Module Map

The system blueprint is written for an Indian small and medium enterprise (SME) lender that may run branch, direct selling agent (DSA), digital, lending service provider (LSP), and co-lending channels. The design principle is strict state ownership: one module owns a record, other modules consume events or read models. This prevents the common failure where the loan origination system (LOS) says “disbursed”, the loan management system (LMS) has not booked the account, collections does not know the first repayment date, and the credit bureau file is wrong.

Regulatory constraints are module boundaries, not footnotes. Digital loans must route disbursement and repayment directly between the regulated entity (RE) and borrower or permitted end-beneficiary, with no LSP pool account, under the RBI Digital Lending Directions, 2025. KYC data, beneficial owners, ongoing due diligence and record retention belong to a controlled KYC domain under the RBI KYC Master Direction, 2016. Co-lending must maintain each RE’s share, escrow routing, blended borrower disclosure and borrower-level SMA/NPA alignment under the RBI Co-Lending Arrangements Directions, 2025. Income recognition, SMA/NPA tagging and NPA upgradation must be date-true under the RBI IRACP clarification, November 12, 2021 and current IRAC directions.

System Modules

Module	Owns	Does not own	Primary users	System of record tables	Key outbound events
Channel CRM	Raw leads, source attribution, campaign, DSA/connector handoff, telecalling disposition before login	Credit decision, KYC verification, sanction, live loan dues	Sales, call centre, DSA manager, partner manager	lead, source_attribution, channel_partner, campaign, lead_contact_event	lead_created, consent_captured, source_locked, lead_login_ready, lead_disqualified
DSA portal	DSA lead submission, document upload, coarse status, payout visibility	Bureau variables, credit memo, fraud signals, approval authority	DSA, connector, DSA ops	dsa_user, dsa_lead_view, dsa_document_upload, payout_claim	dsa_lead_submitted, dsa_document_uploaded, payout_hold_marked
Customer portal and DLA	Borrower self-service, consent capture, offer display, KFS acceptance, service requests	Internal underwriting, internal deviations, collections strategy	Borrower, promoter, guarantor	portal_session, customer_consent_action, offer_view, kfs_acceptance, service_request	borrower_consent_granted, offer_selected, kfs_accepted, service_request_created
Partner API gateway	API authentication, partner application intake, idempotency, partner callbacks, schema validation	Internal policy decision, partner commercial settlement	LSP, anchor, co-lender, marketplace	api_client, api_request_log, partner_application_ref, webhook_delivery	partner_application_received, partner_status_delivered, webhook_failed
Consent and privacy service	Consent artefacts, purpose, data scope, revocation, data-retention instruction	Parsed underwriting results	Borrower, compliance, integrations	consent_artifact, consent_scope, consent_revocation, data_retention_policy	consent_granted, consent_revoked, retention_expired
KYC and AML service	Party master, customer due diligence (CDD), beneficial owners, CKYC, V-CIP, sanctions/adverse media, periodic KYC	Credit approval, loan account accounting	KYC ops, AML officer, compliance	party, natural_person, business_entity, kyc_profile, beneficial_owner, screening_hit	kyc_verified, kyc_rejected, bo_added, sanctions_hit_cleared, rekyc_due
Document service and DMS	Document requirements, uploads, extraction, verification, executed document vault, versioning	Deciding whether a waiver is credit-approved	Operations, sales ops, legal, borrower	document_requirement, document_instance, document_extraction, executed_document, vault_packet	document_uploaded, document_verified, deficiency_raised, document_pack_locked, originals_vaulted
LOS workflow	Application lifecycle from login to loan booking handoff, queue assignment, SLA, conditions, audit trail	Live dues, interest accrual, final accounting ledger	Sales ops, credit, RCU, legal, valuation, ops	application, application_party, workflow_task, condition, queue_assignment	application_submitted, docs_complete, credit_submitted, sanction_accepted, loan_booking_requested
BRE and decision service	Rule versions, eligibility, scorecards, pricing bands, deviations, automated decisions	Human committee minute, post-booking repayment accounting	Credit policy, risk analytics, credit manager	rule_set, rule_version, rule_execution, scorecard_result, deviation	bre_executed, rule_failed, deviation_raised, eligibility_approved, pricing_computed
Credit workbench	Credit appraisal memo (CAM), financial spreading, analyst recommendations, committee decisions, DoA resolution	Disbursement maker-checker, cash posting	Credit analyst, credit manager, committee	credit_assessment, financial_spread, cam, approval_request, committee_decision	cam_submitted, authority_resolved, credit_approved, credit_rejected, condition_added
Collateral and security service	Collateral assets, owners, title chain, legal opinion, valuation, insurance, CERSAI/ROC filings	Repayment collections, borrower service requests except release	Legal, technical, ops, credit	collateral_asset, collateral_owner, legal_opinion, valuation_report, security_charge, cersai_filing, roc_charge_filing	collateral_approved, charge_created, cersai_filed, roc_srn_received, charge_satisfied
Documentation and execution service	Document checklist, generation, stamp duty, e-sign/wet-sign evidence, guarantee execution	Credit term approval and pricing	Operations, legal, borrower	document_checklist, stamp_certificate, signature_event, guarantee, documentation_exception	document_generated, stamp_paid, esign_completed, wet_signature_verified, documents_executed
Disbursement service	CP verification, bank account verification, mandate status, tranche instruction, payment instruction	Sanction approval, post-booking schedule recalculation	Operations maker/checker, treasury	disbursement_request, condition_clearance, bank_account_verification, mandate, tranche, payment_instruction	cp_cleared, mandate_activated, payment_initiated, disbursement_posted, disbursement_failed
LMS core	Loan account, facility, repayment schedule, demands, receipts, appropriation, interest, charges, DPD/SMA/NPA, closure	New application underwriting	Operations, finance, servicing, collections	loan_account, facility, schedule_version, repayment_due, loan_transaction, asset_classification	loan_booked, demand_generated, receipt_posted, dpd_changed, loan_closed
Collections platform	Delinquency cases, allocation, PTP, tele/field/legal workflows, agency activity, settlement proposal	Regulatory asset classification calculation source; it consumes LMS classification	Collections, recovery, agency manager, legal	delinquency_snapshot, collection_case, case_allocation, contact_attempt, ptp, settlement_proposal	case_opened, ptp_recorded, field_visit_completed, settlement_approved, case_closed
Finance and GL adapter	Accounting event mapping, GL posting, suspense, reconciliation, DSA payout, tax splits	Customer-facing statements unless sourced from LMS	Finance, treasury, audit	accounting_event, gl_posting, bank_reconciliation, suspense_item, payout_ledger	gl_posted, reconciliation_break_created, payout_accrued, payout_reversed
Co-lending and partner ledger	Partner shares, escrow split, blended rate, partner status exchange, DLG set and invocation	Base loan schedule; LMS remains source for borrower dues	Partner ops, finance, risk, co-lender	co_lending_arrangement, partner_share, escrow_movement, partner_ledger, dlg_set, partner_status_event	partner_share_booked, escrow_reconciled, partner_dpd_sent, dlg_invoked
Compliance, audit and reporting	Audit trail, regulatory evidence, CIC reporting extract, KFS archive, grievance control, access review	Operational approval except compliance holds	Compliance, internal audit, statutory audit	audit_event, regulatory_report_run, cic_submission, kfs_version, complaint, access_review	audit_event_recorded, cic_file_generated, complaint_escalated, access_review_due

The BRE module is detailed in BRE functional specification for decision contracts and BRE runtime architecture for deterministic evaluation, scaling, replay and observability.

Cross-Module Contracts

Contract	Producer	Consumers	Required payload	Idempotency key	Failure handling
Lead to application	Channel CRM	LOS, consent service	lead_id, source, product, requested amount, identifiers, consent ref	lead_id	Duplicate creates a dedupe_match, not a second application.
KYC result	KYC service	LOS, LMS, compliance	party_id, KYC status, risk category, BO status, expiry/re-KYC date	party_id plus kyc_profile_version	Failed screening places application on compliance hold.
BRE decision	BRE	LOS, credit workbench	Rule version, pass/fail tree, score, limit, tenor, price band, deviations	application_id plus rule_version_id	External dependency failure retries; policy hard fail cannot be suppressed without deviation approval.
Document pack lock	Document service	LOS, documentation service, credit	Requirement status, verified documents, waivers, deficiencies	application_id plus checklist_version	New upload after lock creates a new version and reopens verification.
Sanction accepted	Credit workbench	LOS, documentation, KFS archive, co-lending	Sanction id, terms, conditions, KFS version, acceptance timestamp	sanction_id	Expired sanction blocks documentation and routes to revalidation.
Loan booking request	Disbursement service	LMS, finance, co-lending	Accepted sanction, cleared CPs, tranche, mandate, disbursement instruction	disbursement_request_id	LMS booking failure rolls LOS to booking_failed; no collections record is opened.
Repayment event	LMS	Collections, finance, co-lending, CIC reporting	Loan id, receipt, reversal, appropriation, DPD before/after	loan_transaction_id	Reversal creates compensating event; DPD recomputes from due ledger.
Asset classification event	LMS	Collections, finance, risk, co-lending	Borrower id, facility ids, SMA/NPA status, effective date, reason	borrower_id plus classification_date	Manual override requires maker-checker because it affects IRAC and CIC reporting.
Recovery agent assignment	Collections	Customer portal, notification service, compliance	Case id, agency, agent, valid dates, contact channel	case_allocation_id	Borrower notification must precede first recovery contact under RBI digital-lending and recovery-agent conduct requirements.

Source Of Truth Rules

Data object	Source of truth	Read-only mirrors allowed in	Rationale
Party identity and KYC status	KYC and AML service	LOS, LMS, collections, partner module	KYC/beneficial-owner duties are regulated under the RBI KYC Master Direction.
Application state	LOS workflow until loan_booked	Channel CRM, portals, partner APIs	Origination queues and pre-booking conditions need one owner.
Credit decision and DoA evidence	Credit workbench	LOS, compliance, audit	Approval authority must remain immutable after sanction.
KFS and borrower acceptance	KFS archive with LOS reference	Customer portal, document service, LMS	KFS must preserve APR, charges and schedule disclosure for covered MSME loans under RBI’s KFS circular.
Live dues, DPD and asset class	LMS	Collections, customer portal, co-lending, finance	IRAC classification must be computed from dues, receipts, reversals and waivers, not edited in collections.
Collection strategy and PTP	Collections platform	LMS, risk dashboard	Collections strategy changes daily and should not pollute accounting ledgers.
GL posting and reconciliation	Finance and GL adapter	LMS, co-lending, reporting	Accounting events must reconcile to bank and GL independently of UI status.
Partner share and DLG	Co-lending module	LMS, finance, compliance	Co-lending needs partner-wise books, escrow movements and DLG cap tracking.

Minimum Deployment Slices

Slice	Include	Exclude until later	Exit criteria
Origination MVP	CRM lead, LOS, consent, KYC, document checklist, BRE policy gates, credit approval, sanction	Co-lending, advanced scorecards, automated valuation	A policy-compliant unsecured loan can reach accepted sanction with audit trail.
Booking MVP	Documentation checklist, e-sign evidence, mandate, disbursement maker-checker, LMS booking, repayment schedule, GL event	Tranches, supplier financing, CERSAI filing automation	A booked loan has account number, schedule, first due date, accounting event and borrower communication.
Servicing and delinquency MVP	Demand generation, receipts, appropriation, DPD/SMA/NPA, collections case opening, PTP, payment link	Legal recovery, repossession, OTS	Missed EMI creates correct bucket and collections task from LMS event.
Secured SME extension	Collateral, valuation, legal opinion, security charge, insurance, CERSAI/ROC tracking, vault	Complex consortium security trustee workflows	A loan against property cannot disburse without approved charge or approved exception.
Partner/co-lending extension	Partner APIs, CLA config, partner share, escrow reconciliation, partner DPD exchange, DLG set	Portfolio sale/securitisation	Both RE shares reconcile within the 15-calendar-day rule in RBI CLA directions.

Sources

• RBI, Reserve Bank of India (Digital Lending) Directions, 2025
• RBI, Master Direction - Know Your Customer (KYC) Direction, 2016
• RBI, Reserve Bank of India (Co-Lending Arrangements) Directions, 2025
• RBI, Prudential norms on IRACP - Clarifications, November 12, 2021