// CREDIT POLICY
Credit policy rules every small NBFC should automate (with an example BRE policy)
The credit policy rules small NBFCs and LSPs should automate first — knock-outs, eligibility, bureau, FOIR, limits and routing — with an example policy.
8 min read
Every NBFC has a credit policy. The question is whether it lives in a PDF that credit managers interpret, or in credit policy rules that run automatically on every application. This article lists the rules small NBFCs and LSPs should automate first, shows how to structure them in a business rule engine (BRE), and flags the mistakes that make automated policies misfire.
About the thresholds below: every number in this article is an example to show the structure of a rule. Set your own values from your product, your borrowers and your book's repayment history.
The six rule groups in a lending credit policy
Group rules by purpose and run them in this order. Cheap, decisive checks come first so the engine does not pull a bureau report for an applicant who was always going to be rejected.
1. Knock-out rules
Hard stops. If any one fails, the application is rejected with a reason code.
- PAN or mobile number appears on your internal blacklist
- An active loan with you is already overdue
- KYC verification failed or the face match did not pass
- Location or IP address is flagged as high-risk
2. Eligibility rules
Is this applicant someone this product is designed for?
- Age within the product's band (for example 21–58)
- Pincode in your serviceable list
- Employment type the product allows (salaried, self-employed)
- Requested amount and tenure within product limits
3. Bureau rules
- Bureau score at or above your cut-off
- No write-off or settlement in the last N months
- Maximum number of credit enquiries in the last 30 or 90 days
- Maximum number of active unsecured loans
4. Affordability rules
Affordability is usually measured with FOIR — the share of monthly income already committed to fixed obligations such as EMIs. The rule checks FOIR including the new EMI. Try different values in our FOIR calculator.
- FOIR after the new EMI must stay at or below your cap
- Net monthly income above a minimum for the product
- No more than N EMI or cheque bounces in the last six months of bank statements
5. Limit rules
Instead of only approving or rejecting, set the amount:
- Approve the lower of the requested amount and the amount that keeps FOIR within your cap
- Cap first-time borrowers at a lower amount than repeat borrowers with a clean history
6. Routing rules
- Refer any application above a set amount to a senior credit manager
- Refer when a data source is unavailable instead of rejecting
- Refer near-misses (for example, FOIR within two points of the cap) for human review
An example policy for an unsecured personal loan
Here is how those groups look as a single decision table. The values are illustrative.
| # | Rule | Condition | If it fails |
|---|---|---|---|
| 1 | Blacklist | PAN not on internal blacklist | Reject |
| 2 | KYC | Aadhaar, PAN and face match verified | Reject |
| 3 | Age | 21 ≤ age ≤ 58 | Reject |
| 4 | Serviceable area | Pincode in serviceable list | Reject |
| 5 | Bureau score | Score ≥ your cut-off | Reject |
| 6 | Recent enquiries | ≤ 4 enquiries in 30 days | Refer |
| 7 | Income | Net monthly income ≥ product minimum | Reject |
| 8 | FOIR | FOIR incl. new EMI ≤ 50% | Reduce amount, else reject |
| 9 | Bounces | ≤ 1 EMI bounce in 6 months | Refer |
| 10 | Ticket size | Amount ≤ senior-approval threshold | Refer |
The same policy expressed as configuration might look like this:
policy: personal-loan
version: 3
rules:
- id: blacklist when: pan in blacklist then: reject
- id: kyc when: not kyc.verified then: reject
- id: age when: age < 21 or age > 58 then: reject
- id: bureau_score when: bureau.score < cutoff then: reject
- id: enquiries_30d when: bureau.enquiries_30d > 4 then: refer
- id: foir when: foir_with_new_emi > 0.50 then: reduce_amount_or_reject
- id: bounces_6m when: bsa.bounces_6m > 1 then: refer
default: approveHow rules differ by product
One policy rarely fits every loan you offer. Keep a separate rule set per product so you can tune each one on its own:
| Product | Rules that matter most |
|---|---|
| Short-term personal loan | Bank statement income and bounces, recent enquiries, repeat-borrower history |
| EMI-based personal loan | FOIR including the new EMI, bureau score, employment stability |
| Gold loan | Loan-to-value against the appraised gold, KYC, lighter bureau rules |
| Business / MSME loan | Business vintage, bank statement turnover, existing business obligations |
Common mistakes when automating credit policy
- Rejecting on missing data. If the bureau times out, “reject” loses good borrowers. Route to refer instead.
- No reason codes. A decision without a reason cannot be explained to an auditor or a borrower.
- Editing rules in place. Always create a new policy version so past decisions remain explainable.
- Automating everything on day one. Start with knock-outs and clear approvals; keep the middle in the referral queue until the numbers prove the rules.
- Never reviewing thresholds. Check approval, referral and early-delinquency rates by policy version every month.
For real-world scenarios — clearing a credit backlog, stopping repeat fraud, reacting to rising delinquencies — read six ways a BRE improves lending operations.
Turn this policy into live rules. CredBrick's Business Rule Engine (launching soon) runs rules like these on the KYC, bureau and bank statement data CredBrick already collects. Get early access.
Frequently asked questions
What rules should an NBFC automate first?
Start with knock-out rules (blacklists, failed KYC) and eligibility rules (age, serviceable pincode, product limits). They are unambiguous, easy to verify and remove the most obvious rejections from the credit team's queue.
What FOIR cap should an NBFC use?
There is no single correct value. Lenders set FOIR caps in their own credit policy based on product, income level and portfolio performance, and often allow higher caps for higher-income borrowers.
Should a business rule engine reject applications when bureau data is unavailable?
Usually not. Routing those applications to manual review (refer) avoids rejecting good borrowers because of a temporary technical failure.