Reach last-mile retail borrowers — through community retailers, not sales teams.
Under any of your four partner tracks, you can deploy a network of proprietor sub-agents — neighbourhood retail outlets, local market aggregators, transport-hub operators — who source micro-loans to micro-enterprise owners, gig-income workers and small traders. Every rupee flows through Satsai's dynamic QR. Proprietors never touch cash. The DLD-2025 fund-flow rule is unbroken.
Four layers, one regulatory anchor
Satsai is the only RBI-regulated entity in the chain. Every other layer contracts back to Satsai directly — no nested sub-LSP accountability gap.
Satsai Finlease Pvt Ltd
RBI Reg. B-14.01646. Licence, balance sheet, credit sanction, CIC reporting, grievance final escalation.
You — under any T1 / T2 / T3 / T4 track
Tech platform, onboarding + monitoring of proprietor network, monthly commission payouts, reconciliation, first-line grievance — all under Satsai's MSA.
Proprietor A — retail outlet / market aggregator / transport-hub operator
LSP sub-category DSA + Recovery Agent. Sources borrowers, displays rotating Satsai QR at counter, first-line grievance intake. Never touches funds. Tripartite contract with Satsai + Primary LSP.
Borrower A — micro-enterprise owner / gig-income worker / informal-sector self-employed
Scans counter QR → UPI → lands in Satsai master CASA auto-tagged to proprietor. Repayment in daily / weekly micro-EMI cadence.
Why this is not a prohibited "sub-LSP chain"
RBI's concern with nested LSP structures is the accountability gap — the RE doesn't know who's actually fronting the customer. We neutralise that with a tripartite Proprietor Services Agreement: Satsai + Primary LSP + Proprietor, all named parties. Proprietor is listed on Satsai's public List of LSPs within 2 working days of go-live, per DLD 2025. Every proprietor is knowable, contracted and audit-able by Satsai directly — even when the Primary LSP runs day-to-day operations.
The borrower scans the proprietor's QR. Money lands in Satsai. Every time.
Satsai master CASA (@ ICICI / HDFC / Axis)
▲
│ every inbound tagged with
│ proprietorId + loanId
│
┌──────────────┴──────────────┐
│ VA + Dynamic QR infra │
│ Razorpay / Cashfree / │
│ Decentro / M2P │
└──────────────┬──────────────┘
│
Per-proprietor: │
• VA IFSC + │
10-digit number │
• UPI QR with │
rotating signed │
token │
│
Borrower scans proprietor's counter QR
│
└─► UPI → Satsai CASA
ref: PROP-0007-LOAN-ABC
Disbursal: Satsai → borrower's bank / VPA
Commission: Satsai → proprietor's bank, monthly
(TDS 194H @ 5%)
Cash: Not supported in v1Funds never touch the proprietor
UPI lands directly in Satsai's CASA. Proprietor app shows receipt of the credit; no pass-through account exists. DLD 2025 fund-flow rule fully respected.
Auto-attribution in Satsai's ledger
Each VA + QR encodes proprietorId + loanId in the UPI reference, auto-credited to the right sub-ledger in real time.
Multi-vendor VA fallback
Primary VA provider + standby second vendor (different bank rails). If one goes down, QR auto-switches.
Rotating QR token (anti-diversion)
Each proprietor's QR is a signed token rotated daily. Off-platform QR attempts are detected by book-outstanding vs collection lag anomaly checks.
From first handshake to first EMI in one counter
Tech-led, vernacular, scalable. Target: 30-minute onboarding; first loan sourced the same day.
Onboarding (30 minutes)
Individual KYC (PAN + Aadhaar OTP + selfie), shop verification by gig field agent, 2 references, bank account, tripartite eSign. Proprietor is on Satsai's List of LSPs within 2 working days.
Training + Fair Practices Code
Online module in preferred language: FPC, collections conduct, DPDP basics, fraud red-flags, grievance handling. Completion certificate stored.
Virtual Account + Dynamic QR provisioned
Each proprietor gets a Satsai-backed VA (Razorpay / Cashfree / Decentro / M2P) + rotating UPI QR token. Counter poster auto-generated with grievance numbers in vernacular.
First loan sourcing
Proprietor triggers application; borrower's own phone completes KYC (Aadhaar OTP + geo-selfie + bureau + bank penny-drop). Underwriting runs on Satsai credit policy. eSigned vernacular KFS issued.
Repayment at the counter
Borrower scans the shop QR. UPI credit lands in Satsai master CASA, auto-tagged to proprietor + loan. Proprietor sees live collection in app. Commission accrues.
Monthly commission payout
Satsai pays proprietor directly to personal bank with TDS 194H @ 5% deducted. Form 26Q filed quarterly. Commission invoice trail preserved for audit.
A different product for a different customer
Existing STPL does not fit last-mile retail borrowers. We engineer a distinct micro-loan construct under Satsai's credit policy.
| Attribute | STPL (existing Quikkred) | Proprietor-sourced micro |
|---|---|---|
| Typical ticket | Mid-range personal | Micro |
| Tenure | 7 / 15 / 30 / 60 / 90 days | 14 / 30 / 45 / 60 days |
| Repayment cadence | Bullet / monthly | Daily / weekly / bi-weekly (cashflow-matched) |
| KFS language | English + 12 Indian | Vernacular-first, 13 Indian |
| KYC | Aadhaar OTP + bureau-led | Aadhaar OTP + geo-selfie + penny-drop; thin bureau tolerated |
| Disbursal channel | Borrower's bank account | Borrower's bank / UPI VPA |
| Repayment channel | UPI / NACH | UPI at proprietor's QR (primary) |
| Segment | Salaried + self-employed urban | Micro-enterprise owner, informal-sector self-employed, small trader |
| PSL eligibility | Case-by-case | Weaker Sections / Micro — typically eligible |
The micro-loan product is PSL-eligible under RBI's Priority Sector Master Direction — which opens a Priority Sector Lending Certificate (PSLC) sale to banks, providing an additional revenue stream on top of the interest spread.
Commission, TDS, GST — who pays what, who owes what
Sourcing commission
One-time, at disbursal. Paid monthly by Satsai to proprietor's personal bank. TDS u/s 194H @ 5% deducted if annual commission > ₹15,000.
Collection commission
Recurring, linked to each successful EMI credit. Accrues daily in the proprietor ledger; settles monthly.
Performance bonus + claw-back
Bonus for high on-time-rate. Claw-back of sourcing commission on early default — protects against mis-sourcing.
GST at proprietor level
Unregistered proprietors (turnover < ₹20 L) charge no GST. Registered proprietors charge 18%; Satsai absorbs as cost (no ITC, consistent with §5a). Budgeted into commission commercials.
Satsai's revenue remains 100% interest (exempt from GST output). Proprietor commission is a cost line, not a revenue line. Our engineered zero-GST-output posture on revenue is preserved. ITC leakage on the commission input is priced into the interest spread.
Proprietor-layer risks + controls
The 8 risks most likely to break a proprietor network — and the specific technical + contractual controls that catch them.
Local coercion of borrower
FPC e-training + audio-recorded consent at origination + random mystery-borrower audits + vernacular grievance poster at counter.
Ghost-loan fraud
Borrower video KYC + Aadhaar OTP + geo-tagged selfie + bank penny-drop to borrower's own account (never the proprietor's). Per-proprietor disbursal cap ramps with tenure.
Off-platform QR diversion
Satsai issues daily-rotated signed-token QR. Proprietor app renders only the authorised QR. Book-outstanding vs collection lag anomaly detection.
Over-concentration on one proprietor
Per-proprietor portfolio caps. Book auto-distributes across 2+ proprietors in same cluster post-threshold. Fluxusforge tele-collections absorbs if a proprietor exits.
Paying on behalf of defaulting borrower
UPI-sender VPA mismatch vs loan holder detected; flagged for review. DPD logic unchanged; credit signal preserved.
Raw PII at the counter
Origination runs on borrower's own device. Proprietor dashboard shows masked identifiers only. DPDP data minimisation enforced in API layer.
AML / PMLA conduit
Full KYC as LSP + CKYC pull + STR pattern monitoring + periodic AML re-screen. Proprietor listed on Satsai's public List of LSPs — transparency is a control.
Device compromise / proprietor incapacitation
Device binding + remote wipe + session kill-switch. Nominee clause in tripartite for incapacitation; book fails over to nearest proprietor + Fluxusforge.
The regulatory corpus for this layer
Ready to reach the last-mile borrower?
Two ways in: apply as a Distributor if you can recruit and manage a cluster of proprietor shops, or as a Primary LSP if you want to operate the network platform itself under any of the four partner tracks.
Proprietor onboarding is governed by the Tripartite Proprietor Services Agreement (Satsai + Primary LSP + Proprietor). Proprietors are listed on Satsai's public List of LSPs within 2 working days of go-live, as required by RBI (Digital Lending) Directions, 2025. Satsai remains the lender of record on every KFS and loan agreement. Grievances: Grievance Redressal Policy · Nodal Officer. Final escalation: RBI Integrated Ombudsman (cms.rbi.org.in).
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