Philippine Long Distance Telephone Co.

July 12, 1984 Philippine Long Distance Telephone Co. c/o Mr. Enrique D. Perez P. O. Box No. 952 Makati, Metro Manila Gentlemen: In reply to your letter dated February 27, 1984 requesting that the above-named company, for purposes of stockholders' meeting be allowed to submit to the Commission a list of its top 20 or 30 stockholders instead of the required complete list in view of the increasing number of its stockholders, hereunder is the pertinent rule on the matter for your information and compliance: LibLex "All stock corporations must prepare a list of stockholders as of the date of the next annual or special stockholders' meeting, showing the name of stockholders, address, nationality, number of shares subscribed, and amount subscribed by each which shall be made available for inspection by any stockholder of record. Non-stock corporations must prepare a list of members as of the date of the next annual or special meeting of the members showing the name of the members, address, and nationality which shall be made available for inspection by any member. All corporations must submit the said list within five (5) days from the date of the stockholders'/members' meeting . However, in the case of corporations where the stockholders/members entitled to vote are as of a date prior to the said meeting, the corporation must submit to this Commission within five (5) days before the date of the said meeting the list of stockholders/members showing the information named above duly certified by the corporate secretary and/or the transfer agent concerned. Corporations having 10,000 or more stockholders must submit a certification under oath by the corporate secretary or transfer agent stating among others the total number of shares subscribed, total amount subscribed and total amount paid and the distribution of the ownership thereof by citizenship classified into "Filipino", "American", "Chinese", "Japanese", and "Others", in lieu of the list of stockholders mentioned in the preceding paragraph ." (Rules Requiring the Maintenance of Stock and Transfer Book/Membership Book and the Preparation of Annual List of Stockholders/Members dated June 29, 1977, as amended on December 29, 1977, emphasis supplied) Please be advised accordingly. Very truly yours, (SGD.) ROSARIO N. LOPEZ Associate Commissioner