Bansal Credits Limited
Penalty: ₹6.20 LakhKey Regulatory Details
| Order Date | December 02, 2025 |
|---|---|
| Inspection Date | March 31, 2024 |
| Regulatory Act | Section 58G(1)(b) read with 58B(5)(aa) of RBI Act, 1934 |
| Reason for Penalty |
1. Failure to put in place a system for alerts for suspicious transactions. 2. Failure to upload KYC records to the Central KYC Records Registry (CKYCR). |
Root Cause Analysis (RCA)
- Technological Gap: Absence of an automated AML (Anti-Money Laundering) transaction monitoring solution capable of generating scenario-based alerts.
- Process Failure: Lack of API integration or batch-processing workflows to push customer data to CKYCR immediately upon onboarding.
- Oversight: Potential reliance on manual transaction reviews which are prone to error and unscalable.
Preventive Controls
- System Implementation: Deploy a robust AML software with predefined rule engines (e.g., high value, rapid velocity) to trigger alerts automatically.
- CKYCR Integration: Implement a “Maker-Checker” process where account activation is restricted until CKYCR upload confirmation is received.
- Periodic Audits: Monthly reconciliation between internal customer databases and CKYCR data dumps.
Lessons Learnt
Compliance is no longer just about policy documents; it requires active technological intervention. Financial institutions must treat the CKYCR upload as a critical step in the onboarding lifecycle, not a post-facto administrative task. Furthermore, “suspicious transaction monitoring” cannot be manual; it requires demonstrable algorithmic systems.
RBI Press Release
Truhome Finance Limited
Penalty: ₹3.10 LakhKey Regulatory Details
| Order Date | December 03, 2025 |
|---|---|
| Inspection Date | March 31, 2024 |
| Regulatory Act | Section 52A of the National Housing Bank Act, 1987 |
| Reason for Penalty | Failure to obtain Permanent Account Number (PAN) or Form No. 60 in certain loan accounts. |
Root Cause Analysis (RCA)
- LOS Deficiency: The Loan Origination System (LOS) likely did not have “Hard Stops” configured to prevent loan disbursement without PAN/Form 60 data entry.
- Documentation Fatigue: Operational staff may have bypassed mandatory fields to expedite disbursals.
- Compliance Training: Inadequate understanding of Income Tax Rule 114B among frontline staff regarding mandatory PAN requirements.
Preventive Controls
- System Validation: Configure the core lending system to make the “PAN” or “Form 60” field mandatory. The system should block sanction letter generation if fields are empty.
- PAN Validation API: Integrate NSDL/UTIITSL APIs to validate the PAN in real-time during the application stage.
- Post-Disbursement Audit: Implement a T+1 sample check by the Central Processing Unit (CPU) to verify documentation completeness.
Lessons Learnt
Basic statutory documents like PAN are non-negotiable. The lesson here is the importance of System-Driven Compliance over Human-Driven Compliance. Regulatory fields must be “mandatory” at the database level to remove human discretion or error from the process.
RBI Press Release
Keertana Finserv Limited
Penalty: ₹3.10 LakhKey Regulatory Details
| Order Date | December 02, 2025 |
|---|---|
| Inspection Date | March 31, 2024 |
| Regulatory Act | Section 58G(1)(b) read with Section 58B(5)(aa) of RBI Act, 1934 |
| Reason for Penalty | Failure to take prior written permission of RBI while appointing a director, resulting in management change of >30% of directors. |
Root Cause Analysis (RCA)
- Governance Oversight: The Secretarial Department failed to track the cumulative percentage change in the Board of Directors composition.
- Interpretation Error: Lack of clarity on the definition of “Change in Management” as per RBI’s specific Directions for NBFCs.
- Process Gap: Nomination and Remuneration Committee (NRC) agenda did not include a “Regulatory Approval Check” prior to recommending appointments.
Preventive Controls
- Board Composition Tracker: Maintain a dynamic tracker of Board changes to flag when the 30% threshold is approaching.
- Pre-Appointment Checklist: Mandatory sign-off from the Compliance/Legal Head confirming if RBI approval is required before the Board resolution is passed.
- External Review: Periodic review of Corporate Governance practices by an external firm to ensure alignment with RBI Master Directions.
Lessons Learnt
Corporate Governance violations are viewed seriously by the regulator. The key lesson is that Change in Management is a regulated event, not just an internal corporate decision. Companies must calculate the “30% turnover rule” continuously to avoid inadvertent breaches of the “Prior Permission” clause.