The new guidelines released on 9 July 2021 have made some additions to the 2015 framework. They provide a coverage of the MMO value chain from service providers to subscribers and agents. Two types of operations governed by these guidelines include:
The Bank Led Model: These are deposit money banks offering MMO services alone or with other banks, essentially commercial banks operating disruptively in the MMO space.
The Non-Bank Led Models: These are non-banking organisations that have obtained a licence from the CBN to carry on MMO services.
The new Guidelines have made additions to the permissible activities that were listed out under the old guidelines. The additions include MMOs being operational, wallet creation, e-money issuance, agent recruitment and management, pool account management, non-bank acquiring services, and card-acquiring services.
However, even with the additions made, MMOs are still prohibited from carrying on the following types of businesses: 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. Besides, customers can use the funds in these wallets to invest only in government treasury bills.
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.
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