BBNFC · OPERATIONAL CONTROL REGISTER
Legal Director Compliance Heads + Director Control Actions Register
One mapped workflow for regulatory controls, investor protection, documents, agreements, legal gaps, director decisions, evidence and BBAI recommendations.
Compliance register controls and current status
Mapped controls
18
Review gaps
6
Evidence files
0
Director actions
0
24 of 24 controlsSelect a row to activate contextual actions
| ID / Category | Compliance Head | Mapping / Priority | Role / Responsible | Document / Linked Code | Agreement | Purpose / Benefit | Risk / Gap | Deadline / Status | Director Control Action | Actions |
|---|---|---|---|---|---|---|---|---|---|---|
| BBNFC-0002 RBI | NBFC Certificate of Registration validity | Mapped Critical | Compliance Officer Compliance Officer | RBI CoR + supervisory letters | SSA / SPA Conditions Precedent | Confirm active NBFC licence. Protects investor entry from unauthorised entity risk. | Licence cancellation, conditional registration breach. | Before closing Pending | Assign the responsible officer, verify evidence and escalate unresolved gaps to the legal team. | |
| BBNFC-0003 FEMA | FCGPR filing within 30 days of allotment | Mapped Critical | CFO CFO + Company Secretary | FCGPR + valuation report | Investment Agreement | RBI reporting of foreign allotment. Avoids compounding; legitimises foreign capital. | Late-filing penalty, compounding, share-cancellation risk. | Within 30 days Pending | Assign the responsible officer, verify evidence and escalate unresolved gaps to the legal team. | |
| BBNFC-0004 DPDP | Borrower master KYC accuracy | Review Gap High | Data Protection Officer DPO | KYC register + consent log | Data Processing Agreement | Lawful processing of borrower data. Protects from DPDP penalty and investor diligence findings. | Consent absence, breach notification gap. Evidence and agreement clause require legal verification for KYC register + consent log. | Next compliance review Pending | Assign the responsible officer, verify evidence and escalate unresolved gaps to the legal team. | |
| BBNFC-0005 MCA | Charge registration on borrower security | Mapped Critical | Company Secretary CS | ROC Form CHG-1 / CHG-4 | SHA Schedule of Security | Perfect security interest of NBFC. Priority over unsecured creditors during recovery. | Loss of security, IBC ranking risk. | Next compliance review Pending | Assign the responsible officer, verify evidence and escalate unresolved gaps to the legal team. | |
| BBNFC-0006 Director Duties | Director fit-and-proper declaration | Mapped Critical | NBFC Director Each Director | Fit-and-Proper certificate | Director Declaration | RBI directors' eligibility. Sustains board legitimacy. | Disqualification, RBI direction. | Before closing Pending | Review evidence, approve the board note and certify completion. | |
| BBNFC-0007 AI | AI underwriting model audit trail | Mapped High | AI Platform Officer AI Officer | Model card + audit log | AI Platform Agreement | Explainability of digital lending. Defends against fairness and bias complaints. | RBI digital-lending breach, consumer complaint. | Next compliance review Pending | Assign the responsible officer, verify evidence and escalate unresolved gaps to the legal team. | |
| BBNFC-0008 Escrow | Escrow trigger on insolvency event | Mapped High | Escrow Officer Escrow Officer | Escrow mandate | Escrow Agreement | Protect investor funds on default. Freezes funds for investor priority. | Misuse during distress. | Next compliance review Pending | Mark as investor protection control and add the protection to the transaction agreement schedule. | |
| BBNFC-0009 Investor Rights | Reserved-matter list (investor consent) | Mapped High | Investor Nominee Investor Nominee Director | SHA Reserved-Matters Schedule | SHA | Investor veto on key decisions. Prevents value erosion by majority. | Unilateral dilution, related-party transfer. | Next compliance review Pending | Mark as investor protection control and add the protection to the transaction agreement schedule. | |
| BBNFC-0010 SPV | SPV ring-fencing covenants | Mapped High | SPV Manager SPV Manager | SPV Constitutional Documents | SPV Agreement | Asset and liability segregation. Protects investor pool from parent risk. | Veil piercing, commingling. | Next compliance review Pending | Mark as investor protection control and add the protection to the transaction agreement schedule. | |
| BBNFC-0011 RBI | Fair Practice Code adoption | Mapped Critical | Compliance Officer Compliance Officer | Board-approved FPC | Compliance Certificate | RBI customer protection. Avoids supervisory action. | Customer complaint, RBI direction. | Next compliance review Pending | Assign the responsible officer, verify evidence and escalate unresolved gaps to the legal team. | |
| BBNFC-0012 IBC | IBC Section 29A bidder eligibility check | Review Gap High | External Legal Team External Lawyer | 29A declaration | Resolution Submission | Avoid ineligible resolution applicant. Preserves bid validity. | Plan rejection. Evidence and agreement clause require legal verification for 29A declaration. | Next compliance review Pending | Assign the responsible officer, verify evidence and escalate unresolved gaps to the legal team. | |
| BBNFC-0013 Cyber | Cyber incident response plan | Review Gap High | IT/Cyber Officer CISO | Cyber playbook + drill log | Vendor SLA | RBI cyber directions compliance. Reduces breach impact and reporting delay. | Regulatory notice, customer suit. Evidence and agreement clause require legal verification for Cyber playbook + drill log. | Next compliance review Pending | Assign the responsible officer, verify evidence and escalate unresolved gaps to the legal team. | |
| BBNFC-0014 ESG | BRSR ESG disclosures | Review Gap High | CFO CFO + Sustainability Lead | BRSR report | Investor MIS | ESG transparency for investors. Attracts ESG capital. | Greenwashing claim. Evidence and agreement clause require legal verification for BRSR report. | Next compliance review Pending | Assign the responsible officer, verify evidence and escalate unresolved gaps to the legal team. | |
| BBNFC-0015 MCA | Related-party transaction approval | Mapped Medium | Audit Committee Audit Committee | RPT register + approvals | Director Declaration | Sec 188 / Listing Reg compliance. Prevents conflict of interest. | Penalty, investor objection. | Next compliance review Pending | Assign the responsible officer, verify evidence and escalate unresolved gaps to the legal team. | |
| BBNFC-0016 Director Duties | Closing compliance certificate | Mapped Critical | NBFC Director Managing Director | Closing Certificate | SPA / SSA Closing | Confirm CPs satisfied at closing. Triggers investor funding release. | Misrepresentation indemnity. | Before closing Pending | Review evidence, approve the board note and certify completion. | |
| BBNFC-0017 RBI | ALM and capital adequacy report | Review Gap Critical | CFO CFO | ALM + CRAR statement | Investor MIS Schedule | Prudential ratio compliance. Supports investor diligence on solvency. | RBI direction, downgrade. Evidence and agreement clause require legal verification for ALM + CRAR statement. | Next compliance review Pending | Assign the responsible officer, verify evidence and escalate unresolved gaps to the legal team. | |
| BBNFC-0018 MCA | Lender NOCs for change in control | Mapped Critical | CFO CFO | Lender NOCs | SPA Conditions Precedent | Avoid event of default. Smooth acquisition closing. | Cross-default acceleration. | Next compliance review Pending | Assign the responsible officer, verify evidence and escalate unresolved gaps to the legal team. | |
| BBNFC-0019 Investor Rights | Anti-dilution protection (broad-based) | Mapped Medium | Investor Investor | SHA Anti-dilution Schedule | SHA | Protect investor valuation. Down-round protection. | Value erosion. | Next compliance review Pending | Mark as investor protection control and add the protection to the transaction agreement schedule. | |
| BBNFC-0020 Investor Rights | Drag-along and tag-along rights | Mapped Medium | Investor Investor | SHA Exit Schedule | SHA | Aligned exit. Liquidity certainty. | Stranded minority risk. | Next compliance review Pending | Mark as investor protection control and add the protection to the transaction agreement schedule. | |
| BBNFC-0021 SPV | Recovery waterfall in SPV | Review Gap High | SPV Manager SPV Manager | Waterfall schedule | SPV / IA | Investor priority on recovery. Predictable distribution. | Disputed payout. Evidence and agreement clause require legal verification for Waterfall schedule. | Next compliance review Pending | Mark as investor protection control and add the protection to the transaction agreement schedule. | |
| BBNFC-0022 SPA | Conditions precedent — regulatory approvals | Mapped Critical | External Legal Team External Lawyer | CP checklist | SPA | Funding gated on approvals. Prevents premature closing. | Regulatory rollback. | Before closing Pending | Mark as investor protection control and add the protection to the transaction agreement schedule. | |
| BBNFC-0023 SPA | Indemnity cap and basket | Mapped Critical | Investor Investor + Promoter | Indemnity schedule | SPA | Allocate post-closing risk. Quantified investor recourse. | Hidden liabilities. | Before closing Pending | Mark as investor protection control and add the protection to the transaction agreement schedule. | |
| BBNFC-0024 FEMA | Source-of-funds declaration | Mapped Critical | Investor Investor | SoF declaration + KYC | SSA | PMLA / FEMA compliance. Validates capital legitimacy. | Reporting, freezing. | Within 30 days Pending | Assign the responsible officer, verify evidence and escalate unresolved gaps to the legal team. | |
| BBNFC-0025 RBI | Digital lending LSP agreement compliance | Mapped Critical | Compliance Officer Compliance Officer | LSP master agreement | LSP Agreement | RBI DL guidelines compliance. Lawful outsourcing. | Action against NBFC. | Next compliance review Pending | Assign the responsible officer, verify evidence and escalate unresolved gaps to the legal team. |