You are on page 1of 11

FINTECH NEWSLETTER:

RECENT LEGAL
DEVELOPMENTS AND
MARKET UPDATES FROM INDIA
JUNE 01, 2023 - JUNE 30, 2023

Authors: Avimukt Dar | Suneeth Katarki | Namita Viswanath


| Shreya Suri | Sarthak Doshi | Srika Agarwal | Pravi Jain
01 of 06

INTRODUCTION

Regulatory developments in the fintech sector are being the highest among start-ups in other sectors, similar to
rolled out at a pace like never before. June 2023 started 2019-2020 levels.1 Although, given the dynamic nature
off with the Reserve Bank of India (“RBI”) robustly of the fintech landscape as well as persistent oversight
responding to the industry’s call for clarity on Default Loss and intervention from financial regulators in the country,
Guarantee (“DLG”), alongside other proposals involving the industry could potentially witness a slowdown in the
expansion in the scope of e-RUPI vouchers and issuance coming months.
and use of RuPay cards for international payments.
This newsletter highlights key developments,
Despite the funding winter looming in the market, announcements, measures as well as other developments
the fintech sector has seen funding of nearly USD 2.1 in the Indian FinTech space from June 01, 2023, to June
billion being raised in the March-June 2023 quarter - 30, 2023.
02 of 08

RECENT LEGAL & REGULATORY DEVELOPMENTS

RBI issues the much-awaited guidelines on the with unregulated entities. The Draft Directions
DLG model accordingly provide a framework for information security
and emphasize on cyber resilience to secure digital
On June 8, 2023, the RBI released the ‘Guidelines on
payment transactions. In this regard, PSOs are required
Default Loss Guarantee in Digital Lending’2 (“DLG
to formulate a board approved information security
Guidelines”) to govern the DLG model. The DLG model
policy and implement a cyber crisis management plan
for the very first time recognises and permits regulated
to detect, contain, respond to, and recover from cyber
entities (“REs”) to enter into arrangements with lending
threats and attacks.
service providers (“LSPs”) or other REs, under which the
latter guarantees to compensate the RE, loss due to The Draft Directions also propose that PSOs must put in
default (up to a certain percentage) of the loans provided place a board approved incident response mechanism,
by the RE. with provisions to notify its senior management, relevant
employees and regulatory and supervisory authorities
While the latest development comes as a respite to
about cyber incidents. Any cyber security incident is
fintech companies who were requesting RBI to allow
required to be reported to Indian Computer Emergency
DLG models, there are certain guardrails that the RBI has
Response Team (CERT-In).
put in the DLG Guidelines.
IndusLaw was involved in the stakeholder consultation
The most significant among these is prescribing an
process on the Draft Directions and has provided
overall 5% (five percent) limit on the DLG cover that a
stakeholder comments to the RBI.
third-party can provide on the total loan portfolio, which
means most of the credit risk will continue to remain with
the RE. Further, the DLG amount cannot be set off against RBI expands the scope of Trade Receivables
the underlying individual loans and REs are required to Discounting System
invoke the DLG within a maximum overdue period of
On June 07, 2023, the RBI expanded the scope of the
120 (one hundred and twenty) days, unless paid by the
Trade Receivables Discounting System (“TReDS”)4
borrower before invocation. Other safeguards under the
as prescribed under the Guidelines for the Trade
DLG guidelines require REs to have a board-approved
Receivables Discounting System, 2014 (“Guidelines”)
policy for DLG arrangements, providing an eligibility
(updated as on July 02, 2018).5 TReDS is a type of a
criterion for the third party, fees payable by the RE (if
‘payment system’ that enables Micro, Small and Medium
any), and process for monitoring and reviewing DLG
Enterprises (“MSMEs”) to finance or discount their
arrangements, among others.
trade receivables through different financiers. Earlier,
You can find our article analysing the DLG Guidelines on February 08, 2023, the RBI had announced in the
here. Statement on Developmental and Regulatory Policies,
to make certain enhancements to the Guidelines, which
had been issued to MSMEs in converting their trade
RBI releases the ‘Draft Master Directions on receivables to liquid funds.
Cyber Resilience and Digital Payment Security
Controls for Payment System Operators’ RBI has now proposed to expand the scope of the
Guidelines to further facilitate operation of the TReDS
On June 02, 2023, the RBI released the draft ‘Master
by permitting all entities and institutions, allowed to
Directions on Cyber Resilience and Digital Payment
undertake factoring business under the Factoring
Security Controls for Payment System Operators’ (“Draft
Regulation Act, 2011, to participate as financiers. TReDS
Directions”) inviting feedback and comments from
are now also permitted to have insurance facility and
stakeholders by June 30, 2023.3
secondary market operations on their platforms. Apart
The Draft Directions are proposed to apply to all from this, the other requirements of TReDS will remain
authorised non-bank Payment System Operators the same. This move by the RBI will improve the cash
(“PSOs”) and aim to identify, manage, monitor, and flow of MSMEs by enabling financing by a wider range of
improve safety and security of the payment systems financiers, ultimately boosting the growth of the MSME
operated by PSOs in order to help them avoid any cyber industry.
and technology related risks arising from partnerships
03 of 08

RBI releases framework for ‘Compromise a clear definition of what constitutes a complaint
Settlements and Technical Write-offs’ under the Internal Grievance Redress mechanism, as
well as recommended to strengthen regulation for
Over the years, the RBI has issued various instructions
overall customer protection in the financial sector. The
to REs regarding compromise settlements in respect of
Committee has also identified certain gaps as well as
stressed accounts, including the Prudential Framework
lack of enforcement action against REs failing to meet
for Resolution of Stressed Assets dated June 07, 2019.6
customer service requirements. Accordingly, it has
On June 08, 2023, the RBI released a supplementary urged REs to leverage technology for better delivery of
regulatory framework for compromise settlements customer services and has proposed penal action against
and technical write-offs applicable to all REs7 REs which fail to meet the customer service standards,
(“Supplementary Framework”) followed by some while also providing incentives to REs making systemic
frequently asked questions thereon.8 It is important improvements.
to note that the Supplementary Framework does not
prescribe any debt threshold to trigger its applicability.
SEBI amends the Anti-Money Laundering/
The Supplementary Framework provides a clear Combating the Financing of Terrorism Guidelines
definition of ‘compromise settlements’ and ‘technical for Securities Market Intermediaries
write-offs’ and has mandated REs to put in place board- On June 16, 2023, the Securities and Exchange
approved policies for delegation of powers for approval Board of India (“SEBI”) issued a circular amending
and proposals to undertake compromise settlements in the Guidelines on Anti-Money Laundering (“AML”)
respect of debtors classified as fraud or wilful defaulters. Standards and Combating the Financing of Terrorism
The Supplementary Framework inter alia also outlines (“CFT”) Obligations of Securities Market Intermediaries
the pre-conditions and process for undertaking such (“Guidelines”) under the Prevention of Money-
settlements and write-offs, along with a mechanism for laundering Act, 2002 and rules framed there under, to
reporting to the supervisory body. ‘further enhance the effectiveness of the AML/CFT
framework.’11
RBI publishes report of the Committee for The circular emphasizes the key changes made to the
Review of Customer Service Standards in RBI Guidelines, which includes modification to the definition
Regulated Entities of a ’group’, addition of requirements regarding
On June 05, 2023, the RBI released a report prepared issuance of statement of policies and procedure to
by the committee formed for reviewing customer service deal with money laundering and terrorism financing
standards for REs (“Committee”), inviting comments by securities market intermediaries (“Intermediaries”)
and feedback from stakeholders by July 07, 2023.9 to reflect the current regulatory requirements. Further,
the Intermediaries have been directed to register the
The Committee was set up by the RBI in May 2022 to details of clients which are non-profit organizations, on
evaluate and review the quality of customer service, the Digital Advancement of Rural Post Office for a new
examine evolving needs, identify global best practices, India (DARPAN) Portal of NITI Aayog and maintain the
and suggest measures for improvement in processes record of such registration for 5 (five) years, after such
and standards.10 business relationship with the client comes to an end
In the report, the Committee has made observations with or closing of the client’s account, whichever is later. The
respect to lack of uniformity among REs in classifying Guidelines have further directed Intermediaries and
customer complaints and has urged the RBI to establish stock exchanges to leverage technological innovations
for effective implementation of name screening.
04 of 09

INDUSTRY CHALLENGES

RBI and NPCI direct co-branding partners to players. Further, while the DLG Guidelines now permit
‘stop UPI in a co-branding arrangement’ LSPs to provide DLG cover to the REs, the cap of 5%
(five per cent) for such DLG cover has been viewed by
The RBI, through the National Payments Corporation of
many as low, given that most of the credit risk would
India (“NPCI”) had directed both bank and non-bank
still lie with the REs. Additionally, going forward, the
issuers of prepaid payment instruments (“PPIs”), to stop
due diligence and disclosure requirements stipulated
providing Unified Payments Interface (“UPI”) services in
under the DLG Guidelines, may also have an impact on
a co-branding arrangement by June 30, 2023. While this
increased regulatory compliance burden on LSPs, which
directive has not been formally notified by either the RBI
in turn may pose cost and business continuity challenges
or NPCI, news reports indicate that certain players have
for the LSPs. Given that the DLG Guidelines are still at
received emails from the abovementioned regulators
an extremely nascent stage, the manner in which these
in this regard. Through this directive, the RBI and NPCI
challenges play out and how stakeholders adapt to the
have asked PPI issuers to ensure that PPI holders are on-
same remains to be seen.
boarded only by their own PPI issuer, therefore directing
all PPI issuers providing UPI services on partner/co-
branded application to discontinue issuance of the SEC acts against Binance and Coinbase
PPI wallet.12 The reports also indicate that PPI issuers
United States (“US”) Securities and Exchange
have been directed to share an official confirmation to
Commission (“SEC”) filed charges against: (i) Binance
the NPCI with respect to their discontinuation of PPI
Holdings Ltd., which operates the crypto asset trading
offerings under the partner/ co-branded model on UPI.13
platform Binance.com and Binance.US with its affiliate
The RBI has also communicated and directed PPI license
BAM Trading Services Inc. (collectively referred as
holders that non-PPIs cannot undertake UPI services with
“Binance”), and (ii) Coinbase Inc. (“Coinbase”), for
any third-party PPI license holders.
multiple violations of federal securities laws captured
This move has predominantly affected the integrated in the Securities Act and the Exchange Act (collectively
and co-branded wallet providers who do not hold a referred as “SEC Regulations”).15 SEC, in its charges,
PPI authorisation and partner with other PPI issuers has explicitly identified certain crypto assets (such as
to provide UPI as a payment service on their digital SOL, and MATIC) and stable coin (such as Binance USD)
application. While the exact reasons for issuing this as ‘securities’ under the SEC Regulations. The SEC has
directive are unclear, the move has put on hold on-going also reviewed the crypto trading platforms and taken a
operations of these entities. Accordingly, the only way position that they are akin to exchanges and clearing
for these companies to enable UPI transactions is to get agencies, therefore requiring registration under the SEC
a PPI authorisation. Given the sudden and unexpected Regulations. The charges of the SEC against Binance and
nature of the direction, several players in the market Coinbase impacts the market and legal understanding
have been forced to rethink their business models. on what may be construed as ‘securities’ in the US.

It is important to note that the Howey test is the only test


Impact of the DLG Guidelines on the Fintech in the US which determines whether an asset qualifies
Sector as a ‘security’, based on fulfilment of 4 (four) elements,
i.e., whether a transaction is (a) an investment of money,
The issuance of the DLG Guidelines by the RBI is no
(b) in a common enterprise, (b) with the expectation
doubt a significant milestone for the digital lending
of profit, (d) derived from the efforts of others. Given
sector in India. While the DLG Guidelines have received
the wide interpretation that can be accorded to these
a positive response from the industry, there are certain
elements, a lot of discretion vests with the SEC on what
challenges that continue to exist and would have to be
can be considered as ‘securities’. For instance, in relation
navigated by the stakeholders involved.
to crypto assets, the SEC was earlier of the view that if
Given that the DLG Guidelines were effective on the a crypto asset is more decentralized (i.e., the control
date of its issuance, there is limited clarity on how over a particular crypto asset vests with a larger group
stakeholders are expected to transition their existing of individuals, against a single centralised source), it may
arrangements in this regard, which has caused some fall outside the ambit of ‘securities’. However, whether
amount of chaos and uncertainty amongst industry a particular crypto asset is decentralized enough to
05 of 09

fall outside the scope of the ‘securities’ would be of the impact on the cryptocurrency market in the US,
determined by the SEC itself based on its interpretation we may witness more entities actively shifting their
of the Howey, and such determination could be very operations to countries that provide a regulatory haven
subjective, with the possibility of extending to other for such businesses, instead of the US. There may also be
crypto assets in the future. a sudden surge of attempts at registration with the SEC.
Moreover, without access to the US market and given the
Given the circumstances, it is becoming apparent that
‘long arm’ jurisdiction of the SEC, it could prove crippling
the SEC aims to incorporate crypto assets under its
for the industry including decentralized finance (DeFi),
jurisdiction. Considering the aforesaid lawsuits, it is
especially given the overall impact on how regulators
conceivable that the consequences of these cases may
worldwide perceive and analyse the SEC’s recent moves
significantly impact the SEC’s enforcement endeavors
in the crypto sector.
in the crypto industry for an extended period. In terms
06 of 09

MARKET UPDATES AND MAJOR DEALS IN INDIAi

The ‘Statement on Developmental and Regulatory Separately, it is also relevant to note that the
Policies, issued by the RBI on June 08, 2023 International Organization of Securities Commissions
(“Statement”),15 proposed certain positive changes for (“IOSCO”) unveiled a consultation report titled “Policy
the sector such as an expansion in the scope of purpose Recommendations for Crypto and Digital Asset Markets.”
and activity specific e-Rupi vouchers, by permitting This can be seen as a consequence of the collapse of
(a) non-bank PPI issuers to issue e-Rupi vouchers, and the US based crypto exchange FTX, that raised concerns
(b) enabling issuance of e-RUPI vouchers on behalf over consumer protection. The industry, which typically
of individuals. Through the Statement, the RBI also only has to comply with anti-money laundering checks,
proposed to streamline the membership process for has been calling for a global regulation, as different
Bharat Bill Payment Operating Units, to make the Bharat jurisdictions follow their own rules. The recommendations
Bill Payment System more efficient and garner increased are a set of 18 (eighteen) principles that aim to promote
participation. Furthermore, in order to enable increased investor protection and market integrity in the crypto
payment options for Indians travelling abroad, the RBI sector. The recommendations cover a wide range of
has decided to permit banks to issue RuPay Prepaid topics, including market abuse, custody of assets, and
Forex Cards which can be used at ATMs, Point of Sale consumer protection. The IOSCO recommendations are
(PoS) machines, and online merchants overseas. The RBI significant because they represent the first global attempt
will also enable issuance of RuPay Debit, Credit, and to regulate the crypto sector. The recommendations are
Prepaid Cards in foreign jurisdictions, which can be used likely to have a major impact on the way that crypto
internationally (including in India). businesses operate, and they could also help to attract
more institutional investors to the sector.

While the RBI has made efforts to keep regulations at


pace with evolving business needs, it has not loosened The IOSCO recommendations are a positive step
its grip on regulatory oversight. Certain media reports towards regulating the crypto sector. However, it remains
published in June 2023 indicate that the RBI reached to be seen how effective the recommendations will be
out to registered peer-to-peer (“P2P”) lending startups in practice. The success of the recommendations will
in March and April 2023, and posed various questions depend on a number of factors, including the willingness
to such entities in relation to their partnership modes of regulators to enforce the rules and cooperation of
with consumer-facing applications, and risk-sharing crypto businesses.
mechanism adopted by them.16 This is said to have been
an aftermath of the issuance of the ‘Digital Lending
Lastly, financial influencers (“finfluencers”) came to the
Guidelines’ by the RBI on September 02, 2022, and a
spotlight in the last week of June, when an advertisement
part of the RBI’s efforts to ensure that REs in the digital
featuring a finfluencer was published with logos of the
lending space are compliant with such guidelines.
Ministry of Electronics and Information Technology
(“MeitY”), and the India G20, which in turn gave several
Further, the Parliamentary Standing Committee on readers the impression that the advertisements were
Finance while dealing with ‘cyber security and rising endorsed by the Government.19 The MeitY subsequently
incidence of cyber/white collar crimes’ headed by Lok clarified that the same ought not to be seen as an
Sabha MP, Jayant Sinha (“Parliamentary Committee”) endorsement by the Government of a specific individual,
also recently posed questions to startup executives in or social media platform. The development received
fintech companies, on the increased rate of cybercrime significant backlash from the industry and sparked a
incidents in India and actions which can be taken debate on the content published by finfluencers, given
to effectively address the same. The Parliamentary that SEBI-registered investment advisers are required to
Committee also discussed the operations of illegal comply with various regulatory norms, while finfluencers,
lending applications which have recently been singled who are not regulated and are not required to adhere
out for charging extremely high interest rates and for to any norms, have often through their content said to
harassing customers. provide advice which may be seen as investment advice.

i. To the extent any transactions involve clients of IndusLaw, the information herein is based on statements in the media and not our
professional knowledge of the relevant transaction.
07 of 09

This elicited a response from the SEBI in the form of a is expected to expand Cred Flow’s target market and
draft discussion paper, outlining rules and guidelines for enable the company to cater to a wider range of SME
regulating finfluencers, which is expected to be released customers.25
within the next 2 (two) months.20

Pepper Group, a Singapore-based consumer finance


That said, players in the fintech industry have continued company has announced an investment of USD 150 (One
to grow at a steady space, and the industry witnessed Hundred and Fifty) Million over the course of the next 4
certain notable developments in the month of June. (four) years to establish a fintech startup in India under
the brand name of Pepper Money. The fintech startup is
scheduled to launch in the second half of 2023 and will
PayMate,ii a leading B2B payment solutions provider, target 150 (one hundred and fifty) million households in
following receipt of an in-principle approval from RBI to
smaller cities that demonstrate a potential for economic
operate as a payment aggregator, is gearing up to re-
growth.26
file its Draft Red Herring Prospectus (“DRHP”) with SEBI
in the next 3 (three) months. In May last year, PayMate
had filed its DRHP with an IPO offer of USD 182.36 Indifi Technologies, an online lending platform, has
(one hundred and eighty-two point thirty-six) Million. raised USD 35 (thirty-five) Million in its recent Series E
However, earlier this year, SEBI asked PayMate to refile funding round. The round was led by funds managed
its DRHP with updated details.21 and advised by ICICI Venture, with participation
from existing investors including British International
Investment, OP Finnfund Global Impact Fund I, Omidyar
PhonePe,iii a prominent player in the fintech industry, Network India, Flourish Ventures, and CX Partners. The
has recently introduced its very own payment gateway
startup aims to accelerate its growth trajectory through
(“PG”).22 PhonePe’s PG offers a special free onboarding
expansion and an increased market presence with the
offer exclusively for new merchants, while most
infusion of fresh capital. It will also utilize the funding to
competing PGs impose a standard transaction fee of
focus on developing new products to better serve the
2% (two per cent). Earlier this month, the PhonePe
underserved segments of the MSME sector.27
group also launched its Account Aggregator (“AA”)
services, following the receipt of its NBFC – Account
Aggregator license from the RBI.23 The AA services Lentra, a cloud-based lending software provider that
are being facilitated through PhonePe’s wholly-owned helps banks and financial institutions digitise credit
subsidiary, PhonePe Technology Services and will disbursal and loan servicing, has raised USD 27 (twenty-
enable users to seamlessly share their financial data, seven) Million in an extended Series B round. The
including bank statements and insurance policies. round was led by MUFG Bank and Dharana Capital. The
Additionally, PhonePe, towards the end of June, also fresh funding will help Lentra explore synergies within
launched a merchant lending marketplace which would the group, including with its strategic partner banks in
permit banks and NBFCs to offer credit to PhonePe’s 35 southeast Asia.28
(thirty-five) million strong merchant base.24 With these
significant new offerings, PhonePe has forayed deeper
into the fintech landscape, and fostering a more robust
Revfin, an electric vehicle financing company, has raised
USD 5 (five) Million from US International Development
ecosystem for merchants and customers alike.
Finance Corporation. The company intends to utilise
these funds for introducing new products, diversify into
CredFlow, a small and medium enterprises (“SME”) two-wheelers for last-mile deliveries, four-wheelers for
focused cash flow management company has mid-mile cargo delivery, and ride-share taxis.29
acquired business management start-up TechBiz, for
an undisclosed amount in an all-cash deal. Cred flow
offers SMEs with comprehensive financial solutions and
TechBiz assists SMEs in tracking overdue payments and ii. PayMate is a client of IndusLaw.
sending timely reminders to customers. This acquisition iii. PhonePe is a client of IndusLaw.
08 of 09

KarmaLife, a credit solutions provider for gig workers, four) Million in a long-term debt funding from growth-
has raised USD 5.3 (five point three) Million in an extension stage debt financing platform EvolutionX Debt Capital.
to its pre-Series A funding round. The round was led by The startup aims to utilise the funds to drive growth and
Krishna Bhupal’s family office and existing investor, Artha enable financing to a larger number of MSMEs across
Venture Fund, and saw participation from other existing India.31
investors, including Net Graph Investments, Singularity
Ventures, LogX Venture Partners, Balesh Sharma, Amit
Scapia, a traveltech startup has raised USD 9 Million
Jain, Vikram Kailas, and Shaji Kumar Devakar. The
in a seed round led by Matrix Partners India. The round
company aims to use the fresh funds to scale and expand
also saw participation from Tanglin Venture Partners,
into new geographies and launch more products.30
Binny Bansal’s 3 STATE Ventures and angel investors Keki
Mistry, CEO of HDFC Ltd. The startup, founded in 2022,
Lendingkart, a fintech startup which evaluates will utilise the fresh funds to scale operations and invest
borrower’s creditworthiness, has raised USD 24 (twenty- in technological capabilities.32
09 of 09

1. https://inc42.com/buzz/winter-gloom-investors-shiver-indian-startup-funding-falls-5-4-bn-h1-2023/
2. https://www.rbi.org.in/Scripts/NotificationUser.aspx?Id=12514&Mode=0
3. https://www.rbi.org.in/Scripts/bs_viewcontent.aspx?Id=4267
4. https://rbi.org.in/Scripts/NotificationUser.aspx?Id=12510&Mode=0
5. https://www.rbi.org.in/Scripts/bs_viewcontent.aspx?Id=3504
6. https://www.rbi.org.in/Scripts/NotificationUser.aspx?Id=11580&Mode=0
7. https://rbi.org.in/Scripts/NotificationUser.aspx?Id=12513&Mode=0
8. https://www.rbi.org.in/Scripts/FAQView.aspx?Id=160
9. https://www.rbi.org.in/Scripts/PublicationReportDetails.aspx?UrlPage=&ID=1232
10. https://www.rbi.org.in/Scripts/BS_PressReleaseDisplay.aspx?prid=53750
11. https://www.sebi.gov.in/legal/circulars/jun-2023/amendment-to-guidelines-on-anti-money-laundering-aml-standards-and-
combating-the-financing-of-terrorism-cft-obligations-of-securities-market-intermediaries-under-the-prevention-of-money-
launderin-_72683.html
12. https://inc42.com/features/has-rbis-new-ppi-directive-given-another-blow-to-the-fintech-dreamland/
13. https://www.forbesindia.com/article/news/rbis-signal-to-ppi-holders-use-licence-for-only-what-is-mandated/86259/1
14. https://www.forbesindia.com/article/cryptocurrency/sec-presses-charges-against-binances-usbased-entity-community-
accuses-the-administration-of-hindering-crypto-growth/85503/1
15. StatementonDevelopmentalandRegulatoryPolicies
16. https://inc42.com/buzz/p2p-lending-under-scanner-as-rbi-quizzes-startups/
17. https://inc42.com/buzz/parl-panel-quizzes-razorpay-phonepe-cred-execs-over-rising-cyber-incidents/;
18. https://economictimes.indiatimes.com/tech/technology/parliamentary-panel-on-finance-debates-cyber-security-rising-
white-collar-crimes/articleshow/100741974.cms?from=mdr
19. https://www.iosco.org/library/pubdocs/pdf/IOSCOPD734.pdf
20. https://www.cnbctv18.com/finance/ad-featuring-finfluencer-with-govt-logo-rachna-ranade-backlash-ministry-advises-to-be-
careful-17042921.htm; https://www.financialexpress.com/business/brandwagon-youtube-advt-prompts-calls-to-regulate-
finfluencers-3145640/
21. https://inc42.com/buzz/sebi-preparing-guidelines-to-crack-the-whip-on-unregistered-finfluencers/
22. https://inc42.com/buzz/b2b-fintech-startup-paymate-likely-to-refile-drhp-within-next-90-days/
23. https://inc42.com/buzz/phonepe-launches-own-payment-gateway-offers-free-onboarding-to-new-merchants/
24. https://inc42.com/buzz/phonepe-launches-account-aggregator-aa-services-after-acquiring-rbi-licence/
25. https://inc42.com/buzz/phonepe-launches-merchant-lending-marketplace-to-take-on-paytm/
26. https://www.vccircle.com/stellaris-backed-credflow-snaps-up-business-management-startup
27. https://inc42.com/buzz/pepper-group-to-launch-fintech-startup-pepper-money-in-india-this-year/
28. https://inc42.com/buzz/lendingtech-startup-indifi-secures-35-mn-funding-from-icici-venture-others/
29. https://www.vccircle.com/mufgbank-dharana-capital-write-27-mn-cheque-to-lentra; https://economictimes.indiatimes.com/
tech/funding/fintech-saas-firm-lentra-bags-27-million-in-extended-series-b/articleshow/100801904.cms
30. https://www.business-standard.com/finance/news/ev-financing-platform-revfin-raises-5-million-in-investment-from-
dfc-123060900774_1.html
31. https://www.vccircle.com/earlystage-startups-karmalife-bharatnxt-raise-funding
32. https://inc42.com/buzz/lendingkart-bags-funding-to-make-finance-more-accessible-to-msmes/
33. https://inc42.com/buzz/former-flipkart-exec-anil-gotetis-scapia-raises-9-mn-in-seed-funding/
www.induslaw.com

OUR OFFICES

BENGALURU DELHI & NCR


101, 1st Floor, “Embassy Classic”# 11 2nd Floor, Block D
Vittal Mallya Road The MIRA, Mathura Road, Ishwar Nagar
Bengaluru 560 001 New Delhi 110 065 
T: +91 80 4072 6600  T: +91 11 4782 1000 
F: +91 80 4072 6666  F: +91 11 4782 1097 
E: bangalore@induslaw.com E: delhi@induslaw.com

9th Floor, Block-B


HYDERABAD DLF Cyber Park
204, Ashoka Capitol, Road No. 2 Udyog Vihar Phase - 3
Banjarahills Sector - 20
Hyderabad 500 034 Gurugram 122 008
T: +91 40 4026 4624 T: +91 12 4673 1000
F: +91 40 4004 0979  E: gurugram@induslaw.com
E: hyderabad@induslaw.com

MUMBAI
CHENNAI 1502B, 15th Floor
#11, Venkatraman Street, T Nagar, Tower – 1C, One Indiabulls Centre
Chennai - 600017 India Senapati Bapat Marg, Lower Parel
T: +91 44 4354 6600 Mumbai – 400013
F: +91 44 4354 6600 T: +91 22 4920 7200
E: chennai@induslaw.com F: +91 22 4920 7299 
E: mumbai@induslaw.com

#81-83, 8th Floor


A Wing, Mittal Court
Jamnalal Bajaj Marg
Nariman Point
Mumbai – 400021
T: +91 22 4007 4400
E: mumbai@induslaw.com

This newsletter is for information purposes only. Nothing contained herein is, purports to be, or is intended as legal advice and you should
seek legal advice before you act on any information or view expressed herein.

Although we have endeavoured to accurately reflect the subject matter of this newsletter, we make no representation or warranty, express or
implied, in any manner whatsoever in connection with the contents of this article.

You might also like