Investment reconciliation for fund managers: T-bills, CSCS and custodian statements

A fund manager reconciles four things every month: holdings against the custodian and CSCS statements, cash against the bank, accruals against each instrument's terms, and client money against the client ledger. When they disagree, the cause is rarely dramatic. A T-bill matured but is still in the register. A bonus issue was credited at CSCS and never booked. A coupon was accrued at the wrong rate for three months.

What to reconcile, and where it breaks

T-bills and matured bills

The CBN auctions Nigerian Treasury Bills in 91-day, 182-day and 364-day tenors; at the 9 September 2026 auction the 364-day stop rate was 16.62%, according to Nairametrics.

T-bill holdings are recorded with the CBN's depository or CSCS through your bank or custodian, so reconcile the custodian statement to your T-bill ledger, line by line. The register should show each bill's face value, purchase price, issue date and maturity date.

The most common break is a matured bill still in the register. Example figures: a 91-day bill bought on 10 July matures on 9 October. The proceeds reach the bank and are posted to cash, but nobody removes the bill. At month-end the fund counts the money twice. A line-by-line reconciliation catches it the same month; a total-only check may not.

Equities and bonds against CSCS

CSCS (Central Securities Clearing System Plc) is Nigeria's central securities depository for equities, treasury bills, bonds, commodities and funds, according to its own website. Equity holdings should agree to the CSCS or custodian statement by security and quantity.

Corporate actions cause most breaks. Bonus issues and splits change the quantity but bring no cash, so they are easy to miss. Rights issues bring a decision, a payment and a deadline. Dividends should be matched to the holding at the qualification date, and unclaimed ones recorded. For bonds, check each coupon against the rate, the nominal held and the payment date.

Accruals

Recompute each accrual from the instrument's terms every month instead of rolling last month's figure forward.

Example figures: a ₦50m face value 182-day T-bill bought for ₦46.4m carries a ₦3.6m discount. On a straight-line basis for simplicity, that is about ₦19,780 a day, so after 40 days accrued income should be about ₦791,209. Your policy may use the effective interest method instead. Either way, the ledger should agree with a fresh calculation.

Where withholding tax is deducted from interest, the rate under the Deduction of Tax at Source (Withholding) Regulations 2024 is 10%, according to PwC Tax Summaries (checked November 2026). Match each net receipt to its gross amount and keep the WHT receipt as evidence of the credit. Confirm the rules that apply to you with your tax adviser.

Client money and trades

Client money is reconciled separately from the firm's own funds. The total of individual client balances should equal the money held for clients at the custodian, trustee or bank, with any surplus or shortfall explained. A debit balance on a client usually means one client's money has been used for another, so report those separately rather than netting them.

For trades, agree each contract note to the broker or custodian record and the cash movement, separate trade date from settlement date, and keep a short aged list of failed or pending trades with an owner.

Controls and ICFR

If your company is public, the SEC's guidance on Sections 60 to 63 of the Investments and Securities Act 2007 requires the CEO and CFO to certify, the board to report on ICFR, and the external auditor to report on internal controls. The FRC has its own guidance for Public Interest Entities; see ICFR in Nigeria. For an investment business, the key controls are independent reconciliation to the custodian, review of accruals, segregation between dealing and settlement, and client money reconciliation.

How Brillrec helps

Brillrec is the finance operations platform for Nigerian businesses, with three products: Reconciliation, Internal Control Automation and Financial Close Management. Investments, client money and other currencies are on Professional and above (₦350,000 a month plus VAT). See pricing.

Investments (Reconciliation) - Holdings are checked against custodian and CSCS statements by security and quantity. - Treasury bills are matched by maturity date, with face and amortised value checked, and bills matured but still held are flagged. - Unit changes that look like a bonus, split or consolidation are flagged. - Trades are compared with broker or custodian records. - Valuation statements, uploaded or emailed in, are checked: holdings plus cash must equal the portfolio value. - The Cash tab looks for each trade's net amount and each matured T-bill's proceeds in your bank reconciliations, and shows whether each was found, differs or is missing.

Client money - Client balances are matched per client against the custodian, trustee or bank. - The safeguarding statement shows the requirement, resources held and any surplus or shortfall, with debit balances separate, and exports as PDF or CSV.

Statements and currencies. Bank statements are read as PDF, Excel or CSV in the bank's own layout, with the running balance checked. Dollar and other currency accounts are reconciled in their own currency, never converted, using rates you enter.

Controls and evidence (Internal Control Automation, Professional and above) - ICFR testing and certification: risks mapped to controls, key controls tested on items Brillrec selects, deficiencies tracked, and certification by owners, then the CFO, then the CEO, with a management assessment report for auditors, the FRC and SEC Nigeria. Brillrec records the process. The company and its auditors decide the conclusions. - An unclaimed items register for unclaimed dividends, refunds and dormant balances, tracking the deadlines your institution sets. - A control evidence pack and read-only guest auditors, with everything they open logged.

Close. Financial Close Management includes a fund manager month-end and SEC returns template on every plan. Brillrec also suggests follow-up tasks from what reconciliation finds, such as T-bills maturing soon, for you to accept or dismiss.

Own sign-in address. On Professional and above your team can sign in at your own address (yourcompany.brillrec.com), and an admin can allow sign-in only there.

Reported by clients: 99% of clients' bank and ledger lines matched automatically in a month (bank reconciliation), and 50% less audit preparation time. Results depend on your records and how your team works. See client results.

Frequently asked questions

How do fund managers reconcile T-bills?

Reconcile the T-bill ledger line by line to the custodian statement each month, checking face value, purchase price and maturity, and remove matured bills when the proceeds arrive.

How should T-bill accruals be checked?

Recompute each accrual from the purchase price, face value and tenor every month, using your accounting policy's method, and compare it with the ledger.

Which Brillrec plan covers investments and client money?

Professional and above. The 14-day trial includes every Professional feature, so you can test it on last month's custodian statement.

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