The RBI's co-lending framework — Master Direction FIDD.CO.Plan.BC.5/04.09.01/2020-21 and its subsequent circulars — requires NBFCs participating in co-lending arrangements to maintain specific records, report portfolio performance to their banking partner monthly, and ensure that every co-lending account is reported to credit bureaus by the partner responsible for reporting under the agreement. The Co-Lending Ops Agent AI generates the complete monthly reporting suite — the partner performance report, the regulatory return data, the bureau reporting reconciliation, and the FLDG utilisation statement — all drawn from verified reconciled data.
What co-lending reporting requires — and why it routinely fails
Co-lending reporting is more complex than standard NBFC regulatory reporting because it involves data from two institutions' systems, reported in formats that must satisfy the bank partner's internal reporting requirements, the RBI's regulatory requirements for co-lending disclosure, and the credit bureau's reporting obligations for jointly originated loans. The co-lending agreement typically specifies which partner is the "lead partner" responsible for bureau reporting — usually the NBFC, since it has the direct borrower relationship — but the reported data must reflect both partners' shares accurately.
Reporting routinely fails in three ways: the monthly partner performance report is assembled manually from two separate CBS extracts that have not been reconciled, producing a report that the bank partner questions; the bureau reporting is submitted with the NBFC's account number only, without the co-lending flag or the bank's co-lender code, creating a bureau record that understates the loan's total size and misrepresents its credit structure; and the regulatory return data for co-lending volumes is compiled from operational reports that were never designed for regulatory submission, producing a return that an RBI inspector will find inconsistent with the institution's CBS records.
The monthly reporting suite: what the Co-Lending AI generates
Complete portfolio health report for the bank partner: origination, repayment, delinquency, and FLDG utilisation
The monthly partner report is the NBFC's primary communication to the bank about the co-lending portfolio's performance. It covers: new accounts originated during the month, total portfolio outstanding (split by partner share), EMI collection rate for the month, overdue accounts by DPD bucket, NPA classification and provisioning status, FLDG corpus position and utilisation, prepayments and foreclosures, and any accounts where legal action has been initiated. Every figure in the report is drawn from the reconciled daily reconciliation ledger — the same data the bank's own reconciliation team will have in its records.
The specific co-lending disclosure data the RBI requires from co-lending NBFCs
The RBI requires NBFCs to report co-lending volumes as part of their regular returns — specifically disclosing the total loans originated under co-lending arrangements, the outstanding portfolio split by priority sector and non-priority sector (since co-lending is primarily structured for priority sector lending), and the number of active banking partners. The Co-Lending Ops Agent AI compiles this data for inclusion in the institution's monthly regulatory returns, formatted for the relevant return template.
Verifies that every co-lending account is reported to CIBIL with the co-lender flag and the correct split amounts
RBI and CIBIL require that co-lending accounts are reported with specific flags indicating the co-lending structure, the lead lender, and each lender's share. The Co-Lending Ops Agent AI checks the monthly CIBIL submission against the co-lending account register: every co-lending account must have the co-lender flag set, the sanctioned amount must reflect the total loan (not just the NBFC's 20%), and the co-lender's code (the bank's CIBIL member code) must be included. Any co-lending account submitted without these flags is flagged for correction before the submission is finalised.
Formal monthly FLDG position statement: corpus deposited, drawn, remaining, and utilisation rate
The FLDG utilisation statement is a formal document — it is typically a schedule to the co-lending agreement and both partners' finance teams receive it monthly. The statement shows: opening FLDG corpus balance, additions (if additional corpus was deposited), drawdowns (with account-level detail for each NPA that triggered a drawdown), closing corpus balance, and utilisation rate. The bank uses this to verify that the NBFC's FLDG position is consistent with the bank's own NPA records for the co-lending portfolio.
Full-year reconciliation of all co-lending transactions, interest true-ups, and FLDG movements
At year-end, the Co-Lending Ops AI generates the complete annual reconciliation statement — the definitive record of the year's co-lending transactions between the two partners. This includes: the interest methodology true-up (resolving the accumulated difference between daily and monthly reducing balance calculations), the rounding true-up (clearing the accumulated ₹1–2 rounding differences from the monthly settlement), and the FLDG annual statement (showing every drawdown, the NPA account it was associated with, and the current recovery status of that account). This document is the statutory auditor's primary reference for co-lending operations.
A monthly partner performance report: what the Co-Lending AI sends to SBI
| Metric | Total portfolio | NBFC share (20%) | Bank share (80%) |
|---|---|---|---|
| Outstanding principal (Oct 31) | ₹98,42,18,000 | ₹19,68,43,600 | ₹78,73,74,400 |
| New accounts originated (Oct) | 84 accounts · ₹8.4 Cr | ₹1.68 Cr | ₹6.72 Cr |
| EMI collected (Oct) | ₹1,84,28,000 | ₹36,85,600 | ₹1,47,42,400 |
| Prepayments and foreclosures (Oct) | ₹48,40,000 | ₹9,68,000 | ₹38,72,000 |
| EMI collection rate (Oct) | 94.2% of due EMIs collected | — | — |
| DPD bucket | No. of accounts | Outstanding (total) | Outstanding (bank 80%) |
|---|---|---|---|
| Current (DPD 0) | 1,842 | ₹74.2 Cr | ₹59.4 Cr |
| 1–30 DPD (early warning) | 248 | ₹12.4 Cr | ₹9.9 Cr |
| 31–60 DPD (watch) | 124 | ₹6.2 Cr | ₹5.0 Cr |
| 61–89 DPD (pre-NPA) | 82 | ₹3.8 Cr | ₹3.0 Cr |
| 90+ DPD NPA | 41 | ₹1.84 Cr | ₹1.47 Cr |
| FLDG component | Amount (₹) |
|---|---|
| FLDG corpus (opening, Oct 1) | ₹7,12,40,000 |
| Drawdowns during October (3 new NPA accounts) | −₹22,40,000 |
| Recoveries credited back to corpus (Oct) | +₹0 |
| FLDG corpus (closing, Oct 31) | ₹6,90,00,000 |
| Utilisation rate (drawn ÷ committed) | 29.9% (committed: ₹9.84 Cr · Drawn to date: ₹2.94 Cr) |
| Trigger threshold | 40% — currently 10.1 pp below trigger |
| Metric | October 2025 |
|---|---|
| Total transactions in month | 4,184 |
| Auto-matched (no manual intervention) | 4,168 (99.6%) |
| Exceptions resolved during month | 16 (all resolved by Oct 31) |
| Open reconciliation items at month-end | 0 |
| Accumulated rounding difference (Oct) | ₹842 — included in Nov true-up |
A co-lending report generated from unreconciled data is a report that will produce 3 weeks of email threads between the NBFC and the bank
The bank's finance team receives the NBFC's monthly partner performance report and checks it against the bank's own records for the same portfolio. Every discrepancy creates a question. Every question requires the NBFC's ops team to investigate, respond, and potentially restate figures. In a manually prepared report, discrepancies are the norm — value date differences, methodology gaps, and reconciliation backlogs all produce numbers that do not agree with the bank's records. The Co-Lending Ops Agent AI generates the report from the same reconciled data that underpins the daily reconciliation — so the bank's first look at the NBFC's report is not the beginning of a discrepancy investigation, but a confirmation of what both parties already know.