RBI Digital Lending Guidelines compliance for lending apps and FinTech platforms — KFS format, Loan Service Provider agreements, data privacy, and Fair Practices Code.
RBI issued the Digital Lending Guidelines 2022 (revised Master Directions) to regulate the rapidly growing digital lending ecosystem. All banks, NBFCs, and Regulated Entities (REs) engaging in digital lending — including those partnering with Lending Service Providers (LSPs) and apps — must comply with these guidelines. Key requirements include: Key Fact Statement (KFS) disclosure to all borrowers before loan sanction; all credit must flow directly to the borrower's bank account; all repayments must flow directly to the RE without pass-through via LSP; data collection limited to purpose-specific consent; Annual Percentage Rate (APR) disclosure; and grievance redressal mechanism.
FinTech companies acting as LSPs (Buy Now Pay Later platforms, lending apps, credit marketplaces) must be registered with a Regulated Entity, comply with data privacy requirements, and not hold customer funds. MFiling audits your current lending tech stack, identifies compliance gaps, and implements all required policy, process, and technology changes for RBI Digital Lending Guidelines compliance.
MFiling professional charges: from Rs.19,999 for compliance gap assessment and policy implementation.
Review current loan documentation, app features, data collection, and fund flow against RBI guidelines.
Identify all non-compliant elements — KFS missing, improper fund flow, excess data collection, no APR disclosure.
Prepare KFS format with all mandatory disclosures — loan amount, APR, processing fee, repayment schedule.
Update loan agreements to include all RBI-mandated disclosures and borrower rights.
Restructure technology and commercial agreements between fintech LSP and RE partner for compliance.
Set up nodal officer, grievance portal, and RBI Ombudsman escalation pathway.