SEC FORM 12-1-ICA

REGISTRATION STATEMENT
CHECKLIST OF REQUIRED DISCLOSURES

REGISTRANT:
Date of Registration Statement:
Date Filed:
Reviewed by:
Date:
Summary of Comments
CGFD Ref. Page Comments/
Leg. Ref. List of Disclosure Requirements on Registration Statement/ Prospectus No.* No. Remarks Recommendations
General Instruction: A remark of "Not Applicable (NA)" or "Compliance (C)" or "Non-Compliance (NC)" or "Incomplete (INC) " is indicated herein to
emphasize or highlight the information not found in the report. If the required information is not applicable, please state/explain in a separate covering
letter.
General Comment: 1.) Provide all undisclosed details and figures; 2) Make reference to specific page/s. Do not merely state “elsewhere in the prospectus”.
COVER SHEET
1. SEC Identification Number CS.1
2. Exact name of registrant as specified in its charter CS.2
3. Province, country or other jurisdiction of incorporation or organization CS.3
4. BIR Tax Identification Number CS.4
5. General character of business of registrant CS.5
6. Industry Classification Code: ____________ (SEC Use only) CS.6
7. Address, including postal code, telephone number, FAX number including area
code, of registrant's principal offices CS.7

8. If registrant is not resident in the Philippines, or its principal business is outside the
Philippines, state name and address including postal code, telephone number and FAX
number, including area code, and email address of resident agent in the Philippines. CS.8
9. Fiscal Year Ending Date (Month and Day) CS.9
Computation of Registration Fee
1. Title of each Class of securities to be registered RF.1
2. Amount to be registered RF.2
3. Proposed Maximum offering price per unit RF.3
4. Proposed maximum aggregate offering price RF.4
5. Amount of registration fee RF.5
PART I - INFORMATION REQUIRED IN PROSPECTUS

ITEM 1. FRONT OF THE REGISTRATION STATEMENT AND OUTSIDE FRONT COVER PAGE OF PROSPECTUS

1. Name of the Issuer I.1.1

[Note: The name of the corporation shall contain the word “Fund” and indicate
whether it is an Equity Fund, Bond or Fixed Income Fund, Balanced Fund, Money
Market Fund, Index Fund, Feeder Fund, Fund-of-funds, Co-Managed Fund, Multi-
asset/Asset Allocation funds etc.
I.1.2
Indicate whether the fund is open-en or closed-end.

If units are to be offere, it shall contain the words "Unitized Mutual Fund" or
"UMF".]
Part VI,
Par. (A) of 2. The terms of the offer including:
"Annex C, a. Description and amount of securities offered I.1.2.a
as
[ Note: It shall have a minimum subscribed and paid up capital of Fifty Million
amended"
Pesos (Php50,000,000.00)]
and ICA
IRR b. Public offering price, or the offering price range in the case of a preliminary
I.1.2.b
prospectus
c. Where the securities will be traded (exchange or over-the-counter) I.1.2.c

3. Name/s of the underwriter/s or Distributors I.1.3

4. The date of the prospectus I.1.4

5. The following statement in bold face 12 point type, prominently displayed: I.1.5

THE SECURITIES AND EXCHANGE COMMISSION HAS NOT APPROVED THESE

SECURITIES OR DETERMINED IF THIS PROSPECTUS IS ACCURATE OR
COMPLETE. ANY REPRESENTATION TO THE CONTRARY IS A CRIMINAL
OFFENSE AND SHOULD BE REPORTED IMMEDIATELY TO THE SECURITIES
AND EXCHANGE COMMISSION.
6. Summary of fees, commissions and other charges to be deducted from the fund and
I.1.6
paid by the shareholders/unit holders

ITEM 2. INSIDE FRONT COVER AND FIRST TWO OR MORE PAGES OF PROSPECTUS
1. If not included on the cover of the prospectus, provide the following information on I.2.1
the inside front cover:
a. Number of shares offered by current stockholders I.2.1.a
1 of 14
 b. Total number of shares outstanding after the offering I.2.1.b
c. Total proceeds raised by the offering I.2.1.c
d. Brief description of use of proceeds from the offering I.2.1.d
e. Underwriters' fees I.2.1.e
f. Dividend policy and frequency of declaration I.2.1.f
g. Address and telephone number of the company's principal office. I.2.1.g

2. Table of Contents I.2.2

3. Brief description of the company's business. More detailed information shall be
I.2.3
provided in the body of the prospectus.
[Note: The primary purpose clause of the AOI shall provide that the corporation
shall engage in the business of investing, reinvesting or trading in securities or
other investment assets allowed under the Act and this Rule]

4. Summary paragraph or key points characterizing the risks of the offering under the
caption "Risks of Investing". More detailed information shall be provided in the body of I.2.4
Part VI, the prospectus.
Paragraph
(B) of 5. Summary financial information (data shall include, but need not be limited to the
I.2.5
"Annex C, following:
as a. Abbreviated income statement data for prior two years I.2.5.a
amended" b. Abbreviated balance sheet data for the prior two years I.2.5.b
and ICA 6. A Glossary which defines all technical terms used in the prospectus. I.2.6
IRR
7. The following statement in bold face 12-point type, prominently displayed, in the case
I.2.7
of a preliminary prospectus :

A REGISTRATION STATEMENT RELATING TO THESE SECURITIES HAS BEEN

FILED WITH THE SECURITIES AND EXCHANGE COMMISSION BUT HAS NOT YET
BEEN DECLARED EFFECTIVE. NO OFFER TO BUY THE SECURITIES CAN BE
ACCEPTED AND NO PART OF THE PURCHASE PRICE CAN BE ACCEPTED OR
RECEIVED UNTIL THE REGISTRATION STATEMENT HAS BECOME EFFECTIVE,
AND ANY SUCH OFFER MAY BE WITHDRAWN OR REVOKED, WITHOUT
OBLIGATION OR COMMITMENT OF ANY KIND, AT ANY TIME PRIOR TO NOTICE
OF ITS ACCEPTANCE GIVEN AFTER THE EFFECTIVE DATE. AN INDICATION OF
INTEREST IN RESPONSE HERETO INVOLVES NO OBLIGATION OR
COMMITMENT OF ANY KIND. THIS PROSPECTUS SHALL NOT CONSTITUTE AN
OFFER TO SELL OR THE SOLICITATION OF AN OFFER TO BUY.

8. Provide a statement that the liability of the shareholders or loss to the unitholders are I.2.8
limited to their investments to the investment company;
9. In the case of a prospectus that has become effective, the following statement in
bold face 12-point type, prominently displayed, and signed by the president under I.2.9
oath:
ALL REGISTRATION REQUIREMENTS HAVE BEEN MET AND ALL INFORMATION
CONTAINED IS TRUE AND CURRENT.
ITEM 3. RISK FACTORS AND OTHER INFORMATION
RISK FACTORS

Under the caption "Risk Factors", registrant shall list in the order of importance and
discuss fully the factors that make the offering speculative or risky (i.e. those factors
which constitute the greatest threat that the investment in the securities will be lost in
whole or in part, or not provide an adequate return). These factors may include, among I.3.C
other things, an absence of operating history of the registrant, no recent profit from
operations, poor financial position, the kind of business in which the registrant is
engaged or proposes to engage, or no market for the registrant's securities.

I. GENERAL RISK WARNING

a. The price of securities can and does fluctuate, and any individual security may
experience upward or downward movements, may even become valueless. There I.3.I.a
is an inherent risk that losses may be incurred rather than profit made as a result of
buying and selling securities.
b. Past performance is not a guide to future performance. I.3.I.b
c. There is an extra risk of losing money when securities are brought from smaller
Part VI, companies. There may be a big difference between the buying and selling price of I.3.I.c
Par. (C) these securities.
and (D) of
"Annex C d. An investor deals in a range of investments each of which may carry a different I.3.I.d
as level of risk.
amended"
II. PRUDENCE REQUIRED
and ICA
IRR This risk disclosure does not purport to disclose all the risks and other significant
aspects investing in these securities. An investor should undertake his or her own
research and study on the trading of securities before commencing any trading activity. I.3.II
He/she may request information on the securities and the issuer thereof from the
Commission which are available to the public.

III. PROFESSIONAL ADVICE

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 a. An investor should seek professional advice if he or she is uncertain of, or has not
understood any aspect of the securities to invest in or the nature of risks involved in I.3.III.a
trading of securities specially those high risk securities.
i. List in the order of importance and discuss fully the factors that make the offering I.3.III.a.i
speculative or risky
ii. Discussion on how the company shall manage the risks I.3.III.a.ii

b. Risk monitoring and management procedure, including a risk management

I.3.III.b
framework for the assets managed by the Fund Manager

c. Discuss risk monitoring and management procedure, including a risk management

framework for the assets managed by the fund manager based on the size, complexity I.3.III.c
and risk of the AUM;

ITEM 4. USE OF PROCEEDS

a. State the principal purposes for which the net proceeds of the offering will be
used, indicating the approximate amount intended to be used for each such
purpose. Where the registrant has no current specific plan for the proceeds, I.4.a
or a significant portion thereof, the registrant shall so state and discuss the
principal reasons for the offering.

b. Where less than all of the securities to be offered may be sold and more than
one use is listed for the proceeds, the registrant shall indicate the order of priority of
I.4.b
such purposes and discuss its plans if substantially less than the maximum
proceeds are obtained.
c. If any material amounts of other funds are necessary to accomplish the
specified purpose/s for which the offering is made, the registrant shall state the I.4.c
amounts and sources of such other funds needed.
Part VI, d. If a material amount of proceeds will discharge debt, state the interest rate and
Par. (E) of maturity. If debt was incurred within one year, describe the use of the proceeds of I.4.d
"Annex C, that debt
as
amended" e. If any material amount of proceeds is to be used to acquire assets or finance
the acquisition of other business, describe the asset or business and identify the
person from whom they will be bought. State the cost of the asset, where such I.4.e
asset is to be acquired from affiliates of the registrant or their associates, give the
names of the persons. Set forth the principle followed in determining the cost.

f. Explain, if any of the proceeds are to be used to reimburse any officer, director,
employee or shareholder for service rendered, assets previously transferred, money I.4.f
loaned or advance or otherwise.

I.4.g
g. Disclose the expenses which shall be deducted or paid out of the gross proceeds
h. State that the proceeds from the sale of securities, including the original
subscription payments at the time of incorporation constituting the original paid-in I.4.h
capital of the investment company, shall be held by a custodian bank referred to in
rules adopted under the Investment Company Act.

i. Investment powers of the Fund Managers with respect to the funds of the
I.4.i
Investment Company.

ITEM 5. DETERMINATION OF OFFERING PRICE

a. The price of securities subscribed or redeemed within the cut-off time of the day the
subscription or request for redemption is received, respectively, shall be based on the
Rule 8 of net asset value per share/unit computed as of the closing day. Subscription or request
I.5.a
ICA IRR for redemption received beyond the cut-off time is deemed received the following
banking day and to be priced at net asset value per share/unit computed on the next
banking day

b. Generally the daily cut-off time shall be at 12:00 noon. A different cut-off time may be
I.5.b
set as long as it is provided in the prospectus.

c. Daily Computation and Publication of the NAVps and NAVpu I.5.c

d. Pricing method/methodology of asset valuation (Price Determination of the Assets) I.5.d

e. Net Asset Value Calculation I.5.e

ITEM 6. PLAN OF DISTRIBUTION

(I) PLAN OF DISTRIBUTION

This section requires the disclosure of the amount of compensation to the selling
agents and underwriters, and the nature of any relationships between them and the
registrant. After reviewing the information contained herein, a potential investor should I.6.I
be in a better position to assess the extent to which he may rely upon any
recommendation by the underwriter or selling agent to buy the securities.

1. Underwriters/Marketers and underwriting/marketing obligation

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 a. State the name of the lead underwriter/s and the respective amounts
underwritten. Identify each underwriter having a material relationship with the
I.6.I.1.a
registrant and describe the nature of the relationship. State briefly the nature
of the obligation of the underwriter/s to take the securities.

b. If any of the underwriters has a contract or other arrangement with the issuer
by which the underwriter may put back to the issuer any unsold securities of the
I.6.I.1.b
offering, so state, and submit a copy of the agreement or, if oral, state the
substance thereof.

c. Disclose whether or not the underwriter or marketer is licensed by the

Commission to engaged in underwriting or distribution of securities to I.6.I.1.c
the public, or the status of its application, if not yet licensed.

2. New Underwriters
Part VI,
Par. (I), Describe the business experience of the lead underwriter. If such
(J) and (K) underwriter has been in business less than three years, state their principal I.6.I.2
of "Annex business function and identify any material relationships between the promoters
C, as of the issuer and the underwriter/s. This information need not be given if the
amended" issuer is a reporting company and an offering has no material risks.
and ICA 3. Other Distributions
IRR
Outline briefly the plan of distribution of any securities to be registered that
I.6.I.3
are to be offered other than through underwriters.
4. Underwriters' Compensation
To the extent not set forth on the cover page of the prospectus, describe the
discounts and commissions paid or to be paid, directly or indirectly, to the I.6.I.4
underwriters.
5. Underwriter's Representative in the Board of Directors
Describe any arrangement whereby the underwriter has the right to
designate or nominate a member/s of the board of directors of the registrant. I.6.I.5
Identify any director so designated or nominated and indicate any relationship
with the registrant.
6. Designated Shares and Allocations

State whether any shares are designated to be sold to specified persons

and, if so, name them and the amount of the shares to be so designated. State
I.6.I.6
the manner in which shares are to be allocated to an Exchange and/or to its
members, or by an Exchange to its members.

7. Procedure for monitoring fund distribution I.6.I.7

(J) BROKERS/DEALERS' COMPENSATION

State briefly the discounts and commissions to be allowed or paid to Broker

Dealers, including all cash, securities, contracts or other considerations to be I.6.J
received by any Broker Dealer in connection with the sale of the securities.

ITEM 7. DESCRIPTION OF SECURITIES TO BE REGISTERED

1. Common or Preferred Stock
a. State the amount of capital stock of each class issued or included in the shares
I.7.1.a
of stock to be offered.
Part II, b. If the registrant is offering common equity, describe any dividend, voting and
Par. (B) of I.7.1.b
preemption rights.
"Annex C,
as
amended" c. If the registrant is offering preferred stock, describe the dividend, voting, I.7.1.c
conversion and liquidation rights as well as redemption or sinking fund provisions.

I.7.1.d
d. Describe any other material rights of common or preferred stockholders.
e. Describe any provision in the charter or by-laws that would delay, defer or
I.7.1.e
prevent a change in control of the registrant.

Part VI,
Paragraph ITEM 8. INTERESTS OF NAMED EXPERTS AND INDEPENDENT COUNSEL
(L) of a. Direct or Indirect Interest in Registrant I.8.a
"Annex C,
as
I.8.b
amended" b. Disclosure is not necessary if the interest of an expert or independent counsel does
not exceed P500,000.00

ITEM 9. INFORMATION WITH RESPECT TO THE REGISTRANT

A. DESCRIPTION OF BUSINESS

(1) BUSINESS DEVELOPMENT

4 of 14
 Describe the development of the business of the registrant and its significant
subsidiaries during the past three (3) years , or such shorter period as the registrant
may have been engaged in business. If the registrant has not been in business for I.9.A.1
three years, give the same information for predecessor(s) of the registrant if there is
any. This business development description should include, for the registrant and its
subsidiaries, the following:
(a) Form and date of organization I.9.A.1.a
(b) Any Bankruptcy, Receivership or Similar Proceedings I.9.A.1.b

(c ) Any Material Reclassification, Merger, Consolidation, or Purchase or Sale of a

I.9.A.1.c
Significant Amount of Assets (not in the ordinary course of business)

(2) BUSINESS OF ISSUER

This section shall describe in detail what business the registrant does and
proposes to do , including what products or goods are or will be produced or I.9.A.2
services that are or will be rendered .
(a) Description of Registrant

Briefly describe the business of registrant and its significant subsidiaries and
I.9.A.2.a
include, to the extent material to an understanding of the registrant:

(i) Principal products or services and their markets indicating their relative
contribution to sales or revenues of each product or service, or group of related
products or services, which contribute ten percent (10%) or more to sales or
I.9.A.2.a.i
revenues. If the relative contribution to net income of any product or service, or
group of related products or services, is substantially different than its relative
contribution to sales or revenues, appropriate information should be given;

(ii) Percentage of sales or revenues and net income contributed by foreign

sales (broken down into major markets such as Western Europe, I.9.A.2.a.ii
Southeast Asia, etc.) for each of the last three years;

(iii) Distribution methods of the products or services; I.9.A.2.a.iii

(iv) Status of any publicly-announced new product or service (e.g. whether in
the planning stage, whether prototypes exist), the degree to which product
design has progressed or whether further engineering is necessary. Indicate if I.9.A.2.a.iv
completion of development of the product would require a material amount of
the resources of the registrant and the estimated amount;

Part I,
(v) Competition. Describe the industry in which the registrant is selling or
Par. (A) of
expects to sell its products or services, and where applicable , any recognized
"Annex C,
trends within that industry. Describe the part of the industry and the geographic
as
area in which the business competes or will compete. Identify the principal
amended"
methods of competition (price, service, warranty or product performance). I.9.A.2.a.v
Name the principal competitors that the registrant has or expects to have in its
area of competition. Indicate the relative size and financial and market
strengths of the registrant’s competitors. State why the registrant believes that it
can effectively compete with other companies in its area of competition;

(vi) Sources and availability of raw materials and the names of principal
suppliers; If the registrant is or is expected to be dependent upon one or a
I.9.A.2.a.vi
limited number of suppliers for essential raw materials, energy or other items,
describe. Describe any major existing supply contracts;

(vii) Disclose how dependent the business is upon a single customer or a few
customers, the loss of any or more of which would have a material adverse
effect on the registrant and its subsidiaries taken as a whole. Identify any
I.9.A.2.a.vii
customer that accounts for, or based upon existing orders will account for,
twenty percent (20%) or more of the registrant’s sales; Describe any major
existing sales contracts;

(viii) Transactions with and/or dependence on related parties; I.9.A.2.a.viii

(ix) Summarize the principal terms and expiration dates of all patents,
trademarks, copyrights, licenses, franchises, concessions, and royalty
agreements held; Indicate the extent to which the registrant’s operations I.9.A.2.a.ix
depend, or are expected to depend, on the foregoing and what steps are
undertaken to secure these rights;
(x) Need for any government approval of principal products or services. If
government approval is necessary and the registrant has not yet received that
I.9.A.2.a.x
approval, discuss the status of the approval within the government approval
process;

(xi) Effect of existing or probable governmental regulations on the business; I.9.A.2.a.xi

(xii) Indicate the amount spent on research and development activities, and its
I.9.A.2.a.xii
percentage to revenues during each of the last three fiscal years;

(xiii) Costs and effects of compliance with environmental laws; I.9.A.2.a.xiii

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 (xiv) State the number of the registrant's present employees and number of
employees it anticipates to have within the ensuing twelve (12) months. Indicate
the no. by type of employee (I.e. clerical, operations, administrative,etc.)
whether or not any of them are subject to Collective Bargaining Agreements
I.9.A.2.a.xiv
(CBA) and the expiration dates of any CBA. If the registrant's employees are
on strike, or have been in the past three (3) years, or are threatening to strike,
describe the dispute. Indicate any supplemental benefits or incentive
arrangements the registrant has or will have with its employees.

(xv) Discuss the major risk/s involved in each of the businesses of the company
and subsidiaries. Include a disclosure of the procedures being undertaken to I.9.A.2.a.xv
identify, assess and manage such risks.
(b) Additional Requirements for Investment Company
A. a statement of its proposed operation including the proposed investment
I.9.A.2.b.A
objectives and initial investment plans;

B. Category of the fund whether aggressive, growth-oriented, or

conservative; character and kind of investments which may be purchased
I.9.A.2.b.B
by the Fund Manager on behalf of the Investment Company and dealings in
debt securities, whether it is short term, medium term or long term

C. Profile of the prospective investors and investment suitability I.9.A.2.b.C

D. The procedure for issuance and redemption/payoff structure, redemption

I.9.A.2.b.D
centers and the costs involved

E. Name and background of the parties which should include roles, duties
and responsibilities of the Fund Manager, Fund Advisor, Fund Distributor, I.9.A.2.b.E
Custodian, Fund Accountant, and Transfer Agent
F. Liabilities of the investment company and the fund manager to the
I.9.A.2.b.F
shareholders/unit holders

G. Disclosures on related party transactions and description of involvement,

if any, of the Investment Company, Fund Manager, their officers, or I.9.A.2.b.G
directors in companies which the Investment Company will be dealing with

ICA IRR
H. Annual meeting of shareholders I.9.A.2.b.H

I. Procedure for handling customer’s complaints I.9.A.2.b.I

J. Policies on the following: conflict of interest; and management and

I.9.A.2.b.J
procedures in monitoring and resolving conflicts of interest

K. Delegation of fund management or custody of assets, if any I.9.A.2.b.K

L. Borrowing of money I.9.A.2.b.L

M. Anti-money laundering, FATCA and counter-terrorist financing policies I.9.A.2.b.M

N. Taxation I.9.A.2.b.N

O. Other laws and government policies applicable to the company I.9.A.2.b.O

P. Procedures to ensure compliance with relevant Laws and Regulations I.9.A.2.b.P

Q. The rights of the shareholders/unit holders in case of dissolution of the

I.9.A.2.b.Q
Investment Company and the dissolution plan

B. DESCRIPTION OF PROPERTIES

Part I, Give the location and describe the condition of the principal properties (such as real
Par. (B) of estate, plant and equipment, mines, patents, etc.) that the registrant and its subsidiaries
"Annex C, own. Disclose any mortgage, lien or encumbrance over the property and describe
as I.9.B
the limitations on ownership or usage over the same . Indicate also what properties
amended"
it leases, the amount of lease payments, expiration dates and the terms of renewal
options. Indicate what properties the registrant intends to acquire in the next twelve
(12) months, the cost of such acquisitions, the mode of acquisition (i.e. by purchase,
lease or otherwise) and the sources of financing it expects to use.
C. LEGAL PROCEEDINGS
Part I,
paragraph 6 of 14
(C) of
"Annex C,
as
amended"
Part I, Describe briefly any material pending legal proceedings to which the registrant or
paragraph any of its subsidiaries or affiliates is a party or of which any of their property is
(C) of the subject. Include the name of the court or agency in which the proceedings are
"Annex C, pending, the date instituted, the principal parties thereto, a description of the factual I.9.C
as basis alleged to underlie the proceedings and the relief sought. Include similar
amended" information as to any such proceedings known to be contemplated by governmental
authorities or any other entity.

D. MARKET FOR ISSUER'S COMMON EQUITY AND RELATED STOCKHOLDERS’ MATTERS

(A) MARKET PRICE OF AND DIVIDENDS ON REGISTRANT'S COMMON EQUITY AND RELATED STOCKHOLDER MATTERS
(1) MARKET INFORMATION

(a) Identify the principal market or markets where the registrant's common I.9.D.A.1.a
equity is traded. If there is no public trading market, so state.

(i) If the principal market for the registrant's common equity is a Stock
Exchange in the Philippines or a foreign Exchange, state the name of
that Exchange and give the high and low sales prices for each quarter
within the last two fiscal years and any subsequent interim period for I.9.D.A.1.a
which financial statements are required by SRC Rule 68. If the prices
stated are from a foreign Exchange, they shall be stated in the currency
in which they are quoted. The registrant may translate such prices into
Philippine currency at the official currency exchange rate in effect on the
date the price disclosed was reported on the foreign exchange,
including disclosure of the exchange rate used for the calculation.

(ii) If the principal market is not an Exchange, state the frequency with
which trading occurs; if sporadic, so state; give the range of high and
low bid information for the registrant's common equity for each quarter I.9.D.A.1.a
within the last two fiscal years and any subsequent interim period for
which financial statements are required by SRC Rule 68. Show the
source of statements regarding frequency of trading and the high and
low bid information.

(b) If the information called for by paragraph (A) of this Part is being
presented in a registration statement filed pursuant to Section 12 or in an
annual report filed pursuant to Section 17 of the Code, the document shall I.9.D.A.1.b
also include price information as of the latest practicable trading date, and,
in the case of securities to be issued in connection with an acquisition,
business combination or other reorganization, as of the trading date
immediately prior to the public announcement of such transaction

(c) If the information called for by paragraph (A) of this Part is being
presented in a registration statement relating to a class of common equity I.9.D.A.1.c
for which at the time of filing there is no established public trading market in
the Philippines, indicate the amounts of common equity:

(i) that is subject to outstanding options or warrants to purchase, or I.9.D.A.1.c.i

securities convertible into, common equity of the registrant;

(ii) that is being or has been proposed to be publicly offered by the

registrant, unless such common equity is being offered pursuant to an I.9.D.A.1.c.ii
employee benefit or stock options plan, the offering of which could have
a material effect on the market price of the registrant's common equity.
(2) HOLDERS

(a) Set forth the approximate number of holders of each class of common
equity of the registrant as of the latest practicable date but in no event more
I.9.D.A.2.a
than ninety (90) days prior to filing the registration statement. Include the
names of the top twenty (20) shareholders of each class and the number of
shares held and the percentage of total shares outstanding held by each.

Part II, (b) If the information called for by this subparagraph (2) is being presented
Par. (A)(1) in a registration statement filed pursuant to Section 12, or an information
through statement filed pursuant to Section 20 of the Code, that relates to an I.9.D.A.2.b
(4) of acquisition, business combination or other reorganization, indicate the effect
"Annex C, of such transaction on the amount and percentage of present holdings of
as the registrant's common equity owned beneficially by:
amended" (i) any person or group who is known to the registrant to be the
beneficial owner of more than five percent (5%) of any class of the I.9.D.A.2.b.i
registrant's common equity;
(ii) each director and nominee; and I.9.D.A.2.b.ii

7 of 14
amended"

(iii) all directors and officers as a group, and the registrant's present
I.9.D.A.2.b.iii
commitments to such persons with respect to the issuance of shares of
any class of its common equity.

(c) For purposes of subparagraph (2)(b)(i) hereof, the term "group" shall
mean two or more persons acting as a partnership, limited partnership, I.9.D.A.2.c
syndicate or other group for the purpose of acquiring, holding or disposing
of securities of an issuer.

(d) If the information called for by this subparagraph (2) is being presented
in a registration statement filed pursuant to Section 12 indicate the effect of
such issuance on the amount and percentage of present holdings of the I.9.D.A.2.d
registrant's common equity holders. Indicate the effect of the issuance on
the percentage of the registrant’s securities beneficially owned by
foreigners.
(3) DIVIDENDS
(a) Discuss any cash dividends declared on each class of its common
equity by the registrant for the two most recent fiscal years and any
I.9.D.A.3.a
subsequent interim period for which financial statements are required to be
presented by SRC Rule 68.

(b) Describe any restrictions that limit the ability to pay dividends on I.9.D.A.3.b
common equity or that are likely to do so in the future.
(4) RECENT SALES OF UNREGISTERED OR EXEMPT SECURITIES, INCLUDING RECENT ISSUANCE OF SECURITIES
CONSTITUTING AN EXEMPT TRANSACTIONS

Furnish the following information as to all securities of the registrant sold by

it within the past three (3) years which were not registered under the Code.
Include sales of reacquired securities, as well as new issues, securities issued
in exchange for property, services, or other securities, and new securities I.9.D.A.4
resulting from the modification of outstanding securities. Indicate whether the
issuer received written confirmation from the Commission under SRC Rule 10.1
that such exemptive relief from registration was available and, if so, the date
such confirmation was issued:
(a) Securities Sold
Give the date of sale and the title and amount of securities sold. I.9.D.A.4.a
(b) Underwriters and Other Purchasers

Give the names of the underwriters, if any. If securities were not

publicly offered, identify the persons or the class of persons to whom
the securities were sold; provided however, in connection with I.9.D.A.4.b
securities sold under Section 10.1 of the Code and SRC Rule 10.1 (k)
thereunder, disclose the date that the required notice of such sale was
provided to the Commission.
(c) Consideration

For securities sold for cash, state the total offering price and the total
underwriting discounts or commissions. For securities sold otherwise I.9.D.A.4.c
than for cash, state the nature of the transaction and the type and
amount of consideration received by the registrant.
(d) Exemption from Registration Claimed

Indicate the section of the Code or the rule or regulation under which
I.9.D.A.4.d
an exemption from registration is claimed and state briefly the facts
relied upon to make the exemption available.

E. MANAGEMENT'S DISCUSSION AND ANALYSIS OR PLAN OF OPERATIONS

Registrants that have not had revenues from operations in each of the last two fiscal
years, or the last fiscal year and any interim period in the current fiscal year for which
financial statements are furnished in the disclosure document, shall in addition to
applicable items under subparagraph (2) , provide the information in subparagraph
(1) hereof.

(1) Plan of Operation. Describe the plan of operation for the next twelve (12) months.
I.9.E.1
This description should include such matters as:

(a) a discussion of how long the registrant can satisfy its cash requirements and
I.9.E.1.a
whether it will have to raise additional funds in the next twelve (12) months;

(b) a summary of any product research and development that the registrant will
I.9.E.1.b
perform for the term of the plan;

(c) any expected purchase or sale of plant and significant equipment; and I.9.E.1.c

(d) any expected significant changes in the number of employees. I.9.E.1.d

(2) A. Management’s Discussion and Analysis. MD&A helps to explain financial

results. A reader of the MD&A should be able to understand the financial results of the
registrant’s business as discussed in the “Business” section. It shall provide information
I.9.E.2.A
with respect to liquidity, capital resources and other information necessary to
understand the registrant's financial condition and results of operation including
peformance benchmark .
8 of 14
 Note: With respect to performance benchmark, the Investment Company shall
disclose where the information on the benchmark can be obtained. If a
customized benchmark or combination of multiple benchmarks is used, there
shall be a description on how the benchmark is derived.

For both full fiscal years and interim periods, disclose the company’s and its
majority-owned subsidiaries’ top five (5) key performance indicators. It shall
include a discussion of the manner by which the company calculates or
identifies the indicators presented on a comparable basis

(a) Full fiscal years

Discuss the registrant's financial condition, changes in financial condition

and results of operations for each of the last three fiscal years . If the
registrant’s financial statement shows losses from operations, explain the
causes underlying these losses and the steps the registrant has taken or is
taking to address these causes. This discussion should address the past and
I.9.E.2.a
future financial condition and results of operation of the registrant, with
particular emphasis on the prospects for the future. The discussion should also
address those key variable and other qualitative and quantitative factors which
are necessary to an understanding and evaluation of the registrant. If material,
the registrant should disclose the following:

(i) Any known trends or any known demands, commitments, events or

uncertainties that will result in or that are reasonably likely to result in the
registrant’s liquidity increasing or decreasing in any material way. The
registrant shall indicate balance sheet conditions or income or cash flow
items that it believes may be indicators of its liquidity condition. The
Part III,
following conditions shall be indicated: whether or not the registrant is
Par. (A) of
having or anticipates having within the next 12 months any cash flow or
"Annex C,
liquidity problems; whether or not the registrant is in default or breach of any
as I.9.E.2.a.i
note, loan, lease or other indebtedness or financing arrangement requiring it
amended"
to make payments; whether or not a significant amount of the registrant's
trade payables have not been paid within the stated trade terms. If a
material deficiency is identified, the course of action that the registrant has
taken or proposes to take to remedy the deficiency should also be
indicated. The registrant should identify and separately describe internal
and external sources of liquidity, and briefly discuss any sources of liquid
assets used;

The term “liquidity” refers to the ability of an enterprise to generate

adequate amount of cash to meet its needs for cash. Liquidity generally
must be discussed on both long and short-term bases.

(ii) Any events that will trigger direct or contingent financial

obligation that is material to the company, including any default or I.9.E.2.a.ii
acceleration of an obligation;

(iii) All material off-balance sheet transactions, arrangements,

obligations (including contingent obligations), and other
I.9.E.2.a.iii
relationships of the company with unconsolidated entities or other
persons created during the reporting period;

(iv) Any material commitments for capital expenditures, the general purpose
of such commitments, and the expected sources of funds for such I.9.E.2.a.iv
expenditures should be described;

(v) Any known trends, events or uncertainties that have had or that are
reasonably expected to have a material favorable or unfavorable impact on
net sales or revenues or income from continuing operations should be
described. If the registrant knows of events that will cause a material I.9.E.2.a.v
change in the relationship between costs and revenues (such as known
future increases in cost of labor or materials or price increases or inventory
adjustments), the change in the relationship shall be disclosed;

(vi) Any significant elements of income or loss that did not arise from the
I.9.E.2.a.vi
registrant's continuing operations;

(vii) The causes for any material change from period to period which shall
I.9.E.2.a.vii
include vertical and horizontal analyses of any material item;

The term “material” in this section shall refer to changes or items

amounting to five percent (5%) of the relevant accounts or such lower
amount, which the registrant deems material on the basis of other
factors.
(viii) Any seasonal aspects that had a material effect on the financial
I.9.E.2.a.viii
condition or results of operations.
(b) Interim Periods

9 of 14
 If interim financial statements are included in the registration statement or
report, provide a comparable discussion that will enable the reader to assess
material changes in financial condition and results of operations since the end I.9.E.2.b
of the last fiscal year and for the comparable interim period in the preceding
year.
The company shall disclose the required information under
subparagraph (2)(a)(i) to (viii) above.

F. CHANGES IN AND DISAGREEMENTS WITH ACCOUNTANT ON ACCOUNTING AND FINANCIAL DISCLOSURES

(During the registrant's two most recent fiscal years)

1) If during the registrant's two most recent fiscal years or any subsequent interim
period, an independent accountant who was previously engaged as the principal
accountant to audit the registrant's financial statements, or an independent accountant
who was previously engaged to audit a significant subsidiary, ceased performing I.9.F.1
services for registrant, disclose the name of the previous accountant or the handling
partner in case of a firm , reason/s for the cessation of service and the date of his
Part III,
resignation, dismissal or cessation of performing services for registrant.
Paragraph
(B) of
"Annex C, 2) If there were any disagreements with the former accountant on any matter of
as accounting principles or practices, financial statement disclosure, or auditing scope or
amended" procedure which, if not resolved to the satisfaction of the former accountant, would have
I.9.F.2
caused it to make reference to the subject matter of the disagreement(s) in connection
with its report, describe such disagreement.

3) If there were any disagreements as described in subparagraph (2), the registrant

shall request the former accountant to furnish the registrant with a letter addressed to
the Commission stating whether it agrees with the statements made by the registrant
I.9.F.3
and, if not, stating the respects in which it does not agree. The registrant shall file the
former accountant's letter as an exhibit to the report or registration statement containing
this disclosure.

Information on Independent Accountant and other Related Matters

EXTERNAL AUDIT FEES and SERVICES
(a) Under the caption Audit and Audit-Related Fees, the aggregate fees billed for each
of the last two (2) fiscal years for professional services rendered by the external auditor I.9.AF.a
for:
1. The audit of the registrant's annual financial statements or services that are
normally provided by the external auditor in connection with statutory and regulatory I.9.AF.a.1
filings or engagements for those fiscal years; and

2. Other assurance and related services by the external auditor that are reasonably
related to the performance of the audit or review of the registrant's financial I.9.AF.a.2
SEC MC
statements. The registrant shall describe the nature of the services comprising the
No. 14,
fees disclosed under this category.
Series of
2004
(b) Under the caption "Tax Fees", the aggregate fees billed in each of the last two (2)
fiscal years for professional services rendered by the external auditor for tax accounting, I.9.AF.b
compliance, advice, planning and any other form of tax services. Registrant shall
describe the nature of the services comprising the fees disclosed under this category;

(c) Under the caption "All Other Fees", the aggregate fees billed in each of the last two
(2) fiscal years for products and services provided by the external auditor, other than I.9.AF.c
the services reported under items (a) & (b) above. Registrants shall describe the nature
of the services comprising the fees disclosed under this category; and

I.9.AF.d
(d) The audit committee's approval policies and procedures for the above services.
G. DIRECTORS, OFFICERS, PROMOTERS AND CONTROL PERSONS

Directors, Executive Officers, Promoters and Control Persons: This section requires
disclosure of information concerning the background of the registrant’s officers, I.9.G
directors, and other key personnel. A potential investor who reads this section should
be able to consider whether or not these persons have adequate background and
experience to develop and operate the registrant’s business and make it successful.
[ Note : All members of the Board of Directors shall be Filipino citizens]

(1) Identify Directors, Including Independent Directors, and Executive Officers

(a) List the names, ages and citizenship of all directors, including independent
directors, where required under Section 38 of the Code and SRC Rule 38.1 adopted
thereunder, and executive officers and all persons nominated or chosen to become I.9.G.1.a
such; in the case of an investment company, also provide the names of the
incorporators;
(b) List the positions and offices that each such person held, or will hold, if known, I.9.G.1.b
with the registrant;

(c) Give the person's term of office as a director and the period during which the I.9.G.1.c
person has served;

10 of 14
 (d) Briefly describe the person's business experience during the past five (5) years; I.9.G.1.d
and
(e) If a director, identify other directorships held in reporting companies, naming I.9.G.1.e
each company.
(2) Significant Employee

Give the information specified in paragraph (A)(1) for each person who is not an
executive officer but who is expected by the registrant to make a significant contribution
to the business. If the business is highly dependent on the services of certain key I.9.G.2
personnel, describe any arrangements to assure that these persons will remain with the
registrant and not compete upon any termination.

(3) Family Relationships

Part IV,
Describe any family relationships up to the fourth civil degree either by consanguinity or
Par. (A) of
affinity among directors, executive officers, or persons nominated or chosen by the I.9.G.3
"Annex C,
registrant to become directors or executive officers.
as
amended"
and ICA (4) Involvement in Certain Legal Proceedings
IRR (Occurred during the past 5 years and material to evaluation)
Describe any of the following events that occurred during the past five (5) years up to
the latest date that are material to an evaluation of the ability or integrity of any
I.9.G.4
director, any nominee for election as director, executive officer, underwriter or control
person of the registrant:

(a) Any bankruptcy petition filed by or against any business of which such person
was a general partner or executive officer either at the time of the bankruptcy or I.9.G.4.a
within two years prior to that time;
(b) Any conviction by final judgment, including the nature of the offense, in a
criminal proceeding, domestic or foreign, or being subject to a pending criminal
I.9.G.4.b
proceeding, domestic or foreign, excluding traffic violations and other minor
offenses;

(c) Being subject to any order, judgment, or decree, not subsequently reversed,
suspended or vacated, of any court of competent jurisdiction, domestic or foreign,
permanently or temporarily enjoining, barring, suspending or otherwise limiting his I.9.G.4.c
involvement in any type of business, securities, commodities or banking activities;
and

(d) Being found by a domestic or foreign court of competent jurisdiction (in a civil
action), the Commission or comparable foreign body, or a domestic or foreign
Exchange or other organized trading market or self regulatory organization, to have I.9.G.4.d
violated a securities or commodities law or regulation and the judgment has not
been reversed, suspended, or vacated.

(5) Promoters and Control Persons

Name and background of the parties which should include roles, duties and
responsibilities of the Fund Manager, Fund Advisor, Fund Distributor, Custodian, I.9.G.5.1
1 Fund Accountant, and Transfer Agent;
Liabilities of the investment company and the fund manager to the
I.9.G.5.2
2 shareholders/unit holders;

Legal proceedings involving fund manager, and their officers and directors. I.9.G.5.3
3
H. EXECUTIVE COMPENSATION

The information specified in paragraph (B)(2)(b), concerning the compensation of the

named executive officers, and in the aggregate as to all officers and directors as a I.9.H
group, shall be supplied for each of the registrant's last two completed fiscal years and
ensuing year, and shall be provided in a Summary Compensation Table.
1. Compensation of Directors

(a) Standard Arrangements. Describe any standard arrangements, stating

amounts, pursuant to which directors of the registrant are compensated, or are to
be compensated, directly or indirectly, for any services provided as a director, I.9.H.1.a
including any additional amounts payable for committee participation or special
assignments, for the last completed fiscal year and the ensuing year.

Part IV, (b) Other Arrangements. Describe the material terms of any other arrangements,
Par. (B) of including consulting contracts, pursuant to which any director of the registrant was
"Annex C, compensated, or is to be compensated, directly or indirectly, during the registrant's I.9.H.1.b
as last completed fiscal year, and the ensuing year, for any service provided as a
amended" director, stating the amount paid and the name of the director.

2. Employment Contracts and Termination of Employment and Change-in-Control Arrangements. Describe the terms and conditions of each of
the following contracts or arrangements:
(a) Any employment contract between the registrant and a named executive officer;
I.9.H.2.a
and

11 of 14
 (b) Any compensatory plan or arrangement, including payments to be received from
the registrant, with respect to a named executive officer, if such plan or
arrangement results or will result from the resignation, retirement or any other
termination of such executive officer's employment with the registrant and its
I.9.H.2.b
subsidiaries or from a change-in-control of the registrant or a change in the named
executive officer's responsibilities following a change-in-control and the amount
involved, including all periodic payments or installments, which exceeds
P2,500,000.

I. SECURITY OWNERSHIP OF CERTAIN BENEFICIAL OWNERS AND MANAGEMENT

(1) Security Ownership of Certain Record and Beneficial Owners

(1) Title of class
(2) Name, address of record owner and relationship with issuer
(3) Name of Beneficial Owner and Relationship with Record Owner I.9.I.1
(4) Citizenship
(5) No. of Shares Held

Complete the table under par.(c) (1) of Part IV for any person (including any "group")
who is known to the registrant to be directly or indirectly the record and/or beneficial
owner of more than 5% of any class of registrant's voting securities.
(2) Security Ownership of Management

Furnish the information under par. (c)(2) of Part IV, as of the date the registration
statement is filed, in substantially the tabular form indicated, as to each class of equity
securities of the registrant or any of its parents or subsidiaries other than directors'
qualifying shares, beneficially owned by all directors and nominees, naming them, each I.9.I.2
of the named executive officers as defined in paragraph (B)(1)(b)of this Part IV, and
Part IV,
directors and executive officers of the registrant as a group, without naming them. Show
Par. (C) of in column (3) the total number of shares beneficially owned and in column (4) the
"Annex C, percent of class so owned. Of the number of shares shown in column (3), indicate, by
as
footnote or otherwise, the amount of shares with respect to which such persons have
amended" the right to acquire beneficial ownership.

(1) Title of class

(2) Name of beneficial Owner
(3) Amount and nature of beneficial ownership I.9.I.2.a
(4) Citizenship
(5) Percent of Class
(3) Voting Trust Holders of 5% Or More
Where persons hold more than 5% of a class under a voting trust or similar agreement, I.9.I.3
provide the following:
(a) the title of such securities; I.9.I.3.a
(b) the amount that they hold under the trust or agreement (if not clear from the
I.9.I.3.b
table);
(c) the duration of the agreement; I.9.I.3.c
(d) the names and addresses of the voting trustees; and I.9.I.3.d
(e) a brief outline of the voting rights and other powers of the voting trustees under I.9.I.3.e
the trust or agreement.
(4) Changes in Control

I.9.I.4.e
Describe any arrangements which may result in a change in control of the registrant.
J. CERTAIN RELATIONSHIPS AND RELATED TRANSACTIONS

(1) In addition to the disclosures in the financial statements which are required
under SFAS/IAS No. 24 on the Related Party Disclosures, registrant shall describe
under this item the elements of the transactions that are necessary for an understanding
I.9.J.1.a
of the transactions' business purpose and economic substance, their effect on the
financial statements, and the special risks or contingencies arising from these
transactions. The Commission consider the discussion of the following to be necessary.

(a) the business purpose of the arrangement; I.9.J.1.a

(b) identification of the related parties transaction business with the registrant and I.9.J.1.b
nature of the relationship;
(c) how transaction prices were determined by parties; I.9.J.1.c

(d) if disclosures represent that transactions have been evaluated for fairness, a I.9.J.1.d
description of how the evaluation was made; and

I.9.J.1.e
(e) any ongoing contractual or other commitments as a result of the arrangement.
SEC MC
No. 14,
Series of
2004

12 of 14
SEC MC
No. 14,
Series of (2) The disclosure shall also include information about parties that fall outside the
2004 definition "related parties" under SFAS/IAS No. 24, but with whom the registrants or its
related parties have a relationship that enables the parties to negotiate terms of material
transactions that may not be available from other, more clearly independent, parties on
an arm's length basis. For example, an entity may be established and operated by
individuals that were former senior management of, or have some other current or
former relationship with, a registrant. The purpose of the entity may be to own assets I.9.J.2
used by the registrant or provide financing or services to the registrant. Although former
management or persons with other relationships may not meet the definition of a related
party pursuant to SFAS/IAS 24, the former management positions may result in
negotiation of terms that are more or less favorable than those available on an arm's-
length basis from clearly independent third parties that are material to the registrant's
financial position or financial performance.

In some cases, investors may be unable to understand the registrant's reported results
of operations without a clear explanation of these arrangements and relationships. Items
of similar nature may be disclosed in aggregate except when separate disclosure is
necessary for an understanding of the effects of related party transactions on the
financial statements

3. Description of involvement, if any, of the Investment Company, Fund Manager, their

ICA IRR I.9.J.3
officers, or directors in companies which the Investment Company will be dealing with

K. CORPORATE GOVERNANCE
The following information, as declared and approved by the Board of Directors of the I.9.K
company, shall be discussed:
(a) The evaluation system established by the company to measure or determine
the level of compliance of the Board of Directors and top-level management with its I.9.K.a
Manual of Corporate Governance;
(b) Measures being undertaken by the company to fully comply with the adopted I.9.K.b
leading practices on good corporate governance;
(c) Any deviation from the company’s Manual of Corporate Governance. It shall
I.9.K.c
include a disclosure of the name and position of the person/s involved, and the

(d) Any plan to improve corporate governance of the company. I.9.K.d

ITEM 10. FINANCIAL STATEMENTS

1. Statement of Management's Responsibility duly notarized and signed by
I.10.1
Chairman, CEO & CFO
2. Auditor’s Report [Refer to New Auditor's Report and requirement of Independent
Revised I.10.2
Securities Auditor per Part I(3) of Revised SRC Rule 68]
Regulation
Code (SRC) 3. Consolidated Audited Financial Statements (Part II(5)(A) of the Revised SRC
I.10.3
68 Rule 68

4. Other documents required to be attached to financial statements (Part I(5) of I.10.4

the Revised SRC Rule 68)

5 Schedules under Annex-J I.10.5

ICA IRR ITEM 11. PRODUCT HIGHLIGHT SHEET I.11

PART II - INFORMATION INCLUDED IN REGISTRATION STATEMENT BUT NOT REQUIRED IN PROSPECTUS

ITEM 12. OTHER EXPENSES OF ISSUANCE AND DISTRIBUTION

Give an itemized statement of all expenses of the offering, other than underwriting II.12
discounts and commissions. If any of the securities are registered for sale by security
Part VI,
holder, state how much of the expenses the security holder will pay.
Paragraph
(M) of 1. The itemized list should include Registration Fee, Taxes, Trustees and Transfer
"Annex C" Agents Fees, Cost of Printing and Engraving, Legal, Accounting and Engineering II.12.1
as Fees and any Listing Fees.
amended
2. Include as a separate any Premium paid by the registrant or any selling security II.12.2
holder on any policy to insure or indemnify director, or officer against any liability
they may incur in the registration, offering or sale of these securities.

3. If the amounts of any items are not known, give estimates but identify them as II.12.3
such.

ITEM 13. EXHIBITS

Provide an Exhibit Table which shall be filed or incorporated by reference as part of the
Registration Statement.
1. Draft Notice re: Filing of Registration Statement for Publication (Proof of Publication
II.13.1
of Notice, with Affidavit and copy of Publication shall be submitted after the publication)

13 of 14
 2. Articles of Incorporation (AOI) and By-Laws for newly organized corporations or
II.13.2
latest amended AOI and/or By-laws for existing investment companies

3. Opinion re: Tax Matter II.13.3

4. Consents of Experts and Independent Counsel (applicable only if the direct or indirect
II.13.4
interest of an expert or independent counsel in the registrant exceeds Php500,000)

5. Notarized Curriculum Vitae and Recent Photographs of Officers and Members of the
II.13.5
Board of Directors and Fund Manager
6. Bank Authorization which shall be continuous as long as the registration of securities
II.13.6
of the issuer is effective

7. Copy of Board Resolution approving the securities offering and authorizing the filing
II.13.7
of the RS

8. Duly notarized Board Resolution dated and manually signed by a majority of the
issuer’s Board of Directors; approving the disclosures contained in the RS and II.13.8
assuming responsibility for the information contained therein
9. Secretary’s Certificate as to adoption by the company’s Board re: (1) Adoption of a Fit
and Proper Rule for the selection of corporate directors/officer; (2) Submission of an
II.13.9
Undertaking allowing the SEC to resolve conflicting issues regarding the selection of
Part VII of independent directors
"Annex C,
as 10. Subscription Form (with attached Client Suitability Assessment Form); II.13.10
amended"
11. Manual on Corporate Governance II.13.11
12. Monitoring Clearance, if previously operating as ordinary corporation II.13.12
13. Management Agreement II.13.13

14. Distribution Agreement II.13.14

15. Custodian Agreement II.13.15

16. Transfer Agency Agreement II.13.16

17. Advisory Agreement (if any) II.13.17

18. Certification, under oath, by the President and Chairman of the Board, or their
equivalent in rank, describing the involvement, if any, by management or members of II.13.18
the Board of Directors in companies that the investment company will be dealing with

19. Redemption Form II.13.19

20. Anti-Money Laundering Manual/MLPP II.13.20

ITEM 14. SIGNATURES

a. Furnish any other document the omission of which will render the foregoing material
II.14.a
facts or any other part of the Registration Statement misleading.

b. Duly signed by the following (1) Principal Executive Officer; (2) Principal Operating
Officer; (3) Principal Financial Officer; (4) Comptroller; (5) Principal Accounting Officer; II.14.b
(6) Corporate Secretary.
c. NOTARY PUBLIC II.14.c

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