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3 rd Quarter Accomplishment Report. BSP Advocacy.
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BSP Advocacy • MB approved the grant of authority for TBs capitalized at P325 million (for Metro Manila TBs) and P100 million (for outside Metro Manila TBs) to engage in limited trust business; Limited trust business refers to (1) court-trusts and (2) administration of properties • issuance of BSP Circular 582 which liberalized the requirements for operating an FCDU by a TB and RB, particularly the required experience for the officer who will be in-charge of a thrift bank’s FCDU operations
BSP Advocacy • proposed guidelines on the Overnight Clearing Line may be revised as evaluated by the BSP Committee incorporating CTB’s comments, among others • on the proposed Rediscounting guidelines, CTB requested for the retention of Section 268.4 which is necessary to give banks sufficient time to adjust to their new line limit after reduction of rediscounting lines arising from operation of the Credit Information System, in addition to our earlier proposal
BSP Advocacy • proposed liberalized guidelines on establishment of new TB and RB branches due for submission to the MB • CTB provided inputs to the exposure draft on derivatives and asked that TBs be allowed to engage in derivatives transactions as end-user • submitted to the AMLC CTB’s position paper on the implementation issues of AMLC Resolution No. 10 (Suspicious Transaction Reports or STRs on cases involving the deposit of fraudulent or spurious checks)
Legislative Advocacy • participated in a Senate Committee hearing and a TWG meeting on various bills seeking to amend the Magna Carta for SMEs and articulated CTB’s position on major provisions of the proposed measures, viz; inclusion of micro enterprises as part of definition of SMEs, banking sector representation in the SMED Council, and mandatory allocation of credit resources to SMEs • MAGNA CARTA FOR SMEs
Legislative Advocacy • proposed that the following incentives be extended to banks who lend to SMEs; 1. exemption of revenues earned by the lender on GRT and DST 2. to allow exposure to SMEs in excess of the minimum mandated by law as alternative compliance to AGRI-AGRA requirement 3. waive the reserve requirements on deposit liabilities equivalent to the micro loan outstanding in the books of the bank 4. exemption of micro and small enterprises from the required submission of ITR and FS
Legislative Advocacy • will seek legal opinion from the Secretary of Justice to clarify DAR practice of subjecting to CARP a bank’s acquired agricultural property beyond the 5 year holding period and may include this as among the amendments to the CAR Law • CTB to push for the passage of the Credit Information System Act (CISA) during this 14th Congress
Judicial Advocacy • CTB is working on a paper addressed to the SC Chief Justice on proposed amendments to the Interim Rules of Procedure on Corporate Rehabilitation as well as on issuance of another Administrative Circular pursuant to the Constitutional Rule-Making Power of the SC • creation of the Legal Sub-Committee (under the CTB Technical Committee) to strengthen the legal advocacy of CTB