Before you take your first client, six structural decisions need to be made and documented.

1. Choose your operating entity. Most practitioners operate either as a sole proprietor (business name registered with CAC) or through a limited liability company (LLC, also CAC-registered). Both are legal; the LLC gives liability protection at the cost of more administration. Lenders, LASRERA, and SCUML all expect to see proper CAC registration before they engage with you.

2. Register with CAC. The Corporate Affairs Commission registration takes 1-2 weeks for a business name, 2-4 weeks for a company. You receive a CAC certificate that becomes the foundation document for every other registration that follows.

3. Register with SCUML. The Special Control Unit Against Money Laundering (under EFCC) requires DNFBPs — including mortgage brokers, real estate agents, and property managers — to register. The registration is free, done through the official SCUML portal, and is a precondition to legal practice. Without SCUML registration, EFCC sanctions become a question of when, not if.

4. Register with LASRERA (if practising in Lagos). The Lagos State Real Estate Regulatory Authority requires individual practitioners and corporate entities to obtain a permit. Categories range from approximately ₦50,000-₦55,000 for marketers/brokers up to ₦1,005,000 for housing estate developers. Permits are valid for one year and must be renewed at least two weeks before expiration. Other states are introducing similar regimes; track developments in your state.

5. Open a separate client account. Mortgage and property transactions involve client money — deposits, fees, escrow holdings. The IMBL Manual of Practice and LASRERA’s corporate requirements both require a dedicated client bank account, separate from your business operating account. Never co-mingle. The client account name must clearly identify it as a trust/client account.

6. Obtain Professional Indemnity Insurance. Not always legally required but always professionally sensible. Covers your firm against negligence claims, errors, omissions. Premium scales with your transaction volumes. Treat this as part of the cost of practice, not as optional.

Client money is sacred. Mishandling it is the fastest career-ending mistake in the profession.

Core rules:

• All deposits, escrow holdings, and fees collected on behalf of clients flow through the dedicated client account
• Your business operating expenses never come out of the client account
• Transfers from client account to business account happen only when fees are legitimately earned (Supreme Court’s “effective cause” principle applies — Lesson 6) and only with documented authority
• Bank statements for the client account are reconciled monthly against your internal records
• Any shortfall, however small, is investigated immediately
• Annual reconciliation is documented and retained for audit

The Practice Manual standard. Section 17 of the IMBL Practice Manual specifies the management of “deemed trust funds” with monthly reconciliation statements, duty to report shortfalls, and annual reconciliation. AMP-certified practitioners should treat these as binding operational rules from day one.

The South African parallel. The PPRA Fidelity Fund Certificate framework (Appendix A6) makes trust-money discipline a precondition for legal practice. The IMBL reform direction is toward a similar regime in Nigeria. Practitioners who set up properly today are ready for tomorrow’s regulatory regime.

A small set of habits, done consistently, keeps you on the right side of every regulator.

KYC at every onboarding (no exceptions). Lesson 6 covers the five customer-relations duties and 14 confidentiality practices. Operationally:

• Capture and verify NIN and BVN at first meeting
• Photo-ID copy retained
• Identify beneficial owners to the 5% threshold for legal-person clients
• Source-of-funds question asked and answered
• Higher-risk clients (PEPs, foreign nationals, complex ownership) flagged for Enhanced Due Diligence with senior approval

AML threshold awareness. Never accept cash above ₦5 million from individuals or ₦10 million from corporates except through a financial institution. International transfers above US$10,000 reportable within one day. Cash transactions above US$1,000 equivalent reportable within 7 days as CBTRs. Suspicious activity becomes an STR to NFIU via the goAML platform within 24 hours.

Documented red flags. Maintain a written list of patterns that trigger additional scrutiny — unusual cash deposits, payment from third parties unrelated to the transaction, rushed timelines without commercial justification, refusal to provide identification, mismatched names on documents. Update the list quarterly based on industry alerts.

Compliance officer designation. Even as a small practice, designate someone (yourself if sole) as compliance officer with documented responsibility for AML/KYC oversight. Write a one-page compliance manual. Train staff annually.

The records you keep are your protection in any dispute.

What to retain (minimum 5 years):

• Client identification documents and CDD/EDD records
• All transaction documents (contracts, deeds, valuations, mortgage applications, disbursement records)
• Client account bank statements and reconciliations
• Suspicious Transaction Reports and any responses
• Fee receipts, commission records, and tax documentation
• Correspondence with clients, lenders, surveyors, and regulators
• Staff training records and policy acknowledgements

Tax obligations:

• Income tax filings (corporate or personal depending on entity)
• Tax Clearance Certificate renewed annually (typically required by LASRERA and other regulators)
• VAT (7.5%) charged on agency commission and other professional services — collect from client, remit to FIRS
• Withholding tax: 10% on rental income management on behalf of landlords, remitted to state IRS
• Stamp duty on instruments executed in your role

A practitioner who can produce clean records during any regulator inspection is a practitioner the regulator leaves alone.

The IMBL Practice Guidelines (Appendix A6) require a written fee breakdown to the client before any payment is collected. Implement this as a standard practice document for every engagement.

The Standard Fee Disclosure should include:

• Total fees the practitioner will charge (in naira and as a percentage)
• The basis of those fees (NIESV scale, LASRERA cap, negotiated)
• Any fees the practitioner will receive from third parties (lender commissions, referral fees)
• Costs the client will pay to others (legal, valuation, government, taxes, insurance)
• An estimated all-in cost so the client knows the total budget
• Refund policy if the transaction does not complete

Prohibited practices (the bright lines):

• No standalone inspection fees (NIESV and AEAN both treat these as outside professional practice)
• No demands for more than one year of upfront rent
• No charging the client without a signed engagement
• No splitting of fees with unlicensed agents
• No kickbacks tied to product recommendations (anti-steering: aligned with US RESPA Section 8)

AMP is the entry-level credential. Maintaining it — and progressing toward CMP — requires Mandatory Continuing Professional Development.

Annual MCPD expectations:

• Attend IMBL-organised events and CPD sessions
• Read CBN, SEC, FMBN, and NMRC circulars as they’re issued
• Track LASRERA updates (and equivalents in other states)
• Maintain working knowledge of MLPPA 2022 amendments
• Engage with peer professionals through MBAN, REDAN, NIESV chapter events
• Document your CPD hours annually

Career pathway:

• AMP (entry-level abridged certification)
• CMP (Chartered Mortgage Professional — full curriculum)
• Specialist designations (where IMBL introduces them — commercial, refinance, valuation specialist)

AMP holders who complete CMP are recognised at the full Chartered level.

A working calendar for a sole or small-firm AMP practitioner:

Daily
– Check for new client enquiries; respond within 24 hours
– Review any pending transactions for action items
– Log time and activities for billing/audit

Weekly
– Review pipeline (open applications, status of each)
– File one cross-discipline learning artifact (regulator circular, article, case)
– Reconcile small expenses

Monthly
– Reconcile client account; document the reconciliation
– Review compliance: SCUML reporting current? Any STRs to file?
– Review accounts receivable; chase outstanding fees
– Self-audit one closed transaction file end-to-end for quality

Quarterly
– Update Standard Fee Disclosure document if rates have shifted
– Update red-flag list based on industry alerts
– Refresh training: one CPD event or peer session
– Track stakeholder relationships (lenders, surveyors, lawyers)

Annually
– Renew CAC, SCUML, LASRERA, and other permits
– File income tax returns; obtain Tax Clearance Certificate
– Renew Professional Indemnity Insurance
– Annual reconciliation of client account documented
– AGM-style review of practice performance against goals
– Plan CPD calendar for the coming year

As needed
– Respond to regulator enquiries (CBN, EFCC, FCCPC, LASRERA, NFIU)
– Update written policies as regulations change

This appendix is not bureaucracy. Each item exists because somewhere, a practitioner who skipped it lost a client, lost a credential, lost their business, or worse.

Strip away the procedural detail. The AMP-certified practitioner runs a business that:

1. Is properly set up — registered with the right bodies, documented, insured
2. Handles client money with absolute discipline — separate account, monthly reconciliation, never co-mingled
3. Knows the AML rules and applies them daily — KYC at every onboarding, threshold awareness, STR readiness
4. Keeps records that protect everyone — 5 years minimum, organised, retrievable
5. Discloses fees clearly and refuses prohibited practices — written, transparent, repeatable
6. Maintains professional competence through structured CPD — learning is non-negotiable
7. Runs on a routine calendar — not by ad-hoc response

Practitioners who live this manual become the AMP-certified professionals worth the credential.

1. What are the six structural decisions to make when setting up your practice?
2. What is the client account, and what is the single most important rule about it?
3. Quote from memory the four MLPPA 2022 cash and reporting thresholds (cash limit individual / corporate, STR deadline, international-transfer threshold).
4. What must the Standard Fee Disclosure include, and what five practices are prohibited?
5. What does the annual operating calendar require, and which professional renewals fall due each year?
6. Why is this manual described as “not bureaucracy” but a survival framework?

— End of Appendix Lesson A5 —

Next: Appendix Lesson A6 — IMBLN Practice Guidelines and International Benchmarks