Overview: NBFC Aggregators

NBFC Account Aggregators are organizations that facilitate the allocation of data from numerous financial sector organizations and act as “consent brokers”, the transit data transfer among the financial organizations with the approval of the client. This was declared by the Reserve Bank India in September 2016 stating master directions for a new class of NBFCs called Account Aggregators.

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What does Account Aggregation Mean?

• Account Aggregation is the assembling of financial data that includes gathering information on a single platform from various accounts such as bank accounts, investment accounts, business accounts, consumer accounts, and other related financial accounts.
• Account Aggregators are financial organizations that provide structured financial data allocation from Financial Information Providers to Financial Information Users. For transmission of this information, approval is taken from the users. This right of administrating and revoking the assent lies with the users.
• Financial Information Providers: These are financial organizations that provide account information of a user upon request of another organization or individual and are synchronized under the financial sector.
• Financial Information Users: These are the organizations that need information about the users from the FIP for many uses such as market evaluation, customer analysis, etc. This includes both organizations and individuals. These are regulated under statutory bodies like SEBI, IRDA, RBI, and PFRDA.
• The Financial Information is shared in accordance with the master direction issued by the RBI-DNBR.

What Constitutes Financial Information?

According to the master directions of RBI-DNBR, financial information shall include:

• Various kinds of Bank deposits
• SIP
• Certificate of Deposit
• Equity Shares
• Debentures
• ETFs
• Collective Investment Scheme (CIS) Units
• Infrastructure Investment Trusts Units
• Real Estate Investment Trusts Units
• Deposits with NBFCs
• Commercial Paper
• Tradable Government Securities
• Bonds
• Mutual Fund Units
• Indian Depository Receipts
• Units of Alternative Investment Funds (AIF)
• Balance under the National Pension System (NPS)

Consent Manager for Transferring Financial Data

• NBFC-AA shall provide the users with a platform to make data payments or transfer financial data of different accounts of the user to any organization that needs admittance to that data. The approval request of the user can be initiated by sending a request for the necessary financial information to the user via the NBFC-AA identifier. Prior to the request has been sent, the NBFC-AA shall ensure that the needed information is communicated after the consent of the user has been acquired via the NBFC-AA app. This is similar to the authorization of collect request in a UPI application.
• The data collected by the FIU can be used in offering a variety of services to its customers such as credit facilities, personal financial services, wealth management advice, investment offers, or even upcoming financial services such as Robo banking, which is operated via artificial intelligence.
• The users that get their accounts registered with NBFC-A have the sole discretion of granting or revoking the sharing of the data of the accounts held by them in any FIP. Also, the users may or may not grant consent of their data being exported in a structured format.

How is the Registration of NBFC-AA done?

• Any company that wants to get itself registered as an NBFC-AA would be needed to make an application in the appropriate format to the DNRB, Mumbai. The Bank has to make sure that the below-mentioned conditions are fulfilled :
• The company must possess the needed resources to offer such services to its customers.
• The company must have an essential capital structure to run the business of an account aggregator.
• The company must have fit and proper promoters.
• The general character of the management of the company must not be malignant to the public interest.
• An effective Information Technology System plan should be laid out by the company.
• The leverage ratio of the company must not be more than seven.
• The AA shall be granted the COI to undertake the business in India in order to make sure that it is in the public interest.
• Any other condition may be specified by the Bank time and again, the fulfillment of which as per the Bank shall be necessary to confirm that the starting off or the running off the business in India shall not be malignant to the public interest.
• If the conditions that are mentioned above are satisfied, the Bank may grant in-principle sanction to the company for registration as an Account Aggregator.
• The in-principle sanction shall be valid for twelve months from the date of its being granted.
• Within twelve months of granting of the in-principle sanction, the company will be needed to prepare the platform for technology and enter into all the other essential legal documentation and make all the compliances appropriate with the in-principle sanction. The Bank will, thereafter, grant the company a Certificate of Registration if it is satisfied that the company is ready for the business and has made all the important legal compliances.

Any company that wants to get itself registered as an Account Aggregator must have a net-owned fund of rupees two crores.

Revocation of Certificate of Registration of NBFC-AA

• The RBI-DNBR is in authority to cancel the Account Aggregator’s certificate of registration if any of the below-mentioned conditions are not fulfilled:
• the company shuts off the business of account aggregators in India
• the company is not able to satisfy any condition subject to which the certificate of registration as AA has been issued
• If the Bank thinks that the company is no longer qualified to hold the COR.
• If the company breaches any condition which is mandatory for getting the certificate of registration
• the company fails to –
• conform with the appropriate directions that have been issued by RBI
• maintain accounts or issue information or disclose financial information as per the directions of the Bank or under appropriate law
• submitting its books of accounts or other relevant documents to the Bank for assessment

Duties of NBFC-AA

The duties and responsibilities of an NBFC-AA are mentioned below:

• It shall deliver amenities to the customer in accordance with the customer’s consent.
• It has to make sure that when providing services, the same shall be held up by appropriate agreement/authorization between the NBFC-AA, the customer, and the FIPs.
• It shall not hold up any transactions by the customers.
• It shall take up the to-the-point mechanisms for ensuring appropriate customer documentation.
• The information will be shared only with the customer who owns it or to any other FIU as sanctioned by the customer as per the terms and conditions of the consent.
• It shall not contract in any other business except for the business of NBFC-AA. However, permission has been granted for the disposition of investible surplus in avenues not meant for trading.
• The financial information of a consumer that has been examined from FIPs shall not be with the NBFC-AA.
• There should not be any third party taking up the business of Account Aggregator.
• It will have a Citizen’s Charter that will clearly make sure the protection of the rights of customers. It cannot cut off from any information that has been obtained by it from the customer or on his behalf, till the time the customer consents for the same.
• If in case there is a disagreement between the financial information generated by the Account Aggregator and the financial information in the books of the FIP, the position is shown in the books of FIP shall be overcome.

Account Aggregators are definitely a dependable platform for giving out information digitally, opposing the paper statements that were given by the individuals earlier. NBFC-AA has undoubtedly condensed the risk for financial entities as the appropriate data of the customers can be collected with no trouble. However, this also means that the customers have lost actual control over their financial data which can become risky and give rise to poor quality data. Therefore, the RBI requires fortifying the regulations relating to sharing financial data digitally.