Your Rights Are
Not Fine Print.
Najem Financial believes that consumer protection is the most fundamental obligation a financial institution carries. Every account opened, every loan originated, every transaction processed exists within a framework of rights that belong to the customer — not as legal technicalities buried in a disclosure document, but as substantive protections actively enforced by our institution. Our fair practices commitment is embedded in every product design decision: we review fee structures, account terms, marketing materials, and customer communications against a single standard — would a reasonable customer feel misled? Our complaint resolution philosophy prioritizes speed and genuine remediation over bureaucratic deflection. We respond to 100% of regulatory complaints within 15 days, and our internal resolution team targets a 48-hour acknowledgment for every complaint received through any channel. We measure our consumer protection performance not by the absence of regulatory findings, but by customer outcomes — resolution rates, satisfaction scores, and the degree to which our customers feel genuinely protected when things go wrong.
Your Core Consumer Rights
Federal law gives you meaningful rights as a bank customer. Here is what they mean in practice at Najem Financial.
Right to Clear Disclosures
Lending Disclosure StandardsLending disclosure regulations guarantee your right to understand the true cost of credit before you commit. Najem Financial provides Annual Percentage Rate (APR) disclosures on all consumer loans — expressing the total cost of borrowing as a standardized annual rate that makes comparison shopping straightforward. For mortgage applications, we provide a Loan Estimate within three business days of your application, detailing projected monthly payments, total interest costs, and closing costs in a standardized format. Before your mortgage closing, you receive a Closing Disclosure at least three business days in advance, allowing time to review and question any unexpected differences. We never charge fees that are not disclosed in advance, and our account fee schedules are published in plain language on our website and available in every branch. If you are ever charged a fee you did not expect or cannot find in your account agreement, our customer service team is obligated to investigate and resolve it, and refunds are processed without requiring legal escalation. The right to clear disclosures also covers credit card terms, deposit account terms, and electronic services agreements — all written to meet plain language standards.
Right to Fair Credit
Fair Lending StandardsFair lending regulations prohibit discrimination in credit decisions based on race, color, religion, national origin, sex, marital status, age, or because you receive public assistance. At Najem Financial, every credit decision is made on the basis of creditworthiness factors — income, debts, credit history, and collateral — not on any protected characteristic. Our underwriting criteria are documented, applied consistently, and subject to ongoing fair lending statistical analysis by our compliance team and independent auditors. If your credit application is denied or approved on less favorable terms than requested, you have the right to receive a written Adverse Action Notice within 30 days of our decision, explaining the specific reasons for our determination. This notice also informs you of your right to obtain a free copy of your credit report within 60 days if the decision was based on credit reporting information. You also have the right to request an explanation of any decision in person. Our fair lending training program ensures that every employee involved in credit decisions understands that discriminatory lending — intentional or through disparate impact — violates regulations and our core values, and is grounds for immediate corrective action.
Right to Privacy
Financial Privacy StandardsFinancial privacy regulations give you meaningful rights over how Najem Financial collects, uses, and shares your nonpublic personal financial information. Every year, we send you a Privacy Notice that describes our information practices in plain language. We do not sell your personal financial information to unaffiliated third parties for marketing purposes. We share information with service providers and joint marketing partners only under written agreements that require them to protect your information to the same standard we apply internally. You have the right to opt out of sharing your information with certain unaffiliated third parties — this opt-out right is permanent until you change it, and we honor opt-out elections promptly. Our internal data access controls ensure that only employees with a legitimate business need can access your account information, and all such accesses are logged and subject to audit. Our data retention policy limits the retention of personal financial data to legally required or operationally necessary periods, after which records are securely destroyed according to documented procedures. In the event of a data breach affecting your information, we will notify you in accordance with applicable law and provide you with guidance on protective steps to take.
Right to Dispute Errors
Credit Reporting StandardsCredit reporting regulations give you the right to dispute inaccurate or incomplete information in your credit report. If you believe Najem Financial has furnished inaccurate information to any consumer reporting agency, you may notify us in writing and we are required to investigate the dispute, review all relevant information, and correct or delete inaccurate data within 30 days (or 45 days in certain circumstances involving information you obtained from a free annual credit report). We will notify the applicable credit reporting agency of any corrections we make. You also have the right to add a 100-word statement to your credit file explaining any disputed item. You have the right to one free credit report annually from each of the major credit bureaus, and additional free reports are available if you have been denied credit, employment, or insurance based on credit information within the past 60 days. We take our data furnishing obligations seriously — our credit reporting quality assurance program reviews samples of our reported data quarterly to ensure accuracy, completeness, and consistency with our internal records.
Right to Accessible Banking
Accessibility StandardsAccessibility regulations require Najem Financial to ensure that our banking services are accessible to customers with disabilities. All of our branch locations meet physical accessibility requirements, and our digital banking platforms — website, mobile app, and ATM network — are designed to meet WCAG 2.1 AA accessibility standards. Customers who require accommodations are entitled to request them, and we provide auxiliary aids and services at no charge. Electronic fund transfer regulations govern electronic transactions and establish your rights when errors occur on your account. If you believe an unauthorized transaction or error has occurred on an account with electronic access, you must notify us within 60 days of the statement date on which the error appeared. We are required to investigate promptly — within 10 business days for most errors, or 20 business days for new accounts — and correct confirmed errors by the close of business on the next business day. For transactions meeting the zero-liability standard, provisional credit is provided within five business days while our investigation is ongoing. Your error resolution rights apply to debit card transactions, ATM withdrawals, and electronic fund transfers — providing a comprehensive safety net for digital banking activity.
Complaint & Dispute Resolution
A structured, transparent process — from first contact to regulatory escalation
Call +971 2 610 4800 or submit through our secure customer portal. We acknowledge all complaints within 48 hours and assign a dedicated case representative. Most routine disputes are resolved at this stage within 5 business days.
If your initial complaint is not resolved to your satisfaction, request escalation to our independent Ombudsman office. The Ombudsman operates with full independence from our business lines and has authority to recommend remedies including fee waivers, account credits, and policy exceptions. Target resolution: 10 business days.
Customers may file complaints at any time through the Consumer Protection Authority. Najem Financial responds to 100% of regulatory complaints within 15 days of receipt, and we treat regulatory complaints with the same urgency as internal escalations.
Customers may also file complaints with banking regulators. We cooperate fully with all regulatory inquiries and respond promptly to all escalations.
Complaint Resolution Timeline — 2025
% of complaints fully resolved within each timeframe
Fair Lending Commitment
Equal access to credit — our legal obligations and voluntary commitments
Equal Credit Opportunity
Fair Lending StandardsNajem Financial conducts fair lending statistical analysis quarterly, examining our loan approval and denial rates across protected class categories. Our regression models control for legitimate underwriting factors — income, debt-to-income ratio, credit score, LTV — and flag any residual disparity by race, sex, national origin, or other protected class for immediate investigation. In 2025, our fair lending regression analysis found no statistically significant disparities across any product category. We supplement statistical monitoring with mystery shopping programs and file review audits to ensure that front-line underwriting decisions align with our written policies and fair lending obligations.
Fair Housing Compliance
Mortgage Disclosure StandardsFair housing regulations prohibit discrimination in residential real estate lending based on race, color, religion, national origin, sex, familial status, or disability. Najem Financial maintains robust mortgage disclosure reporting, which allows regulators and the public to assess whether our mortgage lending activities serve all segments of our assessment area equitably. Our mortgage data is submitted accurately and on time annually and is available for public inspection. Our Outstanding community investment rating reflects the breadth and quality of our mortgage lending activities in low- and moderate-income areas. We conduct an annual redlining analysis to confirm that our assessment area delineation and lending distribution do not exclude any neighborhood on the basis of prohibited factors, and the results are reviewed by our board fair lending committee.
Community Investment Program
Community ReinvestmentOur community investment program requires us to help meet the credit needs of the communities we serve, including low- and moderate-income neighborhoods, consistent with safe and sound banking practices. Najem Financial has received an Outstanding rating for three consecutive examination cycles — placing us among the top 8% of all institutions in community reinvestment performance. In 2025, we originated $1.2 billion in small business loans under $1 million to businesses in our assessment area, provided $340 million in community development financing for affordable housing, and made $18 million in qualified investments through community development financial institutions. Our community investment file is available for inspection at any branch or online.
Fair Lending Audit Results — 2025
| Product Category | Approval Rate | Denial Rate | HMDA Disparity Index | Audit Finding |
|---|---|---|---|---|
| Mortgage (Purchase) | 74.2% | 25.8% | 1.04 | No Significant Disparity |
| Mortgage (Refinance) | 71.8% | 28.2% | 1.06 | No Significant Disparity |
| Auto Loan | 82.4% | 17.6% | 1.02 | No Significant Disparity |
| Credit Card | 88.1% | 11.9% | 1.03 | No Significant Disparity |
| Personal Loan | 76.3% | 23.7% | 1.05 | No Significant Disparity |
HMDA Disparity Index: ratio of minority to non-minority approval rates after controlling for creditworthiness factors. Index of 1.00 = complete parity. Threshold for significance: >1.25.
Zero-Liability & Fraud Protection
Comprehensive protection against unauthorized transactions, account takeover, and identity theft
Our Zero-Liability Guarantee
Najem Financial's zero-liability guarantee means that you are not responsible for unauthorized transactions on your account, provided you report them promptly. There is no deductible, no dollar cap, and no requirement to first pursue recovery from the fraudster. Our guarantee covers unauthorized debit card transactions, credit card fraud, unauthorized ACH transfers, and account takeover events — the full spectrum of electronic fraud scenarios that affect modern banking customers.
To receive full zero-liability protection on your debit or prepaid card, report unauthorized transactions within 60 days of the statement on which they appear. For credit cards, the Fair Credit Billing Act limits your maximum liability to $50 for charges before the card is reported lost or stolen — our zero-liability policy improves on this statutory floor by eliminating even this $50 exposure. For account takeover events — where someone gains unauthorized access to your account credentials — we initiate a full security review, freeze affected access methods, and begin our investigation within four hours of your report.
To report a suspected unauthorized transaction or account takeover, call our 24/7 fraud line immediately. Do not wait to resolve the issue through normal customer service channels — early reporting enables faster account protection and maximizes your legal protections. Our fraud investigators will work with you through the dispute process from start to resolution, keeping you informed at each stage.
Consumer Resources
Key documents explaining your rights and our policies — available to download at any time
Regulatory Contacts
Federal agencies you can contact independently if you have a concern about our practices
The CFPB is the federal agency responsible for consumer financial protection. File a complaint about any consumer financial product or service — including checking accounts, loans, credit cards, and mortgages — if you feel we have not treated you fairly or resolved your complaint adequately. The CFPB forwards complaints to us and monitors our responses.
As a nationally chartered bank, Najem Financial is supervised by the OCC. The OCC's Customer Assistance Group handles consumer complaints about national banks and federal savings associations. Use this contact for issues relating to your deposit accounts, loans, and bank services where the CFPB may not have jurisdiction.
The Federal Reserve Board handles consumer complaints about state member banks and bank holding companies. For issues that may relate to our systemic banking practices or Federal Reserve-regulated activities, the Federal Reserve Consumer Help Center is an appropriate escalation point.
The FDIC's Consumer Response Center handles complaints about FDIC-supervised institutions and provides information about deposit insurance coverage. If you have questions about the scope of your FDIC insurance coverage at Najem Financial, or wish to verify our insured status, the FDIC's consumer team can assist.
Questions About Your Consumer Rights?
Our consumer protection team is dedicated to ensuring your rights are upheld. Whether you have a complaint, a question about a disclosure, or need help navigating a dispute, we are here to help.