The Central Bank of Nigeria (CBN) has released the Regulatory Framework & Guidelines on Mobile Money Services in Nigeria. The Framework incorporates an updated version of the previous Guidelines on Mobile Money Services in Nigeria. One of the reasons for  the Framework is to set the minimum technical and business requirements for the various participants in the MMS ecosystem. The Framework also highlights the obligations and responsibilities of the identified participants.

Scope of the Guideline

The guideline grouped the participants in the MMS ecosystem into six major categories as follow:

1. Regulators (CBN and the Nigeria Communications Commission)
2. Mobile Money Operators (Banks and other Corporate Organisations)
3. Infrastructure providers (provide switching, processing and settlement facilities)
4. Other Service Providers (entities with specialised skills and resources to support MMOs)
5. Consumers (end-users of mobile money services); and
6. Mobile Money Agents (regulated under the Guidelines on Agent Banking and Agent Banking Relationship in Nigeria).

Implementation Modalities for the MMS in Nigeria

MMS in Nigeria is implemented under two models as follow:

Bank-led:

Under this model, a bank or a consortium of banks will deliver MMS by leveraging the mobile payments system.

Non-bank led:

This model allows a corporate organisation that CBN licenses to deliver MMS to customers. Under this model, the Lead Initiator is a corporate organisation other than a deposit money bank (DMB), a national primary mortgage bank, a national microfinance bank or a telecommunication company subsidiary,  licensed explicitly by the CBN to provide MMS in Nigeria. Under the old Guidelines, only DMBs and telcos were excluded from this model.

The telco-led model where the lead initiator is a Mobile Network Operator (MNO) is not operational in Nigeria

Activities Permitted for MMOs

According to the guideline, the following are the activities permissible for the MMOs

• Wallet creation and management
• E-money issuing;
• Agent recruitment and management
• Pool account management
• Non-bank acquiring (as stipulated in the regulatory requirements for non-bank merchant acquiring in Nigeria);
• Card Acquiring; and
• Any other activity that the CBN may permit.

 

Mobile Money Scenarios

There are three methods through which mobile money can be undertaken:

1. Bank Account (savings, current and domiciliary accounts)
2. Card Account (credit, debit and pre-paid)
3. Stored Value (e-Wallet) Account (Re-loadable Stored Value Account and Pre-paid Account).

Highlights of the Store Value scenario includes:

• An MMO offering a Savings wallet service must operate a Savings Wallet Principal Pool Account and a Savings Wallet Interest Pool Account in a settlement bank with the funds having NDIC protection under the pass-through insurance.
• Funds on saving wallets can only be invested in Nigerian Treasury Bills.
• Charges for the investment management must not be more than 10% of interest income on savings wallet funds investment.
• A Mobile Money savings wallet account holder cannot suffer diminution in the principal sum on theirwallet as a result of fees or charges.
• DMBs serving as settlement banks are prohibited from offsetting any other transactions of the MMO against the savings wallet principal pool accounts and savings wallets interest pool account.

Key Compliance Obligations for MMOs

• Non-Bank MMOs must keep records of transactions for a minimum of seven years.
• Non-Bank MMOs must provide a monthly assessment report to CBN
• An MMO must, at the end of every month (and not later than the 14th day of the following month), submit information in the prescribed format to CBN.
• MMOs must submit their audited annual returns to CBN within the first three months after the year-end or 31st of March.

Commentaries

The Framework provides a more comprehensive set of rules/regulations for players in the MMS sector.

The Framework appears to have modified the document retention period under the Companies and Allied Matters Act.

Participants are advised to review their processes and compliance framework to ensure they are up to date.