The Multi-Framework Problem
A lending product needs to comply with multiple regulatory frameworks, including KYC requirements, responsible lending and conduct obligations, credit bureau reporting rules, and data protection law. These requirements do not always align, and some product-specific questions may remain unresolved. Lenders therefore need to identify and address these issues before launch, rather than remediate compliance gaps after the product is live.
Our Framework
We conduct pre-launch regulatory audits that assess a product against the full range of applicable requirements, with particular focus on how those requirements interact in practice. Our experience advising NBFCs, lending service providers and technology partners gives us a broad view of how regulatory responsibilities are allocated and applied across the lending ecosystem. Where the law does not give a clear answer, we work through the issue from first principles and help the platform take a reasoned and defensible position. We then translate this analysis into a practical launch roadmap, identifying the changes required and the steps needed to implement them.
Applying It in Practice
We used this approach for a fast-growing digital lending platform backed by a global fintech group, building flexible credit products for India’s underserved millennials and Gen Z.
As part of its expansion, the platform was preparing to launch a new loan product for sole proprietors. We conducted a pre-launch regulatory audit of the proposed product and its underlying customer journey, processes and compliance requirements.
The review identified the key issues that needed to be addressed before launch. We advised on the changes required to the product and its implementation, and helped the platform reach defensible positions on questions where the regulatory framework did not provide a clear answer. The result was a clear roadmap for taking the product from design to launch. The Ikigai Law team on this matter comprised of Aparajita Srivastava, Astha Srivastava and Akshat Tenneti.
“A regulatory audit is more than a checklist exercise. A lending product can meet each requirement in isolation and still raise problems when those requirements come together in a single product and customer journey. The real work is in identifying those friction points before launch and working through the harder questions where the framework does not provide a clear answer. The aim is to help the business arrive at positions that are reasoned, practical and defensible as the product evolves.”
— Astha Srivastava, Principal Associate
Image credits: AI-generated
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