Video: Dr. Nachiket Mor on the Report of the RBI Committee on Comprehensive Financial Services

The Draft Guidance proposes broad regulatory expectations for model risk management across the model lifecycle. It intends to strengthen governance, oversight, risk management and controls of Regulated Entities (REs) using models (including AI / ML models). In this response we present our comments to the Draft Guidance, through six recommendations

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.

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.

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, […]

In this response, we present our comments to the paper. We divide our comments into three sections.

In this response, we present four recommendations to the Draft Amendments.