Bautista, Picaso, Buyco, Tan & Fider

April 24, 1990 Bautista, Picaso, Buyco, Tan & Fider 5th Floor, WIP Building 349 Sen. Gil J. Puyat Avenue Makati, Metro Manila Attention : Atty . Antonio A . Picazo Gentlemen: This refers to your letter dated April 3, 1990 requesting confirmation of your contention that shares of stocks of banking institutions are considered exempt securities under the Revised Securities Act. Consequently, no request for exemption from registration requirements under said law shall be required and no exemption fee shall be imposed on the shares to be issued out of the proposed increase of capital stock of Asian Savings Bank from P50 Million to P1.5 Billion. Please be advised that under Section 5(a-3) of the Revised Securities Act, shares of stock of banking institutions are considered exempt securities. The law provides thus: "SECTION 5. Exempt securities . (a) Except as expressly provided, the requirement of registration under Section four of this Act shall not apply to any of the following classes of securities: xxx xxx xxx (3) Any security issued or guaranteed by any banking institution authorized to do business in the Philippines, the business of which is substantially confined to banking or a financial institution licensed to engage in quasi-banking, and is supervised by the Central Bank. . . . ." (Emphasis supplied) In view of the foregoing, the Commission hereby confirms your view on the matter. Very truly yours, SGD. RODOLFO L. SAMARISTA Associate Commissioner