What FACE actually does
Fintech Association for Consumer Empowerment FACE
Standards, oversight & dispute resolution for digital lending
FACE (registered 24 August 2020, recognised 28 August 2024) is the first RBI-recognised SRO-FT. Its published work splits into five streams: standards, oversight & enforcement, grievance & dispute resolution (GDR), policy engagement, and knowledge tooling.
Standards & guidelines (dated trail)
- Guidelines on Arbitration Framework in Loan Agreement — 2 Sep 2026
- Guidelines on DLG (Default Loss Guarantee) disclosure — Jul 2026
- Guidelines for LSP–RE agreements (lending service provider ↔ regulated entity) — 31 Mar 2026
- Guidelines on Whistleblower Mechanism — Sep 2025
- Guidelines on Debt Recovery — 29 Aug 2025
- Guidelines on Penal Charges — Jun 2025
- Guidelines on Cybersecurity Measures — 13 May 2025
- Pricing of Digital Loans by NBFCs — Jan 2025
Practical tooling for members
- List of Regulatory Policies for base-layer NBFCs — 31 Aug 2026
- List of Supervisory Returns for NBFCs — 28 Aug 2026
- Checklist for Responsible & Trustworthy AI in digital lending (with Dvara and PwC) — 18 Mar 2026
- Checklist for public disclosure on DLAs and LSP/RE websites — 14 Aug 2025
- Checklist on Customer Grievance Redressal — 13 Mar 2024; defence guide against unauthorised use of company details — 4 Mar 2024
- Baseline technology standards suggestions for DLAs — Mar 2023
Oversight & enforcement
The Oversight & Enforcement Policy (18 Aug 2025) sets out monitoring, review, escalation and enforcement across self-regulatory work: company-level monitoring, industry-level pattern analysis (including tracking app marketplaces), distinguishing isolated lapses from recurring deviations, with escalation paths to member-support, cautions, and RBI referral.
Grievance & dispute resolution (GDR)
A governed pathway for member disputes and complaints: submission via prescribed digital channels → initial review by the nodal officer and CEO → escalation to the Grievance and Dispute Redressal Committee → examination → formal closure. Documented, confidential, time-bound; positioned as an alternative to escalation and litigation.
Policy & knowledge work
- Consultation responses and structured dialogue with RBI, government and regulators — engagement framed as evidence-based and balanced across buy/sell side
- Industry surveys and reports under its Knowledge stream; member-only advisories
- Client-insight channel and engagement with marketplaces and app ecosystems
Gaps & open questions
- The DAK (Digital Assurance & Keeping?) scorecard detail referenced in its framework pages is not published as a standalone document
- No public complaint statistics or enforcement actions register
- Full member agreements/code sign-offs are not public