The Consent Template CT004 finalized by the PFM Use Case Council which includes RIAs, PMs and AMC. This Consent Template provides a structured framework for obtaining consent from borrowers to monitor their financial activities for the purpose of wealth management and advisory services, ensuring alignment with industry best practices.
Please find below the parameters for AA Consent Template ID CT004 as finalized by the Lending Use Case Council:
Consent Template Information - CT004
| Consent Template Information | Description | Further Explanation |
|---|---|---|
| Consent Template ID | CT004 | 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 | Personal Finance | For Sahamati's internal records and explanation to the community |
| Use case | Wealth Management Services | To be used by FIUs that have an advisory charter under which they get into advisory contracts with the customer. Further, the FIUs have a fiduciary relationship with the customers which means they act as an advisor of the customer (and not as a distributor) and earn their fees/commission from the customer |
Consent Template Attributes and Values - CT004
| Consent Details (Attributes) | Values | Rationale |
|---|---|---|
| Purpose Text | As agreed by FIUs to show to the customer: To provide (Wealth Management / Advisory) Services | to ensure that the purpose explains the underlying use case explicitly and is easy to understand for the customer. Only portfolio managers offering non discretionary portfolio services can decide not to write the word advisory in the purpose text |
| As per ReBIT: Wealth management service | In line with per ReBIT Purpose Codes | |
| Purpose Code | 101 | In line with per ReBIT Purpose Codes |
| Purpose Code Category Name | Personal Finance | In line with per ReBIT Purpose Codes |
| FI Types | DEPOSIT, TERM_DEPOSIT, RECURRING_DEPOSIT, SIP, CP, GOVT_SECURITIES, EQUITIES, BONDS, DEBENTURES, MUTUAL_FUNDS, ETF, IDR, CIS, AIF, INVIT, REIT, GSTR1_3B | Requires a 360 degree view of a customer's finances to be able to provide advisory or portfolio management services |
| Consent Types | Profile, Summary, and Transactions | Requires a 360 degree view of a consumer finances and their profile to be able to provide advisory or portfolio management services |
| Fetch-type | Periodic | Requires a regular view of the customers finances to be able to provide advisory or portfolio management services |
| Maximum Frequency | 31 per month | -Based on Poll conducted among the Council members, 22 fetches per month (exchange and market working days in a month) are sufficient for the purpose of advisory. -Currently SEBI FIPs share only two years data in one data fetch request. Wealth advisors need 20 years of mutual funds statement data of the customer to be able to calculate returns and investment purchase dates of customers. -Hence, a buffer of 9 fetches have been added to 22 fetches to enable the FIUs fetch 20 years of data from SEBI FI types in data packets of two years each. |
| Maximum FI Data Range | 13 Months for other FI Types 20 years for SEBI FI Types | Deemed as sufficient to be able to offer wealth management or investment advisory for the customer While the Maximum FI Data Range is higher, the FIUs agree that they will do only incremental pulls over and above their last date of fetching data FIUs have agreed to not fetch insurance data on daily basis |
| Maximum Consent Validity | 1 Year | Based on Usual tenure of the Wealth Management and Portfolio Management Agreements |
| Maximum Data Life | 1 month | Considering as sufficient time for the FIU required to analyse the information and provide recommendations/advisory to the customer |
| Last published on: | 10th August 2024 |
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.
