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When Fines Replace Accountability: The NSE Settlement and the Arithmetic of Absurdity
NSE Settlement and the Arithmetic of Absurdity The proposed settlement between the National Stock Exchange of India (NSE) and the Securities and Exchange Board of India (SEBI) is being presented as closure. In formal terms, it fits within a consent-based enforcement architecture. In economic terms, however, it raises a sharper question: Has a multi-year structural distortion of market fairness been reduced to a financially efficient exit? A tighter reading—through the lenses
Rajangam Jayaprakash
Apr 233 min read


RBI’s Tightening of NBFC Lending to Defaulting Borrowers: A Necessary but Delayed Intervention
The Reserve Bank of India (RBI) has recently tightened regulations governing how Non-Banking Financial Companies (NBFCs) lend to borrowers who have already defaulted on existing loans. The regulatory move aims to prevent the practice of extending fresh credit to stressed borrowers without adequate safeguards—a practice that can mask underlying asset quality issues and deepen systemic risk. While the intent of the RBI’s action is sound and necessary, the intervention arguably
Rajangam Jayaprakash
Mar 43 min read


Board-Level Early Warning Dashboard with respect to fraud in revenue recognition
Revenue recognition remains the single most significant fraud risk area identified by the National Financial Reporting Authority (NFRA). In its inspection and enforcement memoranda, NFRA has consistently observed that revenue misstatements rarely arise from technical errors, but from deliberate misuse of judgment, premature recognition, suppression of variable consideration, and management override of controls. NFRA has emphasised that Boards and Audit Committees carry a heig
Rajangam Jayaprakash
Jan 63 min read


NBFC Growth Approval Scorecard - For Board / Audit & Risk Committee governance Use
Purpose: To objectively assess whether a proposed growth rate is prudent, fundable, controllable, and survivable under stress . Yesterday's blog was focussed on the Growth approval philosophy. Today i am building further detailed blocks on how NBFC Board members can take a structured governance call on growth strategy. How to Use: Score each category from 1 (Weak) to 5 (Strong) Apply the weighting Compute the weighted score Use the decision matrix before approving growth
Rajangam Jayaprakash
Dec 27, 20252 min read


NBFC Board governance Checklist - Before Approving Growth Rate / Business Expansion
Purpose: To ensure growth decisions are risk-aligned, funding-backed, and governance - sound , and to protect NBFC Board of directors from regulatory and personal liability. 1. Business Model & Growth Rationale ☐ Is the proposed growth consistent with the NBFC’s core business model (product, customer segment, tenure)? ☐ Is growth driven by underwriting strength or by availability of short-term funding ? ☐ Does management clearly articulate why this level of growth is s
Rajangam Jayaprakash
Dec 26, 20253 min read


Director Liability Heat Map - NBFC Governance Boards – RBI Supervisory Perspective
Audience: NBFC Board of Directors | Audit Committee | Risk Management Committee Applicability: Middle Layer & Upper Layer NBFCs (heightened relevance post SBR) Objective: To identify areas of highest regulatory and personal liability exposure for NBFC directors under RBI oversight. This is in continuation to my earlier blog which focussed on "Tone at the Top" for Banks and financial Institutions. However my experiences make me capture and articulate NBFC governance linke
Rajangam Jayaprakash
Dec 25, 20253 min read


Director Liability Heat Map - RBI Regulatory Oversight Perspective
Audience: Board of Directors | Audit Committee | Risk Management Committee Objective: To identify areas of highest regulatory exposure for directors and committees under RBI supervision. Over the years i have interacted with mutiple Financial services entities in India and Abroad. I have also had the opportinity to engage with financial regulators in the course of my consulting engagements. i have realized that that "Tone at the Top" sets up the financial institution for su
Rajangam Jayaprakash
Dec 25, 20252 min read


Genesis of scams in Financial Services sector – Manner and causation
Financial sector scam, the manner it is perpetuated and the root cause.
Rajangam Jayaprakash
Nov 24, 20257 min read
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