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Part 05 — The Lending Lifecycle

Servicing

Servicing is everything that happens to a standard loan after disbursement and before delinquency or closure: billing, interest accrual, repayment posting, statements, certificates, rate resets, mandate maintenance, part-prepayment, foreclosure, top-up, balance transfer out, and customer-service changes. In SME lending, servicing quality has direct credit impact. A wrong due date, stale mandate, unapplied receipt, or hidden charge can create customer disputes, bureau complaints, and avoidable delinquency.

Regulatory conduct rules matter here. RBI’s KFS framework says fees not disclosed in the KFS cannot be charged later without explicit consent, and the KFS must disclose APR and repayment schedule for covered retail and MSME term loans (Key Facts Statement for Loans & Advances, April 15, 2024). RBI’s penal-charges circular changed market practice by requiring penal charges for non-compliance with loan terms to be treated as charges, not penal interest added to the interest rate (Fair Lending Practice - Penal Charges in Loan Accounts, August 18, 2023). Foreclosure rules also differ by borrower and product: RBI’s August 2, 2019 circular bars banks from charging foreclosure/prepayment penalties on floating-rate term loans sanctioned to individual borrowers for purposes other than business; NBFCs have aligned restrictions under their applicable directions, but business-purpose SME loans to firms and companies can still have contracted prepayment terms if fairly disclosed.

The loan servicing team owns repayment schedules, customer requests, certificates, and account changes. Finance owns accounting and tax certificates. Treasury and product teams own rate-reset logic. Customer service handles statements, no-dues certificates, and complaints. Collections gets involved once a bill is unpaid. Credit approves top-ups, limit renewals, major tenor changes, and waivers. Compliance reviews charge, foreclosure, and grievance practices.

The core inputs are loan agreement, KFS, repayment schedule, mandate record, disbursement date, rate type, benchmark/spread, charge schedule, insurance schedule, collateral release conditions, and borrower communication preferences. Servicing requests may need board resolution, revised mandate, bank-account proof, top-up application, foreclosure quote request, statement request, or balance transfer letter.

  1. LMS generates demand. For term loans, the EMI/equated periodic instalment (EPI) schedule is generated from disbursement date, interest start date, moratorium, rate, and tenor. For cash credit/overdraft, monthly interest is applied on daily outstanding and drawing power controls availability.
  2. The system presents the mandate before due date. For NACH/UPI Autopay, the borrower should receive pre-debit communication as per payment-system rules and lender policy.
  3. Receipts are matched. Auto-debits, NEFT/RTGS/IMPS, UPI, cash where permitted, and settlement receipts are posted against the loan.
  4. Repayment appropriation is applied. A typical standard-account order is statutory dues/taxes, fees and charges, penal charges, overdue interest, current interest, overdue principal, and current principal; for non-performing assets (NPAs), RBI allows banks to adopt a uniform accounting principle where there is no clear agreement on appropriation (Master Circular - Prudential norms on IRAC, April 1, 2025). The exact order must match the contract and product policy.
  5. Customer outputs are generated: statement of account, repayment schedule, interest certificate, provisional interest certificate, no-dues certificate, foreclosure quote, and collateral release list.
  6. Rate resets are processed. Floating-rate loans need benchmark updates, spread controls, borrower communication, and schedule recalculation. Banks’ MSE/medium-enterprise floating rates may be linked to external benchmarks under RBI’s external benchmark regime; NBFCs usually price under board-approved interest-rate models rather than RBI’s bank benchmark rules.
  7. Closure or balance transfer is completed only after full dues are received, lien/charge releases are filed, original documents are returned, and credit bureau closure is reported.

Foreclosure and prepayment are product-sensitive. A proprietor borrowing for personal LAP may be treated differently from the same person borrowing for business expansion; the purpose stated in sanction and agreement matters. Fixed-rate loans, mixed-rate loans, loans to partnerships/LLPs/companies, and working-capital limits can carry different prepayment clauses. The system should not apply one foreclosure rule to all loans.

Top-ups require fresh underwriting, not just available LTV. A 24-month seasoned LAP with clean repayment may qualify for top-up if LTV and income support it; a GST drop, cheque bounces, or stock-statement default should route it to credit. Balance transfer out creates operational risk: the incoming lender wants foreclosure letter and document list, while the existing lender must prevent release of originals before funds clear.

Servicing also owns non-credit changes: mobile/email update, bank-account swap, mandate cancellation/recreation, GST invoice for processing charges where applicable, and borrower death or constitution change routing to special workflows.

LMS, payment gateway/NACH system, general ledger, customer portal, contact-center CRM, bureau reporting module, rate-reset engine, document custody, collections system, tax/GST module, and grievance system. A mature LMS keeps a transaction-level ledger with value date, posting date, appropriation bucket, reversal link, and user/system origin.

Statement requests are usually same day digitally and 1-2 working days manually. Foreclosure letters take 2-5 working days after request and are valid for a limited period, often 7-15 days. No-dues certificates and document release for secured loans commonly take 7-15 working days after closure, depending on vault location and charge-satisfaction filings. Mandate swaps take 3-10 working days depending on destination bank and mode.

Track billing success, mandate bounce rate, receipt unapplied ageing, customer request TAT, foreclosure quote TAT, rate-reset error rate, statement complaints, waiver volume, top-up conversion, closure-to-document-release TAT, and bureau dispute rate. For working capital, track interest servicing regularity and frequency of excess drawings.

In co-lending, servicing must split cash correctly. The 2025 Co-Lending Directions require all disbursement and repayment transactions between REs and with the borrower to route through a bank escrow, with appropriation specified in the agreement; each RE maintains the borrower’s account for its own share (RBI Co-Lending Arrangements Directions, 2025). Customer-facing statements should avoid confusing the borrower with two inconsistent balances. Back-end ledgers, however, must support partner-wise principal, interest, charges, tax, refunds, DPD, and bureau reporting.

For settlement-linked marketplace repayment, servicing also needs settlement-instruction reconciliation, seller-churn triggers and fallback mandate tracking; see Marketplace Seller Finance.