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 […]
The 7-Day Rule: Why Your Recovery Agency List Can’t Sit Static on Your Website
TL;DR Your Recovery Agency Disclosure Obligation Started in 2025, Not 2027 If your compliance calendar has flagged January 2027 as the date this obligation begins, that’s incomplete. The obligation to publish a recovery agency list already exists. The RBI (NBFC – Responsible Business Conduct) Directions, 2025, at what secondary sources cite as para 97, already […]
Build vs Buy vs Partner: 2026 Decision Framework for AI Collections at Indian Banks
Every Vendor Deck Leads With Cost and Speed. The Question That Actually Matters Is Who Answers to RBI When the Model Fails. TL;DR Every vendor pitch for AI collections leads with the same two numbers: how much faster it is than building in-house, and how much cheaper it is over three years. Those numbers matter, […]
Hardship Workflow Automation: How AI Routes Distressed Borrowers to the Right Programme
Two Borrowers in Identical Distress Shouldn’t Get Different Outcomes Because They Reached Different Agents TL;DR A borrower calls in genuinely struggling. Depending on which agent picks up, on their training, their caseload that day, their read of an ambiguous situation, that borrower gets routed to a forbearance conversation, a payment plan pitch, or nothing more […]
Your Vendor Validated The Model. RBI Says That Doesn’t Count
TL;DR Para 45 of RBI’s draft guidance on Model Risk Management contains one sentence that most vendor relationships in Indian banking are not built around. “An RE acquiring, using or relying upon third-party models at any stage of the model lifecycle is accountable for its outcomes.” That sentence is complete as written. The accountability does […]
Your Institution Probably Has 10x More Models Than You Think. Here Is How RBI Counts Them
TL;DR Think of the last three quantitative decisions your institution made. A lending rate was set. A collection account was routed to an agent. A loan application was declined. For each one, ask: did a tool take an input, apply some logic to it, and produce an output that drove that decision? If the answer […]
NCA Section 86 and AI Collections: Real-Time Debt Review Integration for SA Credit Providers
TL;DR NCA Section 86, AI Collections, and the Case for Real-Time Debt Review Integration South African credit providers running AI-driven collections workflows face a compliance exposure that most batch-based systems cannot close: the gap between when a borrower applies for debt review and when the collections platform actually knows about it. NCA Section 86, as […]
NCA-Compliant AI Collections in South Africa: Debt Review, Conduct, and Section 129 Requirements
TL;DR South African credit providers deploying AI in collections face a compliance problem that batch-based systems cannot solve. The National Credit Act 34 of 2005 (NCA), as amended by the National Credit Amendment Act 2014, together with the NCR Guideline 2023 on AI automated systems, creates a regulatory framework where the timing of each contact […]
CFPB UDAAP and AI Collections: What Unfair, Deceptive, and Abusive Means for US Banks in 2026
TL;DR CFPB UDAAP Standards and AI-Driven Collections: What US Banks Must Address in 2026 The CFPB’s UDAAP authority now reaches directly into AI collections workflows at US banks, and the enforcement data from 2025 confirms that examiners are acting on it. The regulatory foundation sits in Dodd-Frank Section 1031, which grants the CFPB authority over […]
RBI Scale Based Regulation for Upper Layer NBFCs: AI Collections Governance Requirements
TL;DR RBI Scale Based Regulation and AI Collections Governance for Upper Layer NBFCs The intersection of RBI scale based regulation for Upper Layer NBFCs and AI collections governance has become the most scrutinized compliance domain for India’s largest non-bank lenders. RBI’s Scale Based Regulation for NBFCs, issued in October 2021, operationalized through the Upper Layer […]
