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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

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”, or the “company”), pursuant to the Reserve Bank of India’s (“RBI”) Master Direction - Non-Banking Financial Company – Housing Finance Company (Reserve Bank) Directions, 2021.

1) Objectives:

The primary objective of these codes are as below-

1. To promote good and fair practices by setting minimum standards in dealing with customers.

2. To increase transparency so that the customer can have a better understanding of the services expected.

3. To promote a fair relationship between the company and the customer.

4. To encourage market forces, through fair competition, to achieve higher operating standards.

5. To foster confidence in the housing finance system overall.

2) Application of the Code:

1. The Code would be applicable to all persons offering all the Products and Services of the company as an employee or offering any Products and Services of other Service Provider under Agency Arrangements or otherwise in any manner and / or by any mode.

2. The Code is applicable under normal operating environment except in the event of any force majeure.

3. The Code is based on ethical principles of integrity and transparency and all actions and dealings will follow the spirit of the Code.

3) 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 charges/ 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.

· Contents of this code will be covered appropriately in employee training modules to give relevant trainings to employees so that the code will effectively put into practice.

4) Advertising, Marketing and Sales:

The company will

· Ensure that all advertising and promotional material is clear, factual 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 and / or on the website of the Company.

· The company will ensure proper communication on interest rates, processing fees and charges to the prospective customers by putting up

a) personal discussion with the prospect;

b) Notices in its branches;

c) through telephone or help-lines;

d) on the company’s website;

e) 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.

5) 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.

6) 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 charges to be 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.

7) 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. Any changes in interest rates and charges can be done only prospectively and if such change is to the disadvantage of the borrower, he/ she may within 60 days and without notice close his/ her account or switch it without having to pay any extra charges or interest.

· 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:

a) Where the housing loan is on floating interest rate basis.

b) 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.

· Company 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, and shall be handed over along with a copy of this code to the borrower under acknowledgement.

8) Penal Charges Policy:

In compliance with RBI Circular dated August 18, 2023, on Fair Lending Practice - Penal Charges in Loan Accounts, the Company, establishes the following board approved policy on penal charges or similar charges on loans, which shall come into effect from January 1, 2024:

Treatment of Penal Charges:

· Penalty, if charged, for non-compliance of material terms and conditions of the loan contract by the borrower shall be treated as 'penal charges.'

· Penal charges will not be levied in the form of 'penal interest' and further added to the interest rate charged on advances.

· There shall be no capitalization of penal charges, i.e., no further interest will be computed on such charges. However, this will not affect the normal procedures for compounding of interest in the loan account.

Components of Interest Rate:

· The Company shall not introduce any additional component to the rate of interest and will ensure compliance with these guidelines in both letter and spirit.

Reasonable Quantum:

· The quantum of penal charges is reasonable and commensurate with the non-compliance of material terms and conditions of the loan contract without being discriminatory within a particular loan/product category, and further reviewed and approved by the Board before mentioning into MITC Documents.

Equality for Individual Borrowers:

· Penal charges in case of loans sanctioned to 'individual borrowers, for purposes other than business,' would not be higher than the penal charges applicable to non-individual borrowers for similar non-compliance of material terms and conditions.

Disclosure and Communication:

· The quantum and reason for penal charges will be clearly disclosed to customers in the loan agreement and most important terms & conditions (MITC) documents which will be handed over to the borrower and a copy of MITC will also be hosted on the website of the Company, in addition to being displayed on the Company's website under Interest rates and Service Charges.

· Whenever reminders for non-compliance are sent to borrowers, the applicable penal charges will also be communicated. Any instance of the levy of penal charges and the reason therefor shall also be communicated.

Transparent Communication:

· The Company is committed to provide information on interest rates, common fees and charges (including penal charges, if any) through various communication channels, including notices in branches, telephone or help-lines, the company’s website, designated staff/help desk, and service guide/tariff schedule available at branches.

9) Important Customer Communication:

· 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.

· Interest Rate Model: 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 charges, 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.

· 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 Company, 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.

10) Policy on Reset of Floating Interest Rate on EMI:

In compliance with RBI Circular dated August 18, 2023, on Reset of Floating Interest Rate on Equated Monthly Instalments (EMI) based Personal Loans, the Company, establishes the following board approved policy on Reset of Floating Interest Rate on its loans to borrowers, which shall come into effect by December 31, 2023:

Communication and Impact Assessment

· Sanction letters will explain how changes in benchmark interest rates may affect EMIs and/or the loan tenor. The company commits to promptly communicating any adjustments through appropriate channels, ensuring transparency in the process.

Reset Options

· Upon interest rate reset, borrowers will be provided the option to switch to a fixed rate subject to applicable switching fee in accordance with MITC. The Company may fix the permissible frequency of such switches during the loan tenor. Borrowers can also choose to enhance EMI, elongate tenor, or opt for a combination of both. Additionally, borrowers retain the right to prepay partially or in full at any point during the loan tenor, adhering to existing foreclosure charges/pre-payment penalty charges in accordance with MITC.

Transparent Disclosure

· Applicable Switching Fee for option to switch from floating to fixed rates and any other applicable service charges/administrative costs linked to the mentioned options will be clearly disclosed in the MITC and shall be communicated to the Borrower from time to time during subsequent revisions, if any.

No negative amortization

· Ummeed Housing Finance will be ensuring that elongation of tenor for floating-rate loans does not result in negative amortization.

Quarterly Statements

· Ummeed Housing Finance will arrange to provide access to borrowers with quarterly statements via appropriate channels or mobile applications, detailing principal and interest recovered, EMI amount, remaining EMIs, and the annualized rate of interest/Annual Percentage Rate (APR) in a clear and easily understood format.

Communication to Existing Borrowers

· Existing borrowers will receive communication through appropriate channels, outlining the available options under this policy by December 31, 2023.

11) Release of Property Documents on Repayment/ Settlement of Loans:

In compliance with RBI Circular dated September 13, 2023, on responsible lending conduct – release of movable / immovable property documents on repayment/ settlement of personal loans, the Company, establishes the following board approved policy on release of property documents on repayment/ settlement of loans by borrower, which shall come into effect by December 1, 2023:

· Ummeed is dedicated to releasing all original property documents and removing associated charges within 30 days of full repayment/settlement of the loan account by the Borrower, provided there are no pending dues and fulfilment of obligations by Borrower. Upon settlement and a written request, the Borrower can collect documents from the nearest HUB office or the branch where the loan was serviced, based on preference of Borrower. A list of HUB offices will be promptly shared upon fulfilling all obligations by Borrower. The loan sanction letter will contain details on the timeline and place for returning original property documents.

· In the event of the borrower's demise, Ummeed Housing Finance will adhere to a predefined procedure for returning property documents to legal heirs, as displayed on Ummeed Housing Finance's website.

· Any delay beyond 30 days post-repayment in releasing property documents or filing charge satisfaction forms will be communicated to the borrower. If the delay is finally attributable to Ummeed Housing Finance, compensation at the rate of Rs. 5,000 per day of delay will be provided.

· In cases of loss or damage to property documents, Ummeed Housing Finance will assist the borrower in obtaining duplicate/certified copies, bearing associated costs. Delay compensation will apply, with an additional 30-day resolution period, i.e., after a total period of 60 days from the date of full satisfaction of the borrower's obligations.

12) Website and Other Modes of Disclosure:

· The rates of interest and the approach for gradation of risks, and penal charges/ penalty (if any) shall also be made available on the website of the company 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 charges (if any) must be annualised rate and made available on the website to make the borrowers aware of the exact rates that would be charged by the Company.

· The Company will publish on its website the interest rate range of contracted loans for the past quarter for different categories of loans or advances granted to individual borrowers along with mean interest rates for such loans.

· Company's website publishes an Annual Percentage Rate (APR) or such similar other arrangement of representing the total cost of credit on a loan to an individual borrower.

13) 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 material adverse change/s in the financial position of the borrower to whom he/ she 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.

14) 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.

15) 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.

16) 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:

a) 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.

b) Identity and authority to represent the company will be made known to the customer at the first instance.

c) Customer’s privacy will be respected.

d) Interaction with the customer will be in a civil manner.

e) 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.

f) 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.

g) All assistance will be given to resolve disputes or differences regarding dues in a mutually acceptable and in an orderly manner.

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

17) Responsibility of Board of Directors:

The Board of Directors of the Company shall -

a) 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;

b) Periodically review a consolidated report on compliances of this Code and the functioning of the grievance redressal mechanism at various levels of management;

c) 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;

d) 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.

18) Complaints and Grievances:

The Company ensures to maintain a system and/or procedure is in place for receiving, registering and disposing of complaints and grievances of borrowers in each of branches/offices, including those received on-line.

Level 1

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

· By telephonic communication at 1800 2126 127 between 10:00 am to 05.30 pm (except holidays).

· Make an entry of query/ complaint in the Complaint Register at the branch and fill the CRF form. · By way of writing an email at “customercare@ummeedhfc.com” or “enquiry@ummeedhfc.com”

Level 2

If the customer does not receive any response from the company within 15 days or is not satisfied with the resolution provided by the above channel, the customer may complaint to the Grievance Redressal Manager of by way of writing letter/ Email to:

 

Mrs. Veena Mishra

Sr. Manager – Customer Service & Grievance Redressal

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: service@ummeedhfc.in

Contact No.: 0124-4836480

Level 3

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. Sandeep Verma

Grievance Redressal Officer

Ummeed Housing Finance Private Limited,

Unit 809-815, 8'h Floor, Tower A, Emaar Digital Greens,

Golf Course Extension Road, Sector 61,

Gurugram — 122102 Email ID: grievance@ummeedhfc.in

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. 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 4

In case your complaint has not been resolved to your satisfaction, you can also approach the Complaint Redressal Department of National Housing Bank by lodging its complaints in Online mode at the link: https://grids.nhbonline.org.in/(S(r3ep3nauzqhjria21ha42gms))/Complainant/Default OR in offline mode by post, in prescribed format available at link: https://nhb.org.in/wp-content/uploads/2021/08/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:

 

Grievance Redressal Department

National Housing Bank

Core 5A, India Habitat Centre

Lodhi Road

New Delhi -110 003

 

19) Publication:

The Company shall display various key aspect such as service charges, interest rates, Penal charges (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.

20) Review of Code:

The aforementioned code encompasses various policies aligning with fair lending practices, established in adherence to the guidelines and directives outlined in RBI’s Master Directions - Non-Banking Financial Company – Housing Finance Company (Reserve Bank) Directions, 2021, and other circulars issued by the Reserve Bank of India. This framework will undergo periodic reviews and amendments, either in response to modifications in Directions or circulars issued by the RBI, or annually, whichever occurs earlier. Any necessary Operating Procedures for the policy's implementation, if required at any stage, will be issued with the approval of the Managing Director.

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Contents

1.      Background. 2

2.      Objectives 2

3.      Scope. 2

4.      Policy Standards and AML Program Structure. 3

4.3   Beneficial Owner (BO) 4

4.6   Customer Acceptance Policy (CAP) 5

4.7   Customer Identification Procedures (CIP) 7

4.8   Money Laundering and Terrorist Financing Risk Assessment 8

4.9   Risk Categorization. 8

4.10 AML Risk Mitigation Tools: 12

4.11 KYC and Customer Due Diligence (CDD) 12

5.      Enhanced Due Diligence (“EDD”) 15

6.      Politically Exposed Persons (“PEPs”) 17

7.      Negative List 17

8.      Sanctions List 17

9.      Appointment of the Principal Officer (PO) / Money Laundering Reporting Officer (MLRO) & Designated Director. 18

10.   Reporting to Financial Intelligence Unit-India (FIU-IND) 19

11.   Reporting of Cash Transactions. 20

12.   Suspicious Transactions- Monitoring and Reporting. 20

13.   Central KYC Records Registry (CKYCR) - and reporting requirements under Foreign Account Tax Compliance Act (FATCA)/ Common Reporting Standards (CRS) 21

14.   Record-keeping Requirements. 21

15.   Hiring & Training of Employees and Customer Education. 22

16.   Audit of the KYC & AML Program and other Reporting Requirements. 23

17.   Consequences of Non-Compliance. 24

Annexure I 25

Annexure II 33

 

 

 

Know Your Customer and Anti-Money Laundering Policy

 

  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 and the amendments made thereto, as applicable to NBFCs (including HFCs).

 

  1. 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.

  1. Scope

 

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 /outsourced 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:

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      • 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

      • Co-operate with AML-related law enforcement and regulatory agencies fully under applicable laws.

      • Designate officials for overall compliance of KYC and AML procedures and for reporting purposes to Financial Intelligence Unit (FIU-IND).

 

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.

Annual Review

The Policy shall be reviewed annually by the Board of Directors of the Company, to incorporate the changes as are required due to modifications in applicable directions, rules and regulations.

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:

 

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      • Formulating and periodically reviewing the Policy in line with the applicable regulatory guidelines;

      • Reviewing the reports of Internal Audit and /or the feedback on the status of compliance submitted by the Principal Officer (PO) every quarter;

      • Reviewing the staff training program and also customer related educational/informational material on KYC/AML;

      • Reviewing quarterly reports relating to fraud prevention, control and reporting and recommending appropriate action to the Board.

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.   

  1. Policy Standards and AML Program Structure

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

  1. Customer Acceptance Policy (CAP)

  2. Customer identification Procedures (CIP)

  3. Monitoring of Transactions, and

  4. Risk Categorization

  5.  
    1. For the purpose of the Policy, a ’Customer’ is defined as:

      1. a person or entity (including an employee) that maintains an account and/or has a business relationship with the Company, including the walk-in customer;

      2. one on whose behalf the account is maintained (i.e., the beneficial owner);

      3. beneficiaries of transactions conducted by professional intermediaries, such as Stockbrokers, Chartered Accountants, Solicitors etc. as permitted under the law, and

      4. 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.

  6.  
    1. Beneficial Owner (BO)

      1. 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 10 per cent of the shares or capital or profits of the company.

  • “Control” shall include the right to appoint a 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.

    1.  

      1. 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 10 per cent of capital or profits of the partnership or who exercises control through other means.

                          Explanation – Term “control” shall include the right to control the management or policy decision.

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    1.  
      1. 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.

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    1.  
      1. 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 10 per cent 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.

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    1.  
      1. Exemption from identification of BO: It is not necessary to identify and verify the identity of any shareholder or beneficial owner of such an entity. where the customer or the owner of the controlling interest is:

  • An entity listed on a stock exchange in India; or

  • An entity resident in jurisdictions notified by the Central Government and listed on stock exchanges in such jurisdictions; or

  • A subsidiary of such listed entities.

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    1. 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.

  2.  
    1. Obtaining the additional information other than the mandatory information for identification of customer, where 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.

  3.  
    1. Customer Acceptance Policy (CAP)

The Company has developed 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 shall form an integral part of the Group wide AML Policy.

The features of the CAP are detailed below:

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    1.  
      1. The Company will 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.

      2. Where Permanent Account Number (PAN) is obtained, the same shall be verified from the verification facility of the issuing authority. Similarly, if the GST number is available, then the Company will verify it using the search/verification facility provided by the issuing authority.

      3. Where an equivalent e-document is obtained from the customer, the Company shall verify the digital signature as per the provisions of the Information Technology Act, 2000 (21 of 2000).

      4. 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.

      5. 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.

      6. 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. The Company may rely, at their own option, on third party certification/introduction under the terms of the following outsourcing agreement.

(i) Records or the information of the customer due diligence carried out by the third party is obtained immediately from the third party or from the Central KYC Records Registry.

(ii) Adequate steps are taken by the Company to satisfy themselves that copies of identification data and other relevant documentation relating to the customer due diligence requirements shall be made available from the third party upon request without delay.

(iii) The third party is regulated, supervised or monitored for, and has measures in place for, compliance with customer due diligence and record-keeping requirements in line with the requirements and obligations under the PML Act.

(iv) The third party shall not be based in a country or jurisdiction assessed as high risk.

(v) The ultimate responsibility for customer due diligence and undertaking enhanced due diligence measures, as applicable, will be with the Company.

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      1. The purpose of commencing the relationship/opening of accounts shall be established and the beneficiary of the relationship/account shall also be identified.

      2. The information collected from the customer shall be kept secure and confidential.

      3. Appropriate Enhanced Due Diligence (EDD) measures will 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.

      4. In respect of unusual or suspicious transactions/applications or when the customer moves from a lower risk to a high-risk profile, appropriate EDD measures shall be adopted.

      5. The Company will ensure that the identity of the customer does not match with any person with known criminal background or with banned entities/ individual such as individual terrorists or terrorist organizations, etc. For this purpose, the Company maintains 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 to any of the individuals/entities in the list shall be treated as suspicious and reported.

      6. 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. The Company also consider filing an STR to FIU-IND, if necessary, when it is unable to comply with the relevant CDD measures in relation to the customer

      7. 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.

      8. If it is suspected that money laundering or terrorist financing and it seems to believe that performing the Customer Due Diligence (CDD) process will alert the customer, the Company will not proceed with the CDD process. Instead, it should file a Suspicious Transaction Report (STR) to FIU-IND,.

      9. Further, additional information that is not specified anywhere in this Policy, if required for the purposes of efficient implementation of this policy, can also be taken with the explicit consent of the customer.

 

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.

 

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    1. Customer Identification Procedures (CIP)

      1. The Company shall obtain satisfactory evidence of the identity of the customer in the following cases:

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              1. If there is any perceived risks at the time of commencement of relationship/opening of account, or

              2. when there is a doubt about the authenticity or adequacy of the customer identification data it has obtained, or

              3. selling third party products as corporate agents, selling own products and any other product for more than rupees fifty thousand and transaction details of sale of third-party products and related records shall be maintained as prescribed in section 14 of this Policy i.e., Record-keeping Requirements or

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

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      1. The company shall ensure that introduction is not to be sought while opening accounts.

      2. In order to avoid customer inconvenience, under special circumstances, the Company may also rely on certain data/information available to 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.

      3. 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.

      4. Indicative guidelines on Customer Identification requirements are provided in Annexure 1.

      5. 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 the Master Direction issued by RBI.

  2.  
    1. Money Laundering and Terrorist Financing Risk Assessment

The Company shall undertake, that:

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      1. Periodic Risk Assessment’ exercise for ‘Money Laundering (ML) and Terrorist Financing (TF);

      2. Risk assessment process should consider all the relevant risk factors, level of overall risk & type of mitigation to be applied;

      3. Risk assessment process shall be properly documented and be proportionate to the nature, size, geographical presence, complexity of activities/structure, etc. of the Company;

      4. Periodicity of risk assessment exercise shall be determined by the Board, or the Audit Committee and the Risk Management Committee to which power in this regard has been delegated, which should be reviewed at least annually;

      5. Outcome of the exercise shall be put up to the Board/ Audit Committee;

      6. A Risk-Based Approach (RBA) is to be adopted for the mitigation and management of identified risks in accordance with the provisions outlined in Board-approved policies, controls, and procedures as specified under the Risk Management Policy of the Company. This approach includes the incorporation of a Customer Due Diligence (CDD) Programme. The CDD Programme should take into consideration the Money Laundering (ML) and Terrorist Financing (TF) risks identified by Ummeed or through the National Risk Assessment, with due regard to the size of the business

      7. Monitoring of implementation of the controls and enhance them if necessary.

 

  1.  
    1. Risk Categorization

Ummeed will categorize its customers into High, Medium, and Low risk categories based on the perceived Anti-Money Laundering (AML) risk. The risk categorization may be conducted using the following parameters based on the types of borrowers and the assessment of risk perception:

  • Customer’s identity

  • Social/financial status

  • Nature of business activity

  • Information about the customer’s business and their location

  • Geographical risk covering customers as well as transactions

  • Type of products/services offered

  • Delivery channel used for delivery of products/services

  • Types of transaction undertaken – cash, cheque/monetary instruments, wire transfers, forex transactions, etc.

In the process of considering customer identity, the ability to verify identity documents through online or other services offered by issuing authorities may also be taken into account.

The risk categorization of a customer and the specific reasons for such categorization will be kept confidential. Provided that various other information collected from different categories of customers relating to the perceived risk, is non-intrusive and the same is specified in the KYC Policy.

FATF Public Statement, the reports and guidance notes on KYC/AML issued by the Indian Banks Association (IBA), and other agencies, etc., may also be used in risk assessment.

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      1. Medium/High Risk from AML perspective- Customers that are likely to pose a higher-than-average risk to the Company may be categorized as medium or high risk depending on customer's background, nature and location of activity, country of origin, sources of funds and his client profile, etc. Such category of customers will include the following:

        1. Politically Exposed Persons (PEP’s);

        2. Non-Resident Indians;

        3. Certain Non-Governmental Organizations (“NGOs”), Trusts and unregulated charities;

        4. Money services businesses (“MSBs”), including licensed money transmitters and currency exchangers, and their owners;

        5. Dealers in high value or precious goods, such as jewel, gem or precious metal dealers, antique dealers and auction houses, and their owners;

        6. Casinos and other gambling businesses, their payment providers, and their owners;

        7. Arms and ammunitions manufacturers and dealers;

        8. 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;

        9. High Net Worth individuals, with Loan amount of more than Rs.3 crore;

        10. 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.

      2. The Company will apply enhanced due diligence measures for higher risk customers, especially those for whom the sources of funds are not clear.

      3. Low-Risk Customers: All other customers (other than Medium/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.

      4. Periodical Review: 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 out such review of risk categorization of customers at a periodicity of not less than once in six months.

      5. Periodical Updation: The Company shall also introduce a system of periodical updation of customer identification data (including photograph/s) after the account is opened to ensure that the information or data collected is kept up-to-date and relevant, particularly where there is high risk. The periodicity of such updation will not be less than once in ten years in case of low-risk category customers, not less than once in eight years in case of medium risk categories and not less than once in two years in case of high risk categories.

      6. Aadhaar OTP based e-KYC in non-face to face mode can be used for periodic updation. Declaration of current address, if the current address is different from the address in Aadhaar, shall not require positive confirmation in this case. The Company will, however, ensure that the mobile number for Aadhaar authentication is same as the one available with them in the customer’s profile, in order to prevent any fraud. It may be noted that the Company shall not be relying on OTP based verification in the account opening stage due to regulatory restrictions on credit limits, in such cases, till the verification is completed through normal CDD procedures.

 

[Following is the process for Updation / Periodic Updation of KYC in case of different types of Customers:

 

 

No Change in KYC Information

Change in Address  

Individuals:

  • In case of no change in the KYC information, a self-declaration from the customer in this regard will be obtained through customer’s registered email-id/ registered mobile number/ digital channels (such as mobile application)/ letter.

  • In case of a change only in the address details of the customer, a self-declaration of the new address shall be obtained from the customer through customer’s registered email-id/ registered mobile number/ digital channels (such as mobile application)/ letter; and the declared address will be verified through positive confirmation within two months, by means such as address verification letter, contact point verification, deliverables, etc.; OR

  • In certain cases, we may also obtain a copy of OVD or deemed OVD or the equivalent e-documents thereof, for the purpose of proof of address, declared by the customer at the time of periodic updation.  

Non-Individual Customers (Company, Trust, Partnership, etc.)

  • In case of no change in the KYC information of such customers, a self-declaration in this regard shall be obtained through its registered email-id/ registered mobile number/ digital channels (such as mobile application)/ letter from an official authorized by such customer in this regard, board resolution, etc.

  • The company will also ensure during this process that Beneficial Ownership (BO) information available with them is accurate and shall update the same, if required, to keep it as up-to-date as possible.

  • In case of change in KYC information, the Company will undertake the KYC process equivalent to that applicable for on-boarding a new non-individual customer.

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    1.  
      1. Additional measures: In addition to the above, the Company will ensure that,

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      • The KYC documents of the customer as per the current CDD standards are available. This is applicable even if there is no change in customer information but the documents available with the Company are not as per the current CDD standards. Further, in case the validity of the CDD documents available with the Company has expired at the time of periodic updation of KYC, the Company will undertake the KYC process equivalent to that applicable for on-boarding a new customer.

      • Customer’s PAN details, if available, will be verified from the database of the issuing authority at the time of periodic updation of KYC.

      • Acknowledgment is provided to the customer mentioning the date of receipt of the relevant document(s), including self-declaration from the customer, for carrying out periodic updation. Further, it shall be ensured that the information / documents obtained from the customers at the time of periodic updation of KYC are promptly updated in the records / database of the Company and an intimation, mentioning the date of updation of KYC details, is provided to the customer.

      • In order to ensure customer convenience, Company may consider making available the facility of periodic updation of KYC at its branches.

      • Any additional and exceptional measures, may also be taken in certain high-risk cases, such as requirement of obtaining recent photograph, requirement of physical presence of the customer, requirement of periodic updation of KYC only in the branch where account is maintained, a more frequent periodicity of KYC updation than the minimum specified periodicity etc.]

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      1. Customer Mobile Number Change Process: To ensure transaction alerts, OTP, etc. are sent to the correct mobile number, customers must register with the mobile number associated with their Aadhaar. If a customer requests a change in their registered mobile number, the following process must be followed:

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      • The customer submits a written request for a mobile number change along with updated OVD documents (passport, driving license, voter ID card) through any e-mode or at a branch.

      • The concerned officer of the Company will verify the submitted OVD documents and compares them with the customer information available in the records.

      • The concerned officer of the Company checks that the updated mobile number is not already registered with another account or has been reported as lost or stolen.

      • If they find any discrepancies or doubts the authenticity of the documents, further verification may be requested, such as in-person verification or additional documents.

      • Once the concerned officer of the Company is satisfied with the verification process, the customer's mobile number is updated in their records, and a confirmation message is sent to the updated mobile number.

      • Transaction alerts, OTPs, etc. are sent only to the updated mobile number.

      • The Company will document the process followed for the mobile number change request and maintain the records as per regulatory requirements.

 

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    1. AML Risk Mitigation Tools:

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

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      1. KYC documentation

      2. Customer due diligence

      3. Dedupe check

      4. CIBIL Checks with credit scores

      5. Reference checks

      6. Tele verification

      7. Field Investigation

      8. Limit on amount of loan in cash

      9. Suspicious transaction reporting

      10. Checking whether amount of jewelry or loan is in line with disclosed sources of income and wealth

 

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    1. KYC and Customer Due Diligence (CDD)

 

CDD measures in case of individual customers

The Company will identify the beneficial owner and take all reasonable steps to verify their identity using reliable and independent sources of identification We will also conduct ongoing due diligence with respect to the business relationship with every client and closely examine transactions to ensure consistency with our knowledge of the customer, their business, and risk profile and the source of funds/wealth

Explanation: “On-going Due Diligence” means regular monitoring of transactions in accounts to ensure that those are consistent with Company’s knowledge about the customers, customers’ business and risk profile, the source of funds / wealth.

For undertaking CDD, following should be obtained from an individual while establishing an account-based relationship or while carrying out occasional transaction of an amount equal to or exceeding rupees fifty thousand, whether conducted as a single transaction or several transactions that appear to be connected, or any international money transfer operations or while dealing with the individual who is a beneficial owner, authorised signatory or the power of attorney holder related to any legal entity:

 

  1. 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

  2. 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

  3. 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 and its ownership and control

 

We can obtain KYC Identifier with explicit customer consent to download KYC records from CKYCR for the purpose of CDD. We will not use KYC documents downloaded from the CKYCR whose validity has lapsed for KYC purposes.

Provided that where the customer has submitted,

  1. 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.

  2. proof of possession of Aadhaar where offline verification can be carried out, the same shall be done.

  3. an equivalent e-document of any OVD, then, shall verify the digital signature as prescribed.

  4. 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: When a customer submits proof of possession of Aadhaar number containing the number, ensure that the customer obscures or blacks out their Aadhaar number through appropriate means, where Aadhaar number authentication is not required as per our KYC policy.

Note 2: Biometric-based e-KYC authentication can be carried out by authorized officials, business correspondents, and business facilitators wherever allowed by the Reserve Bank in this behalf.

Note 3: The usage of Aadhaar and proof of possession of Aadhaar shall comply with the Aadhaar (Targeted Delivery of Financial and Other Subsidies, Benefits, and Services) Act, 2016, the regulations made thereunder, and amendments made from time to time.

Note 4: Authorized officials, business correspondents, and business facilitators of the Company wherever allowed by the Reserve Bank in this behalf, will perform Offline Verification of Aadhaar for identification purposes.

Note 5: When opening an account for a legal entity that is not a natural person, identify the beneficial owner(s), and follow reasonable steps as per Rule 9(3) of the Rules to verify their identity. Please note the following:

In cases of trust, nominee, or fiduciary accounts, obtain satisfactory evidence of the identity of intermediaries and the persons on whose behalf they are acting. Additionally, collect details of the nature of the trust or other arrangements in place.

CDD Measures for Legal Entities

In order to comply with our company’s KYC policy, we require certain documents to be provided for non-individual customers. Please find below the details for each type of entity:

Company: For opening an account of a company, we require certified copies or equivalent e-documents of the following:

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    • Certificate of incorporation

    • Memorandum and Articles of Association

    • Permanent Account Number of the company

    • A resolution from the Board of Directors and power of attorney granted to its managers, officers or employees to transact on its behalf

    • Documents, as specified in Section 16 of the KYC Master Directions, relating to beneficial owner, the managers, officers or employees, as the case may be, holding an attorney to transact on the company's behalf

    • The names of the relevant persons holding senior management position

    • The registered office and the principal place of its business, if it is different.

Partnership Firms: For opening an account of a partnership firm, we require certified copies or equivalent e-documents of the following:

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    • Registration certificate

    • Partnership deed

    • Permanent Account Number of the partnership firm

    • Documents, as specified in Section 16 of the KYC Master Directions, relating to beneficial owner, managers, officers or employees, as the case may be, holding an attorney to transact on its behalf

    • The names of all the partners

    • Address of the registered office and the principal place of its business, if it is different.

 

Trusts: For opening an account of a trust, we require certified copies or equivalent e-documents of the following:

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    • Registration certificate

    • Trust deed

    • Permanent Account Number or Form No.60 of the trust

    • Documents, as specified in Section 16 of the KYC Master Directions, relating to beneficial owner, managers, officers or employees, as the case may be, holding an attorney to transact on its behalf

    • The names of the beneficiaries, trustees, settlor, protector, if any and authors of the trust

    • The address of the registered office of the trust

    • List of trustees and documents, as specified in Section 16 of the KYC Master Directions, for those discharging role as trustee and authorised to transact on behalf of the trust.

 

Unincorporated Associations or Bodies of Individuals: For opening an account of an unincorporated association or a body of individuals, we require certified copies or equivalent e-documents of the following:

  •  
    • Resolution of the managing body of such association or body of individuals

    • Permanent Account Number or Form No. 60 of the unincorporated association or a body of individuals

    • Power of attorney granted to transact on its behalf

    • Documents, as specified in Section 16 of the KYC Master Directions, relating to beneficial owner, managers, officers or employees, as the case may be, holding an attorney to transact on its behalf

    • Such information as may be required by us to collectively establish the legal existence of such an association or body of individuals.

 

In addition, for non-individual customers who are juridical persons or who purport to act on behalf of such entities, we require the following documents or equivalent e-documents to be obtained and verified:

  •  
    • Document showing name of the person authorized to act on behalf of the entity

    • Documents, as specified in Section 16 of the KYC Master Directions, of the person holding an attorney to transact on its behalf

    • Such documents as may be required by the Company to establish the legal existence of such an entity/juridical person.

 

In case of a Trust, Ummeed shall ensure that trustees disclose their status at the time of commencement of an account-based relationship or when carrying out transactions as specified in clause 4.7 (a) (4) of the Policy.

 

Furthermore, as per our policy, we advise customers to update any changes to the documents submitted at the time of establishment of business relationship or account-based relationship with the Company, as necessary. This update must be submitted to us within 30 days of the change in order to update our records.

 

  1. Enhanced Due Diligence (“EDD”)

    1. Enhanced Due Diligence (“EDD”) procedures will be implemented by the Company for higher risk customers and transactions with natural and legal persons (including financial institutions) from countries for which this is called for by the FATF.

    2. The EDD procedures will aid the Company in:

  2. Determining whether the customer appears to be engaged in legitimate business activities and has legitimate sources of funds.

  3. Anticipating the customer’s usual and expected activity so that suspicious activity can be detected.

    1. Higher-risk customers must be approved by a Zonal Credit Manager level or minimum grade of General Manager.

    2. Customer transactions should be reviewed more closely at account opening and more frequently throughout the term of their relationship.

    3. The Company’s EDD procedures will consider requiring additional information and documentation to be obtained on higher risk customers, such as:

  4. Purpose of the account/End-use.

  5. Source of funds and wealth.

  6. Individuals with ownership or control over the account, such as beneficial owners, signatories, or guarantors.

  7. Financial statements.

  8. Banking references.

  9. Domicile (where the business is organized).

  10. Citizenship or nationality for individuals.

  11. Proximity of the customer’s residence, place of employment, or place of business.

  12. Description of the customer’s primary trade area and whether international transactions are expected to be routine.

  13. 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.

  14. Explanations for changes in account activity.

    1. The Company’s EDD procedures will consider requiring additional information and documentation to be obtained on higher risk customers periodically throughout the relationship, such as:

  15. Updation of KYC documents every 2 years.

  16. EDD is an ongoing process, and the Company will 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 taken.

  17. Our authorized officer will verify the current address through positive confirmation before allowing operations in the account, PAN will be obtained from the customer and shall be verified, customers shall be categorized as high-risk customers and accounts opened in non-face-to-face mode shall be subjected to enhanced monitoring until the identity of the customer is verified in a face-to-face manner or through V-CIP (if such facility is provided), etc.

 

  1. Politically Exposed Persons (“PEPs”)

Politically exposed persons are individuals who are or have been entrusted with prominent public functions by a foreign country, including the Heads of States/ Governments, senior politicians, senior government or judicial or military officers, senior executives of state-owned corporations and important political party officials.

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.

 

  1. Negative List

Our branches will maintain a negative list of persons to the extent possible, and after a thorough check of the client base, we will determine if any matches exist. If there is a match with a credit-related nature only (no other negativities associated with the name), the PO/MLRO or any other person with appropriate authority may approve the acceptance of the client/prospect.

 

  1. Sanctions List

We will ensure compliance with statutory and regulatory requirements related to sanctions lists of individuals/groups. The list of such individuals/entities will be regularly updated based on advice received from government, statutory, regulatory authorities, or international bodies. This includes individuals/entities suspected of having terrorist links, as approved and periodically circulated by the aforementioned authorities.

We strictly refrain from engaging in transactions with customers whose identities match those of individuals with known criminal backgrounds or banned entities, as well as those reported to have links with terrorists or terrorist organizations identified by the relevant authorities. If any match is identified with an entity listed in the Sanctions List, we will meticulously follow the required procedures as dictated by legal, statutory, and regulatory requirements.

Additionally, our company officials will conduct checks to the extent applicable on the Company and based on specified parameters when establishing a customer relationship and periodically thereafter. This is done to verify whether individuals and entities listed in the designated list hold any funds, financial assets, or other assets in the form of bank accounts or similar financial instruments.

To the extent applicable on the Company, we will every day verify the 'UNSCR 1718 Sanctions List of Designated Individuals and Entities' available at [https://www.mea.gov.in/Implementation-of-UNSC-Sanctions-DPRK.htm]. This ensures that any modifications, such as additions, deletions, or other changes to the list, are taken into account. We also ensure compliance with the 'Implementation of Security Council Resolution on Democratic People’s Republic of Korea Order, 2017' as amended by the Central Government.

Furthermore, we refer to the updated published list of jurisdictions not fully or partially complying with the FATF Guidelines provided by the Financial Action Task Force (FATF). This is to ensure that none of our existing or new customers' credentials match the details of individuals/entities falling within non-compliance jurisdictions of FATF. Additionally, Ummeed will apply enhanced due diligence measures, which are effective and proportionate to the risks, to business relationships and transactions with natural and legal persons (including financial institutions) from countries for which this is called for by the FATF.

Moreover, we comply with orders, directions, guidelines, and lists issued by the appropriate authorities/regulatory bodies, including the Government of India, for the implementation of or obligations under:

  • Section 51-A of the Unlawful Activities (Prevention) (UAPA) Act, 1967.

  • Prevention and Suppression of Terrorism (Implementation of Security Council Resolutions) Order, 2007, as amended from time to time.

  • Freezing of Assets under Section 51A of UAPA, 1967, as per UAPA notification dated February 2, 2021 (Annex II of the KYC Master Direction). We submit the necessary details to the Nodal Officers for UAPA, as available on the website of the Ministry of Home Affairs (MHA).

  • Obligations under the Weapons of Mass Destruction (WMD) and their Delivery Systems (Prohibition of Unlawful Activities) Act, 2005 and related prescription made under KYC Master Directions (including Annex III of the KYC Master Direction).

  • Countermeasures when called upon to do so by any international or intergovernmental organization of which India is a member and accepted by the Central Government.

 

  1. Appointment of the Principal Officer (PO) / Money Laundering Reporting Officer (MLRO) & Designated Director.

Principal Officer:

Designation of Principal Officer: A Senior Official of the Company at the management level, who shall not below the rank of General Manager or immediately below the level of MD or CEO, will be designated as the Principal Officer of the Company by the Board of Directors. The Principal Officer will be responsible for overseeing and managing the Anti-Money Laundering (AML) Implementation, ensuring compliance with Regulatory Directions, and managing and mitigating AML risks.

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.

Communication of Principal Officer Information: The name, designation, contact details and address of the Principal Officer will also be communicated to the Financial Intelligence Unit of India (FIU-IND) , National Housing Bank (NHB) /and the Reserve Bank of India (RBI).

Key Responsibilities of the Principal Officer (PO)/ MLRO

  •  
    • The PO will develop effective AML programs, including programs to provide AML training to business personnel.

    • The PO will ensure 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 will 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.

    • The PO will be monitoring the implementation of the company’s KYC/AML policy.

    • The PO will be reporting transactions and sharing information as required under the law.

    • The PO will be maintaining liaison with regulatory authorities.

    • The PO will ensure submission of periodical reports to the top Management/Board.

    • The PO will be organizing continual training of employees to make them aware and keep them up to date with requirements of PMLA and any amendments thereto.

    • The PO will review all reports required to be submitted to regulatory/law enforcement authorities.

    • The PO will be reporting to the FIU-IND.

    • The PO will be monitoring compliance and exception reporting.

Designated Director:

Designation of Designated Director: The Company will nominate a Designated Director to ensure overall compliance with Chapter IV of the Prevention of Money Laundering Act (PMLA) and the Rules. The Designated Director will be nominated by the Board and shall not be the Principal Officer. The Board may consider candidature of MD, WTD, or CEO of the company, for appointing anyone of them as the Designated Director for reporting purposes and the same shall be communicated to the FIU or other regulatory institutions (RBI & NHB).

Communication of Designated Director Information: The name, designation, address, and contact details of the Designated Director will be communicated to the FIU-IND, NHB /and the RBI.

Key Responsibilities of the Designated Director

 

  •  
    • Review reports to be submitted to the FIU.

    • Ensure compliance with issued guidelines.

    • Attend meetings and conferences organized by the FIU or other regulatory bodies.

 

  1. Reporting to Financial Intelligence Unit-India (FIU-IND)

 

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”.

 

The Principal Officer shall ensure there is no delay in reporting a transaction as the 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.

 

The Company shall refrain from imposing any restrictions on operations in the accounts solely based on the filing of Suspicious Transaction Reports (STRs). Ummeed, along with its directors, officers, and all employees, is obligated to maintain the confidentiality of records pertaining to all cash and suspicious transactions as referred to in Rule 3 of the Prevention of Money Laundering (Maintenance of Records) Rules, 2005. The company is committed to keeping such information strictly confidential and ensuring its confidentiality is upheld.

 

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.

 

  1. Reporting of Cash Transactions

    1.  

      1. 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:

        1. all cash transactions of the value of more than rupees ten lakh or its equivalent in foreign currency;

        2. 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

 

  1.  
    1.  
      1. 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.

 

  1.  
    1.  
      1. 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 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.)

 

  1. 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.

 

  1. Central KYC Records Registry (CKYCR) - and reporting requirements under Foreign Account Tax Compliance Act (FATCA)/ Common Reporting Standards (CRS)

The company will upload the Know Your Customer (KYC) data with CERSAI in respect of new individual accounts (opened w.e.f. Nov 01, 2016). KYC information will be captured for sharing with the Central KYC Record Registry in the manner mentioned in the “Prevention of Money-Laundering (Maintenance of Records) Rules, 2005” (and amendments thereto). The Company shall keep the KYC data ready in digital format in the templates advised by NHB/ RBI of all our existing clients. The Loan Application forms of Retail and Commercial Credit clients may be revised, if required, to capture the data of clients in NHB/ RBI prescribed template in future. The existing clients be contacted to fill up the gaps, if any. The KYC data will be shared with CKYCR as and when advised by NHB. The company shall also take all steps to comply with the FATCA and CRS reporting requirements, as advised by Regulatory Authorities from time to time.

 

  1. Record-keeping Requirements

    1. The Company have a system of maintaining proper record of transactions as required with reference to provisions of PML Act and Rules, as mentioned below:

      1. 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, and the Company is committed to preserving records related to the identification of customers and their addresses, acquired during the account opening process and throughout the course of the business relationship. These identification records will be retained for at least five years after the termination of the business relationship

      2. To make available the identification records and transaction data to the competent authorities upon request whereas, "records pertaining to the identification", “identification records”, etc., shall include updated records of the identification data, account files, business correspondence and results of any analysis undertaken.

      3. 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);

      4. 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.

      5. all cash transactions of the value of more than rupees ten lakh or its equivalent in foreign currency;

      6. 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;

      7. all transactions involving receipts by non-profit organizations of rupees ten lakhs or its equivalent in foreign currency;

      8. 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

      9. all suspicious transactions whether or not made in cash and by way of as mentioned in the Rule 3(1) (D).

      10. 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.

 

  1.  
    1. Records to contain the specified information- The above records, in terms with Rule 3 of the PMLA Rules, to contain the following information:

  2. the nature of the transactions;

  3. the amount of the transaction and the currency in which it was denominated;

  4. the date on which the transaction was conducted; and

  5. the parties to the transaction.

 

  1.  
    1. 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.

 

  1. Hiring & Training of Employees and Customer Education

 

At our Company, we understand that implementing KYC procedures may require us to seek personal information from our customers that they may not have been asked for before. This can sometimes lead to questioning from customers about the purpose of collecting such information. To address this, we prioritize educating our customers about the importance and objectives of our KYC procedures to alleviate any concerns they may have.

 

Employees: To ensure that we have the right people on our team, we have put in place a rigorous screening process as part of our hiring process, including a Know Your Employee/Staff policy. We also provide training on KYC/AML requirements and procedures to all employees, with a focus on different areas such as frontline staff, compliance staff, and those dealing with new customers. We make sure our staff is equipped to handle issues that may arise due to lack of customer education, and we have a dedicated team that is well-versed in our KYC/AML policies to ensure compliance.

 

To educate our customers and build their trust, we provide literature containing all relevant information about KYC and AML measures, which can be accessed directly or through our website. Our staff is always available to promptly explain why specific information is being requested and address any concerns or questions.

 

We believe in maintaining high standards of integrity and ethics, effective communication skills, and the ability to keep up with changing regulations for our employees. Therefore, we strive to develop an environment that fosters open communication and high integrity amongst our staff. Additionally, we have an ongoing employee training program that ensures our staff is adequately trained in our KYC/AML/CFT policies. The training has a different focus for frontline staff, compliance staff, and staff dealing with new customers. The front desk staff is specially trained to handle issues that may arise due to lack of customer education. We also ensure that our audit function is staffed with personnel who are well-versed in our KYC/AML/CFT policies and related issues for proper compliance.

 

Customers: We will provide our customers with literature that contains all relevant information regarding our KYC and AML measures, which can be made available directly or through our website. Our staff are trained and instructed to promptly attend to any queries or concerns our customers may have and explain the reasons for seeking specific information.

 

  1. 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 the 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.

 

Unique Customer Identification Code (UCIC)/ Customer ID (Cust ID):

 

To maintain a record of our individual customers, we will allot a Unique Customer Identification Code (UCIC) {i.e., Customer ID (Cust ID)} while entering into new relationships with them. Existing individual customers will also be allotted the UCIC.

 

In case of walk-in/occasional customers, we may not issue UCICs, provided we can identify such customers with frequent transactions and ensure that they are allotted UCICs.

 

Secrecy Obligations and Sharing of Information:

 

To maintain the confidentiality of customer information, we will maintain secrecy regarding the customer information that arises out of the contractual relationship between the customer and our Company.

 

Information collected from customers for the purpose of opening an account will be treated as confidential, and the details thereof will not be divulged for the purpose of cross-selling or for any other purpose without the express permission of the customer.

 

While considering requests for data/information from the Government and other agencies, we will ensure that the information being sought is not of such a nature as to violate the provisions of laws relating to secrecy in transactions. The exceptions to the above shall be as under:

  1. Where disclosure is under compulsion of law

  2. Where there is a duty to the public to disclose,

  3. the interest of RE requires disclosure and

  4. Where the disclosure is made with the express or implied consent of the customer.

 

Introduction of new Products/ Technologies

 

At our company, we recognize that the introduction of new products and technologies can introduce new risks that may not have been present before. As such, we will adopt a risk-based approach to identify and assess ML/TF risks associated with the development of new products and business practices, as well as the use of new or developing technologies. This means that we will analyze the potential risks associated with each new product or technology, and tailor our approach to managing those risks based on their severity.

 

In addition, we will conduct ML/TF risk assessments before introducing any new product, practice, service, or technology to identify any potential risks and take steps to mitigate them. To manage and mitigate the risks associated with the introduction of new products and technologies, we will adopt appropriate Enhanced Due Diligence (EDD) measures and transaction monitoring. By doing so, we will ensure that we are effectively managing any potential ML/TF risks and protecting our business and our customers.

 

  1. 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.

 

Updated Master Direction - Know Your Customer (KYC) Direction, 2016 of RBI shall be referred to for any policy gaps /better interpretation.

 

 

Annexure I

 

  1. 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:

(a) Registration certificate;

(b) Trust deed;

(c) Permanent Account Number or Form No.60 of the trust;

(d) 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:

(a) Certificate of incorporation/ Registration Certificate;

(b) Memorandum and Articles of Association / Partnership deed;

(c) Permanent Account Number of the company/ firm;

(d) 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;

(e) 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)

Accounts of Politically Exposed Persons (PEPs), whether as customers or beneficial owners, will be subject to additional scrutiny by the Company beyond the standard customer due diligence process. The Company commits to gathering sufficient information on any individual or customer falling within the PEP category and intends to establish a relationship. This process includes a comprehensive check of all available information about the person in the public domain. To effectively manage the associated risks, the Company will maintain appropriate risk management systems designed to determine whether the customer or beneficial owner qualifies as a Politically Exposed Person. Prior to accepting a PEP as a customer, the Company will conduct identity verification and seek information regarding the sources of funds/wealth. The decision to open an account for a PEP will undergo a rigorous approval process, with the authorization granted by a Zonal Credit Manager or a minimum-grade General Manager, emphasizing the elevated level of scrutiny and approval for such cases. Furthermore, the Company extends these established norms to also apply to the accounts of family members or close associates of PEPs. This approach ensures a comprehensive due diligence process for individuals closely connected to Politically Exposed Persons.[35]

 

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.

 

  1. Indicative List of the Nature and Type of Documents/ Information

 

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

  1.  
    1. Passport;

    2. Driving License;

    3. Proof of Possession of Aadhaar Number;

    4. Voter's Identity Card issued by the Election Commission of India;

    5. Job card issued by NREGA duly signed by an officer of the State Government;

    6. Letter issued by the National Population Register containing details of name and address;

 

Provided that:

  1.  
    1.  
      1. 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;

      2. 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:

  2. Utility bill which is not more than two months old of any service provider (electricity, telephone, post-paid mobile phone, piped gas, water bill);

  3. property or Municipal tax receipt;

  4. pension or family pension payment orders (PPOs) issued to retired employees by Government Departments or Public Sector Undertakings, if they contain the address;

  5. 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;

 

  1.  
    1.  
      1. the customer shall submit OVD with current address within a period of three months of submitting the documents specified at “b” above

      2. 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.

 

  1. 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 in addition to Address Proof)                                         

  1. For Individuals:

  • PAN Card or Form 60

  • Valid Passport (not expired)

  • Aadhar Card

  • Driving License

  • Voters ID Card

  • 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

  • Identity Card /Certificate with Applicant’s Photograph issued by Government Body/ Regulatory or Statutory Authority/ Public Sector Undertaking/ Scheduled Commercial Banks and Public Financial Institution

  • Photo debit card / Bank account statement 1st Page/ Passbook with Photographs issued by a Bank & Bank Stamp on the Photo

  • 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 Applicant

 
  1. For Non-Individuals/ business entities:

  • PAN or Form 60

  • Shops & Establishment Certificate /Trade License Certificate

  • MSME Registration Certificate

  • GST Registration Certificate

  • Registered Partnership Deed (for firms) / Memorandum of Association (MOA) for companies

  • Export-Import Code Certificate

  • Professional qualification Certificate and Degree Certificate for professionals with photo (For Proprietorship Firms)

  • 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)

  • Valid Passport (not expired)

  • 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 (10th)

  • Employee ID Card clearly mentioning the exact date of birth (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 / Office Address proof                                        (any one in addition to Identity Proof)

  •  For Individuals (Following OVD Documents can be collected)

  • Valid Passport (not expired)

  • Driving License

  • Voters ID card

  • Aadhar Card

  • 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

 

Following Documents can also be considered as an Address Proof for “Low Risk” Customers with condition that the Officially Valid Documents (OVD) listed above with updated address shall be collected within 3 (three) months of submission:

  • Ration Card

  • Utility bill (Electricity, Landline Telephone, Post Paid Mobile, Piped Gas line, Water)  from latest 2 (two) months from date of application.)

  • Rent agreement on stamp Paper subject to positive Residence FI (at the same address as mentioned on rent agreement (registered or notarized)

  • Bank Statements 1st Page/ Passbook 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

 
  1. Non-Individuals / Business entities

  • Shops & Establishment Certificate

  • Trade License Certificate

  • MSME/ SSI Registration Certificate

  • GST Registration

  • Registered Partnership    Deed (for   firms) with business address mentioned

  • Certificate of Incorporation issued by MCA/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 - Constitution documents

  1.  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

  1. 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.

 

Sole Proprietary Firms

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.

[“Registration certificate” as a proof of business/ activity in the name of the proprietary firm includes “Udyam Registration Certificate (URC) issued by the Government”.][36]

 

i)   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, GST 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.

 

ii)    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.

 

iii) 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.

 

 iv) 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 firm’s 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:

  1. Banker’s sign. Verification

  2. Passport copy

  3. PAN card

  4. Driving license with photograph & signature.

  5. Ration Card with the signature of the customer

  6. Debit Card bearing the signature (embossed on the front) of the applicant and should be the same as in the Application Form.

  7. Copy of registered sales deed bearing signature of the applicant / co applicant / guarantor / authorised signatory as the case may be.

  8. 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. {An officer of the Company shall certify under his/ her signature that the Applicant/ Co-applicant) has affixed his/ her signature or thumb impression in his/ her presence.}

  • A declaration (signed in front of Employee) for sign verification for Co-applicants with no income & who are also not property owner can be accepted.

 

 

 

  1. 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 requirements 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

  1. Passport (unexpired)

  2. Voters’ Identity Card

  3. UID (AADHAR card)

  4. Job card issued by NREGA duly signed by an officer of the State Government,

  5. Valid Driving License (unexpired)

  6. 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 APPLICANTS. 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

  1. Passport (unexpired)

  2. Voters’ Identity Card

  3. UID (AADHAR card)

  4. Job card issued by NREGA duly signed by an officer of the State Government,

  5. Valid Driving License (unexpired)

  6. PAN Card

  7. 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

  8. 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.

  1. 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);

  2. Property or Municipal Tax receipt;

  3. Bank account or Post Office savings bank account statement;

  4. Pension or family pension payment orders (PPOs) issued to retired employees by Government Departments or Public Sector Undertakings if they contain the address.

  5. 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

  6. 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 APPLICANTS. 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)

 

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 applies for digital KYC process then:

 

  1. The original OVD is required to be presented.

  2. Live photograph of the customer shall be taken and the same photograph is embedded in the Customer Application Form (CAF).

  3. Other guidelines as per the directions of RBI are followed while capturing  the Photograph  and  OVD documents.

  4. OTP validation, shall be carried out for successful singing of authorized officer on the declaration.

  5. 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:

 

  1.  
    1. Customer is reluctant to provide information, data, documents;

    2. Submission of false documents, data, purpose of loan, details of accounts;

    3. Refuses to furnish details of source of funds by which initial contribution is made, sources of funds is doubtful etc.;

    4. Reluctant to meet in person, represents through a third party/Power of Attorney holder without sufficient reasons;

    5. 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;

    6. Unable to explain or satisfy the numerous transfers in the statement of account/ multiple accounts;

    7. Initial contribution made through unrelated third party accounts without proper justification;

    8. Availing a top-up loan and/or equity loan, without proper justification of the end use of the loan amount;

    9. Suggesting dubious means for the sanction of loan;

    10. Where transactions do not make economic sense;

    11. There are reasonable doubts over the real beneficiary of the loan and the flat to be purchased;

    12. Encashment of loan amount by opening a fictitious bank account;

    13. 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;

    14. Sale consideration stated in the agreement for sale is abnormally higher/lower than what is prevailing in the area of purchase;

    15. Multiple funding of the same property/dwelling unit;

    16. Request for payment made in favour of a third party who has no relation to the transaction;

    17. 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.

    18. Multiple funding / financing involving NGO / Charitable Organisation / Small / Medium Establishments (SMEs) / Self Help Groups (SHGs) / Micro Finance Groups (MFGs)

    19. Frequent requests for change of address;

    20. Overpayment of instalments with a request to refund the overpaid amount;

    21. Legal structure of client has been altered numerous times (name changes, transfer of ownership, change of corporate seat);

    22. Unnecessarily complex client structure;

    23. Individual or classes of transactions that take place outside the established business profile, and expected activities/ transaction unclear;

    24. Unusual financial transactions with unknown source;

    25. Payments received from un-associated or unknown third parties and payments for fees in cash where this would not be a typical method of payment;

    26. Investment in real estate at a higher/ lower price than expected.

  2. Clients incorporated in countries that permit bearer shares.

 

Illustrative List of Suspicious Transactions pertaining to Builder/ Project Loans:

 

  1. Builder approaching the HFC for a small loan compared to the total cost of the project;

  2. Builder is unable to explain the sources of funding for the project;

  3. Approvals/sanctions from various authorities are proved to be fake;

  4. Management appears to be acting according to instructions of unknown or inappropriate person(s);

  5. Employees numbers or structure out of keeping with size or nature of the business (for  instance the turnover of a company is unreasonably high considering the number of employees and assets used);

  6. Clients with multijurisdictional operations that do not have adequate centralized corporate oversight;

  7. Advice on the setting up of legal arrangements, which may be used to obscure ownership  or real economic purpose (including setting up of trusts, companies or change of name/corporate seat or other complex group structures);

  8. Entities with a high level of transactions in cash or readily transferable assets, among which illegitimate funds could be obscured.


Updated vide Board Resolution dated June 23, 2023, following the amendment to the KYC Master Direction on April 28, 2023, and May 4, 2023.

Updated vide Board Resolution dated December 05, 2023, following the amendment to the KYC Master Direction on October 17, 2023.

 Updated vide Board Resolution dated June 23, 2023, following the amendment to the KYC Master Direction on April 28, 2023, and May 4, 2023.

Updated vide Board Resolution dated June 23, 2023, following the amendment to the KYC Master Direction on April 28, 2023, and May 4, 2023.

Inserted vide Board Resolution dated June 23, 2023, following the amendment to the KYC Master Direction on April 28, 2023, and May 4, 2023. 

Inserted vide Board Resolution dated June 23, 2023, following the amendment to the KYC Master Direction on April 28, 2023, and May 4, 2023. 

Updated vide Board Resolution dated December 05, 2023, following the amendment to the KYC Master Direction on October 17, 2023.

Updated vide Board Resolution dated December 05, 2023, following the amendment to the KYC Master Direction on October 17, 2023.

 Inserted vide Board Resolution dated June 23, 2023, following the amendment to the KYC Master Direction on April 28, 2023, and May 4, 2023.

Inserted vide Board Resolution dated June 23, 2023, following the amendment to the KYC Master Direction on April 28, 2023, and May 4, 2023.

 Updated vide Board Resolution dated December 05, 2023, following the amendment to the KYC Master Direction on October 17, 2023.

Inserted vide Board Resolution dated December 05, 2023, following the amendment to the KYC Master Direction on October 17, 2023.

Inserted vide Board Resolution dated December 05, 2023, following the amendment to the KYC Master Direction on October 17, 2023.

Updated vide Board Resolution dated December 05, 2023, following the amendment to the KYC Master Direction on October 17, 2023.

.Inserted vide Board Resolution dated June 23, 2023, following the amendment to the KYC Master Direction on April 28, 2023, and May 4, 2023.

 Inserted vide Board Resolution dated June 23, 2023, following the amendment to the KYC Master Direction on April 28, 2023, and May 4, 2023.

 Inserted vide Board Resolution dated June 23, 2023, following the amendment to the KYC Master Direction on April 28, 2023, and May 4, 2023.

 Updated vide Board Resolution dated December 05, 2023, following the amendment to the KYC Master Direction on October 17, 2023.

Updated vide Board Resolution dated December 05, 2023, following the amendment to the KYC Master Direction on October 17, 2023.

 Updated vide Board Resolution dated December 05, 2023, following the amendment to the KYC Master Direction on October 17, 2023.

 Updated vide Board Resolution dated December 05, 2023, following the amendment to the KYC Master Direction on October 17, 2023.

 Updated vide Board Resolution dated December 05, 2023, following the amendment to the KYC Master Direction on October 17, 2023.

 Inserted vide Board Resolution dated June 23, 2023, following the amendment to the KYC Master Direction on April 28, 2023, and May 4, 2023.

Inserted vide Board Resolution dated December 05, 2023, following the amendment to the KYC Master Direction on October 17, 2023.

Updated vide Board Resolution dated December 05, 2023, following the amendment to the KYC Master Direction on October 17, 2023.

Inserted vide Board Resolution dated June 23, 2023, following the amendment to the KYC Master Direction on April 28, 2023, and May 4, 2023.

Inserted vide Board Resolution dated June 23, 2023, following the amendment to the KYC Master Direction on April 28, 2023, and May 4, 2023.

 Updated vide Board Resolution dated December 05, 2023, following the amendment to the KYC Master Direction on October 17, 2023.

 Updated vide Board Resolution dated December 05, 2023, following the amendment to the KYC Master Direction on October 17, 2023.

Updated vide Board Resolution dated December 05, 2023, following the amendment to the KYC Master Direction on October 17, 2023.

Updated vide Board Resolution dated December 05, 2023, following the amendment to the KYC Master Direction on October 17, 2023.

 Updated vide Board Resolution dated December 05, 2023, following the amendment to the KYC Master Direction on October 17, 2023.Inserted vide Board Resolution dated June 23, 2023, following the amendment to the KYC Master Direction on April 28, 2023, and May 4, 2023.

Inserted vide Board Resolution dated June 23, 2023, following the amendment to the KYC Master Direction on April 28, 2023, and May 4, 2023.

 Updated vide Board Resolution dated December 05, 2023, following the amendment to the KYC Master Direction on October 17, 2023.

 Inserted vide Board Resolution dated June 23, 2023, following the amendment to the KYC Master Direction on April 28, 2023, and May 4, 2023.

 

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Grievance Redressal Policy

Ummeed Housing Finance Private Limited (“the Company” or “Ummeed”), believes in providing efficient and prompt service to its customers. With a view to serve out our customers, the company has come up with this Grievance Redressal Policy (said policy). The said policy also deal with the query/ complaint/ grievance of customer with respect to services provided under any outsourced arrangement.

Level 1

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

  • टेलीफोन संचार द्वारा 1800 2126 127 पर सुबह 10:00 बजे से शाम 05.30 बजे के बीच (छुट्टियों को छोड़कर)।Make an entry of query/ complaint in the Complaint Register at the branch and fill the CRF form.
  • By way of writing an email at “customercare@ummeedhfc.com” or “enquiry@ummeedhfc.com”
Level 2

If the customer does not receive any response from the company within 15 days or is not satisfied with the resolution provided by the above channel, the customer may complaint to the Grievance Redressal Manager of by way of writing letter/ Email to:

Mrs. Veena Mishra
Sr. Manager – Customer Service & Grievance Redressal
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: service@ummeedhfc.in
Contact No.: 0124-4836480

Level 3

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. Sandeep Verma
Grievance Redressal Officer
Ummeed Housing Finance Private Limited,
Unit 809-815, 8'h Floor, Tower A, Emaar Digital Greens,
Golf Course Extension Road, Sector 61,
Gurugram — 122102
Email ID: - grievance@ummeedhfc.in
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. 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 4

In case your complaint has not been resolved to your satisfaction, you can also approach the Complaint Redressal Department of National Housing Bank by lodging its complaints in Online mode at the link: https://grids.nhbonline.org.in/(S(r3ep3nauzqhjria21ha42gms))/Complainant/Default OR in offline mode by post, in prescribed format available at link: https://nhb.org.in/wp-content/uploads/2021/08/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:

Grievance Redressal Department
National Housing Bank
Core 5A, India Habitat Centre
Lodhi Road, New Delhi - 110 003

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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 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.

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Most Important Terms and Conditions (MITC)

 

 

Ummeed Housing Finance Private Limited

 

MOST IMPORTANT TERMS AND CONDITIONS (MITC)

 

Loan ……………………………… (Name of the specific Loan Product i.e. HL/LAP/BL/STBL)

 

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:

 

Loan Agreement Date:

 

  1. Interest

 

  1. Type (Fixed or Floating or Dual/ Special Rate):

 

  1. Interest chargeable [……………. i.e. ..... % {Ummeed Reference Rate (URR) +/- …………} for floating rate loans; and ……% for fixed rate loans].

 

  1. Moratorium or subsidy:

 

  1. Date of reset of interest:

 

  1. Modes of communication of changes in interest rate and other charges: 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. Penal charges are clearly disclosed in the loan agreement and Tariff Sheet-Schedule of Charges within the MITC documents, provided to the borrower and hosted on the website. Reminders for non-compliance include communication of applicable penal charges, and instances of charge levies are communicated through suitable channels, ensuring borrowers are well-informed and promoting transparency in financial dealings.

 

  1. Installment Types

    1. Repayment of loan through monthly Instalment.

 

  1.  
    1. Amount: ……………………(In Figures). Subject to change with a change in URR in case of floating rate loans.

 

  1.  
    1. Date of Commencement of EMI: 

 

  1.  
    1. Due Date for EMI:

 

  1. Loan Tenure: __________months (Subject to change with a change in Ummeed Reference Rate in case of floating rate loans)

 

  1. Purpose of Loan: 

    1. Home Loan

    2. Plot Purchase Plus Construction

    3. Repair & Renovation

    4. Home Extension Loan

    5. Construction Refinance

    6. Purchase Refinance (Non-Housing)

    7. Loan Against Property

    8. Business Loan

    9. Small Ticket Business Loan

    10. Others (Please Specify) ________________________

 

  1. Fee and Other Charges

 

  1. On application (all type of fee/ charges, to be specified individually): Please refer table below

 

  1. During the term of loan (all type of fee/ charges, to be specified individually): Please refer table below

 

  1. On foreclosure (all type of fee/ charges, to be specified individually): Please refer table below

 

  1. Fee refundable if loan not sanctioned/disbursed (all type of fee, to be specified individually): Please refer table below

 

  1. Conversion charges for switching from floating to fixed interest and vice-versa (type of charges, to be specified individually): Please refer table below

 

  1. 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)

Non-Home Loan
(Business Loan & Small Ticket Business Loan)

 

Copy of Welcome Letter & Amortization Schedule

NIL.

 

Commitment Fee (at the time of Login the file) – non-refundable

Not to exceed Rs.10,000/-.

 

Processing FeeUp to 1%.Up to 2%.Up to 2%.

 

Document & Service ChargesUp to 3% of Sanction Amount.Up to 4% of Sanction Amount.Up to 4% of Sanction Amount.

 

CERSAI Charge

Up to Rs.750/- or as applicable.

 

Loan Cancellation Charges

Rs.5,000/- or 1% of Sanction amount whichever is higher.

 

PDC/ECS/ACH Bounced Charges

Rs.600/- per bounce.

 

Penal Charges for delay in deposit
(applicable on Outstanding EMI/PEMI Due)

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.

 

Repayment Swap Charges

Rs.500/-.

 

Duplicate NOC

Rs.500/-.

 

Statement of Accounts/ Foreclosure Letter)

Rs.1,500/- per statement.

 

Retrieval of copy of documents

Rs.1,500/-.

 

List of Documents -Duplicate Copy

Rs.1,500/-.

 

Pre-Closure Charges (Fixed Rate of Interest) by Individual BorrowersNIL 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.5% on Principal Outstanding.

 

Pre-Closure Charges (Fixed Rate of Interest) by Non-Individual Borrowers5% on Principal Outstanding.5% on Principal Outstanding.5% on Principal Outstanding.

 

Pre-Closure Charges (Floating Rate of Interest) by Individual BorrowersNILNIL5% on Principal Outstanding.

 

Pre-Closure Charges (Floating Rate of Interest) by Non-Individual Borrowers5% on Principal Outstanding.5% on Principal Outstanding.5% on Principal Outstanding.

 

Part Payment Charges (Fixed Rate of Interest) by Individual BorrowersNIL5% on Principal Outstanding.5% on Principal Outstanding.

 

Part Payment Charges (Fixed Rate of Interest) by Non-Individual Borrowers5% on Part Payment Amount.5% on Part Payment Amount.5% on Part Payment Amount.

 

Part Payment Charges (Floating Rate of Interest) by Individual BorrowersNILNIL5% on Part Payment Amount.

 

Part Payment Charges (Floating Rate of Interest) by Non-Individual Borrowers5% on Part Payment Amount.5% on Part Payment Amount.5% on Part Payment Amount.

 

Collection Charges

Rs.500/- per collection from the customer's residence/office.

 

Differential Interest

Will be applicable on cases (retention cases), which are getting closed within 12 months of ROI repricing, if any. In such cases the customer at the time of closure needs to pay the differential interest amount along with the foreclosure charges, wherever applicable.

 

Document Custodian Fee
(To be charged at the time of loan closure)

Rs.200/- per month (after first 60 days of loan disbursement).

 

Property Swapping Charges

NA.

 

Applicable Taxes will be charged over and above the charges mentioned above in the Tariff Sheet

 

Note:

  1.  
    1. Fee/Charges mentioned above are excluding applicable GST/ taxes and charges, while making payment applicable service tax and other statutory charges to be added as notified by statutory/government bodies.

    2. We share credit performance details of your loan account with credit information bureau of India limited (CIBIL) and with other bureau agencies.

 

  1. Security/ Collateral for the Loan

 

  1.  
    1.  
      1. Mortgage (Mention detail of the property to be mortgaged as security for the loan):

 

......………………………………………………………………………………………………………..…

 

......………………………………………………………………………………………………………..…

 

  1.  
    1.  
      1. Guarantee (Mention the name of the guarantors):

 

......………………………………………………………………………………………………………..…

 

......………………………………………………………………………………………………………..…

 

  1.  
    1.  
      1. Other Security (Mention the details of other securities, if any).

 

......………………………………………………………………………………………………………..…

 

......………………………………………………………………………………………………………..…

  1. Insurance of the Property/ Borrowers

 

  1. 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.

  2. 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.

 

  1. 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.

  1. The borrower must fulfil the Ummeed Housing Finance requirement of credit worthiness.

  2. Submission of all relevant documents as mentioned by Ummeed Housing Finance in the sanction letter / Loan agreement.

  3. Legal and Technical assessment of the property.

  4. Execution of the loan agreement and such other ancillary documents.

  5. Submission of Cheques/ACH. any other clearing system in force for the time being towards repayment of instalments.

  6. 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.

  7. Post disbursement and during the term of the Loan, the Borrower shall be entitled to prepay the Loan, either partly or fully, however, all term loans shall be repaid after a specified term period, i.e., twelve months from the disbursement, as per rules of the Company, including levy of prepayments charges, subject to applicability as per relevant regulatory directions or guidelines, if any, for the time being in force, and in accordance with the terms and conditions recorded in the Schedules to the loan agreement.

 

  1. Repayment of the Loan & Interest

Repayment of the loan to be by the way of pre-EMI/EMI during the entire tenure of the loan. The instalments (EMI) comprise 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.

  1. The EMI / PEMI for your Loan is:

  2.  Numbers of installments to be paid are:

  3. Modes of communication of changes in interest rate: through email / SMS / call on the registered phone / mobile number.

The Company will be releasing the original property documents and removing charges registered with any registry within 30 days of full repayment, provided there are no pending dues from the Borrower. Upon settlement of all dues and upon receiving a written request from the Borrower, the Borrower can opt to collect the documents from the HUB office nearest to their location or the branch where the loan was serviced. A list of such HUB offices will be promptly notified to the Borrower upon fulfilment of all obligations.

 

  1. Brief procedure to be followed for Recovery of overdues

 

  1. Telephone/Personal contact and follow up for recovery of instalments and interest due.

  2. 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 send notice to the borrower/s as required under applicable law.

 

  1. 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 of 31st March every year on or before 31st May.

 

Quarterly Statements: Ummeed Housing Finance will arrange to provide access to borrowers with quarterly statements via appropriate channels or mobile applications, detailing principal and interest recovered, EMI amount, remaining EMIs, and the annualized rate of interest/Annual Percentage Rate (APR) in a clear and easily understood format.

 

  1. Customer Services 

    1.  

      1. Visiting Hours at office / Branch

Monday to Saturday 10.00 AM to 06.00 PM

1st Saturday 10.00 AM to 02.00 PM

Office will be closed on 2nd Saturday of every month, all Sundays and all public Holiday.

  1.  
    1.  
      1. Borrowers are requested to contact the Branch manager during working hours for any clarifications/guidance.

      2. Borrower can contact our customer service helpdesk at 1800 2126 127/ 0124 483 6480 during office hours

      3. Indicative timelines of common request servicing:

  2.  
    1.  
      1. Loan Account Statement – 15 days from the date of request.

      2. Photocopy of title documents-21 days from the date of request.

      3. Issuance of foreclosure letter -21 days from the date of request.

      4. Return of Original Documents on Closure/ Transfer of Loan- 21 days from the date of request post loan closure

 

  1. Grievance Redressal

Level 1

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

  • By telephone communication on 1800 2126 127 between 10:00 AM to 05:30 PM (Except Holidays).

  • Make an entry of query/ complaint in the Complaint Register at the branch and fill the CRF form.

  • By way of writing an email atcustomercare@ummeedhfc.com” or “enquiry@ummeedhfc.com

Level 2

If the customer does not receive any response from the company within 15 days or is not satisfied with the resolution provided by the above channel, the customer may complaint to the Grievance Redressal Manager of by way of writing letter/ Email to:

Mrs. Veena Mishra

Sr. Manager – Customer Service & Grievance Redressal

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: service@ummeedhfc.in

Contact No.: 0124-4836480

Level 3

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. Sandeep Verma

Grievance Redressal Officer

Ummeed Housing Finance Private Limited,

Unit 809-815, 8'h Floor, Tower A, Emaar Digital Greens,

Golf Course Extension Road, Sector 61,

Gurugram — 122102

Email ID: grievance@ummeedhfc.in

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. 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 4

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/(S(r3ep3nauzqhjria21ha42gms))/Complainant/Default OR in offline mode by post, in prescribed format available at link: https://nhb.org.in/wp-content/uploads/2021/08/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:

 

Grievance Redressal Department

National Housing Bank

Core 5A, 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 or thumb impression

of the Borrower/s)

(Signature of the authorized person

of Lender)

 

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

 

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Internal Guidelines on Corporate Governance

At Ummeed Housing Finance Private Limited (‘the Company’), we believe that sound governance practices are the bedrock for the functioning of the Company and for creation of value for its stakeholders on a sustainable and long-term basis. This philosophy guides us in maintaining an ethical framework within which we operate.

In order to adopt best practices and greater transparency in the operations of the Company and in compliance with the directions on Corporate Governance issued by the Reserve Bank vide its notification no. RBI/2020-21/73, DOR.FIN.HFC.CC.No.120 /03.10.136 /2020-21 dated February 17, 2021 (RBI Directions), the Company has framed these Internal Guidelines on Corporate Governance. The Company is committed to practice good Corporate Governance standards in adherence to the RBI guideline/directions, SEBI regulations, MCA guidelines and Companies Act.

The Board

The Company’s Board has a primary role of trusteeship to protect and enhance stakeholders value through supervision and strategic inputs. The Board along with its Committees provides supervision and exercises appropriate controls and in addition to basic governance issues, the Board lays strong emphasis on transparency, accountability and integrity.

Policy on ‘Fit and Proper’ criteria for Directors

The Company has formulated a policy on ‘fit and proper’ criteria for directors on the lines of the guidelines prescribed under RBI Directions. This policy prescribes to Nomination and Remuneration Committee (“NRC”) to ascertain the fit and proper criteria at the time of appointment of Directors, and on a continuing basis. The NRC reviews the appointment/re-appointment of Directors considering their qualifications, expertise, track record, integrity and other 'fit and proper' criteria.

As per this policy, all the Directors are required to meet the ‘fit and proper’ criteria as prescribed by the Reserve Bank, and to provide a ‘declaration and undertaking’ giving additional information on the lines of the format prescribed under RBI Directions. Directors are also required to sign a deed of covenant with the Company, in line with the format prescribed under RBI Directions.

Further as per this policy, the Company will submit to the NHB, a quarterly statement on change of directors, and a certificate from the Managing Director of the Company that fit and proper criteria in selection of the directors has been followed. The Company to submit such statement to the NHB within 15 days of the close of the respective quarter. Further, the statement being submitted for the quarter ending March 31, should be certified by the auditors. In the event, there is no change in the directors during a quarter, a ‘Nil’ statement should be submitted.

Board’s Composition

Board shall have an optimum combination of Executive, Non-Executive and Independent Directors in line with the requirements of the provisions of the Companies Act, 2013, the Articles of Association of the Company and the Shareholder’s Agreement.

Meetings of the Board

At least 4 meetings of the Board shall be held in every calendar year and at least 1 (one) meeting will be held every calendar quarter, with a maximum time gap of 120 (one hundred and twenty) days between two Board meetings. The minimum information to be statutorily made available to the Board shall be furnished to the Directors before the meeting.

The decisions of the Board shall be taken by simple majority of the Directors and each Director shall exercise one vote.

Independent Directors

Independent Directors shall comply with the provisions specified in Schedule IV to the Companies Act, 2013, rules made thereunder, SEBI Regulations and the relevant RBI Directions.

REMUNERATION

The remuneration payable to the Director(s) shall be determined by the Nomination and Remuneration Committee and shall be recommended to the Board for its consideration and approval. The remuneration payable shall be in accordance with the Board approved Remuneration Policy and applicable laws.

COMMITTEES OF THE BOARD

The Board shall constitute Committees with specific terms of reference to focus on specific issues and ensure expedient resolution of diverse matters. The Minutes of the Meetings of all Committees of the Board shall be circulated to the Board of Directors, for their noting.

Details of various committees of the Board are mentioned below:

Audit Committee

An Audit Committee, consisting of not less than three members of its Board of Directors is constituted as required under Section 177 of the Companies Act, 2013. The Audit Committee is having such powers, functions and duties as laid down in Section 177 of the Companies Act, 2013.

The Audit Committee of the Board shall deal in accordance with the terms of reference specified by the Board including recommendation for appointment, remuneration and terms of appointment of auditors, review and monitor the auditor’s independence and performance, and effectiveness of audit process, examination of the financial statement and the auditors’ report thereon, approval or any subsequent modification of transactions of the company with related parties, accounting policies, compliance report, financial reporting and internal control systems.

The Audit Committee must ensure that an Information System Audit carried out separately through a Certified Information System Auditor (CISA) of the critical and significant internal systems and processes is conducted at least once in two years (one year once asset size crosses Rs 500 Crores as per audited financial statements) to assess operational risks faced by the Company. Nomination and Remuneration Committee:

Nomination and Remuneration Committee (“NRC”) is constituted as required under Section 178 of the Companies Act, 2013. NRC is having such powers, functions and duties as laid down in relevant provisions of Section 178 of the Companies Act, 2013.

Terms of references of NRC includes formulating criteria for determining qualifications, positive attributes and independence of a director and recommend to the Board a policy, relating to the remuneration for the directors, key managerial personnel, and other employees. NRC is ensuring 'fit and proper' status of proposed/ existing directors and that there is no conflict of interest in appointment of directors and their independence is not subject to potential threats.

Other Committees

The Company shall constitute various Committees as per the requirement under Housing Finance Companies (NHB) Circulars/Directions issued from time to time. These Committees shall meet time to time as per requirement, minimum number of meeting or prescribed frequency as per applicable laws or NHB Directions / Guidelines.

A list of such committees as follows:

Corporate Social Responsibility (CSR) Committee

Corporate Social Responsibility (CSR) Committee is constituted under provisions of Section 135 of the Companies Act, 2013. CSR Committee indulges itself into formulation of CSR policy, recommend the CSR budget, formulate annual action plan and monitoring CSR activities. Committee monitors activities undertaken by the company under its CSR. Progress is being reported to committee at periodical intervals.

Risk Management Committee

The Risk Management Committee shall be responsible for managing integrated risk, setting up and reviewing risk management policies of the Company from time to time. The Risk Management Committee shall primarily be responsible for identifying, monitoring, managing and mitigating the credit risk, market risk, operational risk and other risks of the Company that can be applicable to the Company considering the business operations of the Company through integrated risk management systems, strategies and mechanisms. Risk Management Committee discusses and recommends various ways to manage all integrated risk on monthly basis and review action plans submitted by management.

Asset Liability Management Committee (ALCO)

The liquidity risk management of the Company has been delegated to Asset & Liability Management Committee (ALCO). The ALCO monitors the asset liability composition of the Company’s balance sheet and determine actions to mitigate risks associated with the asset liability mismatches. The ALCO is responsible for ensuring adherence to the risk tolerance/ limits set by the Board as well as implementing the liquidity risk management strategy. ALCO with respect to liquidity risk should include, inter alia, decide on desired maturity profile and mix of incremental assets and liabilities, sale of assets as a source of funding, the structure, responsibilities and controls for managing liquidity risk, and overseeing the liquidity positions. Members of ALCO meet monthly to review debt position, strategy, liquidity risk management, ALM positioning.

IT Strategy Committee

The IT Strategy Committee has been formed to carry out review and amend the IT strategies in line with the overall strategies of the Company, and to review cyber security arrangements and any other matter related to IT Governance. The IT Strategy Committee shall be responsible for recommending IT related policies and other security policies, evaluating new threats and reducing the risk of intrusion, loss of data integrity, compliance violations, and the committee is also responsible for role-based access controls, resource allocation, documentation, and reporting. The committee meets at least twice a year with a gap less than six months to approve and recommend to the board all IT related policies, and oversee the IT investments, and implementation of IT infrastructural and application projects and strategy.

Wilful Defaulter Identification Committee

The Company shall constitute Wilful Defaulter Identification Committee headed by an Executive Director or equivalent and consisting of two other senior officers of the Company. Identification committee examines and concludes the event of wilful default has occurred, issue a Show Cause Notice to the concerned borrower. Committee meets periodically but at least in a quarter to review cases which may qualify to be concluded as wilful default.

Wilful Defaulter Review Committee

This committee shall be headed by Managing Director/ Chairman and consist of two Non-executive/ Independent Director to review the order passed by Identification Committee or wilful defaulters. Review Committee, will be headed by the MD and consisting, to one ID and one Non-ex Director of Ummeed, shall finally review and confirm the order of Identification Committee.

Borrowing & Banking Committee

The Borrowing & Banking Committee is responsible to (i) To borrow monies from Banks, Financial Institutions, Firms, Bodies Corporate and Other Persons/Entities including securitization transactions up to a sum prescribed by the Board while delegating its Borrowing Powers; (ii) Opening / Closing of Bank/ Imprest Accounts of the Company; (iii) Addition/ Deletion/ Change in Authorised Signatories of the Bank Accounts of the Company; (iv) Revising the authorization limits of the Bank Accounts of the Company; and (v) Availing of payment gateway services, Internet Banking or Cash Management Services or entering any agreement for those services with Banks/ Financial Institutions.

In addition to above, the Board shall constitute other committees, such as Internal Complaints Committee, Customer Service and Grievance Redressal Committee, Whistle Blower Committee, Human Resource Matters Committee, Marketing Committee as may be required for effective functioning of the Company.

  • GUIDELINES FOR CONVENING BOARD AND AUDIT COMMITTEE MEETINGS:

    • Finalisation of next Board and Audit Committee day, dates, venue and time at the current meeting;
    • On finalisation of the date of the Meetings the notice to be sent to all the Directors/ Members of the Board and Audit on the same day;
    • Agenda of the said meetings shall be circulated to all the Directors/members not later than seven (7) days (or less, in case of shorter notice) before the date of the meetings. However, annexures having price sensitive information may be circulated three (3) days prior to the date of the meeting;
    • In case representatives Director of Shareholders/ Investors, express their inability to attend the meetings then a waiver to be obtained from attending the Meetings;
    • The quorum of meeting of any committee of the Board shall be one third of total strength of members of committee or two members, whichever is higher, (including one independent director wherever required under relevant provisions as applicable) and the participation of the members by video conferencing or by other audio-visual means shall also be counted for the purposes of quorum.
    • Finalisation of the Minutes of the meetings shall be done within fifteen (15) days from the date of such meetings;
    • The said Minutes to be circulated members of the Board or Audit Committee for their review and comments;
    • The members of the Board/ Audit shall be provided 7 days’ time from the date of circulation to review and comment. The comments, if any, received on the Minutes then it shall be incorporated appropriately after obtaining approval of MD. In the event no comments received from any Directors/ Members within seven (7) days, then it will be deemed approved;
    • The approved Minutes shall be printed on the Minute sheet and will be filed in a Minute Book. The approval/ confirmation of the said Minutes shall be done at the next Meeting and it will be signed by the Chairman of that Meeting.
    PERFORMANCE EVALUATION

    The Nomination and Remuneration Committee of the Company shall evaluate the performance of the individual Directors, the Board, as a whole and its Committees. The Nomination Committee shall provide an overview Report of the evaluation conducted by it, to the Board for their discussion and analysis.

    CONFLICT OF INTEREST

    The Company expects its directors, officers and other employees to act ethically at all times and to acknowledge their adherence to the policy(ies) and code(s) adopted by the Company.

    The Directors, Senior Management and other Employees of the Company shall endeavour to avoid any conflict of interest with respect to their dealings with the Company. A Director who is interested in any proposed transaction shall not exercise any influence over other Board/Committee Members in any manner whatsoever. Further, as regards to appointment of directors, NRC is ensuring that there is no conflict of interest and their independence is not subject to potential threats.

    AUDITORS

    The Board and the Audit Committee of the Company shall be responsible to appoint Auditors, statutory or otherwise, as required under Companies Act and NHB Directions. The Company shall review the independence and performance of Auditors and effectiveness of their audit process periodically.

    The Company has formulated a Policy for appointment of Statutory Auditors (SAs) in line with norms applicable to the Company under the RBI’ circular no. DoS.CO.ARG/ SEC.01/ 08.91.001/ 2021-22 dated April 27, 2021, containing guidelines for appointment of SAs read with para 54 of RBI Directions. All other procedural and reporting requirements related to appointment of SAs are governed by the Policy for appointment of SAs. The Company shall incorporate appropriate terms in the letter of appointment of the firm of auditors and ensure its compliances listed in said policy.

    CODE OF CONDUCT AND POLICIES

    The Code of Conduct for Directors (including Independent Directors) and Employees provides guide to professional code of conduct to be applied in their businesses and affairs in compliance with applicable laws, rules and regulations of India. The Code is applicable to all employees of the Company, including Executive Director(s) and to the Non-Executive Director(s), whether Independent or Non- Independent to the extent of their role and responsibilities in the Company.

    In accordance with the applicable provisions of the Companies Act, 2013, the directions / guidelines issued by the National Housing Bank, under other applicable laws and for internal requirements and operational convenience, the Company shall frame and adopt various policies and shall modify/ update / revise / review as and when required under the applicable laws or due to change in the functioning or the structure of the Company.

    DISCLOSURES

    The Company is committed to make adequate disclosures based on the principles of transparency, timeliness, fairness and continuity. The Board of Directors and employees of the Company shall ensure and make necessary disclosures to the Company, the Regulator(s) / Statutory Authorities, the Shareholders, Investors, Members or other stakeholders as may be required by the applicable laws and the codes / policies of the Company.

    The Board of Directors of the Company or such other person authorized by the Board or any law / regulation, shall ensure that all the disclosures statutorily required to made on behalf of the Company are duly made to the Regulatory/ Statutory authorities or such other persons as maybe required under applicable laws / regulations.

    Further, following disclosures are being made to the Board of Directors on half yearly basis:
    • the progress made in putting in place a progressive risk management system and risk management policy and strategy followed by the HFC; and
    • conformity with corporate governance standards viz., in composition of various committees, their role and functions, periodicity of the meetings and compliance with coverage and review functions, etc.
    The Company will also disclose the following (wherever applicable) in its Annual Financial Statements:
    • registration/ license/ authorisation, obtained from other financial sector regulators;
    • ratings assigned by credit rating agencies and migration of ratings during the year;
    • penalties, if any, levied by any RBI/ NHB or any enforcement authority;
    • information namely, area, country of operation and information about JV and overseas subsidiaries, if any; and
    • Asset-Liability profile, NPAs and movement of NPAs, details of all off-balance sheet exposures, exposure to real estate, exposure to capital market, structured products issued by them as also securitization/ assignment transactions and other disclosures, as prescribed under RBI Directions;
    COMPLIANCE OFFICER

    A qualified Company Secretary shall be the Compliance Officer of the Company.

    REVIEW

    The Board or its Committee may review the policy from time to time as may be required. Changes, if any, shall be effective only upon approval by the Board itself or by COO / MD wherever authorised by the Board.

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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.

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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 identifiedSector in which the Project is coveredProjects/ Programs 1.Local area/others- 2.specify the state and district where projects or program was undertakenAmount outlay (budget) project or program wiseAmount 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)

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Ummeed Housing Finance - Power Partner - Terms & Conditions

The hereinafter mentioned terms and conditions (including the rules/policies set out or referred to on this page) shall apply to all Power Partners (be also referred as “you”, or “your”)., who are existing users or who can use the website and mobile application (“Website or/and App”) of the Company.

Whereas the term “Company” refers to Ummeed Housing Finance Private Limited, having its registered & corporate office at 809-815, 8th floor, Tower A, Emaar Digital Greens, Sector 61, Gurgaon, 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”) and regulated by Reserve Bank of India (“RBI”).

  1. The term Power Partner means the sourcing partner of the Company.
  2. The Power Partner confirms to provide proof of his/ her/ business details as and when required by the company.
  3. The Company reserves the right to change, modify, or remove the contents of the Power Partner application at any time or for any reason at its own discretion without notice. Notwithstanding anything contrary contained herein, the Power Partner agrees that the Company shall not be responsible or under obligation or liable under any circumstances for updating any information relating to the Power Partner Application or of its website contents.
  4. The Power Partner agrees to abide by the terms and conditions set forth herein, and all applicable rules, guidelines, codes, procedures and policies and changes thereto, and the Company reserves the right to change the terms and conditions at any time without notice, by posting changes on the website or by updating the App. The Power Partner is responsible for regularly reviewing the information posted online and/or on the App for timely notification of such changes. The Power Partner continued use of the App or/and the Website following the posting of changes constitutes their acceptance of the revised Terms and Conditions. The Company also reserves the right to modify or discontinue all or part of the Power Partner application without notice at any time.
  5. The Company will not be liable to Power Partner or any third party for any modification, price change, suspension, or discontinuance of the application.
  6. The Power Partner agrees to accept responsibility associated with the Company's Power Partner Program, including assisting in offering, interpreting, sourcing and documenting products and services offered to Company's prospects.
  7. The Power Partner agrees that the company has no liability whatsoever for any loss, damage, or any inconvenience caused by Power Partner’s inability to access or use the site during any downtime or discontinuance of the application.
  8. The Power Partner confirms to provide/upload only accurate, correct & complete information on the Power Partner App, in case the Power Partner provides any information that is inaccurate, or the Company has reasonable grounds to suspect that the information is undue, inaccurate, or incomplete, in that case, Company has right to terminate your engagement without any prior notice.
  9. The Power Partner shall ensure that all the information provided to the company will be secured without any misconduct and negligence and the same will not be shared with any third party or competitor.
  10. In case of termination of engagement with the Power Partner, no pay-outs shall get released to the concerned Power Partner.
  11. The detailed terms & conditions can be accessed at https://www.ummeedhfc.com By accepting the terms & conditions, the Power Partner agrees to have fully read & understood the detailed terms and are ready to abide by all the terms & conditions.
  12. The Power Partner agrees that in the discharge of its duties, the Power Partner is bound to follow the code of conduct as given/ referred in the above terms and conditions. The Power Partner confirms that the Power Partner has read and understood the above Code of Conduct and agrees to abide by the same. In case of any breach, non-compliance of the said Code, the Company shall have the right to take such action against the Power Partner as it may deem fit.

Confidentiality, Intellectual Property and Privacy Policy

  1. All details of prospective and/ or existing customers provided by or available with Power Partner, will not be shared with any third person, party or entity in any circumstances.
  2. The design & any subsequent modifications on the Power Partner App will be company’s intellectual property and may not be used or shared in any other form without our prior written consent.
  3. By using the application, Power Partner agrees that internet transmissions are never completely private and secure, and that any information uploaded by Power Partner on application (Name, account details, phone numbers) may be intercepted by others although it is encrypted.
  4. The detailed privacy policy can be accessed at https://ummeedhfc.com/en/privacy-policy The Power Partner confirms to have fully read and understood the detailed privacy policy and is ready to abide by it.

Payment Terms

  1. Pay-out (as specified and decided by the company) as per fresh file disbursal – Home Loan (subject to clearance of disbursal cheque).
  2. The pay-out will be calculated monthly (calendar month).
  3. The pay-out will be released within the monthly cycle [30 days of month end (last date of the calendar month)], once the Disbursal cheque has been cleared.

LIMITATION OF LIABILITY

IN NO EVENT WILL THE COMPANY, INCLUDING ITS AFFILIATES, SUCCESSORS AND ASSIGNS, AND EACH OF ITS OFFICERS, DIRECTORS, EMPLOYEES, AGENTS, OR SHAREHOLDERS (COLLECTIVELY “THE COMPANY ” FOR PURPOSES OF THIS SECTION), BE LIABLE TO YOU FOR ANY INCIDENTAL, SPECIAL, EXEMPLARY, PUNITIVE, CONSEQUENTIAL, OR INDIRECT DAMAGES (INCLUDING DAMAGES FOR DELETION, CORRUPTION, LOSS OF DATA, LOSS OF PROGRAMS, FAILURE TO STORE ANY INFORMATION OR OTHER CONTENT MAINTAINED OR TRANSMITTED BY THE COMPANY, SERVICE INTERRUPTIONS, OR FOR THE COST OF PROCUREMENT OF SUBSTITUTE SERVICES) ARISING OUT OF OR IN CONNECTION WITH THE APP OR WEBSITE. IF THESE LAWS APPLY TO YOU, SOME OR ALL OF THE ABOVE DISCLAIMERS, EXCLUSIONS OR LIMITATIONS MAY NOT APPLY TO YOU, AND YOU MAY HAVE ADDITIONAL RIGHTS.

COMPLIANCE OF TERMS AND CONDITIONS BY THE POWER PARTNER

THE POWER PARTNER HEREBY CONFIRMS THAT THE POWER PARTNER HAS READ AND UNDERSTOOD THE TERMS AND CONDITIONS APPLICABLE FOR POWER PARTNER EMPANELLED WITH COMPANY (“POWER PARTNER TERMS & CONDITIONS”), DISPLAYED ON THE WEBSITE OF THE COMPANY AND THE POWER PARTNER AGREES TO COMPLY WITH ALL THE SAID POWER PARTNER TERMS & CONDITIONS AS AMENDED FROM TIME TO TIME.

ALL ABOVE APP TERMS AND CONDITIONS AND POWER PARTNER TERMS & CONDITIONS DISPLAYED ON THE WEBSITE SHALL FORM AN INTEGRAL PART OF POWER PARTNER TERMS & CONDITIONS ("AGREEMENT") TO BE AGREED BY THE POWER PARTNER.

Co-lending Policy

Contents

Introduction................................................................................................................................2

Scope/ Applicability ....................................................................................................................2

Objective of the Policy................................................................................................................2

Co-Lending Partners..................................................................................................................2

Minimum Retention by the Originator for PSL..........................................................................  3

Assessment of the Co-Lending Partner and Approval................................................................3

Credit Policy and Product parameters...................................................................................... ..3

Agreement to be executed...........................................................................................................3

Co-lending Model (“CLM”) for the PSL Exposures with the Company as the Originator and a

Bank as a Lending Partner .........................................................................................................3

Other Types of Co-Lending Arrangements.................................................................................4

Customer Related Aspects..........................................................................................................5

Selection Criteria of Partners.....................................................................................................5

Selection Criteria of Potential Lending Partners........................................................................5

Selection Criteria of Originator..................................................................................................5

Operational Guidelines..............................................................................................................6

Review of the Policy...................................................................................................................6

Introduction

The Reserve Bank of India (RBI) issued a notification dated November 05, 2020, titled 'Co-Lending by Banks and NBFCs to Priority Sector' (referred to as 'Co-Lending Guidelines'). These guidelines defined the co-lending model and provided instructions primarily for co-origination and co-lending of loans categorized as Priority Sector Loans (PSL) by Scheduled Commercial Banks.
The Co-Lending Model (CLM) prescribed by the RBI facilitates joint lending arrangements between Non-Banking Finance Companies (NBFCs), including Housing Finance Companies (HFCs), and Banks. It aims to create a framework for lenders to collaborate and engage in joint lending in the market. Under CLM, the RBI grants operational flexibility to lending institutions, fostering increased credit flow to underserved sectors of the economy and ensuring affordable access to funds for end beneficiaries.
In alignment with regulatory requirements, Ummeed Housing Finance Private Limited (referred to as 'Company' or 'UMMEED') seeks to adopt this Co-Lending Model Policy ('Policy') with the approval of its Board of Directors.

 Scope/ Applicability

This Policy shall be applicable to all types of co-lending arrangements, which may be entered by the Company with various types of lenders such as Banks and other NBFCs/ HFCs.

Objective of the Policy

The objective of this Policy is to put in place a framework for the Company to enter into the CLM/ colending arrangements, while ensuring compliance with the regulatory requirements.

Co-Lending Framework

UMMEED shall endeavour to enter into Co-Lending Arrangements with the Banks for the PSL exposures. Further, the Company may also enter into similar partnership with the Banks and other NBFCs/ HFCs for co-origination of Housing Loans/ Non-Housing Loans including non-PSL exposures.
It's important to note that while the Co-Lending Model and regulatory framework pertain specifically to PSL transactions, UMMEED's non-PSL exposure will adhere to the RBI Directions on Transfer of Loan Exposure, as outlined in the Directions dated September 24, 2021 (as amended), and as applicable to loan participation/assignment transactions. The key elements of the proposed Co-Lending Framework have been provided in the subsequent paragraphs.

Co-Lending Partners

Co-lending arrangement shall have two lenders for a loan exposure, i.e., Originator and Co- Lending Partner (“Lending Partner”). The Originator shall source the loan and have some share in the total credit exposure taken on the borrower while the Lending Partner shall take majority share of such credit exposure. Depending on specific arrangement with the counter party, UMMEED may take the role of the Originator or the Lending Partner role in the funding proportion, as per the applicable guidelines.

Minimum Retention by the Originator for PSL

For the loans to be categorized as PSL exposures, the Company, as an Originator, shall retain a minimum of 20% share of the individual loans on its books, so that the Co-lending Bank will take their share of the Individual Loans on a back-to-back basis in their books.

Assessment of the Co-Lending Partner and Approval

UMMEED shall evaluate proposed Co-Lending partnerships as per the selection criteria mentioned below in the Paragraphs of the Policy. Thereafter, after seeking and receiving approval of the Asset Liability Management Committee (“ALCO”), the Company shall enter into a prior agreement with a Co-Lending Partner.

Credit Policy and Product parameters 

UMMEED will collaboratively develop the credit policy and identify the product lines to be offered in conjunction with potential co-lending partners.

Agreement to be executed

UMMEED and the Co-Lending Partner will execute either a Master Co-Lending Agreement or a comprehensive agreement. This agreement will encompass various terms and conditions governing the partnership, including but not limited to:
(i) Establishing the overall framework and scope of the partnership.
(ii) Defining the product lines and operating model.
(iii) Specifying geographical areas of operation.
(iv) Assigning responsibilities to co-lending partners, including those related to customer interactions, fair practices, customer service, customer grievance resolution at the originator level, and escalation procedures up to NHB or Banks/NBFC ombudsman levels.
(v) Inclusion of necessary clauses on representations and warranties for which both the Originator and Co-Lending Partner will be responsible concerning the loans allocated to the Lending Partner.
(vi) Framework for loan control, monitoring, reporting, and recovery.
(vii) Addressing issues related to confidentiality, customer data privacy, information preservation, and sharing of relevant records.
(viii) Establishing a common bank escrow account at a designated bank for loan collections, disbursements, and servicing.
(ix) Implementing a suitable business continuity plan at all participating lenders' levels.
(x) Handling aspects related to the creation of security/mortgage and other operational requirements as necessary. (xi) Determining the terms of termination and the agreement's tenor.

Co-lending Model (“CLM”) for the PSL Exposures with the Company as the Originator and a Bank as a Lending Partner

According to the Co-Lending Guidelines, the CLM consists of two sub-models: CLM-1 and CLM-2, based on the disbursement stage and the Lending Partner's discretionary selection. The Master Agreement, established between the Originator and the Lending Partner for implementing the CLM, may require the Lending Partner to either obligatorily include its portion of individual loans originated by the Originator in its records or exercise discretion to reject specific loans following its due diligence process. The Master Agreement, along with other agreements related to the CLM arrangement, will contain specific provisions pertaining to the chosen CLM sub-model:

a) CLM-1 Model:

If the Master Agreement or any other associated agreements include CLM-1 provisions, the Lending Partner shall be under an irrevocable obligation to incorporate its allocated portion of individual loans originated by the Originator into its own financial records. This commitment shall be executed while ensuring strict adherence to the 'Guidelines on Managing Risks and Code of Conduct in Outsourcing of Financial Services' issued by the Reserve Bank of India (RBI), as applicable and updated periodically. Moreover, recognizing that the credit sanction process is not eligible for outsourcing under CLM-1, both the Lending Partner and the Originator shall establish an appropriate mechanism for conducting ex-ante due diligence by the Lending Partner.

b) CLM-2 Model:

Under CLM-2, the Lending Partner retains the discretion to include loans originated by the Originator in its own books as outlined in the Agreement. This arrangement bears similarity to a direct assignment transaction. Consequently, the acquiring Lending Partner shall ensure strict compliance with all stipulations delineated in the 'Reserve Bank of India (Transfer of Loan Exposures) Directions, 2021' (referred to as the 'RBI TLE Directions'), as updated periodically. However, it is noteworthy that the Minimum Holding Period ('MHP') requirement specified in the RBI TLE Directions does not apply to transactions conducted under CLM. The MHP exemption shall solely be applicable in instances where a pre-existing agreement between the Lending Partner and the Originator incorporates a back-to-back basis clause and adheres to all other conditions mandated in the RBI TLE Directions.

 Other Types of Co-Lending Arrangements

(i) The Company is authorized to establish a Co-Lending Arrangement with a Small Finance Bank, NBFC, or any other HFC in accordance with the relevant regulatory prerequisites and within the broader framework delineated in this Policy.
(ii) In the event of a collaborative lending arrangement between banks and the Company for providing loans to borrowers, both parties shall maintain meticulous, separate records documenting their respective loan transactions. To facilitate these financial transactions, a dedicated 'Escrow Account' shall be established with a bank to ensure the strict segregation of their respective funds, thereby mitigating the risk of commingling.
(iii) All requisite protocols, procedures, and terms governing this collaborative lending arrangement shall be comprehensively documented in a formalized written agreement, herein referred to as the 'Master Agreement.' The 'Master Agreement' shall function as the guiding framework dictating the parameters of their collaborative involvement within the co-lending structure.
(iv) Each lender shall be mandated to adhere to asset classification and provisioning requirements in accordance with the pertinent regulatory guidelines that are applicable to each of them. This includes compliance with reporting obligations to Credit Information Companies, as mandated by the applicable regulations, with respect to their respective portions of the loan account.
(v) Any assignment of a loan by one co-lender to a third party shall only be carried out with the prior consent of the other co-lender.
(vi) The Originator, including participating lenders, may choose to seek legal vetting of the Master Agreement to ensure full legal and regulatory compliance.
(vii) For non-PSL exposure, the minimum retention ratio shall be subject to compliance with relevant regulatory requirements, if any.

Customer Related Aspects

(i) The Originator shall be the single point of interface for the customers and shall enter into a loan agreement with the borrower, which shall clearly contain the features of the arrangement and the roles and responsibilities of the Originator and the Lending Partner.
(ii) The Originator shall ensure that all the details of the arrangement shall be disclosed to the customers upfront, and their explicit consent shall be taken.
(iii) The ultimate borrower may be charged an all-inclusive interest rate as may be agreed upon by both the lenders conforming to the extant guidelines applicable to both.
(iv) The Company shall ensure compliance with the applicable Fair Practices Code.
(v) The Originator shall generate a single unified statement of the customer, through appropriate information sharing arrangements with the Lending Partner.
(vi) With regard to grievance redressal, suitable arrangements shall be put in place in accordance with the applicable regulatory/ supervisory instructions.

Selection Criteria of Partners
Selection Criteria of Potential Lending Partners

UMMEED, as an Originator, shall ensure that the Lending Partners selected for the Co-lending business are the Scheduled Commercial Banks registered with the RBI. However, subject to the applicable regulatory requirements from time to time, the Company may also enter into such co-lending arrangement with a Small Finance Bank (“SFB”), NBFC or any other HFC, registered with RBI.
The key criteria of selecting a potential Lending Partner would be to have viablebusiness arrangement to make funds available to the ultimate beneficiary at an affordable cost while ensuring robust growth of the Company’s business in low income and affordable loan segments.

Selection Criteria of Originator

In case UMMEED is acting just as a Lending Partner in the Co-Lending Arrangement, it may opt to enter such an arrangement with NBFCs or other HFCs. However, the Company shall conduct due diligence on the following parameters:
(i) Vintage- Only those originators who have more than 3 years of experience in the similar product lines shall be considered.
(ii) Analysis of the financial statements of the Originator for Profitability, Liquidity, ALM profile and other financial parameters shall be carried out
(iii) The Company shall conduct an assessment of the performance of the Originator’s loan portfolio to ascertain the efficiency of its sourcing quality and collection processes. For this purpose, data pertaining to product mix, delinquency trends, vintage curves, credit loss trends and recovery performance of the portfolio shall be evaluated. (iv) The Company shall obtain feedback as per the credit rating agency reports or other industry players.
(v) The Company shall conduct an assessment of qualitative factors such as reputation of the promoters, funding profile, management quality, corporate governance and historical performance of the portfolio originated.

 Operational Guidelines

Operational modalities of the Co-lending arrangement shall be guided by the Master Agreement, Servicer Agreement, and any other such agreement signed bilaterally between both the parties.

 Review of the Policy

The Policy shall be amended or modified with approval of the Board. The Policy shall be reviewed by the Board on an annual basis. Consequent upon any amendments to the Co- Lending Guidelines or any other relevant regulatory directions or any change in the position of the Company, necessary changes in this Policy shall be incorporated and approved by the Board.
Notwithstanding anything contained in this Policy, in case of any contradiction of the provision of this Policy with any existing legislations, rules, regulations, laws or modification thereof or enactment of a new applicable law, the provisions under such law, legislation, rules, regulation or enactment shall prevail over this Policy.