Learning Objectives

By the end of this lesson, the candidate should be able to:

Explain why Nigeria needed a dedicated professional body for mortgage practitioners and describe the regulatory gap that existed before the IMBL Act 2022

Trace the legislative journey of the IMBL Act from the House of Representatives in March 2021 through Presidential assent in December 2022

Identify the five principal objectives of the IMBL Act: registration and certification, training and capacity building, standard-setting and code of ethics, discipline and enforcement, and consumer protection

Outline the six-part structure of the IMBL Act and explain how each part contributes to the regulatory framework for mortgage practice in Nigeria

Compare the Nigerian IMBL framework with parallel regulatory regimes in the United Kingdom (FCA/MCOB), Kenya (EARB/Cap 533), and South Africa (FSCA/FAIS)

Introduction: Why Nigeria Needed a Professional Body for Mortgage Practitioners

Think of a busy Lagos intersection with no traffic lights, no lane markings, and no police officer directing vehicles. Drivers make their own rules. Accidents happen daily. Nobody is accountable. That was the Nigerian mortgage industry before the IMBL Act 2022.

The numbers tell the story plainly. Nigeria’s mortgage sector is worth roughly USD 29.2 billion. And yet, according to EFCC statistics, land fraud alone costs Nigerians approximately USD 4 billion every year. Before December 2022, anyone could call themselves a mortgage broker or agent without any formal training, licensing, or oversight.

The IMBL Act changed that. It created the Institute of Mortgage Brokers and Lenders of Nigeria (IMBLN) and gave it real teeth: the power to register practitioners, set training standards, issue certifications, enforce a code of ethics, and discipline those who break the rules.

Before the IMBL Act, Nigeria didn’t lack financial regulators. The Central Bank of Nigeria (CBN) supervised banks and primary mortgage institutions. The Federal Mortgage Bank of Nigeria (FMBN) managed the National Housing Fund. The NDIC insured depositors. ESVARBON regulated estate surveyors and valuers.

But here’s the gap. None of these bodies regulated mortgage brokers and agents specifically. A bank lending officer fell under CBN oversight. An estate surveyor answered to ESVARBON. A mortgage broker? They answered to nobody.

Other countries had solved this problem long ago. The UK’s Financial Conduct Authority (FCA) requires mortgage advisers to pass competency exams and follow the Mortgage Conduct of Business (MCOB) rules. Kenya’s Estate Agents Registration Board (EARB), established under Cap 533, licenses and disciplines property practitioners. South Africa’s Financial Sector Conduct Authority (FSCA) does the same under the Financial Advisory and Intermediary Services (FAIS) Act. Nigeria was the outlier.

Nigeria’s housing deficit sits somewhere between 17 million and 28 million units. Mortgage penetration tells an even grimmer story. Nigeria’s mortgage-to-GDP ratio is under 1%. Compare that to South Africa at 30%, the UK at 72%, and the United States at 65%.

An unregulated brokerage market made this problem worse, not better. Buyers couldn’t trust brokers. Lenders couldn’t verify intermediaries’ qualifications. And fraud drove cautious Nigerians away from formal mortgage products entirely.

The bill that became the IMBL Act was introduced in the House of Representatives in March 2021. It passed through the Senate in September 2022 and received Presidential assent in December 2022.

The drafters drew on several existing Nigerian statutes as models: the Chartered Institute of Bankers of Nigeria (CIBN) Act, the ESVARBON Act, the Legal Practitioners Act (LPA), and the Institute of Chartered Accountants of Nigeria (ICAN) Act. Each had established a professional body with registration, training, standard-setting, and disciplinary powers.

The IMBL Act follows a tested template. What makes it distinctive is its specific focus on mortgage brokers and lenders, a category that had never before been subject to dedicated regulation in Nigeria.

Think of registration as immigration control for the mortgage profession. You can’t just walk in. You need a passport (your qualifications), a visa (your registration with IMBLN), and an entry stamp (your practising certificate).

The Act requires every person who wants to practise as a mortgage broker, lender, or agent in Nigeria to register with the IMBLN and obtain certification. Unregistered practice is an offence. And the register is public.

Registration alone isn’t enough. The Act mandates that the IMBLN develop curricula, run examinations, and require continuing professional development (CPD) for all registered practitioners.

This is the part that will change the industry over time. When every mortgage broker in Nigeria has passed standardised exams covering property law, lending principles, ethics, and consumer protection, the average quality of advice will rise.

Every profession needs a rulebook. Doctors have the Medical and Dental Council’s code. Lawyers have the Rules of Professional Conduct. Before the IMBL Act, mortgage brokers had nothing comparable.

The Act empowers IMBLN to issue a binding code of ethics and practice standards covering how client funds are handled to how fees are disclosed to what constitutes a conflict of interest.

Rules without enforcement are suggestions. The Act gives IMBLN a disciplinary committee with the power to investigate complaints, conduct hearings, and impose sanctions ranging from fines to suspension to permanent removal from the register.

Before the Act, a dishonest broker could defraud clients and simply move to a different neighbourhood to start again.

All four objectives above serve a fifth, overarching goal: protecting consumers and building confidence in the mortgage market. When buyers know that their broker is registered, trained, and subject to a code of conduct, they’re more likely to use formal mortgage products. And that matters for the housing deficit.

Case Study 1: The Abuja Phantom Estate Scandal (2019-2021)

Between 2019 and 2021, an unregistered firm operating from a polished office in Wuse II, Abuja, sold off-plan units in what it called the Green Valley Estate. The firm collected deposits from over 300 buyers, totalling approximately N1.4 billion. The estate didn’t exist. There was no land allocation, no building permit, no construction.

When the fraud collapsed in mid-2021, the firm’s directors vanished. The EFCC eventually arrested two of the three directors, but recovery of funds has been minimal.

Under the IMBL Act framework, this firm would have needed to register with IMBLN before offering mortgage brokerage. The public register would have allowed any buyer to verify the firm’s credentials before handing over money.

The Act is organised into six parts:

Part II: Registration and Practising Certificates. Defines who must register, the requirements for registration, the categories of membership, and the process for issuing (and revoking) practising certificates.

Part III: Training and Examinations. Empowers the IMBLN to set curricula, conduct examinations, accredit training providers, and mandate continuing professional development.

Part IV: Code of Conduct and Practice Standards. Authorises the IMBLN to issue a binding code of ethics. Breach constitutes professional misconduct.

Part VI: Miscellaneous Provisions. Covers offences (including practising without registration), penalties, transitional arrangements, funding, and the Minister’s power to make regulations.

Each part builds on the one before it. You can’t have discipline without a code of conduct. You can’t have a code of conduct without knowing who’s subject to it. And none of it works without the institutional foundation.

Before the IMBL Act, mortgage brokerage was a trade. Anyone could do it. After the Act, it’s a profession. Only registered, certified, and supervised practitioners can lawfully do it.

The IMBLN doesn’t replace the CBN, FMBN, NDIC, or ESVARBON. Each regulator keeps its existing jurisdiction. The relationship is additive, not substitutive.

The CBN builds the road (prudential regulation of banks and mortgage institutions). ESVARBON certifies the vehicle inspectors. The IMBLN issues driving licences (certification of mortgage brokers and lenders). You need all three for the system to work properly.

Consumer trust is the missing ingredient in Nigeria’s mortgage market. The IMBL Act attacks distrust at its root. A public register means you can check before you pay. Standardised training means your broker actually knows property law and mortgage finance. A disciplinary process means there are consequences for misconduct.

Case Study 2: ICPC-IMBLN Joint Task Committee (March 2026)

In June 2024, the Independent Corrupt Practices Commission (ICPC) and the IMBLN signed a Memorandum of Understanding to cooperate on combating fraud in the mortgage and real estate sector.

The MoU led to the inauguration of a Joint Task Committee in March 2026, co-chaired by an ICPC Commissioner and the IMBLN Registrar/CEO. The Committee’s mandate includes shared intelligence on suspected fraudulent practitioners, joint investigations of reported fraud cases, and the development of anti-fraud training modules.

For practitioners, the practical takeaway is clear: the regulatory net is tightening. Registration with the IMBLN connects you to a system actively monitored by both your professional body and a federal anti-corruption agency.

United Kingdom: FCA and MCOB

The UK’s Financial Conduct Authority regulates all mortgage advisers under MCOB rules. Every adviser must pass a qualification exam (CeMAP or equivalent), register with the FCA, and comply with conduct rules covering suitability assessments, fee disclosure, and complaints handling. The IMBLN framework draws on this model.

Kenya: EARB and Cap 533

Kenya’s Estate Agents Registration Board (EARB), established under the Estate Agents Act (Cap 533), registers and regulates estate agents including those involved in mortgage intermediation. Kenya’s system is closer to Nigeria’s in terms of economic context and market maturity.

South Africa: FSCA and FAIS

South Africa’s FSCA regulates financial advisers under the FAIS Act. Practitioners must meet fit-and-proper requirements covering honesty, competence, and financial soundness. South Africa’s mortgage-to-GDP ratio of 30% reflects a much more developed mortgage market.

If you’re a working mortgage broker, lender, or agent in Nigeria, the IMBL Act changes your daily reality in five concrete ways:

Registration is mandatory. Operating without registration is a criminal offence.

Certification requires exams covering mortgage law, lending principles, property valuation fundamentals, ethics, and consumer protection.

A code of ethics applies to you. Violations trigger the disciplinary process.

CPD is not optional. Continuing professional development is a condition of maintaining your practising certificate.

Documentation standards are higher. Sloppy paperwork is no longer just bad practice — it’s a regulatory risk.

Summary

Before December 2022, Nigeria had no dedicated regulator for mortgage brokers and agents. The CBN, FMBN, NDIC, and ESVARBON each covered their own domains, but mortgage intermediaries fell through the cracks. The IMBL Act closed that gap.

The Act passed through the House of Representatives (March 2021), the Senate (September 2022), and received Presidential assent (December 2022). Its six parts establish the Institute, define registration requirements, mandate training, authorise a code of conduct, create a disciplinary framework, and address offences and penalties.

For practitioners: register, get certified, follow the code, keep learning, and keep proper records.

KEY TAKEAWAYS

The IMBL Act 2022 created the IMBLN as Nigeria’s first dedicated regulatory body for mortgage brokers, lenders, and agents

Before the Act, no regulator specifically oversaw mortgage intermediaries, despite the sector being worth USD 29.2 billion and losing USD 4 billion annually to land fraud

The Act received Presidential assent in December 2022 after passing the House of Representatives (March 2021) and Senate (September 2022)

Five objectives drive the Act: registration/certification, training/capacity building, standard-setting/code of ethics, discipline/enforcement, and consumer protection

The Act is structured in six parts covering establishment, registration, training, code of conduct, discipline, and miscellaneous provisions

The IMBLN works alongside (not instead of) existing regulators like the CBN, FMBN, NDIC, and ESVARBON

Comparable frameworks exist in the UK (FCA/MCOB), Kenya (EARB/Cap 533), and South Africa (FSCA/FAIS)

Knowledge Check (10 Questions)

1. What was the primary regulatory gap that the IMBL Act 2022 was designed to fill?

   1. The CBN lacked power to regulate deposit money banks
   2. ESVARBON could not register estate surveyors
   3. No regulatory body specifically oversaw mortgage brokers and agents in Nigeria
   4. The FMBN was unable to manage the National Housing Fund

2. In what year did the IMBL Act receive Presidential assent?

   1. 2021
   2. 2022
   3. 2023
   4. 2020

3. Which of the following best describes Nigeria’s mortgage-to-GDP ratio before the Act?

   1. Approximately 30%
   2. Under 1%
   3. About 15%
   4. Over 50%

4. The IMBL Act was modelled on which of the following existing Nigerian statutes?

   1. The Petroleum Industry Act
   2. The CIBN Act, ESVARBON Act, LPA, and ICAN Act
   3. The Companies and Allied Matters Act only
   4. The Electoral Act

5. Which Part of the IMBL Act establishes the disciplinary framework?

   1. Part II
   2. Part III
   3. Part V
   4. Part VI

6. The ICPC-IMBLN Joint Task Committee was inaugurated in:

   1. June 2024
   2. December 2022
   3. March 2026
   4. January 2025

7. Which country’s mortgage regulatory model uses the MCOB rules?

   1. South Africa
   2. Kenya
   3. United Kingdom
   4. Ghana

8. Under the IMBL Act, practising as a mortgage broker without registration is:

   1. Permitted for the first six months
   2. A criminal offence
   3. Allowed if the practitioner has a university degree
   4. Subject only to a warning letter

9. The Abuja Phantom Estate scandal involved fraud totalling approximately:

   1. N500 million
   2. N2.8 billion
   3. N1.4 billion
   4. N800 million

10. Nigeria’s housing deficit is estimated at:

    1. 5-10 million units
    2. 17-28 million units
    3. 50-60 million units
    4. 1-3 million units

Answers

Answers: 1. (c) 2. (b) 3. (b) 4. (b) 5. (c) 6. (c) 7. (c) 8. (b) 9. (c) 10. (b)

Further Reading

The Institute of Mortgage Brokers and Lenders of Nigeria (Establishment) Act 2022

Chartered Institute of Bankers of Nigeria (CIBN) Act, Cap C7, LFN 2004

Estate Surveyors and Valuers (Registration, etc.) Act (ESVARBON Act), Cap E13, LFN 2004

Legal Practitioners Act (LPA), Cap L11, LFN 2004

Institute of Chartered Accountants of Nigeria (ICAN) Act, Cap I1, LFN 2004

Central Bank of Nigeria Act 2007

Federal Mortgage Bank of Nigeria Act, Cap F16, LFN 2004

Nigeria Deposit Insurance Corporation (NDIC) Act 2006

UK Financial Conduct Authority, Mortgage Conduct of Business (MCOB) Sourcebook

Kenya Estate Agents Act, Cap 533, Laws of Kenya

South Africa Financial Advisory and Intermediary Services (FAIS) Act 37 of 2002

EFCC Annual Reports on Land Fraud Statistics

Nigeria Mortgage Refinance Company (NMRC) publications

IMBL Nigeria Certification