Q1. Could you start by giving us a brief overview of your professional background, with a particular focus on your industry expertise?

16+ years of experience across the financial services domain. Managed Digital Lending Business, Colending Partnerships, Delivery Management, Co-lender Portfolio, Financial Operations in NBFC. Previously associated with NBFC/Fintechs such as Fibe (earlySalary), Cars24 Financial Services, and Ziploan.in & Hero Fincorp.

Built Digital lending Business and Co lending Partnerships for the last 6 Years. Expert in the setting of Lending Operations and Customer Service for 10 Years.

Managed and provided expertise in various financial products across the spectrum, ranging from Personal Loan, Business Loans, Two-wheeler loan, User Car Finance, Dealer Financing & Merchant Checkout.

Q2. Beyond traditional banks, how are digital NBFCs in 2026 leveraging Co-lending with other NBFCs to manage capital adequacy without diluting equity?

Co-lending with banks and bigger NBFCs has opened a good supply-side opportunity for Digital lenders. Digital Lenders, being more tech savvy and with a lighter Operating model, have more penetration in terms of demand (Lead). Banks, being highly regulated by the RBI are difficult and more time-consuming to capture as a Co-lending Partner. They have a very high threshold of compliance and infosec, but with very little risk appetite. Moreover, Banks are more comfortable working with digital lenders with higher credit ratings (AAA or so).

Mostly, these digital lenders do not fit the selection criteria of the banks for lending.

While co-lending with NBFCs is comparatively easier than with banks. NBFCs have a higher risk appetite as compared to banks; they are more agile in structure & systems.

Thus, co-lending between NBFCs and Digital NBFCs has created a win-win for both. Lending NBFCs get a good growth portfolio without any opex, while Digital NBFCs can cater to a large customer base and can earn on servicing.

Q3. In your opinion, what "Decision-Grade" structures are actually passing RBI audits in 2026 since the 5% cap?

Most of the prominent Digital NBFCs were already following the 5% FLDG structure even before 2026.

Some structures that are assumed to be good with RBI are:

1. Customer ROI to be blended rate of both NBFC and both NBFCs to have similar ROI for their respective lending Portion.
   Digital Lender-originator to keep all Interest & PF on its 10% or 20% loan portion and  to get a fixed Service fee on servicing of the majority lender portion. Digital Lenders(Originator or Junior lender) -service fee is either based on collection amount or AUM.
2. Customer ROI to be blended, but both Lenders to lend at different ROI based on their Pricing policy.
   Both to keep their share of revenue. Servicing lender to get a fixed servicer fee.

Q4. With the rise of Account Aggregators (AA), how has co-lending underwriting shifted from Income Estimation to Verified Cash-Flow modeling?

Income Estimation is still being used for bureau-based underwriting.

AA, being easier to use and just a click consent-based, has majorly replaced the Manual bank statement/Bank statement fetching through online services.

With AA coming to impact, more customers have started moving from bureau-based to banking-based underwriting, as AA is simpler for customers as compared to Bank statement fetching through internet banking or offline upload.

Also, with AA, Lenders can have recursive consent for fetching bank statements, helping lenders in repeat underwriting of customers, thus enhancing the underwriting capabilities of lenders.

Q5. In digital lending, we see "stacking". How can partnership operations be engineered to catch intra-day leverage that hasn't hit the Bureau yet?

Bureau reporting has moved from a monthly to a weekly basis, making it easier to stack, but still, there is a risk of Intra-day stacking.

Services like Account Aggregators can help in avoiding multiple disbursals or stacking. Checking the banking statement through AA or getting a real-time bank account statement just before disbursal could avoid stacking.

Also, alternative services like scraping of messages or alternate data of smartphones, i.e., checking multiple app installs, etc., could help in catching intra-day leverage.

Q6. From your point of view, how have the APIs been re-engineered to ensure that Bank partners can approve loans in near-real-time without losing the "Instant Loan" value proposition?

Mostly, underwriting at Lending Partners has moved to BRE-based score cards. These scorecards give output on a real-time basis based on Bureau and Banking parameters.

Direct API integration between both the Partners in co-lending has played a major role in approving and disbursing loans on a real-time basis. Once the Originating partner approves the case through its BRE , the same is forwarded to the Co-lending partner through API. Instantly, the Co lending partner's BRE is hit, and an instant real-time call back is given to the originating partner.

Based on the callback, the customer gets the disbursement.

Q7. If you were an investor looking at companies within the space, what critical question would you pose to their senior management?

The major question would be:

1. Business Volumes & Plan ahead
2. Delinquency
3. Key Management team & Structure
4. P&L & Balance sheet
5. Tech, Compliance & Infosec