POLICY &
REPRESENTATIONS.
A historical record of our systemic interventions and regulatory submissions.
Refine Archive
REPRESENTATION TO CANARA BANK
Request for reconsideration of penalties on BCs for delayed onboarding. Emphasized operational realities like limited infrastructure in remote areas, dependency on third-party verifications, and device shortages.
REQUEST FOR REVIEW OF BC FRAMEWORK – DFS
Proposed to Ministry of Finance to revisit guidelines around certification, audits, and biometric auth. Suggested self-paced online certification, digital audits, and Face Authentication rollout to safeguard DBT infrastructure.
PRESENTATION TO DPSS, RBI ON BC OPERATIONS
Presented overview of BC types, transaction flows, and challenges in AePS/DMT. Advocated for streamlined processes, secure agent verification, and efficient commission settlements.
CLARIFICATION ON MOBILE BCs VS. BANKING OUTLETS
Proposed defining "Mobile BCs" (CiCo/DMT apps) separately from full-service "Banking Outlets". Recommended online training for Mobile BCs and IIBF certification for full-service BCs.
PROPOSAL ON STRENGTHENING AePS SECURITY
Proposal for uniform BC onboarding including dual biometric authentication, geo-fencing, AI fraud detection, transaction limits for new BCs, and blacklisting of high-risk zones.
EASE OF DOING BUSINESS & BC VIABILITY
Submitted to DFS Monitoring Committee. Raised issues on entry-level certification for Transaction BCs via online modules, UIDAI face-auth certification, and digitization of SHG loans.
SCALING BC TRAINING TO COVER 20 LAKH AGENTS
Proposed scalable, tech-driven training to IBA & DFS. Recommended removing complex services from basic syllabus and shifting to self-paced digital modules with AI-enabled Virtual Proctoring.
FOLLOW-UP ON IIBF CERTIFICATION
Reiterated need for auditable, self-learning modules to meet deadlines. Confirmed IIBF readiness for proctor-less exams and requested inclusion of BCFI CEO as Special Invitee to BC Governing Council.
REQUEST FOR ONLINE CERTIFICATION MODEL
Sought RBI support to scale up certification via online exams to address mass backlog. Flagged urgency of certifying 15-20 lakh Transaction BCs and infrastructure gaps.
WORKING GROUP SUBMISSION ON ECOSYSTEM REFORM
Submitted to Ministry of Finance. Recommendations included fair agent compensation, mobile-first models for remote regions, tiered certification, women agent inclusion, and tax exemptions (TDS/GST).
DFS SUB-COMMITTEE FEEDBACK
Recommended classifying CSPs into Level-1 (Mobile) and Level-2 (Fixed). Proposed minimum 60% commission share for CSPs, fixed monthly payouts for rural areas, and rationalized commission caps.
FREEZING OF CORPORATE BC ACCOUNTS BY CYBERCRIME
Raised concerns over freezing of entire settlement accounts due to disputed fraud. Proposed listing nodal officers, applying lien only on disputed amounts, and automatic lien removal after 4 weeks.
Research Repository
Our team continuously monitors the regulatory landscape to ensure BCs are represented at the highest levels of policy making. For specific archived data older than 2024, please contact our secretariat.