The Situation
What They Said
“Those are standard bank charges — it says so in your terms and conditions. There's nothing I can do.”
You notice unexpected deductions from your bank account — SMS notification fees, card maintenance charges, COT fees, or other levies that were never explicitly explained to you at account opening. When you visit the branch or call the customer service line, a representative dismisses your complaint by pointing to the terms and conditions you signed. This situation is extremely common in Nigeria. The CBN has received thousands of consumer complaints about undisclosed or incorrectly applied bank charges. Many Nigerians accept these deductions silently because they believe the bank's terms are unchallengeable, unaware that both federal statute and the CBN's own regulatory framework give them enforceable rights to pre-charge disclosure and full redress.
The Fallacy
Terms and Conditions as Blanket Authorisation
The bank representative is using the existence of a signed terms and conditions document as though it provides unlimited authorisation for any charge the bank chooses to apply. This is legally incorrect. Consumer protection law does not merely require that charges appear somewhere in a document — it requires that specific charges be disclosed clearly and prominently before they are applied. A reference buried in a lengthy document does not constitute meaningful disclosure under the FCCPA. Furthermore, terms and conditions cannot lawfully authorise charges that contradict CBN regulations, which set the approved schedule of bank charges. A T&C clause that purports to authorise an unapproved charge is void regardless of the customer's signature.
What the Law Says
Your Legal Foundation
Federal Competition and Consumer Protection Act 2018
Section 114 — Right to Full Disclosure Before Charges Applied
“A consumer has the right to information about goods and services, including full disclosure of all fees, charges, and levies applicable to any product or service before those charges are applied.”
Section 114 establishes a proactive duty of disclosure — the bank must tell you about charges before applying them, not simply after the fact via a statement entry. A reference to a charge buried in a lengthy terms document that was not highlighted or explained at account opening may not meet the standard of 'full disclosure' that this section requires. The consumer's right to know is not discharged by document volume.
Federal Competition and Consumer Protection Act 2018
Section 129 — Right to Redress
“A consumer who has suffered any loss or damage as a result of the supply of goods or services is entitled to seek redress from the supplier, including a refund, replacement, or repair as may be appropriate in the circumstances.”
Where a charge was applied without adequate prior disclosure, the consumer has suffered a loss within the meaning of Section 129. The bank's obligation is not merely to explain the charge after the fact but to reverse it. 'There is nothing I can do' is not a lawful response to a refund demand grounded in this section.
Central Bank of Nigeria Consumer Protection Framework 2016
Sections 3.1 and 4.2 — Charge Notification and Complaint Resolution
“Financial institutions shall notify consumers of all applicable charges and fees before those charges are applied, and shall establish accessible complaint resolution mechanisms to address consumer grievances within prescribed timelines.”
The CBN Framework creates a regulatory obligation layered on top of the statutory right in FCCPA. Banks are required to have functional complaint channels and to resolve complaints within specified periods. Failure to do so is a regulatory breach reportable directly to the CBN Consumer Protection Department, which has authority to compel refunds and impose sanctions on non-compliant banks.
What Scripture Says
God's Word on This
Proverbs 11:1 (NIV)
“Dishonest scales are detestable to the Lord, but accurate weights find favor with him.”
The ancient principle behind this verse is straightforward: taking from another person more than what was fairly and openly agreed upon is a form of dishonesty, regardless of how the transaction is dressed. A bank charge that was never clearly disclosed before being applied is a weight placed on the scale without the customer's knowledge. The principle of honest, transparent dealing is not just a moral value — it is what consumer protection law is designed to enforce.
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What They'll Say Next
Common Counter-Arguments
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They might say: “You agreed to these terms digitally — you can't claim you didn't know.”
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They might say: “We can only reverse the charge if management approves — that takes 30 days.”
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