NBFCs and financial services

Establish the regulatory perimeter

Separate lending on own account, investment holding, factoring, servicing and technology activities. Assess registration or exemption under the current framework for the actual business, including its assets, income, funding and customer relationships. A company’s objects clause does not by itself authorise a regulated financial activity.

Record the applicable category, certificate conditions and governing directions. Do not infer permission to accept public deposits from ordinary company incorporation or an NBFC registration alone.

Turn obligations into accountable records

Maintain a register covering the directions applicable to the entity, regulatory returns, board policies, inspections and action items. Assign an owner and evidence location to each requirement. Revisit the register when funding, size, products, ownership or group structure changes.

Capital, prudential, governance and customer-conduct requirements depend on the applicable framework. Use current instruments for the specific entity rather than copying thresholds or filing schedules from another NBFC.

Connect loan systems and the ledger

• Sanctioned terms, disbursements, repayments and borrower balances reconciled to bank records.
• Interest, fees, overdue status, modifications and recoveries supported by transaction history.
• Classification and provisioning workings under the applicable accounting and regulatory requirements.
• Collateral documents, releases, guarantees and custody responsibilities.
• Borrowings, covenants, liquidity forecasts and related-party exposures.

Keep customer conduct visible

Preserve onboarding evidence, approved disclosures, complaints and resolution records with controlled access. Review outsourced collections and other customer-facing arrangements with the responsible compliance owner. Digital distribution introduces additional product, data and partner questions; it does not remove the lender’s need to supervise its customer journey.

Example: expanding into a new loan product

Before launching a secured product, the business should align sanction documentation, security creation, custody, valuation, repayment accounting and release procedures. Finance should be able to reconcile the product from first disbursement through closure, while management can identify overdue actions and complaints.

Separate support from regulated decisions

Kosha can support corporate records, bookkeeping, reconciliations, management reporting and evidence preparation. Regulatory eligibility, prudential interpretation, statutory assurance and specialist financial-services advice require a defined professional scope. No approval outcome or registration timeline is promised.

Prepare a loan-system reconciliation

For bookkeeping and monthly-close support, identify the loan-system extract, ledger period and bank accounts being reconciled. Keep the extract date and cut-off time with the file so later collections or backdated changes can be explained.

For example, a payment partner may settle several borrower receipts as one bank credit after deducting its charges. Retain the receipt-level allocation, settlement reference, charges and bank entry. An unmatched settlement should stay on an exception list until the responsible team resolves its allocation; it should not be assigned to a borrower merely to clear the difference.

Agree which approved schedules finance will receive for interest adjustments, modifications and other specialist calculations. Record the owner, version and outstanding questions for each schedule. The accounting handover should make those inputs traceable without substituting for the entity’s credit or regulatory decisions.