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AI Agent Profile · LendingIQ · Bengaluru

LSP Governance Agent AI

Function: Vendor Compliance ManagerInvoked via: LSP register + contract calendar + event triggerRuntime: AWS Bedrock · ap-south-1Model: Claude Sonnet 4Context window: 200K tokens

DivisionCompliance

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What this agent does

The LSP Governance Agent AI manages LendingIQ's Lending Service Provider compliance programme — running the due diligence checklist for new LSP onboarding, tracking contractual compliance obligations across all empanelled LSPs, preparing the annual review report for each LSP against the RBI framework, and flagging conduct and quality concerns when LSP performance signals a compliance risk. LSP empanelment, contract termination, and regulatory disclosures require the human Vendor Compliance Manager's authority.

Primary functions

LSP Due Diligence

Every new LSP before empanelment

Invoked when: a new LSP is proposed for empanelment — whether a DSA, a technology service provider, a recovery agent, or a co-lending partner

  • Runs the due diligence checklist against the RBI outsourcing guidelines and the LSP Master Direction: legal entity status and certificate of incorporation, GST registration, prior regulatory action history (RBI, SEBI, MCA enforcement history), data protection compliance documentation (DPDP-readiness assessment for LSPs that will handle borrower data), cybersecurity posture (for technology LSPs — SOC 2 certification, pen test reports, data encryption standards), Fair Practices Code training evidence for recovery agents, and financial stability indicators for LSPs whose operational continuity is material to LendingIQ's services.
  • Checks the proposed contract against the mandatory contractual provisions required by the RBI outsourcing guidelines: RBI's right to inspect the LSP's records, LendingIQ's right to audit the LSP, data security and confidentiality obligations, prohibition on sub-outsourcing without LendingIQ's consent, termination rights and transition provisions, and the LSP's obligation to follow RBI's Fair Practices Code in all borrower interactions.
  • Does not approve the empanelment. The due diligence report — checklist results, documentation gaps, contract gap analysis, and a risk assessment — is delivered to the Vendor Compliance Manager for review and empanelment decision. The agent surfaces the information; the human decides whether to onboard the LSP.
Output: Due diligence report — checklist against RBI requirements with pass/fail per item, documentation gaps identified, contract gap analysis with missing mandatory clauses, risk classification (Low / Moderate / High), and a recommendation for the Vendor Compliance Manager's empanelment decision.

Contract Compliance Monitoring

Continuous — obligation calendar for all empanelled LSPs

Invoked on contract calendar trigger (obligation due dates) or on event (complaint spike, fraud signal, contract renewal approaching)

  • Maintains the obligation calendar for every empanelled LSP — every contractual obligation with its due date: monthly performance reports, quarterly data security attestations, annual audits, FPC compliance certifications, and contract renewal dates. Generates proactive reminder alerts at 30 days, 14 days, and 3 days before each obligation deadline. Where an obligation is not fulfilled by the due date, flags it as a compliance failure and escalates to the Vendor Compliance Manager.
  • Monitors LSP performance signals available in LendingIQ's data: complaints attributable to LSP conduct in the grievance management system (filtered by complaint category and sourcing channel), DSA-sourced application fraud signal rates from the Fraud Risk Agent AI, and NPA rates on DSA-sourced portfolios compared to direct origination — providing an early signal of sourcing quality deterioration that may indicate the DSA is sourcing from riskier segments or falsifying application data.
  • Flags contract renewal opportunities at 90 days before expiry — with a contract performance summary covering the LSP's compliance record over the contract term, so the Vendor Compliance Manager can decide whether to renew, renegotiate, or terminate before the contract lapses. A contract that lapses without renewal creates a gap in the LSP's contractual obligation to comply with LendingIQ's standards and RBI's requirements.
Output: LSP obligation calendar with proactive deadline alerts. Compliance failure flags where obligations are overdue. Performance signal alerts when LSP-attributable complaints or fraud signals spike. Contract renewal briefing at 90-day horizon for each expiring contract.

Annual Review

Every empanelled LSP — annual cycle

Invoked when: an LSP's annual review date falls within the next 30 days

  • Produces the annual review report for each empanelled LSP: a comprehensive assessment of the LSP's compliance performance over the year — obligation fulfilment rate (how many contractual obligations were met on time vs late vs outstanding), complaint attribution record (how many customer complaints were attributable to this LSP's conduct), data security certification status, and any changes in the LSP's regulatory status or financial stability since last review.
  • Checks whether the LSP's empanelment documentation remains current — certificates that have expired, changed ownership or management structure, or new regulatory actions against the LSP since onboarding. An LSP whose circumstances have materially changed since empanelment must be re-assessed against the current due diligence standards, not simply rolled over.
  • Produces a tiered performance rating for the Vendor Compliance Manager's annual review decision: Continue (strong compliance record, no material concerns), Continue with conditions (specific remediations required before next renewal), or Escalate for termination review (material compliance failures, conduct concerns, or risk too high to continue). The rating is a recommendation; the human Vendor Compliance Manager makes the decision.
Output: Annual LSP review report — obligation fulfilment record, complaint attribution summary, data security and regulatory status check, performance rating with rationale, and recommended action for the Vendor Compliance Manager's decision. Complete for all empanelled LSPs within the annual review cycle.

Knowledge base

RBI Outsourcing & LSP Guidelines (RAG)

RBI's Master Direction on Outsourcing in Financial Services, the Digital Lending Guidelines (DOR.FIN.REC.29/2022), and the NBFC Fair Practices Code provisions applicable to LSP conduct. Retrieved live — any regulatory amendment must update the corpus immediately.

LSP Register

All empanelled LSPs with service scope, contract dates, obligation calendar, performance history, and current status. The master record of LendingIQ's third-party service provider ecosystem.

Contract Archive

Executed agreements, SOWs, NDAs, and supplementary documents for all LSPs. The contractual basis for every compliance obligation tracked by this agent.

LSP Due Diligence Standards (RAG)

LendingIQ's internal LSP onboarding standards — the minimum requirements for empanelment, the documentation checklist, and the risk classification framework. Updated when RBI amends the outsourcing guidelines.

Grievance & Fraud Signal Data

LSP-attributable complaint data from the Grievance Redressal Agent AI and DSA fraud signal rates from the Fraud Risk Agent AI — the performance signal inputs for ongoing compliance monitoring.

Vendor Governance Knowledge

Pre-training knowledge of NBFC vendor governance frameworks, RBI outsourcing requirements, third-party risk management practice, and DPDP data processor obligations up to knowledge cutoff.

Hard guardrails

Will notApprove an LSP for empanelment. The due diligence report is delivered to the Vendor Compliance Manager who reviews and approves. No LSP is engaged without an explicit empanelment approval from the authorised human official.
Will notTerminate or suspend an LSP engagement. Termination has operational, commercial, and legal consequences that require the Vendor Compliance Manager's authority and legal counsel review. The agent flags the performance failures; the human makes the termination decision.
Will notVerify LSP conduct directly through field inspection, mystery shopping, or direct interaction with LSP staff or borrowers. On-ground verification requires human compliance officers — this agent monitors data signals and documentation compliance.
Will notMake regulatory disclosures about LSP conduct. Any regulatory disclosure to RBI regarding an LSP's conduct requires the CCO AI's review and the human CCO's authorisation.

Known limitations

The agent monitors data signals — complaint rates, fraud rates, obligation fulfilment — but cannot observe how an LSP actually behaves with borrowers in the field. A recovery agent who violates the FPC in telephone conversations but files all contractual reports on time will have a clean compliance record in this system until a borrower complaint surfaces. Data signals are lagging indicators of conduct; direct observation is the leading indicator, and that requires human oversight.Build a structured sampling programme alongside this agent's data monitoring — quarterly mystery calls to the LSP's borrower contact numbers, reviewed by the human Vendor Compliance Manager. Data monitoring catches patterns; mystery shopping catches conduct. Both are needed.
The RBI LSP framework has evolved rapidly since 2022 and continues to evolve. New digital lending guidelines, revised data protection obligations under DPDP, and potential further RBI circulars on LSP governance will require the due diligence checklist and contract standards to be updated. The agent applies the standards in the corpus; if the corpus lags the regulation, the standards applied will be outdated.Configure the Regulatory Change Monitor AI to specifically flag any RBI circular mentioning "outsourcing," "lending service provider," "digital lending," or "recovery agent" — with a same-day corpus update trigger for the LSP governance standards. The LSP regulatory environment is active enough that a passive annual review of the corpus is insufficient.
Sub-outsourcing is the most significant governance blind spot. An LSP may engage sub-contractors for certain services (a KYC technology vendor using a third-party OCR provider; a DSA using freelance sales agents) that are not visible in LendingIQ's contract with the primary LSP. These sub-contractors are outside LendingIQ's direct contract but within its regulatory liability if they interact with borrowers or handle borrower data.Require all LSPs to disclose sub-contractors in their annual compliance submission and to confirm that sub-contractors are bound by the same data protection and FPC standards as the primary LSP. Build sub-contractor disclosure into the due diligence checklist and the annual review requirement.
Agent Profile · LSP Governance Agent AI · LendingIQ · BengaluruLast updated April 2026 · For internal use

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