Reconciliation for microfinance banks: what CBN examiners and auditors look for

CBN examiners and auditors look for the same things in a microfinance bank's reconciliations: every bank and correspondent account reconciled monthly, signed by a preparer and a different reviewer, open items aged with an owner, suspense and clearing accounts cleared, the core banking system tied to the general ledger, and the evidence attached.

We could not find a CBN circular that sets reconciliation rules specifically for microfinance banks. This is what examiners and auditors typically ask for, so check the circulars for your licence and your examiner's request list.

What examiners and auditors ask for

Core banking to general ledger

The core banking system holds every deposit account and loan; the general ledger holds the summary. Each month, check:

• Customer deposits: total deposit balances in the core banking export against the deposit control accounts.
• Loan book: principal outstanding against the loans control account, with interest receivable and impairment reconciled separately.
• Teller and vault cash: core banking cash balances against cash counts and the GL.
• Inter-branch accounts: for MFBs with several branches, these should net to nil.

Finacle, Temenos T24, Oracle Flexcube and BankOne each export in their own layout, and reformatting them by hand every month is fragile.

Suspense and clearing accounts

Examiners spend time here, because this is where unexplained money sits. Typical accounts are NIP inward and outward clearing, POS clearing, agent cash, unallocated receipts and general suspense.

Each should be matched in and out, item by item, and aged. A long schedule of old items, or a balance with no detail behind it, is a finding.

Example figures: NIP outward clearing shows ₦2,340,000 at 31 October. ₦2,100,000 is three transfers dated 31 October that settled on 1 November. The other ₦240,000 is a failed transfer from 14 August that was never reversed in the ledger. The first is timing; the second is a finding unless it has an owner and an action.

Loan repayments and POS agents

Virtual accounts, one per borrower, reduce unidentified credits but don't remove the reconciliation. Confirm each receipt reached the right borrower and loan, that part and early repayments were treated correctly, and that unmatched receipts sit in unallocated receipts with an owner, not in a borrower's account by guesswork.

If you run a POS agent network, a CBN circular requires monthly agent reports by the 10th of the following month, signed by the MD/CEO and the Chief Compliance Officer, according to Nairametrics (6 October 2025). The figures should agree with your agent float and settlement reconciliations.

Controls and ICFR

The FRC Guidance on the Management Report on ICFR applies to Public Interest Entities for periods ending on or after 31 December 2024, and expressly excludes unit microfinance banks. Other MFBs may be Public Interest Entities, so check your status. See ICFR in Nigeria.

How Brillrec helps

Brillrec is the finance operations platform for Nigerian businesses, with three products: Reconciliation, Internal Control Automation and Financial Close Management. They share one record, so a signed-off reconciliation completes its close task and shows its control as operating, with who did the work and when.

• Statements and exports. Bank statements are read as PDF, Excel or CSV in the bank's own layout, with the running balance checked line by line. Finacle, Temenos T24, Oracle Flexcube and BankOne exports are read using layouts built from their published column names, still to be checked with a real export, so bring one of yours to the trial. NIBSS NIP session reports are matched by session ID. See integrations.
• Clearing, suspense and control accounts (Professional and above). POS clearing, cash in transit, unallocated receipts, suspense and the other clearing kinds are matched or aged and owned, and an account signs off only when it nets to nil or every item is explained. A NIP clearing account can be reconciled this way today, matched by NIP session ID first, then amount and date. See Reconciliation.
• Failed transfers. Failed or timed-out NIP transfers kept with their response code, and a line quoting one marked "Status mismatch, possible loss".
• Collections through virtual accounts (Professional and above). Repayments from Monnify, Paystack, Flutterwave or bank reports are matched to the payer, then to what they owe, as paid, part-paid, overpaid or not paid.
• Agency banking. On Professional and above, an agency banking template that reconciles agent float, agent by agent.
• Sign-off and approvals. Preparer, optional approver, then reviewer. Sign-off can require a reviewer who is not the preparer, and segregation of duties is checked. A preparer's write-offs and matches with a difference go to an approver before they apply. Sign-off locks the reconciliation; reopening needs a reason and is logged.
• Open items. The Exceptions report ages every open item across all accounts in your own age bands, filters by owner, kind or amount, and can be emailed weekly. Items over 30 days are tracked as long-outstanding on every plan.
• Unusual journals (Essential and above). Rules flag self-approval, posting after close, round amounts, quick reversals and more on an imported journal listing. Someone other than the poster reviews each flag. See Internal Control Automation.
• Professional and above. ICFR testing and certification (key controls tested on items Brillrec selects, deficiencies tracked, owners then CFO then CEO certify), the control evidence pack, read-only guest auditors, and an unclaimed items register for stale cheques, dormant and credit balances, with deadlines set by your institution. Brillrec records the process. The company and its auditors decide the conclusions.
• Close. Financial Close Management includes a CBN returns checklist for MFBs, with each statutory date marked "to confirm" until a manager confirms it.
• Sign-in. Two-factor sign-in is required. 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.
• Volume. Business (₦950,000 a month plus VAT) covers 250,000 records a month, 100 bank feeds, SFTP and the API. See pricing.

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

Frequently asked questions

What do CBN examiners look for in an MFB's reconciliations?

Signed, dated reconciliations for every bank and correspondent account, aged open items, cleared suspense and clearing accounts, segregation of duties and attached evidence. Check the circulars that apply to your licence.

Does the FRC ICFR guidance apply to microfinance banks?

It excludes unit microfinance banks. Other MFBs may be Public Interest Entities, so check your status.

How often should an MFB reconcile its suspense account?

At least monthly, item by item, with every open item aged and owned. High-volume clearing accounts are worth reviewing daily; daily reconciliations are on Brillrec's Essential plan and above.

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