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Economy | Monetary Policy

CBN Issues Guidelines for the Registration and Operation of Bank Neutral Cash Hubs (BNCH) in Nigeria

Mar 15, 2022   •   by Proshare Research   •   Source: Proshare   •   eye-icon 123 views

Tuesday, March 15, 2022 / 12:48 PM / By CBN / Header Image Credit: Guardian Nigeria

 

1.0  Introduction

The Central bank of Nigeria (CBN), in furtherance of its mandate to promote a sound financial system in Nigeria, in collaboration with Banker's Committee initiated the Nigerian Cash Management System (NCMS) which seeks to reduce cost and improve operational efficiency in the country's cash management value chain. One initiative towards the above stated goal is the introduction of Bank Neutral Cash Hubs (BNCH). BNCHs are cash collection centers to be established by registered processing companies or Deposit Money Banks (DMBs) based on business needs. They will be located in areas with high volumes of commercial activities and cash transactions. The hubs will provide a platform for customers make cash deposits and receive value irrespective of the bank with which their account is domiciled. This guideline aims to provide minimum standards and requirements for BNCH registration and operations for effective supervision.

 

2.0 Objective

The key objective of setting up Bank Neutral Cash Hubs (BNCH) is to reduce the risks and cost borne by banks, merchants and huge cash handlers in the course of cash management activities; deepen financial inclusion; and leverage on shared services to enhance cash management efficiency.

 

3.0 Permissible And Non-Permissible Activities

 

3.1 Permissible Activities

A BNCH may carry out the following:

  1. Receipt of Naira denominated deposits on behalf of financial institutions from individuals and businesses with high volumes of cash.
  2. High volume cash disbursement to members of the public on behalf of financial institutions.
  3. Any other activities that may be permitted by the CBN.

 

3.2 Non Permissible Activities

A BNCH shall not:

  1. Carry out investing or lending activities.
  2. Receive, disburse, or engage in any transaction involving foreign currency.
  3. Undertake any other transaction which is not prescribed by this guideline.
  4. Sub-contract another entity to carry out its operations v. Any other activities that may be prohibited by the CBN.

 

4.0 Eligible Promoters

The following may apply for registration of a BNCH:

  1. Deposit Money Banks (DMBs)
  2. Cash Processing Companies (CPCs)


5.0 Registration Requirements

The promoters shall submit a formal application to the Director, Currency Operations Department (COD) requesting to be granted approval to operate a BNCH, which shall be processed in two stages, namely: Approval-in-Principle (AIP) and Final Approval.

 

5.1 Requirements for Approval-In-Principle (AIP)

A. Prospective promoters of BNCH (CPC or DMB) seeking to operate a BNCH shall apply in writing to the Director, Currency Operations Department (COD) and submit the following documents with the application:

i. A valid DMB license or a valid proof of CPC registration issued by the CBN;

ii. A non-refundable application fee of N100,000 only, or such other amount as the CBN may specify, in a bank draft payable to the CBN;

iii Evidence of board resolution approving the application duly signed by the Chairman and Secretary of the board of the CPC or the DMB;

iv. Detailed business plan or feasibility report which shall, at a minimum, include:

a. Objectives of the BNCH;

b. Services to be rendered by the BNCH;

c. Justification for the application;

d. Organizational structure, showing functional units, responsibilities, reporting relationships;

e. List of proposed staff in charge of BNCH operations/services;

f. Technical Services Agreement (where applicable); and

v. Certificate of Incorporation and certified true copies of other incorporation documents of the CPC or the DMB;

vi. Detailed Manuals and Policies, including but not limited to:

a. Operations manual;

b. Dispute resolution protocols

c. Whistle-blowing policy;

d. Enterprise Risk Management (ERM) Framework

e. Code of Business Ethics and Conduct.

 

B. Following the receipt of an application with complete and satisfactory documentation, the CBN shall issue a no objection to the promoters of the BNCH.

 

C. In all cases, the CBN shall communicate its decision to the promoters within thirty (30) days of receipt of the application.

 

5.2 Requirements for Grant of Final Approval

Upon the issuance of no objection to the application and before the grant of Final Approval to operate as BNCH, the promoters shall submit the following:

i.                  Evidence of location of office (rented or owned) for the takeoff of the business;

ii.        Evidence of ability to meet technical requirements and provision of modern infrastructural facilities such as office equipment, computers, telecommunications, to perform the BNCH's operations and meet CBN and other regulatory requirements;

iii.              Evidence of insurance to cover hub vault cash.

iv.              Evidence of collaboration with the Nigeria Police Force (NPF).

v.               A facility with; adequate office space for day-to-day operations; a secure minivault for storage of cash; basic security infrastructure such as 24/7 electronic CCTV surveillance, access control and monitoring etc by appropriate security personnel.

vi.          Secure connectivity with the Nigerian Interbank Settlement System (NIBSS) who must provide interoperability amongst DMBs to establish a platform for customers at the BNCHs to receive same day value for their deposits.

vii. Provision of Service Level Agreement between Currency Processing Company and Deposit Money Bank, for the extension of clearing, settlement and indirect connectivity with NIBSS.

vii.       Internal Control Policy;

ix.      Business Continuity Plan;

x. Comprehensive plan on the commencement of the BNCH's operations with milestones and timelines; and

xi. Evidence of staff training program.

xii. Evidence of insurance of total deposits

 

5.3 Financial Requirements

The financial requirements for an approval to operate as BNCH, which may be amended by the CBN as it deems necessary, are as follows:

  1. Non-refundable application fee of one hundred thousand Naira (N100,000); and
  2. Non-refundable approval fee of five hundred thousand Naira (N500,000).


5.4 Conduct of Pre-Approval Inspection

As a requirement for the grant of final approval, the CBN shall conduct an inspection of the premises and facilities of the proposed BNCH to, amongst others:

  1. Check the suitability of the physical structure of the office building and infrastructure provided for take-off of the BNCH;
  2. Sight the original copies of the documents submitted in support of the application for Approval; and
  3. Meet with the Management team.

 

5.5 Post-Commencement Requirements

A BNCH shall:

  1. Comply with the requirements incidental to the authorization to perform its operations as stipulated by the CBN from time to time;
  2. Comply with all guidelines and regulations issued by the CBN;
  3. Maintain an adequate accounting system and keep records that capture information which reflect the financial condition of the;
  4. Notify CBN upon commencement of operations.

 

5.6 Technology Requirements

The technology implemented by the BNCH shall comply with the industry standard technology in terms of hardware and software.

 

The BNCH shall ensure that:

  1. Transaction information is transmitted in a secure manner.
  2. The technology deployed comprises a set of interoperable infrastructure modules that work seamlessly with the common platform provided by NIBSS.
  3. Customers get immediate value for successful transactions.
  4. Payment instructions are instantly executed.
  5. Immediate reversal shall be mandatory, In the event of communication failure during a transaction,
  6. Generation of receipts or durable acknowledgements for successful transactions.
  7. Audit trail is maintained and made available on request.
  8. All settlement information details are preserved for a minimum period of 5- years, and are made available via the Cash Activity Reporting Portal (CARP).
  9. The BNCH shall put in place adequate measures to mitigate all the risks that could arise from the deployment and use of its IT architecture.

 

5.7 Data and Network Security Requirements

BNCHs shall put in place systems that specifically and at a minimum address the following issues:

  1. Availability of services.
  2. Data confidentiality and integrity.
  3. Encryption of electronic transactions.
  4. Customer accountability and non-repudiation of transactions.
  5. Error messaging and exception handling.
  6. Secure integration to the Cash Activity Reporting Portal (CARP)

 

Download Full Guidelines Here

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