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Naman Lodha

Senior Associate in the Financial Services Regulatory Practice at the Mumbai office of Cyril Amarchand Mangaldas. Naman advises clients on regulatory matters with respect to financial services. He can be reached at naman.lodha@cyrilshroff.com

FIG Paper No. 61: RBI’s Draft Data Governance Guidance: An Overview

Summary: The RBI has released the Draft Guidance on Regulatory Expectations for Data Governance, proposing a comprehensive enterprise-wide framework applicable across banks, NBFCs, payment banks, co-operative banks, CICs, and other regulated entities. The Draft Guidance emphasises board oversight, defined data governance roles, lifecycle-based controls, SSOT architecture, metadata and lineage management, data classification, data quality processes

FIG Paper No 59 – AI in Indian Financial Services: Balancing Innovation with Accountability and Regulation

Summary: As artificial intelligence reshapes the contours of India’s financial landscape, regulated entities find themselves navigating a delicate balance between harnessing transformative innovation and managing its inherent risks spanning algorithmic bias, model opacity, and systemic concentration. The RBI’s establishment of the FREE-AI committee signals a decisive regulatory commitment to responsible AI governance, anchored in principles of accountability, fairness, and explainability. The paper ultimately calls upon regulated entities to embed these imperatives at the very foundation of their AI frameworks, underpinned by robust data governance and a culture of institutional vigilance.

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FIG Paper No 58: RBI Issues Operating Framework for Facilitating Outward Remittance Services by Non-Bank Entities

Introduction

The Foreign Exchange Department, Reserve Bank of India (“RBI”), on May 13, 2026, issued a circular titled ‘Operating framework for facilitating Outward Remittance services by non-bank entities through Authorized Dealer (Category I) Banks (“AD Banks”) in India’ (“Outward Remittance Circular”), which:

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FIG Paper No. 50: Recent SEBI Changes – Implications for Intermediaries

Summary: SEBI has recently approved various rule changes for intermediaries such as stock-brokers, REITs/ InvITs, IAs, RAs, FPIs, and angel funds, with a view to ease entry norms and compliance obligations, provide flexibility and to attract more retail and foreign investments. This paper summarises the key changes and their implications for intermediaries.

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FIG Paper no. 48: Change in Control & Learnings in FIG space

Mergers and acquisitions (M&A) in the banking, financial services, and insurance (BFSI) sector constituted approximately 10% of all M&A activity in India in 2024, exceeding USD 12.1 billion[1] in value, making it the second highest among all sectors. Infrastructure and BFSI are expected to continue driving M&A deal activity in India. Recently, India is seeing several large M&A transactions involving complex structuring, regulatory approvals on account of change in control, bespoke due diligence and documentation considerations and nuanced approach to regulatory interface before and after deal signing to obviate deal failure risks. Basis our recent experience, and change in control provisions applicable to banks, non-banks, payment system operators (PSOs), mutual funds and insurance players, this paper provides an overview of the specific deal and change in control linked regulatory approvals and learnings / considerations relevant from a transaction structuring and deal execution perspective, across each of the BFSI verticals.

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FIG Paper (No. 42 – Series 1) – Regulatory Trends in NBFC Sector

Background

Of India’s overall credit market, non-banking financial companies (“NBFCs”) command a 22% share[1], primarily catering to underserved sectors and providing retail loans, particularly to small businesses and households. As NBFCs have become systemically important for the economy, they have been subject to increased regulatory oversight by the Reserve Bank of India (“RBI”), evidenced by the introduction of scale-based regulations, which prescribe differential regulatory norms basis size and scale of the NBFC. This FIG paper explores the recent regulatory trends in this sector.

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FIG Paper (No. 40 – Data Law Series 6) Draft Digital Personal Data Protection Rules, 2025 - Key Implications for Financial Services Sector

Background:

  1. India’s first dedicated data privacy law, the Digital Personal Data Protection Act, 2023 (“DPDP Act”)[1], was passed by both houses of Parliament, and received Presidential assent on August 11, 2023. 
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FIG Paper (No. 37 – Series 1) | SEBI Proposes to Introduce ‘New Asset Class’

Background and Key Features:

  • The Securities and Exchange Board of India (“SEBI”) regulates the asset management and wealth management sector through a graded approach in relation to prudential, governance and investment norms, with flexibility given progressively, basis minimum investment threshold. This sector has also seen a significant rise in assets under management (“AUM”) over the last decade:
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FIG Paper No 29 – Data Law Series 3: (Implications of Digital Personal Data Protection Act, 2023, on Asset Management Companies)

Background:

  • Asset Management Companies (“AMCs”) act as fiduciaries of unitholders (i.e. investors who hold units in funds managed by an AMC), due to which the Securities and Exchange Board of India (“SEBI”) has mandated various data privacy obligations for AMCs, either directly or through the Association of Mutual Funds of India (“AMFI”).
  • SEBI, in a private letter to AMCs, AMFI and registrar and transfer agents (“RTAs”) dated July 10, 2020 (“SEBI Letter”), required that digital platforms involved in distribution/ advisory and AMCs/ RTAs must respect unitholder’s data privacy. The letter included the following two mandates:
    • unitholder data should not be shared with group entities having multiple business/ products; and
    • products and services of group companies cannot be cross marketed.
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