Philippine Bank of Communications

CREDIT POLICY NO. 25

Date: 23 December 2002

Subject:
DIRECTORS, OFFICERS, STOCKHOLDERS AND RELATED
INTEREST [DOSRI] OF BANKING INSTITUTION

Please discuss with all officers and staff.

I.

POLICIES AND PROCEDURES:

A. Credit accommodations to DOSRI accounts shall be subject to the
provisions enumerated under Sections X326 X339 of the Manual of
Regulations for Banks of the Bangko Sentral ng Pilipinas and Section
36 of RA # 8791 (The General Banking Law of 2000).
B. All credits extended to DOSRI accounts require the approval of the
Board of Directors.
C. Dealings of a bank with any of its DOSRI should be in the regular
course of business and upon terms not less favorable to the Bank than
those offered to others.
D. To monitor compliance with the MOR provisions on DOSRI accounts,
the Management Information Systems [MIS] Division External
Reports Unit of the Controllership Segment shall be designated as the
control unit and shall strictly monitor compliance with the following
provisions.
1. Individual Ceiling:
The total outstanding direct credit accommodations to each of the
Banks directors, officers or stockholders shall not exceed, at any
time, an amount equivalent to the unencumbered portion of his
outstanding deposits which are not subject of an assignment or
hold out agreement and book value of his paid-in capital
contribution in the lending bank: Provided, that unsecured credit
accommodations to each of the banks directors, officers or
stockholders shall not exceed thirty percent (30%) of his total
credit accommodations.
2. Aggregate Ceiling/Ceiling on Unsecured Loans:

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Except with the prior approval of the Monetary Board, the total
outstanding borrowings of a director, officer or stockholder, whether
direct or indirect, shall not exceed fifteen percent (15%) of the
total loan portfolio of the Bank or 100% of the combined Capital
Accounts as defined in the Manual of Regulations for Banks
Section X106: Provided, that in no case shall the total unsecured
direct and indirect borrowings of DOSRI exceed thirty percent
(30%) of the aggregate ceiling or the outstanding direct/indirect
loans thereto, whichever is lower. For the purpose of determining
compliance with the ceiling on unsecured loans, Banks shall be
allowed to average their ceiling on unsecured loans and their
outstanding unsecured loans every week.
E. Computation of Ceiling:
1. Individual Ceiling:
a. The outstanding direct credit accommodations must, at all
times, be equivalent to the outstanding deposits which are not
subject of an assignment or holdout agreement and the book
value of the paid-in-capital contribution in the Bank which are
not subject of pledge, assignment or any other encumbrance.
b. The available ceiling shall be computed as follows:
Outstanding Deposits (except Trust Investment)
Add: Book Value of the Paid-In Capital
Contribution

P xxx

Individual Ceiling

P xxx
====

xxx

2. Aggregate Ceiling/Ceiling on Unsecured Loans:

a. All lending units of the Bank shall provide the MIS Division of
the Controllership Segment with the outstanding balances of
deposits which are not subject of an assignment or hold-out
agreement of all direct DOSRI borrowers on or before Monday
after end of each reference week. Lending and Operating units
are to ensure that computation of DOSRI ceilings are within the
context of the definition given for secured and unsecured loans
(Section X326.1 of the BSP MOR for Banks).
b. The available limit shall be computed by MISD as follows:

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AGGREGATE CEILING:
Aggregate Ceiling
Less: Total Secured & Unsecured DOSRI loans
Pre-cleared request not yet released

P xxx
( xxx )
( xxx )

Available Ceiling

P xxx
====

CEILING ON UNSECURED LOANS:

Ceiling on Unsecured Loans
Less: Total Unsecured DOSRI loans
Pre-cleared request not yet released
(unsecured loans)

P xxx
( xxx )

Available Ceiling

P xxx
====

( xxx )

F. The available ceiling on aggregate and unsecured DOSRI

accommodations shall be circularized to the Group/Segment Heads of
Corporate Banking, Branch Banking and Treasury on a monthly basis.
G. Clearance of Central Liability Unit [CLU]:
1. Before any loan releases to DOSRI accounts is implemented, the
lending unit should first request for clearance from the Central
Liability Unit (CLU) by sending a specific request form.
(Attachment I)
2. The Central Liability Unit shall establish a numbering system for all
clearances.
3. The Central Liability Unit must promptly return the request form
duly indicating the approval or disapproval of the request to the
originating unit. The specific request for clearance received and
cleared by the CLU is to be earmarked against the available limit
and cannot be utilized for other later requests until the loan is
partially or fully liquidated.
4. It is assumed that once a clearance request is approved by the
CLU, the loan will be released on the date indicated in the request
from and shall remain deducted from the available limit until a
formal advise on any changes, i.e., cancellation or reduction, is
received by them. (Attachment II)

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H. Booking units must only release an amount equivalent to that
stipulated in the clearance request duly approved by the Central
Liability Unit. Hence, the clearance request duly approved by the CLU
shall be a necessary requisite prior to booking, in addition to other
appropriate documents.
I. The clearance by the Central Liability Unit (CLU) does not operate as
credit approval. The usual credit process and routine have to be
followed.
II.

WAIVER OF SECRECY OF DEPOSITS:

In accordance with BSP Circular # 170 dated 10 August 1998 (refer to
Attachment III), a borrower is required to waive the secrecy of his
deposits of whatever nature in all banks in the Philippines in cases
wherein:
A. He is a director, officer or stockholder of a bank; and
B. He contracts a loan, or any form of financial accommodation and is the
recipient of the proceeds of said loan; and
C. The loan or financial accommodation is from:
1. His (DOSRI-borrowers) bank; or
2. A bank that is a subsidiary of a bank holding company of which
both his bank and the lending bank are subsidiaries; or
3. A bank in which a controlling proportion of the shares is owned by
the same interest that owns a controlling proportion of the shares of
his bank; and
D. The loan or financial accommodation of the director, officer or
stockholder, singly or with that of his related interest, is in excess of
the 5% of the Capital and Surplus of the lending bank or in the
maximum amount permitted by the law, whichever is lower.
BSP Circular # 170 also clarifies that if the borrower is a related interest
but not the director, officer or stockholder himself, he is not required to
waive the secrecy of his bank deposits.
The borrower shall be required to fill up the waiver form (Attachment IV),
if applicable. The transaction medium cannot be chopped Documentation
In Order if this documentation requirement is not complied with.

III.

REPORTING GUIDELINES:

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Pursuant to the provisions of the BSP Manual of Regulations for Banks
and/or BSP Circulars which are intended to limit/govern the granting of
credit accommodations, both direct and indirect, extended to Directors,
Officers, Stockholders and Related Interests (DOSRI) of Banking
Institutions, a monitoring system has been required by the Bangko Sentral
ng Pilipinas, as follows:
A. Submitted Weekly:
1. Daily reports on Compliance with Aggregate Ceiling
Direct/Indirect
Credit
Accommodations
Directors/Officers/Stockholders/Related Interests;

on
to

2. Daily report on Compliance with Individual Ceiling on Direct Credit

Accommodations to Directors/Officers/Stockholders.
B. Submitted Semi-Annually:
1. Consolidated Report on Compliance with Aggregate Ceilings on
Credit Accommodations to Directors/Officers/Stockholders/Related
Interests;
2. Report
on
Stockholdings
Directors/Officers/Stockholders/Relatives
Corporations/Firms;

of
in

Banks
Borrowing

3. Consolidated Report on Compliance with Individual Ceiling on

Direct Credit Accommodations to Directors/Officers/Stockholders;
4. Contingent Accounts of Directors/Officers/Stockholders/Related
Interests.
The Management Information System Division [MISD] External
Reports Unit, shall handle compliance with the reporting requirements as
discussed above.
IV.

SOME DEFINITION OF TERMS:

A. DOSRI is an acronym for Directors, Officers, Stockholders and
Related Interests
1. Director refers to Bank directors holding their positions in
accordance with the corporate charter, by-laws and other pertinent
provisions of the law (Sub-section 141.1 of the MOR for Banks). A
person can be a director if he or she is elected to a seat in the
Board of Directors.

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2. Officers are the officers of the Bank which include the President all
the way to the most junior officers, as provided for and defined in
the by-laws of the institution (Sub-section 142.1 of the MOR for
Banks).
3. Stockholders shall refer to:
a. Any stockholder of record in the books of the Bank, acting
personally, or through an attorney-in-fact, executor,
administrator or guardian of a minor, incompetent and/or
deceased stockholder or through a trustee designated by one or
more stockholders pursuant to a voting Trust Agreement, whose
stockholdings in the lending bank, individually and/or together
with his spouse or relative within the first degree of
consanguinity or affinity or relative by legal adoption;
b. A partnership, in which the stockholder or his spouse or any of
his relatives mentioned above is a general partner; and
c. A co-owner, with the stockholder or the stockholders spouse or
relative mentioned above of a property/right/interest referred to
in Section X329.b of the MOR for Banks, amounting to 2% or
more of the total subscribed Capital Stock of the Bank.
Stockholdings of individuals related to each other within the fourth
(4th) degree of consanguinity or affinity, legitimate or common-law
(Attachment V) shall be considered family groups or related
interests. Two or more corporations owned/controlled by the same
family group or same group of persons shall likewise be considered
related interests.
Sections 12 and 13 of RA # 8791 (The General Banking Law of
2000) mandates that all transactions with the Bank of individual
stockholders, family groups and related interests within the
fourth (4th) degree of consanguinity or affinity, legitimate or
common-law or by two or more corporations owned or controlled by
the same family group or same group of persons must be fully
disclosed.
4. Consanguinity refers to a blood relationship while affinity refers to
a relationship by operation of law.
To determine a first (1st) degree relationship, consider the following
illustration:

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CONSANGUINITY
AFFINITY
PARENTS

PARENTS-IN-LAW

FATHER

SPOUSE

Children of Father
And Spouse

Step-son/Step-daughter
Son/Daughter in-law

Assume that the stockholder is the father,

His relatives within the first degree of consanguinity are:
His parents (1 degree up)
Children of father and spouse (1 degree down)
His relatives within the first degree of affinity are:
His parents-in-law (1 degree up)
Sons and daughters-in-law (1 degree down)
Step sons and step daughters (1 degree down)
A degree is moving one degree up or down from a reference point, in
this example, the father.
B. Secured Loan, borrowing or credit accommodations per item (h) of
sub-section X326.1 of the Manual of Regulations for Banks, shall refer
to:
1. Any loan, discount, credit or advance or portion thereof referred to
in Section X327 of the MOR for Banks, which is secured by real
estate mortgage; chattel mortgage on tangible assets; standby
letters of credit issued by foreign banks excluding Philippine
branches of foreign banks; assignment of or hold-out on deposits or
deposit substitutes maintained in the lending bank; cash margin
deposit; or assignment or pledge of government securities or
readily marketable bonds and other high grade debt securities
except those issued by the lending entity;
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2. Customers Liability under Import Bills outstanding for more than

thirty (30) days from date of original entry;
3. Sales Contract Receivables arising from sale of real property on
credit where title to the property is retained by the Bank;
4. Customers Liability Import Bills under Trust Receipts outstanding
for not more than thirty (30) days from date of booking; Provided,
that the booking under Trust Receipts shall have been made not
later than the thirty-first (31st) day from the date of original entry
referred to in sub-item # 2 above.
C. Unsecured Loan shall refer to any loan, discount, credit or advance or
portion thereof referred to in Sec. X327 of the MOR for Banks, as
enumerated below, which is not secured/covered in accordance with
item (h) of sub-section X326.1 of the MOR for Banks:
1. Any advance by means of an incidental or temporary overdraft,
cash item, vale, etc.;
2. Outstanding availments under an established credit line;
3. Drawings against an existing letter of credit;
4. The acquisition of discount, purchase, exchange or otherwise of
any note, draft, bill of exchange or other evidence of indebtedness
upon which a director, officer or stockholder may be liable as a
maker, drawer, acceptor, guarantor or surety;
5. Any advance or unearned salary or other unearned compensation
for periods in excess of thirty (30) days;
6. Loans or other credit accommodations granted by another financial
intermediary to such director, officer or stockholder from funds of
the bank invested in the other institutions Trust or other department
when there is a clear relationship between the transactions;
7. Any advances by means of DAUDs;
8. The increase of existing indebtedness, as well as additional
availments under a credit line or additional drawings against a letter
of credit;
9. The sale of assets such as shares of stocks on credit; and,

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10. Any other transactions as a result of which, a director, officer or
stockholder becomes obligated or may become obligated to the
lending bank, directly or indirectly, by any means whatsoever, to
pay money or its equivalent such as standby and deferred letters of
credit.
D. Direct/Indirect Borrowings, for purposes of defining the rules on loans
and other credit accommodations to DOSRi, shall refer to:
1. Direct Borrowing.
If the director, officer or stockholder of the
lending banks is a party to any of the transactions enumerated in
Sec. X327 of the MOR for Banks, for himself or as the
representative or agent of others, or if he acts as a guarantor,
endorser or surety for loans from the bank, or if the loan or credit
accommodation to another party is secured by a property interest
or right of the director, officer or stockholders.
2. Indirect Borrowing.
If in any of the transactions in Sec. X327 of
the MOR for Banks, the borrower, guarantor, endorser or surety is
a:
a. Spouse or relative within the first degree of consanguinity or
affinity, or relative by legal adoption, of a director, officer or
stockholder of the bank;
b. Partnership of which a director, officer or stockholder or his
spouse or relative within the first degree of consanguinity or
affinity or relative by legal adoption, is a general partner;
c. Co-owner with the director, officer, stockholder or his spouse or
relative within the first degree of consanguinity or affinity, or
relative by legal adoption, of the property, interest or right,
mortgaged, pledged or assigned to secure the loans or credit
accommodations, except when the mortgage, pledge or
assignment covers only said co-owners undivided interest;
d. Corporation, association or firm of which a director, or officer of
the Bank or his spouse is also a director or officer of such
corporation, association or firm, except:
1). Where the securities of such corporation, association or firm
are listed and traded in the Big Board or commercial and
industrial board of domestic stock exchange and less than
fifty (50%) percent of the voting stock thereof is owned by
one person or by persons related to each other within the
third (3rd) degree of consanguinity or affinity; or

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2). Where the director, officer or stockholder of the Bank sits as
a representative of the Bank in the Board of Directors of
such corporation; Provided, That the bank representative
shall not have any equity interest on the corporation except
for the minimum shares required by law, rules and
regulations or by the By-laws of the corporation; Provided
further, that the borrowing corporation under item 1 or 2 is
not among those mentioned in items 2(e) and 2 (f) of this
section.
e. Corporation, association or firm of which any or a group of
directors, officers or stockholders of the lending bank and/or
their spouses or relatives within the first degree of consanguinity
or affinity, or relative by legal adoption, hold/own more than
twenty percent (20%) of the subscribed capital of such
corporation or of the equity for such corporation, association or
firm.
f. Corporation, association or firm wholly or majority-owned or
controlled by any related entity or a group of related entities
mentioned in items 2 (b), 2 (d) and 2 (e) of this section.
Other cases of direct/indirect borrowing shall be resolved on a
case-to-case basis.
It shall be the responsibility of the bank concerned to ascertain
whether the borrower, guarantor or surety is related to persons
mentioned in item 2 (a) of this section or connected with any of the
directors, officers or stockholders of the Bank in any of the
capacities mentioned in 2 (b-f) of this section.
In determining indirect borrowings as enumerated above, only
those cases involving living relatives shall be considered.
Please be guided accordingly.

(original signed)
M. U. FRANCISCO
Series # 2002-025
Filename: CP25.doc

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Attachment I
MEMO TO
FROM
DATE
RE

:
:
:
:

CENTRAL LIABILITY UNIT

[Originating Unit]
REQUEST FOR CLEARANCE

********************************************************************************************
ACCOUNT NAME
TYPE OF DOSRI
Direct
Indirect
AMOUNT
CREDIT FACILITY
COLLATERAL
RELEASE DATE
MATURITY
PRESENT BALANCE

:
:

___________________________________

:
:
:
:
:
:

___________________________________
___________________________________
___________________________________
___________________________________
___________________________________
___________________________________

TO BE FILLED UP IF DIRECT DOSRI ONLY:

Outstanding Deposit
Subscribed Capital Stock
Kind of Stock
No. of Shares
Par Value

:
:
:
:
:

___________________________________
___________________________________
___________________________________
___________________________________
___________________________________

_____________________
Account Officer

___________________
Division Head

********************************************************************************************
Cleared
No available limit

____________________________
CLU Authorized Signatory
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Clearance No. __________________

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Attachment II
MEMO TO
FROM
DATE
RE
ACCOUNT

:
:
:
:
:

CENTRAL LIABILITY UNIT

[Originating Unit]
DOSRI CLEARANCE CANCELLATION/REDUCTION

********************************************************************************************
Please be advised that subjects request for clearance under Clearance No.
__________ in the amount of PhP __________________ has been

Cancelled on _______________________
Reduced to _______________________

__________________________
Account Officer

__________________________
Division Head

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Attachment III
BANGKO SENTRAL NG PILIPINAS
MAYNILA, PILIPINAS
OFFICE OF THE GOVERNOR
Excerpt from
CIRCULAR NO. 170
Series of 1998
Pursuant to the Monetary Board Resolution Nos. 832 and 1098 dated June 10,
1998 and August 5, 1998 respectively,
the following clarifications and
illustrations are hereby issued relative to Section 26 of Republic Act No. 7653:
Section 1
All banks and the directors, officers & stockholders shall continue to comply with
Section 26 of Republic Act No. 7653, which provides, thus:
Section 26. Bank Deposits and Investments Any director, officer or
stockholder who, together with his related interest contracts a loan or any
form of financial accommodation from:
a. His bank; or
b. From a bank:
1). Which is a subsidiary of a bank holding company of which both bank
and the lending bank are subsidiaries, or
2). In which a controlling portion is owned by the same interest that owns
a controlling proportion of the shares of his bank, in excess of five
percent (5%) of the capital and surplus of the bank, or in maximum
amount permitted by law whichever is lower, shall be required by the
lending bank to waive the secrecy of his deposits of whatever nature in
all banks in the Philippines.
Any information obtained from an examination of his deposits shall be held
strictly confidential and may be used by the examiners only in connection with
their supervisory and examination responsibility or by the Bangko Sentral in an
appropriate legal action it has initiated involving the deposit account.
Section 3
In the paragraph above, the director, officer or any stockholder should himself be
the borrower or recipient of the loan or financial accommodation. Thus, if
borrower is the related interest but not the director, officer or stockholder
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himself, the director, officer or stockholders is not required to waive the secrecy
of his bank deposits. The function of the phrase who, together with his related
interest in above-quoted Section 26 is to determine whether the loan/s or
financial accommodation/s exceeds the aggregate ceiling prescribed therein.
Moreover, the term stockholder means one as defined in Section 83 of Republic
Act No. 337 as amended, and its implementing rules in Part III of the Manual of
Regulations for Banks and Other Financial Intermediaries, owning two percent
(2%) or more of the subscribed Capital Stock of the bank.
Section 5
In the above paragraph, the terms loans or financial accommodation shall
refer to transactions which involve the grant, renewal, extension or increase of
any loan, discount, credit or advances in any form whatsoever, including the
transactions considered as such in Part III of the MOR for Banks and Other
Financial Intermediaries.
Section 6
Illustration of Section I is shown below:
X
Holding Company

Y Bank
(Subsidiary)

Z Bank
(Subsidiary)

Thus, if Mr. A, who is a director of Z Bank borrows from Y Bank, he should waive
the secrecy of deposits of whatever nature in all banks in the Philippines since
both Y Bank and Z Bank are subsidiaries of X Holding Company.

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Lending Banks Equity Structure:
Bank Y
Owner B
49%

Owner A
51%

Borrowers Banks Equity Structure:

Bank Z
Owner A
49%
Owner B
51%

The term controlling interest means ownership of more than 50% of the voting
stock or subscribed capital stock of the bank. In the illustration above, the
controlling shares in both banks belong to the same interest, Owner A. The
term same interest as used herein shall refer to any of the following:
a. The same natural person;
b. The same corporation, partnership or entity;
c. The same family group, i.e., persons related to each other within the third
degree of consanguinity or affinity, including any corporation majority or all of
the equity of which is owned by such family group; or
d. The same business group, i.e., a group of persons whose stockholdings
altogether constitute a majority or control in one or more enterprises.

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Thus, if Mr. B, who is a director of Bank Z borrows from Bank Y, Mr. B should
waive the secrecy of his deposits of whatever nature in all banks in the
Philippines since the controlling shares in both banks belong to the same
interest.
Section 8
Violation of Section 26 of Republic Act No. 7653 committed after date of
issuance of this Circular, or those committed in connection with loans or financial
accommodations granted on or after July 3, 1993 (date of effectivity of Republic
Act No. 7653) and which are still outstanding on the date of this Circular, will
subject the offender to the sanctions provided under Section 37 of Republic Act.
No. 7653.

Original Circular signed - For the Monetary Board

GABRIEL SINGSON
Governor

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Attachment IV

(Date)

BANGKO SENTRAL NG PILIPINAS

BSP Complex
Manila
RE:

Waiver of Secrecy of Bank Deposits

Pursuant to Sec. 26 of R.A. No. 7653
As Implemented by BSP Circular No. 170
Series of 1998

Gentlemen:
In connection with the loans and/or credit accommodations (hereinafter referred
to as Loans) obtained by ___________________________ from the
PHILIPPINE BANK OF COMMUNICATIONS, the undersigned hereby waives
the secrecy of his/her/its deposits of whatever nature in all banks in the
Philippines in favor of the Bangko Sentral ng Pilipinas (BSP) where the
undersigneds interests fall within the purview of BSP Circular No. 170, Series of
1998.
Any information obtained from an examination of the said deposits shall be
considered strictly confidential and may be used by the BSP examiners only in
connection with their supervisory and examination responsibility or by the BSP in
an appropriate legal action it has initiated involving the said deposits.
The waiver shall be deemed automatically revoked upon full payment of the
Loans.
Thank you.
Very truly yours,

________________________
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DEGREE OF CONSANGUINITY

FIRST COUSIN

AUNTS/UNCLES
GRANDPARENTS

FATHER/MOTHER
LEGITIMATE/
COMMON LAW
SPOUSE
BROTHER

SISTER

CHILDREN

1st DEGREE *

GRANDCHILDREN
2nd DEGREE *

NEPHEWS/NIECES

3rd DEGREE *

4TH DEGREE *

* Include In-laws [by Affinity]

PBCOM CREDIT POLICY MANUAL

FIRST COUSIN