Country _ Name
Nigeria
SectionTitle
Trading platforms/social trading platforms/signal following
Body
FinTechs belonging to this category operate trading platforms or online marketplaces for investment opportunities or certain financial contracts – e.g. securities, factoring etc. and sometimes furthermore provide contact to financial experts and tools for the decision-making.

FinTech-signalling and social trading platforms provide users with the opportunity to exchange opinions on financial investments and offer signal providers and traders the possibility to make their securities portfolio publicly visible. This way the portfolios can be linked to and followed by other traders via the platform automatically, so that the trading and investment strategy of the followed traders can be copied.

The platform often cooperates with a financial services provider or a credit institution where both the trader and the follower hold their securities accounts, and which execute the orders both of the trader and the follower and to which the platform passes on the trading decisions.

Introduction

Attitude of the country towards trading, social trading or signalling platforms

Trading, social trading, and signaling platforms have gained significant traction among Nigerians, particularly the youth, for various reasons. One of such reasons is the accessibility of trading, social trading and signaling platforms. Nigeria’s mobile penetration currently stands at about 87%, with 172 million mobile subscribers, the majority of whom are young Nigerians. Due to the ubiquity of mobile phones in Nigeria, many Nigerians can easily access, interact, and engage with these platforms.
Despite the burgeoning demand for trading, social trading and signaling platforms in Nigeria, regulatory bodies in Nigeria have adopted a cautious and conservative stance toward them. The regulators have expressed concerns that the potential

exploitation of these platforms could facilitate criminal activities like money laundering, terrorism and proliferation financing. Consequently, recent regulations issued by Nigerian authorities reflect this apprehensive approach aimed at mitigating such risks.


Legal affairs

Obligations and requirements to provide trading, social trading or signalling platforms described above

In Nigeria, trading platforms are regulated by the SEC and are classified by the SEC as Sub-brokers serving Multiple Brokers through a Digital Platform (the “Digital Sub-brokers”). To obtain a Digital Sub-broker license from the SEC, the prospective operators must first incorporate and register a company with the CAC. The company must maintain a minimum paid-up capital of ?10,000,000 (Ten Million Naira) which may be in the form of bank balances, fixed assets or investment in quoted securities. The company must also have a current fidelity insurance bond covering at least 20% of the minimum paid-up capital.

After incorporation, the company must submit an application to the SEC for registration as a Digital Sub-broker. Under the SEC Rules 2013, the company is obligated to pay the following: ?100,000 ($66) as a filing/application fee, ?300,000 ($197) as a processing fee, ?100,000 ($66) for each sponsored individual, and ?1,000,000 ($654) as a registration fee.

In addition to the aforementioned requirements, the rules mandate that applicants for a Digital Sub-broker license must provide various documentation/information, including but not limited to: (i) a copy of the multiple principal agreements with every sponsoring broker; (ii) a description of the technology upon which their infrastructure is built; (iii) certification by a National Information Technology Development Agency (“NITDA”) registered IT service provider confirming that the infrastructure is sufficient to perform the required functions, documented policies and procedures for managing technology risks and (iv) agreement with every client.

Upon registration, the Digital Sub-broker will be authorized to facilitate the following functions: (i) purchase and sale of securities; (ii) receiving payments from clients in relation to the sale or purchase of securities; (iii) making payments to clients in relation to the sale or purchase of securities; and (iv) other services ancillary to the sale, purchase, and payments of securities.
Conversely, social trading and signaling platforms are not subject to registration with the SEC or any regulator as long as they solely provide accurate financial market data, news, research, and analytics, and users only exchange investment strategies and knowledge. However, if these platforms offer investment advisory services and make recommendations regarding the types of securities to buy and sell, they will need to register with the SEC.

Additional comments regarding the legal situation for trading, social trading or signalling platforms or what FinTech’s must be aware of in this business area

Alongside the requirement to obtain a licence to operate as a Digital sub-broker in Nigeria, operators are also at the risk of incurring tortious and/or criminal liabilities. This could arise from instances where users rely on inaccurate market data or investment advice provided by the platform, leading to poor investment decisions. However, such platforms can mitigate this risk by providing a disclaimer to users or clients, clarifying the limitations of the information provided and absolving themselves from legal responsibility for any resulting actions or outcomes.

Furthermore, FinTechs belonging to this category are also required to ensure that the data provided by their users and stakeholders are protected and secured in line with the applicable data protection laws in Nigeria. FinTechs are also required to maintain and be guided by robust KYC/AML Policies. This is to mitigate against financial fraud including financing terrorist activities. The KYC/AML policy of every FinTech Company must be in line with requirements provided by existing laws, regulations, and international best practices.


Economic conditions

Market size for trading, social trading or signalling platforms and biggest companies in this business area

There is no available official data on the market size for trading, social trading and signaling platforms. However, the biggest companies in this sector are Chaka Technologies Limited, Bamboo Systems Technology Limited, and Rise Vest Technologies Global Limited.

Additional comments regarding the economic situation for trading, social trading or signalling platforms or what FinTech’s must be aware of in this business area

According to the World Bank, approximately 50% of Nigerians live below the poverty line. Additionally, the Nigerian Deposit Insurance Corporation reported that 99.4% of bank accounts contain less than ?500,000 (approx. $327). In other words, there are very few individuals in Nigeria with sufficient disposable income to save, let alone invest using trading, social trading or signalling platforms platforms.

Also, given that FinTech companies such as trading, social trading, or signaling platforms rely heavily on digital infrastructure, they must invest significantly in cybersecurity measures to safeguard user data, prevent unauthorized access to trading accounts, and mitigate fraud. They must also comply with data protection laws as to the protection of their users’ data and prevent data breaches.

Furthermore, due to the constant fluctuations in foreign exchange rates in Nigeria, FinTech companies are advised to carefully consider the implications of exchange rate risk on their operations and implement appropriate hedging strategies.



Authors

NameOrganisationEmail
Ebimobowei JikenghanG Elias[email protected]06346
Eberechukwu Ezike [email protected]0 

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