Nigeria is a populous country with abundant natural resources, despite this, it has witnessed an exodus of international companies in the last few years. Nigeria is currently ranked 131 out of 190 economies in the World Bank ease of doing business index. This ranking is based on the friendliness of a country’s regulatory environment towards business operations. The success and growth of places like Stockholm, Delaware, and the Cayman Islands are linked to well-developed corporate infrastructures that support business operations and management. This rating shows a need to revamp Nigeria’s regulatory climate.
The Business Facilitation Act (BFA) is a miscellaneous provision that was enacted to simplifies business-related laws and streamline processes in government agencies. As a catch-all law, the BFA amends and modifies provisions in twenty-one existing laws. Our review focuses on the digitization of Ministries, Departments, and Agencies (MDAs), and thirteen (13) business-related laws, by highlighting the impact of the changes on Nigeria’s regulatory and business landscape.
DIGITIZATION OF MINISTRIES, DEPARTMENTS AND AGENCIES
The official websites and social media accounts of many ministries, departments, and agencies (MDAs) in Nigeria provide the public with general information on the MDAs, but only a few have fully automated their processes. Consequently, manual handling of applications, client relations, negotiations, and contracting is still prevalent. However, the BFA’s mandate to the MDAs is aimed at completely digitizing their operations, which is expected to improve their efficiency, reduce costs, enhance user experience, and promote a business-friendly environment in Nigeria.
Below are the mandates:
Transparency Requirements : Each MDA is required to publish on its website or make available at the customer help desk a list of requirements (documents, fees, timelines) to access their service or product. In an event of a conflict between a published list and an unpublished list, the published list shall prevail. MDAs are now required to maintain a register of all applications.
Default Approvals: Every MDA is to communicate to an applicant if an application has been approved or denied, within the timeline stipulated in the published list. Where the MDA fails to communicate approval or rejection of an application within the time stipulated in the published list, the application shall be deemed approved and granted. The applicant may then apply for a certificate as evidence of the grant, which must be issued within 14 days of the request. This clause will put MDAs on a schedule and end unjustified delays.
One Government Directive: Where an applicant requires services from an MDA that requires confirmation or approval from other MDAs, the MDA is to collaborate with the other MDA to conduct necessary verification or certification. By this provision, an applicant will no longer have to approach each MDA individually to get approvals.
Service Level Agreements: Every MDA shall publish its Service Level Agreement (SLA) on its website, which shall be binding on the MDA. This would promote transparency by ensuring that parties to a contract are aware from the start of the contract’s terms, timeliness, documentation requirements, approval method, redress mechanism, and other details pertinent to the application.
Communication modes : MDAs shall maintain at least two preferred modes of communication, which are to be published on the websites. It would guarantee effective communication with the general public and help the general public check information, particularly false information, or information from unreliable sources.
Registration of Businesses: Within 14 days of the Act, all application processes at CAC must be entirely automated from beginning to end. This clause focuses on CAC’s post-incorporation services, which were not entirely automated at the time the BFA was enacted.
AMENDMENTS TO BUSINESS-RELATED LAWS
The business and investment growth of a nation is significantly influenced by its regulatory environment. Certain laws in Nigeria no longer reflect the country’s economic reality. With the passage of the BFA, several laws were amended to cover the gaps in legislative oversight caused by the changing economic environment. We examined thirteen business-related laws below:
A. COMPANIES AND ALLIED MATTERS ACT, 2020
Exemption from Registration: Under Section 78(3) of the Companies and Allied Matters Act, 2020 (CAMA 2020) foreign companies intending to carry on business in Nigeria must be registered, unless exempted prior to the Act, or under any treaty in which Nigeria is a party, or by the Minister. The BFA has now introduced exemptions from registration that may be granted under “any other acts of the National Assembly”. To address economic and commercial needs, the legislature may make a law exempting a foreign company from registration under the BFA regime.
Increase of Share Capital:Prior to the BFA, a company could only increase its share capital by allotment of new shares at a general meeting. With the BFA, a company can now increase its issued share capital by a resolution of the board of directors subject to any conditions imposed in the articles of association, by the members in a general meeting. Power to increase share capital can now be exercised by the Board, and the company need not convey a general meeting to pass a resolution to increase the share capital of a company.
Pre-emptive rights :The law before the BFA was that existing shareholders of private and public companies had pre-emptive rights over newly issued shares, and this right can be exercised within a reasonable time of the offer. The BFA has now restricted the rights to only shareholders of private companies and limited the timeline for accepting the offer to 21 days, otherwise, it would be deemed declined.
Power to allot shares: Under the CAMA, only the company itself has the authority to allocate shares. However, in the context of a private company, the authority to allocate shares may be delegated to the company’s directors, as long as it aligns with the company’s articles of association and adheres to the guidelines established by the members in general meetings. The BFA substituted the provision of CAMA on the rights of the company or the directors of a private company to allot shares, by stating that a director cannot exercise an option to allot shares of a company (whether it is a private or public company) unless the board of directors has been specifically given permission to do so by the company’s articles or at the general meeting.
Return on allotment: The BFA reduced the timeline for making returns on the allotment of shares from one month to 15 days. This means that when a company makes an allotment of shares, the return on allotment must be filed with the Corporate Affairs Commission within 15 days of the allotment.
Electronic Share certificate: There was no specification on the format of a share certificate prior to the BFA. The CAMA simply stipulated that a share certificate be ready for delivery within two months of allotment and three months of the transfer of shares. With the BFA, the share certificate can be issued either in physical or electronic form. This would save cost and time of printing and physical delivery, especially for foreign investors.
Certificate of Transfer: Prior to the BFA, a shareholder wishing to transfer a part of his shares shall deliver the instrument of transfer and certificate to the company with a request that the transfer be recognized and registered, and a certificate of transfer shall include a certificate issued in electronic form. The BFA substituted the marginal note of the section from “certificate of transfer” to “instrument of transfer”, and amended the expression certificate of transfer, to read instrument of transfer.
Priority Rights of Fixed Charge: According to section 207(4) of CAMA the holder of a fixed charge has absolute priority rights over other debts of the company, including preferential debts. With the implementation of the BFA, section 207(4) is now subject to section 204 of CAMA, which states that a fixed charge holder will lose its priority rights if the terms of issuance of the floating charge prohibit the company from granting any later priority rights over the floating charge, and the holder of the later charge had notice of this term. A person is deemed to have notice of the prohibition if the notice of the prohibition is registered with the Corporate Affairs Commission.
Electronic General Meeting: Only private companies were allowed to conduct their general meetings electronically under the CAMA. With the BFA, all companies can now hold their general meetings electronically provided it is conducted in accordance with the Company’s Articles of Association.
Electronic Notices : Notices to shareholders can now be served electronically. Section 244 of CAMA states that notices can be served personally, by post, or by electronic mail to the electronic mail address provided by the shareholder. The BFA deleted the provision on electronic mail and introduced the electronic service of notice, which covers all forms of electronic notices. In addition to the show of hands method of voting applicable under the CAMA, the BFA has formally recognized electronic voting.
Independent Directors: A public company was required to have at least three independent directors under the CAMA, but with the BFA, every public company must have not less than one-third of the total number of directors as independent directors. Also, any person nominating a majority of the directors must nominate at least one-third of the persons that would be independent directors.
Disqualification from Directorship: Prior to the BFA, a person was ineligible to serve as a director of another company after being removed by a company, regardless of the reason for removal. The BFA has now qualified this provision by noting that the removal under section 288 of CAMA must be on grounds of fraud, dishonesty, or unethical conduct for the disqualification to apply.
Multiple Directorship: At the annual general meeting of a company, any person serving as a director for more than five public companies must resign from any additional directorships exceeding this limit.  Under the BFA, it is not necessary for the resignation from excess public companies to take place at the company’s next annual general meeting. It can occur anytime before the next annual general meeting of the company.
Financial Statements: The position before the BFA was that the format and content of all financial statements must comply with the first schedule to the CAMA, while the accounting standards must be in line with those set forth by the Financial Reporting Council of Nigeria (or “FRCN”). Also, where there is a conflict, the first schedule takes precedence over the FRCN’s standards. The BFA dispensed with the need to comply with the first schedule to CAMA and provides that financial statements need only conform with the FRCN standards.
Small Company : The default position is that a company qualifies as a small company in the first year, if the qualifying conditions are met in that year. For subsequent years, Section 394(2) of CAMA, provides three conditions for qualification as a small company: if the qualifying conditions are met in that year and the preceding financial year; or are met in that year and the company qualified as a small company in relation to the preceding financial year; and were met in the preceding financial year and the company qualified as small in relation to that year. The BFA simplified the conditions for determining if a company is a small company in a subsequent financial if the qualifying conditions are met in that year and the preceding financial year.
Insolvency Cash Flow Threshold: The threshold for insolvency under the CAMA is N200,000. So, A company is deemed to be unable to pay its debts if it owes a sum exceeding N200,000 and is unable to pay after a demand notice is served on it by the creditor. The BFA deleted the monetary threshold and replaced it with “a sum to be determined by a regulation issued by the Commission”. This gives the commission the flexibility to amend the threshold to align with economic realities.
Connection to a Company: In determining if there has been a fraudulent preference in favour of a connected person, the CAMA provides that the relevant time shall be the period of years ending with the onset of insolvency. The BFA substituted the phrase “period of years” with “period of two years”. This means that the relevant time for determining if there has been a fraudulent preference in favour of a connected person shall be two years prior to the commencement of insolvency.
Insolvency Practitioner: The BFA deletes the definition of ‘insolvency practitioner’ under the interpretation section of CAMA By section 868 of CAMA, an insolvency practitioner means a legal practitioner, a member of the Institute of Chartered Accountants of Nigeria or other professional bodies. This section implies that all legal practitioners and accountants of relevant professional bodies are insolvency practitioners. With the deletion of that section, the definition of insolvency practitioner would be in accordance with section 705 of CAMA , which states that a person is only qualified to act as an insolvency practitioner if he has obtained a degree in law, accountancy or relevant discipline, has a minimum of five years post qualification experience in matters relating to insolvency, authorized by a certificate issued by the Business Recovery and Insolvency Practitioners Association of Nigeria (BRIPAN), and holds an authorization granted by the Commission.
B. AMENDMENTS TO THE EXPORT (PROHIBITION) ACT
Power to vary the list of Prohibited Goods:
Section 1 of the Export Prohibition Act absolutely prohibits the goods listed in the Schedule to the Act from being exported out of Nigeria. The goods include beans, cassava tuber, maize, rice, yam tuber, all derivatives of items 1 to 5 and all imported food items. The prohibition was absolute under the Export (Prohibition) Act and attracted a penalty for contravention.
The BFA added a few modifications to the law by deleting the penalty clause for breach, replacing “absolute prohibition” with “prohibition,” and giving the Minister of Finance the authority to alter the items listed in the Schedule to this Act. This suggests that the Minister may approve the exportation of any of the restricted commodities or increase the number of goods that are prohibited. Although it should be highlighted that the BFA did not provide any metrics for variation of the list, and the minister may exercise its powers for any reason at all.
C. AMENDMENT TO THE FINANCIAL REPORTING COUNCIL OF NIGERIA ACT
FRCN to Issue Standards for Financial Statements in Nigeria:
The Financial Reporting Council of Nigeria (FRCN) is responsible for reviewing, promoting, and enforcing compliance with accounting and financial reporting standards that have been adopted by the organization. Section 59 of the FRCN Act, 2011, authorizes the Council to adopt as its standards the accounts, financial reports, or annual returns of some listed Acts, and where there is a conflict between the Acts, the standards and guidelines adopted by the Council shall prevail.
Following the amendment under the BFA, the form and content of financial statements in Nigeria shall be prepared in accordance with standards, regulations, rules, and pronouncements issued and adopted by the Financial Reporting Council of Nigeria (FRCN). The implication, therefore, is that the FRCN shall no longer accept the standards of other Acts but will now issue its standard for financial statements in Nigeria. It is important to note that the amendment applies only to financial statements and does not include annual returns and other documents.
D. AMENDMENTS TO FOREIGN EXCHANGE (MONITORING AND MISCELLANEOUS PROVISIONS) ACT
Grounds for Revoking the Appointment of an Authorized Dealer:
Under 6(1) of the Foreign Exchange (FOREX) Act, the Central Bank may revoke the appointment of an authorized dealer or buyer, if it has reason to believe that it is not in the national interest for the authorized dealer or buyer to continue operations. The decision was subjective and there was no matrix for determining “national interest” for the purposes of revoking an authorized dealer’s licence.
The BFA explicitly stipulates the basis upon which the Central Bank of Nigeria (CBN) may revoke the appointment of an authorized dealer or buyer, which includes- a) failure to utilize the license within 30 days; b) failure to commence its exchange business within 6 months from the date of issuance; c) failure to comply with a directive under the FOREX Act; d) where the entity conducts or intends to administer its business in a manner that threatens the interest of customers or potential customers; and e) failure to disclose in its application, any material information known to the entity or reasonably expected to have been known by the entity, among others.
E. AMENDMENTS TO THE INDUSTRIAL INSPECTORATE ACT
Increase in Monetary Threshold:
The Industrial Inspectorate Act establishes the Industrial Inspectorate Division, which is charged with the responsibility of investigating the undertakings of industries involving capital expenditure and obtaining necessary information on economic trends in the country. By Section 3 of the IIA a person who wants to start a new undertaking or to incur additional capital expenditure in respect of an existing undertaking in excess of twenty thousand Naira only, shall notify the Director of the Industrial Inspectorate Division.
The BFA increased the monetary threshold from Twenty Thousand Naira to Five million Naira. Therefore, any person proposing to start a new undertaking or to incur additional capital expenditure of not less than Five Million naira shall give notice of intention in the form specified in the First Schedule to the Director. The BFA also gives the Minister of Industries (now Minister of Industry, Trade and Investment) the power to vary the threshold. This amendment is necessary to align the monetary threshold with economic realities.
F. AMENDMENTS TO THE INDUSTRIAL TRAINING FUND ACT
Exemption of Employers within the Free Trade Zone:
The Industrial Training Fund (ITF) Act establishes a fund, the Industrial Training Fund, into which contributions shall be made. The Fund is to be utilized to promote and encourage the acquisition of skills and to create indigenously trained manpower. Section 6 of the ITF Act imposes an obligation on every employer having twenty-five or more employees in his establishment to contribute one percent of its annual payroll to the Fund.
The BFA excludes employers operating within the free trade zone from contributing to the Fund irrespective of the number of employees engaged by the employer. Also, it imposes an obligation on any supplier, contractor or consultant bidding for contracts or businesses from any federal government MDAs and having more than 25 employees in his establishment, to contribute to the Fund. The exemption of employers trading in the Free Trade Zone is to reduce tax liability on entities operating in these Zone and attract investment to the Free Trade Zones in Nigeria.
G. AMENDMENT TO THE INVESTMENT AND SECURITIES ACT
A Private Company can now Allot shares to the Public:
By Section 67 (1) of the Investment and Securities Act (ISA), only a public company, quoted or unquoted, and a statutory body or bank established by an Act of the National Assembly, or empowered to accept deposits and savings can make an invitation to the public to acquire or dispose of securities of any corporate body. It also provides that the public company must comply with sections 73 to 87 of the ISA on issuance of prospectus.
The BFA modifies Section 67(1) of the ISA in two respects. First, it replaced banks and other statutory bodies with private company, which means that a private company can make an invitation to the public to acquire or dispose of securities of any corporate, through any lawful means as the Commission may describe. Second, it explicitly provides that a public company cannot make an offer to the public for subscription unless the amount stated in the prospectus, as the minimum amount that is required to be raised by the issue of share capital has been subscribed, and the sum payable on application for the amount so stated has been paid to and received by the company. We anticipate that the Securities and Exchange Commission’s will come up with rules regulating the issuance of securities to the public by private companies.
H. AMENDMENTS TO THE NATIONAL HOUSING FUND ACT
Minimum Wage as the Eligibility Threshold:
The National Housing Fund Act establishes the National Housing Fund to facilitate the provision of houses for Nigerians at affordable prices. Section 4 of the NHF Act deals with the contribution of Nigerian workers, and it provides that a Nigerian worker earning an income of N3,000 and above per annum in both the public and the private sectors of the economy shall contribute 2.5 per cent of his basic monthly salary to the Fund also, an interest rate of 4 per cent shall be payable on contributions made. Additionally, under section 9, an employer with an employee earning a basic salary of N3,000 and above monthly shall deduct 2.5 per cent of the monthly salary of that employee as the employee’s contribution to the Fund, to be remitted to the bank within one month of the deduction.
The BFA changed the qualifying threshold from N3000 to minimum wage, reduced the interest payable on the employees’ contributions from 4% to 2%, and redesignated Nigerian workers as employees. This suggests that every employee in Nigeria earning the national minimum wage and above is expected to contribute 2.5% of his monthly income to the Fund and would in turn enjoy an interest rate of 2% per annum on the contributions or as may be determined by the Bank.
I. AMENDMENT TO THE NATIONAL OFFICE FOR TECHNOLOGY ACQUISITION AND PROMOTION ACT
Exemption from Penalties for Non-Registration:
The National Office for Technology Acquisition and Promotion (NOTAP) is an agency under the aegis of the Federal Ministry of Science, Technology and Innovation, charged with monitoring the transfer and adaptation of foreign technology in Nigeria. The Act provides that all contracts and agreements entered into by any person in Nigeria with another person outside Nigeria in relation to any matter for the transfer of foreign technology to Nigeria (for some specified purposes under the Act), be registered with NOTAP within 60 days from its execution.
The BFA did not expressly extend the timeline for registration but shielded companies from payment of late registration penalties in their first two years of business operation.  This implies that a company will be exempt from penalties for non-registration or late registration within the first two years of its business operations. The exemption is limited to payment of penalties and does not extend to other consequences for non-registration.
J. AMENDMENT TO THE NIGERIAN INVESTMENT PROMOTION COMMISSION ACT
Registration Requirement upon Acquisition of Foreign Participation:
The Nigerian Investment Promotion (NIPC) Act permits a non-Nigerian to invest and participate in the operations of any business in Nigeria, however an enterprise seeking foreign participation shall before the commencement of business, apply to the Commission for Registration. The NIPC Act made no provision for registration where the investment is in an ongoing business. However, with the BFA, an enterprise registered in Nigeria, which subsequently acquires foreign participation after commencement of business must within three (3) months of such acquisition, register with the NIPC. This relates to foreign direct investment that involves investing and participating in the operation of any enterprise in Nigeria.
Also, under section 22 of the NIPC Act, the NIPC may, in consultation with other appropriate government agencies, negotiate specific investment packages for the promotion of identified strategic or major investments. Under the BFA the NIPC is not required to consult with other appropriate government agencies and can specify priority areas of investment and their applicable benefits and incentives and negotiate specific incentives packages for strategic investments in addition to any other incentives applicable under any other law. In addition, NIPC must publish in the Federal Government Gazette and on its website, the criteria for determining strategic investment and details of special incentives awarded through negotiation.
K. AMENDMENT TO THE PATENTS AND DESIGNS ACT
Regulation for Compulsory Licenses:
The first schedule to the Patents and Designs Act (PDA) provides for compulsory licenses, which are licenses issued by the government to a person other than the holder of the patents, without the explicit permission of the patent owner. The BFA inserted paragraph 13A to the first schedule which empowers the Federal Minister of Industry, Trade & Investment to, by regulation, prescribe the procedure for the application, grant, use and withdrawal of compulsory licenses.
L. AMENDMENT TO THE PENSION REFORM ACT
Pension Assets now Eligible for Securities Lending:
The Pension Reform Act was established to create the Contributory Pension Scheme for employees in both public and private sectors of the economy. Section 89(1)(c) of the Pensions Reform Act outrightly prohibits a Pension Fund Administrator from applying pension fund assets as loans and credits or as collateral for loans taken by a holder of retirement savings. However, with the amendment, pension assets are eligible for securities lending, and a Pension Fund Administrator is allowed to issue a percentage of the pension assets in the retirement savings account for payment of equity contribution of residential mortgage by a holder of Retirement Savings Account (RSA), and for securities lending. Ultimately, this will make more funds available to the RSA Holders and could further expand the capital market reserve.
M. AMENDMENTS TO THE TRADEMARKS ACT
The BFA amends the Interpretation Section of the Trademarks Act by inserting the definition of Goods to include Services and substituting the definition of trademarks by including the shape of goods, their packaging, and the combination of colours. This implies that the shape of goods, packaging and colour combination can now be trademarked. Also, by this, companies that deploy solutions by technology-enabled software can now trademark their services.
- OTHER ACTS amended by the BFA, which are not covered under this article include the following:
- The Nigerian Export Promotion Council Act
- Customs and Excise Management Act
- Immigration Act
- National Planning Commission Act
- Customs Service Board Act
- Nigerian Oil and Gas Industry Content Development Act
- Nigerian Ports Authority Act
- Standards Organization of Nigeria Act
The Business Facilitation Act represents a step in the right direction for Nigeria. It has the potential to facilitate development and position the country as an attractive destination for foreign direct investment. Nonetheless, it is crucial that the supervisors of various Ministries, Departments, and Agencies (MDA) take a proactive approach in implementing the amendments introduced by the law. This can be achieved by issuing guidelines, circulars, and directives on the amendments, and outlining a clear roadmap for implementation in the coming months. We remain optimistic that these steps will be taken.
Authors: Ifeoma Ezeribe and Azeezat Ogunsola
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 President Muhammadu Buhari signed the Business Facilitation (Miscellaneous Provision) bill into law on February 15, 2023. The Business Facilitation (Miscellaneous Provision) Act, 2022 (BFA) is a legislative intervention by the Presidential Enabling Business Environment Council (PEBEC), which codifies Executive Order 001.
 Section 3 of BFA
 Section 4 of BFA
 Section 5 of BFA
 Section 6 of BFA
 Paragraph 2, Part of the Schedule to the Act
 Section 127(1) of CAMA
 Paragraph 3, Part 1 of the Schedule to the Act
 By section 142(1) of CAMA,
 Paragraph 5, Part 1 of the Schedule to the Act
 Section 149(1) of CAMA
 Paragraph 5, Part 1 of the Schedule to the Act
 Section 154(1) of CAMA
 Paragraph 6, Part 1 of the Schedule to the Act
 Section 171 of CAMA
 Paragraph 7, Part 1 of the Schedule to the Act
 Paragraph 8, Part 1 of the Schedule to the Act
 Paragraph 9, Part 1 of the Schedule to the Act
 Section 240(2) of CAMA
 Paragraph 11, Part 1 of the Schedule to the Act
 Paragraph 12, Part 1 of the Schedule to the Act
 Section 248(1) of CAMA and Paragraph 13, Part 1 of the Schedule to the Act
 section 275(1) and (2) of CAMA
 Paragraph 14, Part 1 of the Schedule to the Act
 Section 283 of CAMA 2020
 Paragraph 15, Part 1 of the Schedule to the Act
 By Section 307(3) of CAMA 2020
 Paragraph 17, Part 1 of the Schedule to the Act
 Section 378(1) of CAMA
 Paragraph 17, Part 1 of the Schedule to the Act
 Paragraph 18, Part 1 of the Schedule to the Act
 Paragraph 19, Part 1 of the Schedule to the Act
 Section 658(6) of CAMA
 Paragraph 20, Part 1 of the Schedule to the Act
 Paragraph 21, Part 1 of the Schedule to the Act
 Export (Prohibition) Act, Cap. C49, Laws of the Federation of Nigeria, 2004
 Paragraph 30, Part IV to the Schedule to the Act
 Section 3 of the FRCN Act, 2011
 Paragraph 32, Part V to the Schedule to the Act
 Foreign Exchange (Monitoring and Miscellaneous Provisions) (FOREX) Act, 2004: Section 6
 Paragraph 34, Part VI of the Schedule to the Act.
 Paragraph 39, Part VIII of the Schedule to the Act
 Section 1 Industrial Training Fund Act, Cap. 19, Laws of the Federation of Nigeria, 2004
 Paragraph 41, Part IX of the Schedule to the Act
 Paragraph 43, Part X of the Schedule to the Act.
 National Housing Fund Act, Cap. N45, 2004
 Paragraph 45 and 49, Part XI of the Schedule to the Act
 Section 5(2) of the NOTAP Act
 Paragraph 48, Part XII of the Schedule to the Act.
 Sections 17 and 20 of the NIPC Act
 Paragraph 54, Part XV of the Schedule to the Act.
 Paragraph 54, Part XV of the Schedule to the Act.
 Paragraph 55, Part XV of the Schedule to the Act.
 Paragraph 62, Part XVIII of the Schedule to the Act.
 Pension Reform Act No.4, 2014
 Paragraph 64, Part XIX of the Schedule to the Act
 Part II of the BFA
 Part III of the BFA
 Part IV of the BFA
 Part VIII of the BFA
 Part XIV of the BFA
 Part XVI of the BFA
 Part XVII of the BFA
 Part XX of the BFA