Housing is the fourth largest contributor to India’s GDP. The sector is a key driver of economic activity with its ability to create employment and its linkages to many other sectors.

This sector has grown rapidly in India in the last decade. The growth has further been propelled by government’s focus on ‘Housing for All by 2022’. The growth has been fuelled by favourable policies for housing finance by the government. This in turn has lead to double digit growth for housing finance companies in India.

Our Client

Our client is a debt listed finance company and registered NBFC under National Housing Bank (NHB). The company has 352 branches across 25 States in India with over 1,300 employees.

Our client had a complex business environment with geographically dispersed operations. Keeping a tight control over applicability of various Acts and status of key compliances was challenging on a day to day basis. In addition, RBI & NHB would issue several notifications and circulars several times in a year resulting in changes to compliances. Our client was managing their compliances using spreadsheets, emails and paper folders.

Some of the key challenges faced as given below:

  • Lack of confidence in the list of applicable Acts and Compliances. No baseline review and gap analysis had been done for years
  • Highly distributed compliance environment with no central visibility and control
  • Penalties on account of delayed Filings due to human errors
  • Highly manual and time intensive search for applicable Legal Updates
  • Lack of clarity on State Rules and State Wise applicable Compliances
  • Highly manual and spreadsheet system for tracking the status of various compliances
  • Lack of clarity on industry specific compliances including ALM, NBS and Branch Info Returns
  • Several statutory notices on account of missed compliances
  • Business risks arising out of missed license renewals
  • Irregular tracking of vendor and supplier agreements leading to financial implications

Our client needed a compliance automation solution which could help them bring greater control over applicability, legal updates and real time status tracking.

Avantis Engagement

Avantis engaged with the client in the first quarter of 2017. A team of 3 SMEs visited their South India based head office for a period of 1 week to conduct a thorough review of their business operations across India.

The implementation of AVACOM was initiated in June, 2017 and completed on August, 2017.

Phase 1 - Business Discovery

This phase of the project focussed on understanding their business to establish the applicability of Acts and Compliances. Comprehensive information was collected via in-person interviews / meetings / discussions with the Board & Management, individual department heads, and other representatives in the company. The following items were collated:

  • Business Set up (Group, Entities, Locations, number and nature of establishments, Client, Industry)
  • Products (Housing Finance)

Phase 2 - Compliance Applicability Assessment

Avantis identified client business, entities, locations, products etc. and develop a list of Acts and compliances applicable to their business. The client work with 352 Operational branches in 25 States.

The team identified over 68 applicable Acts including 18 master directions and circulars under RBI. There were an additional 11 regulations under NHB. In all there were over 4,280 applicable compliances including time based and on-going compliances.

In addition, there were over 60 event based compliances mapped under Secretarial Category. These added approximately 1,020 compliances.

Phase 3 - Implementation

Avantis assigned a 2 member team to work with the client. The client was keen to implement the product in phases. Our team worked collaboratively with the client and developed an implementation plan spread over 2 months. The plan included physical visits to key branch offices. Here are the key activities undertaken during the implementation phase:

  • Map the Client Organisation (Entities, Sub-Entities, Branches, Locations, Departments)
  • Review of identified applicable Acts and Compliances with respective department heads
  • Discuss identified gaps with department heads and compliance head
  • Map Compliances to specific users based on their roles
  • Hands on training sessions with user groups based on their locations and roles
  • Activation of system for a predetermined go-live date
  • A total of 128 users were mapped and trained over a period of 6 weeks for Performer, Reviewer, Approver and Management Roles

In Conclusion

Our client is a leading NBFC in India with a large national footprint. Avantis completed end to end implementation of such a complex NBFC in 8 weeks. Now, the Compliance officer has much greater control over their organisation’s compliance. The level of awareness and sensitivity to statutory liabilities across the organisation has improved dramatically. He is able to identify risks and issues in real time and plan necessary interventions. The management now reviews the Management Dashboard in AVACOM during every board meeting. There is greater visibility, transparency and accountability in the system. The cost of poor compliances arising out of delays and missed compliances reduced by 90% in the first year.

Project Highlights