Reading Your Bank Statement Against CBN Charge Limits
Every Nigerian business receives a bank statement each month. Most file it. A small number read it. A tiny fraction read it against the Central Bank of Nigeria's published fee and charge limits — and discover they have been overcharged, sometimes for years.
Excess bank charges recovery is the practice of examining a company's bank statements against the CBN's regulatory framework and claiming back the difference. It is not litigation. It is not a complaint process. It is an accounting exercise: identify the charge, verify the regulatory limit, calculate the excess, and submit a claim.
What CBN Permits Banks to Charge
The CBN's Guide to Charges by Banks and Other Financial Institutions sets out what banks may charge, and the maximum rates and amounts. The framework covers:
- Account maintenance fees (monthly or quarterly, capped)
- Card issuance and renewal fees
- Electronic transfer and NIP charges
- Cheque book issuance
- ATM withdrawal fees beyond the free monthly allowance
- Commission on turnover (COT)
- Stamp duties on eligible transactions
- SMS and alert charges
The key point is not that these fees exist — it is that each one has a stated maximum. A bank may charge below the maximum, but it may not charge above it. And the regulatory framework has changed over the years, so the limit that applied to a charge made in 2022 may differ from the limit that applies to one made today.
What Banks Actually Charge
In practice, fees that exceed CBN limits arise in a few common patterns:
- COT charged at a rate above the prevailing cap. Commission on turnover is the most frequently misapplied charge on Nigerian corporate statements. The permitted rate has changed several times, and billing systems do not always update on the effective date.
- Stamp duties collected on transactions that are not dutiable. Stamp duty at ₦50 per transaction applies to certain electronic transfers above a threshold. Transfers below the threshold, or transfers within the same bank, are sometimes incorrectly stamped anyway.
- SMS charges on opt-out accounts. A customer who has opted out of SMS alerts should not be charged for them. The opt-out is not always honoured.
- Duplicate charges and unauthorised debits. Recurring fees sometimes post twice in a cycle, or a fee that should have been waived posts in full.
- Maintenance fees on dormant accounts. A dormant or inactive account should not accrue monthly maintenance fees in some frameworks, or should attract a reduced rate.
The Recovery Process
We follow a systematic approach:
Statement collection. We gather the company's bank statements for the review period — typically the last three to six years, depending on the volume of transactions and the statute of limitations applicable to the claim.
Line-by-line audit. Every debit entry on every statement is checked against the CBN fee guide that was in effect on the date the charge posted. Fees that exceed the limit are flagged. Fees that have no regulatory basis are flagged. Duplicates are flagged.
Quantification. The flagged items are aggregated to produce a schedule of excess charges by month and by fee type. This schedule forms the basis of the claim.
Submission. A formal claim is prepared and submitted to the bank's customer complaints unit, with the CBN circular as the legal reference. Banks are required to respond within a stated period under the CBN's Consumer Protection Regulations.
Escalation if needed. If the bank rejects the claim or does not respond, the matter may be escalated to the CBN's Consumer Protection Department or referred through the banker-customer dispute resolution framework.
What Makes This Worth Doing
For a business with active transaction volumes, the accumulated excess charges over a multi-year period are often material. The direct cost of the recovery process is a fraction of the expected recovery amount, and the recovered funds come back as a credit to the account — no new revenue to generate, no new product to sell, no new client to win. It is money already spent that should not have been spent, found by reading the statement closely enough.
And once the audit is done, the pricing errors on the account are corrected going forward, so the monthly charge level drops to the correct amount from that point on.
What We Check
Our statement audit covers every fee type that has a regulatory limit or a regulatory basis. We are not assessing the bank's service quality or the commercial reasonableness of its pricing. We are reading the statement against the published rules and counting the difference. If the rules permit the charge, the charge stands. If the rules do not, we flag it.
The service works on a contingency basis: we take a percentage of the recovered amount. If there is nothing to recover, there is no fee.