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Tag: reform

  • Nigeria’s digital asset reform: From regulation to coordination

    Nigeria’s digital asset reform: From regulation to coordination

    By Kike Gbajumo

    Nigeria’s first encounter with the digital frontier of finance was reactive rather than strategic, characterised by episodic interventions rather than a coherent institutional design. That era—marked by “episodic constraint” and “shadow regulation”—saw authorities issue circulars restricting banks and telecommunications operators, creating a patchwork of control that was more reactive than anticipatory. Over time, however, this approach has given way to a structured legal and regulatory framework grounded in statute, fiscal oversight, and coordinated supervision. In its place, a new architecture of “sustained supervision” is taking shape. Yet anyone familiar with bureaucratic processes knows that the distance between enacting a law or issuing regulations and seeing a functioning system in practice is measured in friction, administrative deadlines, and the unyielding march of the calendar.

    By formally bringing virtual asset regulatory coordination under tax administration via Section 79 of the Nigeria Tax Administration Act 2025, authorities have signalled a pragmatic recognition: digital assets have grown too economically significant to be ignored. The classic sequence of regulatory power is on display here—first, make the market observable; then, stabilise it. Observability allows regulators to shift from suppression to market hardening, using oversight to enforce rules and ensure systemic integrity. Yet visibility is a double-edged sword. While the Securities and Exchange Commission’s jurisdiction has been clarified and constrained by Section 79, the statutory design effectively produces a model of “distributed supervision,” in which no single agency has full oversight. Coordination, therefore, becomes not just desirable, but essential—the difference between a functioning market and a regulatory bottleneck. What this architecture now requires is not further policy elaboration but clear command intent to ensure that agencies with intersecting mandates act in sequence rather than at cross-purposes.

    It is against this backdrop of fragmented authority and tightening timelines that regulatory measures have begun to stack, producing what can be described as a pincer movement. Fiscal, market-supervisory, financial-access, and security pressures now converge under overlapping, time-bound regulatory calendars, amplifying the need for precise sequencing.

    Read Also: PDP condemns Senate’s rejection of electronic transmission of results

    On January 16, the Securities and Exchange Commission issued Circular No. 26-1, materially raising the cost of entry into Nigeria’s digital asset market. Minimum capital requirements for Digital Asset Exchanges and custodians were set at N2 billion, with a compliance deadline of June 30, 2027. Operators now face a stark choice: recapitalise, consolidate, or exit. This regulatory hardening coincides with parallel domestic and international pressures. Nigeria was removed from the FATF Grey List on October 24, 2025, after implementing a 19-point action plan, but obligations remain to strengthen virtual asset monitoring and inter-agency intelligence coordination. Concurrently, banks face a March 31 recapitalisation deadline under Central Bank, while a December MoU with France’s DGFiP highlights international coordination in digital tax enforcement.

    The challenge of poorly coordinated reform lies in the “ghosts” that inhabit bureaucratic machinery—conditionalities and procedural gaps that sit outside the formal permitting pathway. Consider a virtual exchange that meets the SEC’s N2 billion capital threshold, only to find that banks refuse to host its accounts because the CBN has not lifted restrictions on banking access. In this scenario, a SEC licence becomes operationally meaningless. Here, coordination is a matter of survival. Fortunately, the CBN occupies a central regulatory role in virtual asset oversight, whereas other agencies, such as National Communications Commission (NCC), occupy enabling roles. Telecommunications infrastructure—the digital arteries through which customers access platforms—remains pivotal. Unlike banks, whose regulatory obligations are directly enforced by CBN, telecommunications restrictions require additional action from NCC, following guidance from the wider security and financial-integrity apparatus.

    In short, the tax authorities, securities regulators, banks, and telecommunications operators must move in a single, synchronised formation. Without such coordination, the reform risks losing credibility. In a low-trust environment, legal compliance that is obstructed by infrastructure gaps is perceived as institutional failure, even if policy intent is clear. Coming after controversies surrounding passage of tax reform statutes and the MOU with France, operationalising Section 79 without a glitch is essential to maintain market confidence.

    At this stage, calendar and coordination converge, creating a unique urgency. The foundational laws are, however controversially, on the books, and institutions are adjusting to the realities of Section 79. What remains unannounced is the exact mechanism to operationalise coordination, even as sectoral reforms reach a critical point in banking, capital markets, and international fiscal cooperation. Capital is being raised, regulatory scrutiny has intensified, and operators are moving to comply. Yet the final test of reform will be whether a newly licensed digital firm can actually open a bank account and reach customers via the internet. Coordination is no longer a convenience—it is an essential condition for credibility.

    Since the formal lifting of CBN restrictions in late 2023, Nigeria has enacted at least three major statutes incorporating digital assets into multiple regulatory and fiscal regimes. Capital gains taxation, securities licensing, financial and compliance reporting, and revenue-led coordination are now grounded in law. Despite this momentum, residual access constraints have persisted in practice, prolonging a costly period of legal limbo for compliant operators while unregulated actors continue to serve the market. The central challenge is execution—aligning policy intent with operational reality.

    Ultimately, the Gordian Knot is not legal but coordinative. Policy intent is clear, statutory foundations are in place, and institutions are aligned in principle. What remains unresolved is the authority to translate intent consistently across organisational boundaries at a moment when mandates overlap and incentives diverge. Historically, Nigerian reforms move fastest when clear presidential direction reinforces sequencing and inter-agency alignment. Where the “Commander’s intent” is understood, execution follows.

    ·         Gbajumo, a crypto analyst, writes from Lagos

  • Nigeria: Close of year – from reform to relief

    Nigeria: Close of year – from reform to relief

    • By Sunday Dare

    As 2025 draws to a close, President Bola Tinubu’s administration presents Nigerians with not rhetoric, but a measurable accounting of progress-one that is increasingly visible and relatable in everyday life, not just in macroeconomic charts.

    Year 2025 was one of deliberate, sometimes difficult, reforms. Today, those reforms are beginning to yield stabilisation, easing prices, and renewing confidence across the economy.

    What it means for households and businesses?

    After eight consecutive months of decline, headline inflation eased to 14.45% in November 2025. This matters because it slows the pace at which prices of food, transport, and household essentials rise. Food inflation has also entered a downward trend, offering gradual relief in markets and retail outlets nationwide.

    Fuel prices – one of the most visible cost drivers for households – have now stabilised and begun to ease. Petrol currently sells at around N845 per litre by NNPCL, while private refiner–owned filling stations are selling below N800 per litre in several locations. This moderation has reduced transport costs, eased pressure on food prices, and improved cost planning for businesses and families alike.

    The foreign exchange market has steadied, supported by external reserves of $44.56 billion. For Nigerians, this translates into fewer sudden currency swings, lower imported inflation, and more predictable pricing for essentials such as medicines, school supplies, and manufactured goods.

    Growth without illusions

    Nigeria’s economy expanded by 3.98% in Q3 2025, driven largely by the non-oil sector. This growth reflects real activity in agriculture, services, manufacturing, and trade—sectors that create jobs and sustain livelihoods.

    Business confidence has followed the same trajectory. The Purchasing Managers’ Index recorded 12 consecutive months of expansion, signalling increased production, restocking, and hiring across supply chains.

    Read Also: Southeast will vote massively for Tinubu, Nwifuru — Umahi

    Investor confidence has also returned. A massively oversubscribed Eurobond issuance—four times the $2.3 billion target—demonstrated renewed international belief in Nigeria’s reform path, reducing future borrowing costs and strengthening fiscal buffers.

    Infrastructure and power: lowering costs at the base

    Record power generation, the rollout of the Presidential Metering Initiative, and decisive action on legacy power-sector debt are all directed at reducing the hidden “generator tax” Nigerians pay daily. More reliable electricity lowers production costs for small businesses and reduces household spending on diesel and petrol.

    In parallel, over N1.5 trillion committed to road infrastructure – including the Lagos-Calabar Coastal Highway and the Sokoto-Badagry Super Highway.

    Security, confidence, and the social contract

    Security outcomes, including the successful rescue of all abducted schoolchildren in Niger State, reflect a more coordinated national security architecture – critical for farming communities, logistics corridors, and investor confidence.

    Internationally, Nigeria exited the FATF Grey List, regained key strategic seats, and secured major health and trade partnerships – steps that reinforce institutional credibility and global trust.

    Looking ahead to 2026

    The N58.18 trillion “Budget of Consolidation, Renewed Resilience and Shared Prosperity” anchors the next phase. With record capital expenditure, the largest-ever allocation to security, and prudent revenue assumptions, the focus now shifts from stabilisation to acceleration.

    Bottom line

    2025 was about restoring balance and credibility. The early dividends—slowing inflation, easing fuel prices, steadier foreign exchange, and rising confidence – are now visible.

    2026 is positioned to be the year these gains are felt more deeply, more broadly, and more permanently.

    Nigeria is not yet where it intends to be – but it is decisively no longer where it was.

    •Dare is the Special adviser Media and Public Communications to the President.

  • Let gains of reform reflect on citizens, says Yusuf

    Let gains of reform reflect on citizens, says Yusuf

    Economy and finance experts described the increase in revenue accruable to the tiers of government as one of the early gains of the ongoing economic reforms.

    They called for probity and citizen participation to ensure that the improvement in revenue translates into improvements in general living standards of the citizenry.

    Chief Executive Officer, Centre for the Promotion of Private Enterprise (CPPE), Dr. Muda Yusuf, said the growth in FAAC allocations was one of the positive outcomes of current economic reforms and such revenue improvement should reflect in the welfare of the citizens at all levels of government.

    He said: “This is one way to generate legitimacy and approvals for the ongoing reforms.  The resources must be appropriated in a manner that will clearly reflect the benefits of the reforms.

    “It is important to upscale the level of transparency and accountability in the management of resources at all levels of government – federal, states and local governments.

    Read Also: I’ll take on your concerns one by one, Tinubu assures South-south indigenes

     ”Developmental and welfare issues should be prioritised especially at the states and local government levels.”

     Managing Director, HighCap Securities, Mr. David Adonri described the increase in revenue to governments as a “pleasant development”

    “The federal government is now discharging its responsibility to sub-nationals by empowering them financially. While commending the federal government, the worry is whether the fiscal indiscipline that is prevalent in states will allow the funds to be optimized,” Adonri said.

    He noted that government might also need to consider revisiting the revenue sharing formula by looking at the formula that existed at independence.

  • Pains, gains of economic reform

    Pains, gains of economic reform

    It’s still a cautious call for President Bola Tinubu, but more stakes are on his side. His May 29, 2023 inauguration speech was a call to action and urgency and the country has been gripped by the momentum of fast-paced policy actions and reforms for more than three months.

    No government, arguably, has packed so much into its 100-day period and major reforms are gradually changing decades-old economic burdens. The shocks and pains of the changes are excruciating, visibly. But the gains and prospects are evident.

    An economy literally running on borrowed lifeline; a burgeoning national debt, which servicing alone overwhelmed national revenue, declining national incomes, a draining and corruption-ridden foreign exchange (forex) crisis with multiple rates fuelling a crony economy, a food crisis compounded by multi-dimensional poverty and a disconcerted governance lacking in fiscal and monetary coordination; Tinubu came in the nick of time for Nigeria. The policy choices were known but tough. There were almost a consensus on policy actions but then the courage to make a detour was difficult. The changes required new thought process and uprooting of long-entrenched, yet retrogressive, vested interests. Exiting a vicious cycle of excessive borrowings to support equally excessive and unproductive lifestyles, an economy idling in inefficiencies and contradictions. The fears of changes were real; Nigeria and Nigerians had been long on fake economy.

    The removal of subsidy on premium motor spirit, popularly known as petrol, came with harsh realities-increase in costs of movements, services and items. For an economy already under a choke of hyperinflation, it was hard to swallow. The abolition of multiple foreign exchange (forex) rates and adoption of a relative market model implied that naira had less official support and shock absorber, thus a volatile and lower national currency. Official figures and audit now showing the nation was on a junk. Fiscal deficit was N1.43 trillion in first quarter 2023 alone.    

    Read Also: SMEDAN, BoI partner business school on MSME summit

    But the gains are becoming evident and the prospects appear brighter. The opaqueness around petrol and the round-tripping of unfounded subsidy gone. With less incentive to smuggling and relative market-based economy, daily petrol consumption has dropped by a quarter. As against the previous claims of indebtedness and subsequent non-remittance to federation account, the country has saved nearly N2 trillion over the past three months and national revenue is on the upbeat. This has translated into increase in allocations to all tiers of government, ensuring that the gains of national resources are brought closer to all Nigerians.

    The oil sector, running on the negative for more than three years, is set for rebound. Crude oil production has recovered to 1.67mbpd compared to previous data of 1.29mbpd. A return to growth in the oil sector, projected in third quarter 2023, is expected to support the resilient non-oil export and steady the Gross Domestic Products (GDP). Nigeria’s foreign reserves broke almost four consecutive months of decline with its first accretion at the weekend and the naira appreciated by 5.1 per cent. The inauguration of the Federal Executive Council (FEC) has brought strong impetus and clarity to government’s vision and action plans. For the economic management, it’s more about production and investment, than borrowing and complacency. It’s too early in the day to make a more definitive call. But the charge from Nigerians echoes in the President’s order to the ministers: perform or be fired!

  • Welcome reform

    LAGOS State Chief Judge, Justice Opeyemi Oke, is leading the way to transform the state judiciary, particularly in tackling delays in the courts. With a population estimate of over 20 million, serviced by 59 judges and 122 magistrates, the state is currently the worst hit in terms of delay of suits in the courts, according to official report. But that record will soon change, once the new High Court Civil Procedure Rules kicks in by January 2018. Justice Oke has promised that the present situation where cases last for years in court will end with the year.

    Under the new regime, litigants, lawyers and judges will have to sit up, or pay very dearly for any tardiness. For example, where a party frustrates a hearing date set down for trial of a matter, the minimum cost payable will be N100,000. Where the delay is with regards to an interlocutory application, the minimum cost will be N50,000. Where the opposing party has incurred extra costs to attend a scheduled hearing, like flight tickets and hotel bills, the defaulting party will pay a higher cost. Furthermore, the daily penalty for late filing will move from N200 to N1,000 per day.

    No doubt, undue delays in our courts affect the confidence of investors, even as it costs the state huge resources, including remuneration for judicial officers, maintenance of the physical infrastructure, amongst other costs, to maintain the delays. Henceforth, to tackle the challenges, the state judiciary will adopt only the best practices as applicable to leading jurisdictions across the world. According to Justice Kazeem Alogba, an administrative judge, “we have taken a very strong position about delays in the prosecution of cases. We have introduced a new regime, a new manner of approach in our response…”

    There is no doubt that the delay in judicial process makes a mockery of justice. For instance, the present situation where a bank debtor can frustrate a creditor over money borrowed, because the matter is traversing the courts, for a decade, is perhaps the greatest disincentive to financial transactions. The same is applicable for clear breaches of contracts and other forms of commercial transactions, which in other climes would be dealt with within few weeks, so that parties can go back to their businesses instead of awaiting an unending litigation.

    Justice Alogba spoke to the needs of well-meaning residents of Lagos, when he pledged: “we have now decided that in view of the congestion of cases in our courts and the yearning of the public for better service, delays will not be tolerated any longer.”

    We commend the Chief Judge for setting in motion the process to heal the challenges facing the judiciary. Her passion to make changes was evident at the stakeholders meeting held last week. Some other measures include allowing substituted service through electronic communications, once it is verifiable; using video conferencing to give evidence, and reducing the volume of written addresses, so as not to debilitate judges with needless work.

    If well implemented, the new rules will reinforce the state as the centre of excellence, and bring more direct foreign investment to the country’s commercial hub. The country will benefit from the reforms and hopefully other states will copy the model. There is no justification for cases in our courts lasting beyond two to three years up to the Supreme Court. No one, whether a litigant, lawyer ,or even a judge, should be allowed to hold the process to ransom or drag the name of the state into disrepute.

    But we must quickly add that these rules can only be more effective if the Court of Appeal and the Supreme Court buy into them. Otherwise, cases may be expeditiously decided in Lagos jurisdiction and still suffer undue delays in the higher courts that are not bound by the new rules. This will   make nonsense of the objectives of the reform.

  • Govt, stakeholders to deliberate on banking reform

    Top government officials and stakeholders in the economy will on Monday, March 12, converge at the International Conference Centre, Abuja, to unveil a book meant to chart the way forward to revamp the banking sector.

    The Vice President, Prof Yemi Osinbajo, will lead the guests that will brainstorm at the gathering, which will take place at the public presentation and launch of the book, “Banking Reform in Nigeria: The law, The Prospects and The Challenges,” written by eminent scholar, lawyer, chartered banker and influential member of the House of Representatives,  ‘Bode Ayorinde.

    Other top government officials expected at the occasion include Senate President Bukola Saraki, Speaker Yakubu Dogara, and the National Leader of the All Progressives Congress (APC), Asiwaju Bola Tinubu.

    The Central Bank of Nigeria (CBN) Governor Godwin Emefiele, Ondo State Governor Rotimi Akeredolu, who is  Special Guest of Honour; Chief Justice of Nigeria Hon. Justice Walter Samuel Nkanu Onnoghen, Minister of Finance, among others, will also grace the event.

    The book traces the historical development of banking business in Nigeria and critically examines all the laws relating to banking since inception.

  • Nigerians getting poorer despite recovery – IMF

    Nigerians getting poorer despite recovery – IMF

    Nigerians are getting poorer despite the ongoing economic recovery after the recession, the International Monetary Fund (IMF) has said.

    The Fund urged the government to urgently begin economic reforms to turn things around, according to the IMF Annual Article IV review of Nigeria quoted by Reuters.

    The Fund expects the government to “muddle through” in the medium term, and any progress could also be threatened if elections next year consume political energy and resources, the report said.

    The report said economic managers had continued to boast that they had set the economy back on track after emerging from recession in the second quarter of last year.

    It said critics insisted much of the recovery came from a return to oil dependence after a rise in global oil prices and a recovery in crude production, mainly as a result of the militants in the Niger Delta stopping attacks on oil facilities than of economic policy under President Muhammadu Buhari’s administration.

    The IMF said in the report that the outlook for growth had improved but remained challenging. “Comprehensive and coherent” economic policies “remain urgent and must not be delayed by approaching elections and recovering oil prices,” it said in its annual Article IV review of Nigeria’s economy.

    “Higher oil prices would support a recovery in 2018 but a ‘muddle-through’ outlook is projected for the medium term under current policies, with fiscal dominance and structural constraints leading to continuing falls in real GDP per capita,” the IMF said.

    In the report, IMF identified risks to growth, including additional delays to implementing policies and reforms ahead of 2019 elections, security tensions, and oil prices, a fall which could see capital flows reversed. “Further delays in policy action — including pre-election pressures — can only make the inevitable adjustment more difficult and costlier,” the report said.

    The lender repeated its call for Nigeria to simplify its “complex” foreign exchange system, a bugbear for the IMF for more than a year which has left large gaps between official rates and various windows that certain groups can use to get other rates.

    “Moving towards a unified exchange rate should be pursued as soon as possible,” the IMF said. “(IMF) staff does not support the exchange measures that have given rise to the exchange restrictions and multiple currency practices.”

    The Fund singled out the Central Bank, saying it should discontinue direct interventions in the economy. The Central Bank of Nigeria (CBN) frequently injects hundreds of millions of dollars into the foreign exchange market to keep its own rates stable.

    Commercial banks struggling to remain solvent were also called out, but not identified by the IMF, including one that the lender said was already insolvent: “Some of these banks are kept afloat through continuous recourse to the CBN’s lending facilities.”

    The IMF said it does not comment on purported leaks. A spokeswoman for the Fund said a statement would be issued after the lender’s board meets to discuss its assessment on Friday. A Finance ministry spokeswoman did not immediately respond to a phone call and email requesting comment, Reuters said.

  • Provost seeks reform in education sector

    Provost seeks reform in education sector

    The Provost of Kwara College of Education (Technical), Lafiagi, Alhaji Alhassan Ishiaku, has advocated for pragmatic reforms in the education sector to galvanise the nation’s socio-political and economic development.

    Ishiaku spoke yesterday in a telephone interview with the News Agency of Nigeria (NAN) in Lafiagi, Edu Local Government Area of the state.

    The provost called on the three tiers of government to continue to commit themselves to pursuing education reforms that would address the needs of the population.

    “Teachers are undoubtedly the key actors in any reform process in the education sector and, therefore, must be adequately involved in the process.

    “The quality of education anywhere depends solely on the quality of teachers since no education system can rise above the quality of its teachers,’’ he said.

    Describing education as an inalienable right of every citizen, the educationist stressed the need for the government to ensure affordable and sustainable education for the citizenry.

    Ishiaku also advised the government to provide necessary infrastructure and facilities to guarantee a steady flow of teachers in the school system.

    He suggested that the pre-service and in-service training programmes for teachers should be entrenched into the system while more incentives be introduced to boost teachers’ morale for effective service delivery.

  • Reform federal medical centres, group urges Buhari

    Reform federal medical centres, group urges Buhari

    President Mohammadu Buhari has been urged to reform federal medical centres across the country.

    A civil society organisation, Seventh Force in a letter to the president, dated January 8th, 2018, also called for the immediate sack of the Chief Medical Director of FMC, Makurdi, Dr Peteru Inunduh.

    The Seventh Force is a group of nonpartisan patriots with membership across the country.

    The group, in the letter signed by Mr. Folarin Odusote, said: ”We have diligently followed issues in the polity and have come to the conclusion that Nigerians are more concerned about the parlous state of healthcare delivery even more than security and economic issues. From the latest survey conducted by the Seventh Force, we have found that the Federal Medical Centres across the country have become deathtraps to Nigerians on account of how they are being run.

    “The conduct of many, if not all, of the Chief Medical Directors of these centres underscores the urgent need to reform them to address the hardship they put Nigerians through for Your Excellency to deliver on campaign promises made to Nigeria.”

    Thee group accused the medical directors of sabotaging the efforts of the president to deliver on democracy dividends to the people.

    The group added: “Majority of these medical directors have demonstrated the highest level of incompetence and ineptitude in the administration of the centres, which has resulted in the facilities being closed to the public for extended period of time owing to industrial actions by workers’ unions, shortage of consumables and other ills that are inimical to their ability to meet the healthcare needs of Nigerians.

    “The Federal Medical Centre, Makurdi has become the classical example and proof that Mr. President cannot continue to harbour agents of darkness and expect that the health sector can function optimally. They are acting as deliberate saboteurs to ruin the administration.”

    The group accused the CMDs of being involved in corruption, financial recklessness and abuse of public funds that have been repeatedly swept under the carpet because the Chief Medical Directors use their positions to silence would be whistleblowers who are often victimised until they comply to a code of silence instituted by them.

    “In some instances, strikes called by unions are not unconnected with the corrupt acts they witness under the Chief Medical Director. This trend has been a bane of the Federal Medical Centre, Makurdi to an extent that Nigerians are now questioning if such brazen incidence of sustained corruption could be taking place unchallenged under Your Excellency’s Presidency,”he added.

  • OPS laments inability to reform oil sector

    The Organised Private Sector (OPS) has decried the inability of the Federal Government to drive reforms in the oil and gas sector in the last 10 years.

    It said the failure to reform the sector has removed the shine from Nigeria as a preferred destination for investment in the sector.

    It also lamented that the reason for the delay is the failure of successive governments to articulate the appropriate legal framework that will underpin the reform.

    Manufacturer’s Association of Nigeria (MAN) Director-General, Segun Ajayi-Kadir, who spoke  on behalf of his colleagues, regretted that at some point, all efforts aimed at achieving  the desired result  have led to  confusion as there were  many versions of the Petroleum Industry Bill (PIB) before the National Assembly, with no one knowing  the  correct version.

    He, however, commended the current move of the National Assembly to revisit the bill with a view to accelerating economic development.  He rejected the likely emergence of the Petroleum Regulatory Commission (PRC), which he referred to as humongous commission that will be empowered to regulate the entire petroleum sector.

    He said: “We do not share the views of the National Assembly on the creation of a behemoth regulator for a sector that is not necessarily homogenous in its activities and deliverables. The idea of a single regulator for the whole sector runs contrary to industry standards which by default already provide for an upstream and downstream regulator.”

    He said the OPS is against it because the responsibilities expected to be handled by the proposed commission are too wide and cuts-across various value chains in a key sector of the economy.

    He said: “The bureaucratic bottlenecks that will arise would clearly negate the ease of doing business policy  being pursued by the  administration. We believe that an omnibus regulator will further result in cumbersome and constant delays in securing the necessary approvals to conduct business.”

    He said the OPS is of the opinion that a single regulator will create  challenges for operators in the petroleum value chain because the structure, operation and nature of the downstream are totally different from that of the upstream sector.

    Segun-Kadiri said this is more so when there are different operators in the petroleum sector value chain with multifarious and diverse objectives, ranging from guarding against systemic risk to protecting the individual consumer from fraud.