- Is stating the APR percentage enough, or do we need to show how it's calculated?
Just stating the APR percentage is not enough. You need to show an amortization schedule, which shows the borrower how their principal will compound.
The RBI has provided illustrative examples of how APR and amortization schedule should be disclosed in Annexures B and C of the KFS Rules.
- What does it mean to 'provide KFS' to the customer? Should it be sent in a downloadable format?
Providing KFS to the customer means the borrower must be given a copy of the KFS so that the borrower can access it at any time. So in short - yes. In a digital KFS process, you must send a copy to the borrower in a downloadable format.
- Can OTP-based consent for KFS be used in a digital loan journey?
Yes, you can use OTP-based consent for KFS. The KFS rules require the KFS to be acknowledged, but it does not define the specific type of acknowledgement.
You should, however, evaluate the mode and manner of acknowledgement you collect based on -
a) How easy will it be to enforce in recovery/insolvency proceedings
b) Whether it will pass muster in RBI audits