Know Your Rights: (15) We have prepared a comprehensive list of policies that protect you as a borrower. Know your rights and be free from the shackles of loan apps.

• 4.2.1 The content of advertisements shall be factual and unambiguous, expressed in clear and simple language and shall not be offensive, misleading, deceptive, injurious, or exaggerate the benefits of the products or services being advertised. 

5.2.9 Issue Letter of Discharge at no cost to customers within 5 business days after liquidation of their loans, and where the loan is guaranteed, the guarantor shall also be notified accordingly.  

5.5.7 Not engage in any of the following:

a. Contact friends, employer, relatives or neighbours of a customer for any information other than information on employment status, telephone numbers or address, except where:

1. The person has guaranteed the loan; or
2. The person has consented to be contacted. 

b. Require any of the persons listed in (a) above to offset the debt, except where the person has acted as a guarantor. 

c. Make telephone or personal contact with customers between the hours of 9.00pm and 8.00am for the purpose of debt recovery, except with the prior consent of the customer. 

1️⃣ Hidden or Non-Disclosed Charges

• Any charge or fee not clearly disclosed before the consumer signs the agreement is unfair.
• Example: A loan app that adds a “processing” or “penalty” fee that wasn’t mentioned in the loan offer.
• 📜 CBN Rule: All fees, charges, and penalties must be clearly disclosed in writing before or at the time of entering the contract.

Contract terms that conflict with any laws or regulations are null and void

Management Fee covering processing, appraisal, ancillary and other related fees on a new loan application (one-off charge)

Negotiable, subject to maximum of 1% of the principal amount disbursed (one off charge)

Section 17(a), (g), (m), (s) & (t) — The Commission shall protect consumers from unfair trade practices, ensure fairness, honesty, and equitable dealings, and prohibit misleading, unfair, or deceptive conduct.

Loan Apps must be honest about their terms and interest. If they lie or use threats, you can report them, and you are not liable to pay such a loan

If a loan app falsely accuses you of being a thief, publishes your name or contact info, or sends messages to your friends or family saying you defaulted — you have rights under Nigerian law.

According to

Section 373 of the Criminal Code Act,

defamation means “matter likely to injure the reputation of any person by exposing him to hatred, contempt or ridicule, or likely to damage any person in his profession or trade by injury to his reputation.”

What this means is: when a digital lender publishes false and damaging information about you, you can take legal action — and you may be entitled to compensation (such as the headline “up to ₦7 million”) if you can show the harm done to your reputation.

5.4.3 Not transfer personal data of consumers to a third party without their express consent, except in compliance with a legal obligation.

5.4.4 Inform consumers whenever their data is exchanged with an authorized third party, stating details of the exchange.

To prove your case, gather:

• 📱 Screenshots of the loan app’s messages to your contacts
• 🧾 Proof of payment (if you already paid your loan)
• 📤 Any social media posts or WhatsApp chats where they mentioned your name
• 🧍‍♂️ Witness statements (from friends, family, or colleagues who got the messages)

Keep everything neatly arranged — courts rely heavily on evidence.

A clause that allows the institution to impose new penalties under vague or undisclosed conditions.

Example: “Other charges may apply” without specifying what they are.

• 📜 CBN Rule: Contracts must clearly define all applicable charges, and vague “open-ended” penalty terms are unfair.