Why Co-Lending Controls Must Be Product-Specific

Common Controls Are Necessary, But Not Sufficient

The RBI Co-Lending Directions 2025 mandate headline controls that apply to every co-lending arrangement: minimum 10% on-book retention, ex-ante commitment pre-dating disbursement, 15-calendar-day booking timelines, escrow routing, and borrower-level classification convergence.

However, applying identical compliance checks to a 3-month gold loan and a 20-year housing loan creates massive audit blind spots. Evidence requirements depend on the underlying asset class. An auditor verifying a gold loan portfolio asks completely different questions than one reviewing an MSME working capital line.

Asset-Class Control Breakdown

1. Gold Loans

Gold loan co-lending requires strict collateral physical custody and valuation evidence:

• Valuation & LTV Evidence: Independent assayer certificate, purity verification, and LTV cap compliance at disbursement.
• Custody Verification: Branch vault location, packet tracking, dual-custody audit logs, and insurance cover.
• Borrower Acknowledgement & Auction State: Pledge card delivery evidence and mandatory notice records prior to default auctions.

2. Housing Loans & LAP

Secured real-estate co-lending requires title and encumbrance continuity:

• Title Search & Legal Opinion: Verification of property title search report and advocate opinion.
• CERSAI Charge Filing: Proof of CERSAI security interest registration within statutory timelines.
• Property Valuation & Insurance: Multi-valuer appraisal reports and property insurance policy status.

3. Vehicle & Tractor Finance

Movable asset co-lending hinges on registration and hypothecation:

• RC & Parivahan Verification: Match of chassis number, engine number, and borrower identity against Vahan records.
• Hypothecation Stamping: Explicit lender hypothecation recorded in the RC.
• Comprehensive Insurance: Live motor insurance policy with lender endorsement.

4. MSME Term Loans

Commercial MSME lending requires business identity and end-use evidence:

• Business Identity Tiers: Verified GSTIN, MCA/CIN, Udyam registration, and PAN.
• End-Use Disbursement Proof: Direct vendor payment receipts, invoice corroboration, or CA end-use certificate.
• Priority Sector Lending (PSL): Explicit sub-category evidence (Micro/Small, Agriculture, Weaker Sections).

5. Revolving Working Capital Facilities

Revolving facilities demand continuous drawing power surveillance:

• Stock & Receivables Statements: Monthly borrower inventory declaration and aging analysis.
• Drawing Power Recomputation: Blended DP calculation against current asset valuations.
• Annual Renewal Timelines: Renewal evidence pre-dating facility expiry to avoid technical SMA classification.

Deterministic Control Readiness in AssureCLA

AssureCLA exposes preconfigured, deterministic product-control packs across all six asset classes. Lenders can view rule counts, mandatory evidence items, and explicit readiness states (demo-ready / production approval pending / production-ready) directly inside the workspace.

The latest pack-readiness layer adds a counsel-review dossier for each product pack. That dossier lists rule IDs, required evidence, source provenance, approval metadata and the permitted public-claim boundary. In practical terms: a gold-loan pack can be shown as demo-ready while still being blocked from production-certified claims until counsel/risk approval and authoritative source mapping are complete.