Respondents of the various interactions deployed by Lagos Business School for its Digital Financial Services in Nigeria: State of the Market Report 2017, were quite generous in proposing policy and legislation reform suggestionshttp://sustainabledfs.lbs.edu.ng/FI-Resources/SoMR-Full_Report-2017.pdf
Amongst other recommendations, the respondents asked government to allow participation of telcos as key actors of mobile money given the widespread availability of airtime and established distribution networks.
Other observations regarding policy and regulatory process activities in need of improvement were noted. These include:
- Reduce the time and effort associated with policy and regulatory actions such as licensing
- Generate evidence-based policies and regulations that genuinely reflect and meet the needs of the constituents
- Conceptualize implementation strategies and evaluation frameworks alongside policies
- Relax conditions, primarily relating to KYC and agency banking
- Revisit fees (prices), the lack of consideration of market prices and cost-to-serve jeopardise policy sustainability, especially for much needed agents whose role is to provide the last mile over the counter (OTC) financial services to the under-banked and unbanked.
- Review credit bureau practices and microfinance bank (MFB) licensing requirements
- Explore alternate licensing models such as regional licenses for agency banking, MMOs providing a full suite of essential financial services, not just payments, but also offering savings and credit products.
- Leverage existing license approvals to enable additional financial services licenses applications. For example, deposit money banks desirous of establishing microfinance banks are required to commence licensing procedures without any recourse to an existing banking license. Supplemental licenses could ride on existing licenses.
- Improved collaboration and cooperation among financial services providers (FSPs) and between FSPs and telcos
- Consider airtime as a store of value
- Establish a unified body to oversee government agencies and regulators and enhance inter-governmental agency collaboration.