NASD OTC Securities ExchangeA Self-Regulatory Organisation, registered with and
regulated by the Securities and Exchange Commission, Nigeria
NASD NEXT · GATE SERIES · VOLUME 04 OF 06 · RESOLUTIONS & FAILURE MODES

What we resolve as we work: failures and open decisions

v2 · 22 Jul 2026 · volume 04 · the working register · twelve failure entries, budgeted · companions: 01, 02, 03, 05
THE LOGIC WE ARE AIMING FOR

Launching on time means resolving in parallel, not discovering in sequence. This book holds both halves of that: the failure catalogue (budgeted, bounded, honest) and the resolution register, every open decision across the three layers, each with an owner and a track.

Below: the resolution register first (what we are resolving as we work), then the severity ladder and the twelve-entry failure catalogue (what we are protected against while we do).
THE RESOLUTION REGISTER

Open decisions, merged across all three layers

The exchange PRD's open-decision register and the substrate's counsel list, merged and deduplicated. Several of one document's questions are answered by the other; those are marked resolved-by-plan and close at Friday's alignment.
RESOLVED BY THE PLAN · CLOSE FRIDAY

Answered across documents

MINIMUM KYC SETThe SEC three-tier framework (Jun 2017): Trade Ready = L1/L2 under caps; Full KYC = L3. The caps are the risk budget.
BROKER RELIANCEReliance-not-portability legal read + per-broker snapshot attestation + Rule 67 digital sub-broker as the licence category.
TRADE NOW FAIRNESSPublished allocation formula, open panel enrolment, cost never dominant. SRO neutrality by rule, not assertion.
AI CONTROLSLaws applied to models: inference reads/writes on the ledger, honest state on automated holds, deterministic lawful fallbacks, tiered in-jurisdiction infrastructure (Gate Series 01).
COUNSEL TRACK

Legal resolutions in flight

L3 FACE-TO-FACEWhether BVN + biometric remote verification satisfies Level 3 opening, or an agent touchpoint / SEC no-objection is needed. Fallback: L2 caps.
CLIENT-MONEY STRUCTURELicensed entity holding client money, account structure, safeguarding rules. Exchange PRD item; joint with commercial track.
SETTLEMENT FINALITYLegal meaning of instant availability vs finality; prefunding/guarantee options.
MARGIN LENDING POSTURECredit-layer regulatory classification (CBN/SEC), adverse-action explainability for LTV decisions, framed as collateral registration per the credit deck's own mitigation.
DATA ROLESController/processor split across NASD, Bvndle, VBank; cross-platform consent under NDPA/GAID.
CSCS TRACK

Depository resolutions in flight

LOOKUP + CREATIONIdentifiers, legal basis, API semantics, and whether CSCS acknowledgement suffices for order entry or final creation is required.
LIEN APIReal-time placement/release semantics for the credit layer; instant placement vs T+2 enforcement stated honestly in product copy.
DIRECT CASH SETTLEMENTIntegration, bank-verification rules, user mandates for withdrawal.
COMMERCIAL TRACK

Terms papered before launch

PANEL TERMSParticipation agreement: SLAs, reliance, liability, pause switch, allocation formula publication, minimum panel size.
RELATED-PARTY RAILSVBank cash node and the inference substrate: priced, papered, governed openly. Fee schedule, tax and payout timing per the fee engine.
HOW TO THINK ABOUT SAFEGUARDING IT

How failures are contained

The design pre-spends its risk: caps bound the money, snapshots bound the liability, hooks bound the data, honesty bounds the trust damage. Safeguarding is keeping every failure inside its budget.
SEV LADDER

What outranks what

SEV-1Identity integrity: two objects for one BVN, chain tamper, attestation forged. These threaten the thing everything else stands on.
SEV-2Funds and custody: rebind takeover, cap enforcement failure, exit-ramp breach.
SEV-3Availability: NIBSS, store, rails, panel. Painful, bounded, survivable, because the discipline below holds.
THE DISCIPLINE

One split, one direction

THE SPLITOnboarding fails closed · trading fails open · display fails cached. Different paths earn different failure rights.
THE DIRECTIONUnder stress the system sheds speed, never legality. The degraded mode is always the slower lawful path.
THE PATTERNEvery response below is the same five beats: detect → bound → tell the truth → take the lawful path → ledger it.
THE CATALOGUE

The catalogue: twelve failure modes

F1 · NIBSS UNREACHABLE · SEV-3

Minting pauses, honestly

BOUNDED BYFail-closed mint; existing users untouched
RESPONSEVisible retry state with a working retry. Never open accounts on self-declared data: BVN is the dedupe key and the one-account rule dies without it.
STATE SHOWN“Identity checks are briefly delayed on the national rail. Your details are safe; retry shortly.”
F2 · STORE DEGRADED · SEV-3

Split the paths

BOUNDED BYStrong consistency on provenance writes only
RESPONSEMint pauses (closed) · attested users trade on broker rails (open) · reads serve cached with stale stamps (cached)
F3 · DUPLICATE BVN / CONCURRENT MINT · SEV-1

One object, always

BOUNDED BYIdempotent mint resolution
RESPONSESecond session → account recovery. Two objects for one BVN is a sev-1 data event, not a ticket.
F4 · SCREENING STALLS OR FAILS POST-L1 · SEV-2

The caps do their job

BOUNDED BY₦200k cumulative, by the regulator's own rule
RESPONSEStall: truthful countdown at L1; chronic breach feeds allocation weighting. Fail: FROZEN-AT-L1 → exit ramp R6.
F5 · CHN PIPELINE STALLS · SEV-2

The systemic one

BOUNDED BYCircuit breaker holds new users at L1 caps: bounded trapped value
RESPONSESETTLING countdown switches to real queue times. This is the original funding wall one gate right; the breaker exists so it can never silently recur.
STATE SHOWN“Your market number is queued at CSCS; the queue is running at N days. Buying stays open under your limits.”
F6 · REBIND ATTACK · SEV-2

The worst headline

BOUNDED BYEnrolled-template liveness, cooling window, step-up
RESPONSESuspected takeover freezes withdrawals, never market data. Comms within the hour: honest state applies to incidents too.
F7 · EVIDENCE API ABUSE · SEV-2

The exfiltration channel

DETECTA broker pulling more trails than it has clients, the simplest alarm in the book; plus grant checks, rate ceilings, watermarks
RESPONSEGrant suspension, pause switch, read-ledger extract to both compliance officers
F8 · INSIDER ACCESS · SEV-1

Watch the watchers

BOUNDED BYTokenised index, separately-keyed vault, HSM keys: leaking the index does not leak the vault
RESPONSEInternal reads sit on the same ledger; anomaly review over internal principals
F9 · PANEL EXHAUSTED · SEV-3

Nowhere to allocate

BOUNDED BYMinimum panel size as contract (C1), capacity signalling
RESPONSEBelow minimum: minting continues to OPEN, attestation queues with a truthful ETA
F10 · VBANK RAIL DOWN · SEV-3

Money pauses, market does not

RESPONSEFunding and cash-out pause with honest status; trading intact. One honest rail beats a hasty second rail that breaks the funding-source rule.
F11 · PANEL AGREEMENT CHALLENGED · SEV-2

The legal outage

BOUNDED BYThe drilled fallback
RESPONSEExplicit choose-your-broker flow takes allocation's place: slower, lawful, rehearsed quarterly
F12 · CHAIN TAMPER SUSPECTED · SEV-1

Anchors answer

DETECTRoot mismatch vs published, broker-witnessed anchors
RESPONSEQuarantine range, re-verify attestations against broker-held copies, disclose per runbook. The witnessed root makes this provable, not arguable.

Review rule: a proposed feature names which entries it can trigger and which budget it spends. A feature with no failure entry is a feature not yet designed.