Schedule of Fees, Fines and Penalties

May 3, 2001 SEC MEMORANDUM CIRCULAR NO. 04-01 TO : All Broker Dealer, Investment Company Advisers, Investment Houses and Transfer Agents SUBJECT : Schedule of Fees, Fines and Penalties Pursuant to the Securities Regulation Code [SRC] (RA No. 8799) and its Implementing Rules and Regulations, the Basic Rules to Implement the Provisions of the Investment Houses Law (P.D. 129), the Corporation Code (BP Blg. 68) and the Investment Company Act (RA No. 2629), the following schedule of fees, fines and penalties are hereby adopted: A. Broker/Dealer 1. Fees Date of Filing Amount New Registration Head Office P50,000 + other fees Branch Office 10,000 + other fees Salesman 2,000 + other fees Associated Person 3,000 + other fees Renewal December 2 Head Office P20,000 + other fees Branch Office P5,000 + other fees Salesman P1,000 + other fees Associated Person P1,500 + other fees 2. Fines & Penalties Reports FINOP (late filing) Within 15 days Basic fine of P10,000 after month end Plus P100 for every day of delay Annual Audited Financial Report 110 days after end Basic fine of P10,000 of fiscal year Plus P100 for every day of delay Other periodic reports Basic fine of P10,000 Plus P100 for every day of delay Other practices prohibited P10,000 for every under SRC violation without prejudice to the filing of criminal case B. Investment Company Advisers 1. Fees Date of Filing Amount New Registration Head Office P10,000 + other fees Sales Agent 2,000 + other fees Renewal March 15 Head Office P3,000 + other fees Sales Agent P1,000 + other fees C. Investment Houses 1. Fees Date of Filing Amount New Registration Head Office P50,000 + other fees Branch Office 10,000 + other fees Associated Person 1,000 + other fees Renewal January 15 Head Office P10,000 + other fees Branch Office P5,000 + other fees Associated Person P500 + other fees 2. Fines & Penalties Reports Progress Within 15 days P200 per day of delay end of quarter Semi-Annual Within 60 days end P200 per day of delay of semester Annual Within the month of March of each year P200 per day of delay General Information Sheet 1 month after the P200 per day of delay date of the actual Annual Meeting Other Violations Minimum Paid-up P200 per day of non- Capital Requirement compliance Unimpaired Capital P200 per day of non- compliance 25% Fee-Based Income P200 per day of non- compliance Capital Adequacy Ratios P200 per day of non- - Single Borrower's Limit compliance - Net worth to Risk-Asset Interlocking Directors P200 per day of non- compliance Underwriting Fees P200 per day of non- compliance D. Transfer Agents 1. Fees Date of Filing Amount New Registration Within 30 days P10,000 + other fees from June 1 of every year Renewal Within 30 days P3,000 + other fees from June 1 of Plus P200.00 per issue every year being handled but not more than P5,000.00 2. Fines & Penalties Failure/Late Filing of 10 days after the Basic fine - P10,000 Monthly Reconciliation end of each month of PCD and TA Plus P100/day of delay Failure/Late filing of 10 days after the Basic fine - P10,000 monthly certification end of each month as to the number of Plus P100/day of delay shares registered under the name of PCD Nominee Failure/Late submission 105 days after the Basic fine P10,000 of Annual Report using end of fiscal year SEC Form 36-AR Plus P100/day of delay Failure to submit any Within 7 days of Basic fine P10,000 of the following the occurrence of exception reports the events Plus P100/day of delay Any delay in the turnaround or processing of an issue, transfer or replacement of a security Any discrepancy between its records and those of the registered clearing agency, if applicable Any loss of securities reports to it; and The termination of its functions as a transfer agent for a particular security Failure to submit Annual 105 days after the Basic fine P10,000 Audited Financial end of fiscal year Statements Plus P100/day of delay Failure to submit General Within 30 days Basic fine P10,000 Information Sheet (GIS) from the date of postponement of Plus P100/day of delay the Annual Meeting Failure to submit Affidavit Within 30 days Basic fine P10,000 of Non-Holding of Meeting from the date of of Postponement of Annual postponement of Plus P100/day of delay Stockholder's Meeting the Annual Meeting Failure to submit Notice Within 10 days Basic fine P10,000 of Change of Address after the end of each month Plus P100/day of delay This Memorandum Circular shall take effect immediately. EHTSCD May 3, 2001. Mandaluyong City, Philippines. For the Commission: (SGD.) LILIA R. BAUTISTA Chairperson