When experience becomes infrastructure.

Can experience be shared? From deposit pricing to digital KYC, two regulatory changes show how hard-earned judgment is becoming reusable infrastructure for financial institutions.

Mayank Jain · 31 Jul 2026 · 4 min read

Hello everyone,

Welcome to the 214th edition of The Pattern.

A few months ago, I was at a roundtable and asked a senior credit head a simple question: How long does it take for a new underwriter to actually get good at the job?

He just looked at me and said, "About three years."

The sheer specificity of that threw me off.

Learning a credit policy, he explained, takes a few weeks—anyone can do that. What takes years is learning how to apply it well. It's knowing which clean-looking application deserves a closer look, spotting the tiny detail that doesn't quite add up, and knowing the difference between a smart exception and a default waiting to happen six months down the line. You can't teach that in a classroom. It only comes from years of reviewing files, getting things wrong, and living with the consequences.

I’ve been thinking about that conversation on and off. And this week, two regulatory updates that I want to address in today's edition got me wondering.

Can you shortcut that kind of experience, or is there no way around it?

Replacing a treasury desk's judgment with a formula

The RBI now lets banks set differential interest rates on bulk deposits based on their Liquidity Coverage Ratio (LCR) run-off rates, effective October 1, 2026. But the basic rule stays the same: rates still need to be uniform across branches, and two deposits of similar amount booked on the same day must get the same rate.

What has changed is how banks can price bulk deposits. Bulk deposits could already be priced by quantum and tenor. What's new is that banks can now also price based on the run-off rate — how likely that deposit is to leave the bank during a period of stress, as defined under the LCR framework.

The LCR run-off rate itself is the product of years of observing how different types of deposits behave during periods of stress. Instead of every treasury team relying only on experience to judge how "sticky" a deposit is, the RBI now lets banks use that accumulated learning as a standardised pricing input.

A KYC officer's read, turned into a score

At the same time, India is rolling out a central digital KYC framework across banks and insurers, with mutual funds expected to join next. Instead of re-submitting the same stack of documents for every new account, customers can provide OTP-based consent to pull a verified record straight from a central registry.

Crucially, each record carries a confidence score indicating how reliable the information is and whether a regulated institution has already vetted it. The next bank or insurer doesn't have to start from scratch. They know not just what the customer submitted, but exactly how much to trust it.

That brought me right back to the credit head's three-year timeline. The hard work of verifying a customer still has to happen once. But once it's done, that judgement doesn't stay trapped inside a single institution. It travels with the record, saving everyone downstream from repeating the exact same work. (Related: how Superflows puts your risk team in control of verification for digital lending — the same shift, playing out inside a single lender's own onboarding stack.)

So—can you shortcut the three years?

Not entirely, and I don't think that's what either of these regulatory changes is trying to do.

What they are doing is identifying the parts of judgment that don't need to be rediscovered every time. A run-off rate captures years of learning about how deposits behave under stress. A KYC confidence score tells the next institution how much trust it can place in a customer's identity record. Neither replaces the people making the decision, but both mean they don't have to start from zero.

The treasury manager who can sense when a corporate client is getting nervous still matters. So does the underwriter who spots something that doesn't quite add up. Those decisions still rely on experience.

What's changing is that some of that experience no longer stays locked inside one person's head or one institution's files. It becomes something the next person can build on instead of having to recreate for themselves.

The credit head at that roundtable was right: true judgment takes years of intuition and hard lessons to build. But going forward, new risk officers won't have to waste those years re-learning what a formula or a shared registry can now hand them on day one.

Reading list

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Cheers,
Mayank

All opinions expressed are my own and do not necessarily reflect the views of FinBox or its promoters.