What is the RBI 30-day post-sale feedback obligation under Para 101Y and Para 85Y?

Under the RBI Responsible Business Conduct (RBC) Directions effective 1 January 2027, every regulated entity (Commercial Banks, NBFCs, AIFIs) must establish a mechanism to seek customer feedback within 30 days of sale for credit and third-party financial products. Lenders must report findings half-yearly to the Board and provide full refunds plus compensation where mis-selling is established.

How does the SINTRIX in-window cure engine work?

SINTRIX identifies comprehension gaps between Day 3 and Day 8 post-disbursal, while cancellation windows remain open. For identified gaps, it routes the case to the lender's Nodal Grievance Officer to execute V1 corrective re-disclosure. The customer is informed of their rights and may re-consent with understanding or take a clean statutory exit; where mis-selling is established, the lender's process provides for refund and cancellation as required under RBI Para 101Z. This reduces dispute exposure before the Ombudsman or Consumer Commissions.

What is the difference between SKU A (Assured) and SKU B (In-House Engine)?

SKU A is a turnkey service where SINTRIX supplies technology and execution capacity over the client's own DLT-registered telephony, while the client's non-sales compliance vertical owns, directs and signs off the feedback function. SKU B is a software and rubric engine license where the client's internal staff or captive BPO dials the borrower, ensuring zero customer phone numbers leave the bank's network perimeter.

How does the Sale Integrity Record (SIR) comply with Bharatiya Sakshya Adhiniyam §63(4)?

The Sale Integrity Record (SIR) is a cryptographically hash-chained PDF and JSON artefact that retains page-level quoted clause text snippets alongside recorded customer voice transcripts. It is designed to support §63(4) BSA electronic evidence certification on demand across the RBI Ombudsman, Insurance Ombudsman, and Consumer Commissions.

RBI RBC Directions · Effective 1st January 2027

Prove Customer Understanding, Not Just a Signature.

The conduct-assurance layer for Indian banks, NBFCs & their lending partners. On a Board-approved sampling basis, we verify credit-linked, bundled and third-party financial sales, detect comprehension gaps, and execute corrective re-disclosure inside the cancellation window.

A sub-90-second, consent-driven conduct verification engineered to validate genuine borrower comprehension, support in-window corrective disclosure, and keep a defensible, evidence-backed record.

Aligned to RBI Responsible Business Conduct Directions
Structured to BSA §63(4) evidence standards
Frictionless, consent-driven verification
Zero Phone-Number Transfer Option (SKU B)

Launch Interactive Demo

SAMPLE INGEST · #SIR-2026-MH-8921

Nashik · Gold Loan ₹3,10,000

Ingest KFS + Certificate of Insurance
Loan KFS & policy schedules — even skewed scans.
Structured document reconciliation
Window length, trigger type, delivery-log evidence.
Multilingual contact ladder
English & Hindi workflows · regional Indic templates configured per lender book.
In-window remediation protocol
Corrective re-disclosure executed at the earliest safe point in-window.

REMEDIATED · IN-WINDOW

SHA-256 · STRUCTURED TO BSA §63(4)

The RBI Responsible Business Conduct Directions take effect on 1 January 2027. The Board's advertising and sale policy should be in place by then.

84days to the
effective date

The Problem · Regulatory Reality

January 2027 Regulatory Shift

From 1st January 2027, RBI's Responsible Business Conduct framework is set to require lenders to evidence actual customer comprehension within 30 days of sale — not just hold a signature. Today's compliance stack was not built for that.

Before SINTRIX

Generic SMS surveys
Compliance discharged via low-response generic SMS surveys.
Late discovery
Mis-selling surfaces months later via RBI Integrated Ombudsman or Consumer Commission — mandatory full premium refund, compensation awards, and supervisory conduct penalties.
Signature defence
Relies on a signature in a document the customer may not have read.
Zero field visibility
Limited visibility into field-DSA and branch-counter conduct.

With SINTRIX

Board-approved sampling
Sampling policy with logged RNG seeds and attainment reports.
Day 3–8 detection
Gaps detected when remediation is a documented re-disclosure (V1) or clean cancellation.
Falsifiable rubric
Recorded, voice-verified customer words + retained clause snippets.
DSA scorecards
DSA-level gap-rate scorecards with confidence intervals (n ≥ 50).

Regulatory anchors — RBI Responsible Business Conduct Directions · RBI Managing Risks in Outsourcing Directions (2025) · Bharatiya Sakshya Adhiniyam (BSA) §63(4).

Proprietary Methodology

The In-Window Cure Engine

Conduct protection begins upon verified receipt of the policy certificate. SINTRIX operates entirely inside this critical window — identifying and remediating exposure while it still carries a compliance margin.

Conduct window · opens at document receiptWithin regulatory window

DAY 0

CoI deemed receipt

DAY 3–8

Cure executed

WINDOW CLOSES

Clean margin

Cure target

Earliest safe point in-window

Executed with a clean compliance margin before the window closes.

Anchored to verified CoI receiptRemediation at the earliest safe pointClose reached with margin

The Window

Anchored to document receipt

Cancellation rights run from receipt of the policy document — 30 days for eligible life/health policies; contractual for group and general covers, per the Certificate of Insurance.

Our Position

Earliest safe point

Remediation is timed to the earliest point where the customer can act with clarity — so exposure is corrected while it is still cheap.

V1 · Default

Non-solicitation re-disclosure

Corrective re-disclosure by the lender's compliance desk. The customer either re-consents with understanding or takes a clean cancellation / refund. No retention push.

Evidence · Reporting

Tamper-evident record & Board pack

Every case is sealed into a Sale Integrity Record, and DSA/branch gap rates, closure tiers and sampling logs roll up into the half-yearly Board report required under RBI Para 101Y.

Detect

SINTRIX Core™ reconciles declared document terms against actual customer comprehension signals.

Isolate

Each exposure is indexed, graded and routed by severity across your branch and DSA network.

Remediate

Remediation is executed between Day 3 and Day 8, preserving a clean compliance margin.

Certify

Every case is sealed as a tamper-evident SIR for the Board, internal audit and regulatory examination.

Proactive remediation reduces dispute exposure; it does not erase a point-of-sale breach. Where mis-selling is established, the lender's process provides refund and cancellation under RBI Para 101Z.

Evidentiary Standard · Interactive Inspector

The Sale Integrity Record (SIR)

Not a vague survey score. A tamper-evident evidentiary record marrying ingested KFS clause snippets, verified customer responses, and rubric determinations — structured to the electronic-evidence standards of BSA §63(4), across Indic languages.

Core Workflows: English & HindiRegional Indic cohorts configured per lender book

SIR-2026-KA-7001.pdfCOMPREHENSION 96/100 · CLEAN

Generated: Within Cancellation Window

Ingested Metadata & Identity Identity Verified

CustomerBorrower #***001 (Age 29)

Originating BranchBengaluru Indiranagar, KA

Loan FacilityPersonal Loan · ₹4,20,000

Attached CoverCredit Life Shield (₹9,200)

Disbursal Date04 Sep 2026

Identity ChecksDOB + Last 4 of Loan (MATCH)

Verification ChannelMESSAGE VERIFICATION · CLEARED

Consent-based message check (English)

The structured comprehension prompt was answered and self-verified at first contact — no recorded voice leg required.

“Yes — I understand the ₹9,200 life cover is optional and billed separately from my loan.”

Structured Term Sheet vs. Customer Perception DeltaVERIFIED CONGRUENT · NO GAP

Ingested Clause 4.1 (KFS Page 2)OCR Confidence: 99.8%

“Credit protection insurance is an optional financial risk-mitigation product. Customer consent is obtained separately from the primary loan agreement.”

Comprehension Rubric · Structured AssessmentPASS · COMPREHENSION 96/100

Customer Perception: Clear awareness of voluntary nature, exact deduction amount, and coverage benefits. Full alignment with KFS Clause 4.1.

Regulatory risk: Negligible. Clean proof of informed consent under RBI RBC & Consumer Protection Act.

Evidentiary Archive SealedRECORD ARCHIVED

Automated cryptographic certificate issued. Cryptographic hash recorded in institution's monthly conduct audit roll.

Audit Trail Ready: Available for RBI supervision / inspection & internal audit sampling.

Tamper-Evident Block #148092 · SHA-256 ChainedStructured to Bharatiya Sakshya Adhiniyam §63(4)

Full specimen shared on request

The complete Sale Integrity Record — clause mapping, verification channel and sealed evidentiary payload — is shared with evaluators under NDA.

* Redacted sample generated from SINTRIX Synthetic Compliance Testing Corpus.

Commercial Models · Architectural Choice

Two-SKU Architecture: Solved for RBI Outsourcing

Under the RBI 2025 Outsourcing Directions, some lenders demand full turnkey execution, while others cannot let a single borrower mobile number cross outside their perimeter. SINTRIX provides a dedicated architecture for both. Coverage is governed by your Board-approved sampling policy — RBI expressly permits statistically valid, random customer selection, with 100% review of defined high-exposure cohorts.

SKU A · ASSURED

Turnkey Conduct Assurance

Full-stack execution. We ingest your disbursal files, parse KFS docs, drive multilingual outreach over your DLT-registered 1600-series service telephony, and deliver audit-ready SIRs. Messaging runs via Meta WhatsApp Business and DLT SMS (BSP/Meta process the contact number as sub-processors).

Engagement Structure · Turnkey

Custom Enterprise Scope

Tiered by monthly loan disbursal volume · Function owned and directed by the client's compliance vertical

Multilingual contact execution over the client's DLT-registered 1600-series (transactional / service) telephony
Delivered under the client's DLT registration (TCCCPR); SINTRIX is a registered telemarketer where applicable
Feedback function owned, directed and signed off by the client's own non-sales compliance vertical
Automated structured parse & OCR on all ingested KFS & CoIs
Complete delivery of tamper-evident SIRs and monthly Board compliance packs
Complements (does not replace) the insurer's own pre-issuance verification call
Best for: Lenders seeking execution capacity, not a sales channel

Zero Phone Transfer Option

SKU B · IN-HOUSE ENGINE

In-House Engine & Rubric

Data minimisation. You host the software, or keep borrower phone numbers isolated inside your perimeter. Your staff or existing BPO dials; SINTRIX scores transcripts and generates SIRs.

Engagement Structure · In-House Engine

Software License Model

Annual platform license + audit packs · Zero customer phone transfer

Software & rubric engine only — runs on client premise or dedicated India VPC
Zero customer phone numbers ever touch or leave SINTRIX infrastructure
Designed to reduce RBI outsourcing & third-party data concerns
Client's internal team or captive BPO executes all voice/outreach touches
Full scoring rubric, exception dashboard, and SIR generator included
Best for: High-sensitivity banks & large NBFCs with strict internal calling policies

Where SINTRIX deploys fastest

Finance-sector segments

Banks & SFBs

Conduct-assurance for on-book credit and third-party distribution

Mid-Market NBFCs

Field-DSA oversight and Board-ready sample governance

Digital Lending Apps & Fintech NBFCs

Conduct gate for partner-lending journeys

Co-Lending / LSP Oversight

Evidencing the regulated entity's oversight of partner conduct

Interactive Economics · Board Dial

CCO Cost-Dial Calculator

Illustrative Model

Remediation is not an uncontrolled risk; it is a board-governed dial you configure. Simulate your institution’s post-disbursal volume to model indicative dispute exposure against proactive assurance.

Institution Parameters

Monthly Loan Disbursals & Distributed Policies5,000 accounts/mo

1,000 (Boutique NBFC)10,000 (Mid-Market SFB)20,000+ (Large NBFC)

Estimated Comprehension Gap Rate

18% illustrative

5% (Strict Direct-to-Consumer)20% (Industry Average DSA)35% (High Agency Friction)

Coverage scope (per your Board sampling policy)

Default protocol · Non-solicitation re-disclosureCorrective disclosure by the lender's compliance desk. The customer either re-consents with understanding or takes a clean cancellation / refund. SINTRIX does not run a retention push.

* Illustrative modelling for institutional risk governance. Actual coverage follows your Board-approved sampling policy. Figures are planning estimates, not commitments, and are distinct from platform subscription fees.

Indicative Impact ModelILLUSTRATIVE · ANNUAL

Modelled annual in-window remediations

3,610cases documented

95.5% modelled closure· evidence structured to BSA §63(4)

Client-Controllable Remediation Outlay

₹9L – ₹31Lp.a. variable dial

Illustrative client-side refund and handling outlay. Coverage follows your Board-approved sampling policy, so this is a planning view, not a commitment and not an uncontrolled liability.

Comprehension Exceptions Surfaced

3,780cases identified

Across 21,000 in-scope accounts at an illustrative 18% comprehension gap rate.

Board Governance Assurance

Table ready quarterly Board Packs with RNG seed sampling logs and DSA-by-DSA variance distributions.

Door-Opener Engagement · 30-Day Sprint

Active Cohort Risk Diagnostic

Do not wait for 1st January 2027 to discover your real field mis-selling exposure. Avoid cumbersome months-long historical extraction debates: test SINTRIX on your upcoming 30-day disbursal cohort to quantify actual comprehension drift and remediation efficiency.

Stratified Sample Audit: 350–400 total files (trailing historical audit + client-certified control stratum + live-window cure test)
Empirical branch & DSA mis-selling gap rate distribution report across active channels
Live demonstration of the Day 3–8 in-window cure test without core disruption
Complete Board Advertising & Sale Policy Template ready for Board tabling before the Directions take effect on 1 January 2027
Zero-friction deployment via secure API or encrypted batch upload (transient processing, no persistent SINTRIX copy)

Board policy to be in place before 1 January 2027·Fixed 30-Day Active Cohort

Diagnostic Sprint Engagement

Executive Pilot

Fixed 30-day scope. 100% credited against annual deployment upon institutional onboarding.

Includes live in-window pilot calls, comprehension heatmaps & Board Pack generation.

Strict mutual NDA executed prior to file ingestion

Enterprise Defensibility · Risk Committee Clearance

Enterprise Security & DPDP Defense Center

Architected from day one to withstand institutional Information Security (InfoSec), Chief Risk Officer (CRO) and Data Protection Officer (DPO) due diligence — with the security posture documented in a reviewable vendor pack.

DPDP Act 2023 Aligned Architecture

Purpose-limited processing built to the Digital Personal Data Protection Act. Transient raw scans are purged within 30 days; the durable compliance record — consent confirmation, quoted clause snippets, and a cryptographic hash chain — is retained for the period RBI requires (consent and related records preserved for one year after the contractual relationship ends, Para 101G, and aligned to the lender's own record-keeping policy).

30-Day Transient Purge · Regulatory Retention

India Data Residency (MeitY-Empanelled CSP)

Compute and storage run in MeitY-empanelled cloud data centres in India (AWS Mumbai / Azure Central India). In SKU B, customer phone numbers never leave the lender's perimeter and cross-border transfer is disabled by configuration. In SKU A, contact numbers are necessarily processed by messaging sub-processors (Meta WhatsApp Business / BSP) and DLT SMS operators; these are disclosed in the data processing agreement.

MeitY-Empanelled Cloud · Mumbai Region

Pre-Structured Two-Tier Liability Caps

Pre-structured two-tier liability caps: general liability capped at 1x annual fees; data protection liabilities super-capped at contract multiples, backed by institutional Cyber & Professional Indemnity policies. Full schedules shared under NDA.

Two-Tier Super-Cap Posture

No Model Training on Client Data

Client documents, borrower transcripts and loan agreements are contractually isolated and excluded from any public or shared model training. No third-party LLM data reuse.

Zero Model Training on Client Data

Regulatory Frame

Bharatiya Sakshya Adhiniyam, 2023 §63(4) · Digital Personal Data Protection Act, 2023 · RBI Responsible Business Conduct Directions · RBI Outsourcing Risk Management Guidance

Hash-Chain Audit Trail

* Security posture, data-processing schedules, third-party VAPT reports, and business continuity arrangements are shared in full under NDA during institutional vendor due diligence.

Executive Gateway

Schedule a 40-Minute CCO Briefing

Discuss your institution’s post-sale verification obligations before the RBI Directions take effect on 1 January 2027. We provide a custom walkthrough of the In-Window Cure Engine.