Regi Tom Antony & Associates (RTA), Chartered Accountants in Kochi since 1997, acts as virtual CFO and internal auditor to non-banking financial companies (NBFCs). The CFO role covers business plans, budgets, variance analysis, cost of funds, board and lender reporting, and statutory audit support, including engaging with the statutory auditors. Internal audit covers risk-based branch, process, RBI compliance and IT reviews. Both rest on monthly reconciliations of the loan book (principal, interest and charges), control accounts such as foreclosure and collection suspense, and co-lending partner shares. The team includes staff with NBFC operations experience and works with gold loan, microfinance, vehicle, MSME, housing and investment NBFCs and their co-lending partners.
By Regi Tom Antony, FCA, CISA · Updated 3 November 2026
NBFC promoters need someone who can turn the loan book into a plan: how fast to grow, at what cost of funds, with how much capital and risk. Our CFO role sits with the promoter and the board, not only with the accounts team.
Annual budget and three-year plan by product and branch: disbursement targets, yields, cost of funds, credit cost, opex and capital needs.
Budget versus actual on disbursements, collections, yield, spread, credit cost and opex, with the reasons and the actions agreed.
Contribution by product, branch and channel after cost of funds, credit cost and allocated overheads, so growth goes where it pays.
Borrowing plans, cost of funds, covenant tracking, lender MIS and support for bank lines, co-lending and assignment partners.
Monthly MIS, quarterly board packs, KPI scorecards and a clear view of risk, compliance and capital.
Audit-ready books, schedules and reconciliations, PBC lists delivered on time, Ind AS and provisioning workings, and a single point of contact who engages with your statutory auditors, answers their queries and closes management letter points.
Policies, governance and reporting that let the NBFC grow into larger RBI layers, raise equity or attract a co-lending bank.
We act as outsourced or co-sourced internal auditor, reporting to the audit committee. Each review ends with ranked findings, agreed owners and a follow-up date, not a long list nobody reads.
An annual plan that ranks branches, products and processes by risk, so the audit effort goes where losses and RBI findings are most likely.
Sourcing, appraisal, sanction, documentation, disbursement, collection and closure, tested against policy and delegation limits.
Checks against applicable RBI directions, including KYC, fair practices code, asset classification and provisioning, and the returns calendar.
Packet verification, weight and purity records, LTV compliance, auction process and return-of-collateral timelines.
User access, maker-checker, back-dated entries and interface controls between the loan system and the ledger, from a CISA perspective.
Open findings tracked to closure and reported back to the audit committee every quarter.
We provide CFO, internal audit and statutory audit support. We do not act as statutory auditor for NBFCs we serve; instead we prepare the NBFC for its audit and work with its statutory auditors so it closes smoothly.
Every NBFC runs two ledgers: the loan management system, which knows each borrower, and the general ledger, which the auditor and RBI see. Small timing and mapping gaps between them compound every month until the balance sheet and the loan book no longer agree.
Principal outstanding, interest accrued and charges differ between the loan system and the books, often because of back-dated entries, reversals or product mapping errors.
Foreclosure, pre-closure, disbursement payable and collection suspense accounts accumulate old, unexplained balances that nobody owns.
In co-lending and assignment deals, each lender’s share of principal, interest and fees drifts from the partner’s own statement and the escrow account.
Budgets, variance reviews and audit findings are only as good as the books underneath. This is the work that makes them reliable.
Principal, interest, penal charges, processing fees and other charges reconciled loan-wise and branch-wise between the loan system, the general ledger and bank statements, with a clear list of breaks and their owners.
Foreclosure and pre-closure control accounts, disbursement payable, collection suspense, unidentified receipts, insurance payable and GST on charges, cleared and kept clear every month.
Partner-wise shares of principal and interest, escrow movements, servicing fee and loss guarantee positions, reconciled to each partner’s statements.
A single calendar of RBI returns, board approvals and policy reviews, with data checks before figures go into returns.
Overdue ageing, SMA and NPA classification, provisioning and, where Ind AS applies, review of expected credit loss inputs.
Maturity buckets, liquidity gaps and funding plans that the treasury and the board can read.
The reconciliation logic changes with the product. These are the patterns we see most often.
Packet and weight reconciliation between vault, loan system and books, auction and surplus accounting, and readiness for RBI’s 2025 directions on lending against gold and silver collateral.
Field collection and branch cash reconciliation, centre-wise demand versus collection, and portfolio-at-risk reporting.
Repossession and sale accounting, dealer payables and subvention, and overdue bucket tracking.
Sanction-to-disbursement controls, collateral tracking and early-warning MIS.
Tranche disbursement, construction-linked releases and interest computation checks.
Investment registers, fair value and income reconciliation, and RBI applicability reviews.
The Reserve Bank of India (Co-Lending Arrangements) Directions, 2025 apply from 1 January 2026. Each partner must retain at least 10% of every loan, the originating lender’s default loss guarantee is capped at 5% of outstanding loans, and changes in a loan’s SMA or NPA status must be shared between partners by the next working day.
Those rules only work if both partners’ books agree. We reconcile each lender’s share of principal, interest and charges, escrow flows, servicing fees and guarantee positions, and flag classification mismatches before they reach credit bureaus or returns.
Our analytics team turns loan system data into the views a promoter, CEO and board need, refreshed every month or every day.
Overdue buckets, roll rates, portfolio at risk and vintage curves by product, branch and officer.
Demand versus collection, bounce and recovery trends, and field team performance.
Cost of funds, lender-wise exposure, maturity profile and liquidity gaps.
One version of the numbers for management, board and lenders, built on reconciled data. More on our financial analytics and MIS reporting.
| FRAMEWORK | WHAT IT DOES | FINANCE TEAM IMPACT |
|---|---|---|
| Scale-based regulation | Places NBFCs in Base, Middle, Upper and Top layers by size and activity | Layer decides governance, capital, concentration and disclosure requirements |
| Consolidated Master Directions (29 Nov 2025) | RBI replaced thousands of circulars with function-wise directions for each regulated entity type | Policies, compliance calendars and checklists need re-mapping to the new references |
| Co-Lending Arrangements Directions, 2025 | Framework for loans jointly funded by banks and NBFCs, from 1 January 2026 | Partner shares, guarantees and classification must reconcile between lenders |
| Lending Against Gold and Silver Collateral Directions, 2025 | LTV caps of 85%, 80% and 75% by loan size, 12-month bullet loans, valuation, return and auction rules; compliance by 1 April 2026 | Vault, packet, valuation and auction records must tie to the loan system and the books |
| Companies Act, 2013, section 144 | Lists services a company’s statutory auditor cannot provide | We confirm independence before accepting any accounting or CFO engagement |
We confirm independence, agree the CFO and internal audit scope with the promoter and audit committee, and map products, branches, systems, partners and control accounts.
Loan system, general ledger and bank tied for a cut-off date, with every break listed by age, amount and owner.
Old control account balances cleared or escalated, mapping errors fixed, and a monthly reconciliation routine agreed.
Monthly reconciliations, variance review and board MIS, quarterly internal audit reports and the RBI calendar, on a fixed timetable.
Engagements are led by Regi Tom Antony, FCA, MBA (Australia), ACMA (UK), CGMA (USA), CISA (USA), a former Group CFO/COO with OSRAM/Siemens and Westcon Group. His CISA background matters in NBFCs, where most reconciliation breaks start in systems and data mapping.
The working team includes staff who have run reconciliations and operations inside NBFCs, supported by RTA’s analytics team for data extraction, automation and Power BI reporting.
Tell us your products, loan system and the reviews your audit committee wants. We will scope the CFO and internal audit role and show you what the first quarter would look like. Each month Regi also writes The CFO Desk, a LinkedIn newsletter for owners running businesses in the Gulf, overseas and India.