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QuickCredit offers instant personal loans up to ₹2L via a mobile app. Customers complete video KYC, receive a loan offer, and repay in EMIs. The app displays the Key Fact Statement, including APR and total cost, before the borrower confirms the loan. Disbursals are routed through a partner NBFC's pooled settlement account before reaching the borrower, and the app requests full contact list and SMS access at signup to help build a credit score.
Assessment demo-sample-assessment · 6/18/2026
5 of 5 clauses considered produced a classified verdict below.
Every clause in scope for this product is tested directly and accounted for in this report — none are filtered out by a relevance step before reaching a conclusion. See /architecture for how the regulatory corpus is scoped.Loan disbursal is described as passing through the partner NBFC's pooled settlement account before reaching the borrower, rather than moving directly from the RE to the borrower's bank account.
DLG Para 5(i) requires all disbursals and repayments to be executed directly in the bank account of the borrower, with no pass-through or pool account for the LSP or any third party. A pooled settlement account is exactly the structure this clause was written to prohibit.
Why this confidence: The description explicitly states disbursal is routed through a pooled settlement account — direct, unambiguous evidence of the exact structure this clause prohibits, not an inference.
“All loan disbursals and repayments shall be executed directly in the bank account of the borrower, without any pass-through or pool account of the Lending Service Provider (LSP) or any third party.”
RBI Digital Lending Guidelines, September 2022
Reserve Bank of India· Version 1· Published September 2022
The app requests full contact list and SMS access during signup, ahead of and unrelated to any specific loan-servicing need.
DLG Para 7 prohibits blanket permission to access phone resources such as contact lists, call logs, and SMS at onboarding — access must be need-based, tied to a specific purpose, and taken with explicit consent at the time of use.
Why this confidence: The description explicitly states the app requests full contact list and SMS access at signup for credit scoring — direct evidence of blanket permission collection at onboarding, exactly what this clause prohibits.
“Blanket permission to access mobile phone resources including files and media, contact lists, call logs, telephony functions, etc., shall not be taken at the time of onboarding / app installation. Such access shall be based on need and purpose for each permission.”
RBI Digital Lending Guidelines, September 2022
Reserve Bank of India· Version 1· Published September 2022
The product performs video KYC, which typically triggers a risk-categorisation obligation, but the description gives no indication that customers are subsequently tiered by risk — this reads as a likely gap, not a confirmed one.
Risk-based customer categorisation is a foundational KYC/AML control: it determines how often a customer's KYC is refreshed and whether enhanced due diligence applies. Skipping it flattens every customer to the same due-diligence level regardless of actual risk.
Why this confidence: Video KYC confirms a formal identification process exists, which usually implies a risk-categorisation step should follow — but nothing in the description confirms tiers are actually assigned, so this is inferred as likely rather than certain.
Inferred that risk categorisation is a live obligation here because the product performs formal KYC and extends credit — both conditions under which risk-based due diligence is expected.
“A regulated entity shall categorise customers into low, medium, and high risk based on factors such as identity, occupation, source of funds, location, and nature of business, and apply due diligence measures proportionate to the assigned risk category.”
RBI Master Direction – Know Your Customer (KYC), 2016 (as amended) — reconstructed from general knowledge, NOT verified against current source text
Reserve Bank of India· Version 1· Published 2016 (as amended)
The product description does not state whether a cooling-off / look-up period is offered — this cannot be confirmed as present or absent from the information given.
DLG Para 6 requires a minimum three-day cooling-off period for loans with tenure of seven days or more, during which the borrower can exit by repaying the principal and proportionate APR with no penalty. If missing, this is a real gap — but silence alone isn't evidence either way.
Why this confidence: No discovery answer addresses the cooling-off period and the product description is silent on it — there is no basis to conclude compliance or non-compliance, only that it is unconfirmed.
“The borrower shall be given an explicit option to exit the digital loan by paying back the principal and the proportionate APR without any penalty during a cooling-off / look-up period. The minimum cooling-off period shall be three days for loans with tenure of seven days or more.”
RBI Digital Lending Guidelines, September 2022
Reserve Bank of India· Version 1· Published September 2022
The product description confirms borrowers are shown the Key Fact Statement — including APR and total cost — before confirming the loan, satisfying the core KFS disclosure requirement.
DLG Para 6 requires REs to provide a Key Fact Statement including APR and all-in cost before the loan contract is executed, so borrowers can evaluate the true cost of credit before committing. Confirming a control is in place is as important to document as identifying gaps — a report that only ever lists problems isn't a credible assessment.
Why this confidence: The description explicitly states the KFS, including APR and total cost, is shown before the borrower confirms the loan — direct, unambiguous evidence of compliance, not an inference.
“REs shall provide a Key Fact Statement (KFS) to the borrower before the execution of the loan contract. The KFS shall include the Annual Percentage Rate (APR), all-in cost including fees and charges, and the grievance redressal mechanism.”
RBI Digital Lending Guidelines, September 2022
Reserve Bank of India· Version 1· Published September 2022
Generated by RegImpact AI · Created by Shriyashish Mishra