NASD MOBILE · ONBOARDING & MARKET-ACCESS ARCHITECTURE
object & contract map · v7 · 22 Jul 2026 · prepared with VFD Group (GTPP) · built on build-team answers, the fee schedule and the legal read
How does an investor reach a ready-to-trade wallet in three minutes, whether they arrive new or already carry a bvndle tag?
THE CONSTRAINTS
What the build-team diligence Q&A clarified
Questions issued 20 Jul · annotated answers returned 21 Jul 2026 · relayed to the in-house team and the session brokered by Gbemi · engagement set up and steered with Arese · the team annotated the questions document directly, and their answers are the constraints this design is built on
▸No trade or holding can exist without a broker attached. A preferred or designated broker is supported, and that is the seam this whole design builds on.
▸Wallets are broker custody by design. Wallet creation requires at least one broker KYC account first, so the funding wall reviewers hit is the data model surfacing, not a bug.
▸BVN → CSCS lookup does not exist today. CSCS can be engaged to provide it for KYC'd investors, so instant recognition via the registry is roadmap, not launch.
▸Writing to CSCS is not available. The platform reads only; write integration is in discussion. New CHNs are created through broker rails.
▸KYC is stored per broker today, with reusability planned. Identity data can be shared; each broker's attestation cannot.
▸The stack is React Native / Node / MongoDB, built and maintained in-house. The team is active and a known-issues list exists, so this rework is feasible in place, not a rebuild.
PLUS · THE LEGAL READKYC reuse across brokers is regulated reliance, not portability; explicit consent fires per broker added (NDPA / GAID 2025).
PLUS · THE ENABLERSEC Rule 67 (2021) digital sub-broker category: platform-designated brokers already operate licensed at scale.
PLUS · THE FEE SCHEDULE≈2% per side; ₦4,027 on a ₦100k round trip, with brokerage 67% of the stack.
THE ANSWER
The build strategy
Attach a broker from the designated panel at second zero, and make the identity object do everything else. The shape here is Ikechukwu's original tiered-access direction, get people buying early and gate only what the market genuinely gates, carried through intact and rebuilt on the constraints above. The user never waits for a broker because one is already standing behind them when they open the app, allocated by a published rule from a panel any Participating Institution can earn its way onto. The object carries the KYC evidence, its provenance, and a pre-programmed consent hook, so the allocated broker attests in seconds instead of collecting for days. The tag is how the object is found; VBank is how money finds it. The SEC's own three-tier KYC ladder becomes part of the UX: any held-for-review state opens as a capped Level 1 account instead of a dead end, and accounts climb the tiers as balances grow. And the whole construct stands on ground the SEC has already licensed: the Rule 67 digital sub-broker category that Chaka, Bamboo and Risevest operate on today.
01 · TWO WAYS IN
New investor and returning tag, same destination
Both paths end at the same event: a panel broker attesting over the investor's identity object (unpacked in 03). Neither path ever waits on the user choosing a broker, because one is allocated at second zero and can be swapped at any time.
Mint
FIRST-TIME INVESTOR · NO TAG YET
1Enter BVN, one consent tapNIBSS verifies · fields hydrate · eligibility passes
2Tag minted@name reserved · object sealed · provenance begins
3Panel broker attestsclient agreement, one tap · broker signs over the evidence · VBank number issued
Verify
RETURNING · TAG IN HAND
1Enter @tag, prove it's youbiometric / device key · object retrieved
2Consent hook firesone explicit tap shares evidence with this broker · NDPA satisfied
3Broker re-attests, nothing re-collectedreliance over existing provenance · seconds, not days
↓BOTH PATHS LAND HERE: BROKER-OF-RECORD ATTACHED · WALLET OPENS · VBANK NUMBER LIVE
02 · WALLET STATES
Four states, three gates
Access is earned in the background and arrives as an upgrade, never withheld as a wall. Only one gate is hard, and it is the market's, not ours.
OPENBROWSE
Market, watchlist, prices. Requires nothing. Entered at second zero.
→
ATTESTEDFUND & BUY
A panel broker has signed over the object. VBank number live; funding by transfer from any bank; any admitted security.
→
SETTLINGCHN PENDING
CSCS number resolving via broker rails. Holdings accrue and display accurately. Live countdown shown, never a dead end.
→
FULLSELL & WITHDRAW
Unlocks when CHN is live and settlement clears. Cash-out lands in VBank instantly; external banks via NIBSS. The one hard gate, owned by market plumbing (T+).
GATES: none consent hook + attestation CHN + T+ settlement (external, honest countdown)
FAIL-SAFE FLOOR · any held-for-review state (name mismatch, NIBSS down, ambiguous match) opens as an SEC Level 1 capped account, ₦20k a deposit · ₦200k cumulative · ₦30k daily redemption, rather than a block. The regulator's own inclusion tier is the product's safety valve · SEC Rules and Sundry Amendments, June 2017, Three-tiered KYC Framework for Capital Market Operators
03 · THE OBJECT
One identity object, addressed by tag
Everything above hangs off this. It is not a form and not a profile. It is a portable evidence container with its chain of custody written on it.
The tag is the address
Minted at first KYC, or presented on return. It replaces the CSCS lookup that does not exist: recognition happens on our rail, not the registry's.
Fields are hydrated once
BVN verification fills identity fields. Idempotent: nothing already held is ever asked again, on any surface, for any broker.
Consent is a hook, not a form
NDPA consent for sharing with a new broker is pre-programmed as a hook on the object. Adding a broker fires it as a single explicit tap, captured with timestamp and scope.
BVNDLE RAIL
IDENTITY OBJECT · ov.v1
@ada.okafor
minted 22 Jul 2026 · 14:02:11
bvn•••••••3841 NIBSS ✓
nameAda Okafor MATCHED
dob / age1994 · 18+ ELIGIBLE
cash nodeVBank ••••8812 ISSUED
cscs / chnpending VIA BROKER
classretail DAY-ONE
kyc levelLevel 1 · migrates up SEC 3-TIER
PROVENANCE · producible on demand
14:02:08BVN verified against NIBSS#a41f…
14:02:11Tag minted, object sealed#c07b…
14:02:40ID document captured + hashed#e2d9…
14:03:02Broker Alpha attests over evidence#f610…
14:03:04VBank virtual account issued to tag#0b3e…
CONSENT HOOKS
⚓ Broker Alpha · granted 14:02:55
⚓ next broker · armed, unfired
Provenance is the product
Every verification event is stamped and hash-chained. This is what makes broker attestation a seconds-long decision: they are signing over evidence, not gathering it.
VBank is the cash node
A VBank virtual account is issued against the tag at attestation. It is BVN-linked at birth, so the funding-source-must-match-BVN rule is satisfied by construction, not by checking.
Attestation stays per broker
The law keeps each broker ultimately responsible for its own CDD. So brokers do not share a KYC; they each attest over the same object. Data shared, liability never.
04 · THE THREE MINUTES
What the user does, over what the system does
The user's whole journey is three actions. Everything regulated runs underneath, already resolved or already in motion, never in front of them.
THIS TABLE SCROLLS · SWIPE ACROSS TO FOLLOW THE CLOCK ⟶
Nothing on this track is broker-less at any moment, so it fits the confirmed data model without schema surgery.
05 · THE PANEL
Not an assignment problem, a broker incentive programme
An exchange steering clients to a favourite would be an SRO neutrality problem. This is the opposite: an earned distribution channel that any Participating Institution can join, allocated by a rule every member can read.
QUALIFYOpen enrolment
Any PI in good standing joins by meeting the bar: attestation inside the SLA, evidence-trail reliance capability, and compliance standing. No invitations, no favourites.
ALLOCATEBy published rule
New investors are allocated across the panel by a transparent formula: a round-robin baseline weighted by service performance. Every member can read the rule and audit their share.
ATTESTSpeed is the sport
The allocated broker attests over the object in seconds. Attestation speed, rejection quality and service scores feed the weighting, the same telemetry as the Broker Service Rating already on the Q3 roadmap. One build, two initiatives.
EARNLifetime brokerage
Attestation makes the PI broker-of-record: 1.35% a side on every trade until the client swaps. Distribution is the prize; service is how you keep it.
The flywheel: better service earns more allocation; more allocation builds bigger lifetime books; bigger books justify investing in faster attestation; faster attestation shortens onboarding for everyone; shorter onboarding grows the volume NASD's own 0.25% is paid on. Fairness is not the absence of assignment, it is a rule all 59 owner-members can read, audit, and win under.
Panel governance to be socialised with the PI community · allocation formula published as a market notice · swap rights preserve client choice throughout
06 · THE COMMERCIAL LAYER
Who earns, and only after the path completes
Per the fee schedule circulated to the group (VAT recomputed at 7.5%). A ₦100,000 round trip pays out ≈ ₦4,027 across the stack, and not one naira of it is earned while a user is stuck at a bank-selection screen.
Where a ₦100,000 round trip goes
buy ≈ ₦2,004 (2.00%) · sell ≈ ₦2,023 (2.02%) · total ≈ ₦4,027 (4.03%) + ₦8 trade alerts
BROKERAGE ₦2,700
NASD ₦500
VAT
SEC
CSCS
ST
Brokerage 1.35% × 2 sides
NASD 0.25% × 2 sides
VAT 7.5% on fees ₦259
SEC 0.20% (buy)
CSCS 0.20% (sell)
Stamp 0.08% × 2
Trade alerts ₦4 × 2
AT BROWSE
Nobody earns. No fee in the schedule fires before a funded trade. Every funnel death is the whole stack's loss, including FIRS.
AT FUND & BUY
The buy stack fires: broker 1.35%, NASD 0.25%, SEC 0.20%, stamp, VAT. NASD's 0.25% a side makes its revenue a pure volume game.
AT SELL
The sell stack fires: broker again, NASD again, CSCS 0.20%. Full-state users are the only users who ever pay the second half.
VFD RAIL
VBank earns off-schedule: the funding rail, balances held between trades, and instant cash-out. The tag rail drives the volume everyone above is paid on.
Fee lines as per the circulated schedule; the source sheet's VAT arithmetic corrected where it slips. Market data, API subscription and listing income sit outside this per-trade schedule and compound the same volume argument.
07 · WHY THIS HOLDS
The enabler, then each condition and its mechanism
Reuse across brokers is lawful as regulated reliance, not automatic portability, and platform-designated brokers are an already-licensed pattern. Counsel to confirm before this leaves the group.
THE ENABLER
SEC Rule 67 (2021): the digital sub-broker category
The SEC's 2021 amendment to Rule 67 defines the “sub-broker serving multiple brokers through a digital platform”, with its own capital, documentation and conduct requirements. This is the licence category under which platform-designated brokers already operate at scale in Nigeria: Chaka held the first digital sub-broker licence, Bamboo trades Nigerian equities through Lambeth Capital as partner broker, and Risevest offers NGX trading on Chaka's licence. Users on those platforms never choose a broker; the platform's designated broker is accepted at signup. The construct on this page is that same licensed pattern, upgraded with a panel, a published allocation rule, and an explicit client-agreement tap. Registration comes before launch: the 2021 enforcement action against unregistered platforms is the other half of the precedent.
THE FRAMEWORK
SEC three-tiered KYC (Rules and Sundry Amendments, June 2017)
The tier ladder this design runs on is not ours; it is the Commission's. The June 2017 rules adopt a three-tiered KYC framework for all Capital Market Operators, expressly for financial inclusion: Level 1 opens with basic details and no documentary evidence, capped at ₦20,000 a deposit and ₦200,000 cumulative; Level 2 lifts the caps with verification; Level 3 is uncapped under full KYC. Two clauses do real work here. Operators shall migrate accounts upward once balances exceed a cap, which is this object's progressive enrichment written as regulation. And the framework exists to reach exactly the first-time investors this build targets, so the strategy aligns with the rules rather than asking around them. One clause needs counsel: Level 3 speaks of face-to-face opening, so whether BVN plus biometric remote verification satisfies it, or the uncapped tier needs an agent touchpoint or an SEC no-objection, is a named open question, with Level 2 caps as the graceful fallback.
SEC AML/CFT · RELIANCEEach broker remains ultimately responsible for its own CDD.
Per-broker attestation. Brokers never inherit a KYC; each signs its own attestation over the shared evidence. Liability never moves.
SEC AML/CFT · EVIDENCEIdentification data must be producible to a relying party on request, without delay.
Provenance ledger. The hash-chained trail on the object, documents, timestamps, sources, is pullable by any attesting broker at any time.
NDPA 2023 · CONSENTSharing with a new controller needs explicit, specific, informed consent.
The consent hook. Armed on the object at mint, fired as one explicit tap per broker added, captured with scope and timestamp. Withdrawal as easy as grant.
CONTRACT · MANDATEA broker-client relationship needs both parties' consent, not platform fiat.
Standing offer + two acceptances. The panel agreement is the broker's standing offer; the client-agreement tap is the user's acceptance; attestation is the broker's acceptance of this specific client, preserving their right to refuse.
SEC 3-TIER KYC · LEVEL 1 FLOORSimplified accounts may open with basic details and no documentary evidence, under caps.
The fail-safe floor. Every held-for-review state opens as a capped Level 1 account instead of a dead end. Nobody-is-blocked stops being our principle and becomes the Commission's mechanism.
SEC 3-TIER KYC · MIGRATION DUTYOperators shall migrate accounts to the next level once balances exceed the cap.
Progressive enrichment. The object starts thin and grows richer as it is used, because the rules require it to. Tier, class and evidence all deepen on the same object.
