In the Matter of Optima Balance Fund, Inc.

March 27, 2015 CORPORATE GOVERNANCE AND FINANCE DEPARTMENT IN THE MATTER OF OPTIMA BALANCE FUND, INC. , registrant. AMENDED REGISTRATION STATEMENT NOTICE Notice is hereby given that on 27 March 2015, an Amended Registration Statement was filed with the Securities and Exchange Commission on behalf of OPTIMA BALANCE FUND, INC. (the "Fund") to reflect the following amendments in its Registration Statement: ETHIDa Subject Original Proposed Amendment Reason for the Amendment 1. Change Optima Balance ATRAM Dynamic The Fund will be positioned of name Fund, Inc. Allocation Fund, Inc. as a more aggressive balanced fund with a wider tactical asset allocation range. This is also to align the Fund's name with other ATRAM funds. 2. Change of Metro Manila 15/F Tower One & To adhere to SEC Memo principal Exchange Plaza, Ayala Circular No. 6, Series of address Triangle Avenue, Makati 2014. City 3. Change of 1.20% p.a. 1.75% p.a. To align management fee Management with the other balance fund and (Management fee - (Management fee - of ATRAM and the industry. Distribution 0.70% p.a. 1.25% p.a. Fee Distribution fee - Distribution fee - 0.50% p.a.) 0.50% p.a.) 4. Change Php5,000.00 Php10,000.00 or as To align the minimum of minimum determined from time to time investment amount with investment by the Board of Directors of other peso-denominated amount the Fund ATRAM Funds. 5. Change of Php500.00 The minimum redemption For operational Minimum amount (before deducting efficiency, i.e., to avoid Redemption any applicable Redemption maintenance of small Amount Fee is Five Thousand accounts. Pesos (Php5,000.00) , unless the investor's outstanding investment in the Fund is less than Five Thousand Pesos (Php5,000.00), in which case, minimum redemption amount shall be the total amount of the outstanding investment. 6. Change of Sales fee not to exceed Sales Fee, inclusive of To give wholesale Sales Fee 2% of the investment expanded Value-Added Tax distributors flexibility in amount shall be charged ("e-VAT") shall be charged pricing front-end Fees. to the investors. from zero (0) to five percent (5%) of the investment amount being subscribed. 7. Change of Shares redeemed within Redemption Fees (inclusive For flexibility in setting the Redemption the 15-day holding period, of e-VAT) in amounts from minimum holding period Fee is subject to an early zero (0) to five percent and the redemption fee. redemption fee of 1.0% (5%) will be charged by The current redemption plus 12% eVAT. If the Principal Distributor fee still falls within the redeemed after the 15-day and/or eligible sales agents proposed range. New holding period; no exit or securities dealers to the minimum holding period load is charged investor on shares redeemed and redemption fee to be in less than or within two determined. years of subscription. 8. Change of The Fund is a mutual fund The Fund is a mutual fund The proposed investment Investment invested in selected fixed invested in selected fixed objective takes out the Objective income and stocks, actively income and stocks, actively flexibility to invest in managed for maximum managed for maximum offshore securities to better growth and designed for those growth and designed for those reflect the Investment who seek an investment with who seek an investment with strategy and universe of a low to moderate risk. The a low to moderate risk. The the Fund. The Fund has Fund is designed to provide Fund is designed to provide been a balanced fund total returns consisting of total, returns consisting of which invested only in current income and capital current income and capital Philippine assets even growth through investments growth through investments though it had the flexibility in a diversified portfolio of in a diversified portfolio of to invest in offshore bonds. debt and equity securities debt and equity securities ATRAM intends to continue from both domestic and from domestic issuers . with this strategy and foreign issuer. An adequate An adequate portion of the position the fund as a portion of the portfolio will portfolio will be invested in more aggressive fund be invested in cash and cash and near cash assets with a wider tactical near cash assets to to ensure that redemptions asset allocation range ensure that redemptions will be adequately and than the ATRKE Philippine will be adequately and immediately serviced. Balanced Fund. The immediately serviced. wholesale distributors want a clearly stated investment objective which reflects what the Fund actually does or invests in. This facilitates accreditation of the funds with distributors. 9. Change of The Fund will invest The Fund will invest in a The proposed Investment investment in a combination of stocks combination of stocks Policy takes out the policy with big and medium listed in the Philippine flexibility to invest in capitalization that can Stock Exchange that can offshore. provide good value and provide good value Securities to better reflect capital appreciation over and capital appreciation the investment strategy the medium term. over the medium to and universe of Fund. Management, earning long term. Management, The Fund has been potential, strong balance earning potential, strong a balanced fund which sheet and attractive balance sheet and attractive invested only in Philippine valuations will be the valuations will be the primary assets even though it had primary criteria for stock criteria for stock selection. the flexibility to invest in selection. Changes in the Changes in the offshore bonds. ATRAM macroeconomic conditions macroeconomic conditions intends to continue with this can dictate the equities can dictate the equities strategy and position the that the Fund will invest in. that the Fund will invest in. fund as a more aggressive Temporary shifts to cash Temporary shifts to cash fund with a wider tactical or fixed-income securities or fixed-income securities asset allocation range may be done as a may be done as a defensive that the ATRKE Philippine defensive move. The move. The Fund's fixed- Balanced Fund. The Fund's fixed income income portfolio shall be wholesale distributors want portfolio shall be invested invested in SEC registered a clearly stated investment in SEC registered short to corporate debt papers , the objective which reflects medium term corporate issuers of whom had been what the Fund actually debt papers , the issuers pre-approved by the Board does or invest in. This of whom had been of Directors of the Fund facilitates accreditation of pre-approved by the Management Company. the Funds with distributor. Board of Directors of the The Fund shall also trade Fund Management in securities issued for Company, and subject to guaranteed by the Republic an AAA rating. The fund of the Philippines and shall also trade in medium the Bangko Sentral ng to long term government Pilipinas. securities (5 year to 20- year notes, bonds and other certificate of indebtedness issued by the Philippine Government). Depending on the state of various world economics and markets, the Fund may invest in on- Philippine investment grade issues. The SEC Memorandum Circular No. 7, Series of 2005 ("Guidelines on the Evaluation of Foreign Investments by Mutual Fund Companies) allows mutual fund companies to invest up to 100% of their net assets in foreign securities. Said circular was amended by SEC Memorandum Circular No. 10, Series of 2006, allowing mutual funds to invest in bonds and evidence of indebtedness registered and traded in an organized market of a foreign country whose issue and issuer/ borrower are rated at least BBB from reputable international rating The said Registration Statement and other papers/documents attached thereto are open to inspection by interested parties during business hours, and copies thereof, photostatic or otherwise, shall be furnished to any party upon request at such fees as the Commission may prescribe. The Registration Statement may also be downloaded from www.atram.com.ph . (SGD.) JUSTINA F. CALLANGAN Director Published in The Manila Times on April 17 and 20, 2015.