Could this have happened? A moneylending operation through a commodity exchange?

I approach a sugar factory owner. Offer him a loan of 50 crs. He gives me a certificate saying that goods are in his godown. My understanding is that he will pay me @ 21% p.a. and the tenure is three years. Armed with the warehouse receipt, I now offer ‘investors’ a 15% p.a. yield on sugar. I will keep rolling over the tenure on and on and on. This difference accrues to my NBFC which is an account holder with another body which has members and membership of a commodity exchange. This another body also belongs to me. In effect, I have used the mechanism of a commodity exchange to become a leveraged money lender. The commodity may or may not be there. I know that when I give the loan for three years. So, most of the turnover that happens is of my ability to create enough borrowers. It started with my trying to lend money out of the huge surplus lying in the balance sheet. The commodity exchange came in very handy as a tool to create more lenders and borrowers, with no risk to me. A six percent spread on a few thousand crores is easy money. And have got enough contacts to duck regulatory action.