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Part 2 - Debate Topic Can Loan App Agreements nulify CBN Policy Debate Between the LoansharkReview Team, Pro Loan Apps, and Loan App Agents (Part 2 of 25)

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In Nigeria’s rapidly growing digital lending space, loan apps often include terms that seem to contradict – or outright ignore – policies set by the Central Bank of Nigeria (CBN), such as:

  • Maximum allowable interest rates
  • Prohibited debt recovery methods (e.g., harassing contacts)
  • Data collection and sharing limits

But legally speaking, does a user’s agreement to app terms give lenders the right to bypass CBN guidelines?

In Part 2 of this 25‑part debate series, you will learn:

✅ The legal hierarchy between CBN circulars and private contracts under Nigerian law

✅ Whether the "consent" obtained via checkboxes constitutes valid waiver of regulatory protections

✅ Arguments from Pro Loan Apps – why they claim their terms are lawful and consumer‑approved

✅ Counter‑arguments from the LoanSharkReview Team – why such terms may be void for being contrary to public policy

✅ Real‑life testimony from Loan App Agents on what actually happens in the field vs legal theory

Who should watch/read this?

  • Fintech compliance officers
  • Legal professionals interested in Nigerian banking & contract law
  • Loan app users who have faced unexpected deductions or harassment
  • Regulators and policy advocates

Format:

Video debate + written summary with key legal takeaways

Next in the series (Part 3):

"Do Loan Apps Violate the NDPB Act by Accessing Contacts Without Explicit Consent?"

📎 Reference documents mentioned in this debate:

  • CBN Circular on Digital Lending (link)
  • Nigeria Data Protection Act, 2023 (excerpts)
  • Sample loan app terms & conditions (redacted)
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