Skip to main content

Multiple-Banks Mandate

Global Standing Mandate (GSM)​

Developer & Merchant Integration Guide​


⚠️ Important Disclaimer The Global Standing Mandate (GSM) described in this document is a private, merchant-initiated, consent-based direct debit arrangement built on CreditChek's infrastructure. It is not the Central Bank of Nigeria (CBN) / NIBSS-regulated Global Standing Instruction (GSI) system. Give your business the tools to build and run its own secure, compliant, consent-driven direct debit infrastructure across your borrowers' multiple bank accounts β€” protecting your credit terms at every stage, without compromising consumer rights.

GSI is a regulated interbank framework exclusively available to CBN-licensed commercial banks. GSM is a complementary, fully-consented alternative designed for OFIs, fintechs, cooperative societies, and post-paid service providers operating outside the CBN-licensed banking perimeter. Usage of this system implies acceptance of CreditChek's Terms of Service and applicable regulatory obligations.

Purpose of this document: To provide developers, merchants, compliance officers, and regulators with a fact-based, line-by-line comparison between the CBN's GSI framework and CreditChek's GSM service β€” using the CBN's own published language as the authoritative reference.


Executive Summary​

The CBN's GSI is a regulatory enforcement tool β€” a last resort for licensed commercial banks connected to the NIBSS NIP systems to recover loans already in default, executed involuntarily (upon the condition of the executed GSI condition or prior consent by the payer) against a borrower without requiring their real-time cooperation. It is administered by NIBSS under the authority of the CBN Act 2007.

CreditChek's GSM is a private, consent-driven direct debit infrastructure β€” a pre-default repayment automation tool that requires explicit, active payer participation at every step. It is governed by contract law, the FCCPC Act 2018, and CreditChek's terms of service.

They address different problems, serve different audiences, and operate under entirely different legal regimes. They are not interchangeable or comparable systems.


Table of Contents​

  1. Overview
  2. GSM vs GSI β€” Key Distinctions
  3. Who Can Use GSM
  4. Architecture & Flow
  5. Step 1 β€” Bank Account Discovery (RADAR Lookup)
  6. Step 2 β€” Set Mandate (Place e-Mandate on Accounts)
  7. Step 3 β€” Micro-Deposit Verification Loop
  8. Step 4 β€” Spectrum Credit Bureau Reporting (Mandatory)
  9. Step 5 β€” Automated Collection
  10. Consent & FCCPC Compliance
  11. Caveats, Limits & Legal Boundaries
  12. Glossary

1. Overview​

Global Standing Mandate (GSM) is CreditChek's consent-driven, BVN-anchored multi-bank direct debit framework. It enables merchants and lenders outside the traditional commercial banking space to:

  • Discover all active bank accounts tied to a borrower's BVN via RADAR
  • Place verified e-mandates on one or more of those accounts via RecovaPRO
  • Automate repayment collection from a primary account, with fallback to backup accounts
  • Report every loan lifecycle event to the credit bureau via Spectrum, making collection legally defensible and always FCCPC-compliant

The system is fully consent-based. The payer (borrower) actively participates in designating their accounts β€” there is no silent or involuntary sweep.


2. GSM vs GSI β€” Key Distinctions​

DimensionCBN/NIBSS GSICreditChek GSM
Governing BodyCBN / NIBSSCreditChek (Private Infrastructure)
EligibilityCBN-licensed commercial banks onlyOFIs, fintechs, cooperatives, post-paid providers
Consent ModelRegulatory mandate; borrower consent implicit at loan originationExplicit, active, per-account payer consent required at every step
Account DiscoveryBank-wide sweep by CBN authorityRADAR BVN lookup; payer-confirmed accounts
Initiation AuthorityCBN-empowered sweepMerchant-initiated via CreditChek API
Reporting TriggerNon-performing loan reported to CBNLoan lifecycle reported to Credit Bureau via Spectrum
Legal BasisCBN Act, BOFIA Act 2020FCCPC Act 2018, Contract Law, CreditChek Terms of Service
Collection BehaviorInvoluntary interbank sweepAutomated but fully consented debit per mandate
Bureau ReportingHandled by bankMandatory via CreditChek Spectrum
Micro-deposit VerificationNot applicableRequired for every account enrolled

⚠️ You must never represent this service to borrowers or regulators as equivalent to, or backed by, the CBN's GSI system.


CBN's own language on authority:

"In pursuant of the powers conferred on the Central Bank of Nigeria (CBN) by Section 2(d) of the CBN Act, 2007... the CBN hereby issues this guideline on Global Standing Instruction (GSI) to enhance loan recovery across the banking sector."

Implication for GSM merchants: CreditChek's GSM derives no authority from the CBN Act or any CBN guideline. It operates entirely within the contractual relationship between the merchant and the borrower, governed by FCCPC consumer protection law.


3. Who Can Use GSM β€” Eligibility​

GSM is designed for entities that extend credit or post-paid services but are not CBN-licensed commercial banks:

  • Microfinance Institutions & OFIs β€” registered under CBN MFB/State Government Lending/OFI licences
  • Digital Lenders & Fintechs β€” FCCPC-registered, operating under the Digital Lending Guidelines
  • Cooperative Societies β€” registered under the Cooperative Societies Act
  • Post-paid Service Providers β€” telcos, e-commerce, utilities, SaaS platforms collecting on deferred billing
DimensionCBN GSICreditChek GSM
Eligible initiatorsCBN-licensed Participating Financial Institutions (PFIs) onlyOFIs, digital lenders (FCCPC-registered), cooperatives, post-paid providers, fintechs
Participation requirementMust execute a GSI Master Agreement with NIBSS; must be connected to Nigeria Central SwitchMust hold an active CreditChek merchant account with approved appId and businessId
Infrastructure dependencyNIBSS NIP platform; Industry Customer Accounts Database (ICAD)CreditChek RADAR API; CreditChek RecovaPRO API
Commercial banksβœ… Eligibleβœ… Eligible (as merchants) but GSI is the preferred regulatory channel
Fintechs / digital lenders❌ Not eligibleβœ… Primary target audience
Cooperatives❌ Not eligibleβœ… Eligible
Post-paid service providers❌ Not eligibleβœ… Eligible

Prerequisites before integrating GSM:

  • Active CreditChek merchant account with approved appId (go-live) and businessId
  • FCCPC registration or applicable operating licence
  • A compliant loan origination process with explicit borrower consent captured (written/digital)
  • Integration with CreditChek Spectrum for credit bureau reporting (mandatory β€” see Step 4)

3.1 When It Is Triggered β€” Pre-Default vs Post-Default​

This is arguably the most fundamental distinction between the two systems.

DimensionCBN GSICreditChek GSM
Trigger pointAfter default β€” borrower has already failed to repay per loan terms and classified per CBN Prudential GuidelinesBefore default β€” scheduled, pre-agreed repayment automation from day one of the loan
Nature of useExplicitly a "last resort" recovery mechanismA primary repayment collection infrastructure
Borrower notificationCollection happens "without recourse to the Borrower"Payer is actively informed and consented at every collection event
Loan status at triggerNon-performing; classified under CBN Prudential GuidelinesPerforming; active loan in good standing
Relationship to NPLTriggered because NPL existsDesigned to prevent NPL by automating timely repayments

CBN's own language on trigger intent:

"The GSI shall serve as a last resort by a Creditor bank, without recourse to the Borrower, to recover past due obligations... from a defaulting Borrower through a direct set-off."

Implication: GSI is a debt recovery instrument. GSM is a repayment facilitation instrument. A merchant should be running GSM throughout the healthy life of a loan, not as a response to default.

CBN's own language on consent:

"(a) Execute a GSI mandate in hard copy or digital form. (b) Ensure that the terms and conditions of the mandate are clearly understood before execution."

Important nuance: Both systems require a mandate to be executed. However, in GSI, once that mandate is signed, the CBN-empowered sweep can happen entirely without the borrower's knowledge or participation when default occurs. In CreditChek's GSM, the payer's active, consented participation is required at account discovery, mandate placement, and micro-deposit confirmation β€” and the payer decides which accounts are enrolled.


DimensionCBN GSICreditChek GSM
Consent natureMandate executed once at loan origination; subsequent GSI triggers require no further borrower involvementExplicit, active, per-account consent required from the payer at each mandate placement
Account selectionNIBSS sweeps all qualifying accounts automatically via ICAD β€” borrower has no say in which accounts are hitPayer chooses their Primary Account and opts in to each Backup Account individually
Real-time involvementBorrower is not involved at point of GSI triggerPayer confirms each enrolled account via micro-deposit verification
Consent revocabilityGoverned by the executed GSI mandate instrumentPayer may request mandate cancellation (subject to outstanding obligations); merchant must honour
Consent documentationHard copy or digital GSI mandate; stored by Creditor Bank and retrievable on demandDigital consent with timestamp, IP, payer ID; merchant's responsibility to retain

CBN's own language on consent:

"(a) Execute a GSI mandate in hard copy or digital form. (b) Ensure that the terms and conditions of the mandate are clearly understood before execution."

Important nuance: Both systems require a mandate to be executed. However, in GSI, once that mandate is signed, the CBN-empowered sweep can happen entirely without the borrower's knowledge or participation when default occurs. In GSM, the payer's active participation is required at account discovery, mandate placement, and micro-deposit confirmation β€” and the payer decides which accounts are enrolled.


4. Architecture & Flow​

The GSM integration follows a strict sequential flow. Do not skip or reorder steps.

β”Œβ”€β”€β”€β”€β”€β”€β”€β”€β”€β”€β”€β”€β”€β”€β”€β”€β”€β”€β”€β”€β”€β”€β”€β”€β”€β”€β”€β”€β”€β”€β”€β”€β”€β”€β”€β”€β”€β”€β”€β”€β”€β”€β”€β”€β”€β”€β”€β”€β”€β”€β”€β”€β”€β”€β”€β”€β”€β”€β”€β”€β”€β”€β”€β”€β”€β”€β”€β”€β”€β”
β”‚ PAYER ONBOARDING β”‚
β”‚ β”‚
β”‚ 1. Merchant captures BVN + consent from payer at loan origination β”‚
β”‚ 2. RADAR Lookup β†’ discover all BVN-linked bank accounts β”‚
β”‚ 3. Payer selects Primary Account + Backup Accounts β”‚
β”‚ 4. RecovaPRO β†’ loop micro-deposit (₦50) on each account β”‚
β”‚ 5. Accounts confirmed β†’ e-mandates activated β”‚
β””β”€β”€β”€β”€β”€β”€β”€β”€β”€β”€β”€β”€β”€β”€β”€β”€β”€β”€β”€β”€β”€β”€β”€β”€β”€β”€β”€β”¬β”€β”€β”€β”€β”€β”€β”€β”€β”€β”€β”€β”€β”€β”€β”€β”€β”€β”€β”€β”€β”€β”€β”€β”€β”€β”€β”€β”€β”€β”€β”€β”€β”€β”€β”€β”€β”€β”€β”€β”€β”€β”˜
β”‚
β”Œβ”€β”€β”€β”€β”€β”€β”€β”€β”€β”€β”€β”€β”€β”€β”€β”€β”€β”€β”€β”€β”€β”€β”€β”€β”€β”€β”€β–Όβ”€β”€β”€β”€β”€β”€β”€β”€β”€β”€β”€β”€β”€β”€β”€β”€β”€β”€β”€β”€β”€β”€β”€β”€β”€β”€β”€β”€β”€β”€β”€β”€β”€β”€β”€β”€β”€β”€β”€β”€β”€β”
β”‚ DISBURSEMENT GATE β”‚
β”‚ β”‚
β”‚ 6. Spectrum β†’ report loan approval + disbursement to credit bureau β”‚
β”‚ ⚠️ Automated collection is BLOCKED until disbursement is β”‚
β”‚ confirmed reported to bureau via Spectrum β”‚
β””β”€β”€β”€β”€β”€β”€β”€β”€β”€β”€β”€β”€β”€β”€β”€β”€β”€β”€β”€β”€β”€β”€β”€β”€β”€β”€β”€β”¬β”€β”€β”€β”€β”€β”€β”€β”€β”€β”€β”€β”€β”€β”€β”€β”€β”€β”€β”€β”€β”€β”€β”€β”€β”€β”€β”€β”€β”€β”€β”€β”€β”€β”€β”€β”€β”€β”€β”€β”€β”€β”˜
β”‚
β”Œβ”€β”€β”€β”€β”€β”€β”€β”€β”€β”€β”€β”€β”€β”€β”€β”€β”€β”€β”€β”€β”€β”€β”€β”€β”€β”€β”€β–Όβ”€β”€β”€β”€β”€β”€β”€β”€β”€β”€β”€β”€β”€β”€β”€β”€β”€β”€β”€β”€β”€β”€β”€β”€β”€β”€β”€β”€β”€β”€β”€β”€β”€β”€β”€β”€β”€β”€β”€β”€β”€β”
β”‚ REPAYMENT LIFECYCLE β”‚
β”‚ β”‚
β”‚ 7. On each instalment due date β†’ debit Primary Account β”‚
β”‚ 8. If Primary fails β†’ cascade through Backup Account array β”‚
β”‚ 9. Spectrum β†’ report each payment event (success / missed /partially paidβ”‚
β”‚ 10. Loan reaches term β†’ Spectrum closes loan record with Credit Reference Bureauβ”‚
β””β”€β”€β”€β”€β”€β”€β”€β”€β”€β”€β”€β”€β”€β”€β”€β”€β”€β”€β”€β”€β”€β”€β”€β”€β”€β”€β”€β”€β”€β”€β”€β”€β”€β”€β”€β”€β”€β”€β”€β”€β”€β”€β”€β”€β”€β”€β”€β”€β”€β”€β”€β”€β”€β”€β”€β”€β”€β”€β”€β”€β”€β”€β”€β”€β”€β”€β”€β”€β”€β”˜

5. Step 1 β€” Bank Account Discovery (RADAR BVN Lookup)​

Service: CreditChek RADAR Purpose: Discover all active bank accounts linked to the payer's BVN across Nigerian financial institutions.

Endpoint​

POST: https://api.creditchek.africa/v1/radar/

Request Parameters​

ParameterPositionRequiredDescription
bvnbodyβœ… YesPayer's Bank Verification Number
tokenAuthorizationβœ… Yesapp secret key
typebodyβœ… Yesto contain the bvn in JSON format

Headers:

Authorization: Bearer <token>
Content-Type: application/json

Full documentation: https://docs.creditchek.africa/nigeria/radar/getRadar

Implementation Notes​

  • Present discovered accounts to the payer. The payer must actively select their Primary Account and opt-in to any Backup Accounts. Do not pre-select on their behalf.
  • Store the payer's selection before proceeding to Step 2.
  • RecommendationUndiscovered or inactive accounts should be excluded from the mandate setup(can be added as Tooltip to the users).

Payer Account Selection Model​

{
"primaryAccount": {
"accountNumber": "0088741090",
"bankCode": "044"
},
"backupAccounts": [
{ "accountNumber": "2034556781", "bankCode": "058" },
{ "accountNumber": "0112334456", "bankCode": "033" }
]
}

6. Step 2 β€” Set Mandate (Place e-Mandate on Accounts)​

Service: CreditChek RecovaPRO β€” Initialize e-mandate with the payer Purpose: Register an e-mandate against each of the payer's selected bank accounts. Each account requires a separate API call using the same mandateId, email, and BVN combination.

Endpoint​

POST https://api.creditchek.africa/v1/recova/recova/consent/create

Full documentation: https://docs.creditchek.africa/nigeria/recovaPro/api.md/initiateConsent

Looping Across All Discovered Accounts​

Call this endpoint once per account β€” for the primary account and each backup account β€” using the identical mandateId + email + BVN combination. CreditChek uses this triplet to link all mandates to the same loan arrangement.

// Pseudocode β€” Loop through all payer-selected accounts
const allAccounts = [primaryAccount, ...backupAccounts];

for (const account of allAccounts) {
await placeMandateAPI({
appId: "630c8be89131cd442344e794",
businessId: "630c8be89131cd442344e790",
email: payerEmail,
mandateId: mandateId,
accountNumber: account.accountNumber,
bankCode: account.bankCode,
address: payerAddress,
mobileNumber: payerPhone
});
}

Sample request account_number: 12345678901 and 09876543212

Contact [email protected] if you encounter any error responses at this stage.

Key Rule: The combination of email + BVN + mandateId must be identical across all mandate placement calls for the same loan. This uniquely ties all accounts to one loan event and prevents duplicate mandate conflicts.


7. Step 3 β€” Micro-Deposit Verification Loop​

Purpose: Verify that each enrolled bank account is valid, active, and capable of processing credit and debits by sending a strict ₦50 micro-deposit from each selected account to the displayed account details from the platform. The NIBSS NDD(Direct Debit) platform confirms (or rejects) each deposit to forward the activate request of the mandate to the payer's bank.

How It Works​

  1. PAYER initiates a ₦50 micro-deposit from each selected bank account submitted in Step 2
  2. The payer's bank either honours or rejects the deposit confirmation auto-relayed message from NIBSS NDD.
  3. Honoured accounts have their mandate status set to active
  4. Rejected accounts are marked failed β€” the merchant should notify the payer and optionally prompt re-selection

Micro-Deposit Status Outcomes​

OutcomeMandate StatusAction Required
Deposit accepted by bankactiveAccount ready for collection
Deposit rejected / account inactivefailedNotify payer; prompt re-selection
Payer disputes depositdisputedEscalate through RecovaPRO dispute flow
No response within TTLpending_timeoutNotify payer; prompt re-selection

Mandate Priority Logic​

The collection engine follows this priority during automated repayment:

1. Attempt PRIMARY account debit
2. If PRIMARY fails β†’ attempt BACKUP account [0]
3. If BACKUP [0] fails β†’ attempt BACKUP account [1]
4. Continue through backup array in sequence
5. If ALL accounts fail β†’ trigger missed repayment event β†’ report to Spectrum

Note: A minimum of one active mandate (primary) is required before disbursement is permitted. Backup accounts are strongly recommended to maximise collection success rates.


8. Step 4 β€” Spectrum Credit Bureau Reporting (Mandatory)​

Service: CreditChek Spectrum This step is not optional. Automated collection via RecovaPRO will not be honoured for any mandate unless the associated loan upon disbursement has been reported to the credit bureau through CreditChek's Spectrum.

Why This Is Required​

Under the FCCPC Act 2018 and Nigeria's digital lending guidelines, a merchant cannot initiate automated debt collection unless there is verifiable, auditable proof that:

  1. A loan was approved and the approval reported to a Credit Reference Bureau
  2. Disbursement was completed and confirmed on record
  3. The borrower received the funds they are being collected against

CreditChek, as the mandate infrastructure provider, is not the payment disbursement channel. Spectrum acts as the integration layer that links proof-of-disbursement to the active mandate β€” creating the legal and regulatory basis for each collection attempt.

Spectrum Reporting Events​

You must report all of the following lifecycle events via Spectrum:

EventWhen to ReportDescription
loan.approvedAt credit decisionLoan offer terms, approved amount, tenure
loan.disbursedAt fund transfer completionDisbursed amount, disbursement date, reference
repayment.successfulAfter each successful debitAmount, date, outstanding balance
repayment.missedAfter collection failure on due dateDue amount, failure reason, new outstanding
loan.restructuredIf terms changeNew schedule, reason for restructure
loan.closedAt full repayment or write-offFinal status, close date

Disbursement Gate​

[ Mandate Active ] ──► [ Spectrum: loan.disbursed reported ] ──► [ Collection ENABLED ]
β”‚
β–Ό
β›” If loan.disbursed NOT reported ──► Collection BLOCKED

CreditChek will suppress collection attempts on any mandate where loan.disbursed has not been confirmed via Spectrum. This protects both the merchant and the borrower, and indemnifies CreditChek from liability for collections on unfunded obligations.

Benefits of Spectrum Integration​

  • Legal indemnification β€” establishes that collection is against a real, funded obligation
  • Statutory compliance β€” meets CBN and FCCPC credit reporting obligations
  • NPL intelligence β€” real-time non-performing loan flag across your portfolio
  • Bureau score impact β€” timely positive/negative reporting improves bureau accuracy for all parties
  • Audit trail β€” every mandate action is traceable to a bureau-reported loan event

9. Step 5 β€” Automated Collection​

Once mandates are active and Spectrum confirms disbursement, RecovaPRO's collection engine handles scheduled debits automatically.

Collection Behaviour​

  • Debits are initiated on the scheduled repayment dates defined at mandate creation
  • The primary account is attempted first; backup accounts are cascaded through in order
  • All collection events (success, failure, partial) are automatically fed back to Spectrum for bureau reporting
  • The merchant receives webhook notifications for every collection event and daily collection summary (digest) email

Webhook Events​

Register a webhook URL in your CreditChek dashboard to receive real-time notifications:

EventDescription
mandate.activatede-mandate successfully verified and active
mandate.failedMicro-deposit rejected; mandate not established or Mandate not approved
collection.successRepayment collected successfully
collection.failedAll accounts exhausted; repayment missed
collection.partialPartial amount collected (insufficient funds)
mandate.expiredMandate has reached end of loan tenure

Sample Webhook Payload β€” Collection Success​

{
"businessId": "65c23585353059",
"consentId": "68e505b6c0570b",
"mandateId": "68e4156dc6f60",
"accountName": "LEADSAUTO CENTER NIG LTD",
"accountNumber": "2063293726",
"bankName": "Access Bank",
"totalAmount": 2033626.28,
"providerMessage": "Account debited successfully.",
"amountCollected": 610087.88,
"status": "success",
"collectedOn": "2025-11-06T02:07:46.195Z",
"collectionType": "auto",
"instalmentReference": "4a3b4a76-f897-483c-aca1-d8db30d86efa",
"instalmentStatus": "success",
"reference": "1762394845143",
}

Sample Webhook Payload β€” Collection On Overdue​

{
"businessId": "65c23585353059",
"consentId": "68e505b6c0570b",
"mandateId": "68e4156dc6f60",
"accountName": "LEADSAUTO CENTER NIG LTD",
"accountNumber": "2063293726",
"bankName": "Access Bank",
"totalAmount": 2033626.28,
"providerMessage": "Account debited successfully.",
"amountCollected": 610087.88,
"status": "success",
"collectedOn": "2025-11-06T02:07:46.195Z",
"collectionType": "auto",
"instalmentReference": "4a3b4a76-f897-483c-aca1-d8db30d86efa",
"instalmentStatus": "overdue",
"reference": "1762394845143",
}

Sample Webhook Payload β€” Collection Failed​

{
"businessId": "65c23585353059",
"consentId": "68e505b6c0570b",
"mandateId": "68e4156dc6f60",
"accountName": "LEADSAUTO CENTER NIG LTD",
"accountNumber": "2063293726",
"bankName": "Access Bank",
"totalAmount": 2033626.28,
"providerMessage": "Account debited successfully.",
"amountCollected": 610087.88,
"status": "success",
"collectedOn": "2025-11-06T02:07:46.195Z",
"collectionType": "auto",
"instalmentReference": "4a3b4a76-f897-483c-aca1-d8db30d86efa",
"instalmentStatus": "failed",
"reference": "1762394845143",
}

Sample Webhook Payload β€” Collection Partial Paid​

{
"businessId": "65c23585353059",
"consentId": "68e505b6c0570b",
"mandateId": "68e4156dc6f60",
"accountName": "LEADSAUTO CENTER NIG LTD",
"accountNumber": "2063293726",
"bankName": "Access Bank",
"totalAmount": 2033626.28,
"providerMessage": "Account debited successfully.",
"amountCollected": 610087.88,
"status": "success",
"collectedOn": "2025-11-06T02:07:46.195Z",
"collectionType": "auto",
"instalmentReference": "4a3b4a76-f897-483c-aca1-d8db30d86efa",
"instalmentStatus": "partially paid",
"reference": "1762394845143",
}

Sample Webhook Payload β€” Collection Processing​

{
"businessId": "65c23585353059",
"consentId": "68e505b6c0570b",
"mandateId": "68e4156dc6f60",
"accountName": "LEADSAUTO CENTER NIG LTD",
"accountNumber": "2063293726",
"bankName": "Access Bank",
"totalAmount": 2033626.28,
"providerMessage": "Account debited successfully.",
"amountCollected": 610087.88,
"status": "success",
"collectedOn": "2025-11-06T02:07:46.195Z",
"collectionType": "auto",
"instalmentReference": "4a3b4a76-f897-483c-aca1-d8db30d86efa",
"instalmentStatus": "processing",
"reference": "1762394845143",
}

The Federal Competition and Consumer Protection Commission (FCCPC) Act 2018 governs all consumer-facing financial and credit services in Nigeria. CreditChek's GSM is designed to be fully compliant. The following obligations fall on the merchant:

At loan origination, before any RADAR lookup or mandate placement, you must capture and store verifiable consent from the payer for:

  • Use of their BVN to discover linked bank accounts
  • Placement of e-mandates on each selected bank account
  • Automated debit on repayment due dates
  • Reporting of their loan data to a licensed Credit Reference Bureau
  • Cascading debit to backup accounts if primary account fails

Consent must be:

  • Explicit β€” affirmative action (tick-box, OTP confirmation, digital signature and verifiable personalInfo)
  • Informed β€” payer must understand what they are consenting to in plain language
  • Auditable β€” stored with timestamp, IP address, and payer identifier
  • Revocable β€” payer must be able to request mandate cancellation (subject to outstanding obligations)

FCCPC Prohibited Practices (Merchant Obligations)​

PracticeStatus
Initiating collection without proof of disbursement❌ Prohibited
Collecting amounts exceeding approved loan terms❌ Prohibited
Placing mandates without explicit payer consent❌ Prohibited
Failing to report loan lifecycle to credit bureau❌ Prohibited
Presenting GSM as CBN/NIBSS GSI to borrowers❌ Prohibited
Collecting after borrower has filed valid dispute❌ Prohibited β€” pause pending resolution
Retaining mandate after full loan repayment❌ Prohibited

What CreditChek GSM Is​

  • βœ… A consent-based, merchant-operated, BVN-anchored multi-account direct debit system
  • βœ… A private infrastructure service built by CreditChek for eligible non-bank lenders
  • βœ… Designed as an empowerment tool for businesses to complement the regulated GSI system outside the commercial banking sector
  • βœ… Fully auditable with end-to-end bureau reporting via Spectrum

What GSM Is Not​

  • ❌ Not the CBN/NIBSS Global Standing Instruction (GSI) system
  • ❌ Not a regulatory mandate β€” it is a contract-based arrangement between merchant and payer
  • ❌ Not available to entities without a valid CreditChek merchant account and applicable operating licence
  • ❌ Not a substitute for FCCPC compliance or applicable state/federal lending regulations
  • ❌ Not a payment gateway β€” CreditChek does not hold, move, or settle funds directly

Technical Limits​

ParameterLimit
Maximum backup accounts per mandatePlatform limit β€” NONE
Micro-deposit amount₦50 per account (fixed)
Mandate validityTied to loan tenure defined at mandate creation
Retry attempts per due dateConfigurable per merchant agreement
API rate limitsRefer to CreditChek developer portal

Liability & Indemnification​

  • CreditChek bears no liability for collections on mandates where loan.disbursed has not been reported via Spectrum
  • Merchants bear full responsibility for consent validity, FCCPC compliance, and accuracy of loan data reported to bureaus
  • CreditChek's indemnification of the merchant is contingent on correct use of Spectrum for end-to-end bureau reporting
  • Misuse of the GSM system β€” including misrepresenting it as CBN-regulated β€” may result in immediate account suspension and regulatory referral

12. Glossary​

TermDefinition
BVNBank Verification Number β€” a unique CBN-issued identifier tied to an individual across all Nigerian bank accounts
GSIGlobal Standing Instruction β€” CBN/NIBSS-regulated system for commercial banks to sweep accounts for NPL recovery
GSMGlobal Standing Mandate β€” CreditChek's consent-based multi-bank direct debit framework for non-bank lenders
RADARCreditChek's BVN account discovery service that returns all active accounts linked to a BVN
RecovaPROCreditChek's e-mandate placement and automated collection service
SpectrumCreditChek's credit bureau reporting service; mandatory for GSM collection to be activated
Micro-depositA ₦50 test credit sent to verify an account is active and capable of transacting
Primary AccountThe payer's preferred account for first-attempt repayment collection
Backup AccountsAdditional payer-consented accounts debited in sequence if the primary account fails
MandateA formal, consent-backed authorisation for a merchant to debit a borrower's bank account
NPLNon-Performing Loan β€” a loan where scheduled repayments have been missed beyond a defined threshold
FCCPCFederal Competition and Consumer Protection Commission β€” Nigeria's consumer rights and fair market practices regulator
OFIOther Financial Institution β€” financial entities regulated by the CBN but not licensed as commercial banks