Country Manuals Independent Portfolio Manager/Advisor (EAM)
PHILIPPINES OUT OF COMPANY’S COUNTRY OF ESTABLISHMENT (Def, RS & BT)
Regulatory Summary
Material changes
Following consultations with our local counsel, we have reviewed and updated the documents to take into account an evolving interpretation of the regulatory framework.
We can confirm that while there have been no relevant regulatory changes since the last publication of this Country Manual, the following material change has occurred with respect to the licensing requirements for the introduction of a third-party foreign custodian bank’s custody services by a foreign Company. The answer is now represented by a NO for onsite activities conducted both on an active and passive basis, as the foreign Company presenting the Bank’s custodian services while on Philippine territory would be seen as the solicitation/promotion of regulated financial services in the Philippines which is subject to a license.
Non-material changes
(i) In a number of instances the comments for Grey zone/YES have been changed to reflect standardised comments that BRP has adopted as a result of using a new editing platform for the creation of manuals. The underlying reasoning has not changed.
(ii) Several comments have been slightly reworded (without introducing material changes) to reflect the regulatory situation/current interpretation of the regulatory framework more accurately.
Behaviour Template
The answers in the BT have been aligned to those contained in the RS.
BT Short Comparison
BRP has created a comparison document allowing users to quickly identify the modifications made compared to the previous version of the PB Manual (BT Short Comparison). The BT Short Comparison can be found on BRP’s platform (mybrponline) in the Search tab by entering in the Document Field “CM EAM BT SHORT COMP” and “PHILIPPINES” in the Target Country Field.
The BT Short Comparison should be read as follows:
The first column contains a short description of the activity in question. The second column contains the answers of the previous version of the Country Manual (online until the day of the alert). The third column contains the new answers of the most recent version of the Country Manual. Only the modified answers are displayed (in color). If the answers in the new version are unchanged compared to the previous version, they are shaded in grey.
Best regards,