1. Can the KFS be included as part of the loan agreement, or must it be provided separately?

The KFS must always be provided at the offer stage before the loan contract is executed. It cannot be shown for the first time as part of the loan agreement.

There are two approaches we have seen in the market:

Cautious approach: KFS is shown first separately from the loan agreement. Borrower acknowledges the KFS via an auditable electronic authentication, like a Quick Sign, and then proceeds to the loan agreement.‍

Liberal approach: KFS is shown at the stage of offer, borrower clicks an “I Accept” button (or something similar), and then KFS + loan agreement are eSigned together. 

2. Should the KFS link be hosted exclusively by the RE?

The RBI does not say "hosted by RE".  However, the DLD places the obligation on the RE to provide the KFS link - and ensure the KFS process is followed. 
So while fintechs can display the KFS for convenience, the RE should be the one hosting it or generating it in order to ensure total compliance.  

3. Can the KFS be sent along with the sanction letter instead of separately?

Yes, many lenders already do this. When the sanction letter is issued (before loan agreement execution), the KFS can be clubbed together with it. Borrower signs both, then proceeds to loan agreement.

This is fully compliant because KFS is still being shown and acknowledged before the loan contract is executed.

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