1. ISYAKU BALA TILDE Director, Monitoring Department Securities & Exchange Commission April 2016

2. COMPLAINTS MANAGEMENT FRAMEWORK (CMF) 2 The CMF is aimed at improving the efficiency of complaint management system & aligning it with international best practice. The CMF would enhance market efficiency, reduce cost of conflict resolution as well as build confidence in the capital market. INTRODUCTION  Complains were uncoordinated at the industry level  Some complains often sent to different agencies at the same time  SEC handles the bulk of the complaints in the market EXISTING CHALLENGES

3. COMPLAINTS MANAGEMENT FRAMEWORK – cont’d 3 The SEC rules on Complaint Management was released in February 2015. The rules: Gives more responsibilities to public companies, CMOs, SROs and Trade Groups; Mandates SEC, SROs, Recognised capital market trade groups, CMOs and listed companies to establish policies on complaint management; Requires senior management to endorse the policy and be responsible for its implementation and monitoring; Spelt out the process flow and time lines for resolving complaints in the Capital Market; SEC to concentrate on dealing with major cases of market manipulation, insider trading, accounting frauds and unresolved complaints. KEY ISSUES ADDRESSED BY SEC RULES

4. COMPLAINTS MANAGEMENT FRAMEWORK – cont’d 4  The Commission made consultations with stakeholders (SROs, Trade Groups, CMOs and Public Listed Companies) on the best way to fully implement the framework.  SROs and Trade Groups were directed to sensitize their members and come up with their complaints management policies.  CMOs and Public Listed Companies were also directed to come up with their complaints management policies. WHERE WE ARE Implementation

5. COMPLAINT MANAGEMENT FRAMEWORK – cont’d 5 Harmonized framework of the NSE and ASHON is structured as follows:  Complaints by investors against Dealing members to be managed by the NSE;  Complaints between Dealing members to be managed by ASHON;  NSE and ASHON were directed to notify their members that henceforth Broker/Dealers firms related complaints should be resolved between the brokerage firms and concerned investor(s) within the timeframe. WHERE WE ARE Nigerian Stock Exchange (NSE)/ Association of Stockbroking Houses of Nigeria (ASHON)

6. COMPLAINT MANAGEMENT FRAMEWORK – cont’d 6  The NSE requested for exemption on timeframe for resolving: Complaints relating to transactions spanning up to 7 years or beyond may require more time to enable firms respond to allegations. Complaints that include criminal elements which are referred to the Exchange, these complaints are not likely to be concluded within 20 working days. Appeals against directives/decisions on a complaint may be escalated through the appeal process at the Exchange and is unlikely to be resolved within 20 working days.  The Exchange also requested for an amendment to the Rule to include a provision requiring that investors notify the Exchange of complaints lodged with any Dealing Firms to enable the Exchange track such complaints. WHERE WE ARE Challenges identified by The NSE

7. COMPLIANT MANAGEMENT FRAMEWORK – cont’d 7 WHERE WE ARE Compliance status of other SROs/Trade Groups The SEC received, reviewed and communicated observed deficiencies to the following SROs/trade groups, which have presented their complaints management policies;  FMDQ OTC PLC  Institute of Capital Market Registrars (ICMR)  Association of Issuing Houses of Nigeria (AIHN)  Central Securities Clearing System (CSCS) PLC (being reviewed) The Commission is expecting action from other SROs/trade groups such as;  Fund Managers Association of Nigeria (FMAN)  Association of Asset Custodian of Nigeria (AACN)  Association of Corporate Trustees (ACT)  NASD PLC  Nigeria Commodity Exchange (NCX)  Africa Exchange Holdings (AFEX)

8. COMPLIANT MANAGEMENT FRAMEWORK – cont’d 8 WHERE WE ARE Public Listed Companies The following capital market consultants were notified of CMF;  Capital Market Solicitors Association  Reporting Accountants All Public Listed Companies were directed to come up with their complaints management policies and forward same to the Commission. So far, more than 85% have complied. Capital Market Consultants

9. 9 THANK YOU