The Consent Template CT042 finalized by the Lending Use Case Council to facilitate monitoring of the third parties such as Sourcing Partners, Collection Agents and Employees.
Banks and NBFC require their agents to maintain transparency in all monetary transactions conducted by their agents to prevent fraud, misrepresentation, or unauthorized practices. Monitoring ensures that all actions are in compliance with banking and financial regulations. Regular monitoring of Agents also helps Banks and NBFCs identify underperforming or non-compliant agents early, allowing them to take corrective action before issues escalate. Building on this use case, the Council also agreed to include internal Employees as well, to ensure a consistent and comprehensive approach to monitoring counterparty risks.
Consent Template Information – CT042
| Consent Template Information | Description | Further Explanation |
|---|---|---|
| Consent Template ID | CT042 | For Sahamati's internal records and explanation to the community |
| Status | Active | For Sahamati's internal records and explanation to the community |
| Use Case Category | Account Monitoring | For Sahamati's internal records and explanation to the community |
| Use case | Risk Monitoring of Recovery Agents/ Sourcing Partners | Collection agents and sourcing partners are monitored by NBFC, Banks, particularly in the context of risk monitoring, for several reasons, especially when it involves monetary transactions. This does not include Vendors and Partners who may be reviewed prior to agreement but not monitored on a regular basis. This is further extended to employee disclosure as per regulatory requirements. |
Consent Template Attributes and Values – CT042
| Consent Details (Attributes) | Values (v1.0) | Value (v1.1) | Rationale |
|---|---|---|---|
| Purpose Text | As agreed by FIUs to show to the customer: To monitor the counterparty risks of Recovery Agents / Sourcing Partners. | As agreed by FIUs to show to the customer: monitor the counterparty risks of Recovery Agents / Sourcing Partners/Employees | NBFC and Banks, have regulatory requirement to monitor their agents and partners for operational and other counterparty risks. Employees of regulated institutions are required to disclose their financial transactins under regulations, especially for commerical banks. |
| As per ReBIT: Explicit consent for monitoring of the accounts | As per ReBIT: Explicit consent for monitoring of the accounts | ||
| Purpose Code | 104 | 104 | Continuous monitoring purpose code |
| Purpose Code Category Name | Account Query and Monitoring | Account Query and Monitoring | As per ReBIT |
| FI Types | Deposits, GSTN | Deposits, GSTN | Based on Regulations for Audit/review of the Partners/Agents |
| Consent Types | Profile, Summary, Transaction | Profile, Summary, Transaction | Based on Regulations for Audit/review of the Partners/Agents |
| Fetch-type | Periodic | Periodic | Based on regulations, Agents/Collection agencies are reviewed periodically. |
| Maximum Frequency | 1 per month | 1 per month | Based on current usage - Agents/Collection agencies are reviewed periodically. A monthly review has been suggested by the Council as a good start for the template, this will be revisited in the next review meeting |
| Maximum FI Data Range | 6 months | 6 months | Based on typical range of data / transactions that are needed by the FIU to verify and understand the business of the partners |
| Maximum Consent Validity | 1 year | 1 year | Council agreed that the validity of the consent to be co-terminous with the agreement. Based on the average terms of the collection agents, this limit was considered fair by the Council. |
| Maximum Data Life | 90 days | 90 days | Based on the average monitoring period, to review the history of collections |
| Last published on: | 31st May 2024 | 19th January 2026 |
Please note that the parameters of the individual consent templates in the Consent Template Library represent upper bounds for the respective use cases, as decided in the relevant User Councils. The parameters in the consent templates should be treated by participant(s) as outer limit(s) and not be construed as legal advice in any manner. Participants are encouraged to review their use case(s) and ensure compliance with applicable laws, including the RBI Master Directions on NBFC-AA and the DPDP Act.
Sahamati will publish additional consent templates as the AA ecosystem evolves based on discussions in the relevant Use Case Councils and the Fair Use Committee. Existing consent templates may also be revised based on statutory and regulatory guidance, including the DPDP Act and the Rules issued thereunder.