- Legal waiver requirements need to be clarified further as there are no clear contexts defined which could lead to legal issues.
- Data availability in Regulatory Sandbox has not been covered. A few mentioned that banking data provided in a Regulatory Sandbox could provide better use cases to build and tested. The availability of data by Banks or any other parties needs to comply with security & privacy requirements.
- Integration of RBI’s Regulatory Sandbox with other sandboxes was also discussed. Proposed Regulatory Sandbox framework does not have any provision on the availability of other sandboxes or access to other sandboxes.
- Many people felt that criteria defined for fintech participants on Regulatory Sandbox may allow only established players while startups in early stages may not able to take advantage of the sandbox.
- Security and infrastructure requirements for startups were also discussed. Framework document covers about adherence to security & infrastructure requirements but same is silent on details of requirements.
- There were lots of discussions around on the negative list and excluding some of the areas like credit information, credit registry. The industry had witnessed lots of innovations taking place in the credit side of the business. Inclusion of this in the negative list may impact some of the use cases. It was proposed that the negative list should be reviewed.
- It is proposed to increase the cohort size upto 10-12. It is felt that cohort size should be larger as India has too many players working on different use cases. Limiting the cohort size may delay the viability of innovation.
- Restriction on technologies covered as part of the regulatory framework should be relaxed as innovations are taking place in wider area of technologies too such as RPA, Augmented Reality / Video Reality (AR/VR) etc.
Please write to us at firstname.lastname@example.org in case you wish to add some other points to the above discussion or feel free to comment below.