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by Rakesh Waghela

3.N Reporting and compliance

Purpose

Section titled “Purpose”

Produce, file, and archive every report a regulator, auditor, board member, or partner can ask for, without weeks of scramble at quarter-end.

In-scope features

Section titled “In-scope features”

RBI returns

Section titled “RBI returns”
  • DNBS-01 / 02 / 03 / 04A / 04B / 09 / 13 etc. depending on category and asset size — automated generation against the LMS book.
  • Annual return (DNBS-PPD or equivalent).
  • Submission tracking — submitted, acked, rejected.
  • Resubmission workflow on rejection.

Credit-bureau submission

Section titled “Credit-bureau submission”
  • Monthly file generation for all 4 CICs in standard format — consumer + commercial.
  • Submission ack tracking.
  • Reject / error file processing and re-submission.
  • Data-quality dashboard — match rate, error categories.

CKYC

Section titled “CKYC”
  • CKYC upload queue — new and updated records.
  • CKYC download queue — for existing-KIN matches.
  • Reconciliation — files uploaded vs acked.

CERSAI (only for secured products)

Section titled “CERSAI (only for secured products)”
  • Security-interest registration within prescribed time.
  • Satisfaction filing on closure.

Board reports

Section titled “Board reports”
  • Monthly board pack — disbursement, AUM, NPA, ECL, key flags.
  • Risk-committee pack — concentration, EWS, stress.
  • Audit-committee pack — audit findings, remediation.
  • Quarterly outsourcing report.
  • Annual outsourcing + DLG + co-lending disclosure.

Compliance reports

Section titled “Compliance reports”
  • Grievance summary — volume, resolution time, repeat, escalations.
  • Customer-communication logs — all SMS / WhatsApp / email / IVR records.
  • Audit logs — application + system + database, with integrity attestation.
  • Data-retention reports — what’s retained, what’s purged.
  • Consent reports — active consents, withdrawals, revocations.
  • Security incident log — every incident, response, RCA.

Financial reports (cross-cutting with M)

Section titled “Financial reports (cross-cutting with M)”
  • Quarterly + annual financials for RBI + statutory.
  • Tax audit support.

Co-lending reports

Section titled “Co-lending reports”
  • Per-partner portfolio MIS.
  • Per-partner settlement reports.
  • Per-partner NPA report.

ALM (Asset-Liability Management)

Section titled “ALM (Asset-Liability Management)”
  • ALM bucketing — assets and liabilities by maturity.
  • Liquidity gap analysis.
  • Interest-rate-risk analysis.

Out of scope

Section titled “Out of scope”
  • The accounting itself — see 3.M.
  • Portfolio analytics for internal use — see 3.L and 3.P.

Key entities

Section titled “Key entities”
  • Return — per regulatory return, per period, with file + status.
  • BureauSubmission — per CIC per period.
  • CkycSubmission — per upload batch.
  • BoardPack — per meeting.
  • GrievanceLog — entry per complaint.
  • IncidentLog — per security / operational incident.
  • ConsentSnapshot — per period summary.

Key workflows

Section titled “Key workflows”
  1. Monthly bureau submission — batch → file → submit to each CIC → ack → reconcile.
  2. Quarterly RBI return — generate → review → board approval → submit → ack.
  3. Annual return — yearly.
  4. CKYC upload — daily or batch from new onboardings.
  5. Board pack — monthly cycle.
  6. Incident response — log → triage → root-cause → preventive → close.

Integrations

Section titled “Integrations”
  • RBI portal (online filing).
  • CIC portals + APIs (4 of them).
  • CKYCR portal.
  • CERSAI portal (only if secured).
  • Internal data warehouse as source.

APIs

Section titled “APIs”
  • GET /reports/regulatory/{return}/{period} — generate / fetch.
  • POST /reports/regulatory/{return}/{period}/submit.
  • GET /reports/bureau/{cic}/{period}.
  • POST /reports/bureau/{cic}/{period}/submit.
  • POST /ckyc/upload/batch.
  • GET /reports/board/{period}/{type}.

Events emitted

Section titled “Events emitted”
  • regulatory_return.generated / submitted / acked
  • bureau_submission.generated / submitted / acked
  • ckyc.upload.completed
  • board_pack.published
  • incident.logged / incident.resolved

Edge cases

Section titled “Edge cases”
  • Bureau rejects file with errors — error file parsed; rejected rows fixed; re-submission.
  • CKYC duplicate — KIN already exists; download instead of upload.
  • RBI portal downtime at submission deadline — retain proof of attempt; submit upon recovery.
  • Reporting figures don’t match management accounts — investigate; usually classification / cut-off issue.

Compliance touchpoints

Section titled “Compliance touchpoints”
  • CICRA for bureau.
  • NBFC Master Direction for RBI returns.
  • KYC MD + CKYC norms for CKYC.
  • SARFAESI / CERSAI for secured.
  • DPDP for consent reports.
  • IT MD for incident reporting.

MVP vs production

Section titled “MVP vs production”
FeatureMVPProduction
Bureau monthly submission to 4 CICs✓✓
CKYC upload✓✓
Major RBI returns✓ (manual fill at MVP, ideally automated)✓ (automated)
Board packManual MIS✓ (automated)
Grievance dashboard✓✓
Incident log✓✓
ALM(Phase 3)✓
Per-partner reporting✓ (when co-lending live)✓
CERSAI(Only if secured products)✓

Related: 2.9 Bureau reporting, 2.15 Compliance calendar, 3.M Accounting and finance, 13.15 Reporting backlog, 13.16 Compliance backlog.