EXHIBIT 99.9

                                 Form 51-102F1

                                BANRO CORPORATION
       INTERIM MANAGEMENT'S DISCUSSION AND ANALYSIS - FIRST QUARTER 2004

The following management's discussion and analysis ("MD&A") provides a review of
the  activities,   results  of  operations  and  financial  condition  of  Banro
Corporation  (the "Company") for the three month period ended March 31, 2004, as
well as future prospects of the Company. This MD&A should be read in conjunction
with the  unaudited  consolidated  financial  statements  of the Company for the
three month  period  ended March 31,  2004,  together  with the MD&A and audited
consolidated financial statements of the Company for the year ended December 31,
2003. This MD&A is incremental to the disclosure included in the MD&A in respect
of the audited  consolidated  financial  statements  of the Company for the year
ended December 31, 2003. As the Company's  financial  statements are prepared in
United States  dollars,  all dollar amounts in this MD&A are expressed in United
States dollars unless otherwise  specified.  Additional  information relating to
the Company is available on SEDAR at  www.sedar.com.  This MD&A is dated May 28,
2004.

General
- -------

During the first quarter of 2004,  the Company  continued to gather  information
necessary  to complete the  planning of an  exploration  program for the next 18
months with respect to the Company's gold properties in the Democratic  Republic
of the Congo (the "DRC"). Preparations are underway for a team of geologists and
mining  engineers,  as well as the Company's  President,  to visit in early June
2004 all four of the Company's  properties  in eastern DRC. The Company  expects
that this visit will help assess in greater  detail the exact  nature and extent
of, and the budget  required for, an  exploration  program in respect of each of
the Company's four projects.

Results of Operations
- ---------------------

For the three month period ended March 31, 2004, the Company reported a net loss
of $768,346,  or $0.07 per share, compared to a net income of $177,737, or $0.01
per share,  reported for the three month period ended March 31, 2003.  This loss
was most  significantly  impacted by the recording of $404,675 of employee stock
compensation  expense  pursuant to the adoption by the Company in fiscal 2003 of
the fair value method of  accounting  for stock  options  granted to  employees,
directors  and  officers.  In addition,  compared to the first  quarter of 2003,
notable  increases  occurred in the first  quarter of 2004 in office and sundry,
salary and travel and promotion  expenses due to the resumption of the Company's
activities in the DRC. Despite the overall increase in expenses during the first
quarter of 2004,  consulting  expenses  during this period  decreased to $759 as
compared to $58,873  during the first  quarter of 2003,  which were  incurred in
connection  with the  negotiations  with the government of the DRC regarding the
return of the Company's gold properties in the DRC.

The net income recorded by the Company during the first quarter of 2003 was most
largely  impacted  by  a  foreign  exchange  gain  of  $138,845  resulting  from
fluctuations in the value of the U.S.  dollar  relative to the Canadian  dollar,
and by the recovery of legal fees of $299,056 in relation to a successful  legal
case as discussed in note 10 of the audited consolidated financial statements of
the Company for the year ended December 31, 2003.



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Summary of Quarterly Results
- ----------------------------

The  following  table  sets  out  certain   unaudited   consolidated   financial
information of the Company for each of the last eight  quarters,  beginning with
the first  quarter of 2004.  This  financial  information  has been  prepared in
accordance with Canadian generally accepted accounting principles. The Company's
reporting currency is the U.S. dollar. The Company's measurement currency is the
Canadian  dollar  and  the  measurement  currency  for  each  of  the  Company's
subsidiaries is the U.S. dollar.

- --------------------------------------------------------------------------------
                                2004         2003          2003         2003
- --------------------------------------------------------------------------------
                             1st quarter   4th quarter  3rd quarter  2nd quarter
- --------------------------------------------------------------------------------
- --------------------------------------------------------------------------------
Net loss                   $   (768,346)   $ (549,728)   $(243,720)   $(245,271)
- --------------------------------------------------------------------------------
Net loss per share         $      (0.07)   $    (0.06)   $   (0.02)   $   (0.02)
- --------------------------------------------------------------------------------
- --------------------------------------------------------------------------------
                                2003         2002          2002         2002
- --------------------------------------------------------------------------------
                             1st quarter   4th quarter  3rd quarter  2nd quarter
- --------------------------------------------------------------------------------
- --------------------------------------------------------------------------------
Net income (loss)          $    177,737    $(478,824)   $(427,289)    $(261,552)
- --------------------------------------------------------------------------------
Net income (loss) per share $      0.01    $   (0.05)   $   (0.04)   $    (0.03)
- --------------------------------------------------------------------------------

The increase in the first quarter of 2004 in the Company's net loss, compared to
the fourth quarter of 2003, is due to the general increase in operating expenses
as a result of the  resumption of the Company's  activities in the DRC.  Results
for the fourth quarter of 2003 were impacted by the prospective  adoption by the
Company of stock-based  compensation to employees,  directors and officers which
was only recognized at December 31, 2003. This resulted in an additional expense
during the fourth  quarter  of 2003 in the  amount of  $378,724.  The net income
recorded in the first  quarter of 2003,  as explained  above,  was affected by a
foreign exchange gain and the recovery of legal fees.  Changes in 2002 third and
fourth quarters  results  compared to the previous two quarters of the same year
are due mainly to increased travel and consulting  activities  pertaining to the
return of the Company's assets in the DRC.

Liquidity and Capital Resources
- -------------------------------

The Company does not currently  generate revenues and relies primarily on equity
financings to fund its activities.  This exposes the Company to market risks, in
addition to the risks associated with the Company's  properties being located in
the DRC  and  the  risks  associated  with  the  resource  exploration  industry
generally.

As at March 31, 2004, the Company had working capital of $12,168,746 compared to
working  capital of $961,068 as at December  31,  2003.  The  Company's  working
capital  position is mostly comprised of cash raised during the first quarter of
2004 from the  exercise  of 430,000  stock  options  and  250,000  common  share
purchase warrants and from a private  placement of 2,000,000 common shares.  The
Company's current cash position is considered sufficient for planned exploration
expenditures  on the  Company's  Twangiza-Namoya  gold belt and for  general and
administrative expenses for at least the next 18 months.

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Following  March 31, 2004, the Company  received an additional  $156,744 in cash
from the  exercise of 100,000  common share  purchase  warrants and 10,000 stock
options.

Currently,  the Company has no significant long term contractual obligations and
no long term debt.

Deferred Exploration Expenditures
- ---------------------------------

The following table provides a breakdown of the Company's  deferred  exploration
expenditures on a property-by-property basis:


                                  Banro Congo  Kamituga  Lugushwa   Namoya     Twangiza         Total
                                  -----------  --------  --------   ------     --------         -----
Balance 12/31/2003 $ 273,960      $   273,960  $      -  $      -   $    -     $ 48,730      $ 322,690
                                 ---------------------------------------------------------------------
                                                                                       
Administrative and
office support                         55,480         -         -        -            -         55,480
Geologists                             21,900         -         -        -       48,993         70,893
Travel                                  8,000         -         -        -            -          8,000
Legal                                  24,305         -         -        -            -         24,305
Mining property
fees and taxes                          3,130         -         -        -            -          3,130
Depreciation                            4,599         -         -        -            -          4,599
                                 ---------------------------------------------------------------------
Balance 03/31/2004               $    391,374  $      -  $      -   $    -     $ 97,723      $ 489,097
                                ======================================================================


Outstanding Share Data
- ----------------------

The authorized  share capital of the Company  consists of an unlimited number of
common shares and an unlimited number of preference shares,  issuable in series.
As at May 28, 2004, the Company had outstanding:  (a) 13,217,844  common shares;
(b)  warrants  to  purchase  120,000  common  shares;  and (c) stock  options to
purchase 1,441,500 common shares.























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