FAIR PRACTICES CODE

1. Preface
Hiranandani Financial Services Private Limited (“Company/ HFS”), in pursuance of the Directions issued by Reserve Bank of India for Non-Banking Financial Companies (NBFCs), has adopted the following Code for fair practices while dealing with customers. The Fair Practices Code (“FPC”) is intended to cover the following areas:

  • Applications for loans and their processing
  • Loan appraisal and terms/conditions
  • Disbursement of loans, including changes in terms and conditions
  • General provisions
  • Grievance redressal mechanism
  • Interest Charges, and
  • Penal Charges

2. Objective

  • Promote good, fair and trustworthy practices by setting minimum standards in dealing with customers
  • Increase transparency to enable the customers to have a better understanding of what they can reasonably expect of the services.
  • Promote a fair and cordial relationship between the customers and the Company.

3. Applications for loans and their processing

  •  All relevant information pertaining to the loan/loan facility will be made available in the relevant loan application form(s) or through other modes (term sheet, sanction letter etc.). The loan application form will also indicate/contain the documents required to be submitted together with the duly completed application form and the timelines within which the application will be disposed of, subject to receipt of necessary documents.
  • The Client will have the option to receive all the correspondences, loan documents, recall notices etc. relating to loan in vernacular language or a language understood by the Client. In such a scenario, the Client shall communicate their preferred language separately.
  • Receipt of completed application forms will be duly acknowledged within appropriate timeframe.

4. Loan appraisal and terms/conditions

  • Loan applications shall be assessed in accordance with the Company’s credit appraisal process and policies. The client shall be advised of the outcome of the credit appraisal (approval/rejection) within the period for appraising the loan application indicated in the acknowledgment to loan application, in the vernacular language or a language understood by the Client.
  • Upon approval of the loan, the Company shall convey the amount of loan sanctioned, annualized interest rate and other important terms and conditions to the Client by way of 2 sanction letter or otherwise in the language selected by the Client in the application form for correspondence, etc. The penal charges, if any, to be charged by the Company for late repayment, other charges, etc., if any, shall be levied as per schedule of charges on non compliances of loan terms and conditions shall be mentioned in bold in the loan agreement and the same shall be displayed on the website of the Company .An acceptance of such terms and conditions shall be retained by the Company.
  • The Company shall enter into an agreement indicating the amount of loan sanctioned,annualised rate of interest applicable, schedule of charges along with the terms and conditions with the client. A copy of the said agreement along with schedule(s) and annexure(s) to the agreement will be provided to the client in the language opted by the client.
  • When penal charges are levied for non-compliance with the material terms and conditions of sanctioned loan, it shall be in compliance with the guidelines issued by RBI from time to time.

5. Disbursement of loans, including changes in terms and conditions

  • Any changes to the terms and conditions, interest rates, , shall be informed individually to the borrowers in case of account specific changes, and in case of others, the same shall be available at the Registered office / Corporate office of the Company or on website Changes in the interest rates and charges shall be effected prospectively. A suitable condition to this effect will be inserted in the loan agreement.
  • Decision to recall / accelerate payment or performance under the agreement shall be in accordance with the terms and conditions of the loan documents executed by the borrower with the Company.
  • All securities pertaining to the loan would be released on receipt of full and final payment of the loan(s), subject to any legitimate or contractual right or lien or right to set-off which the Company or any other person may have under the loan documents against the borrowers. 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 the right to retain or setoff the securities/sale proceeds from the securities or right to transfer the securities or sale proceeds is exercised by the Company. In the event of full and final payment of the loans along with other dues, if any, “No outstanding dues” certificate shall be issued by the Company within a period of 30 days after full repayment / settlement of loan account.
  • All notices, correspondence in respect of the loan will be made in the vernacular language or language understood by the borrower.

6. Applicant with Disability
The Company shall not discriminate in extending products and facilities including loan facilities to the physically / visually challenged applicants on the grounds of disability. They shall be treated at par with the other applicants and their application shall be dealt on merit as per the credit process and policy of the Company. All possible assistance will be provided to the applicants with the disability (ies) to enable them to understand, select and avail appropriate product or loan facility.3

7. General Provisions

  • The Company shall refrain from interference in the affairs of the borrower, except for the purposes and as provided in the terms and conditions of the loan documents or unless new information, not earlier disclosed by the borrower, has come to the notice of the Company.
  • 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.
  • In the matter of recovery of loans, the Company shall not resort to undue harassment viz persistently bothering the borrower at odd hours, use of muscle power for recovery of loans and would operate within the legal framework.
  • The Company shall not charge foreclosure charges/ pre-payment charges on any floating rate term loans sanctioned, for purposes other than business to individual borrowers with or without co-obligant (s). The foreclosure charges are to be applied as per the regulatory directions issued from time to time.

8. Grievance Redressal
The implementation of the Fair Practices Code shall be the responsibility of the Company. The Company shall make every effort to ensure that its dealing with borrowers / customers is smooth and hassle free. Any complaint brought to the notice of the Company by a borrower / customer will be handled expeditiously.

The Board of Directors of the Company has laid down the appropriate grievance redressal mechanism within the organization to resolve complaints and grievances. All disputes / complaints arising out of the decisions of the Company’s functionaries would be heard and disposed of at least at the next higher level after it is brought to their notice.

A consolidated report of periodical review with compliance with the Fair Practices Code and functioning of the grievances redressal mechanism at various levels of Management would be submitted to the Board of Directors (or a committee thereof) at regular intervals.

The contact details of the Grievance Redressal Officer (“GRO”) and the local office of RBI (which can be approached, if the complaint / dispute is not resolved within a period of one month) will be displayed at all the branches / places where the Company conducts its business.

Detailed process of grievance redressal and escalation matrix forms part of Grievance Redressal Mechanism which is placed on the website of the Company and shall also be available at the branches and will also be displayed at notice Board.

9. Interest Charges

  • The rate of interest is arrived after considering factors like cost of funds, margin and risk premium, etc. To ensure that the customers are not charged excessive interest rate and charges the Company has adopted the “Interest Rate Policy” and same will be available on the website of the Company
  • The information published in the website or otherwise published will be updated, whenever there is a change in the rates of interest.
  • The rate of interest would be annualized rates so that the borrower is aware of the exact rates that would be charged to the account.4

10. Review of Code
The Code shall be reviewed on an annual basis or as mandated by the regulatory requirement.

                                                                          ……XXX……
Regional language :
Hindi | Gujarati | Marathi | Telugu | Tamil | Kannada

GRIEVANCE REDRESSAL MECHANISM

In case of any grievance, customers can intimate and record their complaints / grievances for a resolution in the manner detailed below:

l. Registration of Complaints:

a. Branch – Customers can visit the branch office for registration of their grievances in form of a written complaint;
b. Email :Customers can send their grievance through email at : wecare@hfs.in
c.  Letters: Customer can write to: Customer Service, Hiranandani Financial Services Private Limited, 9 th Floor, Sigma , Technology Street, Hiranandani Business Park, Powai, Mumbai – 400076.

  • Customers shall ensure that they quote their application number or loan account number in every correspondence with the Company regarding their complaint.
  • Anonymous complaints will not be addressed in terms of this Customer Grievance Redressal Mechanism.

ll. Resolution Process :

  • On receipt of complaint, the Company shall, within reasonable time, send an acknowledgement of the same to the complainant. All the complaints received shall be recorded and subsequently the nature and mode of its resolution also will be tracked and updated.
  • The officer shall ensure that closure of complaints in records is updated post resolution of complaint.
  • The Grievance Redressal Officer shall conduct effective monitoring of the complaint status to ensure that the complaints are resolved within 30 days of receipt of complaint.
  • If any case Company needs additional time, the Company will inform the customer the reasons of delay in resolution within the timelines specified above and provide expected time lines for resolution of the complaint.

III. Escalation Matrix

If a customer is not satisfied with the resolution provided by the Company in the specified period above, the customer can escalate the issue to:

Grievance Redressal Officer & Nodal Officer
Mr. Dheeraj Mittal
Hiranandani Financial Services Private Limited
9 th Floor, Sigma Building, Technology Street,
Hiranandani Business Park, Powai, Mumbai – 400076.
Telephone No.: 022 25763789
Email – dheeraj.mittal@hfs.in

In case a grievance / complaint is not resolved within a period of 30 Days, the customer may further appeal to:

Department of Non-Banking Supervision,
The Reserve Bank of India, Mumbai Regional Office,
3rd Floor, RBI Building, Opposite Mumbai Central Railway Station,
Byculla, Mumbai – 400008.
Telephone No.: 022 2308 4121
Fax No.: 022 2302 2011 
Email – dnbsmro@rbi.org.in

Regional language :
English | Hindi | Gujarati | Marathi | Telugu |Tamil | Kannada

OMBUDSMAN SCHEME
The Reserve Bank – Integrated Ombudsman Scheme, 2021

Salient Features of Ombudsman Scheme :

English | Hindi | Marathi | Gujarati | Telugu | Tamil | Kannada

Address and Area of Operation of Nodal Officers and RBI NBFC Ombudsman :

English | Hindi | Marathi | Gujarati | Telugu | Tamil | Kanada

 
Form of Complaint

Complaint lodging portal of the Ombudsman: https://cms.rbi.org.in

INTEREST RATE POLICY

1. Preface:
The Reserve Bank of India (RBI) vide its Notification No. DNBS. 204 / CGM (ASR)-2009 dated2 January 2009, RBI/2023-24/53 DoR.MCS.REC.28/01.01.001/2023-24 dated August 18,2023 and vide its Guidelines on Fair Practices Code for NBFCs, as amended from time to time(RBI Regulations), has directed all NBFCs to make available the rates of interest and the approach for gradation of risk on web-site of the companies.

In compliance with the requirements of the RBI Regulations mentioned above and the Fair Practices Code adopted by the Company, the Hiranandani Financial Services Private Limited(formerly known as Dobra Finance Private Limited) (“Company/HFS”) has adopted this Interest Rate Policy broadly outlining the Interest Rate Model and the Company’s approach to gradation of risks in its lending business.

2. Interest Rate Model:
The interest rate applicable to each loan account is assessed on a case specific basis, based on evaluation of various factors detailed below:

a. Tenor of the Loan & Payment Terms – term of the loan; terms of payment of interest (viz monthly, quarterly, yearly repayment); terms of repayment of principal; moratorium
period etc.

b. Internal and External Costs of Funds – the rate at which the funds necessary to provide loan facilities to customers are sourced, normally referred to as our external cost of funds.
Internal cost of funds being the expected return on equity.

c. Internal cost loading – the costs of doing business. Factors such as the complexity of the transaction, capital risk weightage, the size of the transaction, location of the borrower
and other factors that affect the costs associated with a particular transaction would be taken into account before arriving at the final interest rate quoted to a customer.

d. Security – Any offering of security by the borrower would be considered while assigning the risk premium for the particular loan account

e. Credit Risk – as a matter of prudence, credit loss (risk) cost would be factored into all transactions. The amount of credit risk cost applicable to a particular transaction depends
on the internal assessment of the credit strength of the customer.

f. Structuring Premium: A premium may be applied to a loan in case the loan has any significant structuring elements with respect to collateral, or other aspects of transaction
structure.

g. Margin: A markup to reflect other costs / overheads to be charged to the loan and our designed margin.

h. ALCO View & Market Dynamics: Views of the Asset Liability Management Committee (ALCO) on product pricing with respect to prevailing interest rates for similar products /
services, market conditions and interest rate outlook shall be taken into consideration.

i. Other Factors – Matching tenor cost, market liquidity, RBI Policies on credit flow, offerings by competition, stability in earnings and employment, subvention and subsidies available, deviations permitted, further business opportunities, external ratings, industry trends,repayment capacity of borrower, etc. Switchover options will also be relevant factors in determining interest rate to be charged.

3. Approach for Gradation of Risk

The risk premium attached with a customer shall be assessed inter-alia based on the following factors:

a) profile and market reputation of the borrower,
b) inherent nature of the product, type / nature of facility, refinance avenues, loan to value of asset financed,
c) tenure of relationship with the borrower group, past repayment track record and historical performance of our similar clients,
d) group strength, overall customer yield, future potential, repayment capacity based on cash flows and other financial commitments of the borrower, mode of payment
e) nature and value of primary and secondary collateral / security,
f) type of asset being financed, end use of the loan represented by the underlying asset,
g) interest, default risk in related business segment,
h) regulatory stipulations, if applicable,
i) possibility of changes in external benchmark rates.
j) any other factors that may be relevant in a particular case.

4. Rate of Interest:

 a) Interest rates offered could be on fixed rate basis or floating rate basis.
 b) In case of floating / variable interest rate, the interest rate will be linked to HFS Benchmark rate “HFSRR”.
 c) The Benchmark rate will be a rate approved by the Asset Liability Committee (ALCO) of
 the Company, from time to time. The Benchmark rates will be reviewed periodically by the ALCO considering the various external benchmark rates. The methodology for
 calculating the HFSRR may be changed at any time with the approval of the ALCO.
 d) The rate of interest for the same product and tenor availed during same period by different customers need not be standardized. The final lending rate applicable to each
 customer will be assessed based on various factors.
 e) Presently, the Company is offering its products at the interest rates not exceeding forty nine percent.
 f) In exceptional circumstances, the Company reserves the right to charge interest rate outside the above indicated range, depending on risk perception and market conditions.
 g) Loan amount, Annualized Rate of Interest and tenure of loan will be communicated to the
 borrower in the sanction letter and the apportionment of instalments towards interest and principal dues shall be made available to the borrower.
 h) Besides normal Interest, the Company may levy additional charges for adhoc facilities, penal charges / default charges for any delay or default by the borrower in servicing of
 the amounts due under the loan. The details of Penal charges for late repayment, schedule of penal charges on non-compliances of loan terms and conditions will be mentioned in
 bold in the loan agreement and will form part of schedule of charges.
 i) Besides interest, other financial charges like processing charges, cheque bouncing charges, pre-payment / foreclosure charges, part disbursement charges, cheque swaps,
 cash handling charges, charges on various other services like issuing NO DUE certificates, NOC, letters ceding charge on assets/ security, security swap & exchange charges etc.
 would be levied by the company wherever considered necessary. In addition, the Goods HFS – Interest Rate Policy – October 25, 2023 Page 4 of 4 and Services Tax and other taxes,   levies or cess would be collected at applicable rates from time to time.
 j) The rate of interest applicable to each customer is subject to change as the situation warrants and is subject to the management’s perceived risk on a case to case basis.
 k) The interest rates can change at any periodicity, depending upon change in market benchmark rates, company’s cost of funds and other market conditions.
 l) Intimation of change of interest or other charges would be communicated to customers in a manner deemed fit, as per terms of the loan documents. Any revision in interest or
 other charges would be with prospective effect.
 m) The interest re-set period for floating rate lending would be decided by the Company from time to time, applying the same decision criteria as considered for fixing of interest   rates.
 n) In the event of change in interest rate, the borrower shall be given an option to enhance the equated monthly instalment or increase the tenor of the loan or a combination of both
 and to prepay, in part or in full, the outstanding loan amount at any point of time.
 o) In case of staggered disbursements, the rates of interest would be subjected to review and the same may vary according to the prevailing rate at the time of successive
 disbursements or as may be decided by the Company.

5. Switchover of floating rate to fixed rate

At the time of reset of interest rates, Company may provide the option to the borrowers to switch over from floating interest rate to fixed interest rate. The option to switchover shall be available with the customer only once during the tenor of the loan.

The Company shall fix the new interest rate in accordance with this policy and further levy switchover and other charges for the same.

6. Quantum of charges

While levying any charges in addition to the applicable interest, the Company shall ensure that –

a) the charges are not capitalised;
b) the charges are reasonable and commensurate with the non-compliance;
c) charges are not discriminatory within a particular loan/product category;
d) charges for individual borrowers are not higher than charges for non-individual borrowers; and
e) no additional component is added to the interest rate, etc.

The Company shall further ensure that the quantum and reason for such charges, as and when
levied, are communicated to the borrower.

7. Content on the website
Appropriate disclosure regarding this Interest Rate Policy shall be made on the Company website.

8. Review
The Policy shall be reviewed on an annual basis or as mandated by the regulatory requirement

SCHEDULE OF CHARGES

Schedule of Fees & Charges

DescriptionFees / Charges
Processing Fees (non-refundable)Upto 4% of the loan amount
Late Payment Penalty2 % per month on overdue amount
Instalment bounce chargeUp to Rs.1000/- per bounce
Annual account statement/Repayment
schedule/ Provisional tax certificate / LOD /
Foreclosure Letter/Welcome Letter
– NIL for one issuance every 12 months
– Subsequent/Duplicate Requests – Rs. 500/- per document
Loan cancellation chargesRs. 5000/- (as cancellation fee)
Further, Interest would be charged for the interim period between
date of loan disbursement and date of loan cancellation and
processing fees paid would be retained)
Document retrieval chargesNil post loan closure, otherwise Rs.1000/- per retrieval
Adhoc statement issuance chargesRs. 500/- per document
Stamp duty and other statutory chargesAs per applicable laws
Penal charges for non-compliance of post
disbursement document conditions or breach
of any other material terms or covenants not
expressly mentioned herein
A) Loan upto Rs. 10 Lakhs – 1% of the loan amount subject to
maximum of Rs. 10,000/-
B) Loan exceeding Rs. 10 Lakhs – 1% of the loan amount subject to
maximum of Rs. 25,000/-
Instalment swap chargeRs. 500/- per instance
Other Documentation chargesRs. 500/-
Instalment due date change feesRs. 1000/- per instance
Part-Prepayment ChargesA. Part-Prepayment before servicing of 12 EMIs is not
allowed
B. Post servicing 12 EMIs
i. Maximum 25% of the Principal outstanding can be paid,
once in every 12 months and
ii. **4% Part-Payment Charges shall be levied on amount
paid
Prepayment/Foreclosure chargesA. Prepayment before servicing of 12 EMIs is not allowed
B. Post servicing 12 EMI’s
Fixed rate loans (Individual & *Non Individual
customer):
Upto 6% of the Principal outstanding
Floating rate loans:
For Individual Customer: **NIL
For Non Individual Customer: Upto 6% of the Principal
outstanding
Switchover Charges (switchover from
floating rate of interest to fixed rate of
interest)

Rs. 10,000/-

Legal collection and incidental charges

At actuals

a. *Non-individual borrower means customers other than individual and includes Sole Proprietorship, HUF, Partnership Firm, Company, LLP, etc. on the loan structure.

b. ** Nil foreclosure /prepayment /part pre-payment charges on floating rate term loan sanctioned for purposes other than business to individuals borrowers.

c. The statement of Fees & Charges is as on the date of disbursement and is subject to changes/revision from time to time and will be updated on the website from time to time (www.hfs.in).

d. All the above Fees & Charges are exclusive of tax and tax will be levied as per applicable tax laws.

e. Any exceptions to the above shall be solely at the discretion of HFS.

Regional language : English | Hindi | Marathi | Gujarati | Tamil | Telugu | Kannada

BENCHMARK RATE

Present Benchmark Rate “HFSRR” is at 20.50%

OTHER DISCLOSURES
Sr. No State Agency Name Address
1 Rajasthan Anjani Associates Plot No. 9/GH/L/10/13, Alkha Nanda Apartment, R.H.B, Pratap Nagar, Sec – 9, Sanganer, Jaipur, Rajasthan, 302033
2 Tamilnadu Ganpat Business Solutions 1st Floor, No.17/21, Puliyur, 2nd Main Road, Trustpuram, Kodambakkam, Chennai, Tamil Nadu- 600024
3 Rajasthan Lakshay associates Office at 407, Unnati Tower, Central Spine Vidhyadhar Nagar Jaipur 302039
4 Karnataka Catch Services #30th, 10th Cross, Brindavan Nagar, Near Mathikere Bus Stop, SBM Colony, Bangalore 560054
5 Andra pradesh and Telengana Hallmark Debt Services Private Limited Second Floor, Flat No 205, Bharat Towers, 5th Lane, Dwarakanagar, Visakhapatnam, Andhra Pradesh- 530016
6 Telangana S. S. Financial Services H.No. 1-3-183/49/9/A/1, Sastry Bhavan, P&T Colony, Gandhi Nagar, Hyderabad-500080
7 Gujarat Chaudhary Enterprise 6th Floor, Shop No E/6, Sar Corporate Centre, Udhana Main Road, Near Krishna Petrol Pump, Khatodara, Surat, Gujarat, 395002
8 Maharashtra Arti Fincorp Office No 110/1st floor, Janki Hari CHS, Phadke Road, Near Ganpati Mandir, Dombivli East – 421201
9 Andhra Pradesh Lasya priya agency 49 – 34 – 4, 2nd floor, 2f -2 opposite Andhra bank Akkayyapalem, Visakhapatnam -530016
  • Credit Rating

Rating Agency

Long- term bank facilities

Short-term bank facilities

Credit Analysis and Research Ltd (CARE)

CARE A, Stable (Single A; Outlook: Stable)

CARE A1 (A One)

Credit Rating Information Services of India Limited (CRISIL)

CRISIL A/Stable

INTERNAL GUIDELINES OFCORPORATE GOVERNANCE
Internal Guidelines of Corporate Governance    View
VIGIL MECHANISM POLICY
Vigil Mechanism Policy    View
Related Party Transaction Policy   Download
POLICY ON APPOINTMENT OF STATUTORY AUDITORY
Policy on Appointment of Statutory Auditors   View
CORPORATE SOCIAL RESPONSIBILITY POLICY
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RETURN OF ORIGINAL PAPERS OF IMMOVABLE PROPERTY
RETURN OF ORIGINAL PAPERS OF IMMOVABLE PROPERTY   View
SECURED ASSETS POSSESSED UNDER SARFAESI ACT
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