Seeking Approval

Seeking approval prior to incorporation 

Coincidence or Under the Influence

For all of you guys who participated in the survey, here is a chance to validate your gut instincts. Obviously, all of you were expressing an opinion or a judgement based on what you have read so far. It is now your chance to comment on these documents that I am posting for you to decide for yourselves whether your instincts were correct or not. You be the judge!

Coincidence or Under the Influence - Item 1 of 4 


Coincidence or Under the Influence - Item 2 of 4 


Coincidence or Under the Influence - Item 3 of 4 


Coincidence or Under the Influence - Item 4 of 4 

"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.

"A ruse by any other circular letter is still a ruse"

I can understand how discombobulating it is to be at the receiving end of the following:

(A) BSP Circular-Letter dated 31 March 2005: Reduced Statutory Reserve under Circular No. 444


OFFICE OF THE DEPUTY GOVERNORSUPERVISION AND EXAMINATION SECTORCIRCULAR-LETTERTo: All Banks and Non-Bank Financial Institutions with Quasi-Banking Functions (NBQBs) Concerned This is to remind all concerned banks and NBQBs that the reduced statutory reserve of two percent (2%) provided under Bangko Sentral ng Pilipinas (BSP) Circular No. 444 dated 18 August 2004 may not yet be availed of pending:

1) the issuance of the pertinent market convention acceptable to BSP that shall govern deposit substitutes transactions evidenced by repurchase agreements (repos) covering government securities; and

2) the opening for the purpose of a separate RoSS account with the Bureau of Treasury by the BSP-accredited third party custodian.

For your guidance.

(Sgd.) ALBERTO V. REYES Deputy Governor
31 March 2005

- Since when have statutory reserves supposedly set by Central Banks for prudential reasons been a function of market conventions on repurchase agreements or absence of such or the opening of RoSS accounts of regulated institutions with another branch or agency of government without the latter's knowledge and assent??!! This is a clearly an attempt to pressure BTr into connectivity using the market as a battering ram!