannot provide the loan to the customer, it will communicate in writing that the loan has been declined and to the extent possible explain to the customers the reasons for decline

Disbursement of loans
  • Disbursement will be made in stages and in accordance with the disbursement schedule agreed by the customer or per the Agreement for Sale which covers terms of payment by the customer to the builder and based on inspection by 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 company will give notice to 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.
  • If such change is to the disadvantage of the customer, he/she may be allowed with or without any notice to close his account without having to pay any extra charges or interest.
  • The company would be free to take any decision to request the customer to close or accelerate payment or seek additional securities to the loan, will be 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 liability as guarantor;
  • the amount of liability he will be committing himself to the company;
  • circumstances in which the company will call on him to pay up his liability;
  • whether the company has recourse to his other monies in the company if he fails to pay up as a guarantor;
  • whether his liabilities as a guarantor are limited to a specific quantum or whether unlimited;
  • time and circumstances in which his liabilities as a guarantor will be discharged as also the manner in which the company will notify him about this.
  • the company will keep him informed of any default on the loan by the borrower to whom he stands as a guarantor.
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.
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 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.
Complaints and Grievances

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 letter / email/ visiting the branch office/telephonic communication. The customer may contact our office through any of the following channels.

  • By telephonic communication at 0124-4836480 between 10 am – 6 pm (except holidays).
  • Make an entry of query/complaint in the Complaint Register at the branch.
  • By way of email at customercare@ummeedhfc.com
  • By way of letter to:
    Grievance Redressal Officer
    Ummeed Housing Finance Private Limited,
    Unit no: 809-815, 8th Floor,Tower A
    Emaar Digital Greens, Golf Course Extn Road,
    Sector 61, Gurugram, 122011

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 6 weeks 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. 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

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Introduction

With reference to the guidelines regarding ‘Know Your Customer’ norms issued by the National Housing Bank (“NHB”) in terms of its Circulars No. (1) NHB(ND)/DRS/POL-No-02/2004-05 dated August 25, 2004, (2) NHB(ND)/DRS/POL-No-05/2004-05 dated September 23, 2004, (3) NHB(ND)/DRS/POL-No-08/2004-05 dated March 31, 2005, (4) NHB(ND)/DRS/POL-No-32/2009- 10 dated March 16, 2010 and (5) NHB/ND/DRS/POL-No-33/2010-11 dated October 11, 2010 wherein Housing Finance Companies(HFCs) were advised to follow certain customer identification procedure for opening of accounts and monitoring transactions of suspicious nature for the purpose of reporting it to appropriate authority, Ummeed Housing Finance Pvt. Ltd. has adhered to the guidelines of National Housing Bank.

Background

The Recommendations made by the Financial Action Task Force (FATF) on Anti Money Laundering (AML) standards and on Combating Financing of Terrorism (CFT) standards have become the international benchmark for framing Anti Money Laundering and combating financing of terrorism policies by the regulatory authorities. Compliance with these standards both by the banks/financial institutions, including HFCs, has become necessary for international financial relationships. The Reserve Bank of India(RBI) has issued revised set of comprehensive ‘Know Your Customer' Guidelines to all Non-Banking Financial Companies (NBFCs), Miscellaneous Non-Banking Companies and Residuary Non-Banking Companies in the context of the recommendations made by the Financial Action Task Force(FATF) and Anti Money Laundering (AML) standards and combating financing of terrorism policies by the regulatory authorities and advised all NBFCs to adopt the same with suitable modifications depending on the activity undertaken by them and ensure that a proper policy framework on KYC and AML measures are formulated and put in place with the approval of their respective Boards. The ‘Know Your Customer' Guidelines issued by the National Housing Bank for HFCs have been drafted and issued in the above context.

Applicability

The Know Your Customer and Anti-Money Laundering (the Policy) applies to Ummeed Housing Finance (UHF or the Company). The Policy also applies to any third parties relied upon or used by the Company to perform any of the requirements of its Anti-Money Laundering (AML) Program. This policy will be reviewed annually or on the basis of any material change in the regulatory requirements or business operations of the Company.

The said policy & measures will enable the company to know and understand its customers and their financial dealings better which in turn will help it manage risks prudently. The policy and measures will further help in preventing the company being used, intentionally or unintentionally by unscrupulous and criminal elements for money laundering activities.

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.

Policy Standards and AML Program Structure
  • 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
  • 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.
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 NHB guidelines on “Know Your Customer Guidelines & Anti Money Laundering Standards”, 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:
    • No account is opened in anonymous or fictitious/benami name(s);
    • Customers are all assessed for location of residence, business if any including type of clients and also the mode of transactions and payments;
    • Volume of turnover, social and financial status, etc. to enable categorization of customers into low, medium and high risk (these customers will require very high level of monitoring). Currently given the size of our loans and type of clients we deal with, all our customers are considered low risk;
    • Documentation requirements and other information collected in respect of different categories of customers depending on perceived risk and keeping in mind the requirements of PML Act, 2002 and guidelines issued from time to time;
    • The company will not open an account where it is unable to apply appropriate customer due diligence measures, i.e. where COMPANY is unable to verify the identity and /or obtain documents required as per the risk categorization due to non co-operation of the customer or non reliability of the data/information furnished. However, COMPANY will have suitable built-in safeguards to avoid harassment of the customer.
    • Circumstances, in which a customer is permitted to act on behalf of another person/entity, will be clearly spelt out in conformity with the established law and practices, as there could be occasions when an account is operated by a mandate holder or where an account may be opened by an intermediary in a fiduciary capacity, and
    • Checks against any notified list of the NHB or the RBI any other regulator, before accepting a customer, to 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.

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.

  • The company will prepare a profile for each new customer which may contain information relating to the customer's identity, social/financial status, nature of business activity, information about his clients' business and their location, etc. The nature and extent of due diligence will depend on the risk perceived by COMPANY. However, while preparing the customer profile, COMPANY will seek only such information from the customer which is relevant and is not intrusive. The customer profile will be a confidential document and details contained therein will not be divulged for cross selling or any other purposes.
  • Given the nature of our business – small ticket loans to low and middle income, informal and financially excluded families – we have categorized our customers as low risk.. It is highly unlikely that COMPANY will have any medium / high risk clients given its focus on the lower income section of society, but for information, examples of customers requiring higher due diligence may include:
    • non-resident customers,
    • high net worth individuals,
    • trusts, charities, NGOs and organizations receiving donations,
    • companies having close family shareholding or beneficial ownership,
    • firms with 'sleeping partners',
    • politically exposed persons (PEPs) of foreign origin,
    • non-face to face customers, and
    • those with dubious reputation as per public information available, etc.

It is important to bear in mind that the adoption of Customer Acceptance Policy and its implementation will not result in denial of COMPANY’s services to the general public, especially to those who are financially or socially disadvantaged.

Customer Identification Procedures
  • COMPANY will follow clear NHB guidelines on the Customer Identification Procedure to be carried out at different stages, i.e. while establishing a relationship; carrying out a financial transaction or when COMPANY has a doubt about the authenticity/veracity or the adequacy of the previously obtained customer identification data. Customer identification means identifying the customer and verifying his/ her identity by using reliable, independent source documents, data or information. COMPANY will obtain sufficient information necessary to establish, to its satisfaction, the identity of each new customer, whether regular or occasional and the purpose of the intended nature of relationship. Being satisfied means that COMPANY must be able to satisfy the competent authorities that due diligence was observed based on the risk profile of the customer in compliance with the extant guidelines in place. Besides risk perception, the nature of information/documents required would also depend on the type of customer (individual, corporate etc). For customers that are natural persons, which will be most of its clients, COMPANY will obtain sufficient identification data to verify the identity of the customer, his address/location, and also his recent photograph. For customers that are legal persons or entities (very unlikely to be a customer except for project finance to construction companies), COMPANY will:
    • verify the legal status of the legal person/ entity through proper and relevant documents;
    • verify that any person purporting to act on behalf of the legal person/entity is so authorized and identify and verify the identity of that person; and
    • understand the ownership and control structure of the customer and determine who are the natural persons who ultimately control the legal person.

Where COMPANY is unable to apply appropriate KYC measures due to non-furnishing of information and /or non-cooperation by the customer, COMPANY may consider closing the account or terminating the business relationship after issuing due notice to the customer explaining the reasons for taking such a decision.

Monitoring of Transactions

Ongoing monitoring is an essential element of effective KYC procedures. COMPANY can effectively control and reduce its risk only if it has an understanding of the normal and reasonable activity of the customer so that it can identify transactions that fall outside the regular pattern. However, the extent of monitoring will depend on the risk sensitivity of the account. Since COMPANY will not have any deposit accounts, this situation will hardly arise, but COMPANY will in any case pay special attention to all complex, unusually large transactions and all unusual patterns which have no apparent economic or visible lawful purpose, or transactions that involve large amounts of cash inconsistent with the normal and expected activity of the customer. COMPANY will put in place a system of periodical review of risk categorization of accounts and the need for applying enhanced due diligence measures. COMPANY will ensure that a record of transactions in the accounts is preserved and maintained as required in terms of section 12 of the PML Act, 2002 (and the Amended Act, 2009). It will also ensure that transactions of suspicious nature and/or any other type of transaction notified under section 12 of the PML Act, 2002 (and the Amended Act, 2009), is reported to the appropriate law enforcement authority.

Risk Management

The Board of Directors of COMPANY has ensured that an effective KYC program is in place and has established appropriate procedures and is overseeing its effective implementation. The program covers proper management oversight, systems and controls, segregation of duties, training and other related matters. Responsibility has been explicitly allocated within COMPANY to ensure that COMPANY’s policies and procedures are implemented effectively. The Board of COMPANY is aware that while all customers will be of low risk profile given the nature of its business, unless belonging to a higher risk profile listed under #5 above and approved as an exception, it will apply various Anti Money Laundering measures keeping in view the risks involved in a transaction, account or business relationship.

COMPANY's Board -through its Audit Committee will directly evaluate and ensure adherence to the KYC policies and procedures, including legal and regulatory requirements.

COMPANY has already ensured that its front line staff and credit staff are aware that no loan accounts will be created unless the KYC procedures are adhered to completely.

Customer Education

The implementation of KYC procedures requires COMPANY to demand certain information from customers, 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. COMPANY’s front line staff will therefore personally discuss this with customers and if required, COMPANY will also prepare specific literature/ pamphlets, etc. so as to educate the customer on the objectives of the KYC program.

Introduction of New Technologies

COMPANY will pay special attention to any money laundering threats that may arise from new or developing technologies including on-line transactions that might favour anonymity, and take measures, if needed, to prevent its use in money laundering schemes.

Appointment of Principal Officer

COMPANY has appointed Shariq Khan to be designated as ‘Principal Officer'. Per the NHB guidelines, the Principal Officer will be located at the corporate office and will be responsible for monitoring and reporting of all transactions and sharing of information as required under the law. He will maintain close liaison with enforcement agencies, other HFCs and any other institution which are involved in the fight against money laundering and combating financing of terrorism.

Maintenance of records of transactions
  • Though it will be unlikely in COMPANY’s case, due to its focus on lower income families, COMPANY has a system of maintaining proper record of transactions prescribed under Rule 3, of the Prevention of Money-Laundering and value of transactions, the procedure and manner of maintaining and verification and maintenance of records of the identity of the clients of the Banking Companies, Financial Institutions and Intermediaries) Rules, 2005, as mentioned below:
  • 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 cash transactions where forged or counterfeit currency notes or bank notes have been used as genuine and where any forgery of a valuable security has taken place;
  • all suspicious transactions whether or not made in cash and by way of as mentioned in the Rules.
Information to be preserved
  • As per the NHB guidelines, COMPANY is required to maintain the following information in respect of transactions referred to in Rule 3:
    • 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.
Maintenance and Preservation of records

COMPANY has a system for proper maintenance and preservation of account information in a manner that allows data to be retrieved easily and quickly whenever required or when requested by the competent authorities. COMPANY will maintain for at least ten years from the date of cessation of transaction between the bank and the client, all necessary records of transactions, both domestic or international, which will permit reconstruction of individual transactions (including the amounts and types of currency involved if any) so as to provide, if necessary, evidence for prosecution of persons involved in criminal activity.

COMPANY will also ensure that records pertaining to the identification of the customer and his / her address (e.g. copies of documents like passports, identity cards, driving licenses, PAN, utility bills etc.) obtained while opening the account and during the course of business relationship, are properly preserved for at least ten years after the business relationship is ended. The identification records and transaction data will be made available to the competent authorities upon request.

Reporting to Financial Intelligence Unit-India

In terms of the PMLA rules, COMPANY will report information relating to cash and suspicious transactions to the Director, Financial Intelligence Unit-India (FIU-IND) at the following address:

Director, FIU-IND,
Financial Intelligence Unit-India,
6 th Floor, Hotel Samrat,
Chanakyapuri,
New Delhi-110021

COMPANY will ensure that the provisions of PMLA Rules framed and the Foreign Contribution and Regulation Act, 1976, wherever applicable, are adhered to strictly.

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Grievance Redressal Mechanism

This Grievance Redressal Mechanism is prepared, inter-alia, for redressal of customer’ grievances arising out of the scheme for grant of ex-gratia payment to eligible borrowers and all other complaints, grievance, questions, or queries.

The complaint if any, directly received by Corporate Office from the Customer, will be attended in consultation with the concerned branch.

Similarly, the Complaint(s) if any, received at branch(es) other than through Complaint Register, shall be recorded in the Complaint Register and redressed in consultation with Corporate Office.

Ummeed Housing Finance Private Limited (“Ummeed” or “Company”) will make available facilities at each of its branches and offices for the customers to lodge and/or submit their complaints or grievances, if any.

  • The customer may contact our office through any of the following channels.
    • By telephonic communication at 0124-4836480 between 10 am – 6 pm (except holidays).
    • Make an entry of query/complaint in the Complaint Register at the branch.
    • By way of email at customercare@ummeedhfc.com
    • By way of letter to the below mentioned address:

      Grievance Redressal Officer
      Ummeed Housing Finance Private Limited,
      Unit 809-815,8 floor, Tower A, Emaar Digital Greens Golf Course Extension Road, Sector-61 Gurugram 122102 HR IN

In case, the response is unsatisfactory or the response is not received from the Company within a reasonable time (i.e. 6 weeks) or the Customer is dissatisfied with the response received, the Customer may approach National Housing Bank (NHB) at the following Email id/ address / NHB’s Grievance Redressal Mechanism on its online portal:

  • By way of email at crcell@nhb.org.in
  • By way of letter to the below mentioned address:

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

  • https://nhb.org.in/
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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 legal or regulatory requirements, incorrect or misrepresentation of any financial statements and reports, etc.

This Policy is formulated in terms of direction related to constitution of Audit Committee under the provisions of Housing Finance Companies – Corporate Governance (NHB) Directions, 2016 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 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 releases 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 direction under Housing Finance Companies – Corporate Governance (NHB) Directions, 2016.
  • "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 speculative 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.
  • "Whistle 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 Whistle Officer. 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.
  • "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
  • 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
  • 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 Control 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

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 victimisation
  • Ensure complete confidentiality
  • Not attempt to conceal evidence of the Protected Disclosure
  • Take disciplinary action, if any one 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.

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.

Company's Powers

The Company is entitled to amend, suspend or 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.p>

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.

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Most Important Terms and Conditions (MITC)

Ummeed Housing Finance Private Limited

The Most Important Terms and Conditions (MITC) of loan with Loan Account No.__________________________ between Shri / Smt.___________________________and other co- borrowers and Ummeed Housing Finance Private Limited (hereinafter referred as Ummeed Housing Finance) are agreed upon and mentioned below:

Loan Details
  • Loan Amount Sanctioned :
  • Type Loan : HL LAP BL STBL
  • Loan Agreement Date :
  • Tenure of Loan :
  • Rate Method : Fixed Rate / Floating Rate
Interest Chargeable
  • Interest chargeable: .............../% which is Ummeed Reference Rate (URR) +/ - ..............%
  • Moratorium or subsidy (If any, please specify):
  • Date of Reset of Interest Rate:
  • 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
Installment type
  • Repayment of loan through monthly Installment.
  • Amount: ..............(In Figures). Subject to change with a change in URR in case of floating rate loans.
  • Date of Commencement of EMI :
  • Due Date for EMI :
Loan tenure

__________months (Subject to change with a change in Ummeed Reference Rate in case of floating rate loans)

Loan Purpose
  • Home Loan
  • Plot Purchase Plus Construction
  • Repair & Renovation
  • Home Extension Loan
  • Construction Refinance
  • Purchase Refinance
  • Loan Against Property
  • Business Loan
  • Small Ticket Business Loan
  • Others (Please Specify) ________________________
Fees and applicable Charges
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
Processing Fee Up to 3% Up to 4%
CERSAI Charge Up to Rs.750/- or as applicable Up to Rs.750/- or as applicable
Loan Cancellation Charges Rs.5000/- or 1% Fees whichever is higher Rs.5000/- or 1% Fees 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) 1% 1%
Repayment Swap Charges Rs.500/- Rs.500/-
Statement of Accounts/Duplicate NOC/Foreclosure Letter) Rs.300/- per statement Rs.300/- per statement
Retrieval of copy of documents Rs.1000/- Rs.1000/-
Pre-Closure Charges (Fixed Rate of Interest) by Individual Borrowers 5% on Principal Outstanding. In case pre-closure of loan is through own sources (except borrowing from Bank / HFC / NBFC / Any other Financial Institution) No fee is applicable 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 NIL
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
Applicable Taxes will be charged over and above the charges mentioned above in the Tariff Sheet
Note :
  • 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.
  • We share credit performance details of your loan account wi th credit information bureau of India limited (CIBIL) and with other bureau agencies.
Non-Refundable Commitment Fees, if loan not sanctioned/disbursed –
  • Home Loan - Not to exceed INR 10,000/- + Applicable Taxes.
  • Non-Home Loan - Not to exceed INR 10,000 + Applicable Taxes.
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).
    ..........................................................................................................................................
    ..........................................................................................................................................
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.
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.
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
Procedure for recovery of Over dues :
  • 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.
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.
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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: 1295880)
    • Mr. Vishal Mehta, Nominee & Non-Executive Director (DIN: 00256331)
    • Mr. Inderjit Walia, Independent Director (DIN: 02582205)
    • Ms. Geeta Mathur, Independent Director (DIN: 2139552)
    • Mr. Kartik Srivasta, Non-Executive Director (DIN: 3559152)
    • 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 has been recently appointed as Independent Director effective 23rd March 2018. Mr. Alok Prasad is the non-executive Director of the Company. The Board also constitutes Nominee Directors, Mr. Vishal Mehta is the nominee director for M/s Lok Capital Growth Fund and Mr. Anurag Bhargava is nominee director of M/s Duane Park Private Limited.

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 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 Srivasta (LGT nominee director)

The terms of reference of the Audit Committee of the Company, are as 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 frame work 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. Harish Gupta (Ummeed's Management)
  • Ms. Veena Mishra (Ummeed's Management)
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