Mr. Nem B. Santos

May 17, 1999 Mr. Nem B. Santos Kapatirang Pilipino Sa Ibayong Dagat, Inc. Suite 104 GSIS Condotel Anonas St. Sta. Mesa, Manila S i r : This refers to your undated letter inquiring whether the activity of Kapatirang Pilipino Sa Ibayong Dagat, Inc. described therein falls within the meaning of a "pre- need" business covered under the Revised Securities Act. To summarize, your association is a non-profit, non-stock membership organization created to supplement government initiatives and to provide additional support and assistance to its members consisting of Overseas Filipino Workers. The organization is primarily established to provide quick and pro-active legal defense assistance program to its members who have legal problems while performing their job responsibilities abroad by c ontracting Pioneer Allied Workers Integrated Service (PAWIS), a multi-dimensional legal service firm, which maintains and/or retains high profile law offices and/or attorneys all over the world who are at standby to assist overseas Filipino Workers involved in legal problems. To meet the financial requirements of its program, the Organization shall generate funds through membership fees, grants and other fund raising activities. Pre-need plans are contracts which provide for the payment and/or performance of future service(s) or monetary consideration(s) at the time of actual need payable in cash or installment by the planholders at stated prices. A pre-need program partakes of a financing scheme designed for buyers who pay the pre-need plans at stated price on the assumption and anticipation of future services or monetary considerations at the current stated price. Thus, if the role of the above-named Organization is merely to provide assistance to its members who are encountering legal problems by contracting a law firm to assist them without undertaking the activity of selling pre-need contracts as defined above, it cannot be said to be engaged in a "pre-need" business. Very truly yours, (SGD.) ROSALINDA U. CASIGURAN Associate Commissioner