The Srisawad Corporation Public Company Limited, which holds 99% of shares in Srisawad Power 2014 Co., Ltd., sent a letter to various news agencies to clarify the Consumer Organization Council's press release warning about the company offering home and land loans without mortgages on July 6, 2022. Sopon Noorath, head of the Consumer Protection and Rights Defense Department of the Consumer Organization Council, commented on the company's clarification letter, stating that the content did not address the issues directly and included some statements that could confuse and mislead consumers. For instance, the claim that not providing a copy of the contract does not affect consumers, and comparing another company with Srisawad Power 2014 Co., Ltd., despite them being different entities with different licenses.

Sopon explained that regarding the failure to provide a copy of the contract to consumers, the company stated that it informed all loan applicants that they could request copies of documents and related information later at their convenience. He noted that if there were legal proceedings, the company would have to provide details and submit relevant documents for the court and loan applicants to consider thoroughly. This implies that the company did not actually provide a copy of the contract to consumers.

The Consumer Organization Council confirmed that the failure to deliver a copy of the contract is indeed a violation of consumer rights. According to the law, it is the business's responsibility to provide the contract and related documents to consumers immediately upon signing, rather than placing the burden on consumers to follow up for documents later. The law stipulates penalties for businesses that fail to deliver copies, including imprisonment of up to one year and fines of up to 200,000 baht, or both, Sopon stated.

Regarding the issue of selling insurance without the right to refuse, although the company stated that it has a clear policy that loan applicants have no obligation or conditions to purchase life or property insurance from the company, Srisawad Power 2014 is licensed as an insurance broker and should be aware of the regulations regarding insurance sales, which require sellers to have a license. However, some employees in certain branches sold insurance without a license, ultimately benefiting the company through commission from insurance sales. This situation indicates that the company knew or should have known about the wrongdoing and thus must be held accountable to consumers under the law.

Sopon further elaborated on the issue of charging an interest rate of 24% per year, which exceeds the legal limit. The company's reference to Srisawad Capital Co., Ltd., which can charge an interest rate of 25% per year as it is a personal loan company regulated by the Bank of Thailand, creates confusion since the two companies are separate legal entities, and Srisawad Power 2014 does not have such a license. The company's claim that a Supreme Court ruling states that 'transactions involving promissory notes do not constitute lending under the law prohibiting excessive interest rates' could lead to misunderstandings, as the contracts complained about to the Consumer Organization Council are not promissory note transactions but loan agreements, which are subject to laws prohibiting excessive interest rates.

Additionally, referencing Srisawad Capital Co., Ltd. as a licensed entity entitled to charge excessive interest in connection with Srisawad Power 2014 could mislead the public into believing that the actual contracting party is Srisawad Capital Co., Ltd. This suggests that Srisawad Capital Co., Ltd. may have knowledge of or consented to the wrongdoing within the group of companies. Therefore, it is appropriate to investigate the connection of any wrongdoing by Srisawad Capital Co., Ltd. to determine if there was any collusion or support for such misconduct.

Regarding the issue of consumers not receiving the full loan amount, the company explained that this was due to fees for fire insurance, group life insurance, and collateral appraisal for 'home and land loans without mortgages.' This admission indicates that the claim of no fees in advertising is untrue and may constitute misleading advertising. The Consumer Organization Council has sent a letter to the Office of the Consumer Protection Board (OCPB) requesting an investigation into this advertisement, and subsequently, the OCPB invited the company to clarify.

Sopon continued that the company's design of the loan repayment structure (for home and land loans without mortgages) limits principal repayments, which increases the burden of interest for consumers and makes it difficult for them to settle debts. Even if consumers pay more than the specified amount, the excess is not immediately deducted from the principal but is held for the next payment.

Moreover, the company's claim that borrowers must complete payments within 12 months due to risk management, including reassessing the value of the property and its surroundings to ensure the collateral is intact, is misleading. The company already has a risk management plan by limiting the loan amount to 200,000 baht and not exceeding 40% of the appraised value by the land department, making it unnecessary to charge for such appraisals.

It was also found that the company did not clarify the issue of not returning the land title deed, citing outstanding fees. Many consumers using the home and land loans without mortgages have reported similar issues on social media. However, it is not only Srisawad Power 2014 that exhibits such behavior; it is believed that many other companies may engage in similar practices, which exploit consumers and cause distress to the public during an economic downturn. This undermines public order and tranquility. The Consumer Organization Council will investigate all cases of wrongdoing to protect consumers.