Question,Practical answer,Law/source verification,State-specific follow-up,Owner
Can I launch a fintech app first and seek RBI approval later?,"Not for activities requiring prior authorisation. First classify services and funds flows, obtain the required licence or structure a permissible technology-only relationship with an authorised entity.",See guide official references,,
Does an NBFC partnership let me lend my own capital?,"No. Partner registration does not automatically authorise independent lending or deposit-taking. The legal lender, contract, ownership of loan and risk must be identified.",See guide official references,,
What makes a digital lending service provider different from a lender?,"An LSP performs contracted origination, servicing or other functions for a regulated entity; it is not necessarily the creditor. Follow applicable RBI Digital Lending Directions and the RE’s oversight obligations.",See guide official references,,
Can my app hold customer money temporarily?,Custody and settlement can engage payment-system regulatory requirements. Record each settlement account and legally permitted path; do not assume a startup can hold third-party funds as float.,See guide official references,,
Can we advertise guaranteed investment returns?,Unsupported return guarantees may be misleading and may engage securities and consumer protections. Only state validated product terms within the firm’s authorisation.,See guide official references,,
What should a Key Fact Statement cover?,"For applicable digital loans, consult RBI Digital Lending Directions for total cost/APR, fees, grievance and other specified disclosures; the exact RE product dictates KFS content.",See guide official references,,
Do we need independent information-security testing?,"Testing and governance requirements differ by regulator, activity, system importance and outsourcing agreement. Build a risk-based vulnerability and partner-assurance programme from the start.",See guide official references,,
Can KYC data from one product be reused in another?,"Only if current law, permitted purpose, valid data-sharing basis and sector-specific rules allow it. Maintain data minimisation, role separation and consent artefacts.",See guide official references,,
Who answers customer complaints when the lender is another company?,The regulated entity retains duties for the regulated service even when an LSP operates the interface. Display clear grievance escalation and ownership to the customer.,See guide official references,,
How should we handle failed payment settlements?,"Maintain transaction reference, payer and beneficiary bank, success/failure/reversal codes, applicable TAT, exception queue, suspense ledger and final customer confirmation.",See guide official references,,
How do we prevent an app becoming a mis-selling channel?,"Separate advice from advertising, display clear pricing and product comparison where required, test dark-pattern risks, record consent and audit sales incentives.",See guide official references,,
What is our first regulator-facing document?,"Prepare a regulatory-perimeter memo: services, user journey, entities, funds and data flow, applicable enactments/Directions, licences required or why not, and signed legal/partner signoff.",See guide official references,,