Part 07 — People & Org

Ops & Control Roles

Operations and control functions decide whether a sanctioned loan becomes a clean asset or a future dispute. Sales may source the borrower and credit may approve the risk, but operations books the account, legal creates enforceable security, treasury funds disbursement, finance reconciles the ledger, compliance tests the rules, technology protects data, customer service handles complaints, and internal audit checks whether everyone is telling the truth.

Operations

Loan operations is the maker-checker spine between sanction and servicing. Common titles are Operations Executive, Loan Operations Officer, Disbursement Maker, Disbursement Checker, Branch Operations Manager, Regional Operations Manager, Central Processing Unit (CPU) Manager and Head - Operations.

Core duties:

Verify sanction conditions, Key Facts Statement (KFS) acceptance, loan agreement, guarantees, e-sign/e-stamp, mandate and insurance.
Check borrower bank account, disbursement beneficiary, invoice or supplier details, and loan management system (LMS) booking.
Ensure CERSAI, Registrar of Companies (ROC) charge filing where applicable, document vault and post-disbursement document pendency.
Run daily disbursement, repayment, bounce, bank-statement, payment-gateway and general ledger (GL) reconciliation.
Manage service requests: statement, repayment schedule, foreclosure, NOC, charge release, mandate swap and address/bank changes.

Operations KPIs should include first-time-right booking, disbursement TAT, reconciliation breaks, open post-disbursement documents, mandate activation rate, service-request ageing and audit exceptions. A disbursement team paid only on volume will book unsafe exceptions.

Legal And Technical

Legal in SME lending is split between business legal, collateral legal and recovery legal. Titles include Legal Manager - LAP, Zonal Legal Manager, State Legal Head, Head - Legal, Litigation Manager and Documentation Counsel. For loan against property (LAP), legal reviews title chain, encumbrances, succession, lease/tenancy, urban-land records, mortgage creation and enforceability. Technical/valuation teams handle property valuation, construction quality, occupancy, marketability and insurance.

Kotak Mahindra Bank’s 2026 Zonal Legal Manager - LAP posting sought experience in recovery and litigation, SARFAESI, mortgage fraud, legal portfolio management, team leadership and coordination with collections/recovery (LiveLaw job update). A separate LAP legal manager posting described reviewing finance facility agreements, property due diligence, title search reports and security documentation (LatestLaws job update).

Good legal KPIs are not only TAT. They include title-defect detection, post-disbursement mortgage perfection, pending original documents, charge release TAT, litigation success rate, panel advocate quality and recovery support.

Compliance And Grievance

Compliance is second line. In larger NBFCs, the Chief Compliance Officer (CCO) must be sufficiently senior and independent under RBI’s Compliance Function and Role of CCO circular for NBFCs, April 11, 2022. The compliance team owns regulatory interpretation, policy mapping, product approvals, regulatory reporting oversight, customer communications, outsourcing controls, fair practices, digital lending controls and complaint governance.

Customer service and grievance are operational but compliance-sensitive. RBI’s NBFC Fair Practices Code directions require NBFCs to display grievance redressal officer details at branches/places of business and put complaint procedures and response timelines on the website; complaints about outsourced services must also be handled by the NBFC’s grievance machinery (RBI NBFC directions, grievance section). Digital lending adds nodal grievance requirements for regulated entities and lending service providers (LSPs) in the Digital Lending Directions, 2025.

Typical customer-service KPIs: first response time, 30-day closure, repeat complaints, Ombudsman escalations, wrong bureau reporting cases, foreclosure/NOC TAT, charge-release TAT and root-cause closure.

Treasury And Finance

Treasury funds the loan book. In an NBFC, this means bank lines, non-convertible debentures (NCDs), securitisation, direct assignment, co-lending, liquidity buffers and asset-liability management (ALM). Finance ensures accounting, income recognition, provisioning, tax, statutory audit, regulatory returns and lender covenants.

Operationally, finance must reconcile:

Area	Why it matters
Disbursement bank vs LMS	Prevents duplicate, wrong-beneficiary or failed disbursement accounting.
Repayment bank vs LMS	Ensures borrower accounts, delinquency and bureau reporting are correct.
Co-lending share	Partner share, escrow, interest split and asset classification must match contract.
DSA payout	Payouts must match disbursed loans, clawbacks and GST invoices.
Collection cash	Same-day borrower-account credit is a conduct and fraud control issue.

Finance KPIs include zero unreconciled high-value breaks, ALM reporting timeliness, provision accuracy, statutory/regulatory return timeliness, DSA payout accuracy, partner reconciliation ageing and audit closure.

Technology And Information Security

Technology is not merely a support desk in lending. The loan origination system (LOS), LMS, business rules engine (BRE), document management system (DMS), bureau integrations, bank-statement analyser, GST connectors, collections platform, partner application programming interfaces (APIs), payment gateways and GL integrations are control systems. RBI’s IT Governance, Risk, Controls and Assurance Practices Directions, 2023 apply to banks and middle/upper/top layer NBFCs from April 1, 2024, and require board/senior-management oversight, IT governance, information security, audit and business continuity controls.

Tech KPIs should include uptime for critical journeys, incident severity, access-review completion, privileged-access exceptions, reconciliation automation, API failure ageing, audit-log completeness, vulnerability closure and disaster-recovery test results. A production-support user should not be able to alter repayment allocation, waive charges or edit KFS artefacts without maker-checker and audit logs.

Internal Audit

Internal audit is third line. RBI’s Risk-Based Internal Audit circular for select NBFCs and urban co-operative banks says internal audit should provide assurance to the Board and senior management on internal controls, risk management and governance, and calls it the third line of defence. In SME lending, audit samples sourcing, KYC, underwriting, disbursement, documentation, collections, vendor management, complaints, system access and regulatory reporting.

Audit should not report operationally to business. Strong audit findings are specific: “18 of 60 LAP files had CERSAI registration delayed beyond policy TAT” is useful; “documentation needs improvement” is not.

Partnership And Alliance Managers

Partnership managers sit between front office, product, credit, compliance, operations and technology. Titles include Alliance Manager, Strategic Partnerships Manager, Lender Partnerships Manager, Co-Lending Manager and Anchor Relationship Manager. Their job is to source and run bank/NBFC partners, fintech platforms, anchors and embedded-lending programs.

Public fintech/NBFC postings show the role clearly: a Strategic Partnerships & Alliances Manager is expected to onboard NBFCs, banks and lending partners, negotiate partnerships, coordinate with product, sales, operations, legal and compliance, and understand digital lending, embedded finance and co-lending (WeCredit LinkedIn job listing). A Partnership Manager listing for lending distribution similarly names disbursal volume, active partners, conversion rates, customer-acquisition cost (CAC) and partner productivity as KPIs (Kashti Finserv listing via Glassdoor).

Partnership incentives should include portfolio quality, partner reconciliation, complaint rate and regulatory readiness. A partner manager who is paid only on disbursal will eventually sign a bad sourcing or default loss guarantee (DLG) arrangement.