Every NBFC books two Ind AS 109 numbers that are supposed to share one rate: interest income on the effective interest rate, and the impairment allowance discounted at that same rate. In practice the EIR comes from a finance spreadsheet and the ECL from a risk model, and they have never agreed. FinIFRS computes both in one engine, from one loan tape, under a methodology that is a versioned, board-approvable document — and stamps every run so a three-year-old provision reproduces to the rupee.
Each is a material misstatement a spreadsheet produces without anyone noticing — and each is what an RBI inspection or a Key Audit Matter eventually finds.
ECL is a sum over time of monthly products. On the worked example, month one is understated ~20% (₹46 vs ₹57.49) when the downside moves both PD and LGD.
A 240-month mortgage on a 14% CPR book has an ~84-month behavioural life. Flat exposure to contractual maturity charges for defaults on loans that will have left.
¶5.5.17(b) says the loan's own EIR. Using the contract rate makes the allowance unreconcilable to interest income — the auditor's first question.
The differentiators are structural: they come from computing EIR and ECL in the same engine, from the same cash-flow vector.
The ECL discounts at the EIR the income was recognised at — because the same code produced both. There is nothing to reconcile.
Six-to-ten construction tranches, pre-EMI moratoria, floating resets that flex the tenor, behavioural life, and a fee taxonomy your auditor signs.
Collateral LGD with SARFAESI realisation lag and a distress haircut. A ₹50 L loan on an ₹80 L flat is not 0% LGD once 3.5 years of workout are priced.
Segmentation, SICR rules, PD / LGD methods, scenarios and overlays are a versioned pack your model committee edits and approves — not a consultant's macro.
Every run is immutable and stamped with data fingerprint, methodology and engine version. The number reproduces exactly, years later.
Management overlays and the RBI prudential floor applied after the model, each shown separately, so governance sees what the model said and what policy added.
validate → index → EIR → lifetime PD → stage → ECL → overlays → prudential floor → Stage 3 net interest → aggregate → disclose → post.
Every figure is engine output first. AI reads the stored run and its evidence.
The run report states on its own initiative what moved and why — stage migration, overlays, floor impact — from the stored run.
“Why Stage 2?” and “why this carrying amount?” answered from the stored schedule and staging evidence, each figure cited.
Proposes how a legacy tape maps to the data contract, refusing mappings that would mis-state income. A person approves.
Account-level signals from bureau refresh, bounce history and collateral value, feeding SICR as evidence rather than as a model score.
Across every FinIFRS product the rule is the same: a deterministic, tested engine computes and stores every figure first. AI reads documents, drafts sentences and answers questions over what is already stored — it never computes, posts or approves an amount.
A change in methodology is a configuration change with a maker-checker approval — not a six-week vendor release.
Against the two ways Indian NBFCs and HFCs produce Ind AS 109 numbers today.
| Capability | Consultant ECL model | EIR spreadsheet + LMS | FinIFRS |
|---|---|---|---|
| ECL discounted at the loan's own EIR | Contract rate | n/a | ✓ Same engine |
| Lifetime ECL as Σ MPD × LGD × EAD × DF | Averages | n/a | ✓ Monthly, scenario-weighted |
| Behavioural life and prepayment | Contractual | — | ✓ Per product |
| Construction tranches and moratoria in EIR | n/a | Manual | ✓ Native |
| Reproduce a past run exactly | Re-engage consultant | — | ✓ Stamped, immutable |
| Methodology change | Engagement | — | ✓ Config + maker-checker |
| Seventeen notes and the journal | Inputs to build them | — | ✓ The output |
No. The engine takes your loan tape through the data contract. If you later want servicing too, the NBFC Lending Suite runs on the same engine.
You do. It is a versioned pack your model committee edits and approves, with the history of every change. We ship sensible defaults; none is imposed.
Overlays and the floor are applied after the model and shown separately, with the IRACP comparison annex RBI requires — so the board sees the model, the judgement and the regulatory top-up as three numbers.
The minimum-viable-ingest tool tells you exactly which fields are required for your book. Typically a loan master, a cash-flow or schedule file, a DPD history and collateral values.
We run your last quarter through the engine and hand back EIR, ECL, the notes and the journal — with the reconciliation between interest income and impairment your auditor has been asking for.