FLEXILOANS: THE BUSINESS OF DIGITAL LENDING, BUT WHERE IS THE ACCOUNTABILITY?

When a digital lender promises convenience, speed and access to credit, customers are entitled to something more than automated messages, unanswered complaints and repeated follow-ups. A growing collection of customer allegations, the company’s own complaint disclosures and credit-rating observations now demand a closer examination of the business practices, customer-protection mechanisms and regulatory oversight surrounding FlexiLoans.

Digital lending companies love to sell a familiar story: financial inclusion, technology, instant credit, paperless processing and the democratisation of business finance. The presentation is attractive. The pitch is polished. The advertisements promise convenience to small businesses and entrepreneurs who may struggle to access conventional banking.

But there is an inconvenient question that deserves considerably more attention than another promotional campaign about fintech innovation:

What happens to the customer after the advertisement has done its job?

What happens when a customer receives what appears to be a loan approval message, submits personal documents and subsequently learns that the application is still being reviewed? What happens when a borrower disputes an EMI debit? Who takes responsibility when a person claims to have been contacted by recovery personnel despite never having borrowed from the lender? What happens when someone allegedly asks a company to stop calling, only to receive more marketing calls?

And, most importantly, what happens when the customer complains?

FlexiLoans, the lending brand associated with Epimoney Private Limited, now faces a collection of uncomfortable questions arising from publicly visible customer reviews, complaints reproduced on consumer platforms, previously reported loan-communication disputes and the company’s own financial and regulatory disclosures.

None of these allegations should automatically be treated as proof of criminal wrongdoing. But neither should a financial institution expect that a digital lending label, a technology platform and a collection of corporate policies will shield it from legitimate scrutiny.

The question is no longer merely whether FlexiLoans can disburse loans. The more consequential question is whether the customer-protection framework surrounding that lending business is keeping pace with its growth.

A 3.4-star Google listing and a customer-service story that cannot simply be dismissed

The Google Business Profile listing for FlexiLoans Technologies Private Limited, located at One World Centre in Mumbai’s Lower Parel business district, displayed a rating of approximately 3.4 out of 5 from 359 reviews at the time of the latest search.

A Google rating is not a regulatory audit. It is not a statistically representative consumer survey, and it does not establish that every allegation made by a reviewer is true.

Nevertheless, customer reviews can identify recurring issues that merit examination, particularly when similar complaints concern different stages of a financial relationship.

The publicly reproduced negative reviews attributed to FlexiLoans customers contain several disturbing allegations.

A reviewer identified as Aadesh Bhise alleged that recovery personnel visited his residence, shouted in the neighbourhood and threatened him.

Another reviewer, using the identifier CK 1213, alleged that recovery personnel continued harassing him following an EMI-related dispute, despite his having made a part-payment. The reviewer also alleged that calls were made to people known to him and that abusive language and threats were used.

Ketan Gupta reportedly complained of alleged doorstep intimidation and threats of physical violence. His complaint also raised the particularly serious issue of recovery personnel allegedly contacting neighbours using telephone numbers that were not supplied as loan references.

A business owner reportedly alleged that the company generated more than 100 calls in a day over a disputed outstanding amount of just ₹130, which the reviewer attributed to a banking-system issue.

Read that last allegation again.

If the account is accurate, the dispute was not over lakhs of rupees, a complicated commercial loan or an extraordinary default. It concerned ₹130. Yet the reviewer claimed that the response involved more than 100 calls in a single day.

A financial institution has every legitimate right to recover money actually due to it. But the right to recover a debt is not a licence to convert a minor accounting dispute into a customer’s personal nightmare.

There are also complaints concerning post-repayment account closure and disputed deductions.

Juned Khan reportedly alleged that outstanding dues had been cleared but the loan account continued to appear active for another year, while communications to the company remained unanswered.

Pavan Pandey complained of an alleged double EMI deduction in one month and a lack of effective response from customer support.

M J Enterprises reportedly complained of difficulties in changing a bank account despite repeated follow-ups and more than 50 emails.

Hirdesh Lohumi alleged that documents had been submitted but that meaningful responses through email and WhatsApp were not forthcoming.

Leito Pndy complained about a website failure during the application process, subsequent rejection and inadequate customer assistance.

These allegations are individually different, but they point towards questions about account reconciliation, escalation mechanisms, customer communication, collection practices and the quality of post-disbursement servicing.

The company should not be permitted to reduce every such complaint to an isolated misunderstanding without providing evidence that the underlying systems work properly.

A digital lender cannot advertise technological sophistication at the customer-acquisition stage and then expect customers to accept administrative confusion when their money, credit history or personal dignity is involved.

The pre-approved loan controversy: was the customer receiving an approval or merely an advertisement dressed up as one?

One of the more important questions concerns loan communications that allegedly used language suggesting that substantial business loans had already been approved or were ready for disbursal.

Earlier public reporting reproduced a WhatsApp communication attributed to FlexiLoans Technologies concerning a business loan of approximately ₹22.90 lakh.

The reproduced message reportedly described the proposed loan as pre-approved at “1% Interest” and used language suggesting that the amount was ready for disbursal.

However, a subsequent communication reportedly stated that the application was still being reviewed and requested further information and verification.

Another reported instance concerned a proposed loan of approximately ₹27 lakh. The recipient allegedly received an approval-style communication despite claiming that there was no corresponding recent live application. According to that account, the individual was subsequently asked to provide identity documents before being informed that the application could not proceed.

These are serious allegations because there is a substantial difference between telling someone that an application is under consideration and communicating that a loan is pre-approved or ready for disbursal.

A lender may legitimately use preliminary eligibility assessments, indicative offers and conditional approvals. Not every pre-approved offer is a final sanction, and a lender must retain the ability to conduct verification and credit-risk assessment before disbursement.

But that is precisely why the language matters.

A communication saying “your application is under assessment” is not equivalent to a communication saying “your loan is ready for disbursal”.

The customer should not be left guessing which stage of the lending process has actually been reached.

FlexiLoans’ own published FAQ states that applications are assessed on the basis of submitted documents and creditworthiness. It also advertises interest rates starting from 1% per month, subject to the applicant and product.

This makes the wording of the reproduced messages particularly important. The phrase “1% Interest”, without a clear period, annualised percentage rate, tenor and complete cost disclosure in the communication itself, can create an impression that is materially different from a fully disclosed credit offer.

The question for the company is straightforward:

Does FlexiLoans classify these communications as marketing messages, indicative offers, conditional pre-approvals or actual sanction communications?

And where does the company’s internal record reflect that distinction?

The relevant evidence is not another generic explanation about how digital lending works. It is the underlying application record, message-generation log, approval workflow, customer-consent record and subsequent status history.

The company should disclose how many customers received comparable communications, how many completed applications, how many were ultimately rejected, how many received loan disbursements and how many complained that the communication had represented a loan as approved when it was not.

A lender that is confident in its communication practices should have no difficulty producing an auditable answer.

Credit-bureau enquiries: did customers knowingly authorise every enquiry?

The approval-message controversy also raises the issue of credit-bureau enquiries.

When a financial institution makes a credit enquiry, the enquiry may appear in the applicant’s credit report. Multiple applications or enquiries within a short period can influence a credit score and may affect how prospective lenders assess a borrower.

This does not mean that every enquiry automatically reduces a score by a fixed number of points. The effect depends on the individual’s credit profile and the scoring methodology. Nor does every credit enquiry amount to wrongdoing.

But a customer should understand when an enquiry is being made, why it is necessary, which institution is making it and what authorisation has been obtained.

If someone receives what appears to be a pre-approved offer, submits documents, and later discovers additional credit enquiries that they did not understand or anticipate, the matter deserves a formal investigation.

The relevant questions include:

• Was there a live loan application?
• Was there a valid and appropriately recorded customer consent?
• Which credit bureau was accessed?
• Was the enquiry classified as a hard enquiry or another type of enquiry?
• Was the applicant clearly told that a credit check would be performed?
• Was the enquiry initiated by Epimoney, FlexiLoans Technologies or a lending service provider or other intermediary?
• What happened when the application was abandoned or rejected?

The answers should be available in the company’s digital audit trail.

The regulatory framework for digital lending requires regulated lenders to retain responsibility for the conduct of their lending service providers and to ensure appropriate consent, data handling, disclosure and auditability.

The responsibility cannot simply disappear into a chain of marketing agencies, technology vendors and outsourced service providers.

A customer does not enter into a relationship with an invisible ecosystem. The customer sees the lender’s name, receives its communications and expects the lender to take responsibility.

Recovery allegations: the Fair Practices Code is not decorative literature

Perhaps the most troubling category of publicly reproduced customer complaints concerns alleged recovery practices.

Allegations of threats, abusive language, unwanted doorstep visits, repeated calls and contact with unrelated third parties are not minor customer-service issues.

They go to the heart of the relationship between a lender and a borrower.

There is nothing unlawful about a lender seeking repayment of an amount that is genuinely due. A lender may use employees or authorised recovery agents, initiate appropriate legal proceedings and communicate with borrowers regarding overdue accounts.

However, recovery activity must remain within the law.

The Reserve Bank of India’s August 2022 directions make it clear that a regulated entity remains responsible for the acts and omissions of recovery agents engaged by it.

The RBI has specifically prohibited intimidation and harassment, including inappropriate messages, threats, anonymous calls, persistently calling borrowers and intruding upon the privacy of their family members, referees and friends.

The RBI also prohibits recovery calls before 8 a.m. and after 7 p.m.

In other words, outsourcing recovery does not outsource accountability.

A lender cannot legitimately claim that an agent’s behaviour is somebody else’s problem merely because the agent is employed by a third-party agency.

This becomes particularly relevant when the publicly reproduced reviews allege that recovery personnel contacted neighbours, relatives or people who were not borrowers.

If these allegations are substantiated, the relevant questions are obvious:

Who authorised the calls? Which agency was engaged? What information did the agency receive? How were telephone numbers obtained? Were call recordings maintained? Were recovery-agent identities disclosed? Was the company informed of earlier complaints? What disciplinary action, if any, followed?

FlexiLoans itself publishes a Fair Practices Code which states that it will not resort to undue harassment, including persistently bothering borrowers at odd hours or using muscle power for recovery.

That is the company’s own stated standard.

The uncomfortable issue is whether its actual collection practices consistently reflect that standard.

A policy promising respectful treatment is useful. A policy backed by enforceable internal controls, recorded calls, agent-level accountability and independent complaint review is considerably more useful.

A Fair Practices Code that exists only as a PDF while customers allegedly describe intimidation is not an adequate consumer-protection outcome.

The company should publish meaningful information about recovery-agent complaints, the number of complaints substantiated, actions taken against agencies and the number of accounts in which disputed third-party contact was identified.

Unsolicited calls and the question of customer consent

Another recurring category concerns marketing calls.

A reviewer identified as Nitin Prasana reportedly complained that FlexiLoans repeatedly contacted him with loan offers despite his having communicated that he did not require a loan.

Mehul Mehta separately complained on a consumer platform in October 2023 that, after making an enquiry about a business loan and deciding not to proceed, he continued receiving approximately 20–30 calls a day.

The allegation is especially relevant because the company’s published privacy policy discusses customer communications and the use of authorised service providers and lending partners.

Its policy states that acceptance of its terms can authorise communications, including in circumstances where a telephone number is registered with DND/NDNC preferences. It also discusses communications by authorised third parties and service partners.

That wording raises a legitimate question about the precise nature of consent obtained at the point of data collection.

The Telecom Regulatory Authority of India has a commercial-communications framework under which relevant senders are required to meet registration, header, content-template and consent requirements.

There is an important distinction here: registration on the DND list does not automatically prohibit a commercial communication where valid consent has been obtained. TRAI has itself acknowledged the problems arising from purported offline or unverifiable consents and has taken steps towards stronger digital consent verification.

Therefore, the question is not simply whether a customer was registered on DND.

The important question is whether the company or its authorised partners can prove that the customer gave the required consent for the particular communication.

Did the customer expressly request a loan quotation? Was the telephone number shared with another service provider? Was consent obtained for a different product and later used for marketing? Was an opt-out request recorded? Was it honoured across every partner and telemarketing system?

And when a customer says “stop calling”, does that instruction actually reach the entire marketing ecosystem?

A modern financial institution should be able to answer all these questions without sending the customer from one call-centre executive to another.

EMI disputes and the basic mathematics of customer servicing

The allegations concerning duplicate deductions, disputed bounce charges, closed accounts remaining active and difficulties obtaining account corrections deserve separate attention.

They concern the most basic obligation of a lender: correctly maintaining the borrower’s account.

FlexiLoans’ FAQ refers to automatic repayment mechanisms such as ECS and NACH.

These systems are designed to make repayment convenient. But where a customer disputes a deduction, the institution must be able to reconcile the repayment instruction, bank statement, presentation record, return code, ledger entry and subsequent settlement.

If an EMI is debited twice, the customer should receive a prompt explanation and correction.

If the payment is successful but the loan account shows an outstanding balance, there must be a documented reconciliation.

If an account has been closed, the customer should not be left fighting to establish that a contractual obligation has been completed.

The allegations reproduced in the public reviews raise precisely these concerns.

They do not prove that FlexiLoans has systematically duplicated EMIs or wrongfully collected money. But they are sufficiently specific to justify an examination of individual transaction records and the quality of the company’s grievance-resolution process.

The difference between a responsible lender and an indifferent lender is often visible in how quickly it corrects a small mistake.

A company dealing in thousands of crores of loan disbursements should not require a customer to send 50 emails to change a bank account or repeatedly explain why a payment has already been made.

The company’s own annual report: 219 complaints received, 243 redressed and none pending

There is another important piece of information that comes not from a disgruntled reviewer but from the company’s own annual-report disclosure.

Epimoney’s FY2023–24 annual report records 219 customer complaints received during the financial year.

The table records 24 complaints pending at the beginning of the year, 243 complaints redressed during the year and zero pending at the end.

The arithmetic is important: the 243 redressed complaints include the 24 carried forward from the previous financial year and the 219 received during FY2023–24.

That disclosure should be read accurately. It does not say that all 219 complaints concerned recovery agents, marketing calls, EMI deductions or loan approvals. It does not establish that every complaint was justified. It also does not establish that all complaints were resolved to the complete satisfaction of the customers.

But it does establish that the company had a meaningful volume of customer grievances to process.

And it raises a reasonable question about transparency.

Where is the current, readily accessible, category-wise complaint dashboard?

How many complaints concern recovery agents? How many concern duplicate deductions? How many involve incorrect account balances? How many relate to credit-bureau enquiries? How many are about unsolicited calls? How many involve loan approval communications?

How many were resolved within seven days? How many required escalation? How many were referred to the RBI Ombudsman? How many were reopened after an initial closure?

A company should not expect the public to accept a single headline figure for complaints resolved without a proper understanding of what those complaints were about and how they were resolved.

The public deserves more than an annual arithmetic exercise.

Fast growth, rising asset-quality stress and the uncomfortable financial questions

Customer-service allegations are one side of the story. The other is the financial performance and asset quality of the lending business.

It is necessary to distinguish between the registered NBFC, Epimoney Private Limited, and FlexiLoans Technologies Private Limited, the associated operating/technology company and brand entity.

The two should not be casually treated as identical legal persons. However, independent credit-rating reports analyse the group and its connected lending operations, making group-level figures relevant to an assessment of the overall business.

The company’s growth figures are substantial.

According to Acuité’s June 2026 rating rationale, annual disbursements increased from approximately ₹1,756.21 crore in FY2023 to ₹3,783.52 crore in FY2026 on a provisional basis.

Assets under management grew from approximately ₹1,064.47 crore to ₹2,920.93 crore over the same period.

That is significant expansion.

But growth in lending is not the same thing as growth in the quality of lending.

The same Acuité rating rationale reported that gross non-performing assets rose from 1.44% in FY2023 to 5.79% in FY2025 before declining to 4.72% in FY2026 on a provisional basis.

Epimoney’s FY2023–24 annual report had already disclosed that its on-book gross NPA ratio increased from 2.7% in FY2023 to 4.3% in FY2024. Its net NPA ratio rose from 1.07% to 2.83%.

Separately, CRISIL’s February 2026 assessment of the group reported 90-plus-day delinquency at approximately 4.8% as of December 31, 2025. When adjusted for the rating agency’s stated write-off methodology, the figure was approximately 8.8%.

These measures are not interchangeable. Gross NPA, net NPA and 90-plus-day delinquency have different definitions, reporting bases and adjustments. They should not be combined into one misleading statistic.

Nevertheless, they collectively point to an asset-quality issue that deserves monitoring.

The rating agencies have also noted moderate earnings and the challenges associated with unsecured lending.

This is not an allegation of fraud. Rising NPAs do not prove misrepresentation, diversion of funds or criminal conduct. Credit losses are a recognised risk of lending, particularly in unsecured business finance.

But a lender rapidly expanding its balance sheet must demonstrate that its underwriting systems, recovery practices, customer communications and internal controls are expanding with equal seriousness.

Otherwise, growth becomes a vanity metric.

A company can announce rising disbursements, expanding AUM and large fundraising rounds. What it cannot do is use those numbers as a substitute for explaining its customer-protection and asset-quality performance.

The profitability question: lending growth is not the same as sustainable performance

Epimoney’s FY2023–24 annual report disclosed total income, including other income, of approximately ₹262.90 crore and profit after tax of approximately ₹3.04 crore.

The corresponding FY2022–23 figures were approximately ₹106.39 crore of total income and ₹1.69 crore of profit after tax.

Those numbers show an increase in reported income and profit. They also indicate why analysts should examine the relationship between lending growth, operating costs, provisioning, funding costs and asset quality rather than simply celebrating higher disbursements.

Acuité’s June 2026 report subsequently recorded standalone provisional profit after tax of approximately ₹17.54 crore for FY2026 and group-level consolidated profit after tax of approximately ₹4.18 crore for FY2025.

These are different reporting periods and financial bases, so they should not be treated as directly comparable.

The point is not that a company must earn extraordinary profits to be a responsible lender. The point is that credit expansion and the cost of managing risk must be examined together.

When asset quality comes under pressure, the relevant question is whether the lender is equipped to manage the consequences without shifting the cost of operational weaknesses onto customers.

That is a question for lenders, investors, rating agencies and regulators alike.

The regulatory standards are not optional

The regulatory framework already provides significant protections.

The RBI’s Digital Lending Guidelines make clear that a regulated entity cannot escape responsibility simply by outsourcing parts of the lending process to a lending service provider.

The regulated lender remains responsible for ensuring compliance with the applicable digital-lending requirements.

The RBI framework also emphasises key fact statements, disclosure of the annual percentage rate, appropriate consent, data minimisation, audit trails and transparency regarding recovery agents.

The RBI’s recovery-agent instructions independently prohibit intimidation and harassment.

TRAI’s commercial-communications framework governs unsolicited commercial communications and requires the appropriate registration and consent processes.

These obligations are not theoretical suggestions. They exist because digital lending involves an enormous quantity of sensitive financial and personal data, automated decisions, outsourced service providers and communications that can materially affect a consumer’s financial life.

The regulated lender must be answerable for the system it operates.

If an outsourced recovery agent threatens a customer, the company cannot simply point towards a vendor agreement.

If a marketing partner sends misleading approval communications, the company cannot simply claim that another department generated the message.

If a credit enquiry is made without the required authorisation, the institution must be able to explain the audit trail.

If repayment records are incorrect, the customer must receive a correction without being forced into months of follow-up.

The regulatory philosophy is clear: outsourcing a function does not eliminate regulatory accountability.

What about court cases, proceedings and alleged criminal wrongdoing?

The distinction between a dispute, a court proceeding, an adverse finding and a criminal conviction is essential.

Public searches surface litigation involving Epimoney Private Limited, including the Bombay High Court matter Rachana Sharma and Another v. Epimoney Private Limited, Arbitration Petition (L) No. 287 of 2019.

The accessible material indicates an interim procedural order concerning continuation of an ad-interim arrangement until the next hearing. The publicly available record reviewed for this article does not establish a final finding of wrongdoing against Epimoney in that matter.

A commercial litigation database also reports a substantial volume of court records associated with Epimoney, with a large majority recorded as proceedings initiated by the company.

However, that database is not a certified consolidated court registry. Its totals should not be treated as a verified count of unique disputes, consumer complaints or criminal cases. The underlying cases must be checked individually before conclusions can be drawn.

It would be irresponsible to convert every borrower-recovery proceeding or procedural court order into an allegation of corporate misconduct.

Equally, it would be irresponsible to ignore a genuine adverse finding if one exists.

Based on the public records and sources reviewed for this report, no final court judgment or criminal conviction establishing that FlexiLoans or Epimoney committed fraud in connection with the specific customer allegations discussed above has been identified.

Nor has a verified RBI penalty or enforcement order establishing such fraud been identified in the reviewed material.

That is an important distinction.

The allegations warrant investigation. They do not, by themselves, establish a criminal offence.

The uncomfortable questions FlexiLoans must answer

The company should not be allowed to respond to this entire controversy with a generic statement about its commitment to customer experience.

The questions are specific and deserve specific answers.

On loan approvals: How many customers received pre-approved or ready-for-disbursal messages and were subsequently informed that their applications remained under review or could not be processed?

On credit enquiries: How many credit-bureau enquiries were initiated following marketing communications, and what documentary records establish the necessary customer authorisation?

On recovery: How many complaints have been made against recovery personnel and agencies? How many were substantiated? What action was taken? Were call recordings and field-visit records examined?

On third-party contact: What controls prevent an unrelated person from being contacted about someone else’s loan? How are telephone numbers supplied by borrowers verified and controlled?

On repayments: How many complaints involved duplicate EMI deductions, disputed bounce charges, incorrect outstanding balances or delays in closing fully repaid accounts?

On telemarketing: How does the company ensure that customer opt-out requests are reflected across all service providers, marketing databases and authorised lending partners?

On grievance redressal: What is the latest category-wise complaint count, time-to-resolution data, reopened complaint count and RBI Ombudsman referral data?

On governance: Does the board receive periodic reporting on recovery-agent conduct, data-consent compliance, misleading communications, complaint recurrence and customer-impact incidents?

These are not unreasonable questions to ask of a company operating a regulated lending business.

They are basic questions of governance.

RBI, TRAI and enforcement agencies must look beyond corporate assurances

The allegations described here are sufficiently varied to justify a structured examination by the relevant authorities.

The Reserve Bank of India should consider examining the company’s grievance data, recovery-agent governance, outsourcing controls, digital-lending audit trails and internal compliance arrangements. The review should include the operating entities and service providers involved in originating, marketing, servicing and recovering loans.

TRAI should examine whether the relevant commercial communications were sent through properly registered channels, whether applicable consent requirements were satisfied and whether withdrawal of consent and opt-out requests were honoured.

Credit-information companies should examine specific complaints involving disputed enquiries, subject to the applicable authorisation and correction procedures.

Where customers provide evidence of threats, intimidation, extortionate conduct, impersonation or other cognisable offences, the police should register and investigate those allegations in accordance with law. Call-detail records, call recordings, message templates, agency contracts, payment records and digital audit trails should be preserved rather than allowed to disappear behind routine corporate processes.

The investigation should not end with a notice sent to a junior customer-care employee.

The people who designed, approved and supervised the relevant systems must be identified where the evidence warrants it.

There must also be faster resolution of genuine consumer grievances and quicker adjudication of cases where offences are established. Investigations should be time-bound where legally feasible, evidence should be preserved promptly and courts should endeavour to avoid unnecessary procedural delays.

But speed cannot mean predetermined guilt. The objective must be accountability based on evidence, followed by appropriate legal consequences where wrongdoing is proved.

A digital lender cannot demand trust while leaving customers to chase answers

FlexiLoans operates in a sector where public trust is the foundation of the business.

A business borrower approaching a digital lender is often looking for working capital, inventory finance, expansion money or funds to manage a temporary liquidity crisis.

For that customer, loan approval is not a marketing event. It can determine a purchase order, a business expansion, a supplier payment or the continuation of operations.

The customer deserves clarity about whether finance has actually been sanctioned.

The borrower deserves accurate statements.

The customer deserves a properly explained deduction.

An individual whose number is mistakenly associated with another person’s loan deserves immediate correction.

A borrower facing recovery proceedings deserves lawful treatment.

And someone who has declined a marketing offer should not have to spend their day asking a lender to stop calling.

A lender may have an impressive app, an attractive website, a large disbursement figure and prestigious institutional investors. None of those things answers the question of how an ordinary customer is treated when something goes wrong.

The irony of digital lending is that a business can automate the process of acquiring a customer, assessing the customer, sending communications and collecting instalments, but still leave that customer struggling to obtain a meaningful human response.

That is not the kind of financial innovation consumers were promised.

A digital lender cannot be digitally sophisticated when collecting a customer’s data and administratively helpless when asked to explain what happened to it.

FlexiLoans and Epimoney should publish their answers, disclose their complaint-handling performance and demonstrate that the safeguards written into their policies actually operate in practice.

Until then, the questions surrounding loan communications, customer consent, recovery conduct and repayment disputes will remain legitimate subjects of public and regulatory scrutiny.

The lending business may be growing. The burden of accountability must grow with it.