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CBN Issues New Guidelines for Mobile Money Operators in Nigeria

The apex regulator of banking activities in Nigeria has released new guidelines to further regulate the services provided by mobile money operators (MMOs) in Nigeria.

MMOs have simplified financial transactions and services in Nigeria by increasing the number of banked individuals, reducing the need for banks to have physical presence to provide financial services to residents of rural areas, a development that further promotes the CBN’s “cash-lite” agenda.

Since 2015, when the last regulatory changes were made using the old guidelines, mobile money operators have evolved to some extent with the surge in financial solutions driven by technology.

The new guidelines which made some additions to the 2015 framework, provide a robust coverage of the MMO value chain from service providers to subscribers and agents.

A statement released on Thursday by Ibrahim Moshood, an associate of the Centurion Law Group, two major types of operations governed by the guidelines are the Bank Led Model which include deposit money banks offering MMO services alone or with other banks, essentially commercial banks operating disruptively in the MMO space and the Non-Bank Led Models comprising non-banking organisations that have obtained a license from the CBN to carry on MMO services.

According to the statement, the new Guidelines have made additions to the permissible activities which include MMOs being operational, wallet creation, e-money issuance, agent recruitment and management, pool account management, non-bank acquiring services and card-acquiring services.

He however, noted that even with the additions made, MMOs are still prohibited from carrying on with direct or indirect loans or guarantees, insurance underwriting, subsidiaries’ establishment, foreign currency deposit services and other forex activities that save the facilitation of cross-border remittances to personal accounts subject to the applicable regulatory framework.

“The new guidelines allow MMOs to offer savings wallets to be operated with settlement banks and the funds held in these wallets are insured with the Nigerian Deposit Insurance Corporation (NDIC) using a pass-through insurance arrangement subject to specific requirements in relation to investment operations and interest distribution.

“The savings wallets funds are subject to a maximum management rate of 10% but must also ensure that the principal sum is not affected by charges and fees. The wallets are also insulated from offsets by the settlement banks with whom the MMOs operate the accounts. Note that customers can use the funds in these wallets to invest ONLY in government treasury bills,” the statement explained.

On Consumer Protection and Sanctions, the guidelines stipulated that MMOs are now required to resolve customer complaints within 48 hours and in addition, must ensure that customers understand the transactions being concluded, provide robust frameworks against loss of service, proper communication channels and offer adequate disclosures to customers.

It further explained; “Where for instance, there is a new capitalisation requirement by the CBN and a settlement bank is unable to meet up, such could have its license withdrawn. In such an event, the NDIC’s maximum deposit coverage level kicks in at N500,000 for each subscriber.

“Where an MMO has its license withdrawn or activities banned, the CBN ensures that the deposit liabilities of the subscribers are assumed by another MMO, or some other financial institution as defined under the Banking and Other Financial Institutions Act (“the BOFIA”). The CBN also reserves the right to take sanctions against an MMO, its board of directors, officers or agents, withhold corporate approvals as well as suspend or revoke licenses.”

For limits for transactions, the new guidelines said the balance limits for wallet holders have been increased from N50,000 to N5,000,000 for daily activities. While for cumulative balance, the N300,000 cap has been removed and is now unlimited, depending on the Know-Your-Customer (KYC) tier.

The statement quotes the new guidelines as stipulating that all risk mitigation techniques adopted by the MMOs must be within the scope of the relevant code of corporate governance such as the Code of Corporate Governance for Finance Companies 2018 (the Code).

“While MMOs have not been listed as financial institutions as such in the Code, it appears that the CBN has expanded the definition in the Code to cover MMOs by virtue of the fact that MMOs are listed as “other financial institutions” in the BOFIA.

“Furthermore, all MMOs are to file annual audited reports and mandatory continuity business plans to the CBN within the first three months of the following year or no later than 31 March of the following year,” it concluded.


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