What Nigerian banks should become

Ciuci Consulting

July 2010

Contents

3 Background

5 Customer segmentation – “who truly are my customers?”

7 Corporate governance – “how do we get it right?”

9 Risk management – “openness is key”

12 Operationalefficiency – “how can we get it right?”

18 Afinalword

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Background

The Nigerian banking industry recently experienced the greatest shakeup since the consolidation exercise of 2005 with the central banks’ announcement of key reforms aimed at promoting growth and sustainability within the sector. After the fallout of the audit carried out by the apex body in mid 2009, the reforms, which include: bank categorisation and the introduction of tenure limits for CEOs and directors, are poised to significantly alter the structure of the industry and usher in a new phase of banking in the country. Only institutions with clear corporate strategies, strict adherence to corporate governance practices and efficient opera-tions will survive this evolution.

By examining some of the recent reforms/actions initiated by the CBN and their im-pact on the industry, it becomes clear that banks have no other option but to rethink their strategies and clearly articulate why they are in business.

Table 1: Key actions initiated by the CBN Governor – Sanusi Lamido

S/N Reforms/Actions Details Impact on the banks

1 CBN Audit · Discovery of significant liquidityshortages in certain banks leading to the injection of over ₦620 billion into the affected banks.

· The sacking of eight MDs of the affected banks

· Affected banks lost their market share.

· Change in the rankings in the industry.

2 CEO tenure limits · Maximum duration for CEO tenures pegged at ten years, causing some of the chief executives to leave earlier than they had anticipated.

· Adequate succession planning has become critical.

· Change in strategies and a true test of sustainability for banks that suffer from the key man syndrome.1

3 Bank Categorisation · Categorisation of banks by type with different banks having different capital requirements.

· It will become imperative for banks to develop sound corporate strategies.

· A shift from universal banking to spe-cialized and more focused banking.

1 the tendency for one man, usually the CEO to solely dominate the decision making process of the bank

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In the processes of rethinking strategies and articulating growth plans, four factors should be considered;

The above mentioned factors can be broadly categorised under the following sub headings:• Segmentation Strategy – as a fallout of the corporate strategy of the bank• Corporate Governance – as an internal regulatory mechanism• Operational Efficiency – as a winning strategy

Figure 2: The Winning Formula

Defining the objectives of all stakeholders i.e. why is the bank in business and on what basis did it choose to serve the segment it selected?

How well positioned is the bank to meet its target segment?

The goals of the regulatory agencies, their expectation of the banks and the likeli-hood for them to change their objectives.

· Low level of economic development in Nigeria.

· Lack of adequate skill in the industry

· Poorly implemented corporate strategies

· High cost of doing business· Unpredictable regulatory

environment.· Poor corporate governance

practicesWhat are competitors doing differently; what is the bank’s market share?

Segmentation Strategy

· Market Analysis· Customer Segmentation · Product Development

Corporate Governance

· Transparency · Risk Management · Compliance

Operational Efficiency

· Human Capital Management· Business Processes

Management · Customer Service

Market realitiesConsiderations

Considerations

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Customer segmentation – “Who truly are my customers?”

The fundamental objective of segmentation is to identify the customer groups with similar needs and organize an institution in a way that it easily meets the needs of the same customers. Banks therefore, like other broad service offering institutions must be able to clearly segment their customers and develop specific strategies to attract and retain them. In the recent past, Nigerian banks were known to deploy resources to target all customer segments with the objective of growing accounts and deposit volumes. This resulted in banks having a large pool of customers with little or no knowledge of who their core customers were. Bank categorisation indirectly ad-dresses segmentation as by law, banks are compelled to define their focus by select-ing and focusing on a niche segment within the market. The categorisation process involves banks streamlining their operations to suit these chosen market segments, thereby causing an adjustment within the industry that will lead to specialised banking. Banks should bear in mind that like babies that are provided with bright coloured toys because of their natural attraction to bright colours, banking customer groups with unique needs should be provided with products and services that are customised for them. Customisation here also means that even the aesthetics of a branch has to be attractive to the customers being targeted by the bank.

Consequently, banks must conduct segmentation exercises that will enable them define who their customers really are. This way, the financial institutions will cease to become all things to all people but offer products and services to select groups of customers based on the segmentation.

How should segmentation be done?

By sub dividing the market into discrete customer groups that share similar char-acteristics, segmentation allows organisations effectively identify customer needs within the individual segments. Banks that identify underserved segments can proceed to outdo the competition by developing uniquely appealing products and services. Customer segmentation is most effective when banks tailor their products to segments that are most profitable and serve them with their distinct competitive advantages. This prioritization can help in developing marketing campaigns and pricing strategies to extract maximum value from both high and low profit custom-ers. A bank can use customer segmentation as the principal basis for allocating resources to product development, marketing, service and delivery programs.

The universal banking system employed in Nigeria afforded banks the liberty of developing broad strategy programs which failed to capture the uniqueness of their operations. Their preoccupation with so called innovative functions eventually led to

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a deviation from core banking operations, which were originally focused on satisfying customer needs. Consequently, a gap was created between customer needs and bank-ing products and services.

Generally, segments in the industry are categorised as either retail or wholesale. The segmentation process requires that these segments are further broken down into smaller sub segments based on specific criteria. Below is an illustration of the process:

Splitting customers into segments enables a more detailed study of the segments. At this point, profitability of the customers and their needs are analysed with the objective of ranking segments in order of value (profitability) and benefit to the organisation. The organisation must also consider its capability, in terms of human and material resources in making its decision on what segment to focus on. Capabil-ity could imply sales and marketing expertise, infrastructure, governance and other competence related issues. Selecting the segment would then be a function of the size of the segment or the value that can be derived from the segment and the capabil-ity of the bank to serve the segment in the immediate and long term. For example, can an investment bank decide to focus on retail banking? Does it have the relevant skills and resources to serve the related customer segment? These are examples of questions that can be asked at this point.

The criteria for determining the category a customer falls into varies from one bank to another. Research has shown that most Nigerian banks do not report their finan-cials by consumer segments, partly because there is no standard method for classify-ing customers. As a result, it is difficult for a bank to track the profitability of each segment and compare itself with its competitors by the same standards.Other questions that should be answered following proper segmentation include:• What are the objectives of the bank?• What are its key capabilities (strengths)?• Who are its most profitable customers (customers that the bank makes more profit

from and not necessarily the ones with the largest account balances)?• What are the market opportunities not captured by the bank and what mechanism

tracks these opportunities consistently?

Table 3: Possible criteria for segmenting the retail market

Examples of Segment

Students

High Net worth

Individuals (HNIs)

Retirees

Military/Civilian

Segmentation Criteria

Income

Turnover

Age

Location

Gender

Lifestyle

Basic considerations in serving segments

Product development

IT & other required Infrastructure

and support

Human capital management

Risk management capabilities

Access to data

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Any bank conducting a segmentation exercise should evaluate its internal custom-ers and leverage market studies to glean insights for determining focus. This could lead the bank to divest from some unprofitable segments and build the channels to support the newly identified segments. The process may eventually lead to a change in the bank’s organizational structure, as well as its marketing and sales strategies. Segmentation will enable a bank position itself rightly for success as the exercise entails a thorough assessment of the bank’s capabilities, a sound evaluation of op-portunities available and the development of a strategic roadmap that shows how the bank can get to serve its customers profitably.

Corporate governance – “How do we get it right?”

The role of corporate governance in management of banks has been the subject of much debate, with stakeholders holding differing opinions on how to institutionalise proper corporate governance within banks. Following the reconsolidation exercise in 2005, the CBN set out to establish a corporate governance code to serve as a frame-work for banks to build their governance systems on. This was done with the objective of mitigating the challenges that came with having bigger banks with greater liabili-ties, improving public confidence in the banking sector and safeguarding shareholder funds. Highlights of the SEC and CBN Corporate Governance Code for banks include:

Despite the noble attempts made by the regulators towards improving the quality of corporate governance, the infamous CBN audit of 2009 revealed significant corpo-rate governance failures in several banks. It was discovered that chief executives of several banks occasionally flouted laws by approving loans without recourse to laid down loan approval processes. They also allocated funds to projects without proper consultation with their boards and other stakeholders. In some cases, boards were found to be complicit in these malpractices as personal interests were put ahead of the interests of stakeholders. Consequently, the issue remains how to ensure that banks adhere to best practices in corporate governance in order to safeguard the investments of shareholders and enhance the value creation process.

Table 4

· Separating the roles of CEO and Chairman

· Improving the quality and performance of board members

· Merit based holding of top management positions against shareholding based system

· Transparency and disclosure in all forms of reporting; financial and non – financial

· Protection of the rights and privileges of all shareholders

· Definition of the role of the audit committee

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Fundamentally, for an institution to ensure quality corporate governance, the pro-moters of the institution must view corporate governance as a priority. By doing so, necessary attention is paid to issues which could ultimately define the company’s existence. The nature of accountability of the managers to the stakeholders is a key factor in determining the quality of governance. Banks must ensure that corporate governance codes, which clearly spell out guidelines for decision making, reporting and compliance, as well as, the responsibilities and limits of executives, offices and employees are developed. Strict adherence to such codes, which must be developed in line with regulatory requirements and international best practices, will ensure that the organisation operates within the confines of globally acceptable governance standards. Agents with the highest responsibility for ensuring corporate governance within banks remain the executive management and the board of directors. As the final authority over the institution, the board of directors must effectively exercise their supervisory function over executives who run the company on a daily basis. Without clearly defining and separating the powers of the board from that of the executives, there is a tendency that a bank may end up with a weak board with no real impact on its activities. For this reason, it is necessary for boards to consist of ‘independent outside directors’ whose interests do not conflict with those of the bank. Studies conducted in the past have shown that companies with boards that have a larger number of independent outside directors tend to act more objectively in the interest of shareholders as against those with directors who are affiliated with the company in some way. As much as the activities of the board may not contribute directly to improved financial performance, its impact on specific issues, which could potentially influence overall performance, is quite significant. Nigerian banks must adopt a pragmatic approach to the selection and appointment of board members for the purpose of improving the quality of corporate governance in their respective organisations.

On the part of the bank executives, CEOs must ensure that they comply with laid down governance codes. A past trend in Nigeria has been one of CEOs controlling the boards by having directors hold shares by proxy. Such counter-productive practices were partly responsible for the recent mishaps in the industry. It is therefore neces-sary for the regulators to outlaw such practices, which undermine the entire system.

Beyond the roles of agents within banks, contemporary practices involve taking an integrated approach towards governance, risk management and compliance. By lev-eraging leadership, risk management and technological resources at their disposal, management can build an extensive governance framework into an institution. The process involves translating risk management, corporate governance and compli-ance practices across business units and processes and using technology to track and measure adherence to such functions. This presupposes that all compliance risks at the business unit and process levels are well defined so that deviations are captured when they occur. A key advantage of this is that the impact of compliance risks on the bank can be appreciated as soon as they happen. Therefore management and employees’ gain better understanding of the business and can work towards making

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improvements to the business and processes. The overall result is the establishment of a governance superstructure that supports the organisations governance objec-tives. Consequently, Nigerian banks need to move with the times in which technol-ogy has become an integral aspect of business and a critical success factor in the modern age. The goal of institutionalising best practices in corporate governance must be pursued from all possible angles.

Finally, three main conclusions can be drawn:• Corporate governance must be given priority status by the promoters of the banks. • Executive management and the board of directors who are primarily responsible

for enthroning corporate governance within banks, must take up the challenge and ensure that corporate governance codes are developed in line with regulatory requirements and best practices are developed and strictly adhered to.

• Adopting an integrated approach to corporate governance, risk management and compliance could be beneficial to banks by promoting a governance culture within the bank.

When top level management demonstrate ethical conduct, abide by generally accepted principles and expect no less from employees, they successfully institute moral values and authenticity as a fundamental aspect of the corporate culture and all employees are more likely to embrace those values.

Risk management – “openness is key”

Weak governance, inappropriate incentive structures and poor risk management systems were among some of the main causes of the collapse of the global financial system. Nigerian banks were not left out as most of them failed to adhere to estab-lished risk management procedures, resulting in massive loan losses. Most banks were highly exposed to the oil and gas sector and were consequently burnt when oil prices crashed. A significant number of banks were also involved in margin lending which arose as a result of the growth of the stock market. CBN’s special audit report indicated that the total deposit liability of the eight affected banks stood at ₦3tril-

lion while aggregate non-performing loans stood at over ₦1.5trillion, representing 61% of industry total. The full disclosure revealed huge losses of unprecedented proportions in the history of Nigerian banking.

Risk management failures are generally attributed to frameworks and technologies adopted by the banks, but are actually largely affected more so by the executives at the helm of affairs. Some banks gave loans to customers who did not meet guidelines as set by the CBN, but based on ‘perceived gains’ from the businesses and the basis

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of relationships. The average non performing ratio for the 24 banks in 2009 stood at 34.4% against the 2008 figures, which stood at 5.6%. This exponential rise only justifies the need to revisit the subject of risk management as a core element of the corporate strategy of any bank.

Risk management is usually tasked with audit and regulatory functions often cen-tered on hedging of certain risks, transferring risks to other participants, controlling of risks that have been taken by the banks, managing insurance policies, reviewing of reports from rating agencies and outsourcing of critical risk analysis.

For a risk management structure to be effective in delivering its benefits, it requires the full involvement and ownership of the executives. This involvement must begin with a genuine determination by the leadership to comply with risk management policies and procedures. They must constantly let their decisions and actions be driv-en by the interest and safety of all stakeholders. It is the duty of the board to take overall responsibility for risk management. Management must then translate the direction set by the board into the strategic development of policies and procedures.

It is also the responsibility of the management to ensure that a climate that encour-ages open communication of risk is maintained in the bank. Departments must be able to cross communicate even when the information negates conventional practice. A well developed risk management policy is useless if it is not clearly communicated and implemented as part of the corporate culture of the bank.

Figure 3: An Integrated Risk Management Approach

Open Communication

Data Driven Decisions

Executive Ownership

Risk Pro active

Effective Risk Management Framework

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Furthermore, the risk information being communicated must be compelling in the data it presents. This will enhance the quality of the decisions made. For immeas-urable risks, qualitative measures can be presented as general guiding principles and qualitative risk measures could be communicated as guidelines. To ensure that risk taking remains within the limits set by management, any material exception to the risk management policies introduction and tolerances should be reported to the board who in turn must initiate appropriate corrective measures.

Risk management as an integral part of corporate strategy

A bank’s ability to measure, monitor and steer risks comprehensively has become a decisive parameter for its strategic positioning. Each bank would have to develop its own risk management processes and internal controls, depending on the nature, size and complexity of the bank’s activities. However there are some basic principles that relate to all financial institutions irrespective of the size and complexity of the bank.

In conclusion, limits and other controls must be respected by top management of any bank if risk management is to be given its rightful place. An effective risk manage-ment office should possess the ability to detect early warning signs and through their already established risk culture, communicate the information to the bank. The risk managers must also be able to keep up with the ever changing needs of the environment in order to have a good understanding of the business and risk associ-ated with each endeavor. The audit function within the risk management framework must remain independent and objective. The banks must be able to support the risk managers with the organisational structure; infrastructure and internal processes to enable them perform their role efficiently.

Figure 4 Figure Source: Ciuci Consulting. *From the Risk Management, Guidelines for Commercial Banks and DFIs, SBP.

Clearly Defined Policies

Clearly defined risk manage-ment policies and procedures covering risk identification, acceptance, measurement, monitoring, reporting and control.

Organization structure

A well constituted organiza-tional structure clearly defining roles and responsibilities of individuals involved in risk tak-ing and management.

Management Information System

An effective management in-formation system that ensures flow of information from opera-tional level to top management and a system to address any exceptions observed.

Constant Review of Policies

A framework that ensures an ongoing review of systems, policies and procedures for risk management to adopt changes.

An Effective Risk Management Framework for Banks*

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Operational efficiency – “How can we get it right?”

The recent global economic downturn has changed the orientation of businesses globally and especially in Nigeria from focusing purely on turnover (volumes) to effi-ciency (business optimisation). Companies must now focus on ensuring that funda-mental business requirements are taken care of before seeking other lofty objectives (which are often derived after the foundation for growth has been well laid). The need for optimizing business processes has become more obvious than ever before. Most Nigerian banks still have rudimentary processes that negatively affect their ability to serve customers given evolving needs and business conditions. This has resulted in most banks having high cost to income ratios in excess of the industry average 58%. In order to address this, banks must review their processes to identify gaps, determine points of failure and subsequently redesign these processes. Opti-mised processes provide multiple benefits to banks, leading to better financial per-formance and an improved reputation. It is pertinent to ensure that skilled persons with the requisite know-how are involved in process design and management as it is the people that play the central role in making systems and processes work.

It is not uncommon to hear customers complain about the quality of service that they receive from their banks. For most, their relationships with account officers are the reasons why they still maintain relationships with their banks. Unfortunately, banks have lost sight of why they are in business. Customers were the premise upon which the practice of banking was founded, for this reason and for the survival of the industry, Nigerian banks need to focus on running efficiently.

After the reconsolidation exercise in 2005, Nigerian banks were awash with funds due to the M&As which produced larger entities and stock offerings which provided capital for investment. They proceeded to expand their operations in line with the regulatory objectives of having bigger and stronger banks, capable of bearing greater risks. In pursuit of these objectives, most banks ignored fundamental issues such as operational efficiency and were consequently caught off guard when the downturn emerged.

Figure 5: Focus on operational efficiency

Focus on operational Efficiency through:

· Human Capital Management

· Business Process Management

· Delivering Customer Service

Revenues

Cost

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Operational efficiency is a function of simplified, standardised and consistently executed business processes across the entire bank. When addressing operational efficiency, three questions must be answered: • How can human capital management be effective?• What is the best way to manage business processes?• What does it take to deliver superior customer service?

Human Capital Management

The human resource question can be answered from two perspectives; capacity build-ing and performance management.

It had been observed in the past that employees were promoted based on their ability to drive deposit volumes and not for their overall performance. This trend led to peo-ple with limited experience in key positions, learning by trial and error in functions which allow for low margins of error. Competence should be developed by specific attempts to build capacity and improve human resource quality.

Capacity building is not a function of training alone as is generally believed. Banks need to understand that people are their most important resource and that factors that determine the performance of any employee can be managed and improved. Employees have personal career goals as banks have corporate goals. Where these two goals meet will determine how far human capital development in any bank will go. For the management of the banks to succeed in capacity building, they need to invest in the personal development of their employees. They need to build the train-ing programmes and initiatives around the work schedules and skill sets required. A well planned training curriculum could help improve knowledge and increase the time for personal development of employees, positively impacting the profitability of the company.

Performance management systems need to be built to down play the deposit driven mentality of the system as a Key Performance Indicator (KPI) and focus on a com-prehensive measurement of all banking required skills that should form part of the personal development goals of the employee. At the beginning of the year, employees should outline their personal objectives and that should form part of their perform-ance assessment.

Additionally, the work environment should also strive to promote learning by en-couraging knowledge sharing and mentorship.

Business Process Management

The second part involves building flexible internal processes that are customised to match the bank’s culture and unique customer demands. Most process related is-sues are caused by simply ignoring obvious fundamental details. Attention to detail begins with re – designing operations by mapping processes and considering areas that are potential pain points and addressing such areas with the required innova-

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tion. Operational errors are costly and difficult for the banks to accurately measure because they do not calculate the cost of serving a customer or a transaction.

From a technology perspective, the challenge is to carve out wholistic system func-tions that enable streamlined business processes. IT solutions need to be integrated with valuable business processes. Banks must overcome internal barriers and articulate an integrated flow of business processes and technologies that is consist-ent with the customers’ demands of the bank. Nigerian banks need to streamline and automate business processes in a cross-functional manner, identify and establish relevant performance indicators that reflect the overall value of their products and services to the bank and most importantly, to the customer.

In managing technology, the banks should follow these two simple rules:

Proper planning

Technology initiatives should not be limited to choosing and deploying IT infrastruc-ture, without an accompanying rationale, context, and support for the workforce. In some instances, banks try to automate flawed processes rather than redesign them according to best practices. Planning begins with the banks accurately articulating their processes and making sure they meet satisfactory standards before requesting for the IT solution. Therefore looking at this from the basics, how is the customer data entry and transaction captured? What are the key performance indicators that will eventually count in checking the performance of the bank at the end of the year as it relates to each customer or transaction?

Proper implementation

To avoid mediocre implementation of IT initiatives, solutions need to be integrated or aligned with the bank’s overall strategy. For instance, if it is a retail bank, it must consider the capability for serving the huge retail market. Therefore, cost-effective alternative service channels like mobile banking and ATM machines must form the core of its strategy.

Customer Service

Satisfying customers should be an issue of utmost importance to all banks. In the past, banks only focused on growing revenue figures regardless of the value of the service they offer to customers. However, some successful banks have now realized that putting customers first helps yield greater results. Banks that adopt a strategic approach towards managing customer satisfaction and make technological invest-ments to support specific objectives are likely to achieve higher rates of customer retention, faster growth and increased profitability. Banks need a combination of customer care and customer service to deliver a pleasant customer experience.

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Service is a vital, multi-dimensional ingredient of the relationship between custom-ers and their bank or more especially, their branch. Word-of-mouth recommen-dations are a valuable source of new business and is often based on the range of services available and delivered. It is therefore an important function for a bank to monitor the quality of service given to customers on a daily basis; to have available an occasional measure of the levels of service available at individual branches. Good service, which is what every customer longs for, could begin with providing a good ambience for transactions and to things even as “seemingly insignificant” as provid-ing ample parking space for customers.

Figure 6: A Sample Customer’s Experience in a Local Nigerian Bank

Customer arrives the bank premises and can’t find parking space.

The Bank’s Role

· Understand the value of different segments of their customers

· Integrate customer service into their overall score card

· Put the right people policies in place to ensure first-class service delivery

· Set the right priorities for investmentin people and technology

· Drive service through innovation· Integrate customer service into the

overall scorecard of employees

The Customer’s Response

· Higher Percentage of Wallet share · Customer Loyalty · Word of mouth recommendation

Customer manages to park, then heads to the entrance and meets a long queue of customers. When it gets to the customer’s turn the door malfunctions.

20 + minutes later, the server is finally up but the account officer who needs to confirm the cheque has gone marketing and cannot be reached on phone due to network problems.

Customer finally gets in and joins the long queue, only for the server to go down at the customer’s turn.

Finally, as the customer is about to get paid, the guard walks in and rudely demands that the customer needs to re-park.

Figure 7: The Pillars of Customer Loyalty

Source: Ciuci Consulting

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Nigerian banks have to pay close attention to customer service processes and consid-er ways to improve them. They need to move quickly with the new trends in technol-ogy that eliminate some of the routine tasks. This will provide employees more time to deal with customers.

In a survey conducted before the recent intervention by the CBN, service was one of the top two important considerations for customers.

Figure 8: Top 3 Factors that would prompt a switch in bank (n=440)

Service

Reliability

Location

Trust

Cost

Convenience

Ease of Transacting

ATM

Knowledge of staff

Product Range

Internet/mobile

Brand perception

Bank Closure

Cultural Affiliations

Look/cleanliness

0 50 100 150 200 250 300

1st choise2nd choise3rd choise

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Figure 9: Reasons for Using Bank for Non- Account Transactions(n= 240)

Service

Reliability

Convenience

Location

Trust

Ease of Transacting

Product Range

Cost

Internet/mobile

Knowledge of staff

ATM

Look/cleanliness

Brand perception

Others

Cultural Affiliations

0 20 40 60 80 100 120 140 160 180

Figure 10: Reasons for Choosing Future Bank(n= 14)

Location

Service

reliability

Trust

Convenience

Cultural Affiliations

Brand perception

Look/cleanliness

0 2 4 6 8 10 12 14

1st choise2nd choise3rd choise

1st choise2nd choise3rd choise

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A final word

Given the changes in the agenda of the regulators, the Nigerian banking landscape will dramatically evolve in the coming months. Evidence of this lies in the CBN’s focus which essentially is designed to improve the quality of banks, restore finan-cial stability, enable a healthy financial sector, and ensure that the financial sector contributes to the real economy. Banks that accept the future for what it is, as laid out by the regulator will be partnering with CBN to work towards achieving these objectives. It is in the interest of CBN that banks are supported in their endeavors, that necessary rules and regulations are designed such that banks can thrive. This means clear communication on all issues in the interest of both international and domestic stakeholders, on required risk capital per activity and balance sheet lever-age ratios, on the requirement of implementation of governance, compliance and risk management policies (not only having a policy on paper). Banks also require active CBN-support when implementing, so that outcomes actually do comply. CBN also has a role in promoting the further development of domestic capital markets at a higher level of sophistication and in different asset categories.

In addition to strategic renewal and operational transformation, implementation of rules and regulations at the banks will come at a cost, however this cost is necessary to come to a more solid, efficient, effective and lasting banking system.

To conclude, discussing the changing landscape and its actors, the banks may want to consider instituting an umbrella organization to take care of non-competitive is-sues, which concern the whole financial sector such as continuing education, interac-tion with law makers and increasingly engaging with international counter parties, to show progress and opportunities in the Nigerian financial sector.

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References

Inam WilsonRegulatory and Institutional Challenges of Corporate Governance In Nigeria Post Banking Consolidation Nigerian Economic Summit Group (NESG) Economic Indicators Vol.12 No. 2 April – June 2006

Code of Corporate Governance for Banks in Nigeria Post Consolidation Central Bank of Nigeria (CBN) 2006

Committee on Corporate Governance Code of Best Practice for Corporate Governance Bank of International Settlements (BIS) September 1999

Anil Shivdasani, Marc Zenner Best Practices in Corporate Governance – What Two Decades of Research Reveals, Salomon Smith BarneyAugust 2002

Charles Teschner, Peter Golder, Thorsten Liebert Bringing Back Best Practices in Risk Management Banks’ Three Lines of Defense Booz&Co, 2008

Russell Walker, Fortune Favours the Well-Prepared Financial Times January 29, 2009

Governance, Risk, Compliance SeriesGlobal Best Practices PricewaterhouseCoopers, 2005

Abimbola Smith, Kingsley AigbeThe Nigerian Banking Sector... What Next? Chapel Hill Denham Analysis January, 2010

MicrosoftBanks Steer Through A Maze Of Customer Interactions: Business Process Management Takes The Wheel http://www.microsoft.com/industry/financialservices/ banking/businessvalue/tgbparticle.mspx 3rd June, 2010

Associate partnerDr. Eelco Fiole

AnalystsCharles IdemEmmanuel TarfaFunmi CarewIfeoma MonyeFola Onasanyaeditorial@ciuci.us