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Messrs. Aiser K. Hussain, et al.,

SEC Opinion • Securities and Exchange Commission • Opinions • Apr 20, 1992

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April 20, 1992 Messrs. Aiser K. Hussain, et al., Suite 402 L. & S Bldg. Corner Sta. Monica St. Ermita, Manila S i r : This refers to your letter of April 8, 1992 requesting opinion on the query posed therein. prcd As stated. you are partners of ALL BROTHERS INTL. PLACEMENT CO. LTD., holding 25% interest of the company's total capital. Recently, in compliance with the Philippines Overseas Employment Administration's policy to upgrade the capitalization and increase the guaranty deposit of recruitment industries, you extended loan in favor of the partnership to finance its new project, upgrade the company's capitalization from P900,000.00 to P1,000,000.00 and to cover the escrow deposit of P200,000.00 In as much as you are prohibited under the Anti-Dummy Act to engage directly in the management , the same being considered a partially nationalized business, you would like to know whether or not you would be allowed, by way of exception, to act as signatory to monitor and counter-check the fund releases of the company. Please be advised that if you act as more signatory to monitor and counter-check fund releases without intervening in the management, operation, administration or control of the company, your query would be answered in the affirmative. Very truly yours, (SGD.) ROSARIO N. LOPEZ Chairman

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