In our February 3, 2020 article, we had written on the differences between a Mobile Money Operator (MMO) license, a Payment Service Bank (PSB) license and a Microfinance Bank (MFB) license. The article was aimed at supporting Fintechs in determining which of the existing Central Bank of Nigeria (CBN) licenses is compatible with their services or proposed products.
MMO | PSB | MFB | |
Minimum share capital
|
NGN 2 billion | NGN 5 billion |
Unit (Tier 1) – NGN 200 million
Unit (Tier 2) – NGN 50 million
State MFB – NGN 1 billion
National MFB – NGN 5 billion |
Service Area | No restriction | 25% of its operations in Rural Areas |
Unit (Tier 1) – operating in urban areas with 5 offices in 5 Local Government Areas (LGAs).
Unit (Tier 2) – operating in rural areas with two branches in 1 LGA.
State – operating in one state.
National – operating in all the states. |
Loan | Not permitted | Not permitted |
Permitted provided that:
|
Bank accounts and Wallets |
Bank Account-Based
Card Account-Based (Credit, Debit and Pre-paid)
e-Wallet |
Account and e-Wallets | Bank accounts |
Cards | Limited to card processing | Debit and Pre-paid cards | Debit and Credit cards |
Transaction limit |
Depending on KYC level:
level 1 – NGN 50,000 (balance of NGN 300,000)
level 2 – NGN 200,000 (balance of NGN 500,000)
level 3 – NGN 5,000,000 (unlimited balance) |
Depending on KYC level:
level 1 – NGN 50,000 (balance of NGN 300,000)
level 2 – NGN 200,000 (balance of NGN 500,000)
level 3 – NGN 5,000,000 (unlimited balance) |
No Limit |
Foreign Currency transaction | Can receive and sell foreign exchange from inbound transfer.
Prohibited from remittance. |
Can receive and sell foreign exchange from inbound transfer.
Prohibited from remittance. |
Prohibited from foreign exchange transactions |
Airtime and USSD service | Permitted (subject to NCC approval) | Permitted (subject to NCC approval) | Permitted (subject to NCC approval) |
QR Code Payments | Permitted | Permitted | Permitted |
Connection with the Nigeria Inter-bank Settlement System
(NIBSS) |
Required | Required | Required |
Connection with the CBN Real Time Gross Settlement (RTGS) |
Required | Not required | Not required |
Agent Banking | Permitted | Permitted | Permitted |
Who can Operate | Existing Banks and any company can apply for an MMO license. |
Limited to the types of companies listed below:Banking AgentsTelecommunication companiesRetail chainsPostal Service and Courier CompaniesMMO (converting to PSB)Switching Companies Financial Technology companies Financial Holding companies |
Any company can apply for an MFB license. |
Since our article, the CBN has issued various regulations and policies affecting MMOs, MFBs and PSBs. In view of this, we have updated our table on the different licenses to reflect the regulatory update.
If you require clarity or further information on the licenses above, contact Pavestones at info@pavestoneslegal.com.
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Read the original publication at Pavestones