Policies

Background

Godrej Housing Finance Limited (“GHF” or “the Company”), as a Housing Finance Company, is required to comply with the ‘Guidelines on Fair Practices Code’ issued by the National Housing Bank (“NHB”). The Company will be required to adopt the ‘Fair Practice Code’ and have grievance redressal mechanism.

Accordingly, it is proposed to adopt Fair Practice Code with the approval of the Board.

Objectives

The objectives of the Fair Practice Code (“the Code”) are:

• To promote good and fair practices by setting minimum standards in dealing with customers
• To increase transparency so that customers can have a better understanding of what they can reasonably expect of the services
• To encourage market forces, through competition, to achieve higher operating standards
• To promote a fair and cordial relationship between customers and Godrej Housing Finance
• To foster confidence in the housing finance system

Approval of the Code

• The Code shall be approved by the Board of Directors.
• Grievance Redressal Committee can at any time, modify or amend the policy only after obtaining approval from MD & CEO. The modification/ amendment to the policy shall be communicated to the Board in its next meeting

Applicability

The Code will apply to the Company and its employees while dealing with its customers, whether they are provided by the company or its subsidiaries across the counter, over the phone, by post, through interactive electronic devices, on the internet or by any other method.

Effective Date

The Code shall be effective from the date of receipt of Certificate of Registration by the Company to carry-on business as a Housing Finance Company.

Review of the Code

• The Code shall be reviewed Annually by the Board of Directors.
• Compliance with Fair Practice Code shall be provided on Annual basis to the Board of Directors
• Half-Yearly report on grievance redressal mechanism to the Board of Directors

The Company will act fairly and reasonably in all dealings with customers, by ensuring that:

• It meets the commitments and standards adopted in the Code for the products and services it offers and in the procedures and practices its employees follow
• Its products and services meet relevant laws and regulations in letter and in spirit
• Its dealings with its customers rest on ethical principles of integrity and transparency 

The Company will transparently disclose to the borrower:

• Fees and charges payable for processing a loan application, amount of fees refundable if loan amount is not sanctioned or disbursed
• Pre-payment options and charges, if any
• Penalty for delayed repayment
• Conversion charges for switching a loan from fixed to floating rate or vice-versa
• Information on interest reset clause, if any, and
• Any other matter which affects the interest of the borrower
• ‘All in cost’ inclusive of all charges involved in processing and sanctioning of a loan application in a transparent manner

NON-DISCRIMINATION POLICY

• The Company will not discriminate between its customers based on gender, physical ability, race or religion. The Company will also not discriminate visually impaired or physically challenged applicants on the ground of disability in extending products, services, facilities, etc. However, this does not preclude the Company from instituting or participating in schemes targeted at different sections of the society.

The Company shall

• Ensure that all advertising & promotional material is clear and not misleading
• In any advertisement, in any media or promotional literature that draws attention to a service or product which includes a reference to interest rates, the Company will also indicate whether other fees or charges will apply and ensure that relevant terms and conditions are made available on request
• Provide information on Interest rates, common fees and charges through any one or more of the following media:
  • Putting up notices at all our branches
  • Through telephone or helplines
  • On the Company’s website, as and when launched
  • Through designated staff or helpdesks
• If the Company avails services of third parties for providing support services, it shall require that such third parties handle customers’ personal information (if any available to such third parties) with the same degree of confidentiality and security as the Company would.
• The Company, from time to time, will communicate to customers, salient features of the products availed by them. Further, the Company may provide information about its other products or promotional offers only if he or she has given his or her consent to receive such information or service either through the application form or the loan agreement or by mail or by registering for the same on the website or on the customer care number.
• Prescribe a Code of Conduct for Direct Selling Agents (DSAs), whose services are availed to market the products of the Company. Such Code of Conduct, amongst other matters, require them to identify themselves when they approach the customer for selling the Company’s products.
• In the event of receipt of any complaint from the customer that the Company’s representative or courier or 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.

APPLICATIONS FOR LOANS AND THEIR PROCESSING

• At the time of sourcing a loan proposal, the Company shall provide information about the applicable interest rates, fees or charges etc. and any other important information which affects the interest of a borrower, so that a meaningful comparison and informed decision can be taken by the borrower
• The Company will issue an acknowledgement receipt for all loan applications. Loan applications shall be disposed of within 21 days or such extended time as may be mutually agreed between the borrower and the Company from the date of receipt of the application form complete in all respects

LOAN APPRAISAL AND TERMS &CONDITIONS

• Normally all details/ documents required for processing the loan application will be collected by the Company at the time of application. If any additional detail/ document is required, the Company will contact the customer again at the earliest possible instance.
• The customer would be informed by means of a written sanction letter of the amount of loan sanctioned or otherwise; all important terms and conditions including Annualized Rate of Interest, method of application of rate of interest, EMI structure, prepayment charges etc. The Company will 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 via email or make it available on the secured customer portal, along with a copy each of all enclosures quoted in the loan agreement to every borrower at the time or after disbursement of loans.

COMMUNICATION OF REJECTION OF LOAN APPLICATION

• If the Company is not in a position to provide a loan to a customer, it shall communicate in writing the reason (s) for rejection

DISBURSEMENT OF LOANS INCLUDING CHANGES IN TERMS AND CONDITIONS

• The Company will disburse the loans in accordance with the disbursement request made by the customer or disbursement conditions mentioned in the loan Agreement or sanction letter
• The Company will give notice to the borrower of any change in the terms and conditions including changes in terms & conditions relating to disbursement schedule, interest rates, service charges, prepayment charges, other applicable fee or charges etc. The Company will also ensure that revisions in rate of interest and charges are implemented only after notification to the customer. A suitable condition in this regard will be incorporated in the loan agreement
• If such change in terms & conditions is to the disadvantage of the customer, he or she may within 60 days and without notice close his or her account or switch the loan account without having to pay any extra charges or interest
• If such change in terms & conditions is to the disadvantage of the customer, he or she may within 60 days and without notice close his or her account or switch the loan account without having to pay any extra charges or interest
• Decision to recall or accelerate payment or performance under the agreement or seeking additional securities, shall be in consonance with the loan agreement
• The Company will release all securities on repayment of all dues or on realization of the outstanding amount of loan subject to any legitimate right or lien for any other claim, the Company may have against borrower. If such right of set off is to be exercised, the borrower shall be given a notice about the same with full particulars about the remaining claims and the conditions under which the Company is entitled to retain the securities till the relevant claim is settled /paid.

GUARANTORS

When a person intends to be a guarantor for a loan, he or she shall be informed about:

• His / her liability as guarantor
• The amount of liability he or she will be committing himself or herself to the Company
• Circumstances in which the Company will call on him or her to pay up the liability
• Whether his or her liabilities as a guarantor are limited to a specific quantum or are they unlimited
• Time and circumstances in which his/ her liabilities as a guarantor will be discharged
• The manner in which the Company will notify him or her about the same
• In case the guarantor refuses to comply with the demand made by the creditor or lender, despite having sufficient means to make the payment of the dues, such guarantor may also be treated as Willful Defaulter at sole discretion of the Company; and
• The Company will keep him or her informed of any material adverse change/s in the financial position of the borrower to whom he/she stands as a guarantor, if it becomes aware of it

SHARING OF INFORMATION

• The Company may provide such information to its group/associate entities or companies for which it has obtained consent/ permission from its customer under loan application/ sanction letter/ loan agreement or through other means
• The Company will treat the personal information of customer even when the customer is no longer a customer as private and confidential. The Company will not reveal the data or information of customer to anyone except as provided above and in the following exceptional cases
  • Putting upRequired by law
  • Duty towards public to reveal information
  • The Company’s interest requires giving information
  • The Company has consent/ permission from the customers
  • The Company’s representatives will inform the customer about his rights/ liabilities under the Laws of India for accessing the personal records that the Company holds about him/her
  • The Company will not use customer’s personal information for marketing purposes unless the customer specifically authorizes us to do so
• If the Company is asked to give a reference about customers by any other bank/ NBFC/ HFC or other entity without any legal/ regulatory obligation, it will obtain his / her written permission before giving it.

CREDIT REFERENCE AGENCIES/ CREDIT INFORMATION COMPANIES

• The Company will share details of the loan and repayment track record of its borrowers to the Credit Information Companies (“CICs”) as per the regulatory directions/ guidelines and the Company’s internal policies.
• The Company will also share information with the Credit Information Companies about the personal debts the customer owes it if:
  • The customer has fallen behind his/ her payments
  • The amount owed is not in dispute
  • The customer has not made proposal following our formal demand for repayment of dues.
• The Company’s representatives will explain to the customers the role of the CICs and the effect the information they provide can have on customer’s ability to get credit.
• The Company will give information about the customer’s account to the CICs in accordance with the statutory/ regulatory requirements.
• The Company will provide relevant information given to the CICs if demanded by the customer.

Any customer with a grievance, complaint or feedback with respect to any of the the products and services offered by Godrej Housing Finance Limited may reach out to the company’s Customer Service Department.

• Call us on 022-68815555 or Email to customercare@godrejhf.com (From Monday to Sunday, 9:00 AM to 6:00 PM)
• Visit the website - www.godrejhf.com
• Write a letter addressed to
  Customer service Team
  Godrej Housing Finance, 3rd Floor, Godrej One
  Pirojshanagar, Vikhroli East,Mumbai, 400079
  Maharashtra, India

HOW SHOULD A COMPLAINT BE MADE?

For accurate and timely resolution, customers are requested to provide all the necessary details like the Customer Relationship Number (CRN), Loan Account Number (LAN), details of the feedback, suggestions, complaint and valid contact Information including phone number & e-mail ID while first contacting with the Company.

HOW SOON SHOULD A CUSTOMER EXPECT A RESPONSE FROM THE COMPANY?

Godrej Housing Finance endeavors to address and respond to all the customers’ requests and complaints within a reasonable time and will keep the customer informed on the status as necessary in the interest of the customer. Since every request and complaint is unique in nature, it may take up to 4 weeks for a thorough resolution, post investigations if any.

WHOM TO APPROACH FOR REDRESSAL?

Customers are requested to first raise their concerns through any of channels mentioned above. In case of delayed or no response from the respective channel within the specified timeline, such complaint may be escalated to the Grievance Redressal Officer of the Company whose details are as given below:

• Name: Aarti Dhurandhar
  E-mail ID.: nodalofficer@godrejhf.com
  Telephone no.: 8657764527
  Address-
  Aarti Dhurandhar
  Godrej Housing Finance
  3rd Floor, Godrej One
  Pirojshanagar, Vikhroli East
  Mumbai, 400079
  Maharashtra, India

ESCALATION TO NATIONAL HOUSING BANK (“NHB”)

In case the customer does not receive a response from the Company within 4 weeks or is dissatisfied with the response received, the customer may approach the Complaint Redressal Cell of NHB by lodging the complaint in the online mode at https://grids.nhbonline.org.in OR in the offline mode by post, in prescribed format available at http://www.nhb.org.in/%20Grievance-Redressal-System/Lodging-Complaint-Against-HFCs-NHB%E2%80%25%2093Physical-Mode.pdf to NHB at the following address:

The Complaint Redressal Cell
Department of Regulation & Supervision
National Housing Bank
4th Floor, Core 5A, India Habitat Centre
Lodhi Road, New Delhi– 110 003

APPLICATIONS FOR LOANS AND THEIR PROCESSING

• The Company, at its sole discretion, may verify the details mentioned by the customer in the loan application by contacting the customer at his/ her residence and/or business addressees through agencies appointed by it.
• The customer is expected to co-operate if the Company needs to investigate a transaction on the customer’s account and with the police/ other investigative agencies, if the Company needs to involve them.
• The customer will be responsible for all losses if such customer acts fraudulently or without reasonable care.
• The Company, generally, will give customers information about our products and services in English. However, if requested by the customer, such information will be provided in Hindi or any other appropriate local language.
• The Company will process requests for transfer of a loan account, either from the borrower or from a bank/financial institution, in the normal course.d
• The Company will make available the Code at every branch and on its website.
• The Company will provide existing and new customers with a copy of the Code, if required by the customer.

Introduction

Godrej Housing Finance Limited (GHF) is a NBFC-Housing Finance Company registered with Reserve Bank of India (RBI) engaged in the business of providing finance solutions to the eligible applicants. For the purpose of acquainting prospective borrowers about its brand, its products and offerings GHF has issued various types and kinds of marketing material.

Applicability

These Terms & Conditions are applicable on all marketing and promotional material (Content) issued by GHF in any form and media, physical or digital or any other, anywhere.

Definition

Content means and includes any material, information, advisory, calculators, FAQs, data or graphs, money market movements, interactive media, marketing material, news items, texts, graphics, links etc., whether belonging to GHF or to its associates, partners and other group entities, which is available either directly or through marketing or Promotional Material of GHF

Consumer refers to the person (s) who is exposed to the Content through any media form or manner. In the document all reference to “You”, “Us”, “Me”, “We” and “I” shall be to Consumer.

Use of Information and Materials

• The Content is provided on an “as is”, “as available” basis and are protected by copyright.
• Consumer is advised to exercise due caution and / or seek independent advice before availing any facility or entering into any financial obligation based on the Content
• Content is designed for informative purposes only; Consumer should also verify the details before making decision
• Decision whether to offer any product or service to the Consumer shall be solely of the GHF
• Final decision with respect to taking any product or service from GHF should be taken by Consumer only post going through Finance Documents
• The Content should not be regarded as an offer, solicitation, invitation, advice or recommendation to buy or sell financial products / schemes of GHF, or any of its group entities
• The full range of products or services may not be available in all locations.
• Periodicity of any offer shall be decided by the GHF and any offer declared may be closed without further notice
• All rates, charges and fees quoted / stated for various financial products and schemes and interest rates cited as examples of rates which may be in effect from time to time are indicative rates only and are subject to change at any time at the sole discretion of GHF; Consumer is advised to refer the Website / branch for latest applicable rate and charges
• Fees and rates may change depending upon the assessment made by GHF in individual cases upon receiving necessary information and documents
• GHF shall be liable and responsible only for the Content which it has issued in its name and in event, the logo, branding name or any other determinative or identifier related to GHF is used by any other entity, with or without GHF permission, for any purpose including for offering any loan through any partnership or otherwise, the Consumer is advised to review the veracity of claim before making any decision. No liability and responsibility shall accrue to GHF.
• Any Content which conflicts with any provision of law or regulation shall be considered to be null and void ab initio
• Adjectives are to be understood in a broader term and not literally
• Easy to understand language has been used for delivery of messages and difficult / industry parlance has been avoided. In case of doubt, please contact branch or contact centre
• You are advised to verify any information / details regarding any project or site including RERA details from the official sources

Intellectual Property

The Content belongs to GHF and cannot be used by Consumer in any manner without prior express written permission of GHF. Hosting of Content on a public forum does not dilute the ownership of GHF.

No Representation or Warranty

No Content shall constitute any representation or warranty by GHF to the Consumer. This Content may contain advice/ opinions and statements of various professionals/ experts/ analysts, etc. Reliance on these statements shall be at the risk of the Consumer. It is the responsibility of the Consumer to independently verify and evaluate the accuracy, completeness, reliability and usefulness of any opinions, services or other information provided on the Content. GHF does not warrant that such information, is complete, free of any errors. GHF may at any time (without being obliged to do so) update, edit, alter and or remove any information in whole or in part that may be available in content and shall not be held responsible for all or any actions that may subsequently result in any loss, damage and or liability. Nothing contained in Content is to be construed as a recommendation to use any product or process, and GHF makes no representation or warranty, express or implied that, the use thereof will not infringe any patent, or otherwise. The user/client is expected to keep abreast of any changes made in this website and the information available on it on a regular basis

Indemnity & Limitation of Liability

As Content is for purely informative purpose and no liability accrues no claim of indemnity shall lie against GHF. GHF, its directors and employees accept no liability and will not be liable for any loss or damage arising directly or indirectly (including special, incidental or consequential, punitive, or exemplary loss, damage or expenses) from your use of content or inability to use by any party, howsoever arising, and including any loss, damage or expense arising from, but not limited to, any defect, error, omission, interruption, imperfection, fault, mistake or inaccuracy with this Content even if the Entities are advised of the possibility of such damages, losses or expenses.

Grievance

In the event you have any grievance towards the Content then you may write at contact@godrejhf.com for its resolution.

Governing Law

This Content shall be governed by and construed in accordance with all applicable laws of India, unless stated otherwise. All disputes arising out of or in connection with this Content shall be submitted to the exclusive jurisdiction of the courts of Mumbai.

Amendments

GHF reserves the right to change the information provided on or via Content, at any time and without notice. GHF shall not be held responsible for all or any actions that may subsequently result in any loss, damage and or liability on account of such change in the information on this Content.

Background

The Prevention of Money Laundering Act, 2002 (“PMLA”) and the Rules notified thereunder impose several obligation on Banks, Non-Banking Financial Companies, Housing Finance Companies (“HFCs”), Chit Fund Company and other defined intermediaries to inter alia verify identity of clients, maintain records and furnish requisite information to Financial Intelligence Unit- India (“FIU-IND”).

As per the circular dated 19th May, 2020 issued by the Reserve Bank of India (“RBI”), the Master Direction- Know Your Customer (KYC) Direction, 2016 prescribed by the RBI (“RBI KYC Master Direction”) for various regulated entities has been made applicable to the Housing Finance Companies (“HFCs”) also and HFCs will now be classified as Regulated Entity (RE) under RBI KYC Master Direction

In accordance with the PMLA and the RBI KYC Master Direction, Godrej Housing Finance Limited (“GHF” or “the Company”), as a Housing Finance Company, has laid down a ‘Know Your Customer (“KYC”) and Anti-Money Laundering (“AML”) Policy’ (“KYC and AML Policy”).

Policy Objective

Key objectives of the KYC and AML Policy are as under:

• To establish regulatorily compliant KYC mechanism to on-board customers;
• To ensure compliance throughout the life-cycle of customers as per the laid down norms
• To prevent the Company’s business channels/ products/ services from being used as a channel for Money Laundering (“ML”)/ Terrorist Financing (“TF’);
• To establish a framework for adopting appropriate AML procedures and controls in the operations/ business processes of the Company;
• To ensure compliance with the laws and regulations in force from time to time;
• To protect the Company’s reputation;
• To lay down KYC-AML compliance norms for the employees of the Company.

Approval and Review of the KYC and AML Policy

• There shall be an annual review of the Policy by the Board of Directors
• Designated Director on recommendation of Principal officer can at any time modify or amend the policy with information to the Board in its next meeting
• Designated Director on recommendation of Principal officer can authorize introduction of subsidiary policies or documents for operationalizing the policy Statutory changes will be read mutatis mutandis in the policy document even if not amended
• Any clause or reference in the policy document which is contrary to or in violation of statutory or regulatory norms shall be deemed to be severed from the policy

Effective Date

The KYC and AML Policy shall be effective from the date of commencement of business by the Company as a Housing Finance Company.

Applicability

All the employees of the Company, while dealing with its customers, will have to ensure adherence with the KYC and AML Policy.

“Aadhaar number” means an identification number issued to an individual under subsection (3) of Section 3 of the Aadhaar (Targeted Delivery of Financial and Other Subsidies, Benefits and Services) Act, 2016 (18 of 2016), and includes any alternative virtual identity generated under sub-section (4) of that section.

Aadhaar Act means Aadhaar (Targeted Delivery of Financial and Other Subsidies Benefits and Services) Act, 2016.

“Authentication”, in the context of Aadhaar authentication, means the process as defined under sub-section (c) of section 2 of the Aadhaar Act.

Beneficial Owner (BO)

• 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 person, has/ have a controlling ownership interest (means ownership of/entitlement to more than 25 per cent of the shares or capital or profits of the company) or who exercise control (right to appoint majority of the directors or to control the management or policy decisions) through other means.
• In case of a partnership firm, the BO 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 capital or profits of the partnership.
• In case of an unincorporated association or body of individuals, the BO 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 entity.

  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.

• In case of a trust, the identification of BO shall include identification of the author of the trust, the trustee, the beneficiaries with 15% 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.

Cash Transaction Report (CTR)- CTR will include the following:

• all cash transactions of the value of more than Rs.10 lakh or its equivalent in foreign currency;
• all series of cash transactions integrally connected to each other which have been individually valued below Rs.10 lakh or its equivalent in foreign currency where such series of transactions have taken place within a month and the monthly aggregate exceeds Rs.10 lakh or its equivalent in foreign currency.

Certified Copy of Officially Valid Document (OVD) shall mean comparing the copy of OVD with the original and recording the same as per the extant law and guidelines / directions

Central KYC Records Registry (CKYCR) means an entity defined under Rule 2(1)(aa) of Prevention of Money-Laundering (Maintenance of Records) Rules, 2005, to receive, store, safeguard and retrieve the KYC records in digital form of a customer.

Counterfeit Currency Transaction Cash transactions where forged or counterfeit Indian currency notes have been used as genuine. These transactions should also include transactions where forgery of valuable security or documents has taken place.

Counterfeit Currency Note Report Quarterly Report on status of receipt of counterfeit note received by any HFC to NHB

Customer means a person who is engaged in a financial transaction or activity with the Company and includes a person on whose behalf the person who is engaged in the transaction or activity, is acting.

Customer Due Diligence (CDD) means identifying and verifying the customer and the beneficial owner.

Designated Director means the Managing Director or a whole-time Director designated by the Board of Directors of the Company to ensure overall compliance with the obligations prescribed by the PMLA and the Rules.

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 authorized officer of the Company as per the provisions contained in the PMLA. The Company will adhere to the applicable requirements in this regard which may be prescribed by the Government/ the Reserve Bank of India (“RBI”) from time to time.

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 client as per rule 9 of the Information Technology (Preservation and Retention of Information by Intermediaries Providing Digital Locker Facilities) Rules, 2016

“FATCA” means Foreign Account Tax Compliance Act of the United States of America (USA) which, inter alia, requires foreign financial institutions to report about financial accounts held by U.S. taxpayers or foreign entities in which U.S. taxpayers hold a substantial ownership interest

Non-face-to-face customers- Customers who open accounts without visiting the branch/ offices of the Company or meeting its officials but will not include customers whose account has been opened as per Video Customer Identification Procedure.

Officially valid document (OVD)- Any document defined as OVD under rule 2(l)(d) of the Prevention of Money-Laundering (Maintenance of Records) Rules, 2005 and the amendments thereto (“PML Rules”) or any document as may be specifically prescribed by the Reserve Bank of India (“RBI”) as per the applicable regulations. Such OVD will be considered valid for verifying identity and proof of address of individual customer/ beneficial owner/ authorized signatory/ power of attorney holder.

Please refer to Annexure 1 for list of OVDs and other documents which are currently considered valid for verifying identity and proof of address of customers.

Offline Verification means the process of verifying the identity of the Aadhaar number holder without authentication, through such offline modes as may be specified by the Aadhaar regulations.

On-going Due Diligence- Regular monitoring of transactions in accounts to ensure that they are consistent with the customers’ profile and source of funds.

Periodic Updation means steps taken to ensure that documents, data or information collected under the CDD process is kept up-to-date and relevant by undertaking reviews of existing records at periodicity prescribed by the RBI or the PMLA and the Rules thereunder.

Politically Exposed Persons (PEPs) are individuals who are or have been entrusted with prominent public functions e.g., Heads of States/ Governments, senior politicians, senior government/ judicial/ military officers, senior executives of state-owned corporations, important political party officials, etc.

Principal Officer (PO)- A senior official designated by the Board of Directors of the Company for overseeing and managing the KYC & AML policies and processes. The PO will be responsible for ensuring compliance, monitoring transactions, and sharing and reporting information as required under the law/regulations.

Suspicious transaction means a “transaction”, including an attempted transaction, whether or not made in cash, which, to a person acting in good faith:

• gives rise to a reasonable ground of suspicion that it may involve the proceeds of crime, regardless of the value involved; or
• appears to be made in circumstances of unusual or unjustified complexity; or
• appears to have no economic rationale or bona fide purpose; or
• gives rise to a reasonable ground of suspicion that it may involve financing of the activities relating to terrorism.

Explanation: Transaction involving financing of the activities relating to terrorism includes transaction involving funds suspected to be linked or related to, or to be used for terrorism, terrorist acts or by a terrorist, terrorist organization or those who finance or are attempting to finance terrorism.

Transaction means a purchase, sale, loan, pledge, gift, transfer, delivery or the arrangement thereof and includes:

• opening of an account;
• deposits, withdrawal, exchange or transfer of funds in whatever currency, whether in cash or by cheque, payment order or other instruments or by electronic or other nonphysical means;
• the use of a safety deposit box or any other form of safe deposit;
• entering into any fiduciary relationship;
• any payment made or received in whole or in part of any contractual or other legal obligation;
• establishing or creating a legal person or legal arrangement.

Video based Customer Identification Process (V-CIP) means 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. V-CIP shall be carried-out by the Company as per the provisions contained in the PMLA and the process defined by the Reserve Bank of India (“RBI”). Such process shall be treated as face-to-face process for the purpose of the KYC and AML Policy.

Compliance of KYC policy

• Senior Management for the purpose of KYC Compliance shall mean Designated Director, Principal Officer and members of Transaction Screening Committee
• Designated Director on recommendation of Principal Officer shall be responsible for setting up the policies
• Principal Officer with support of Transaction screening committee be responsible for overseeing the KYC operations of the Company
• Field Sales, operations and credit team shall be responsible for ensuring that policy is followed
• Internal Audit function will review the KYC operations as mentioned in paragraph 3.4.3 of the Policy
• Quarterly audit notes and compliance shall be submitted to the Audit Committee
• Decision-making functions of determining compliance with KYC norms shall not be outsourced

The KYC and AML Policy has the following 4 key elements:

• Criteria for Customer Acceptance (CAP).
• Risk Management from Money Laundering Risk perspective.
• Customer Identification Procedures (CIP).
• Procedures for monitoring of transactions, as applicable.

CUSTOMER ACCEPTANCE POLICY (CAP) AND CUSTOMER DUE DILIGENCE (CDD)

The Company will adhere to the following criteria for acceptance of customers:

• The Company will not open any account(s) in anonymous, fictitious or 'benami' name(s).
• No account will be opened where the Company is unable to apply required CDD measures, either due to non-cooperation of the customer or non-reliability of the documents/information furnished by the customer
• No transaction or account-based relationship will be undertaken without following appropriate CDD procedure.
• The mandatory information to be sought for KYC purpose while opening an account and during the periodic updation will be specified.
• A Unique Customer Identification Code (UCIC) shall be allotted while entering into new relationships with individual customers
• CDD procedure is being applied at the account level & thus, if an existing KYC compliant customer of GHF desires to open another account with GHF, there shall be no need for a fresh CDD exercise
• Optional or additional information will be obtained with consent of the customer.
• CDD Procedure will be followed for all joint account holders also.
• A customer will be permitted to act on behalf of another person/ entity in accordance with the legal requirements.
• Identity of the customer should not match with any person with known criminal background or with banned entities such as individual terrorists or terrorist organizations, etc. For this purpose, the Company will maintain lists of individuals or entities issued by RBI, United Nations Security Council, UAPA other regulatory & enforcement agencies etc. Details of accounts/ customers bearing resemblance with any of the individuals/ entities in such list shall be treated as suspicious and reported.
• PAN number will be verified from the verification facility of the issuing authority
• 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 will conduct appropriate due diligence. Beneficiary of the relationship/ account shall also be identified.
• The nature and extent of basic due diligence measures to be conducted at the time of establishment of account opening/ relationship, will 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 risks posed by the applicant and the applicant’s expected use of the Company’s products and services from an AML perspective.
• The Company may rely on third party verification subject to the conditions prescribed by the RBI or the PMLA and the Rules thereunder in this regard.
• 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 information collected from customers for the purpose of opening of account shall be treated as confidential and details thereof shall not be divulged for the purpose of cross selling, or for any other purpose without expressed consent of the customer
• Appropriate Enhanced Due Diligence (“EDD”) measures shall be adopted for high risk customers from AML perspective, especially those for whom the sources of funds are not clear and customers who are Politically Exposed Persons (“PEPs”).
• In respect of unusual or suspicious transactions/applications or when the customer moves from a low risk to a high-risk profile, appropriate EDD measures shall be adopted.
• Where the Company is unable to apply appropriate KYC measures due to nonfurnishing 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 the Principal Officer’s level, after giving due notice to the customer explaining the reasons for such a decision.

The aspects mentioned in the CAP would be reckoned while evolving the KYC/AML procedures for various types of customers and products. However, while developing the KYC/CDD procedures, the Company will 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.

RISK MANAGEMENT

The Company will ensure that it has an effective and appropriate KYC procedures. The overall KYC/ AML program will cover proper management oversight, systems and controls, segregation of duties, training and other related matters. Responsibilities will be explicitly allocated within the Company to ensure that the Company’s policies and procedures are implemented effectively.

Risk Categorization

The Company will categorize its customers into low, medium and high-risk category based on the assessment, profiling and perceived money laundering risk. The parameters such as customer’s identity, social/ financial status, nature of business activity, and information about the clients’ business etc. will be considered for the assessment.

Periodic Updation

The Company will conduct periodic updation of KYC documents at least once in every 2 years for high risk customers, once in every 8 years for medium risk customers and once in every 10 years for low risk customers in any of the following manner:

• PAN verification from the verification facility available with the issuing authority
• Authentication, of Aadhaar Number already available with the Company with the explicit consent of the customer in applicable cases.
• In case identification information available with Aadhaar does not contain current address an OVD containing current address may be obtained.
• Certified copy of OVD containing identity and address shall be obtained at the time of periodic updation from individuals except those who are categorised as 'low risk'. In case of low risk customers when there is no change in status with respect to their identities and addresses, a self-certification to that effect shall be obtained.
• In case of Legal entities, the Company should review the documents sought at the time of opening of account and obtain fresh certified copies.
• The Company will not insist on the physical presence of the customer for the purpose of furnishing OVD or furnishing consent for Aadhaar authentication unless there are sufficient reasons that physical presence of the account holder/holders is required to establish their bona-fides. Normally, OVD/ Consent forwarded by the customer through mail/ post, etc., shall be acceptable.
• The Company will provide acknowledgment with date of having performed KYC updation.
• The time limits prescribed above would apply from the date of opening of the account/ last verification of KYC.

Internal Audit and Assurance

To provide reasonable assurance that its KYC and AML procedures are functioning effectively, audit of its KYC and AML processes will also be covered under the scope of Internal Audit of the Company. The audit findings and compliance thereof will be put up before the Audit Committee of the Board till closure of audit findings.

4 Money Laundering (“ML”) and Terrorist Financing (“TF”) Risk Assessment

It is understood that the ML and TF risks for the Company are likely to be low due to the following reasons:

• The Company does not operate in other countries/ geographies;
• The Company does not source/ originate loans from other countries/ geographies and its customer base consists of Indian nationals only;
• The Company extends loans to identified borrowers for which rigorous KYC checks have been put in place
• The company verifies the end-use of the loan
• The Company does not offer banking, liabilities and insurance products; and
• The Company offers loans/ credit facilities with defined end-use

However, in accordance with the regulatory requirements, the Company will carry out ML and TF Risk Assessment exercise periodically to identify, assess and take effective measures to mitigate money laundering and terrorist financing risk to which the Company may be exposed to. Such internal risk assessment should be commensurate to its size, geographical presence, complexity of activities/ structure, etc.

Such assessment process will consider various relevant risk factors and will take cognizance overall sector-specific vulnerabilities, if any, that the regulator/supervisor may share. Accordingly, it will frame its mitigation plan also. It should involve the relevant functions and have the following stages:

• Identification- Development of list of potential risks or risk factors drawn from known/ suspected threats or vulnerabilities. For this purpose, various important aspects of the KYC Policy (non-compliance of which may pose threat to the Company) will be identified along with the risks which the Company may be exposed to due to the same.
• Analysis- Implementation of key requirements under the KYC Policy should be analyzed. This stage should analyse the likelihood and the impact of each of the identified risks. It will help in assigning priority/ importance to each of the risks.
• Evaluation- It should involve taking the results found during the analysis process to determine priorities for addressing the risks. These priorities should contribute to development of a strategy for their mitigation. A typical Risk Evaluation matrix would be as under

The Company shall conduct the ML and TF Risk Assessment at least once in a year. The outcome of the ML and TF Risk Assessment will be put up to the Audit Committee.

CUSTOMER IDENTIFICATION

The Company shall undertake identification of customers in the following cases:

• Commencement of an account-based relationship with a customer.
• When there is a doubt about the authenticity or adequacy of the customer identification data it has obtained.
• Selling third party products as agents, selling their own products or any other product for more than rupees fifty thousand.
• Carrying out transactions for a non-account-based customer where the amount involved is equal to or exceeds Rs.50,000/-, whether conducted as a single transaction or several transactions that appear to be connected.
• When it has reason to believe that a customer is intentionally structuring a transaction into a series of transactions below the threshold of Rs.50,000/-.

Reliance on customer due diligence done by third party

For the purpose of verifying the identity of customers at the time of commencement of an account-based relationship, the Company, may at their option, rely on customer due diligence done by a domestic third party, subject to the following conditions:

• Records or the information of the customer due diligence carried out by the third party is obtained within two days from the third party or from the Central KYC Records Registry;
• 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;
• 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 PMLA;
• The third party shall not be based in a country or jurisdiction assessed as high risk and
• The ultimate responsibility for customer due diligence and undertaking enhanced due diligence measures, as applicable, will be with the Company.

CUSTOMER DUE DILIGENCE (CDD) PROCEDURES

The Company will ensure compliance with the regulatory/ statutory requirements with respect to the Customer Identification Procedure to be carried out at different stages, i.e. while establishing a relationship; carrying out a financial transaction or when the Company has a doubt about the authenticity/veracity or the adequacy of the previously obtained customer identification data.

Customer identification means identifying the customer and verifying his/ her identity by using reliable, independent source documents, data or information. The Company will obtain sufficient information necessary to establish, the identity of each new customer, whether regular or occasional and the purpose of the intended nature of relationship.

CDD Procedure in case of Individuals

Documents/ Information to be collected

From an individual (who is prospective customer OR a Beneficial Owner/ Authorised Signatory/ Power of Attorney Holder related to any legal entity) the following documents/ information will be obtained:

• Recent photograph;
• Certified copy of Permanent Account Number (PAN) OR the equivalent e-document thereof;
• Certified copy of one of the OVDs as defined above to be taken for verification of the identity and the address OR the equivalent e-document thereof; and
• Other document including in respect of the nature of business and financial status of the client OR the equivalent e-document thereof, as may be required by the Company.

Note:

• If PAN is not availed then Form No. 60 as defined in Income-tax Rules, 1962 may be taken;
• Aadhaar Offline Verification- The Company, being a non-bank, may carry out offline verification of a customer if he is desirous of undergoing Aadhaar offline verification for identification purpose. However, where its customer submits his Aadhaar number, the Company will ensure such customer to redact or blackout his Aadhaar number through appropriate means where the authentication of Aadhaar number is not required under section 7 of the Aadhaar Act.
• Authentication using e-KYC authentication facility provided by the UIDAI- As and when the Company is authorized to conduct authorization through e-KYC authentication facility provided by the UIDAI, it may conduct such authorization and use the e-KYC facility in accordance with the conditions prescribed under the PMLA/ the Aadhaar Act/ the KYC & AML Guidelines.
• If the customer provides an equivalent e-document of any OVD, the Company should verify the digital signature as per the provisions of the Information Technology Act, 2000 (21 of 2000) and any rules issues thereunder and take a live photo as specified under Digital KYC Process defined below (at sub-para 3.5.1.3).

  The Company may also carry-out KYC verification under Digital KYC Process defined below (at sub-para 3.5.1.3).

Video based Customer Identification Process (“V-CIP”)

The Company may undertake live V-CIP, to be carried out by an official of the Company, for establishment of an account-based relationship with an individual customer, after obtaining his informed consent.

The Company, if implements V-CIP, will adhere to the following requirements:

• The official of the Company performing the V-CIP should record video as well as capture photograph of the customer present for identification and carry out Offline Verification of Aadhaar for identification.
• Should capture a clear image of PAN card to be displayed by the customer during the process, except in cases where e-PAN is provided by the customer. The PAN details should be verified from the database of the issuing authority.
• Live location of the customer (Geotagging) should be captured to ensure that customer is physically present in India.
• The official should check that photograph of the customer in the Aadhaar/PAN details matches with the customer undertaking the V-CIP and the identification details in Aadhaar/PAN match with the details provided by the customer.
• The sequence and/or type of questions during video interactions should be varied in order to establish that the interactions are real-time and not pre-recorded.
• In case of offline verification of Aadhaar using XML file or Aadhaar Secure QR Code, it should be ensured that the XML file or QR code generation date is not older than 3 days from the date of carrying out V-CIP.
• All accounts opened through V-CIP shall be made operational only after being subject to concurrent audit, to ensure the integrity of process.
• It will be ensured that the process is a seamless, real-time, secured; and end-to-end encrypted audiovisual interaction with the customer and the quality of the communication is adequate to allow identification of the customer beyond doubt. The Company will carry out the liveliness check in order to guard against spoofing and such other fraudulent manipulations
• To ensure security, robustness and end to end encryption, the Company will carry out software and security audit and validation of the V-CIP application before rolling it out.
• The audiovisual interaction should be triggered from the domain of the Company itself. The V-CIP process should be operated by officials specifically trained for this purpose. The activity log along with the credentials of the official performing the V-CIP should be preserved.
• The Company should ensure that the video recording is stored in a safe and secure manner and bears the date and time stamp.
• The Company will endeavor to take assistance of the latest available technology, including Artificial Intelligence (AI) and face matching technologies, to ensure the integrity of the process as well as the information furnished by the customer.
• The Company should ensure to redact or blackout the Aadhaar number

Digital KYC Process

In case Digital KYC Process is adopted by the Company, it will ensure compliance with the following requirements:

• It will use an Application to be made available at customer touch points for undertaking KYC of their customers and the KYC process shall be undertaken only through this authenticated Application of the Company.
• The access of such Application should be controlled by the authorized persons of the Company. The Application shall be accessed only through login-id and password or Live OTP or Time OTP controlled mechanism defined by the Company.
• The customer, for the purpose of KYC, shall visit the location of the Authorized Official of the Company (“Authorized Official”) vice-versa. The original OVD should be in possession of the customer.
• It should be ensured that the Live photograph of the customer is taken by the Authorized Official and the same photograph is embedded in the Customer Application Form (CAF). Further, a water-mark in readable form having CAF number, GPS coordinates, Authorized Official’s name, unique employee Code (assigned by REs) and Date (DD:MM:YYYY) and time stamp (HH:MM:SS) should be put on the captured live photograph of the customer.
• The Application should have the feature that only live photograph of the customer is captured and no printed or video-graphed photograph of the customer is captured. The background behind the customer while capturing live photograph should be of white colour and no other person shall come into the frame while capturing the live photograph of the customer.
• The live photograph of the original OVD or proof of possession of Aadhaar (where offline verification cannot be carried out), placed horizontally, shall be captured vertically from above and water-marking in readable form as mentioned above shall be done. No skew or tilt in the mobile device should be there while capturing the live photograph of the original documents.
• The live photograph of the customer and his original documents shall be captured in proper light so that they are clearly.
• Thereafter, all the entries in the CAF should be filled as per the documents and information furnished by the customer. In those documents where Quick Response (QR) code is available, such details can be auto-populated by scanning the QR code instead of manual filing the details. For example, in case of physical Aadhaar/eAadhaar downloaded from UIDAI where QR code is available, the details like name, gender, date of birth and address can be auto-populated by scanning the QR available on Aadhaar/e-Aadhaar.
• Once the above-mentioned process is completed, a One Time Password (OTP) message containing the text that ‘Please verify the details filled in form before sharing OTP’ shall be sent to customer’s own mobile number. Upon successful validation of the OTP, it will be treated as customer signature on CAF. However, if the customer does not have his/her own mobile number, then mobile number of his/her family/relatives/known persons may be used for this purpose and be clearly mentioned in CAF. In any case, the mobile number of the Authorized Official should not be used for customer signature. The Company will check that the mobile number used in customer signature shall not be the mobile number of the Authorized Official.
• The Authorized Official should provide a declaration about the capturing of the live photograph of customer and the original document. For this purpose, the authorized official shall be verified with One Time Password (OTP) which will be sent to his official mobile number. Upon successful OTP validation, it shall be treated as the Authorized Official’s signature on the declaration. The live photograph of the Authorized Official shall also be captured in this authorized officer’s declaration.
• Subsequent to all these activities, the Application should give information about the completion of the process and submission of activation request to activation officer of the Company, and also generate the transaction-id/reference-id number of the process. The Authorized Official shall intimate the details regarding transaction-id/reference-id number to customer for future reference.
• The Authorized Official should check and verify that: (i) information available in the picture of document is matching with the information entered by the Authorized Official in CAF. (ii) live photograph of the customer matches with the photo available in the document.; and (iii) all of the necessary details in CAF including mandatory field are filled properly.
• On Successful verification, the CAF shall be digitally signed by the Authorized Official who will take a print of CAF, get signatures/thumb-impression of customer at appropriate place, then scan and upload the same in system. Original hard copy may be returned to the customer.

Simplified procedure for opening accounts of Individuals

In case a person who desires to open an account is not able to produce any of the OVDs, the Company may at its discretion open accounts subject to the following conditions:

• The Company shall obtain a self-attested photograph from the customer
• The authorized officer of the Company should certify under his signature that the person opening the account has affixed his signature or thumb impression in his presence.
• The account shall remain operational initially for a period of 12 months, within which CDD as prescribed above should be carried out.
• Balances in all their accounts taken together shall not exceed Rs.50,000/- at any point of time.
• The total credit in all the accounts taken together shall not exceed Rs.1,00,000/- in a year.
• The customer shall be made aware that no further transactions will be permitted until the full KYC procedure is completed in case Directions (d) and (e) above are breached by him.
• When the balance reaches Rs.40,000/- or the total credit in a year reaches Rs.80,000/- , The customer shall be notified that appropriate documents for conducting the KYC must be submitted otherwise the operations in the account shall be stopped when the total balance in all the accounts taken together exceeds the limits prescribed in direction (d) and (e) above.

CDD Measures for Legal Entities

For due diligence with respect to legal entities, the Company will obtain the documents as listed in the Annexure 1.

Identification of Beneficial Owner

For opening an account of an entity who is not a natural person, the beneficial owner(s) (as defined above) shall be identified and all reasonable steps to verify his/her identity shall be undertaken. While doing so, the Company will keep the following in view:

• Where the customer or the owner of the controlling interest is a company listed on a stock exchange, or is a subsidiary of such a company, it is not necessary to identify and verify the identity of any shareholder or beneficial owner of such companies.
• In cases of trust/ nominee or fiduciary accounts, where it is determined that the customer is acting on behalf of another person as trustee/ nominee or so, identity of the intermediaries and of the persons on whose behalf he is acting, as also details of the nature of the trust or other arrangements in place will be obtained.

ENHANCED DUE DILIGENCE (EDD) PROCEDURES

Accounts of non-face-to-face customers: The Company will ensure the first payment is done through any of the KYC Compliant account through banking channels

Accounts of Politically Exposed Persons (PEPs): If the Company decides to establish a business relationship with PEPs, it will ensure the following:

• sufficient information including information about the sources of funds of PEPs is gathered;
• the identity of the person shall have been verified before accepting the PEP as a customer
• the decision to open an account for a PEP is taken at a senior level in accordance with the Company’s procedures;
• all such accounts will be classified as High Risk and will be subjected to required due diligence and monitoring, as applicable;
• if it gets confirmed to the Company that an existing customer or the beneficial owner of an existing account has subsequently become a PEP, an approval from a senior official of the Company will be obtained to continue the business relationship;
• further, such existing accounts which get classified PEPs subsequently will be subjected to enhanced due diligence, as applicable.

The above will also be applicable to accounts where a PEP is the beneficial owner.

MONITORING OF TRANSACTIONS/ ON-GOING DUE DILIGENCE

Ongoing monitoring is an essential element of effective KYC procedures. The Company can effectively control and reduce its risk only if it has an understanding of the normal and reasonable activity of the customer so that it can identify transactions that fall outside the regular pattern. The Company will put in place a process to identify and review complex and unusual transactions/ patterns which have no apparent economic or visible lawful purpose, or transactions that involve large amounts of cash or are inconsistent with the normal and expected activity of the customer.

APPOINTMENT OF THE DESIGNATED DIRECTOR AND THE PRINCIPAL OFFICER

• Designated Director- The Company will nominate a “Designated Director” to ensure compliance with the obligations prescribed by the PMLA and the Rules thereunder.
• Principal Officer- The Company will designate one of its senior officials as the ‘Principal Officer' who will be responsible for ensuring compliance, monitoring transactions, and sharing and reporting information as required under the law/ regulations.

The name, designation and address of Designated Director and Principal Officer shall be communicated to FIU-Ind.

REPORTING THE FINANCIAL INTELLIGENCE UNIT-INDIA (FIU-IND)

In accordance with the requirements under the PMLA, the Company will furnish the following reports, as and when required, to the Director, Financial Intelligence Unit-India (FIU-IND):

• Cash Transaction Report (CTR)- If any such transactions detected, Cash Transaction Report (CTR) for each month by 15th of the succeeding month.
• Counterfeit Currency Report (CCR)- All such cash transactions where forged or counterfeit Indian currency notes have been used as genuine as Counterfeit Currency Report (CCR) for each month by 15th of the succeeding month.

  Additionally, the Company will submit ‘Statement showing the details of Counterfeit Banknotes detected’ to the NHB within 7 days from the last day of the respective quarter. Even in case of ‘Nil’ instance also, the statement is to be submitted to the NHB

• Suspicious Transactions Reporting (STR)- The Company will monitor transactions to identify potentially suspicious activity. Such triggers will be investigated, and any suspicious activity will be reported to 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. However, in accordance with the regulatory requirements, the Company will not put any restriction on operations in the accounts where an STR has been filed.

The Company will maintain confidentiality in investigating suspicious activities and while reporting CTR/ CCR/ STR to the FIU-IND/ higher authorities. 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 govt. authorities etc.

RECORD MANAGEMENT

• Record-keeping requirements- The Company shall ensure maintenance of proper record of transactions required under PMLA as mentioned below:
  • maintain all necessary records of transactions between the RE and the customer, both domestic and international, for at least five years from the date of transaction;
  • preserve the records pertaining to the identification of the customers and their addresses obtained while opening the account and during the course of business relationship, for at least five years after the business relationship is ended;
  • make available the identification records and transaction data to the competent authorities upon request;
  • 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);
  • all cash transactions of the value of more than Rs.10 lakh or its equivalent in foreign currency;
  • all series of cash transactions integrally connected to each other which have been individually valued below Rs.10 lakh or its equivalent in foreign currency where such series of transactions have taken place within a month and the monthly aggregate exceeds Rs.10 lakh or its equivalent in foreign currency;
  • 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;
  • all suspicious transactions whether or not made in cash; and
  • records pertaining to identification of the customer and his/her address; and
  • should allow data to be retrieved easily and quickly whenever required or when requested by the competent authorities.
• The records should contain the following information:
  • the nature of the transactions;
  • the amount of the transaction and the currency in which it was denominated;
  • the date on which the transaction was conducted; and
  • the parties to the transaction.
• Maintenance and Preservation of records- The Company will:
  • maintain all necessary records of transactions between it and the customer, both domestic and international, for at least five years from the date of transaction.
  • preserve the records pertaining to the identification of the customers and their addresses obtained while opening the account and during the course of business relationship, for at least five years after the business relationship is ended.
  • maintain and preserve the following records for the required time-period as prescribed under the PMLA, either in hard or soft format:
    • all necessary records of transactions referred above; which will permit reconstruction of individual transactions so as to provide, if necessary, evidence for prosecution of persons involved in criminal activity;
    • records pertaining to the identification of the customer and his address obtained while opening the account and during the course of business relationship.
  • make available the identification records and transaction data to the competent authorities upon request.
  • 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).

SELLING THIRD PARTY PRODUCTS

The Company, if acting as agents while selling third party products as per regulations in force from time to time, will comply with the following aspects:

• The identity and address of the walk-in customer shall be verified for the transactions as required under the CIP prescribed above;
• Transaction details of sale of third-party products and related records shall be maintained.
• Monitoring of transactions for any suspicious activity will be done.

QUOTING OF PAN

Permanent account number (PAN) of customers shall be obtained and verified while undertaking transactions as per the provisions of Income Tax Rule 114B as amended from time to time. Form 60 shall be obtained from persons who do not have PAN.

CUSTOMER EDUCATION

Seeking of certain KYC information from customers can sometimes lead to queries from the customer as to the motive and purpose of collecting such information. In this regard, the Company will take appropriate steps to educate customers on the objectives of the KYC measures.

HIRING OF EMPLOYEES AND EMPLOYEE TRAINING

• Adequate screening mechanism as an integral part of their personnel recruitment/hiring process shall be put in place.
• On-going employee training programme shall be put in place so that the members of staff are adequately trained in the KYC Policy. The focus of the training will be different for frontline staff, compliance staff and staff dealing with new customers.

ADHERENCE TO THE KYC AND AML GUIDELINES BY THE COMPANY’S AGENTS

• The Company’s agents or persons authorized by it, for the its business, will be required to be compliant with the applicable KYC & AML Guidelines.
• All requisite information shall be made available to the RBI/ National Housing Bank to verify the compliance with the applicable KYC & AML Guidelines.
• The books of accounts of persons authorized by the Company including agents etc., so far as they relate to business of the company, shall be made available for audit and inspection whenever required.

SHARING KYC INFORMATION WITH CENTRAL KYC RECORDS REGISTRY (CKYCR)

The Company will capture the KYC information/ details as the KYC templates and share the same with the CKYCR in the manner as prescribed in the Prevention of Money Laundering (Maintenance of Records) Rules, 2005.

REPORTING REQUIREMENT UNDER FOREIGN ACCOUNT TAX COMPLIANCE ACT (FATCA) AND COMMON REPORTING STANDARDS (CRS)

The Company, if applicable, will adhere to the provisions of Income Tax Rules 114F, 114G and 114H. If the Company becomes a Reporting Financial Institution as defined in Income Tax Rule 114F, it will take requisite steps for complying with the reporting requirements in this regard.

Compliance with Section 51A of Unlawful Activities (Prevention) Act, 1967

The company will ensure compliance with Section 51A of UAPA Act, 1987 by screening the prospective and existing account holders for UN Sanction List or any other list as per UAPA Act, 1987. In event, any account holder resembles the name of as per the list it will be reported to FIU-IND and Ministry of Home Affairs. Further, other requirement including freezing of assets shall be followed by company.

Secrecy Obligations and Sharing of Information

Company shall maintain confidentiality of information as provided in Section 45NB of RBI Act 1934.

List of Documents considered valid for verifying identity and proof of address of prospective customers

Charge Description		CHARGE AMOUNT EXCLUSIVE OF GST IN INR
Processing Fees		Mortgage loan up to 2% of the loan amount, Flexible loan up to 3% of the loan amount
1st Presentation EMI Bounce every month		1000
2nd Presentation EMI Bounce every month		1000
Late Payment Penalty per Month		2% of the total EMI outstanding (principal + interest)
Repayment Mode (Cheque / NACH) Swap		500
Foreclosure and Part Pre-payment charges
Type of Borrower	Type of Loan	Type of ROI	Applicability
Individual	(a) Housing Loans, (b) Per- sonal Loans, (c) LAP other than Business purpose	Floating, Semi-fixed (during the period ROI is floating)	NIL
	LAP Business	Floating, Fixed & Semi-fixed (during the period ROI is Fixed)	Balance Takeover from a bank/ HFC/ NBFC/ any other Financial Institution – 4% for foreclosure on Principal pre-paid
			Self-source – 4% for foreclo- sure on Principal pre-paid on all amounts prepaid over 20% of the loan amount in the financial year
Non-Individual	Any	Any	4% on principal pre-paid
Loan cancellation charges		Nil up to 30 calendar days or the 1st EMI due date, whichever is earlier. Post that 1% of principal outstanding.
Physical Statement of Account		500
Physical Duplicate NOC		500
Physical Repayment Schedule		500
List of Documents		1000
EMI Pick Up		500
Physical copy of Property Documents		2000
Charges to issue Loan Foreclosure Letter		500
Conversion or Switch Charges (Floating to Fixed or Fixed to Floating)		0.5% to 1.5% of the principal outstanding
Repricing Fee		1% of the Principal Outstanding
Document Retreival (Per Retreival)		500
Stamping or Franking		On Actuals
Bank charges on cheque / ECS / NACH bounce		On Actuals as charged by customer’s bank
Charges towards Legal/ SARFAESI/ Recovery action		On Actuals
Charges to be paid to CERSAI/ CKYCR		As applicable and prescribed by CERSAI/ CKYCR
Demand draft or pay order re-issuance or cancellation		750
Other Documents		500
Property Documents Holding Fee (Charged per month post 60 days from date of loan closure)		750
Miscellaneous Charges		On Actuals
Technical Fees (For additional Property)		On Actuals
Valuation Fees (In Construction Linked Loans)		On Actuals
Charges towards Stamp Duty / Registration / Intimation of Mortgage / Creation of Mortgage		As Applicable & Prescribed by the relevant Government Authority

Any customer with a grievance, complaint or feedback with respect to any of the the products and services offered by Godrej Housing Finance Limited may reach out to the company’s Customer Service Department.

• Call us on 022-68815555 or Email to customercare@godrejhf.com (From Monday to Sunday, 9:00 AM to 6:00 PM)
• Visit the website - www.godrejhf.com
• Write a letter addressed to
  Customer service Team
  Godrej Housing Finance, 3rd Floor, Godrej One
  Pirojshanagar, Vikhroli East,Mumbai, 400079
  Maharashtra, India

HOW SHOULD A COMPLAINT BE MADE?

For accurate and timely resolution, customers are requested to provide all the necessary details like the Customer Relationship Number (CRN), Loan Account Number (LAN), details of the feedback, suggestions, complaint and valid contact Information including phone number & e-mail ID while first contacting with the Company.

HOW SOON SHOULD A CUSTOMER EXPECT A RESPONSE FROM THE COMPANY?

Godrej Housing Finance endeavors to address and respond to all the customers’ requests and complaints within a reasonable time and will keep the customer informed on the status as necessary in the interest of the customer. Since every request and complaint is unique in nature, it may take up to 4 weeks for a thorough resolution, post investigations if any.

WHOM TO APPROACH FOR REDRESSAL?

Customers are requested to first raise their concerns through any of channels mentioned above. In case of delayed or no response from the respective channel within the specified timeline, such complaint may be escalated to the Grievance Redressal Officer of the Company whose details are as given below:

• Name: Aarti Dhurandhar
  E-mail ID.: nodalofficer@godrejhf.com
  Telephone no.: 8657764527
  Address-
  Aarti Dhurandhar
  Godrej Housing Finance
  3rd Floor, Godrej One
  Pirojshanagar, Vikhroli East
  Mumbai, 400079
  Maharashtra, India

ESCALATION TO NATIONAL HOUSING BANK (“NHB”)

In case the customer does not receive a response from the Company within 4 weeks or is dissatisfied with the response received, the customer may approach the Complaint Redressal Cell of NHB by lodging the complaint in the online mode at https://grids.nhbonline.org.in OR in the offline mode by post, in prescribed format available at https://nhb.org.in/Grievance-Redressal-System/Lodging-Complaint-Against%20HFCs-NHB%20%83yr%20Physical-Mode.pdf to NHB at the following address:

The Complaint Redressal Cell
Department of Regulation & Supervision
National Housing Bank
4th Floor, Core 5A, India Habitat Centre
Lodhi Road, New Delhi– 110 003

Loan Account No.
Sanctioned Loan Amount
Type of Loan
Purpose of Loan

Type of Rate of Interest (”ROI”)
check_box_outline_blank Fixed Rate of Interest (”ROI”)	_________________ % per annum interest shall be payable by the Borrower at monthly rests or as per the terms & conditions mentioned in the Loan Agreement
check_box_outline_blank Floating / Varibale Rate of Interest (”ROI”)	_________________ % per annum Godrej Housing Finance Prime Lending Rate (“GHFPLR”) (as on date) + / - ________________ % per annum Spread _________________ % per annum Applicable Rate of interest
check_box_outline_blank Semi Fixed Rate of Interest (“ROI”)	_________________ % per annum interest shall be payable by the Borrower at monthly rests or as per the terms & conditions mentioned in the Loan Agreement for_______________ months. + / - ________________ % per annum Spread ____________ % per annum applicable “ROI” from ___________ month onwards.
Subsidy (if applicable)	Eligibility to any subsidy program shall be as per its prescribed eligibility criteria. The application shall be forwarded to competent authority only in case it meets the criteria. Company cannot assure receipt of subsidy as decision rests with competent authority.
Moratorium (if applicable)	Borrower may be offered moratorium on the loan subject to its qualification to company’s internal policy & under specific product terms. Under moratorium, borrower will not be making any payment for moratorium tenure and interest will not be due but shall be capitalized and added to principal. Post expiry of moratorium borrower shall make payment as per the repayment schedule.
Date of reset of Rate of Interest	The applicable rate of interest on the loan will be revised/ reset with the change in the GHFPLR. Any change in GHFPLR will be notified to the Borrower in the mode and manner as mentioned below in section Notice / Communication relating to Rate of Interest, Fee & Charges.

Loan Tenor (Total Number of EMIs to be paid)	______________ Months subject to change in case of Floating/ Semi-Fixed Rate of interest
Instalment Type	Monthly
EMI/ PEMII (as on date)	Rs. _____________________ (subject to change in case of Floating Rate of interest or Type of Repayment Plan).
Repayment Plan - Moratorium Period	__________________ months
EMI Break Months (If applicable)	EMI break, subject to qualification to specific credit norms and satisfactory repayment performance by the borrower in sole opinion of lender, for specific pre-agreed months wherein there will be an increase in EMI for all tenure but the customer need not pay EMI for specified months. For more details refer the amortization schedule

Date of Commencement of PEMII	Basis final disbursement date Before 15th of the month – starts next month onwards Post 15th of the month – starts second month onwardss
Date of Commencement of EMI	EMI start date depends on the projection completion date, loan structure and product features. For more details refer the amortization schedule.
Due Date for payment of EMI/ PEMII	check_box_outline_blank 3rd of the month check_box_outline_blank 6th of the month
In case of any change/revision in applicable Rate of Interest, the Company, at its sole discretion, may revise the EMIs or tenor of the loan or both and inform the customer through prescribed mode. Accordingly fresh ECS /NACH mandate, if required, will have to be provided by the Borrower for revised EMIs. In case of partially disbursed cases, Pre Equated Monthly Instalment Interest (PEMII) may be required to be paid on monthly basis on the due date. PEMII will be charged from the date of the first disbursements to the date of commencement of EMI. In case of delayed payment, overdue interest for the delayed period will be charged at rates mentioned by the Company from time to time. The above terms are subject to change as per market movement or company policy which are explained in detail in loan agreement
Annual Outstanding Balance Statement	To be issued within 30 Days of closure of financial year

Obtaining insurance is not mandatory and neither linked to the Loan. However in order to safeguard the interests of the dependents in the event of untimely death of borrower or in event of damage to the property, the company facilitates obtaining of a life insurance policy for securing loan amount & property insurance for the collateral. Brief details of it are as below:

Company facilitates insurance from an IRDA registered insurance company with whom it has a Master Policy. Policy will be issued as subject to the terms and conditions set out by the Insurer.In the event of death / damage to property the proceeds will be first used for extinguishing loan liability post which the sum, if any, shall be transferred to heirs / borrowers.

Company makes no warranty or representation about the insurance company or product & all guidelines issued by the Insurere on claims, policy, surrender among others will be applicable.

Any grievance related to insurance is to be taken up with insurance company

Taking insurance policy is not linked with obtaining loan.

Procedure for intimation of the changes in Rate of Interest/ EMI or applicable charges

Any revision in rate of interest or fee/ charges by the Company shall be notified through any one or more of the following media and shall be construed as full notice to the customer: Letter on the last known address; E-mail on the registered E-mail ID; SMS/ telephone/ electronic message on the registered mobile no.; Notice at the Company’s branches; Notice on the Company's website.

Mortgage of below mentioned property in favour of the Company

Details of the Property Mortgaged:_________

Other Security:_____________

Detail of Guarantor(s) :________

Any other security as per Sanction Letter :

Charge Description	Charge Amount (in INR) Exclusive of GST
1st presentation EMI Bounce every month	1000
2nd presentation EMI Bounce every month	1000
Late Payment/ penalty (Per month)	2% on the total EMI outstanding (principal and interest)
Repayment mode - Cheque/NACH Swap	500
Foreclosure and Part prepayment	INDIVIDUAL BORROWER Floating Rate Loans 0% Fixed Rate Loans 0% for own source foreclosure. 4% for foreclosure by borrowing from a bank/ HFC/ NBFC/ a Financial Institution, on the Principal outstanding & all amounts prepaid over 20% of the loan amount in the financial year NON-INDIVIDUAL BORROWER Fixed & Floating Rate Loans 4% of the Principal prepaid
Loan cancellation charges	Nil up to 30 calendar days or the 1st EMI due date, whichever is earlier. Post that 1% of principal outstanding.
Physical Statement of Account	500
Physical Duplicate NOC	500
Physical Repayment Schedule	500
List of Documents	1000
EMI Pick up	500
Physical copy of Property documents	2000
Charges to issue Loan Foreclosure letter	500
Conversion or Switch ((Floating to FIxed Rate or vice-versa)	0.5% to 1.5% of the Principal Outstanding
Repricing Fee	1% of the Principal Outstanding
Document retrieval (per retrieval)	500
Stamping or Franking	As per Actuals
Bank charges on cheque / ECS / NACH bounce	On actuals charged by the customer’s bank
Charges towards Legal/ SARFAESI/ Recovery action	As per actuals
Charges to be paid to CERSAI/ CKYCR	As applicable and prescribed by CERSAI/ CKYCR
Demand draft or pay order re-issuance or cancellation	750
Other documents	500
Property documents holding fee – (charged per month post 60 days from the date of loan closure)	750
Miscellaneous charges	On actuals
Technical fees (for additional property)	On actuals
Valuation fee in Construction linked loan cases	On actuals
Charges towards Stamp Duty/ Registration/ Intimation of mortgage/ Creation of Mortgage	As applicable and prescribed by the relevant Government Authority

Clear, marketable title of the property in favour of the borrower A valid mortgage (equitable or registered) to be created in favour of the Company as per the Company’s legal requirements; Execution/ Submission of all documents as mentioned by the Company in the Sanction Letter/ Loan Agreement; Any other condition mentioned in the Sanction Letter/ Loan Agreement.

Any Special Condition: As per the Sanction Letter/ Loan Agreement, if any

The Borrower is expected to pay the EMI or PEMI regularly on due date without any notice, reminder or intimation. If the amount due is not paid within the agreed timelines, the Company will follow-up with/ send reminders to the Borrower/ Guarantor for payment of dues by Post, Telephone, E-mail, SMS , any other electronic means and/or through third parties appointed for collection purpose. Any third party so appointed by the Company will be required to adhere to the code of conduct of the Company for recovery of dues. Further, the Company is required to provide Credit information relating to its borrowers to Credit Information Companies (CICs) periodically. Hence, to avoid any adverse impact on the credit history with CICs like CIBIL, it is advised that the Borrower should ensure timely payment of the amount due on the loan amount. In the event of default, all outstanding amounts owned by the Borrower to the Company shall become due as per the terms of the Loan Documents and the Company may undertake such necessary processes/ measures to enforce rights available to it under the Loan Documents including but not limited to charging Overdue/ Legal Charges, Charges for recovery of dues by enforcing the Security in accordance with the remedy available under the Law.

For any assistance and further information, you may connect the Customer Service team of the Company through below modes between 9 AM to 6 PM on working days:
1. Contact the branch manager / branch in charge of the branch nearby you.
2. Call our Customer care No.: 022-68815555
You can also write an email to us at the E-Mail Id: customercare@godrejhf.com
For further details, you please visit the Company’s website: www.godrejhf.com
You can collect the following documents by visiting our branch as per the mentioned timelines:
Loan Account Statement	Within 1 working days
Photocopy of the title documents	Within 7 working days
Return of Original document on closure of the loan	Within 45 working days

Complaint Point	Call us on 022-68815555 or Email to customercare@godrejhf.com (From Monday to Sunday, 9:00 AM to 6:00 PM) Visit the website - www.godrejhf.com Write a letter addressed to : Customer service Team, Godrej Housing Finance, 3rd Floor, Godrej One,Pirojshanagar, Vikhroli East, Mumbai, 400079, Maharashtra, India
First Escalation	Grievance Redressal Officer: Aarti Dhurandhar E-mail ID.: nodalofficer@godrejhf.com Telephone no.: 9819038612 Address :Godrej Housing Finance, 3rd Floor, Godrej One Pirojshanagar, Vikhroli East, Mumbai, 400079, Maharashtra, India
NHB (In case delayed or no response)	Complaint Redressal Cell of NHB Online mode: https://grids.nhbonline.org.in OR Offline mode: By post, in prescribed format available at https://nhb.org.in/Grievance-Redressal-System/Lodging-Complaint-Against%20HFCs-NHB%20%83yr%20Physical-Mode.pdf to NHB at the following address: The Complaint Redressal Cell Department of Regulation & Supervision National Housing Bank, 4th Floor, Core 5A, India Habitat Centre Lodhi Road, New Delhi– 110 003

GHF endeavours to address and respond to all the customers’ requests and complaints within a reasonable time and will keep the customer informed on the status as necessary in the interest of the customer. Since, every request and complaint is unique in nature, it may take up to 4 weeks for a thorough resolution, post investigations if any.

The above mentioned Most Important Terms and Conditions (MITC) are not exhaustive and are to be read in conjunction with the terms contained in Sanction letter and the Loan Agreement and the other documents which the borrower has executed with Godrej Housing Finance Limited. In case of any conflict in the terms, the terms as provided in the Loan Agreement shall prevail.

With Warm Regards

For Godrej Housing Finance Limited

Authorised Signatory

I have received a copy of the document containing Most Important Terms and Conditions in my preferred language pertaining to the loan availed by me. The above terms and conditions have been read by the Borrower(s) / read over to the borrower by Shri/Smt. ________of the Company. I confirm that I have understood the above Most Important Terms and Conditions and I accept them.
Applicant	___	Co-Borrower 1	___
Signature	___	Signature	___
Co-Borrower 2	___	Co-Borrower 3	___

Click here to view form in Marathi, Hindi, Kannada

• Covid Pledge
• Covid – Educational Media