Fair Practice Code

This Code shall apply to all the products and services offered by IIFL HFL, across the counter, over the phone, by post, through interactive electronic devices, on the internet or by any other method. The loan journey for the customer takes place through in-house mobile platforms by own employees.

(i) All communications to the borrower shall be in the vernacular language or a language as understood by the borrower.

(ii) 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.

(iii) 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.

(iv) 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.

(i)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, the customer should be told immediately he would be contacted again.

(ii)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.

(iii)IIFL HFL shall mention the penal charges charged for late repayment in bold in the loan agreement.

(iv)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.

If IIFL HFL cannot provide the loan to the customer, it shall communicate to the customer in writing the reason(s) for rejection.

(i)Disbursement should be made in accordance with the disbursement schedule given in the Loan Agreement/ Sanction Letter/any other relevant document.

(ii)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 affected only prospectively. A suitable condition in this regard should be incorporated in the loan agreement.

(iii)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.

(iv)Decision to recall/ accelerate payment or performance under the agreement or seeking additional securities, would be in consonance with the loan agreement.

(v)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.

(i)IIFL HFL shall release all the immovable property documents and remove charges registered with any registry within a period of 30 days after full repayment/ settlement of the loan account.

(ii)The Property Owner/Borrower(s) shall option to collecting their original title documents either from the banking outlet/branch where the loan was serviced or any other office of the IIFL HFL where the documents are available, as per her/his preference.

To address the contingent event of demise of the sole borrower or joint borrowers, IIFL HFL has a well laid out procedure for return of original immovable property documents to the legal heirs. Such procedure is displayed on the website of IIFL HFL along with other similar policies and procedures for customer information.

(i)In case of delay of releasing of original property documents or failing to file charge satisfaction form with relevant registry beyond 30 days after full repayment/settlement of loan, IIFL HFL shall communicate to the borrower reasons for such delay. Where the delay is attributable to IIFL HFL, the company shall compensate the borrower at the rate of ₹5,000/- for each day of delay.

(ii)In case of loss/ damage to original immovable property documents, either in part or in full, the IIFL HFL shall assist the borrower in obtaining duplicate/ certified copies of the immovable property documents and shall bear the associated costs, in addition to paying compensation as indicated at sub-paragraph (i) above. However, in such cases, an additional time of 30 days will be available to the IIFL HFL to complete this procedure and the delayed period penalty will be calculated thereafter (i.e. after a total period of 60 days).

(iii)The compensation provided under these directions shall be without prejudice to the rights of a borrower to get any other compensation as per any applicable law.

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

• Customers should be able to access the Company through any of the following means:
  1. Raise an online request at https://www.iiflhomeloans.com/raise-a-request
  2. Walk Into branches (as mentioned in Company brochure/website/any other leaflet)
  3. Call the helpline number 1860 -267-3000 mentioned on the website.
• IIFL HFL would strive for customer satisfaction within the framework of law, adopted policies and procedures.
• On registering the complaint, the customer shall be provided a complaint number and date for future reference.

  IIFL HFL would send response / acknowledge receipt of complaint within a week. If the complaint is relayed over phone at our designated telephone helpdesk or customer service number, the customer shall be provided with a complaint reference number 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 30 days 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 complaint 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 at email id : gro@iiflhomeloans.com or contact number: 1860 267 3000

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:

Nodal Officer at email id: no@iiflhomeloans.com or contact number: 7039 05 0000

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

LEVEL III

In case the Customer does not receive response from the company within a period of one month or is dissatisfied with the response received, the Customer may approach the Complaint Redressal Cell of NHB by lodging its complaints online on the website of NHB

http://grids.nhbonline.org.in or offline mode by post in prescribed format available at link https://www.nhb.org.in/grievance-redressal-officer/ at the following address:

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

www.nhb.org.in Link: https://grids.nhbonline.org.in/

The above-mentioned Grievance Redressal Mechanism is also available at Company’s website at https://www.iiflhomeloans.com/

For the Co-lending arrangement, if the complainant does not receive a response from the Company within 30 days or is dissatisfied with the response received, the complainant may approach the concerned Banking Ombudsman or the Customer Education and Protection Cell (CEPC) in RBI.

More details please refer to the IIFL HFL Grievance redressal Procedure/policy or visit our official website: https://www.iiflhomeloans.com/grievance-redressal-procedure

The Company holds the Registration of a Corporate Agent (composite) with IRDAI for solicitation of insurance business. It will ensure adherence to the IRDAI Regulations, with respect to redressal of grievances relating to insurance. The complaints related to insurance products sold by the company will be acknowledged and IIFL Home Finance Ltd. will facilitate redressal within two weeks of the receipt of such complaint through the respective Insurance Company (ies).

The Insurance customer is advised to follow the below steps for registration and resolution of their complaints.

LEVEL I

In case of response /acknowledgement of your complaint is 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 at gro@iiflhomeloans.com or contact number: 1860 267 3000

IT Grievance Officer - itgro@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 7 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:

Nodal Officer at no@iiflhomeloans.com or contact number: 7039 05 0000

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

LEVEL III

If the complaint is not resolved or the customer is not satisfied with the resolution provided by the Insurer/Nido, then at any point in time he or she can:

• Escalate the complaint online through Bima Bharosa System by logging into - https://bimabharosa.irdai.gov.in/
• Or Call Toll Free Number 155255 or 1800 4254 732
• Or Email to - complaints@irdai.gov.in
• Or write to as follows:

  Insurance Regulatory and Development Authority of India (IRDAI), Sy No 115/1, 4th floor, Financial District, Nanakramguda, Gachibowli, Hyderabad 500032

• In rare cases, in case the borrower is not happy with the resolution provided by the above, then he/she may be guided to the Insurance Ombudsman.

a. IIFL HFL adopts an interest rate model taking into account relevant factors such as cost of funds, margin and risk premium and determining the rate of interest to be charged for loans and advances. The rate of interest and the approach for gradation of risk and rationale for charging different rate of interest to different categories of borrowers would be disclosed to the borrower or customer in the application form and communicated explicitly in the sanction letter.

b. Policy for penal charges (if any) has been laid down by the Company.

c. The rates of interest and the approach for gradation of risks, and penal charges (if any) would be made available on the website of the Company or published in the relevant newspapers. The information published on the website or otherwise published shall be updated whenever there is a change in the rates of interest.

d. The rate of interest will be an annualized rate so that the borrower is aware of the exact rates that would be charged to the account.

e. The IIFL HFL shall not add penal charges to the rate of interest. There shall be no capitalization of penal charges i.e. no further interest should be computed on such charges.

f. The instalments collected from borrowers clearly indicate the bifurcation between interest and principal.

g. IIFL HFL has an internal mechanism to monitor the process and the operations so as to ensure adequate transparency in communications with the borrowers.

IIFL HFL charges penalty for non-compliance of material terms and conditions of loan contract by the borrower. Such penalty shall be 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.

• There shall be no capitalization of penal charges i.e., no further interest should be computed on such charges.
• There will be no affect on the normal procedures for compounding of interest in the loan account.
• We shall not introduce any additional component to the rate of interest and ensure compliance with 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
• 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.
• The penal charges in case of loans sanctioned to ‘individual borrowers, for purposes other than business’, shall not be higher than the penal charges applicable to non-individual borrowers for similar non-compliance of material terms and conditions.
• Whenever reminders for non-compliance of material terms and conditions of loan are sent to borrowers, the applicable penal charges shall be communicated. Further, any instance of levy of penal charges and the reason therefore shall also be communicated.

• At the time of sanction, the Company shall clearly communicate to the borrowers about the possible impact of change in benchmark interest rate on the loan leading to changes in EMI and/or tenor or both. Subsequently, any increase in the EMI/ tenor or both on account of the above shall be communicated to the borrower immediately.
• At the time of reset of interest rate, IIFL HFL shall provide the option to the borrowers to switch over to a fixed rate as per their board approved policy (if any fixed ROI facility is available). The policy inter alia, may also specify the number of time borrower will be allowed to switch during the tenor of loan.
• All applicable charges for switching of loans and any other service charges/administrative cost incidental to exercise of the above options shall be transparently disclosed (i) in the sanction letter (ii) also at the time of revision of such charges /cost by IIFL HFL from time to time.
• The borrowers shall also be given the choice to opt for (i) enhancement in EMI or elongation of tenor or for a combination of both options; and, (ii) to prepay, either in part or in full, at any point during the tenor of the loan.
• IIFL HFL shall ensure that the elongation of tenor in case of floating rate loan does nor result in negative amortization.
• The Company shall provide/make accessible quarterly statements to borrowers covering
  1. the principal and interest recovered till date,
  2. EMI amount, number of EMIs left and
  3. annualized rate of interest / Annual Percentage Rate (APR) for the entire tenor of the loan

     *Personal loans shall be as defined in RBI circular No. DBR.No.BP.BC.99/08.13.100/2017- 18 on “XBRL Returns – Harmonization of Banking Statistics” dated January 04, 2018.

(i) IIFL HFL shall ensure that all advertising and promotional material is clear, and factual.

(ii) 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.

(iii) 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) document shared at the time of loan approval

(iv) 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.

(v) 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.

(vi) We have prescribed a board approved 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.

(vii) 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.

a. his/ her liability as guarantor;

b.the amount of liability he/ she will be committing him/herself to the company;

c. circumstances in which IIFL HFL will call on him/her to pay up his/ her liability;

d. whether IIFL HFL has recourse to his/her other monies in the company if he/ she fail to pay up as a guarantor;

e. whether his/her liabilities as a guarantor are limited to a specific quantum or are they unlimited; and

f. 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.

g. 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 willful 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 asks IIFL 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.

Reference circulars:

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 borrower 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.

   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.

6. 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).
7. IIFL HFL shall comply with instructions contained in the circular on ‘Key Facts Statement (KFS) for Loans & Advances’ dated April 15, 2024.
8. To facilitate quick and good understanding of other major terms and conditions of housing loan agreed upon between IIFL HFL and the individual borrower, IIFL HFL will additionally obtain a document containing the other most important terms and conditions (MITC) of such loan (i.e. other than the details included in KFS) 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 and in the language understood by borrower 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 charges (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. The following list of documents* shall be part of the customer information booklet

10. a) Fair practice code b) KYC and AML policy c) Grievance redressal policy d) Other most important terms and conditions e) Schedule of charges
    *List of documents are not exhaustive in nature and the same will be updated as and when new guidelines/ notifications/advisory received for the same.

11. 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.
12. 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.
    1. RBI Circular RBI/2020- 21/73DOR.FIN.HFC.CC.No.120/03.10.136/2020-21 related to Master Direction – Non-Banking Financial Company – Housing Finance Company (Reserve Bank) Directions, 2021 dated February 17, 2021.
    2. RBI Circular RBI/2023-24/53 DOR.MCS.REC.28/01.01.001/2023-24 related to Fair Practice code – Penal charges in Loan accounts dated August 18, 2023.
    3. RBI Circular RBI/2023-24/55 DOR.MCS.REC.32/01.01.003/2023-24 related to reset of floating interest rate on EMI based personal loan dates August 18, 2023.
    4. RBI Circular RBI/2023-24/60 DOR.MCS.REC.38/01.01.001/2023-24 related to Responsible Lending Conduct – Release of Movable / Immovable Property Documents on Repayment/ Settlement of Personal Loans dated September 13, 2023.
    5. RBI Circular RBI/2022-23/111DOR.CRE.REC.66/21.07.001/2022-23 related to guidelines on digital lending dated September 02,2022, to the extent of applicable.
    6. RBI Circular RBI/ 2024-25/18 DOR.STR.REC.13/13.03.00/2024-25 related to Key fact statement (KFS) for loans & Advances dated April 15, 2024.