"Et Tu , Brutus ?"
SEQUENCE OF UNFORTUNATE EVENTS
APRIL 24, 2001 - BAP CONSULTING, INC.WAS INCORPORATED
NOVEMBER 20,2002-THE CHAIRMAN OF THE BAP OPEN MARKET COMMITTEE
(who later became the president of BAP
CONSULTING, INC. ) WROTE THE BSP RECOMMENDING
THE FUNCTIONS OF A CUSTODIAN
FEBRUARY 6, 2003-BAP CHAIRMAN, OPEN MARKET COMMITTEE (Who later
became the president of BAP CONSULTING,INC.
President) submitted to BSP a draft of BSP Cir.
No. 392 (This draft essentially became the
actual BSP circular No. 392)
APRIL 24, 2003 - BAP CONSULTING, INC. PRESIDENT SOUGHT APPROVAL WITH
BSP OF THE OPERATIONAL FRAMEWORK OF THE PROPOSED
DEPOSITORY & CUSTODY ENITTY OF THE FIE EMBODIED IN
A BUSINESS PLAN ATTACHED THERETO (The letter stated
they will be "filing for incorporation and apply
for accreditation as a custodian.)
BAP CONSULTING PRESIDENT SUBMITS PROPOSED ACCREDIT-
ATION GUIDELINES WITH THE BSP (Guidelines defined
major functions of a custodian, among others, which
later could be found in circular no. 392/428)
JUNE 17,2003 - BAP CONSULTING, INC. WAS RENAMED PHIL.DEALING
SYSTEM HOLDINGS CORPORATION
JULY 23, 2003 - BSP CIRCULAR 392 WAS ISSUED
APRIL 27, 2004 - BSP CIRCULAR 428 IMPLEMENTING CIR 392 WAS ISSUED.
JULY 1, 2004 - BSP CIRCULAR NO. 440 DEFERRING THE EFFECTIVITY
OF CIR. 392 WAS ISSUED
SEPTEMBER 24, 2004-BSP CIRCULAR NO. 453 DEFERRING EFFECTIVITY OF
CIRCULAR 392 TO NOVEMBER 16, 2004 WAS ISSUED
OCTOBER 14, 2004-BSP CIRCULAR NO. 457 WAS ISSUED CLARIFYING CIRCULARS
ON CUSTODIANSHIP
NOVEMBER 2, 2004- BSP CIRCULAR NO. 458 WAS ISSUED EXEMPTING SOME
INSURANCE COMPANIES FROM THE INDEPENDENCE OF
CUSTODIAN AND REGISTRAR RULE
NOVEMBER 12, 2004-BSP CIRCULAR NO. 460 WAS ISSUED DEFERRING THE
EFFECTIVITY OF CIRCULAR 392 TO JANUARY 01, 2005
Copies of some of the letters mentioned are posted above.
3 Comments:
AHA!!! who is regulating who? There seems to be an uncomfortably cozy relationship here!
I may be naive, but, since when did any entity have to submit its business plans to the BSP???
Let me see . . . I really need to digest this sequence of events because I am surprised by it. It raises a lot of questions in my mind. Am I correct in observing that as early as 2001 some parties have already been contemplating on this 3rd party scheme? The author of the letters later on became the head of the private, non-bank custodian isn't it? And did not BAP consulting somehow become part of that 3rd party custodian? Hmmm... it seems the relationship dates way way back...!!!
1:48 PM
BEHOLD, THE FALL OF THE ROMAN EMPIRE!!!
2:17 PM
So much for a very protracted labor ( of ex-traders and their regulator friends) that produced nothing but a lousy mouse!
9:45 AM
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