Authorities and

Enforcement Mechanism
in IBC
Subject – Laws of Insolvency & Bankruptcy
Unit 12, Semester IX
Business Law Specialisation
Curated by – Prof. Shreya Madali
Role of NCLT in IBC
- The Code recognizes National Company Law Tribunal (the NCLT) constituted under
Section 408 of the Companies Act, 2013 as Adjudicating Authority for the purpose of
insolvency resolution and liquidation for corporate persons
- The Code also recognizes Debt Recovery Tribunal (the DRT) constituted under Section
3(1) of the Recovery of Debts Due to Banks and Financial Institutions Act, 1993 as
Adjudicating Authority for the purpose of insolvency resolution and bankruptcy of
partnership firms and individuals
- Location of the registered office of the corporate entity is the deciding criteria for
insolvency resolution and liquidation of corporate persons, corporate debtors and
personal guarantors thereof.
- Application for initiating insolvency resolution process or liquidation of corporate
debtors shall be filed before the NCLT having jurisdiction over the place where
registered office of the corporate entity is situated
- In dealing with the application relating to the insolvency resolution or bankruptcy of
personal guarantor of corporate debtor the NCLT shall be vested with the powers of
DRT dealing with the insolvency resolution or bankruptcy of individual
- Admission of Insolvency Resolution Process application is done by NCLT
irrespective of any of 3 applicants
- Moratorium is granted by NCLT – Section 13, 14 IBC
- Time applications to NCLT - The Section 12 of the Code has set default maximum
time of 180 days for completing insolvency resolution process in normal cases
and 90 days in fast tacked insolvency resolution process under Section 56. The
resolution professional if instructed by committee of creditors shall file
application before NCLT for extension of time beyond 180 days, or 90 days, as
the case may be
- Power to extend time is with NCLT - The NCLT, on being satisfied that subject
matter of the case is such that it cannot be completed within default maximum
time, may, by order, grant one time extension beyond prescribed default
maximum time. One time extension in case of normal process cannot exceed 90
days and in case of fast tracked process cannot exceed 45 days. The NCLT, in
both cases, is empowered to grant extension of time only once
- NCLT to approve resolution plan - When the NCLT is satisfied that resolution plan
approved by committee of creditors meets requirement of the Code, it shall, by order,
approve the plan. An approved plan is binding on debtors and its employees,
members, creditors, guarantors and other stakeholders in the resolution plan
- NCLT can reject the plan - where the NCLT is satisfied that resolution plan does not
meet requirement of the Code, it may, by order, reject the plan.
- Power to order liquidation - The NCLT has power to order liquidation if resolution
plan has been rejected as it fails to meet the requirements of the Code; or maximum
time allowed for resolution process has expired without any resolution plan being
agreed upon; or during the IRP but before confirmation of resolution plan
- Power to order dissolution of corporate person after liquidation - When the
business operations of the corporate person have been completely wound up and its
assets have been completely liquidated, the liquidator shall make an application to
the NCLT for dissolution of corporate person. On such application being filed, the
NCLT shall order that corporate person shall be dissolved from the date of the order.
The order of NCLT has effect of dissolving the corporate person from the date of order
- Avoidance of Preferential Transactions - When liquidator or resolution professional, is
of the opinion that a corporate debtor during the period specified under the Code has
transferred any property or an interest thereof of the debtor to specified persons on
account of antecedent debt or liability in a manner putting specified person in a
beneficial position than it would have been in the event of a distribution of assets in
liquidation(preferential transaction), he shall apply to NCLT for avoidance of such
transactions
- Avoidance of Undervalued Transactions - When a corporate debtor, except in the
course of ordinary business, makes a gift or transfers one or more assets for
insignificant consideration (the undervalued transaction), the resolution professional or
liquidator, shall, or failing them a creditor, member or partner of corporate debtor, may
make an application to NCLT to declare such transaction void and reverse their effect.
- Avoidance of Extortionate Credit Transactions - The term extortionate transaction
means a transaction wherein one party was made to pay unfairly high rate of interest or
subjected to unfair credit term. The Code provides for avoidance of extortionate
transactions related to financial or operational debt during the period within two years
preceding insolvency commencement date. The application for avoidance of
extortionate credit transaction may be made by the resolution professional or the
- Power in Case of Malicious and Fraudulent Proceedings - The NCLT has been
empowered under the Code to deal with cases of fraudulent and malicious
initiation of proceedings to ensure proceedings are brought only for the purpose
of resolution of insolvency, or liquidation and not for malicious or fraudulent
purpose.
i. Where any person initiates fraudulent or malicious liquidation proceeding or
insolvency resolution process the NCLT may impose upon such person a
penalty which may not be less than rupees 1 lakh, but which may extend to
rupees 1 crore.
ii. Also where any person initiates voluntary liquidation proceeding with intent
to defraud any person, the NCLT may impose upon such person a penalty
which may not be less than rupees 1 lakh, but which may extend to rupees 1
crore.
- Power in Case of Fraudulent or Wrongful Trading - When it is detected during
the CIRP or a liquidation process that the business of corporate debtor has been
carried on with the intent to defraud creditors of corporate debtors or for any
fraudulent purpose, the NCLT on an application may
(i) pass an order that any persons who were party to such business
transactions shall be liable to make such contribution to the assets of the
corporate debtors as it may deem fit;
(ii) by an order, under specified conditions, direct that a director or partner of
corporate debtor, as the case may be, shall be liable to make such
contribution to the assets of the corporate debtor as it may deem fit
Role of IBBI in IBC
- The IBBI is the regulating authority for insolvency and bankruptcy proceedings
in the country.
- It also oversees the activities of bodies such as the Insolvency Professional
Agencies (IPA), Insolvency Professionals (IP) and Information Utilities (IU),
Registered Valuers, and Registered Valuer Organisations.
- It was established as a statutory body in 2016 under the Insolvency and
Bankruptcy Code, 2016. The IBBI was established on 1st October 2016
- The IBBI makes and implements rules governing the CIRP, individual insolvency,
corporate liquidation and individual bankruptcy under the IBC.
- The IBBI is a major pillar in the implementation of the IBC that implements the
insolvency and re-organisation resolution process of corporates, individuals and
partnerships in a time-bound manner for all the stakeholders.
- The IBBI is a unique regulator in that it regulates both a professionals and the
processes
Constitution of the Board
- 1 Chairperson
- 3 members from among the officers of the Central Government equivalent or
not below the rank of a Joint Secretary. Out of the three members, each will
represent the Ministry of Finance, Ministry of Corporate Affairs and Ministry of
Law, ex -officio.
- 1 member nominated by the RBI (Reserve Bank of India), ex-officio.
- 5 other members nominated by the Central Government, out of which at least
3 should be whole-time members.
The Chairperson and the other members should be persons of integrity, ability
and standing, having the capacity to deal with problems relating to bankruptcy or
insolvency and having special knowledge and experience in finance, law,
accountancy, economics or administration.
- The term of office of the Chairperson and members (other than ex-officio
members) is 5 years or until they attain 65 years, whichever is earlier, and they
Functions of the Board
- Register, renew, suspend, withdraw, cancel and specify the minimum eligibility requirements for
registering insolvency professionals, insolvency professional agencies and information utilities
- Promote the development and regulate the practices and working of the insolvency
professionals, insolvency professional agencies, information utilities and other institutions
- Levy charges or fees for carrying out the purposes of the IBC, including fees for registration
and renewal of the insolvency professional agencies, insolvency professionals and information
utilities.
- Specify regulations and standards for the functioning of the insolvency professional agencies,
insolvency professionals and information utilities
- Lay down regulations on the minimum curriculum of the examination of the insolvency
professionals for their enrolment as members to the insolvency professional agencies
- Carry out inspections, investigations, monitor the performance and audit the functioning of the
insolvency professional agencies, insolvency professionals and information utilities and pass the
required orders for compliance with the provisions of IBC and the regulations
- Call for any records and information from the insolvency professional agencies, insolvency
professionals and information utilities
- Publish research studies, information, data and other information as specified by the regulations
- Specify regulations on the manner of storing and collecting data by the information utilities and
providing access to such data
- Maintain and collect records and disseminate information relating to bankruptcy and insolvency cases
- Constitute such committees as required, including the committees laid down under Section 197 of
IBC
- Promote best practices and transparency in Board governance.
- Maintain websites and other universally accessible necessary repositories of electronic information
- Enter into a memorandum of understanding with other statutory authorities
- Issue necessary guidelines to the insolvency professionals, insolvency professional agencies and
information utilities
- Specify mechanism for redressal of grievances against the insolvency professionals, insolvency
professional agencies and information utilities and pass orders relating to the complaints filed against
them for compliance with the provisions of the IBC and the regulations
- Specify mechanisms to issue regulations, including the conduct of public consultation processes,
before notifying any regulations
- Make guidelines and regulations on matters relating to bankruptcy and insolvency required under the
IBC, including the mechanism for time-bound disposal of the assets of the corporate debtor/debtor
Powers of the Board to Make Bye-Laws - The Board can make model bye-laws to be
adopted by the insolvency professional agencies, which may provide the following:
- The minimum standards of professional competence for the members of the
insolvency professional agencies
- The standards for the ethical and professional conduct of the members of the
insolvency professional agencies
- Requirements for enrolment of persons as members and granting membership of the
insolvency professional agencies in a non-discriminatory manner
- Setting up a governing board for management and internal governance of the
insolvency professional agency as per the regulations specified by the Board
- The required information that needs to be submitted by the members, including the
time and form for submitting such information
- The particular classes of persons to whom services will be provided at concessional
rates or for no remuneration by members
- The grounds and manner on which penalties can be levied upon the members of the
insolvency professional agencies
- A transparent and fair mechanism for redressal of grievances against the
members of the insolvency professional agencies
- The grounds under which the insolvency professionals can be expelled from the
membership of the insolvency professional agencies
- The procedure for enrolling persons as members, the quantum of fee and
manner of collecting fees for inducting persons as members of the insolvency
professional agency
- The manner of conducting examination for the enrolment of insolvency
professionals
- The manner of reviewing and monitoring the working of the insolvency
professionals who are members
- The duties and other activities that need to be performed by the members
- The manner of conducting disciplinary proceedings, imposing penalties and
utilising the amount received as penalties against its members and insolvency
professionals
Powers of the Board as Vested under CPC
The Board may exercise the powers vested in a civil court under the Civil
Procedure Code, 1908 (CPC) while exercising the powers under the IBC, at the
time of trying a suit, in respect of the following matters:
- The production and discovery of books of account and other documents, at
such time and place as specified by the Board
- Enforcing and summoning the attendance of persons and their examination on
oath
- Inspection of any registers, books and other documents of any person at any
place
- Issuing of commissions for examining documents or witnesses
Role of Insolvency Professional Agencies
- Insolvency professional agency means any person registered with the Board
(IBBI) under section 201 of Insolvency Code, 2016 as an insolvency professional
agency – section 3(20) of Insolvency Code, 2016.
- The Insolvency Professional Agencies will develop professional standards, code
of ethics and be first level regulator for Insolvency professionals members.
- This will lead to development of a competitive industry for such professionals.
- Insolvency and Bankruptcy Board of India (Insolvency Professional Agency)
Regulations, 2016 make provisions for registration of Insolvency Professional
Agency.
- Such Agency should be incorporated as section 8 company. It should have
minimum net worth of Rs. 10 Crores and paid up capital of Rs. 5 Crores. It
should not be a subsidiary of subsidiary.
Functions of Insolvency Professional Agencies:
a) Granting membership to insolvency professionals.
b) Lay down standards of professional conduct to its members.
c) Monitor performance of members.
d) Safeguard rights, privileges and interests of insolvency professionals.
e) Suspend member or cancel membership.
f) Redress grievances of members.
g) Publish information about its functions, list of members, and performance of
its members.
- Application for registration as Insolvency Professional Agency should be made to
IBBI in prescribed form with fees.
- Initially, in-principle approval as Insolvency Professional Agency will be granted
for one year. Then during that period, application of registration shall be made
with IBBI.
- IBBI will exercise control over Insolvency Professional Agency and Insolvency
Professional. Complaints can be made to IBBI under section 217 of Insolvency
Code.
- Section 217 - Any person aggrieved by the functioning of an insolvency
professional agency or insolvency professional or an information utility may file a
complaint to the Board in such form, within such time and in such manner as
may be specified.
- IBBI can carry out investigation of Insolvency Professional Agency and Insolvency Professional under section
218 of Insolvency Code. Disciplinary action can be taken against Insolvency Professional Agency or Insolvency
Professional by appointing disciplinary committee under section 220 of Insolvency Code
Section 218: Investigation of insolvency professional agency or its member or information utility.
- Where the Board, on receipt of a complaint or has reasonable grounds to believe that any insolvency
professional agency or insolvency professional or an information utility has contravened any of the provisions
of the Code or the rules or regulations made or directions issued by the Board thereunder, it may, at any time
by an order in writing, direct any person or persons to act as an investigating authority to conduct an
inspection or investigation of the insolvency professional agency or insolvency professional or an information
utility.
- The Investigating Authority may, in the course of such inspection or investigation, require any other person who
is likely to have any relevant document, record or information to furnish the same, and such person shall be
bound to furnish such document, record or information
- The Investigating Authority may, in the course of its inspection or investigation, enter any building or place
where they may have reasons to believe that any such document, record or information relating to the subject-
matter of the inquiry may be found and may seize any such document, record or information or take extracts or
copies therefrom
- The Investigating Authority shall keep in its custody the books, registers, other documents and records seized
under this section for such period not later than the conclusion of the investigation as it considers necessary
and thereafter shall return the same to the concerned person from whose custody or power they were seized
and return them after investigation is complete
- A detailed report of inspection or investigation shall be submitted to the Board by the Investigating Authority.
Section 220: Appointment of disciplinary committee.
- The Board shall constitute a disciplinary committee to consider the reports of the investigating
Authority and the members of the disciplinary committee shall consist of whole-time members of
the Board only.
- if the disciplinary committee is satisfied that sufficient cause exists, it may impose penalty or suspend
or cancel the registration of the insolvency professional or, suspend or cancel the registration of
insolvency professional agency or information utility as the case may be
- Where any insolvency professional agency or insolvency professional or an information utility has
contravened any provision of this Code or rules or regulations made thereunder, the disciplinary
committee may impose penalty which shall be—
(i) three times the amount of the loss caused, or likely to have been caused, to persons concerned on
account of such contravention; or
(ii) three times the amount of the unlawful gain made on account of such contravention, whichever is
higher
- the Board may direct any person who has made unlawful gain or averted loss by indulging in any
activity in contravention of this Code, or the rules or regulations made thereunder, to disgorge an
amount equivalent to such unlawful gain or aversion of loss
- The Board may take such action as may be required to provide restitution to the person who
suffered loss on account of any contravention from the amount so disgorged, if the person who
suffered such loss is identifiable and the loss so suffered is directly attributable to such person.
Role of Insolvency Professional:
• qualifications and experience for the applicants to be registered as Insolvency
Professionals:
• They must either qualify the National Insolvency Examination (or)
• Pass the Limited Insolvency Examination, in which case the candidate should have 15
years of experience in management after obtaining a bachelor’s degree from a
university established or recognized by law (or)
• Has qualified the Limited Insolvency Examination and has 10 years of expertise as:
• A chartered accountant and is a representative of the Institute of Chartered Accountants
of India (or)
• A company secretary and is a representative of the Institute of Company Secretaries of
India (or)
• A cost accountant and is a fellow of the Institute of Cost Accountants of India (or)
• Is an advocate registered under Bar Council.
• Once the listed qualifications are met, the applicants can start practising as Insolvency
professionals.
Functions Of an Insolvency and Bankruptcy Professional
- is to measure the financial position of the business, partnership, LLPs, individuals., and to guarantee an
effortless procedure of its termination
- Evaluate the financial statement of the firm and recognize the position.
- Set up all the needed arrangements to sell the assets of the liquidating entity or company.
- Know the receivables position of the company/Individual and look after the collection procedure
- Carry out formal discussions with debtors/creditors and oversee their settlement procedure
- Check and agree on the creditors' allegations as per the existing funds. This is one of the primary duties of
Insolvency professionals
- Engage in the fund allocation procedure after setting aside the money required to pay the liquidation
cost.
- Settle all dues with the other competing interest, if any.
- Insolvency professionals are needed to organize and submit a report to the National Company Law
Tribunal with the following
- A comprehensive report on the asset memo.
- Provisional report on how the liquidation process is evolving from time to time.
- Specifics about the sale of all the assets.
- Discussion with the Debtors and Creditors and the decisions arrived.
Information Utility
- The laws governing information utilities are Sections 209 to 216 of the
Insolvency and Bankruptcy Code, 2016 and Insolvency and Bankruptcy Board of
India (Information Utilities) Regulations, 2017.
- Information Utility (IU) is a professional organization which is registered under
Section 210 of the Insolvency and Bankruptcy Code, 2016 whose function is to
gather, assemble, accumulate, validate and disseminate financial information
from companies and creditors to facilitate insolvency, liquidation and
bankruptcy.
- A person can rely on the information stored in the IU before investing. This
ensures that a person’s investment is secured
- In the contemporary state of affairs, the financial information about non-
corporate borrowers is available only from the income-tax department and this
is not publicly accessible under the Right to Information Act, 2005.
- But the Information Utilities (IUs) which are established under the IBC helps in
overcoming this deficiency
Categories of Information
- Reliable and readily accessible records of liabilities of a solvent entity
- Clear evidence of the instance of default
- Records of assets that are pledged as collateral against secured credit contracts;
and
- Reliable and readily accessible records that comprise the balance sheet and cash
flow statements of the entity.
Information Submission-
Section 215 of IBC - financial creditors are obliged to submit financial information to
IUs. - the Code does not, however, stipulate any penalty for not submitting this data
Section 215(3) - it is optional for operational creditors to submit financial information
to the IUs.
The financial information which is required to be submitted to the IU is as follows:
- Records of a person’s debt;
- Liability of the person when the person is solvent
- Records of the assets over which the security has been created
- Proceedings of default by the person against any debt
- Balance sheet and cash-flow statements of the person.
The Working Group on Information Utilities is of the view that the submission of all
the financial information referred to above is not mandatory.
Only information directly relevant to the determination of the existence of debt and
default for the purposes of the CIRP should be made mandatory.
Disclosure of Information
a. When the debtor is solvent - Disclosure of information concerning a solvent
entity should only take place with the entity’s permission.
b. When the debtor has defaulted on a debt: In addition to the disclosures in the
first case above, every financial creditor should be informed of the fact of the
default and not just the creditor against whom it has been defaulted
c. When the application for initiating CIRP has been filed - Once an application
has been made to the adjudicating authority to initiate the CIRP, the
adjudicating authority shall have full access to the information about the
debtor from the IU, free of charge
d. When the CIRP has been triggered - After the CIRP is triggered, all information
about the debtor is available to the public.
Ownership and Immutability of IU Information
- The IU is not considered as the owner of the information but as the custodian of the
information.
- the IU is obliged to be a good steward of the information.
- Once the information is stored in an IU, it should not be deleted or modified in any
way whatsoever.
- That is essential to ensure that an IU preserves the sanctity of information, so that it
can be accepted as conclusive evidence in a court of law.
- if a record stored in an IU is incorrect, this should be marked as erroneous by the IU.
Standards to be complied by Information Utility
• An important standard used by the IU industry is a common Application Programming
Interface (API) whereby all IUs interact with other stakeholders in the performance
of their core services.
• This API specifies how an IU can be inquired for information, how information can be
submitted to an IU, how it can be authenticated, how it can be retrieved and how IU
prices can be queried.
Services of Information Utility - The role of IUs in the corporate insolvency
proceedings depends on three factors:
i. The existence of information on debts and defaults in the IU
ii. The validity of information in the IU as evidence in the court
iii. The use of this information in the insolvency procedure

There are two points where information is critical in an IU:

a. At the time of trigger of the resolution process: The IBC envisages that the
occurrence of default will be recorded in the IU, and this evidence will be used
by the adjudicating authority to initiate the resolution process
b. At the time of forming the creditors committee: The information from the IUs
will be used to identify all creditors to the debtor in order to form the creditors
committee.
Core Services of Information Utility
- Section 3(9) defines core services
- Section 3(13) defines financial information.
- core services of an IU should include the acceptance, storage, authentication
and access to information which includes assets, debts, security interest,
balance sheet and cash flow statements and default
- What is critical is the credit contract record and the occurrence of a default
Processes followed in Information Utility
1. Mode of information submission
- The Information required under the Code must be submitted in Form C of the Schedule of the
Insolvency and Bankruptcy Board of India (Information Utilities) Regulations, 2017.
- All information must be submitted electronically as a machine – readable text – there has to be no
paper documents or scans sent to IUs
- It is essential to be aware of the identity of the information submitter.
- It is also important to ensure that the information is not manipulated between the submitter submitting
the information and receiving it from the IU. Digital signatures can solve both of these problems.
2. Information authentication
- The Code specifies that the IU may accept the information only from specified persons.
- IUs should not accept information from persons not related to the debt transaction.
- The IU has a responsibility to authenticate the information with other concerned parties as per
Section 214(2) of IBC.
The term concerned parties is defined in the following two cases:
a. Where it’s a debt contract - then the concerned parties should be defined as both creditor and debtor
b. Where its an evidence of default - creditor and the bank hosting the repayment account for default
information.
3. Acknowledgement of information
- Once the information submitted to an IU has been authenticated, the IU shall
provide an acknowledgement to the submitter and authenticator
- The acknowledgement serves as evidence that the submitter has fulfilled its
statutory obligation (if any) to submit the information to the IU
- The acknowledgement shall protect against the manipulation of the data by the
IU and the repudiation by the submitter or the authenticator
- The acknowledgement protects against data loss by an IU.
4. Updation of information & Correcting erroneous information
- when there are changes in the terms of repayment of a loan, then this
information has to be updated in the IU by the person availing the services of IU.
- The Code requires the person who intends to rectify errors to apply to the IU
stating the reasons for the request.
5. Storage of information
- The principal purpose of IUs is to safely and reliably store accurate information.
- If an IU accepts information but then loses that information, then it defeats the point of
having IUs.
- Therefore the Working Group on Information Utilities has recommended that IUs should
have very high quality data storage systems including robust backup systems to ensure
information is not lost or corrupted.
- IUs should also have suitable BCP (Business Continuity Planning) and Disaster Recovery (DR)
processes to ensure that they can continue to function effectively even in the event of
disasters.
6. Access to information
- A person who is party to the debt or default
- The adjudicating authority
- The Insolvency and Bankruptcy Board of India
- Resolution Professionals
- The IU also allows any person permitted by the debtor to have access to information
Eligibility Criteria to get registered as Information Utilities
- The IBC states that every IU should be set up as a company under the
Companies Act and it should be a public company.
- The Working Group on Information Utilities has suggested the minimum
authorised capital to be Rs.75 crores and the minimum paid-up capital to be
Rs. 60 crores. It has also suggested a FDI limit of 49%.
- To get registered as an IU an application has to be made to the IBBI in Form A of
the Schedule of the Insolvency and Bankruptcy Board of India (Information
Utilities) Regulations, 2017.
Regulatory requirements to be complied by Information Utility
Data availability to the regulator and the adjudicating authority
- If the adjudicating authority is required to access data from the IU, it should be made available to it immediately and free of charge.
- This ensures that the adjudicating authority always has the relevant data available, and to make court proceedings faster and smoother.
- The IU also ensures that the adjudicating authority is only provided with data relevant to the case being heard by the adjudicating
authority.
Indemnification
- The IU is responsible for the performance of the core services pursuant to the Act, rules and regulations.
- As long as an IU authenticates the data it receives and stores it according to the regulator’s specified requirements, it cannot be held
liable for the accuracy of the data stored therein.
- Furthermore, it cannot be held liable for any loss caused to third parties because of the data stored therein.
- If any loss is caused by negligence on the part of the IU in the performance of its services to the debtor or creditor, the IU should be liable
to indemnify the debtor or creditor.
Exit Management Plan
- The information that is stored on an IU is of regulatory interest.
- Consequently, even if the IU is about to fail or its registration is about to be cancelled, the information contained therein should remain
available to the market.
- To ensure this, each IU shall prepare an exit management plan when applying for a certificate of registration. This plan will contain details
on how the regulator can retrieve the data in the IU and transfer it to another IU, which the regulator has chosen.
Grievance redress
• Every IU shall have a Grievance Redressal Policy to address consumer grievances. The IU should also report the number of grievances
received and resolved at periodic intervals to the regulator.
Outsourcing of core services
• The IU shall not outsource the provision of core services to a third party service provider.
Submission of Information to Information Utility
Step 1 - The creditor submits information to the IU
• The IU verifies the identity of the creditor.
• The creditor submits information, including the identities of all parties, the
amount, the date, details of the security if any, the host bank if any, etc.
• The creditor pays the fee charged by the IU.
Step 2 - The IU enables the debtor to authenticate the information
• The IU verifies the identity of the debtor against the unique identity.
• The IU makes the information submitted by the creditor available to the debtor
for authentication.
Step 3 - The debtor authenticates the information.
Step 4 - The IU generates a unique identifier for the loan, sends
acknowledgements to both the parties and stores the information.