On the Alleged Incorporation of Draconian NGO Regulatory Provisions into the New CAMA -
Here are my thoughts:

Firstly, I have to say that we don’t particularly have much to worry about. The very draconian provisions of the NGO Regulations Bill we dreaded few years back is not included in the 2020 Companies and Allied Matters Act (CAMA).

Surely, there are concerns mostly because all this are new and many penalty fees are not stated by the CAMA but are to be "prescribed" by the Commission (CAC) through a regulation.

Possible "Issue" Concerns;
1. Section 839: empowers the CAC to Suspend Trustees of an NGO and Appoint Interim Managers - on grounds of fraud, misconduct in the MGT of the NGO, etc.

Thoughts; the CAC cannot unilaterally do this. They require an ORDER from a Court (FHC). Similar to a Minority Protection & Dissolution provisions of regular businesses & companies.

2. Section 842: Tranfer of Credit (of an NGO in a Bank) to another charitable association.
Thoughts; the onus/burden/duty is on the relevant bank to notify the CAC that a particular account(s) has been dormant (see meaning of 'dormant account' in the relevant Banking legislation to determine beyond a layman’s understanding the true meaning/qualification of a dormant account). Afterwards, the CAC notifies the NGO to give a "satisfactory" account of activities. Where the NGO does not respond or provide a satisfactory account within 15 days, the CAC would ONLY direct the Tranfer of the said credit with the CONSENT of the MINISTER (Trade/Investment).

3. Section 845: NGO's to submit Bi-annual Statement of Affairs.
Thoughts; I don't see an issue with this provision of filing a Statement as to the Affairs of the NGO twice a year.
This provision won't come into effect until a Regulation to this effect is made by CAC.

- Others: Voluntary Merger of NGOs...

Frankly, a mere surface glance of the initial NGO Bill will reveal even to the blind the deliberate attempt to stifle civil societies in Nigeria.
Its provisions are, however, not included in the new CAMA, 2020.

While some of the aforementioned issues are of considerable concern in a democratic dispensation, I believe the law provided safeguards or checks and where they fail, relevant undemocratic provisions would be challenged in court in due time and quashed.

Thanks.

Charles E. Uche Esq.