(I) BACKGROUND
The Reserve Bank of India ("RBI")
which regulates inter alia credit systems and markets in
India has been considering the regulatory ecosystem around
'digital lending1' ("Digital
Lending") for some time now. It had constituted a
Working Group on 'digital lending including lending through
online platforms and mobile apps' led by one of its
executive directors, Mr. Jayant Kumar Dash ("Working
Group") which had submitted a set of recommendations
to the RBI on November 21, 2021 ("WG
Report"). The WG Report included a host of
recommendations to the RBI and the central government
vis-à-vis the required changes to the digital
lending ecosystem.
Now some of those recommendations have been accepted and the RBI
has issued a press release on August 10, 2022 ("Press
Release"). The Press Release contains:-(a)
recommendations from the WG Report which are up for immediate
implementation; (b) recommendations from the WG Report which have
been accepted in-principl
