Learning Objectives

By the end of this lesson, you will be able to:

Explain the role of the Registrar and the purpose of the Register under Part II of the IMBL Act 2022.

Identify the five membership categories established under Part III of the Act.

Describe the registration process from application through certificate issuance.

Distinguish between the rights and obligations that come with IMBL membership.

Outline the requirements for obtaining and renewing an Annual Practising Licence.

Explain suspension, removal, and restoration procedures and their grounds.

Introduction

Think of the IMBL Register as the profession’s address book. Every name in it tells you: this person (or company) has been vetted, approved, and is accountable to a regulatory body. Without your name in that Register, you can’t legally practise as a mortgage broker or lender in Nigeria.

Parts II and III of the IMBL Act 2022 set out how the Register works, who keeps it, and how you get your name into it. They also spell out the different grades of membership and what each one means for your career.

The Registrar is appointed by the Council of the Institute. The Registrar is the operational backbone of the registration system:

Maintains and updates the Register of members and licensed practitioners.

Issues certificates of registration to approved applicants.

Processes all new applications, renewals, and changes in registration status.

Publishes the Register annually in the Federal Gazette and maintains an online version.

Advises the Council on registration matters, trends, and any irregularities.

The Registrar is also the first point of contact for anyone wanting to verify whether a broker or lender is properly registered.

The Register is a statutory document. It exists because the law says it must. It records:

Full name and contact details of the registered person or firm.

Qualifications (academic and professional) that formed the basis for admission.

Membership category (Student, Graduate/Associate, Member, Corporate, or Fellow).

Current licence status, including whether the Annual Practising Licence is valid.

Disciplinary history, if any, including suspensions, conditions, or restrictions.

The Register is published annually in the Federal Gazette and maintained online so the public can verify a practitioner’s status at any time.

CIBN (Chartered Institute of Bankers of Nigeria): The Registrar maintains the register of chartered bankers. Similar statutory duties focused on banking professionals.

ICAN (Institute of Chartered Accountants of Nigeria): Handles a much larger register given the size of the accounting profession. Same model: maintain, update, publish, advise Council.

MDCN (Medical and Dental Council of Nigeria): Has additional powers related to provisional registration for doctors in training.

The common thread? The Registrar is the gatekeeper. No name enters the register without passing through the Registrar’s office.

The Act creates five distinct membership categories.

This is the entry point. If you’re currently enrolled in a recognised programme of study related to mortgage practice, real estate finance, or a related discipline, you qualify. Student Members can’t practise. They can’t use professional designations. But they get access to learning resources, events, and mentorship programmes.

Once you complete the required examinations or hold an approved qualification, you move up to Graduate or Associate Member. At this level, you can begin working under supervision in mortgage brokerage or lending.

This is the level where you can practise independently and use the professional designations CML (Certified Mortgage Lender) or SML (Senior Mortgage Leader).

To reach this point, you need a combination of passed examinations, verified professional experience, and a clean disciplinary record. Members can vote in Institute elections. They can hold office. And they can apply for an Annual Practising Licence.

This category exists for firms and companies, not individuals. Any company carrying on business as a mortgage broker or lender must register as a Corporate Member. At least one director or principal officer of the firm must also be individually registered with IMBL.

Corporate Members have obligations including maintaining adequate records, carrying professional indemnity insurance, and submitting to the Institute’s regulatory oversight.

Fellow of the Institute of Mortgage Brokers and Lenders of Nigeria. This is the highest grade of membership. Fellowship requires at least 10 years of continuous membership, a distinguished contribution to the mortgage profession, and nomination or recommendation. The Council makes the final decision.

Four-stage process:

You submit a completed application form to the Registrar’s office. Along with the form, you submit supporting documents: certified copies of qualifications, proof of identity, passport photographs, and evidence of relevant work experience. There’s also an application fee.

The Registrar’s office screens your application. They verify your qualifications, check your documents, and confirm your identity. In some cases, the Registrar may request an interview. Applications with false or misleading information are rejected outright.

Once the Registrar is satisfied, the application goes to the Council (or a committee the Council has delegated this function to) for final approval. The Council can approve, reject, or defer.

Approved applicants receive a certificate of registration. It states your name, membership category, registration number, and the date of admission.

Use of professional designations (CML, SML, FIMBLN) appropriate to your membership category.

The right to practise as a mortgage broker or lender (subject to holding a valid Annual Practising Licence).

Voting rights in Institute elections and general meetings.

Access to continuing professional development (CPD) programmes.

Eligibility to hold office within the Institute.

Pay annual subscription fees and any other levies set by the Council on time.

Comply with the Institute’s Code of Professional Conduct at all times.

Complete the required minimum hours of CPD each year and submit evidence.

Cooperate fully with any investigation or disciplinary inquiry.

Maintain proper records of all professional transactions and make them available for audit if requested.

Registration and the Annual Practising Licence are two different things. Registration gets your name into the Register. The licence gives you permission to actively practise for that year.

You can be registered but not licensed. Without a valid licence, you can’t hold yourself out as a practising mortgage broker or lender.

Conditions for Licence Renewal

All annual fees and levies must be paid up to date.

You must have completed the required CPD hours for the preceding year.

You must be in good standing with the Institute (no outstanding disciplinary sanctions).

You must hold valid professional indemnity insurance that meets the minimum cover set by the Council.

Miss any of these, and your licence won’t be renewed.

The Council can suspend a member’s registration for:

Professional misconduct, as determined through the Institute’s disciplinary process.

Persistent failure to pay annual fees or levies.

Criminal conviction for an offence involving dishonesty, fraud, or moral turpitude.

Suspension is temporary. Your name stays in the Register, but with a notation that your registration is currently suspended.

Removal is permanent. It’s reserved for the most serious cases. If the Disciplinary Tribunal finds that a member’s conduct is so egregious that continued membership would bring the profession into disrepute, it can recommend removal.

Even after removal, the Act allows for restoration. A former member must apply to the Council, demonstrating rehabilitation and good character. Restoration is discretionary.

Companies that operate as mortgage brokers or lenders must register with IMBL separately. The company must be incorporated in Nigeria. At least one director or principal officer must hold individual IMBL registration.

If the company’s sole registered director loses their individual registration, the company’s corporate registration is at risk.

The Act requires the Register to be published annually in the Federal Gazette. The Act also requires the Institute to maintain an online, searchable version of the Register. This means anyone — a prospective borrower, a bank, a regulator — can verify whether a person or firm is properly registered and licensed.

Case Study 1: The Unregistered Broker of Victoria Island

Mrs. Funke Adesanya was looking for a mortgage to purchase a three-bedroom flat on Victoria Island, Lagos. A colleague referred her to a man who called himself a senior mortgage consultant. Mrs. Adesanya paid him N2.5 million as a processing fee. He promised to secure her a mortgage within six weeks. Six weeks turned into three months. Then he stopped answering calls.

She reported the matter to IMBL. The Institute confirmed that the man had never been registered. Under the IMBL Act 2022, Mrs. Adesanya could have verified his status before paying. A simple check of the online Register would have revealed that he wasn’t there.

Case Study 2: Corporate Registration in Practice

Alpha Mortgage Services Ltd is a Lagos-based firm founded by three partners: Adamu Bello (a licensed mortgage broker), Chidinma Okafor (a licensed real estate lawyer), and Emeka Nwachukwu (a business operations manager).

When the IMBL Act 2022 came into effect, Alpha needed to register as a Corporate Member. The process required them to demonstrate that at least one director held individual IMBL registration. Adamu already did. Chidinma needed to apply for individual IMBL registration because she was involved in mortgage lending activities. Emeka, as an operations manager without a client-facing mortgage role, did not need individual registration at that stage.

Once both individual registrations were approved, Alpha received its corporate certificate of registration.

Summary

Parts II and III of the IMBL Act 2022 build the profession’s registration infrastructure. The Registrar maintains the Register. The Register records every member and licensed practitioner. And the membership categories create a clear progression from Student to Fellow.

Registration is a four-stage process: apply, get screened, receive approval, collect your certificate. Once registered, you gain rights and take on obligations. The Annual Practising Licence is separate from registration. The system has teeth: suspension, removal, and (sometimes) restoration keep members accountable.

KEY TAKEAWAYS

The Registrar is appointed by the Council and is responsible for maintaining the Register, issuing certificates, processing applications, and publishing the Register.

The Register records each member’s name, qualifications, category, licence status, and disciplinary history, and is published annually in the Federal Gazette and online.

Five membership categories exist: Student Member, Graduate/Associate Member, Member (CML/SML), Corporate Member, and Fellow (FIMBLN, requiring 10+ years and distinguished service).

Registration follows four stages: Application, Screening, Approval by Council, and Certificate issuance.

Members have rights (use designations, practise, vote, access CPD, hold office) and obligations (pay fees, comply with Code, complete CPD, cooperate with investigations, maintain records).

The Annual Practising Licence is separate from registration, requires annual renewal, and depends on fees, CPD completion, good standing, and professional indemnity insurance.

The Council can suspend or remove members for misconduct, non-payment, or criminal conviction, and restoration after removal is discretionary and conditional.

Knowledge Check (10 Questions)

1. Who appoints the Registrar of the Institute under the IMBL Act 2022?

   1. The President of Nigeria
   2. The Council of the Institute
   3. The Federal Ministry of Finance
   4. The Central Bank of Nigeria

2. Which of the following is NOT recorded in the Register?

   1. Membership category
   2. Disciplinary history
   3. Annual income of the member
   4. Licence status

3. What is the minimum period of continuous membership required for Fellowship (FIMBLN)?

   1. 5 years
   2. 10 years
   3. 15 years
   4. 20 years

4. At which stage of the registration process does the Council (or its committee) make the final decision?

   1. Approval
   2. Screening
   3. Application
   4. Certificate issuance

5. Which professional designation is associated with full membership of IMBL?

   1. FIMBLN
   2. AIMBLN
   3. CML/SML
   4. GIMBLN

6. What is the relationship between registration and the Annual Practising Licence?

   1. They are the same thing
   2. Registration is required, but the licence is a separate annual requirement
   3. The licence replaces registration after the first year
   4. Only corporate members need the licence

7. Which condition is NOT required for Annual Practising Licence renewal?

   1. Completion of CPD hours
   2. Payment of annual fees
   3. Publication of a research paper
   4. Professional indemnity insurance

8. For corporate registration, what is the minimum requirement regarding individually registered directors?

   1. At least one director must hold individual IMBL registration
   2. All directors must be registered
   3. No directors need individual registration
   4. Only the CEO must be registered

9. What happens during a suspension of registration?

   1. The member’s name is permanently removed from the Register
   2. The member’s name stays in the Register with a suspension notation, and they cannot practise
   3. The member can continue to practise under supervision
   4. The suspension has no effect on practice rights

10. Where must the Register be published annually according to the Act?

    1. Only on the Institute’s website
    2. Only in national newspapers
    3. In the Federal Gazette and maintained online
    4. In the Central Bank’s annual report

Answers

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

Further Reading

IMBL Act 2022, Parts II and III (full text)

CIBN Act (Cap C4 LFN 2004) — for comparison of Registrar functions

ICAN Act (Cap 14 LFN 2004) — for comparison of registration frameworks

MDCN Act (Cap M8 LFN 2004) — for comparison of professional registration in medicine

Federal Gazette notices relating to professional body registers in Nigeria

CBN Guidelines on Mortgage Banking in Nigeria (current edition)

IMBL Nigeria Certification