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The Insider Who Never Said “Catch Me”: Can SEBI Prove Insider Trading When the Trader Is Not an Obvious Insider?

Insider-trading enforcement is relatively straightforward when the facts fit the conventional pattern: a person connected with the company obtains UPSI, trades shortly before the announcement and benefits when the information becomes public. However, the more difficult cases are those that fall outside this obvious pattern. Consider the following situation: (i) Sometime in January, Investor Z purchased the shares of Company A; (ii) In February, Company A initiates discussions w.r.t. acquisition with Company B; (iii) In March, the aforesaid transaction is put on hold; (iv) From April to June, there was again no discussion on (ii); (v) Then, suddenly, in July, there is a public announcement regarding the transaction. Assumptions here: 1. Investor Z has no formal connection with either Company A or Company B; 2. Investor Z makes a substantial gain out the transaction referred to above. As legal experts, the following issues arise for our consideration: (a) Can a mer...
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RBI Draft Interest Rate Directions 2026: Is RBI Tightening NBFC Group Company Lending?

  -             Reading the RBI's proposed interest-rate framework beyond the headline The Reserve Bank of India’s proposed Reserve Bank of India (Interest Rates on Loans and Advances) Directions, 2026 may, at first glance, appear to be a technical exercise in consolidating the rules governing interest-rate determination. But a closer reading raises a broader regulatory question: Is RBI gradually moving towards a framework where an NBFC is expected to demonstrate genuine credit intermediation and risk-based lending, rather than merely functioning as a financing vehicle for its own group or promoter entities? The answer is not yet an outright “yes” in terms of a prohibition . The Draft Directions do not say that NBFCs cannot lend to subsidiaries, group companies or promoter entities. However, several elements of the proposed framework, when read together with RBI's existing regulatory architecture, point towards a stronge...
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Frequently Asked Questions (FAQs) on RBI's Draft NBFC Credit Facilities Amendment Directions, 2026

The Draft Reserve Bank of India (Non-Banking FinancialCompanies – Credit Facilities) Amendment Directions, 2026 , released on 6 August 2026 , introduces significant changes to the regulatory framework governing credit facilities offered by NBFCs. While the draft is concise, it raises several practical, legal, and operational questions. The following FAQs aim to assist NBFCs, fintech companies, legal professionals, compliance officers, and other stakeholders in understanding the implications of the proposed amendments. 1. What is the purpose of the Draft Amendment Directions? The Draft Amendment Directions seek to amend the Reserve Bank of India (Non-Banking Financial Companies – Credit Facilities) Directions, 2025 by: introducing statutory definitions of "term loan" and "revolving credit" ; prohibiting NBFCs from offering revolving credit products; deleting the existing chapter governing demand/call loans; and making cons...
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RBI's Draft Credit Facilities Amendment Directions, 2026: End of Revolving Credit and Demand/Call Loans for NBFCs?

On 6 August 2026 , the Reserve Bank of India (RBI) issued the Draft Reserve Bank of India (Non-Banking Financial Companies – Credit Facilities) Amendment Directions,2026 for public comments. While the draft comprises only two pages, the proposed amendments have the potential to significantly reshape the lending landscape for NBFCs. The amendments introduce statutory definitions for "term loan" and "revolving credit" , prohibit NBFCs from offering revolving credit products (except by authorised credit card issuers), and delete the existing regulatory framework governing Demand/Call Loans . For NBFCs offering credit lines, digital lending products, overdraft-type facilities, or callable loans, these proposals warrant immediate attention. Background: The draft seeks to amend the Reserve Bank of India (Non-Banking Financial Companies – Credit Facilities) Directions, 2025 , issued on 28 November 2025 . RBI proposes these amendments in exercise of its powers und...
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