Each participant in the Account Aggregator ecosystem – AAs, FIPs, FIUs – will need to have the following contractual arrangements:
- An FIU with multiple AAs, for subscribing to the AAs’ service,
- An FIP, with multiple AAs, for authorizing access to the FIPs’ data, and
- An AA with its customers, when its own services are dependent or interlinked with FIPs and FIUs.
There are two ways of executing such contractual arrangements:
- Through a series of bilateral agreements – each FIP and FIU have to repeatedly undertake the legal process, with multiple AAs, and the AAs with their customers and with FIPs and FIUs. Such a process can add to varying terms, scopes, and could take time to negotiate and conclude. Such bilateral agreements may also be insufficient to address the interdependencies and inter-linkages among the participants vis-à-vis each other and the customers.
- Through acceptance of uniform multipartite contractual arrangement – anchored by Sahamati – through which the participant becomes part of the Sahamati Network and signs up to a set of common terms, that outlines the roles and responsibilities of each role the participant, viz. FIPs, FIUs, AAs and of the customers. In such a contractual framework, the participants have a nexus with each and every participant, with well-defined interdependencies and interlinkages and a commitment to adhere to common standards and protocols. The customers also receive a uniform and seamless experience with AAs that are part of the Sahamati Network
Sahamati, itself a non-profit industry alliance, anchors the Sahamati Network, enforcing (and evolving) these common terms, providing a common set of services – both technical (Central Registry, Token Service) and non-technical (governance, education, certification) – and is also part of the multipartite contractual framework with its own roles and responsibilities duly defined. Sahamati can be considered akin to AMFI, FEDAI, FIMMDA or Visa / MasterCard that brings together the various participants and technical service providers in its fold, with a view to nurture, develop and evolve the ecosystem together with the participants.
The multipartite contractual arrangement framework is a fair, superior, appropriate and right design for efficiency, network benefits and ensuring a level playing-field among all the participants while protecting customer interests. It also provides the comfort of uniformity, fair play and common roles and responsibilities of the participants as well as adherence to evolving standards and protocols, be it regulatory requirements – RBI Master Directions, ReBIT Technical Specifications – or market and other technical standards. It also lays down a uniform framework for addressing customer grievances and disputes in a neutral, independent manner, which, given the interdependencies and inter-linkages could be complex to resolve without such an enabling framework.
Hence, legal experts have helped us craft a single “Sahamati AA Ecosystem Participation Terms”, which encapsulates all the uniform, common, non-commercial, standard terms that are binding on each participant as well as customers and enforced by Sahamati.
With this, the benefit is:
- AAs, FIPs and FIUs have to sign up only once to the “Sahamati AA Ecosystem Participation Terms” and be interlinked with every other participant which has signed up.
- Commercial terms between each FIU and AA (or in the future, FIPs as well) or between customers and AA stays outside these Terms and are subject to market-discovery, bilateral understandings.
The design of the “Terms” accommodates a change-management process, similar to how APIs evolve. At this stage, we request you review and accept the Terms, and not ask for any changes in this version. If basis your review, if you have feedback or changes that you feel are desired, please do pipe it across so that we can factor it in when undertaking release of the next version/s of the Terms. If any items require clarifications, let us know and we would be happy to clarify.
To execute this document, please follow these steps:
1. Update Annexure 1 in the attached document with the Participant details and Regulator Registration Number (with validity date, if any)
2. Convert to PDF
3. Affix the digital signature on Annexure 1, and
4. Send the PDF version of the document to firstname.lastname@example.org