Digital lending breaks compliance in the five seconds between consent and disbursal.
KFS timing, bureau-pull scope, and AA consent that was written for one flow and reused in another - this is where the small gaps live.
What breaks here
The AA fetch type that doesn't match the flow
Loan underwriting needs ONETIME. A copy-pasted consent config leaves it at PERIODIC.
The Key Fact Statement that dispatches late
Or dispatches, but nobody logs that the borrower actually accepted it.
The bureau pull with the wrong consent scope
Consent taken for underwriting gets reused for a monitoring pull six months later.
A composite loan-origination codebase, checked against a live RBI Digital Lending Guidelines circular: the ranked fix list assembled in under two hours.
Six motions, in lending's language
KFS Monitor
Every Key Fact Statement dispatch checked for timing and a logged borrower acceptance.
Consent Fit-Check
A PR that reuses an AA consent config across flows gets flagged if the fetch type doesn't match the new flow.
Bureau-Pull Drift
A pull scope that quietly widened from underwriting to monitoring - reported as a delta.
Interpretation
Letter: what the RBI Digital Lending Guidelines say. Spirit: what a fair credit decision looks like. Both, cited.
Evidence Room
Every KFS dispatch, every AA consent, every bureau pull - assembled continuously.
Exceptions & Overrides
A deferred fix gets an owner and an expiry, not an anonymous “fix later.”
One pattern, two consent flows - and one of them is a gap
Account Aggregator consent is not one thing. A generic GRC tool checks “was AA consent taken.” RegVision knows underwriting consent and monitoring consent break differently - and checks each against the flow it actually belongs to.
{"consentStart": "2024-01-15T10:00:00.000Z","consentMode": "VIEW",x "fetchType": "PERIODIC",✓ "fetchType": "ONETIME","consentTypes": ["PROFILE", "SUMMARY", "TRANSACTIONS"],"fiTypes": ["DEPOSIT", "TERM-DEPOSIT", "SAVINGS-ACCOUNT"],"DataConsumer": { "id": "loan-origination-system@regvision" },"Customer": { "id": "****@onemoney" },"Purpose": { "code": "101", "text": "Loan Underwriting" },"FIDataRange": { "from": "2023-01-15T00:00:00.000Z", "to": "2024-01-15T00:00:00.000Z" },x "DataLife": { "unit": "MONTH", "value": 12 },✓ "DataLife": { "unit": "DAY", "value": 14 },x "Frequency": { "unit": "MONTH", "value": 1 }✓ "Frequency": { "unit": "ONETIME", "value": 1 }}I authorise sharing my financial data for Loan Underwriting via AA.
The agent flags and drafts. Your DPO and your engineers decide what ships. Nothing is auto-resolved.
Maturity
In build. The AA consent pattern above is real and running. The rest of the lending sub-flow library is being authored now.