What Counts as an AI Model Under RBI’s New Guidance, and How to Keep an Audit Trail
TL;DR: RBI’s Draft Guidance Defines “Model” by Substance, Not by What Your Team Calls It On June 24, 2026, the Reserve Bank of India released a draft guidance document (prid=63006) for public comment, with the comment period closing July 24, 2026. It is a draft. It is not a Master Direction, and it has not […]
How Often Should You Revalidate a Model? RBI’s Answer for NBFCs
TL;DR RBI Has Not Set One Number for Model Revalidation Frequency If you searched for this because a risk committee member asked “how often does RBI actually require us to revalidate,” the honest answer is that RBI has not published a single number. The Reserve Bank of India released draft guidance on model risk management […]
Model Governance Software for Indian Banks: What the Category Actually Offers
TL;DR Vendor Certification Does Not Reduce Your Validation Burden Under RBI’s Draft Guidance A model comes with a vendor certificate. The vendor ran its own testing, its own bias checks, its own performance benchmarks, and signed off. For most global model governance platforms, that certificate is treated as a meaningful input into the bank’s own […]
Model Risk Tiering: Why Not Every AI Model Needs the Same Scrutiny
TL;DR A model risk officer at an NBFC gets asked by an examiner which of the institution’s forty deployed models get the deepest scrutiny. There is no RBI-published answer yet, only three named inputs and a deadline that keeps moving. The Three Factors RBI’s Draft Actually Names RBI’s June 24, 2026 draft guidance (“Guidance on […]
What RBI’s Model Risk Management Guidance Actually Means for NBFC AI Teams
TL;DR An NBFC’s model inventory usually lives in three places at once: a spreadsheet the risk team maintains, a vendor scorecard from whichever bureau or fintech partner supplied a scoring model, and someone’s memory of what is actually running in production this quarter. Ask that team to produce a validation trail for one specific model, […]
The 08:00 to 19:00 Rule: Building Calling-Hours Compliance Into Recovery Workflows
TL;DR Most Compliance Teams Read the Calling-Hours Rule Backward Ask a collections operations lead what the 8am to 7pm rule means, and most will describe it as a permitted calling window: agents can dial between those hours, full stop. That reading misses where the rule actually sits. Paragraph 100 of the RBI (NBFC – Responsible […]
The OEM Certification Requirement Nobody’s Talking About in RBI’s Device-Locking Rules
TL;DR The Rule Text Says OEM Certification Is Required. It Doesn’t Say by Whom. Per secondary reporting on RBI’s device-locking guidelines, including coverage by Inc42, regulated entities (REs) and third-party device-locking vendors are required to obtain certification from the device or operating system platform’s OEM before deploying device-locking technology in gadget financing. That is the […]
Device-Locking Compliance Software for NBFCs: What RBI’s January 2027 Deadline Actually Requires
TL;DR The Question Most Compliance Teams Are Answering Wrong Ask a collections or compliance lead at a mid-sized NBFC whether RBI’s new device-locking rules apply to them, and the answer usually comes fast: “We don’t do aggressive collections. This is for the app-based lenders with the bad press.” That’s the wrong question. RBI’s rule, effective […]
Microfinance Collections Run on a Different Rulebook. Does Your Compliance Software Know That?
TL;DR If you’ve read the earlier posts in this series, your recovery-agent compliance stack probably already handles the basics: contact-hour windows, call recording, mandatory disclosure scripts, agent conduct logging. For a general NBFC book, that’s a reasonably solid foundation. But if any part of that book is microfinance lending, here’s the question worth asking your […]
Recovery Agency Due Diligence: What RBI Now Ties to Your Outsourcing Risk Policy
TL;DR An Auditor Just Flagged Your Recovery Agent Vetting as Undocumented Nobody is telling you the vetting was bad. That’s the part worth sitting with. In a growing number of NBFC examinations, the finding isn’t that a recovery agent was under-vetted, that background checks were skipped, or that a red flag went unnoticed. The finding […]
