Lakshya

Banking & Capital Markets Systems · Chapter 4 of 13

Lending — origination, the bureaus, and what the 2025 directions changed

LOS versus LMS versus data aggregation, why lenders pull more than one bureau, and the rule that redrew every fintech lending partnership.

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Three things that get called the same thing

LayerWhat it doesWho
Loan origination (LOS)Application, KYC, underwriting decision, sanction, disbursalNucleus FinnOne Neo · Newgen · Lentra · in-house
Loan management (LMS)Servicing after disbursal — schedules, repayments, delinquency, closureOften the same suite, often the core banking system
Data aggregationParsing bank statements and income data into the underwriting decisionPerfios — and this is not an LOS, though postings blur it

Nucleus FinnOne Neo is Noida-built and long-established, with named clients including ICICI Home Finance and Mirae Asset Financial Services. Newgen comes from business-process and content management, which makes it strongest where origination is document-heavy — mortgages, loans against property. Lentra is the cloud-and-API-first entrant, founded 2019. Yubi, renamed from CredAvenue in 2022, is a debt marketplace whose Co.Lend product targets the bank-NBFC workflow below.

Treat vendor client counts as marketing until you check them.

Lentra publishes figures of 50+ bank and NBFC clients, $20B+ processed and 2 million loans a month, naming HDFC, IndusInd, Federal and others. Perfios publishes 8.2 billion data points a year. These are self-reported and unaudited, and the same is true of Finacle's “one billion end customers” and Intellect's “8 of the top 10 Indian banks”.

They may well be accurate. They are not evidence, and quoting one as a fact in an interview is a risk with no upside.

The four bureaus, and why lenders pull more than one

Credit information companies are licensed by RBI under the Credit Information Companies (Regulation) Act, 2005, and there are exactly four: TransUnion CIBIL (oldest, from 2000, the default for prime retail), Equifax, Experian, and CRIF High Mark — which has the deepest microfinance and rural coverage, inherited from its origins in MFI data.

Lenders commonly pull two or more on larger tickets. Not for a second opinion on the score, but because coverage genuinely differs — a borrower thin at one bureau may be thick at another, and inconsistencies between bureaus are themselves a fraud signal. “Why would you pull two bureaus?” is a good interview question precisely because the obvious answer, redundancy, is the wrong one.

The 2025 directions, and what they broke

RBI's 2022 digital lending guidelines were consolidated into the RBI (Digital Lending) Directions, 2025, notified on 8 May 2025 and effective immediately, except for multi-lender arrangements through a lending service provider (1 November 2025) and digital lending app reporting to the CIMS portal (15 June 2025).

The architecturally significant clause is the flow of money. Disbursal must run directly from the regulated entity — the bank or NBFC — to the borrower, and repayment directly back, without passing through a pooling account controlled by the fintech partner. That single rule invalidated a large number of existing lending-partnership designs, because the pooling account was where a lot of the product experience and the reconciliation lived.

Co-lending runs in two shapes worth knowing by name: CLM1, where bank and NBFC originate jointly and simultaneously, and CLM2, where the NBFC originates and disburses first and the bank buys a participation of up to 80% afterwards. The second is far more common and creates a distinct set of reconciliation and assignment problems.

Check yourself

What is the difference between an LOS, an LMS and Perfios?Origination decides and disburses; management services the loan afterwards; Perfios parses bank-statement and income data into the underwriting decision and is not an LOS, though postings blur it.
How many credit bureaus are there in India, and why?Exactly four, licensed by RBI under the Credit Information Companies (Regulation) Act 2005: CIBIL, Equifax, Experian and CRIF High Mark — the last with the deepest microfinance and rural coverage.
Why pull two bureaus?Coverage genuinely differs — a borrower thin at one may be thick at another — and inconsistency between bureaus is itself a fraud signal. Not redundancy.
What did the 2025 Digital Lending Directions change architecturally?Disbursal must flow directly from the regulated entity to the borrower, not through a fintech-controlled pooling account. That invalidated a lot of existing partnership designs.
What is CLM1 versus CLM2?CLM1 is simultaneous joint origination by bank and NBFC. CLM2 is the NBFC originating and disbursing first, with the bank buying up to 80% afterwards. CLM2 is more common and creates its own reconciliation problems.
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