Fair Banner icon Fair Practice Code

Fair Practice Code

This has reference to the Master Direction - Non-Banking Financial Company – Housing Finance Company (Reserve Bank) Directions,2021, RBI/2020-21/73 dated February 17, 2021, wherein the Reserve Bank of India has revised the guidelines on Fair Practices Code for Housing Finance Companies to implement the same.

The master directions- Fair Lending Practice - Penal Charges in Loan Accounts is introduced vide RBI circular RBI/2023- 24/53 DoR.MCS.REC.28/01.01.001/2023-24 dated August 18, 2023.

This Code shall apply to all the products and services offered by IIFL HFL, whether offered through Digital Lending Platforms (self-owned and/or under an outsourcing arrangement), across the counter, over the phone, by post, through interactive electronic devices, on the internet or by any other method.

It was introduced as it has been observed that organizations use penal rates of interest, over and above the applicable interest rates, in case of defaults / non-compliance by the borrower with the terms on which credit facilities were sanctioned. The intent of levying penal charges is essentially to inculcate a sense of credit discipline and such charges are not meant to be used as a revenue enhancement tool over and above the contracted rate of interest.

  1. All communications to the borrower shall be in the vernacular language or a language as understood by the borrower.
  2. IIFL HFL shall transparently disclose to the borrower 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. In other words, IIFL HFL must disclose ‘all in cost’ inclusive of all charges involved in processing/ sanctioning of loan application in a transparent manner. It should also be ensured that such charges/ fees are non-discriminatory.
  3. Loan application forms/ appropriate communication to the borrower shall include necessary information which affects the interest of the borrower, so that a meaningful comparison with the terms and conditions offered by other HFCs can be made and informed decision can be taken by the borrower. The loan application form may indicate the list of documents required to be submitted with the application form.
  4. IIFL HFL shall devise a system of giving acknowledgement for receipt of all loan applications. IIFL HFL shall also disclose borrower about loan status within reasonable timeframe post receipt of all documents and information required for loan processing.

  1. Normally all particulars required for processing the loan application shall be collected by IIFL HFL at the time of application. In case any additional information is required, we will contact the borrower immediately.
  2. IIFL HFL shall convey in writing to the borrower in the vernacular language or a language as understood by the borrower by means of sanction letter or otherwise, the amount of loan sanctioned along with all terms and conditions including annualized rate of interest, method of application, EMI Structure, prepayment charges, penal Charges(if any) and keep the written acceptance of these terms and conditions by the borrower on its record.
  3. IIFL HFL shall mention thePenal charges charged for late repayment in bold in the loan agreement.
  4. IIFL HFL shall invariably 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.
  5. If IIFL HFL cannot provide the loan to the customer, it shall communicate in writing the reason(s) for rejection

  1. IIFL HFL shall make disbursement in accordance with the disbursement schedule given in the Loan Agreement/ Sanction Letter/any other relevant document.
  2. IIFL HFL shall give notice to the borrower in the vernacular language or a language understood by the borrower about any change in the terms and conditions including disbursement schedule, interest rates, penal Charges (if any), service charges, prepayment charges, other applicable fee/ charges etc. IIFL HFL would also ensure that changes in interest rates and charges are effected only prospectively. A suitable condition in this regard should be incorporated in the loan agreement.
  3. If such change as mentioned above is to the disadvantage of the customer, he/ she may within 60 days and without notice close his/ her account or switch it without having to pay any extra charges or interest.
  4. Decision to recall/ accelerate payment or performance under the agreement or seeking additional securities, would be in consonance with the loan agreement.
  5. IIFL HFL shall release all securities on repayment of all dues or on realization of the outstanding amount of loan subject to any legitimate right or lien for any other claim against borrower. If such right of set off is to be exercised, the borrower shall be given notice about the same with full particulars about the remaining claims and the conditions under which IIFL HFL is entitled to retain the securities till the relevant claim is settled/ paid.

We have a system and a procedure for receiving, registering and disposing of complaints and grievances in each of our offices, as well as on-line.

  1. Raise an online request at https://www.iiflhomeloans.com/reach-us/raise-a-request
  2. Walk Into branches(as mentioned in Company brochure/website/any other leaflet)
  3. Call the helpline number mentioned in the MITC.

  1. IIFL Home Finance Limited would strive for customersatisfaction within the framework of law, adopted policies and procedures.
  2. In case of any grievance, the customer may approach the branch where he / she had his / her account and register the complaint in the 'Complaint Register' available in the branch.
  3. On registering the complaint, the customer shall be provided a complaint number and date for future reference.
  4. https://www.iiflhomeloans.com/reach-us/raise-a-request write / communicate with the concerned location for redressal of the grievance.
  5. Designated Helpline Number forsubmission of complaints:1860 267 3000
  6. Legal proceeding that have been initiated against the customer to recover the dues.
  7. Debts settle through legal recourses against the customer.

IIFL HFL would send response / acknowledge receipt of complaint within a week. The acknowledgement will contain the name & designation of the official who will deal with the grievance. If the complaint is relayed over phone at our designated telephone helpdesk or customer service number, the customer shall be provided with a complaint reference number and be kept informed of the progress within a reasonable period of time.

After examining the matter, IIFL HFL shall send customer its final reply or communicate why it needs more time to respond and shall endeavor to do so within six weeks of receipt of a complaint and customer shall be informed how to take his/ her complaint further if he/ she is still not satisfied.

Level I

In case of response/ acknowledgement of your compliant not received within 7 days, customer can raise an online request at https://www.iiflhomeloans.com/reach-us/raise-a-request or response being unsatisfactory from above mentioned sources the complaint may be further escalated to:

Grievance Redressal Officer Vishal Bahlerao at gro@iiflhomeloans.com

IIFL Tower, 98, Udyog Vihar, Phase-IV, Near Maruti Gate no-3, Gurgaon, Haryana -122016

Level II

In case of response not being received within 15 days of escalation of complaint to Level I or the response being unsatisfactory from the above mentioned sources the complaint may be further escalated to:

NodalOfficer at no@iiflhomeloans.com

IIFL Tower, 98, Udyog Vihar, Phase-IV, Near Maruti Gate no-3, Gurgaon, Haryana -122016

Level III

In case of response not being received or the response being unsatisfactory from the above mentioned sources the complaint may be further escalated to:

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

The complaint can also be emailed to crcell@nhb.org.in

Further, the complaint may be lodged in Online mode https://www.iiflhomeloans.com/reach-us/raise-a-request OR in offline mode by post, in prescribed format available https://www.iiflhomeloans.com/reach-us/raise-a-request

  1. IIFL HFL has adopted an interest rate model 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.
  2. The rate of interest is linked with borrower’s credit score, loan amount applied, type of property and product applied and is disclosed to the borrower in the sanction letter.
  3. IIFL HFL also charge penal charges in case of default in repayment. This annualized rate is communicated during sanction of a loan in MITC document of the Company, loan agreement and is also available on the Company’s website.
  4. Instalments collected from borrowers clearly indicate the bifurcation between interest and principal in Statement of Account

  1. Penalty to be charged for non-compliance of material terms and conditions of loan contract by the borrower.
  2. IIFL HFL treated as ‘penal charges’ and shall not be levied in the form of ‘penal interest’ that is added to the rate of interest charged on the advances.
  3. There shall be no capitalization of penal charges i.e., no further interest should be computed on such charges.
  4. There will be no affect on the normal procedures for compounding of interest in the loan account.
  5. We shall not introduce any additional component to the rate of interest and ensure compliance to these guidelines in both letter and spirit. The quantum and reason for penal charges shall be clearly disclosed to the customers in the loan agreement and most important terms & conditions, in addition to being displayed on website under Interest rates and Service Charge
  6. Penal charges to be charged at 18% per annum on the loan overdue amount. Penalties charged for late payment should be highlighted in bold in the loan agreement.

  1. IIFL HFL shall ensure that all advertising and promotional material is clear, and factual.
  2. 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, IIFL HFL shall also indicate whether other fees and charges will apply and that full details of the relevant terms and conditions are available on request or on the website.
  3. Information on interest rates, common fees and charges (including penal Charges, if any) can be obtained by Customer through:
    • Notice board at branches;
    • By calling at IIFL HFL’s designated helpline numbers;
    • IIFL HFL’s website; or
    • Sanction letter & MITC (Most Important Terms & Conditions) documentshared at the time of loan approval
  4. If IIFL HFL avails of the services of third parties for providing support services, it shall ensure that such third parties handle customer’s personal information (if any available to such third parties) with the same degree of confidentiality and security as we would.
  5. IIFL HFL, from time to time, communicates to its customers various features of its products availed by them. Information about other products or promotional offers in respect of products/ services, are conveyed to customers only if he/ she has given his/ her consent to receive such information/ service to IIFL HFL.
  6. We have prescribed a code of conduct for our Direct Selling Agencies (DSAs) whose services are availed to market products/ services which amongst other matters require them to identify themselves/their representatives when they approach the customer for selling products personally or through phone.
  7. In the event of receipt of any complaint from the customer that representative of IIFL HFL or its DSA has engaged in any improper conduct or acted in violation of this Code, appropriate steps shall be initiated to investigate and to handle the complaint and to make good the loss.

When a person is considering being a guarantor to a loan, he/ she should be informed about:

IIFL HFL will keep him/ her informed of any material adverse change in the financial position of the borrower to home he/ she stands as a guarantor.

  1. his/ her liability as guarantor;
  2. the amount of liability he/ she will be committing him/herself to the company;
  3. circumstances in which IIFL HFL will call on him/her to pay up his/ her liability;
  4. whether IIFL HFL hasrecourse to his/her other monies in the company if he/ she fail to pay up as a guarantor;
  5. whether his/her liabilities as a guarantor are limited to a specific quantum or are they unlimited; and
  6. time and circumstances in which his/ her liabilities as a guarantor will be discharged as also the manner in which IIFL HFL will notify him/ her about this.
  7. In case the guarantor refuses to comply with the demand made by IIFL HFL, despite having sufficient means to make payment of the dues, such guarantor would also be treated as a wilful defaulter.

All personal information of customers, both present and past, shall be treated as private and confidential and shall be guided by the following principles and policies.

IIFL HFL shall not reveal information or data relating to customer accounts, whether provided by the customers or otherwise, to anyone, including other companies/ entities in their group, other than in the following exceptional cases:

  1. If the information is to be given by law.
  2. If there is a duty towards the public to reveal the information.
  3. If IIFL HFL’s interests require them to give the information (for example, to prevent fraud). However, it should 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.
  4. If the customer asksIIFL HFL to reveal the information, or with the customer’s permission.
  5. If IIFL HFL is asked to give a reference about any of its customers, it shall obtain their written permission before giving the reference.

  1. IIFL HFL shall refrain from interference in the affairs of the borrower except for the purposes provided in the terms and conditions of the loan agreement (unless information, not earlier disclosed by the borrower, has been noticed).
  2. In case of receipt of request from the borrower for transfer of borrowal account, the consent or otherwise i.e. objection of IIFL HFL, if any, shall be conveyed within 21 days from the date of receipt of request. Such transfer shall be as per transparent contractual terms in consonance with law.
  3. Whenever loans are given, IIFL HFL shall explain to the customer the repayment process by way of amount, tenure and periodicity of repayment. However, if the customer does not adhere to repayment schedule, a defined process in accordance with the laws of the land shall be followed for recovery of dues. The process will involve reminding the customer by sending him/ her notice or by making personal visits and/or repossession of security if any.
  4. In the matter of recovery of loans, IIFL HFL shall not resort to harassment viz. persistently bothering the borrowers at odd hours, use muscle power for recovery of loans etc.
  5. IIFL HFL shall not charge pre-payment levy or penalty on pre-closure of housing loans under the following situations:
    a. Where the housing loan is on floating interest rate basis and pre-closed from any source.
    b. Where the housing loan is on fixed interest rate basis and the loan is pre-closed by the borrower out of their own sources.
  6. 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.

  7. IIFL HFL 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).
  8. To facilitate quick and good understanding of the major terms and conditions of housing loan agreed upon between IIFL HFL and the individual borrower, IIFL HFL will obtain a document containing the most important terms and conditions (MITC) in all cases in the prescribed format by RBI. The document will be in addition to the existing loan and security documents being obtained by IIFL HFL. Duplicate copy duly executed between IIFL HFL and the borrower is handed over to the borrower under acknowledgement.
  9. Information related to various key aspect such as service charges, interest rates, Penal interest (if any), services offered, product information, time norms for various transactions and grievance redressal mechanism, etc. shall be displayed on our Notice Board, Booklets/ Brochures, Website etc. in English, Hindi and/ or the appropriate local language.
  10. IIFL HFL shall not discriminate on grounds of sex, caste and religion in the matter of lending. Further, we shall also not discriminate visually impaired or physically challenged applicants on the ground of disability in extending products, services, facilities, etc.
  11. This document is public and can be downloaded from our website or can be emailed on request. This document shall also be displayed on the notice board of all our branches for easy reference.