Hi! I am Nina Lasala, former Treasurer of the Philppines. This blog is meant to be an open forum for investors, fellow finance professionals, and other interested parties to discuss the state of Philippine Debt Management.

Friday, March 11, 2005

Preliminary Response to BSP

SOME PRELIMINARY COMMENTS ON BSP RESPONSE TO THIRD PARTY CUSTODIANSHIP ISSUE


In reviewing, the comprehensive reply of the BSP, I realized that there are a lot of topics to cover. It will take me this weekend to compose a reply that can satisfactorily discuss each major topic.

At this point, the major impression I am forming is that all stakeholders need a fuller appreciation of the capabilities of RoSS and its subsequent upgrades. I am saying this because most of the comments within BSP reply seem to be hinged on their less than complete understanding of RoSS

It is painfully apparent also that these capabilities that were implemented by my predecessors as well as by myself were not fully communicated to other stakeholders. If there is a fault, it is s the superficial knowledge of RoSS because a lot of the valid concerns of the BSP for improving investor protection are already addressed in RoSS.

For example,

BSP statement:In the current uncertificated securities environment, control by dealing bank is achieved by "delivering" or transferring by book-entry the purchased securities from its primary account to a sub-account under its own primary account in RoSS.

The arrangement is inherently risky to the customer as far too much trust is required to be placed in bank dealers, who are always under severe pressure to make profit, to always do the right thing for their customers.”

The sub-accounts under the control of dealer banks is only one of the several arrangements available in RoSS for supporting name-on-registry capability, and is intended to support custodianship/nominee arrangements where the custodian or nominee is required to name the beneficial owner of the securities.

What the BSP may not be aware of is that RoSS is also capable of supporting independent investor accounts, which are fully under the control of the investor through the use of a PIN, and actually result in having proceeds of the investment placed directly in the investor’s designated bank account.

This capability has been fully demonstrated “in production mode” in the BTR’s Small Investor Program (SIP) initiated in 1998 which was implemented by my predecessor Prof. Leonor Briones, and again with the Small Denominated Treasury (SDT) Bonds which were listed in the PSE in 2000. These initiatives spurred the incorporation of direct access and direct registration facilities within RoSS itself to benefit and protect small investors. Equally important is the fact that these services could be then cheaply. These facts can easily be verified with both Landbank and DBP since they acted as the direct settlement institutions for these initiatives.


BSP statement: "In the mid-1990s this kind of arrangement led to the BANCAP scam that enabled unscrupulous traders to sell to multiple customers the same securities. At its height, it created a lot of nervousness in the financial system and only timely defensive action prevented full-blown systemic crisis. This case is actually still being disputed in the courts today by three banks claiming ownership over the same set of government securities.

Critics claim that this situation was already addressed by the conversion to scripless government securities recorded under the RoSS system.

It did not. RoSS, as a registry, merely keeps an electronic record of what was once a paper-based system but it does not significantly improve the situation because it perpetuates the system where customer securities accounts, now paperless, are fully controlled by the dealer bank.
"

This reference to the BANCAP scam is used to justify the need for third party custodians is historically out of context. What BSP should mention, however, is that:

1. BANCAP happened in the early 1990’s, BEFORE government securities were dematerialized. In a subsequent capital markets study, the Capital Markets Development Council, I believe, there were several weaknesses cited with the then Book-Entry System and the certificated securities regime. RoSS is actually a direct outcome of this study and was implemented (in 1996). to prevent another Bancap-like scandal. Again, I would urge all stakeholders to read former Treasurer Valdehuesa’s well written historical recounting of these events ;

2. Since RoSS has been in place, there has been NO single incident similar to BANCAP; and

3. In fact, the Realtime Gross Settlement System (RTGS) and Delivery vs. Payment (DVP) conventions now fully implemented in RoSS on both the securities and cash legs of the transactions effectively ensure that it will not be possible for dealers to sell securities they do not have.

Additionally, custodianship as a concept in a regime of "certificated " Treasury Bills and Bonds has no place in a regime of uncertificated Treasury bills and Bonds. RoSS is not the 'registry' of old , e.g., the civil registry or the registry of deeds. RoSS is the state-of-the-arts inseparable phase of the BTr's mandate of managing and controlling national government's debt from domestic and foreign sources. RoSS is the end of the continuum of borrowing domestically through the floatation of Treasury Bills and Bonds, i.e., electronic auction, electronic recording of awards, electronic settlement with BSP. RoSS is the subsidiary ledger in BTr's function of maintaining the financial accounts of the National Government and its agencies.

BSP statement: Transaction confirmations and securities balance reports are also not given directly and are instead coursed through the same dealer banks. For all intents and purposes, investors remain out of the loop and can only hope that they are treated fairly by their bank dealer.

Coursing the securities account statements through dealer banks is only one of several options available to investors in RoSS. The investor has two other options available in RoSS – having a regular statement mailed to his designated mailing address, or having statements or queries “on demand” but without any regularly generated statements.

I will limit my comments to here for now. I beg my readers’ indulgence and if they would so kind as to read the rest of my observations in subsequent postings.

82 Comments:

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i'm still not getting answers to my other posts regarding an independent electronic audit for ross. it seems there is no other system connected to ross to do real-time monitoring/ auditing the integrity of the database.perhaps this is one reason for the 3rd party custodian rule.

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isn't it. The decline of the East side blues scene was disheartening, but, it also gave rise to the need for a fresh start, which came in the form of the next blues-only venue, Antone's, founded by
the late Clifford Antone, during the summer of 1975.


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Narrow blood vessels lie alongside the intestines of the earthworm and
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They feature almost nightly drink specials and some
form of entertainment every night of the week--DJ's, live music, trivia, you name it.

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Some were practical, of course, but others were psychological and emotional.
Popular prizes include sports tickets, cash and vouchers for drinks,
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Anonymous Anonymous said...

Some were practical, of course, but others were psychological and emotional.
* Team answer sheets - Basically a grid lined A4 type sheet
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In other words, they go against the grain of the careers their parents had.
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drink specials on Tuesdays include $2.

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