THE banking sector witnessed several policy measures in 2024 which were largely influenced by three major factors, namely the persistent rise in the inflation rate, policy measures to reform the foreign exchange market and the recapitalization programme announced for the industry.
Inflation The steady rise in prices of goods and services worsened in 2024, due to a combination of further increase in pump price of petrol and continuous naira depreciation.
In 2024, the naira depreciated by 34% and 56% to N1,662 and N1540 per dollar in the parallel and official market, from N1, 240 and N988.46 per dollar at the beginning of the year.
The depreciation of the naira combined with fuel subsidy removal led to 76.4% increase in national average price of petrol to N1,184.83 per liter.
This worsened the rise in prices of goods and services, which started in 2022. Reflecting this trend, the impact on the welfare of Nigerians, the national average Cost of a Healthy Diet, CoHD, rose by 74 per cent to N1.371 in October from N786 in December 2023, according to the National Bureau of Statistics, NBS. As a result, the headline inflation rate rose steadily to 33.88 per cent, in October from 28.92 per cent in December 2023.
Interest rate hikes
In response to the persistent rise in the inflation rate, the Central Bank of Nigeria, CBN, implemented measures to reduce money supply in the banking system. The apex bank raised the benchmark interest rate eight times and by 875 basis points to 27.5 per cent in November from 18.75 per cent at the beginning of the year. The CBN also increased the Cash Reserve Ratio, CRR of Commercial and Merchant banks to 50 per cent and 16 per cent respectively from 32.5 percent and 10 per cent at the beginning of the year. Furthermore, the apex bank conducted a liquidity mop up through regular sale of Open Market Operations, OMO, treasury bills.
Vanguard analysis of data from the apex bank showed that the CBN sold N12.83 trillion worth of OMO TBs from January to December 5th, up from N716.7 billion in the whole of 2023. This development led to acute scarcity of funds in the interbank money market, with banks regularly resorting to borrow from the CBN to meet short term cash needs. Reflecting this, the interbank interest rate rose to 31.5 per cent on Friday December 13, 2024, from 15.38 per cent on December 29th 2023.
In line with the hikes in the MPR, interest rate on 365-days treasury bills rose 22.9% in December from 12.24% at the end of last year. While the high interest rate regime triggered by the MPR hikes, attracted criticism from manufacturers and other real sector operators, it however enhanced investors’ returns on fixed income investment like TBs, Commercial Papers, and bonds, as well as on banks’ interest income and profitability.
For example, the interest income of the top 11 commercial banks rose sharply by 141.75 per cent to N6.89 trillion in the first half of the year, H1’24 from N2.8 trillion in H1’23. FX market A major highlight of 2024 for the banking industry and the economy is the raft of policy measures introduced by the CBN in its bid to enhance transparency, confidence and boost dollar supply in the foreign exchange market. Hence within one week, the CBN introduced five circulars which changed the dynamics of the forex market and triggered momentary appreciation of the Naira.
Price Transparency
First, the CBN on January 29, issued a circular titled ‘Financial Markets Price Transparency’, which addressed the malpractice of inaccurate and misleading information on transactions concluded in the official forex market. The circular stated: “Ongoing investigations have revealed instances of under-reporting of transaction rates and the practice of second cheque and fixed income transactions. This behaviour is not compliant with ethical standards associated with sound financial markets and deliberate attempts to create price distortions by reporting false transactions details amounts to market manipulation which will not be tolerated and will henceforth face sanctions.”
Reflecting the transparency engendered by this warning, the naira depreciated sharply in the official market to N1348.63 per dollar, and as a result, the gap between the official market and parallel market exchange rates narrowed to N76.37 per dollar from N508.1 per dollar last weekend.
Restriction on Banks’ FX holdings
Next, the CBN on January 31st, in a bid to improve forex supply, and address excess dollar holdings by banks, ordered the banks to sell their excess dollar holdings within 24 hours. In a letter on Harmonisation of Reporting Requirements on Foreign Currency Exposures of Banks, the CBN warned banks against excess dollar holdings. “The Central Bank of Nigeria has noted with concern the growth in foreign currency exposures of banks through their Net Open Position (NOP). This has created an incentive for banks to hold excess long foreign currency positions, which exposes banks to foreign exchange and other risks,” the CBN said.
Consequently, the apex bank pegged the Net Open Position, NOP, the difference between a bank’s foreign currency assets and its foreign currency liabilities to 20 per cent of shareholders’ funds. Hence it directed that banks with current NOPs exceeding these limits should adjust their positions to comply with the new regulations latest by February 1, 2024.
IMTOs & Diaspora Remittances
On the same January 31st, and to also boost Diaspora remittances through official channels, the CBN issued a circular titled, ‘Removal of Allowable Limit of Exchange Rate Quoted by the International Money Transfer Operator’ The circular removes the exchange rate cap for IMTO, namely the peg of -2.5% to +2.5% around the previous day’s closing rate of the Nigerian Foreign Exchange Market.
“IMTOs are hereby allowed to quote exchange rates for naira payout to beneficiaries based on the prevailing market rates at the Nigerian Foreign Exchange Market on a willing seller, willing buyer basis,” the CBN said. To complement the above, the CBN, in a bid to enhance the operations of IMTOs and also improve ease of doing business for them, issued a ‘Reviewed Guidelines of International Money Transfer Services in Nigeria.’ Among other things, the reviewed guidelines stipulated minimum operating capital of $1 million, raised application fee for IMTO license to N10 million, and banned banks and FinTechS from offering IMTO services. To further enhance ease of doing business for IMTOs, the CBN created a window for them to access Naira to pay beneficiaries of diaspora remittance.
“Henceforth, eligible IMTOs operators will be able to access the CBN window directly or through their Authorized Dealer Banks (ADBS) to execute transactions for the sale of foreign exchange in the market. ”The option of same day settlement will be available for transactions executed and confirmed before 12 noon on a trading date; “The pricing for transactions executed with the CBN will be based on prevailing Nigeria Autonomous Foreign Exchange Market, NAFEM, rates, as referenced by an observable and acceptable market benchmark,” the apex bank stated. Spread on FX rate removed On February 8, the CBN issued a circular to further liberalise the forex market.
The circular titled ‘Removal of the Spread on Foreign Exchange Transactions’, removed the 2.5 per cent cap spread on interbank foreign exchange transactions, thus allowing banks to determine the gap between their offer and selling rate for forex transactions.
E-payment for PTA/BTA
In a bid to sanitise the forex market, the CBN on February 14th, restricted the payment of Personal and Business Travel Allowances (PTA/BTA) through electronic channels only.
“In line with the Bank’s commitment to ensure transparency and stability in the foreign exchange market and avoid foreign exchange malpractices, All Authorized Dealer Banks shall henceforth effect payout of PTA/BTA through electronic channels only, including debit or credit cards. For the avoidance of doubt, payment of PTA/BTA by cash is no longer permitted,” the apex bank stated in a circular.
FX backlog controversy
A major issue that dogged the banking industry in 2024 was the overdue $7 billion foreign exchange forward transactions. In February, the CBN Governor, Olayemi Cardoso, in an interview, said a forensic audit of $7 billion of overdue foreign exchange transactions, the bank has been trying to clear had uncovered irregularities affecting $2.4 billion worth of the transactions.
Following this disclosure, the CBN in March announced that it has cleared all valid FX backlog, including the $600 million belonging to foreign airlines operating in the country. However, members of the Organised Private Sector, OPS, faulted the claim by the CBN saying many businesses still have funds trapped at the banks without any communication from the CBN regarding what constitutes a valid forex request and those deemed invalid. The National Vice President of the Nigerian Association of Small-Scale Industrialists, Segun Kuti- George, argued that the claim by the CBN that some of the forex requests were invalid was ‘propaganda’ and that some of the affected businesses are contemplating taking legal action against the banks in order to force the CBN’s intervention in the matter.
”Some of the requests have been cleared, but there are others that they are saying were illegal and did not meet their criteria, but the importers are not aware of the reason why the requests have been rejected. Their money is still with the bank, and they are groaning,” he said.
Following the intervention of the Presidency, the CBN Governor, in October, said that the apex bank has commenced a re-validation exercise to ascertain complaints of manufacturers and importers over foreign exchange claims worth $2.4 billion.
Speaking at a special summit dinner organised by the Nigerian Economic Summit Group in Abuja, Cardoso said the CBN has finalised its first stage of verification and is currently going through a second stage to authenticate claims by manufacturers.
IOC dollar remittance
In another move to enhance dollar supply in the forex market, the CBN stopped International Oil Companies, IOCs, from immediately remitting 100 percent of their dollar proceeds to their parent company abroad. Hence the apex bank said IOCs will only be allowed to immediately remit 50% while the balance can be remitted 90 days later. In a circular signed by the Director of Trade and Exchange, Hassan Mahmud, the CBN said: “Banks are allowed to pool cash on behalf of IOCS, subject to a maximum of 50% of the repatriated export proceeds in the first instance. The Balance 50% may be repatriated after 90 days from the date of inflow of export proceeds.”
BDC sector Reforms
The apex bank on February 28th announced sale of $20,000 to each BDCs Explaining the rationale for this move, the CBN, in a circular said, “Following the ongoing reforms in the foreign exchange market, aimed at achieving an appropriate marketdetermined exchange rate for the Naira, the Central Bank of Nigeria has observed the continued price distortions at the retail end of the market, which is feeding into the parallel market and further widening the exchange rate premium. To this end, the CBN has approved the sale of foreign exchange to eligible Bureau De Change to meet the demand for invisible transactions.
This was however followed with the revocation of the license of 4,173 bureaux de change, BDCs, operators on March 1st. According to the apex bank, the licenses of the BDCs were revoked due to their failure to pay all necessary fees, including license renewal, within the stipulated period in line with guidelines, rendition of returns in line with the Guidelines, and compliance with guidelines, directives and circulars of the CBN, particularly Anti-Money Laundering (AML), Countering the Financing of Terrorism (CFT) and Counter-Proliferation Financing (CPF) regulations.
Two months later, the apex bank announced new operating guidelines for BDCs on May 23rd. The new guidelines introduced two categories of BDCs, Tier 1 and Tier 2, with minimum capital requirements of N2 billion and N500 million respectively, with a six months deadline for existing BDCs to apply for new licenses based on the new categories and minimum capital requirements.
The new guidelines also limited the foreign currency holdings of BDCs (Net Open Position, NOP) to 30 per cent of shareholders’ funds unimpaired by losses. It also limited total borrowing to 50 per cent of shareholders’ funds unimpaired by losses.
Electronic Foreign Exchange Matching System (EFEMS)
In line with its efforts to enhance transparency in the forex market, the CBN on October 3rd announced the introduction of the Electronic Foreign Exchange Matching System (EFEMS) for Foreign Exchange (FX) transactions in the Nigerian Foreign Exchange Market (NFEM).
“This development is expected to reduce speculative activities, eliminate market distortions, and give the CBN improved oversight capabilities to effectively regulate the market,” the apex bank explained. Following a two-week test run in November, the apex bank, in a circular announcing the commencement of the EFEMS on December 2nd, said: “The CBN hereby states that effective from December 2, 2024, Authorised Dealers will go live in the use of the Bloomberg BMatch as the Electronic Foreign Exchange Matching System (EFEMS) for its FX trading activities in the FX market.
The Bloomberg BMatch platform will enhance the integrity and operational efficiency of the FX market by providing transparent and automated matching of trades leading to market efficiency and greater price discovery.” The CBN also pegged the minimum foreign exchange trade on the Electronic Foreign Exchange Matching System (EFEMS) platform at $100,000, with incremental clip sizes of $50,000.
In the first week of the commencement of EFEMS, the Naira appreciated for five consecutive days in the forex market, the first time since May. The Naira appreciated by 9.8 per cent in the official market to N1,535 per dollar and also by 7.7 per cent in the parallel market to N1,555 per dollar, reflecting the impact of the EFEMS on the forex market. Foreign Currency Disclosure Scheme Another notable and novel forex market related development this year, is the “Foreign Currency Disclosure, Deposit, Repatriation, and Investment Scheme”, announced by the Federal Government on October 31st.
The scheme allows a 9-month grace period for Nigerians with foreign currency to voluntarily disclose and deposit the same in banks According to the Minister of Finance and Coordinating Minister of the Economy, Mr. Wale Edun, the Disclosure Scheme, outlined by the “Foreign Currency Disclosure, Deposit, Repatriation, and Investment Scheme Guidelines, 2024,” seeks to encourage Nigerians to voluntarily disclose and formalize their foreign currency holdings, whether domestically or abroad. He added that the scheme is also designed to “integrate foreign currency outside the formal financial system into the formal economy” and “strengthen transparency and economic resilience.”
Consequently, the CBN issued guidelines, which among other things directed Commercial, Merchant, and Non- Interest Banks (CMNIBs) to, among other things, open domiciliary accounts for participants in the scheme.
OTHER BANKING DEVELOPMENTS
Wigwe’s transition On February 9th, the banking industry and corporate Nigeria was jolted with the news of the tragic death of Mr. Herbert Wigwe, Chief Executive Officer, Access Corporation, in a helicopter crash near the California-Nevada border, United States of America. The crash also claimed the lives of Wigwe’s Wife, Chizoba, his son, and a former President of Nigeria Exchange Group, Abimbola Ogunbanjo. The late banker played a huge role in the emergence of Access Bank as the largest bank in the country, first as Deputy Managing Director and later as the MD/CEO of the bank. The late Wigwe has played a leading role in the banking industry as the Chairman, Body of Bank CEOs, a position he held till his transition.
Banking consolidation
The banking industry on March 28th commenced another recapitalisation exercise, when the CBN announced new minimum capital requirements for the various categories of banks, with a two-year deadline.
According to the CBN, “The new minimum capital base for commercial banks with national authorisation is now N200 billion, while the new requirement for those with regional authorization is N50 billion. “The new minimum capital for merchant banks would be N50 billion, while the new requirements for noninterest banks with national and regional authorisations are N20 billion and N10 billion, respectively.
All banks are required to meet the minimum capital requirement within 24 months commencing from April 1, 2024, and terminating on March 31, 2026.” However, to the surprise of the industry, the CBN excluded retained earnings in the computation of the bank’s minimum paid up capital.
According to the apex bank, the minimum capital shall comprise paid-up capital and share premium only, stressing that the new capital requirement shall not be based on the Shareholders’ Fund. The announcement prompted a flurry of capital raising exercises, including Public offer, Rights Issue offer, as banks besieged investors for fresh funds to meet the new minimum capital.