Pension Guidelines for Verification and Enrolment of Prospective Retirees

NATIONAL PENSION COMMISSION GUIDELINES FOR VERIFICATION AND ENROLMENT OF PROSPECTIVE RETIREES OF FEDERAL GOVERNMENT TREASURY-FUNDED MINISTRIES, DEPARTMENTS AND AGENCIES (MDAs)

DECEMBER 2025

Table of Contents 1.0 INTRODUCTION ............................................................................................................... 3

1.1 The Contribution and Bond Redemption Application (COBRA).......................................... 3

1.2 The Legal Framework ....................................................................................................... 5

1.3 Objectives of the Guidelines .............................................................................................. 5

1.4 Definition of Terms ............................................................................................................ 6

1.5 Rules of General Application ............................................................................................. 8

2.0 VERIFICATION AND ENROLMENT PROCESS ............................................................... 9

2.1 MDA Data Upload ............................................................................................................. 9

2.2 Registration of Retiree/NOK of Deceased Employees ..................................................... 11

2.3 Minimum Documentation Requirements .......................................................................... 12

2.4 Appointment of Enrolment and Validation Officers .......................................................................... 14

2.5 Documents Verification by PFA ............................................................................................................. 15

2.6 Retiree/NOK Enrolment by PFA ............................................................................................................ 15

2.7 Registration, Verification & Enrolment of Sick/Incapacitated Prospective Retiree ................ 15

2.8 Original Documents to be Retained ..................................................................................................... 16

2.9 Validation of Retiree Records by PFA ................................................................................................. 16

2.10 ICT Requirements ...................................................................................................................................... 17

3.0 RETIREE RECORD UPDATE ............................................................................................................... 18

3.1 Update Request .......................................................................................................................................... 18

3.2 Authorization ................................................................................................................................................ 18

3.3 Update and Re-submission ..................................................................................................................... 18

4.0 OVERSIGHT FUNCTIONS ..................................................................................................................... 18

4.1 Processing Retirement Benefits ............................................................................................................ 18

4.2 Remittance Schedules to PFAs/PFCs ................................................................................................. 19

4.3 Off-site Review of Enrolment Exercise ................................................................................................ 19

4.4 On-site Target Inspection of PFAs ....................................................................................................... 19

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5.0 MULTIPLE PIN RESOLUTION ............................................................................................................. 20

5.1 Procedure for Resolution of Multiple PIN ........................................................................................... 20

6.0 REPORTS..................................................................................................................................................... 20

6.1 Reports Available to Retiree/MDA ........................................................................................................ 20

6.2 Reports Available to PFA/PFC ............................................................................................................... 21

6.3 Returns to the Commission ..................................................................................................................... 21

7.0 ADMINISTRATIVE SANCTIONS AND PENALTIES ....................................................... 25 8.0 REVIEWS AND ENQUIRIES........................................................................................... 26

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1.0 INTRODUCTION

1.1 The Contribution and Bond Redemption Application (COBRA) The National Pension Commission (the Commission) is saddled with the responsibilities of processing the retirement benefits (i. e. accrued pension rights and outstanding pension contributions) of prospective retirees/retirees of Federal Government of Nigeria (FGN) Treasury-funded Ministries, Departments and Agencies (MDAs). Accordingly, the Commission conducts annual pre-retirement verification and enrolment exercise for prospective retirees of FGN Treasury-funded MDAs scheduled for retirement within the next fiscal year in order to obtain necessary information that would aid determination of their Accrued Rights and outstanding/excess pension contributions for budgetary provision by the Federal Government. To facilitate the enrolment exercise which was hitherto conducted physically across the country, the Commission in 2021, deployed an online Enrolment Application with the capabilities to register, verify and enroll the prospective retirees. The Contribution and Bond Redemption Application (COBRA)

is an upgrade of the earlier Enrolment Application to accommodate additional functions, to be more efficient and provide user friendly interface utilizing the latest technology. A m o n g s t o t h e r functionalities, COBRA has the following functionalities in respect of the enrolment process:

1. Provides an electronic platform for the upload of employment details of prospective retirees/deceased employees’ next of kins (NOKs) by Pension Desk Officers (PDOs) of FGN Treasury-funded MDAs. ii) Provides an application interface for prospective retirees/deceased employees’ next-of-kin (NOK) of FGN Treasury-funded MDAs to register their basic biodata as well as monitor the status of the processing and payment of their retirement/terminal benefits. iii) Provides an interface for the electronic upload of employment documents of prospective retirees of FGN Treasury-funded MDAs by Pension Fund Administrators (PFAs) and any update thereof, (where applicable). iv) COBRA provides a more dynamic and user-friendly interface. v) Provides an application interface for PFAs to enrol prospective retirees by capturing their live facial image and validate retirees’ records as well as submission of the records to the Commission.

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1. Provides an interface for the Commission to process retirement benefits (i. e. compute accrued rights and outstanding/excess contributions) of prospective retirees of FGN Treasury-funded MDAs and issuance of certified and approved schedules for remittance of accrued rights and outstanding/excess contributions to PFAs/PFCs.
2. The application provides end-to-end monitoring of the enrolment processes, payments returns and refunds.
3. Provides an electronic platform for the reconciliation of multiple PINs of employees/retirees of FGN Treasury-funded MDAs.
4. Provides a platform for the upload of Nominal Roll by FGN Treasury- funded MDAs for computation and remittance of pension contributions for period before MDA’s migration to IPPIS. x) COBRA provides static and dynamic reports generation as well as statistical analysis of the uploaded, registered and enrolled contributors.

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1.2 The Legal Framework

1.2.1 Section 15(1) of the Pension Reform Act (PRA) 2014 recognizes the accrued pension rights of employees transiting to the CPS for their past service rendered before the commencement of the scheme. 1.2.2 Section 39(1) of the PRA 2014 mandated the Central Bank of Nigeria (CBN) to establish and manage a Retirement Benefits Bond Redemption Fund (RBBRF) for the payment of Accrued Rights. Furthermore, Section 39(2) of the PRA 2014 mandates the Federal Government to be setting aside minimum of 5% of the total monthly wage bill payable to employees in the Public Service into the Fund. 1.2.3 Section 39(3) of PRA 2014, stipulates that the “Commission shall, by the end of every calendar year, determine the adequacy of the RBBRF against the projected accrued pension liability of the FGN arising from voluntary and mandatory retirements, death of employees in service and advise the Budget Office of the Federation of shortfall if any" for appropriation. 1.2.4 Section 24 of the NDPA sets out key principles governing how personal data must be processed. It requires that data be collected for specified, explicit and legitimate purposes. The section also stipulated that all personal data shall be in compliance with the NDPA 2023 and must implement appropriate security controls including encryption, access restrictions and audit logging. 1.2.5 Pursuant to the above statutory requirements, the Commission carries out annual pre-retirement verification and enrolment exercise for prospective retirees of FGN Treasury-funded MDAs. 1.3 Objectives of the Guidelines 1.3.1 These Guidelines establish uniform set of rules, standards and procedures for the verification and enrolment of prospective retirees of FGN Treasury- funded MDAs. 1.3.2 The Guidelines set out minimum documents to be issued by MDAs to the prospective retirees/deceased employees of FGN Treasury-funded MDAs. 1.3.3 They outline the minimum documentation requirements to be provided by

the prospective retirees/deceased employee’s NOK for verification and uploaded by the PFAs.

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Definition of Terms 1.4 thSerial Term Definition Employees of FGN Treasury-funded MDAs who are due to Prospective Retirees that are funded by the Federal Government Treasury. Pension Desk Officers of FGN Treasury-funded MDAs that Government of Nigeria Treasury-funded MDA for service contributor registration requests by PFAs and issuance of PIN Retirement Benefits Bond Redemption Fund. A Fund Letter of First Appointment PDOs RBBRF LOFA June, 2004. Page of Pension Reform Act 2014 Pension Fund Administrators Contributory Pension Scheme Ministries, Departments and Agencies of Federal Government handle pension matters and liaise with PenCom on same. Past Pension Liability due to a retiring employee of Federal rendered from the Date of First Appointment with the FGN to Employer and Employee Monthly Contributions deducted and remitted into an employee’s Retirement Savings Account. retire that are expected to participate in the pre-retirement verification and enrolment exercise. Employees that are retired and have either enrolled or have delayed their enrolment beyond the expected period Personal Identification Number Enhanced Contributors Registration System. ECRS is an electronic platform deployed by PenCom for the submission of by PenCom. established and maintained by the Central Bank of Nigeria, in line with the provisions of Section 39(1) of the PRA 2014. Certified True Copy. A copy of any of prospective retiree/retiree documents that has been authenticated by his MDA by affixing signature and official stamp on it. PRA 2014 PFAs CPS MDAs Accrued Pension Rights Pension Contributions Retirees PIN ECRS CTC

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TPEN Temporary Personal Identification Number, which is opened by employee that died without opening Retirement Savings FGN COBRA IPPIS prospective retiree/retiree in his records with PFA/MDA. Federal Government of Nigeria Contribution and Bond Redemption Application Integrated Personnel and Payroll Information system DOFA Date of First Appointment EDOR Expected Date of Retirement ROS Record of Service LOI Letter of Introduction an employer with any PFA on behalf of NOK of deceased Account NOK RSA DRE PFC Next-Of-Kin. The alternate contact person provided by Retirement Savings Account Data Recapture Exercise Pension Fund Custodian

1.5 Rules of General Application

1.5.1 The Contribution and Bond Redemption Application (COBRA) shall be the medium through which prospective retirees/retirees of FGN Treasury-funded MDAs shall be enrolled for processing of their accrued rights and outstanding contributions. 1.5.2 Only prospective retirees/retirees that have been recaptured/registered on the

Enhanced Contributor Registration System (ECRS) shall be able to enroll on COBRA.

1.5.3 PFAs shall deploy the required IT Infrastructure across their offices for the verification and enrolment of prospective retirees/retirees of FGN Treasury- funded MDAs as may be specified by the Commission, from time to time. 1.5.4 PFAs shall abide by the Code of Ethics on Business Practices issued by the Commission, and shall respect the confidentiality of sensitive information of prospective retirees/retirees. 1.5.5 PFAs shall comply with the Nigeria Data Protection Act, 2023. PFAs must implement and document appropriate technical and organizational measures to protect personal data processed in connection with this enrolment exercise, and shall maintain a mandate file for each RSA holder (hardcopy or electronic). The retention period for such files shall be as set out in Annex X (Retention Schedule) 1.5.6 PFAs must sight, and where applicable retain, the minimum documents specified by the Commission in Sections 2.3 and 2.6 of these Guidelines during verification and enrolment exercise for prospective retirees/retirees. 1.5.7 MDAs shall provide the required support/IT Infrastructure for the Pension Department/Unit to ensure seamless upload of their prospective retirees’/retirees’ employment details. 1.5.8 MDAs shall provide prospective retirees/Next of Kin all the required documents as outlined in 2.3 below, and as may be prescribed by the Commission from time to time. 1.5.9 Death benefits for deceased and missing employees who did not open a Retirement Savings Account shall only be processed and paid through a TPEN, Temporary Personal Identification Number, which shall be flagged off upon payment of the benefits. 1.5.10 All submissions with regards to dates on COBRA, shall be in the format: DD- MMM-YYYY. Guidelines for the Enrolment of FGN Treasury-funded Retirees Page 8 of 27

2.0 VERIFICATION AND ENROLMENT PROCESS 2.1 MDA Data Upload 2.1.1 Each MDA shall play a critical role in the verification and enrolment process for its prospective retirees. Accordingly, the Commission shall request each MDA to nominate two senior ranking officers to serve as MDA Admin Users on COBRA, who shall have the privilege of creating MDA Users. Specifically, the MDA shall have the following roles and Creation of MDA User Account; responsibilities in the enrolment process: ▪ User Management; Provision of introduction letter and record of service for each prospective ▪ ▪ Upload of List of Potential Retirees/Deceased Employees’s NOK Retiree/Retiree/Deceased Employee’s NOK; Resolution of issues affecting Retirees/NOKs during enrolment exercise; and ▪ ▪ Ensuring that Retirees/NOKs are adequately guided on the required

• documents needed for the online enrolment and verification with the PFA. 2.1.2 First Creation of User Account: MDAs shall forward the details of two officers one (1) of which must not be below the rank of Assistant Director to serve as Admin Users in the format below. Their login details shall be emailed to them via COBRA dedicated email address. COBRA will enable MDA Admin to create other Users for the MDA.

2.1.3 User Management: The designated MDA Admin User shall be responsible for management of other Users such as creating other MDA

Users, deactivating/reactivating MDA Users, resetting Users’ password, assigning roles and any other User Administration.

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xxxxxxxxxxxxxxx Surname of Staff Phone Number Designation xxxxxxxxxxxxxxx xxxxxxxxxxxxxxx xxxxxxxxxxxxxxx xxxxxxxxxxxxxxx xxxxxxxxxxxxxxx xxxxxxxxxxxxxxx MDA Name First Name of Staff Staff ID Email Address

2.1.4 Letter of Introduction and Record of Service for each Retiree: MDA shall issue an Introduction Letter and Record of service detailing bio-data and employment details from date of first appointment to the date of retirement for each prospective retiree. Introduction Letter and Record of Service are part of the mandatory documents required for enrolment

and verification of retiree.

2.1.5 MDA shall adequately assist and guide prospective retirees/NOKs of deceased employees to resolve issues during the process of enrolment and verification exercise. 2.1.6 MDA shall ensure that all its prospective retirees/NOKs of deceased employees are adequately guided and assisted on the required documents needed for self-assisted online registration by the Retiree/NOK and also verification of Retiree/NOK by PFA. Any Retiree with health challenge shall be assisted for online registration and PFA verification, provided the Retiree has medical report issued by a recognized Government hospital. 2.1.7 MDA shall be responsible for downloading the template provided on COBRA and populating same with required prerequisite bio-data and employment details of each prospective retiree/deceased employee. The two (2) templates below shall be available on COBRA for download by the MDA. Template for Prospective Retirees

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SURNAME GENDER CURRENTSTAFFID DATEOFRETIREMEN LEAVEOFABSENCE STARTDATE EMPLOYMENTYEAR EMPLOYERID SURNAME GENDER CURRENTSTAFFID DATEOFRETIREMEN LEAVEOFABSENCE STARTDATE EMPLOYMENTYEAR EMPLOYERID DATEOFBIRTH DATE OF TRANSFER LEAVEOFABSENCE ENDDATE SALARYSTRUCTURE DATEOFBIRTH DATE OF TRANSFER LEAVEOFABSENCE _ENDDATE SALARYSTRUCTURE STEP STEP FIRSTNAME FIRSTNAME DOFA OF SERVICE DOFA OF SERVICE OTHERNAME OTHERNAME PHONE GL PHONE GL RSAPIN RSA_PIN T T CONPSS PU000032A001 PEN100275758211 PEN100000302131 ABDULMUMINI F 80123456789-35 HAPPS CONPSS CONPSSII CONPSSII CONPSSII CONPSSII CONPSSII BOSE IBIWOYE F 80123456789-60 HAPPS CONPSSII CONPSSII CONPSSII CONPSSII CONPSSII ZULAI PU000032A001 PU000032A001 PU000032A001 PU000032A001 PU000032A001 PU000032A001 PU000032A001 JULIANA 22-Nov-1990 PU000032A001 PU000032A001 PU000032A001 PU000032A001 PU000032A001 PU000032A001 1-Jun-1996 2-Sep-1959 9-Sep-1959 SEP2019-35 SEP2019-60 2-Sep-2019 9-Sep-2019

Template for Deceased Employees 2.1.8 MDAs Procedures for uploading list of Potential Retirees/Deceased Employees: MDA shall ensure it adheres to the following procedures for uploading the list of potential prospective retirees/deceased employees: User authorized by MDA to upload the list of potential Retirees, should login to ▪ Download the appropriate Template (Microsoft Excel) applicable to COBRA as MDA User;

• Retirees or Deceased Employees via the Upload/Data Upload menu in Populate the downloaded excel template with the bio-data and employment the MDA Module;
• Ensure that all mandatory fields in the template are correctly populated;details of each Retiree/Deceased Employee; ▪ Ensure the correctness of the Salary Structure, Grade level and Step for
• Ensure that all date fields are populated as date, using the format “DD-MMM-accuracy prior to upload of the Template on COBRA;
• Upload the list using the upload tab in the MDA Module on COBRA;YYYY”; The User must check the “Download Result” tab to confirm the success ▪
• or otherwise of uploaded retirees/deceased employees records; Where the downloaded result showed error(s) identified by COBRA, the User must make corrections and re-upload;

2.1.9 COBRA shall allow MDA User to upload as many times as possible provided there is no duplication of records especially the personal details of the prospective retiree/deceased employee. 2.2 Registration of Retiree/NOK of Deceased Employees 2.2.1 The prospective retirees shall ensure that their complete, accurate and current data has been recaptured and uploaded onto the ECRS in line with the provisions of Section 23(e) of the PRA 2014. This is to ensure the elimination of multiple RSA PINs and uniqueness of the prospective Guidelines for the Enrolment of FGN Treasury-funded Retirees Page 11 of 27

retirees RSA PINs. 2.2.2 Self-Registration: The prospective retirees/NOK of deceased employees shall visit the Commission’s website www.pencom.gov.ng and at the home page click on the Contribution and Bond Redemption Application (COBRA) to access the Retiree/NOK Registration Module. The prospective retirees/NOKs can also access their Registration Module directly through the URL: https://cobra.pencom.gov.ng on their browser.

2.2.3 Following the display of the application (COBRA), the prospective retiree/NOK shall at the top of the page click a button ‘Register’ to

enable the creation of account using the following information RSA PIN, Surname, Email address or phone number and Password. In respect of the NOK, these details must be those of the deceased employee’s. A retiree/NOK must ensure that the email he/she provided for registration is functional and accessible as login and communication shall be via the registered email on COBRA.

2.2.4 NOKs of deceased employees that died without opening a Retirement

Savings Account shall liaise with the deceased’s MDA to open a TPEN, Temporary Personal Identification Number for the deceased employee with any PFA, as retiree/NOK registration shall only be done with a valid RSA PIN or TPEN, as applicable.

2.2.5 Upon successful creation of the account, the prospective retiree/NOK shall log on to the registration portal to complete the fields in the registration forms with the information required i.e. Biodata. The prospective retiree/NOK shall review to confirm that the information provided is correct and complete. The prospective retiree/NOK shall click the submit button to conclude the registration process. 2.2.6 The prospective retiree/NOK may wish to print the Acknowledgement Slip, or save a softcopy on the Mobile Telephone as evidence of registration on the COBRA and proceed to the PFA to complete the

physical verification and enrolment exercise.

2.2.7 Where the prospective retiree/NOK is not able to conduct self- registration, he/she shall approach his/her PFA to carry out the retiree/NOK registration process. 2.2.8 The prospective retiree/NOK shall visit the PFA for physical verification and enrolment with the Originals or CTC of the required documents outlined in 2.3.1 below. 2.2.9 PFA Assisted Registration: PFAs shall assist prospective retiree/NOK that

are unable to complete the online Registration on COBRA. PFAs shall

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guide the prospective retiree/NOK with the steps outlined in 2.2.2 to 2.2.5 above, to ensure the successful registration on COBRA. 2.2.10 PFA shall also check the prospective retiree/NOK biodata details to ensure that the information provided by the prospective retiree/NOK are correct and complete. PFA may provide the prospective retiree/NOK with the evidence of registration on COBRA such as the printed

Acknowledgement Slip.

2.3 Minimum Documentation Requirements 2.3.1 During the enrolment process, PFAs shall ensure that the original/CTC of the following documents are sighted from prospective retirees/NOKs of deceased employees and copies uploaded on COBRA:

Upload Status Letter of First DOFA and LOS. (Police) acceptable, where available. Letter of Introduction (LOI) DG PenCom. It ties retiree to his/her career progression retained by the PFA. detailed employment be retained by the PFA. This is to ascertain the grade Page Record of Service (ROS) Promotion Letter & Payslip as at Promotion Letter & Payslip The highest grade level between these periods is to be adopted. Promotion Letter & Payslip The highest grade level and Mandatory Mandatory of This establishes Appointment/Gazette/Attestation CTC of LOFA is original is not LOI must be addressed to the exit MDA and provides summary. Original must be ROS provides retiree’s history. Original/CTC must To associate the employee with his organization. level and step of the prospective retiree as at 30 June 2004 Copy of Staff ID Card 30 June, 2004 (if applicable) between 01 July, 2004 and and steps of the December 2006 (if applicable) prospective retiree between January 2007 and steps of the prospective December 2009 (if applicable) retiree between these periods is to be adopted. Mandatory Non- mandatory Mandatory Mandatory Mandatory

Upload Status th thPage The highest grade level and retiree between these steps of the prospective steps of the prospective periods is to be adopted. service after 30by FGN treasury-funded between January 2010 and and steps of the Promotion Letter & Payslip December 2015 (if applicable) December 2018 (if applicable) prospective retiree between January 2019 and between January 2022 and applicable) Evidence of Change of Evidence of Transfer of Service Transfer of service to FGN beyond 30applicable) Evidence of Extension of Service (If applicable) Introducing the PDO (In Condition) PDO (In case of Critical Health Condition) Letter of Acceptance of Mandatory Mandatory Mandatory Mandatory Mandatory Mandatory Mandatory of June 2004 is June 2004 Medical Report must be from a Government Hospital steps of the prospective periods is to be adopted. The highest grade level and retiree between these periods is to be adopted. The highest grade level and retiree between these This is to ascertain the grade level and step of the prospective retiree as at enrolment Acceptance of transfer of MDA is deemed invalid. December 2012 (if applicable) prospective retiree between these periods is to be adopted. between January 2013 and Promotion Letter & Payslip The highest grade level between January 2016 and and steps of the between these periods is to be adopted. Promotion Letter & Payslip December 2021 (if applicable) December 2024 (if Last Promotion Letter & Pay slip (Current) (if applicable) Name (if applicable) (if applicable) treasury-funded MDA not recognized. Evidence of Acceptance of Transfer of Service (if Letter from the MDA case of Critical Health Medical Report (if applicable) Retirement or Disengagement Copy of Staff ID Card of the Promotion Letter & Payslip Mandatory Mandatory Mandatory Mandatory Mandatory Mandatory Mandatory Promotion Letter & Payslip The highest grade level

2.4 Appointment of Enrolment and Validation Officers 2.4.1 In the minimum, PFAs shall appoint in each of their offices/branches/service centres two (2) officers of different rank to carry out the verification and enrolment of retirees/NOKs. The lower ranking officer (i. e. PFA Enroller) shall be responsible for verification of retiree/NOK documents and enrolment of the retiree/NOK on COBRA. 2.4.2 The higher ranking officer (i. e. PFA Supervisor) shall review and validate the retiree’s/deceased employee’s records enrolled on COBRA, prior to submitting to PenCom Module. 2.5 Documents Verification by PFA 2.5.1 PFAs shall have access to view and edit the records/information of the prospective retirees/NOKs already registered on COBRA. PFAs shall ensure that the prospective retiree/NOK presents all the required documents in line with 2.3.1 above. PFAs shall not collect or accept incomplete documentation from prospective retirees/NOKs as COBRA does not allow incomplete documentation. 2.5.2 PFAs shall sight the Originals or CTC of all the required documents in line with 2.3.1 above, presented by the prospective retiree/NOK. PFAs shall crosscheck the documents provided to ensure that the names therein align with the prospective retiree’s/deceased employee’s biodata. 2.6 Retiree/Next-of-Kin Enrolment by PFA 2.6.1 PFAs shall scan and upload the prospective retiree’s/deceased

employee’s documents, both mandatory and conditionally mandatory (where applicable) on COBRA and must ensure that the scanned documents are clear, readable, complete and correct.

2.6.2 PFAs shall ensure that the prospective retiree’s/deceased employee’s

employment information being inputted/captured on COBRA align with the

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Upload Status disengaged before their Letter of confirmation of period This is to establish university system (for Professors with relevant and PRA 2014. enrolment date) of continuous service in the eligibility of University Professors) Sections of UMPAA 2012 Mandatory (for those who retired or

information on the documents, while the scanned documents being uploaded are complete and tally with the hard copies presented. 2.6.3 Upon confirmation of the above, the enrolment officer shall proceed to capture the retiree/NOK. In this regard, PFAs shall capture a facial image (live image) and an electronic signature of the prospective retiree/NOK on COBRA. In addition, PFAs shall capture the electronic

signature of the prospective retiree/NOK on COBRA.

2.7 Registration, Verification and Enrolment of Sick/Incapacitated Prospective Retiree 2.7.1 The Next-of-Kin (NOK) of a critically health challenged prospective retiree

shall inform the Pension Desk Officer of the condition that would prevent the physical appearance of the prospective retiree for verification and enrolment exercise. The PDO shall proceed to upload the details of the sick/incapacitated prospective retiree as specified in 2.1.6 to 2.1.8 above.

2.7.2 The NOK shall visit the Commission’s website www.pencom.gov.ng and register on COBRA as outlined in 2.2.2 to 2.2.7 above. 2.7.3 Upon the successful registration of the details of the sick/incapacitated prospective retiree, the PDO/NOK shall proceed to the PFA with the evidence of registration on COBRA such as Acknowledgement Slip. 2.7.4 The registration, verification and enrolment of sick/incapacitated prospective retiree shall be accompanied with the following additional documents: Original Medical Report from a recognised Government Hospital and Original MDA Letter stating that the prospective retiree is

sick/incapacitated and unable to appear physically for the enrolment exercise.

2.7.5 PFA shall, having satisfied with all the conditions in 2.5.1 to 2.5.2 above, enrol the sick/incapacitated prospective retiree on COBRA. PFA shall

capture the live photograph of the PDO on behalf of the sick/incapacitated prospective retiree who is unable to physically appear for biometrics (photograph capturing) based on critical medical condition. The record shall be tagged “Health Challenge”.

2.7.6 In addition to PDO live photograph, the PFAs shall also upload certified recent passport photo of retiree and the reverse side duly certified by NOK/MDA, as a level validation Guidelines for the Enrolment of FGN Treasury-funded Retirees Page 16 of 27

2.8 Original Documents to be Retained by PFA

2.8.1 PFAs shall, in respect of each enrolled prospective retiree/deceased employee, keep custody of electronic and hard copies of the Original of Record of Service, Letter of Introduction and, where applicable, the Medical Report from a recognized Government Hospital and MDA Letter on the condition of the sick/incapacitated prospective retiree. 2.8.2 PFAs shall ensure that the Original Copies maintained in 2.8.1 above, are stored in a safe, secure and conducive environment and shall also put in place adequate arrangement to ensure that the Original Copies are protected against loss, damage or alteration. 2.8.3 In addition, access to the stored Original Records shall be restricted and tightly controlled and documented while ensuring that the Original Records are easily retrievable. The hard copies of the Original Records shall only be retained by PFAs for the period specified by the Archival Laws of the Federal Government of Nigeria. 2.9 Validation of Retiree/Deceased Employee Records by PFA 2.9.1 Upon successful completion of retiree/NOK enrolment, PFAs shall assign officers (mentioned in 2.4.2 above) to carry out first-level review and validation of enrolled retiree’s/deceased employee’s records on COBRA. Validation officers shall ensure that all bio-data and employment information captured by the Enrolment officer in respect of each enrolled prospective retiree/deceased employee are complete and correct and are supported by documents uploaded. 2.9.2 Where there is any inconsistency between the information captured and what is indicated on the documents, the Validation officers shall amend the information as may be appropriate. Validation officers shall review and ensure that documents uploaded are clear, legible, correct and properly scanned unto COBRA. 2.9.3 Upon completion of the validation successfully, validation officers shall submit the retiree records to the PenCom Module on the COBRA for further processing. 2.10 Minimum ICT Requirements for PFAs and MDAs 2.10.1 PFAs shall ensure deployment of adequate IT infrastructure in all their branches that shall support seamless enrolment exercise for prospective retirees/NOKs of deceased employees. In this regard, PFAs shall have the following minimum ICT requirements in all their branch offices for Guidelines for the Enrolment of FGN Treasury-funded Retirees Page 17 of 27

enrolment purpose: Desktop/Laptop Computer with minimum Hard Disk free space of 50GB and ▪ minimum RAM of 8GB; USB Web Camera(s); ▪ Document Scanner(s); ▪ Document printer(s); and ▪ Internet/LAN Access. ▪ E-Signature Pad ▪ Updated Antivirus Software ▪ Active Firewalls ▪ Data Encryption for stored and transmitted information Daily Automated Backups across all devices and networks used for enrolment ▪▪ and data processing Bio metric scanner ▪

2.10.2 PFAs shall provide and ensure at all times adequate storage facilities that would allow for scalability as may arise from time to time. 2.10.3 In order to fulfill their critical role of uploading retirees’/deceased

employees’ biodata and employment details in the enrolment process, MDAs shall also ensure that the following minimum IT equipment are Laptop/Desktop Computer (At Least 8GB RAM, 1TB Hard Disk);provided for the Pension Unit/Office: ▪ Microsoft Office tool; and ▪ Dedicated Internet Service. ▪

2.10.4 MDAs shall ensure regular targeted training of their relevant officers who are handling the enrolment process on Computer appreciation and other relevant areas that shall build their capacity and ensure their optimal performance in the enrolment process. 2.10.5 The Commission shall review the minimum IT infrastructure requirements from time to time and PFAs and MDAs shall meet the minimum ICT requirements set by the Commission. Guidelines for the Enrolment of FGN Treasury-funded Retirees Page 18 of 27

3.0 RETIREE RECORD UPDATE

3.1 Update Request 3.1.1 PFA shall be able to request for amendment of submitted records of prospective retirees/deceased employees whom they have completed their enrolment and validation. COBRA shall allow multiple requests from PFA for amendment on a record yet to be validated by the Commission. 3.1.2 Where a prospective retiree’s/deceased employee’s record has been validated by the Commission, such record shall be unavailable for amendment and PFA shall contact the Commission to bring to the attention of the Commission for further action. 3.1.3 PFAs shall only be allowed amendments of prospective retirees’ records in editable data fields and update of document(s). 3.2 Authorization 3.2.1 The Commission shall receive and review all requests for amendment submitted by PFAs through COBRA, if the records have not been validated by the Commission. 3.2.2 Upon review, the Commission shall approve or reject such requests for

amendments and where a record is rejected/not approved for amendments, the Commission shall provide a reason(s) for such decision.

3.3 Update Re-submission 3.3.1 Upon approval of a request, the prospective retiree/deceased employee record shall automatically be open to the PFA for editing. Upon completion of the amendment of editable fields and/or upload of document, the PFA shall save the amended record and the application shall restrict editing of any field after saving. 3.3.2 However, PFA may be allowed to make another request for amendment of the same record, where cogent reason(s) are provided by the PFA. Records authorized/approved for amendment(s) by the Commission shall be re-submitted within two (2) working days by the PFA. Guidelines for the Enrolment of FGN Treasury-funded Retirees Page 19 of 27

4.0 OVERSIGHT FUNCTIONS

4.1 Processing of Retirement Benefits 4.1.1 Upon completion of enrolment and validation, PFAs shall submit the enrolled record to PenCom Module on COBRA. The Commission shall

validate the retiree’s records and, where there are issues that require further action by the PFA, the Commission shall return the record to the PFA’s portal.

4.1.2 Where the retiree’s/deceased employee’s record is validated successfully, the Commission shall proceed to process the retirement/death benefits of the retiree/deceased employee 4.2 Remittance Schedules to PFAs/PFCs 4.2.1 Subject to availability of funds, the Commission shall issue remittance schedules to PFAs and PFCs in respect of retirees/NOKs of deceased employees whose retirement/death benefits have been processed by the Commission. 4.2.2 All remittance schedules for accrued rights and outstanding/excess contributions shall be issued to respective PFAs and PFCs through COBRA and PFAs shall be required to credit the Retirement Savings Accounts of the affected retirees within 48 hours of receipt of funds in their accounts. 4.3 Off-site Review of Enrolment Exercise 4.3.1 On COBRA, the Commission shall closely monitor and supervise the enrolment process and documents being uploaded by the PFAs as well

MDAs’ upload of prospective retirees’/deceased employees’ employment details and retiree/NOK registration.

4.3.2 Where necessary, the Commission shall engage any of the relevant stakeholders on the portal on areas of concern or issues of violation of the enrolment process. 4.4 On-site Target Inspection of PFAs 4.4.1 The Commission shall, in addition to the routine examinations, conduct target inspection of any of the branches of the PFAs to ascertain deployment of the minimum IT infrastructure specified in 2.10.1 above as well as PFA adherence to the stipulated procedures and standards during the enrolment exercise. Guidelines for the Enrolment of FGN Treasury-funded Retirees Page 20 of 27

4.4.2 The Commission may, from time to time, call for the Original Copies of the required documents retained by PFAs in 2.8.1 above of any prospective retiree/retiree and shall also carry out spot checks on the PFA offices to ascertain maintenance of the Original Records by the PFAs, as required in 2.8.2 and 2.8.3 above. 5.0 MULTIPLE PIN RESOLUTION FOR FGN TREASURY-FUNDED MDAs 5.1 Procedure for Resolution of Multiple PIN 5.1.1 Employees/retirees of FGN Treasury-funded Ministries, Departments and Agencies with multiple RSA PIN shall only be able to resolve such multiple registrations when he/she has done the Data Recapture Exercise (DRE) on ECRS with any of the PINs of his/her choice. 5.1.2 Notwithstanding 5.1.1 above, where an RSA holder had retired with one of the multiple PINs prior to the request for merger of the PINs, then such PIN becomes his/her valid PIN and he/she must undergo DRE with the PIN. Where the retiree had recaptured with the invalid PIN, the Commission will invalidate the data recapture to enable the retiree recapture with the valid PIN. 5.1.3 The Commission shall carry out a reconciliation exercise of the remittances of pension contributions made into the multiple PINs. In carrying out the reconciliation, PFAs shall be required to provide information on the balances in the invalid PINs to the Commission to ascertain remittances made by the Commission and investment income earned for the period as well as remittances made from other sources, as indicated in the Template provided for transaction history of the invalid PIN. 5.1.4 PFAs shall ensure that the transaction history of the invalid PIN provided to

the Commission is complete and accurate as requested in the template.

5.1.5 The Commission’s policy on reconciliation of multiple RSA registrations is that where the PINs are funded, the RSA balances in the invalid PINs shall be refunded to the Contributory Pension Account domiciled with the Central Bank of Nigeria. Where the PIN(s) is/are unfunded, the Commission shall carry out reconciliation exercise on the PINs. 5.1.6 The outcome of the reconciliation shall be communicated to the PFA of the

invalid PIN by the Commission and the PFA shall notify the RSA holder that his/her RSAs have been reconciled. Depending on the outcome of the reconciliation exercise, the RSA holder may be required to liaise with his/her employer to submit his/her nominal roll for the period prior to date Guidelines for the Enrolment of FGN Treasury-funded Retirees Page 21 of 27

of migration of his/her MDA to IPPIS platform to the Commission.

6.0 REPORTS 6.1 Reports Available to Retiree/MDA 6.1.1 The following reports shall be available to the MDA Users: i. List of potential retirees per period; and ii. List of enrolled retirees per period iii. List of retirees not yet registered

1. List of retirees not yet enrolled v. Status of Retirees Enrolment. 6.1.2 Upon registration, a retiree/NOK shall view and download his/her acknowledgement slip, and when subsequently enrolled, he/she can track the processing of his/her retirement/death benefits and receive email notification from COBRA on remittance of his/her retirement/death benefits. 6.2 Reports Available to PFAs/PFCs 6.2.1 The following reports shall be available to the PFA Users on COBRA: i. Summary of Registered Retirees ii. Detailed List of Potential Retirees by Period of Retirement; iii. Summary of Potential Retirees per MDA; iv. Summary of Potential Retirees by Period of Retirement; v. Summary of Potential Retirees by Month of Retirement. vi. Detailed List of Retirees yet to complete enrolment; vii. Detailed List of Enrolled Retirees; and viii. Summary of Enrolled Retirees. ix. List of computed RSAs with details of payments 6.2.2 PFAs shall analyze the reports and ensure that they encourage their clients that are due to retire to participate in the enrolment exercise within the stipulated timeframe by the Commission. Specifically, PFAs shall contact potential retirees uploaded by MDAs but yet to register and/or registered retirees that are yet to enroll, to visit any of their nearest branches to undergo the enrolment exercise. Guidelines for the Enrolment of FGN Treasury-funded Retirees Page 22 of 27

6.2.3 In respect of reports available to PFCs, the PFCs shall view and download

all payment schedules of accrued rights and outstanding/excess contributions, in respect of PFAs they provide custodial services to.

6.3 Returns Rendition to PenCom 6.3.1 PFAs shall render returns to the Commission through COBRA. In addition, the Commission shall also generate reports from the Retiree Registration Module Submissions, the MDA Module Submissions and the PFA Module Submissions. All reports shall be generated in PDF and/or MS Excel format and shall also allow download/export for all fields. All reports shall be available to the PenCom Module, which shall include the following: 1. Retiree Registration Report; 2. List of registered retirees by Organization Sector; 3. List of registered retirees by period of retirement; 4. Summary of registered retirees by MDA; 5. Summary of registered retirees per PFA; 6. Summary of registered retirees per PFA per MDA; 7. Summary of registered retirees by period of retirement; 8. Summary of registered retirees by month of retirement; 9. Summary of registered retirees by year of retirement; 10. Summary of registered retirees by year of registration. 11. MDA Submission Report; 12. List of potential retirees per MDA; 13. List of potential retirees by period of retirement; 14. Summary of potential retirees submitted by MDAs; 15. Summary of potential retirees per PFA per MDA; 16. Summary of potential retirees by period of retirement; 17. Summary of potential retirees by month of retirement. 18. PFA Submission Report (Enrolment); 19. List of retirees yet to complete enrolment (all PFAs); 20. List of retirees yet to complete enrolment (per PFA); 21. List of enrolled retirees per MDA; 22. List of enrolled retirees (per PFA); Guidelines for the Enrolment of FGN Treasury-funded Retirees Page 23 of 27

1. List of enrolled retirees by Organization Sector; 24. Summary of enrolled retirees by MDA 25. Summary of enrolled retirees per PFA; 26. Summary of enrolled retirees by period of retirement; 27. Summary of enrolled retirees by month of retirement; 28. Summary of enrolled retirees by year of retirement; 29. Comprehensive enrolment records; 30. Comprehensive enrolment records for the computation of accrued right; 31. Comprehensive enrolment record for the computation of outstanding contribution; 32. List of sick/incapacitated retirees; 33. List of enrollees that are in “Yet to be Paid” database of the Commission; 34. List of enrollees with validation issues; 35. Comprehensive report of validated records; 36. Reports of validations by validators; and 37. Summary of enrolment exercise.

Guidelines for the Enrolment of FGN Treasury-funded Retirees Page 24 of 27

7.0 ADMINISTRATIVE SANCTIONS AND PENALTIES

7.1 The Commission shall impose administrative sanctions on PFAs for violating

the procedures and requirements set out in these Guidelines, as specified in Sections 7.2 to 7.14 of these Guidelines.

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S/No. Description of Infraction Monetary Penalty for Non -Compliance N 50,000 per record. N 50,000 per record. N 100,000 per N 50,000 per record. N 50,000 per retiree. N 100,000 per retiree N 100,000 per 7.12 7.7 retiree/retiree/Deceased valid and confirmed Mandatory N 100,000 per N 50,000 per RSA N 500,000 one-off for N 100,000 per TH. N 500,000 one-off. 7.10 7.14 7.2 7.4 7.8 7.11 7.13 7.3 7.9 N 100,000 per 7.6 7.5 Introduction Letter. documents Upload of unclear/illegible/incomplete documents on COBRA. Upload of wrong document for a retiree. unable to do so on COBRA. retiree. accrued rights and/or outstanding contributions. daily until uploaded Non-deployment of specified minimum IT infrastructure to support the enrolment exercise/process the period of the Failure to collect Original copies of Record of Service and Failure to collect Original of Medical Report, MDA Letter on condition of sick/incapacitated retiree. retiree. Failure to assist prospective retiree with registration who is Failure to provide information on Branch Offices to prospective retirees for enrolment exercise. per week. Non-compliance with the Guidelines on Data Protection and Privacy in the enrolment process. retiree. Non-upload of report on COBRA on RSAs credited after receipt of retiree. Account domiciled at CBN Submission of wrong/misleading information/validation/report. Submission of wrong/misleading information on RSA transaction history for reconciliation of Multiple PINs Delay in refund of recalled funds into Contributory Pension examination. Failure to scan and upload Original/CTC of prospective 8.0 REVIEWS AND ENQUIRIES

8.1 Reviews 8.1.1 These Guidelines shall be subject to periodic reviews by the Commission in line with prevailing conditions as and when the need arises. 8.2 Enquiries 8.2.1 A helpdesk has been created at the Commission to attend to all enquiries and complaints by PFAs, PDOs and prospective retirees on the enrolment process. The contact details of the helpdesk are as follows:

• Email address: cbrd@pencom.gov.ng Telephone Numbers:(0700-225-573-6266) +23494603930 ▪ 8.2.2 All enquiries regarding these Guidelines shall be directed to: The Director General National Pension Commission

174, Adetokunbo Ademola Crescent Wuse II Abuja, Nigeria

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