Under the Reserve Bank of India (Co-Lending Arrangements) Directions, 2025, which apply from 1 January 2026, each co-lending partner must retain at least 10% of every loan, the originating lender may give a default loss guarantee of up to 5% of outstanding loans, and partners must share any change in a loan’s SMA or NPA status by the next working day. Co-lending reconciliation checks that each partner’s share of principal, interest, charges, escrow flows, servicing fees and guarantee, and the loan’s asset classification, agree in both lenders’ books.
| AREA | REQUIREMENT |
|---|---|
| Effective date | 1 January 2026, with early adoption permitted |
| Minimum retention | Each partner holds at least 10% of each loan (the earlier priority sector framework required 20%) |
| Default loss guarantee | Originating lender may provide up to 5% of outstanding loans |
| Asset classification | Change in SMA or NPA status shared with the partner by the next working day |
| Credit bureaus | Each lender reports its share to credit information companies |
| Customer interface | A single point of customer interface identified, with a Key Facts Statement |
| Disclosure | Active co-lending partners listed on the lender’s website; quarterly or annual disclosures in financial statements |
| KYC | Partner lenders may rely on the originating lender’s KYC |
Each break is small, but over thousands of loans it shows up in returns, credit bureau data, provisioning and the auditor’s questions.
Where loans are sourced or collected through Business Correspondent (BC) partners, reconcile loans sourced and amounts collected per BC with the loan system, the collection account and the BC’s statements, and check commissions and settlement timelines. Field cash that has not reached the books is the most common gap.
See how this fits our wider NBFC reconciliation work, alongside LOS and LMS to general ledger, and statutory reconciliations such as income against TDS and fees against GST.
We review your books, controls and systems, and show you what your own Decision Brief would say. Each month Regi also writes The CFO Desk, a LinkedIn newsletter for owners running businesses in the Gulf, overseas and India.