Comments on Draft Amendment Directions on ‘Conduct of Regulated Entities in Recovery of Loans and Engagement of Recovery Agents’, dated 20th May 2026
The Draft Amendments provide detailed guidance to relevant regulated entities (REs) on the loan recovery process, including mandatory certification for recovery agents, safeguards against harassment, grievance redressal mechanisms, and compensation for wrongful use of technology-based mechanisms.
Submission to International Finance Corporation (World Bank Group) for the inclusion of risks of over-indebtedness and debt distress among microfinance borrowers, in its Environmental and Social (E&S) Framework
In response to the public consultation, we argue that borrower over-indebtedness is a customer protection concern that must be explicitly recognised in the revised E&S Framework.
Comments on the Draft Amendment Directions Non-Banking Financial Companies – Registration, Exemptions and Framework for Scale Based Regulation, dated 10 April 2026
On 10 April 2026, the Reserve Bank of India released the “Draft – Reserve Bank of India (Non-Banking Financial Companies – Registration, Exemptions and Framework for Scale Based Regulation) Second Amendment Directions, 2026”. The Draft Amendments provide a new methodology to classify Non-Banking Financial Companies (NBFCs) in the Upper Layer of the scale-based regulatory framework, […]
Comments to the Discussion Paper – Exploring safeguards in digital payments to curb frauds
In this response, we present our comments to the paper. We divide our comments into three sections.
Comments to Draft Reserve Bank of India (Commercial Banks – Responsible Business Conduct) Amendment Directions, 2026, dated 6 March 2026
In this response, we present four recommendations to the Draft Amendments.
Comments to Draft Reserve Bank of India (Commercial Banks – Responsible Business Conduct) Amendment Directions, 2026, dated 11 February 2026
In this response, we present our comments to the Draft Amendment Directions for ‘Advertising, Marketing and Sales of Financial Products and Services by Regulated Entities’ issued by the Reserve Bank of India on February 11, 2026.
Credit Demand of FPOs – A Credit Market Estimation Exercise
This article aims to provide a preliminary estimate of the credit requirements of FPOs, drawing on the experience of professionals who have been closely associated with FPOs for several years in their development and operations.
Towards Customer-Centric KYC: RBI’s 2025 Amendments from a Financial Inclusion Lens
In this blog post, we analyse the changes in the direction and weigh them through the lens of customer protection and long-term sustainability. We also offer suggestions on streamlining the KYC updation (re-KYC) exercise without adding to systemic risks.
Our Observations on the Draft Banning of Unregulated Lending Activities (BULA) Act by the Ministry of Finance (MoF), GoI
On 13 December 2024, the Ministry of Finance, Government of India (MoF) released the draft Banning of Unregulated Lending Activities (BULA) Act. This aligns with recommendations made in the Report of the Working Group on Digital Lending.
Responsible AI means good business for all
When AI-driven decisions are fair, respect privacy and are not opaque, they foster customer confidence
