SETTING UP A PAYMENT SERVICE BANK IN NIGERIA

Source: GSMA Mobile for Development

BACKGROUND STATISTICS

36% of Nigerian adults are unbanked. CBN aims for 95% financial inclusion by 2024. 92% of the nation’s adult male population have mobile phones while 88% of the adult female population have mobile phones.

RATIONALE

CBN aims “To enhance financial inclusion in rural areas by increasing access to deposit products and payment/remittance services to small businesses, low-income households and other entities through high-volume low-value transactions in a secured technology-driven environment.”

PSBs IN NIGERIA

As at the time of writing this article, there are five (5) PSBs in Nigeria namely 9 PSB (a subsidiary of 9Mobile), Hope PSB (A Subsidiary of Unified Payments) , Money Master PSB (A Subsidiary of Globacom), Momo PSB (A Subsidiary of MTN Nigeria), SmartCash PSB (A subsidiary of Airtel Nigeria).

REGULATORS OF PSB

The Central Bank of Nigeria is the main regulator of PSBs in Nigeria, Deposits are also Nigeria Deposit Insurance Corporation (NDIC) insured.

SERVICES PSBs CAN CARRY OUT

  • Accept deposits from customers and small businesses
  • Hold funds in an electronic wallet
  • Invest in an interest-bearing FBN and CBN securities and offer saving products
  • Provide POS and ATM Services
  • Build a network of physical banking agents for deposits, payments and withdrawals
  • Issue prepaid and debit cards
  • Provide inbound remittance services
  • Engage in different forms of local payments including merchant payments, bill payments ad person-to-person transfers.

SERVICES PSBs CAN NOT CARRY OUT

  • They are not to issue loans, advances and guarantees.
  • They are also not allowed to trade in foreign exchanges except for remittances
  • They are also not allowed to issue insurance products.

REGISTRATION REQUIREMENTS FOR PSBs

Steps to obtain a PSB license from CBN

  • Obtain the Grant of Approval-in-Principle (AIP)
  • Obtain the Grant for a Final Banking License

REQUIREMENTS FOR THE GRANT OF APPROVAL IN PRINCIPLE (AIP)

  • Formal application for the grant of a Payment Service Bank license addressed to the Governor of the CBN attached with a proposal to be submitted to the Director, Financial Policy and Regulation Department (FPRD), CBN. The proposal shall contain the business case, vision and strategy, corporate governance arrangements, risk management, compliance; and financial viability.
  • A non-refundable application fee of N500,000 (five hundred thousand Naira only) in bank draft, payable to the Central Bank of Nigeria or such other amount as the CBN may specify from time to time
  • Evidence of capital contribution made by each shareholder
  • Evidence of name reservation with the Corporate Affairs Commission (CAC)
  • Detailed business plan or feasibility report
  • The draft copy of the company’s Memorandum and Articles of Association (MEMART)
  • A written and duly executed undertaking by the promoters that the bank will be adequately capitalized for the volume and character of its business at all times, and that the CBN shall have powers to supervise and regulate its operations
  • Shareholders’ agreement providing for disposal/transfer of shares as well as authorization, amendments, waivers, reimbursement of expenses
  • Statement of intent to invest in the bank by each investor
  • Technical Services Agreement
  • Detailed Manuals and Policies, particularly

For corporate investors as the promoters shall forward the following additional documents:

  • Certificate of Incorporation and certified true copies of other incorporation documents
  • Board resolution supporting the company’s decision to invest in the equity shares of the proposed bank
  • Names and addresses (business and residential) of owners, directors, and their related companies, if any; and
  • Audited financial statements & reports of the company and Tax Clearance Certificate for the immediate past 3 years.

Where all the above requirements have been met, the CBN shall notify the applicant of its decision within 90 days. When the CBN is pleased with the application, it will grant the applicant an Approval-in-Principle (AIP).

Afterwards, the Applicant shall register the PSB with the Corporate Affairs Commission with a 5 Billion minimum share capital.

REQUIREMENTS FOR THE GRANT FOR A FINAL BANKING LICENSE

The applicants of a planned PSB must apply to the CBN for the grant of a final license not later than six (6) months after receiving the A.I.P. The application shall be accompanied by the following:

  • A non-refundable licensing fee of N2,000,000.00 (Two Million Naira Only) in bank draft payable to the Central Bank of Nigeria
  • Certified True Copy (CTC) of Certificate of Incorporation of the bank
  • CTC of MEMART
  • CTC of Form CAC 1.1
  • Evidence of the location of the Head Office (rented or owned) for the take-off of the business
  • Schedule of changes, if any, in the Board and Shareholding after the grant of AIP;
  • Evidence of ability to meet technical requirements and modern infrastructural facilities such as office equipment, computers, and telecommunications, to perform the bank’s operations and meet CBN and other regulatory requirements;
  • Copies of letters of offer and acceptance of employment in respect of the management team;
  • Detailed resumes of top management staff;
  • Completed Fitness and Propriety Questionnaire; and sworn declaration of net worth executed by top management staff; 
  • Bank Verification Number (BVN) and Tax Clearance Certificate of each top management staff;
  • Comprehensive plan on the commencement of the bank’s operations with milestones and timelines for the roll-out of crucial payment channels; and
  • Board and staff training program.

Following that the above requirements have been met, the central bank of Nigeria shall conduct other inspection, which includes: checking the physical structure of the building, verifying the capital contributions of the promoters, meeting with the Board and Management team whose resumes had earlier been submitted to the CBN, check the original copy submitted in support of the license.

For bespoke consultation on setting up a Payment Service Bank in Nigeria

Regville Associates                                                                                                                    08065111667                                                                                                   info@regville.com