Request for Concessions Approval

In accordance with applicable legal regulations and the principles of responsible business conduct, we hereby inform you that you have the right to submit a request for concessions in the event of difficulties in repaying consumer loans.

Our aim is to assist consumers who are facing repayment difficulties that could potentially jeopardize their financial situation, by facilitating debt repayment and preventing debts from escalating into more serious issues.

We encourage all consumers to make timely use of the option to submit a request for concessions and to inform themselves about their rights and the possibilities for exercising those rights.

The consumer has the right to submit a written and substantiated request to the Bank for the approval of concessions, stating the circumstances that led to payment difficulties, including supporting evidence (such as a certificate from the Employment Office, medical documentation, and similar).

What circumstances are considered payment difficulties?

Examples of circumstances considered as payment difficulties include:

loss of employment,
a significant reduction in income,
serious illness or injury resulting in reduced working capacity,
death or illness of a family member,
divorce (if the spouses are co-borrowers or if one spouse is another participant in the credit arrangement).

What circumstances are considered payment difficulties?

The concessions may relate to one or more of the following measures:

extension of the repayment period,
change of the type of contract,
deferred payment of instalments, interest, or principal,
reduction of the interest rate,
temporary moratorium without charging default interest,
partial repayment or debt write-off,
debt consolidation,
for credit card debts and overdrafts, repayment of the debt in 12 monthly instalments with an interest rate that is half of the contracted rate.

Note: The Bank is not strictly bound by the consumer’s request regarding the type of concession or the requested terms and may offer the consumer a different type of concession than the one stated in the Request, if it is deemed more appropriate in the specific case.

How is the request submitted?

The consumer has the right to submit a written request for concessions (at branches or electronically to the Bank’s email address: olaksice.kredit@hb.co.me), together with evidence of the circumstances that led to the difficulties.

For each credit product the consumer uses with the Bank, a separate concession request must be submitted. The consumer must state the number and the date of conclusion of the loan agreement.

The Request for Approval of Concessions form is available at all branches or can be downloaded here.

How does the Bank process the request?

The Bank shall carefully consider each individual consumer request for the application of repayment concessions.

The Bank shall decide on the request for the introduction of repayment concessions within 30 days from the date of receipt of the request and complete documentation, and shall inform the consumer thereof in writing, in paper or electronic form. If the request is incomplete, the Bank shall inform the consumer within 3 working days from the date of receipt of the request and provide instructions on how to complete it.

If, in the request, subsequent communication, or complaint to the Commission, the consumer insists on the application of a specific concession, the Bank may request additional collateral in order to apply such concession.

Until a decision on the request is made, the Bank shall not terminate the relevant agreement, nor declare the entire loan debt due.

In which cases may the Bank reject the request?

The Bank may reject the request in the following cases:

if it determines that the circumstance stated by the consumer as the reason for granting concessions does not exist,
if it determines that such circumstance will not significantly affect the consumer’s ability to regularly repay the loan,
if it determines that the consumer will not be able to ensure regular loan repayment even with the application of concessions, or if the application of concessions would likely place the Bank in a less favorable position compared to other creditors of the consumer.

What if the Bank rejects the request or does not respond within the prescribed deadline?

If the Bank rejects the request or fails to respond within the prescribed deadline, the consumer has the right to submit a complaint to the Bank’s Concessions Commission within ten days from the date of receipt of the decision rejecting the request, or from the expiry of the decision-making deadline if the consumer has not been informed about the decision on the concession request.

The Commission shall decide on the complaint within 15 days, with the possibility of extending the deadline by up to 7 days in complex cases, in which case the consumer will be informed of the extension and the reasons for it.

The Commission may:

reject the complaint if the conditions for granting concessions are not met,
uphold the consumer’s complaint and amend the decision by which the request for concessions was rejected, and/or
offer the consumer a concession, including the possibility of offering a different concession or a concession under modified terms compared to the one previously offered.

The Complaint to the Concessions Commission form is available at all branches or can be downloaded here.

Can the Bank charge additional costs?

No. The Bank may not charge a fee for reviewing the request or implementing measures for granting concessions, except for actual costs that are not determined by the Bank and that can be proven (e.g. costs related to collateral instruments and/or costs of inquiries to the Credit Register of the Central Bank of Montenegro).