Amendments to Regulations on Financial Audit of Non-Bank Financial lnstitutions

BANGKo SeNrnaL No PILIPINAS OFFICE OF THE GOVERNOR CIRCULAR NO. 1075 Series of 2020 Subject: Amendments to Regulations on Financial Audit of Non-Bank Financial lnstitutions The Monetary Board (MB), in its Resolution No. 48 dated 8 January 2020 approved the amendments to the relevant provisions of the Manual of Regulations for Non-Bank Financial Institutions (MORN BFI) as follows: Section 1. Section 4190Q and Subsections 4190Q.1, 4190Q.2,4L90Q.4 and 4425e.3 are hereby amended to read as follows: Section 4190Q Audited Financial Statements. The Bangko Sentral recognizes that external auditors play a vital role in contributing to the conduct of effective supervision and sustaining the confidence of the public in the financial system. In this light, the regulations on financial audit aim to enhance the quality of information channeled to the supervisory process and ultimately promote fairness, transparency and accuracy in financial reporting. The following rules shall govern the submission of audited financial statements (AFS) of QBs. For purposes of this Section, AFS shall include the balance sheets, income statements (lS), statements of changes in equity, statements of cash flows, notes to financial statements, and the opinion of the external auditor. The AFS of QBs with subsidiaries shall be presented side by side on a solo basis (parent) and on a consolidated basis (parent and subsidiaries). Subsection 4190Q.1 Financiol Audit. QBs shall cause an annual financial audit by an external auditor included in the List of Selected External Auditors for BSFIs not later than thirty (30) calendar days after the close of the calendar year or the fiscal year adopted by the QB. The AFS shall be submitted by the QB, to the appropriate supervising department of the Bangko Sentral, not later than 120 calendar days after the close of the calendar year or the fiscal year adopted by the QB, accompanied by the documentary requirements as enumerated under Appendix Q-33. In addition, the external auditor shall be required by the QB to submit to the board of directors a Letter of Comments (LOC) indicating any material weakness or breach in the institution's internal control and risk management systems not later than L20 calendar days after the close of the calendar year or fiscal year adopted by the QB. lf no material weakness or breach is noted to warrant the issuance of an LOC, a certification under oath stating that no material weakness or breach in the internal control and risk management systems was noted in the course of the audit of the QB shall be submitted in its stead, together with the AFS. Moterialweokness shall be defined as a significant control deficiency, or combination of deficiencies, that results in more than a remote likelihood that a material A. Mabini St., Malate 1004 Manila, Philippines . (63i) 708 7701" . www.bsp.gcv ph . bspnraii@:rg5p.gey.pi1

misstatement of the financial statements will not be detected or prevented by the institution's internal control. A material weakness does not mean that a material misstatement has occurred or will occur, but that it could occur. A control deficiency exists when the design or operation of a control does not allow management or employees, in the normal course of performing their assigned functions, to prevent or detect misstatements on a timely basis. A significant deficiency is a control deficiency, or combination of control deficiencies, that adversely affects the institution's ability to initiate, authorize, record, process, or report financial data reliably in accordance with generally accepted accounting principles. The phrase "more than remote likelihood" shall mean that future events are likely to occur or are reasonably possible to occur. The board of directors, in a regular or special meeting, shall consider and act on the AFS and the LOC and shall submit not later than 120 calendar days after the close of the calendar year or fiscal year adopted by the QB, a copy of its resolution (containing the date of receipt of the AFS and LOC by the board of directors) to the appropriate supervising department of the Bangko Sentral. The resolution shall show the action(s) taken on the AFS and the findings and recommendations stated in the LOC, if any. Government-owned or -controlled QBs including their subsidiaries and affiliates under Bangko Sentral supervision which are under the concurrent jurisdiction of the Commission on Audit (COA) shall be exempt from the aforementioned annual financial audit by an external auditor included in the List of Selected ExternalAuditors for BSFIs: Provided, That, when warranted by supervisory concern such as material weakness/breach in internal control and/or risk management systems, the Monetary Board may, upon recommendation of the appropriate supervising department of the Bangko Sentral, require the financial audit to be conducted by an external auditor included in the List of Selected External Auditors for BSFls, at the expense of the QB concerned: Provided, further, That when circumstances such as, but not limited to loans from multilateral Fls, privatization, or public listing warrant, the financial audit of the institution concerned by an external auditor included in the List of Selected ExternalAuditors for BSFIs may also be allowed. QBs under the concurrent jurisdiction of the Bangko Sentral and COA shall, however, submit a copy of the annual audit report (AAR) of the COA to the appropriate supervising department of the Bangko Sentral within forty (40) calendar days after receipt of the AAR by the board of directors. The AAR shall be accompanied by the: (a) certification by the institution concerned on the date of receipt of the AAR by the board of directors; (b) reconciliation statement between the AFS in the AAR and the balance sheet and income statement of QB and trust department submitted to the Bangko Sentral, including copies of adjusting entries on the reconciling items; and (c) other information that may be required by the Bangko Sentral. The board of directors of said institutions, in a regular or special meeting, shall consider and act on the AAR, as well as on the comments and observations and shall submit, within thirty (30) banking days after receipt of the report, a copy of its resolution to the appropriate supervising department of the Bangko Sentral. The resolution shall show the action(s) taken on the report, including on the comments and observations and the names of the directors present and absent, among other things.

The AFS required to be submitted shall in all respect be Philippine Financial Reporting Standards (PFRS)/PAS-compliant. The guidelines under Subsection 4191Q.3 shall be adopted. QBs as well as external auditors shall strictly observe the requirements in the submission of the AFS and reports required to be submitted under Appendix Q-33. The reports and certifications of institutions concerned, schedules and attachments required under this Subsection shall be considered as Category I reports, delayed submission of which shall be subject to the penalties under ltem "b.ii" of Subsection 4r92Q.2. Subsection 4190Q.2 Posting of audited financiol statements. QBs shall post in conspicuous places in their head offices, all their branches and other offices, as well as in their respective websites, their latest AFS. Subsection 4190q.4 Disclosure requirements to the audited linoncial stotements. QBs shall disclose the information prescribed under Annex Q-33-c of Appendix Q-33 in the AFS. Subsection 4425Q.3 Audited linancial stotements. The trust/investment management department of an institution shall adopt the provisions of the Philippine Financial Reporting Standards (PFRs)/Philippine Accounting Standards (PAS) in all respect, for purposes of preparing the AFS of its trust and other fiduciary and investment management activities. The guidelines under Subsection 4191Q.3 shall be adopted. Section 2. The provisions of Subsection 4L72S.I are transferred to Section 41725 and hereby amended to read as follows: Section 4t725 Audited Finoncial Statements. The Bangko Sentral recognizes that external auditors play a vital role in contributing to the conduct of effective supervision and sustaining the confidence of the public in the financial system. In this light, the regulations on financial audit aim to enhance the quality of information channeled to the supervisory process and ultimately promote fairness, transparency and accuracy in financial reporting. The following rules shall govern the submission of audited financial statements (AFS) of NSSLAs. For purposes of this Section, AFS shall include the balance sheets, income statements, statements of changes in equity, statements of cash flows, notes to financial statements, and the opinion of the external auditor. Section 3. The provisions of Section 4t725 are transferred to Subsection 41725.1 and hereby amended, as follows: Subsection 4L72S.t Finonciol Audlt NSSLAs shallcause an annualfinancialaudit byan external auditor included in the List of Selected External Auditors for BSFIs not later than

thirty (30) calendar days after the close of the calendar year or the fiscal year adopted by the NSSLA. The AFS shall be submitted by the NSSLA, to the appropriate supervising department of the Bangko Sentral, not later than 120 calendar days after the close of the calendar year or the fiscal year adopted by the NSSLA, accompanied by the documentary requirements as enumerated under Appendix 5-75. In addition, the external auditor shall be required by the NSSLA to submit to the board of trustees a Letter of Comments (LOC) indicating any material weakness or breach in the institution's internal control and risk management systems not later than 120 calendar days after the close of the calendar year or fiscal year adopted by the NSSLA. lf no material weakness or breach is noted to warrant the issuance of an LOC, a certification under oath stating that no material weakness or breach in the internal control and risk management systems was noted in the course of the audit of the NSSLA shall be submitted in its stead, together with the AFS. Materialweakness shall be defined as a significant control deficiency, or combination of deficiencies, that results in more than a remote likelihood that a material misstatement of the financial statements will not be detected or prevented by the institution's internal control. A material weakness does not mean that a material misstatement has occurred or will occur, but that it could occur. A control deficiency exists when the design or operation of a control does not allow management or employees, in the normal course of performing their assigned functions, to prevent or detect misstatements on a timely basis. A significant deficiency is a control deficiency, or combination of control deficiencies, that adversely affects the institution's ability to initiate, authorize, record, process, or report financial data reliably in accordance with generally accepted accounting principles. The phrase "more than remote likelihood" shall mean that future events are likely to occur or are reasonably possible to occur. The board of trustees, in a regular or special meeting, shall consider and act on the AFS and the LOC and shall submit not later than 120 calendar days after the close of the calendar year or fiscal year adopted by the NSSLA, a copy of its resolution (containing the date of receipt of the AFS and LOC by the board trustees) to the appropriate supervising department of the Bangko Sentral. The resolution shall show the action(s) taken on the AFS and the findings and recommendations stated in the LOC, if any. The AFS required to be submitted shall in all respect be Philippine Financial Reporting Standards (PFRS)/PAS-compliant. The guidelines under Section 41615 and its subsections shall be adopted. NSSLAs as well as external auditors shall strictly observe the requirements in the submission of the AFS and reports required to be submitted under Appendix S-15. The reports and certifications of institutions concerned, schedules and attachments required under this Subsection shall be considered as Category I reports, delayed submission of which shall be subject to the penalties under ltem "b.2" of Subsection 41525.3.

Section 4. Subsection 4L725.2 is herebv amended to read as follows: Subsection 4t725.2 Posting of oudited finonciol stotements. NSSLAs shall post in conspicuous places in their head offices, all their branches and other offices, as well as in their respective websites, their latest AFS. Section 5. Subsection 4L725.4 is hereby added to read as follows: Subsection 4L725.4 Disclosure requirements to the audited finonciol stotements. NSSLAs shalf disclose the information prescribed under Annex S-15-b of Appendix S- 15 in the AFS. Section 6. Section 41.90P is hereby amended to read as follows: Section 4190P Audited Financial Statements. The Bangko Sentral recognizes that external auditors play a vital role in contributing to the conduct of effective supervision and sustaining the confidence of the public in the financial system. In this light, the regulations on financial audit aim to enhance the quality of information channeled to the supervisory process and ultimately promote fairness, transparency and accuracy in financial reporting. The following rules shall govern the submission of audited financial statements (AFS) of pawnshop operators. For purposes of this Section, AFS shall include the balance sheets, income statements, statements of changes in equity, statements of cash flows, notes to financial statements, and the opinion of the external auditor. The AFS of pawnshop operators with subsidiaries shall be presented side by side on a solo basis (parent) and on a consolidated basis (parent and subsidiaries). Section 7. Subsections 4190P.L,4t90P.2 and 4190P.4 are hereby added to read as follows: Subsection 4190P.1 Financial Audit. Pawnshop operators shall cause an annual financial audit by an external auditor, who will render an opinion on the fairness of the pawnshop operator's financial statements. Financial audit of the following pawnshop operators shall be rendered by an external auditor included in the List of Selected External Auditors for BSFIs not later than thirty (30) calendar days after the close of the calendar year: a. Pawnshop business with corollary remittance activity requiring Bangko Sentral Registration, with or without money changing/foreign exchange dealing (Type C License); and b. Virtual pawnshop operators or those engaged in pawnshop buslness through electronic pawning (e-pawning) which refer to systems and processes that enable customers to pawn their personal property through electronic channels (Type D License).

The aforementioned pawnshop operators shall submit their AFS, accompanied by the documentary requirements as enumerated under Appendix P-1.8,to the appropriate supervising department of the Bangko Sentral, not later than 120 calendar days after the close of the calendar year. The external auditor shall be required by the proprietor/partners/board of directors to submit a Letter of Comments (LOC) indicating any material weakness or breach in the institution's internal control and risk management systems not later than 120 calendar days after the close of the calendar year. lf no material weakness or breach is noted to warrant the issuance of an LOC, a certification under oath stating that no materialweakness or breach in the internal control and risk management system was noted in the course of the audit of the pawnshop shall be submitted in its stead, together with the AFS. Materiolweakness shall be defined as a significant control deficiency, or combination of deficiencies, that results in more than a remote likelihood that a material misstatement of the financial statements will not be detected or prevented by the institution's internal control. A material weakness does not mean that a material misstatement has occurred or will occur, but that it could occur. A control deficiency exists when the design or operation of a control does not allow management or employees, in the normal course of performing their assigned functions, to prevent or detect misstatements on a timely basis. A significant deficiency is a control deficiency, or combination of control deficiencies, that adversely affects the institution's ability to initiate, authorize, record, process, or report financial data reliably in accordance with generally accepted accounting principles. The phrase "more than remote likelihood" shall mean that future events are likely to occur or are reasonably possible to occur. The proprietor/partners/board of directors, in a regular or special meeting, shall consider and act on the AFS and the LOC and shall submit, not later than 120 calendar days after the close of the calendar year, a copy of its resolutionl (containing the date of receipt of the AFS and LOC by the proprietor/partners/board of directors) to the appropriate supervising department of the Bangko Sentral. The resolution shall show the action(s) taken on the AFS and the findings and recommendations stated in the LOC, if any. The AFS required to be submitted shall in all respect be Philippine Financial Reporting Standards (PFRS)/ Philippine Accounting Standards (PAS)compliant. The guidelines under Subsection 4I9LPJ shall be adopted. Pawnshop operators as well as external auditors shall strictly observe the requirements in the submission of the AFS and reports required to be submitted under Appendix P-78. Pawnshop operators other than those listed in ltems "a" and "b" above, however, are not required from submitting to the Bangko Sentral their AFS and the documentary requirements enumerated under Appendix P-78, and their annualfinancial audit may I Proprietor may instead issue a certification or report on action taken.

be conducted by external auditor other than those included in the List of Selected External Auditors for BSFIs; provided that the AFS and the aforementioned documentary requirements shall be made readily available to the Bangko Sentral during examination, or whenever requested. Subsection 4t9OP.2 Posting of oudited finoncial statements. Pawnshop operators shall post in conspicuous places in their head offices, all their branches and other offices, as well as in their respective websites, their latest AFS. Subsection 4L9OP.4 Disclosure requirements to the audited finonciol stotements. Pawnshop operators shall disclose the information prescribed under Annex P-18-b of Appendix P-78in the AFS. Section 8. The provisions of Subsection 4172N.1are transferred to 4L72N and hereby amended to read as follows: Section 4172N Audited Financial Statements. The Bangko Sentral recognizes that external auditors play a vital role in contributing to the conduct of effective supervision and sustaining the confidence of the public in the financial system. In this light, the regulations on financial audit aim to enhance the quality of information channeled to the supervisory process and ultimately promote fairness, transparency and accuracy in financial reporting. The following rules shall govern the submission of audited financial statements (AFS) of NBFls. For purposes of this Section, AFS shall include the balance sheets, income statements, statements of changes in equity, statements of cash flows, notes to financial statements, and the opinion of the external auditor. Section 9. The provisions of Subsection 4172N are transferred to 4L72N.L and hereby amended to read as follows: "Subsection 4172N.1 Finoncial Audit NBFIs shall cause an annual financial audit by an external auditor included in the List of Selected External Auditors for BSFIs not later than thirty (30) calendar days after the close of the calendar year or the fiscal year adopted by the NBFI. The AFS shall be submitted by the NBFI, to the appropriate supervising department of the Bangko Sentral, not later than 120 calendar days after the close of the calendar year or the fiscal year adopted by the NBFI, accompanied by the documentary requirements as enumerated under Appendix N-19. In addition, the external auditor shall be required by the NBFI to submit to the proprietor/partners/board of directors a Letter of Comments (LOC) indicating any materialweakness or breach in the institution's internal control and risk management systems not later than 120 calendar days after the close of the calendar year or fiscal year adopted by the NBFI. lf no material weakness or breach is noted to warrant the issuance of an LOC, a certification under oath stating that no material weakness or breach in the internal control and risk management systems was noted in the course of the audit of the NBFI shall be submitted in its stead, together with the AFS.

Moteriolweokness shall be defined as a significant control deficiency, or combination of deficiencies, that results in more than a remote llkelihood that a material misstatement of the financial statements will not be detected or prevented by the institution's internal control. A material weakness does not mean that a material misstatement has occurred or will occur, but that it could occur. A control deficiency exists when the design or operation of a control does not allow management or employees, in the normal course of performing their assigned functions, to prevent or detect misstatements on a timely basis. A significant deficiency is a control deficiency, or combination of control deficiencies, that adversely affects the institution's ability to initiate, authorize, record, process, or report financial data reliably in accordance with generally accepted accounting principles. The phrase "more than remote likelihood" shall mean that future events are likely to occur or are reasonably possible to occur. The proprietor/partners/board of directors, in a regular or special meeting, shall consider and act on the AFS and the LOC and shall submit, not later than 120 calendar days after the close of the calendar year or fiscal year adopted by the NBFI, a copy of its resolution (containing the date of receipt of the AFS and LOC by the proprietor/partners/board of directors) to the appropriate supervising department of the Bangko Sentral. The resolution shall show the action(s) taken on the AFS and the findings and recommendations stated in the LOC, if any. Government-owned or -controlled NBFIs including their subsidiaries and affiliates under Bangko Sentral supervision, which are under the concurrenct jurisdiction of the Commision on Audit (COA) shall be exempt from the aforementioned annualfinancial audit by an externalauditor included in the List of Selected ExternalAuditors for BSFIs: Provided, That, when warranted by supervisory concern such as material weakness/breach in internal control and/or risk management systems, the Monetary Board may, upon recommendation of the appropriate supervising department of the Bangko Sentral, require the financial audit to be conducted by an external auditor included in the List of Selected External Auditors for BSFls, at the expense of the NBFI: Provided, further, That when circumstances such as, but not limited to loans from multilateral Fls, privatization, or public listing warrant, the financial audit of the institution concerned by an external auditor included in the List of Selected External Auditors for BSFIs may also be allowed. NBFIs under the concurrent jurisdiction of the Bangko Sentral and COA shall, however, submit a copy of the annual audit report (AAR) of the COA to the appropriate supervising department of the Bangko Sentral within forty (40) calendar days after receipt of the AAR by the board of directors. The AAR shall be accompanied by the: (a) certification by the institution concerned on the date of receipt of the AAR by the board of directors; (b) reconciliation statement between the AFS in the AAR and the balance sheet and income statement of QB and trust department submitted to the Bangko Sentral, including copies of adjusting entries on the reconciling items; and (c) other information that may be required by the Bangko Sentral. The board of directors of said institutions, in a regular or special meeting, shall consider and act on the AAR, as well as on the comments and observations and shall submit, within thirty (30) banking days after receipt of the report, a copy of its resolution to the appropriate supervising department of the Bangko Sentral. The resolution shall show the action(s)

taken on the report, including on the comments and observations and the names of the directors present and absent, among other things. The AFS required to be submitted shall in all respect be Philippine Financial Reporting Standards (PFRS)/PAS-compliant. The guidelines under Section 4161N shall be adopted. NBFIs as well as external auditors shall strictly observe the requirements in the submission of the AFS and reports required to be submitted under Appendix N-1.9. The reports and certifications of institutions concerned, schedules and attachments required under this Subsection shall be considered as Category I reports, delayed submission of which shall be subject to the penalties under ltem "b.ii" of Subsection 4162N.3." Section 10. Subsection 4172N.2 is hereby amended to read, as follows: Subsection 4L72N.2 Posting of audited financial stotements. NBFIs shall post in conspicuous places in their head offices, all their branches and other offices, as well as in their respective websites, their latest AFS. Section 11. Subsection 451.lN.6 is hereby amended to read, as follows: Subsection 4511N.6 Reports. a. "xxx (2)Audited financial statements (AFS), accompanied by the documentary requirements as enumerated under Appendix N-19, which shall be submitted not later than t20 calendar days after the close of the reference calendar/fiscal year adopted by the RTC/MC/FXD. However, RTCs/MCs/FXDs classified as type "F" (small-scale operator-money changer/ foreign exchange dealer with average monthly network volume of transactions of less than P50 million and with less than P10 million capital) are not required to submit AFS to the Bangko Sentral and its annual financial audit may be conducted by external auditor other than those included in the List of Selected External Auditors for BSFIs: Provided that, the AFS shall be made readily available to the Bangko Sentral during examination, or whenever requested. Financial audit of RTCs/MCs/FXDs, except those with type "F" license, shall be rendered by an external auditor included in the List of Selected External Auditors for BSFls. RTCs/MCs/FXDs as well as external auditors shall strictly observe the requirements in the submission of the AFS and reports under Sections 4I72N and 4180N and its subsections, and Appendix N-L9. In addition, RTCs/MCs/FXDs shall include supplementary information at the end of the notes to the financial statements as prescribed under Annex N-19- c of Appendix N-19. xxx"

Section 12. Subsection 4512N.8 is hereby amended to read as follows: Subsection 4512N.8 Notification and reporting requirements. "xxx ln addition, a VC exchange shall maintain records and submit the following to the appropriate supervising department of the Bangko Sentral: Nature of Report Frequency Due Date 1. AFS (audited by an external auditor Annually Not later than 120 calendar days after the included in the List of Selected close of the reference calendar or fiscal year External Auditors for BSFIs) subject to the provisions under Subsection 4511N.6 xxx XXX,, Section 13. Section 4190T, and Subsections 4190T.1 and 41.90T.4 are hereby amended to read as follows: Section 4190T Audited Financial Statements. The Bangko Sentral recognizes that external auditors play a vital role in contributing to the conduct of effective supervision and sustaining the confidence of the public in the financial system. In this light, the regulations on financial audit aim to enhance the quality of information channeled to the supervisory process and ultimately promote fairness, transparency and accuracy in financial reporting. The following rules shall govern the submission of audited financial statements (AFS) of trust corporations (TCs). For purposes of this Section, AFS shall include the balance sheets, income statement, statement of changes in accountabilities, notes to financial statements, and the opinion of the external auditor. Subsection 4190T.1 Financiol Audit, TCs shall cause an annual financial audit by an external auditor included in the List of Selected External Auditors for BSFIs not later than thirty (30) calendar days after the close of the calendar year or the fiscal year adopted by the TC. The financial audit shall cover the financial statements of both the TC proper and the trust and managed funds ofthe TC. The AFS shall be submitted by the TC, to the appropriate supervising department of the Bangko Sentral, not later than 120 calendar days after the close of the calendar year or the fiscal year adopted by the TC, accompanied by the documentary requirements as enumerated under Appendix T-5. In addition, the external auditor shall be required by the TC to submit to the board of directors a Letter of Comments (LOC) indicating any material weakness or breach in the institution's internal control and risk management systems not later than 120 calendar days after the close of the calendar year or fiscal year adopted by the TC. lf

no material weakness or breach is noted to warrant the issuance of an LOC, a certification under oath stating that no material weakness or breach in the internal control and risk management systems was noted in the course of the audit of the TC shall be submitted in its stead, together with the AFS. Material weakness shall be defined as a significant control deficiency, or combination of deficiencies, that results in more than a remote likelihood that a material misstatement of the financial statements will not be detected or prevented by the institution's internal control. A material weakness does not mean that a material misstatement has occurred or will occur, but that it could occur. A control deficiency exists when the design or operation of a control does not allow management or employees, in the normal course of performing their assigned functions, to prevent or detect misstatements on a timely basis. A significant deficiency is a control deficiency, or combination of control deficiencies, that adversely affects the institution's ability to initiate, authorize, record, process, or report financial data reliably in accordance with generally accepted accounting principles. The phrase "more than remote likelihood" shall mean that future events are likely to occur or are reasonably possible to occur. The board of directors, in a regular or special meeting, shall consider and act on the AFS and the LOC and shall submit not later than 120 calendar days after the close of the calendar year or fiscal year adopted by the TC, a copy of its resolution (containing the date of receipt of the AFS and LOC by the board of directors) to the appropriate supervising department of the Bangko Sentral. The resolution shall show the action(s) taken on the AFS and the findings and recommendations stated in the LOC, if any. Government-owned or -controlled TCs including their subsidiaries and affiliates under Bangko Sentral supervision which are under the concurrent jurisdiction of the Commission on Audit (COA) shall be exempt from the aforementioned annualfinancial audit by an external auditor included in the List of Selected External Auditors for BSFIs: Provided, That, when warranted by supervisory concern such as material weakness/breach in internal control and/or risk management systems, the Monetary Board may, upon recommendation of the appropriate supervising department of the Bangko Sentral, require the financial audit to be conducted by an external auditor included in the List of Selected External Auditors for BSFls, at the expense of the TC concerned: Provided, further, That when circumstances such as, but not limited to loans from multilateral Fls, privatization, or public listing warrant, the financial audit of the institution concerned by an external auditor included in the List of Selected External Auditors for BSFIs may also be allowed. TCs under the concurrent jurisdiction of the Bangko Sentral and COA shall, however, submit a copy of the annual audit report (AAR) of the COA to the appropriate supervising department of the Bangko Sentral within forty (a0) calendar days after receipt of the AAR by the board of directors. The AAR shall be accompanied by the: (a) certification by the institution concerned on the date of receipt of the AAR by the board of directors; (b) reconciliation statement between the AFS in the AAR and the balance sheet and income statement of TC and trust department submitted to the Bangko Sentral, including copies of adjusting entries on the reconciling items; and (c) other information that may be required by the Bangko Sentral. The board of directors

of said institutions, in a regular or special meeting, shall consider and act on the AAR, as well as on the comments and observations and shall submit, within thirty (30) banking days after receipt of the report, a copy of its resolution to the appropriate supervising department of the Bangko Sentral. The resolution shall show the action(s) taken on the report, including on the comments and observations and the names of the directors present and absent, among other things. The AFS required to be submitted shall in all respect be Philippine Financial Reporting Standards (PFRS)/PAS-compliant. TCs as well as external auditors shall strictly observe the requirements in the submission of the AFS and reports required to be submitted under AppendixT-5. The reports and certifications of institutions concerned, schedules and attachments required under this Subsec. shall be considered as Category B reports, delayed submission of which shall be subject to the penalties under ltem "b.ii" of Subsection 4L92Q.2. 4190T.4 Disclosure requirements in the notes to the audited finonciol stotements. TCs shall disclose the information prescribed under Annex T-5-c of Appendix I-5 in the AFS. Section 14. Subsection 4190T.2 is hereby added to read as follows: Subsection 4L9OT.2 Posting of audited finonciol stotements. TCs shall post in conspicuous places in their head offices, all their branches and other offices, as well as in their respective websites, their latest AFS. Section L5. Appendix Q-33 on the checklist of Bangko Sentral requirements for the submission of AFS and AAR is hereby amended and a new Appendix S-15/P-18/N-19/T-5 on the same checklist is hereby added, details of which are presented in Annex A of this Circular. In addition, disclosure requirements to the AFS and the templates for reconciliation statement are hereby added as Annexes A, B ond C of Appendix Q-33/S-1-5/ P-18/N-19/T-5, and are presented as Annexes B and C, respectively, of this Circular. Section 15. The titles and submission deadlines of the required reports under the following Appendices are hereby amended to read as follows: Form No. MOR Submission Deadline Submission Procedure Appendir Category Ref. Report Title Frequency 1-3 xxx xxx xxx xxx xxx xxx XXX Q-3 B Unnumbered 4190q Consolidated Annual Financial Annually Not later than l2O Appropriate Statements of Financial Intermediaries calendar days after the supervising and their Allied close of the reference department of Undertakings/Affiliates/ Subsidiaries calendar or fiscal year. the Bangko supported by Individual Annual Sentral Undertakings/ Affiliates/ Subsidiaries and their Audited Financial Statements

R Unnumbered 4190Q Audited Financial Statementetogether Annually Not later than I2O -oo- with attachments listed in Appendix Q- calendar days after the no prescribec 33 close of the reference form) calendar or fiscal year. xxx xxx xxx Xxx xxx xxx xxx 2 xxx xxx xxx Xxx xxx xxx xxx s-2 B 4t725 Audited/Unaudited Financial Annually Not later than 72O Appropriate Statements required in Sec. 4l.8l,S calendar days after the supervising together with attachments listed.in close of the reference department of calendar or fiscal year Appendix S-15 the Bangko Sentral xxx xxx XXX Xxx xxx xxx xxx r-l.5 xxx xxx xxx Xxx xxx xxx xxx P-13 B Unnumbered 4190P Audited Financial Statements (AFS) Annually Not later than t2O Appropriate together with attachments listed in calendar days after the supervising no prescribec Appendix P-18 close of the calendar year. department form) of the Bangko Sentral xxx xxx xxx Xxx xxx xxx xxx N-1 xxx xxx xxx )(xx xxx xxx xxx A-2 4511N Audited Financial Statements Annually Not later 'than 120 -oo- calendar days after the close of the calendar or fiscal vear Unnumbered 4512N.8 Audited financial statements of Vcs Annually Not later than t2O Appropriate (audited by an external auditor calendar days after the supervising included in the List of Selected External close of the calendar or department of Auditors for BSFIs) together with fiscal year the Bangko attachments listed in Appendix N-19 Sentral B 4172N Audited Financial Statements Annually Not later than 120 -do- calendar days after the close of the calendar or fisc'al year xxx xxx xxx Xxx xxx xxx xxx Sestion 17. This Circular shall take effect fifteen (1"5) calendar days following its publication either in the Official Gazette or in a newspaper of general circulation. FOR THE MONETARY BOARD: C GI BENJAMIN E. DIOKNO Governor 07 --------i- Februarv 2o2o

ANNEX A APPENDIX Q-33 CHECKTIST OF BANGKO SENTRAT REQUIREMENTS IN THE SUBMISSION OF AUDITED FINANCIAT STATEMENTS AND ANNUAT AUDIT REPORT (Appendix to Subsection 4190Q.1) Information/Data Required Deadline for submission A. Audited Financial Statements (AFS) 1. AFS Not later than 120 calendar days after the close of the calendar year or fiscal year adopted by the QB. Z. Certification by the external auditor on compliance with For submission together with the AFS, not later Bangko Sentral requirements on: than 120 calendar days after the close of the calendar year or fiscal year adopted by the QB. a. Confidentiality clause pertinent to read-only access to the Report of Examination; and b. Disclosure under Subsection 4190Q.4 and other information that may be required. 3. Reconciliation statement, including copies of adjusting For submission together with the AFS, not later entries on the reconciling items, between the AFS and than 120 calendar days after the close of the the prudential reports submitted to the Bangko Sentral calendar year or fiscal year adopted by the QB. (i.e. balance sheet and income statement for QB following the formats in Annexes Q-33-a and Q-33-b. 4. Letter of comments (Loc)l indicating material For submission together with the AFS, not later weaknesses on internal control and risk management than 120 calendar days after the close of the system as well as other issues, which may include findings calendar year or fiscal year adopted by the QB. on the quality of governance2, that should be brought to the attention of the board/management along with the recommendations for corrective action. Otherwise, a certification by the external auditor that there are no issues noted in the course of the audit to warrant the submission of an LOC. 5. Copy of the board resolution showing the actions on the For submission together with the AFS not later AFS and the submitted LOC, if any. than 120 calendar days after the close of the calendar year or fiscal year adopt by the QB. 6. The external auditor shall report directly to the Bangko Within fifteen (15) calendar days from discovery. Sentral the following: a. Any material finding involving fraud or error; b. Actual or potential losses the aggregate of which amounts to at least ten percent (10%) of the consolidated total assets of the QB; c. Significant doubt as to the ability of the QB to continue as a going concern; 1 LOC or equivalent letter to management/board of directors 2 Reportable issues on the quality of governance shall onlypertaintofinancialreportingmatter.

ANNEX A d. Material breach of laws or Bangko Sentral rules and regulations such as but not limited to prescribed capital and liquidity ratios, significant deficiency in allowance for credit losses, material weaknesses in fair value measurement methodology, significant vulnerabilities to money laundering and countering the financing of terrorism; e. Material internal control weaknesses which may lead to financial reporting problems; and t. Findings on matters of corporate governance that may require urgent action by the Bangko Sentral. In case there are no matters to report (e.g., fraud, Not later than 120 calendar days after the close dishonesty, breach of laws, etc.) a notarized certification of the calendar year or fiscal year adopted by that there is none to report. the QB. B. Annual Audit Report (AAR) - For QBs under the concurrent jurisdiction of the Bangko Sentral and COA 1. MR accompanied bY: Within forty (40) calendar days after receipt of a. Certification by the institution concerned on the date the MR by the board of directors. of receipt of the MR by the board of directors; b. Reconciliation statement between the AFS in the AAR and the Balance Sheet and Income Statement of QB and trust department submitted to the Bangko Sentral, including copies of adjusting entries on the reconciling items; and c. Other information that may be required by the Bangko Sentral. 2. Copy of the board resolution showing the action taken Within 30 banking days after receipt of the AAR on the MR, as well as on the comments and by the board of directors. observations, including the names of the directors present and absent, among other things.

ANNEX A APPENDIX S.15 CHECKTIST OF BANGKO SENTRAT REQUIREMENTS IN THE SUBMISSION OF AUDITED FINANCIAL STATEMENTS (APPendix to Subsection 47725.7) Information/Data Required Deadline for submission 1. Audited Financial Statements (AFS) Not later than 120 calendar days after the close of the calendar year or fiscal year adopted by the NssLA. 2. Certification by the external auditor on compliance with For submission together with the AFS, not later Bangko Sentral requirements on: than 120 calendar days after the close of the calendar year or fiscal year adopted by the a. Confidentiality clause pertinent to read-only access NSSLA. to the Report of Examination; and b. Disclosure under Subsection 41725.4 and other information that may be required. 3. Reconciliation statement, including copies of adjusting For submission together with the AFS, not later entries on the reconciling items, between the AFS and than 120 calendar days after the close of the the prudential reports submitted to the Bangko Sentral calendar year or fiscal year adopted by the (i.e. balance sheet and income statement for NSSLA) NSSLA. following the formats in Annex S-15-a. 4. Letter of Comments (LOC)3 indicating material For submission together with the AFS, not later weaknesses on internal control and risk management than 120 calendar days after the close of the system as well as other issues, which may include findings calendar year or fiscal year adopted by the on the quality of governance4, that should be brought to NssLA. the attention of the board/management along with the recommendations for corrective action. Otherwise, a certification by the external auditor that there are no issues noted in the course of the audit to warrant the submission of an LOC. 5. Copy of the board resolutions showing the actions on the For submission together with the AFS, not later AFS and the submitted LOC, if any. than 120 calendar days after the close of the calendar year or fiscal year adopted by the NSSLA. 6. The external auditor shall report directly to the Bangko Within fifteen (15) calendar days from discovery. Sentralthe following: a. Any material finding involving fraud or error; b. Actual or potential losses the aggregate of which amounts to at least ten percent (10%) of the consolidated total assets ofthe NSSLA; c. Significant doubt as to the ability of the NSSLA to continue as a going concern; d. Material breach of laws or Bangko Sentral rules and regulations such as but not limited to prescribed capital and liquidity ratios, significant deficiency in allowance for credit losses, material weaknesses in fair value measurement methodology, significant 3 LOC or equivalent letter to management/board of trustees a Reportable issues on the quality of governance shall only pertain to financial reporting matter.

ANNEX A vulnerabilities to money laundering and countering the financing of terrorism; e. Material internal control weaknesses which may lead to financial reporting problems; and f. Findings on matters of corporate governance that may require urgent action by the Bangko Sentral. In case there are no matters to report (e.g., fraud, Not later than 120 calendar days after the close dishonesty, breach of laws, etc.) a notarized certification of the calendar year or fiscal year adopted by that there is none to report. the NSSLA'

ANNEX A APPENDIX P-18 CHECKUST OF BANGKO SENTRAL REQUTREMENTS rN THE SUBMISSION OF AUDITED FINANCIAL STATEMENTS (Appendix to Subsection 4790P.7) Information/Data Required Deadline for submission 1. AUDITED FINANCIAL STATEMENTS (AFs) Not later than 120 calendar days after the close of the calendar year. Certification by the external auditor on compliance with For submission together with the AFS, not later Bangko Sentral requirements on than 120 calendar days after the close of the calendar year. a. Confidentiality clause pertinent to read-only access to the Report of Examinatiory and b. Disclosure under Subsection 4190P.4 and other information that may be required. 3. Reconciliation statement, including copies of adjusting For submission together with the AFS, not later entries on the reconciling items, between the AFS and than 120 calendar days after the close of the the prudential reports submitted to the Bangko Sentral calendar year. (i.e. balance sheet and income statement for pawnshops) following the format in Annex P-18-a. Letter of Comments (LOC)5 indicating material For submission together with the AFS, not later weaknesses on internal control and risk management than 120 calendar days after the close of the system as well as other issues, which may include calendar year. findings on the quality of governances, that should be brought to the attention of the proprietor/partners/ board/management along with the recommendations for corrective action. Otherwise, a certification by the external auditor that there are no issues noted in the course of the audit to warrant the submission of an LOC' Copy of the board resolution showing the actions on the For submission together with the AFS, not later AFS and the submitted LOC, if any. The proprietor may than 120 calendar days after the close of the instead issue a certification or report on action taken. calendar year. 6. The external auditor shall report directly to the Bangko Within fifteen (15) calendar days from discovery. Sentral the following: a. Any material finding involving fraud or error; b. Actual or potential losses the aggregate of which amounts to at least ten percent (10%) of the consolidated total assets of the pawnshop; Significant doubt as to the ability of the pawnshop to continue as a going concern; d. Material breach of laws or Bangko Sentral rules and regulations such as but not limited to prescribed capital and liquidity ratios, significant deficiency in allowance for credit losses, material weaknesses in fair value measurement methodology, significant vulnerabilities to money laundering and countering the financing of terrorism; 5 LOC o, equivalent letter to proprietor/partners/management/board of directors 5 Reportable issues on the quality of governance shall only pertain to financial reporting matter.

ANNEX A e. Material internal control weaknesses which may lead to financial reporting problems; and f. Findings on matters of corporate governance that may require urgent action by the Bangko Sentral. In case there are no matters to report (e.g.,- fraud, Not later than 120 calendar days after the close dishonesty, breach of laws, etc.) a notarized certification of the calendar year. that there is none to report.

ANNEX A APPENDIX N-19 STATEMENTS CHECKTIST OF BANGKO SENTRAT REQUIREMENTS IN THE SUBMISSION OF AUDITED FINANCIAT AND ANNUAT AUDIT REPORT (Appendix to Subsections 4772N.7 and 4577N.6) Information/Data Required Deadline for submission A. Audited Financial Statements (AFS) 1. AFS Not later than 120 calendar days after the close of the calendar year or fiscal year adopted by the N BFls/RTCs/MCs/FXDs. Certification by the external auditor on compliance with For submission together with the AFS, not later Bangko Sentral requirements on than 120 calendar days after the close of the calendar year or fiscal year adopted by a. Confidentiality clause pertinent to read-only access NBFIs/RTCs/MCS/FXDs. to the Report of Examination; and b. Disclosure under Subsection 4511N.6 and other information that may be required. This requirement shall only apply to RTC/MC/FXD. Reconciliation statement, including copies of adjusting For submission together with the AFS, not later entries on the reconciling items, between the AFS and than 120 calendar days after the close of the the prudential reports submitted to the Bangko Sentral calendar year or fiscal year adopted by NBFI. (i.e. balance sheet and income statement for NBFI) following the format in Annexes N-19-a and N-19-b. This requirement shall not apply to RTC/MC/FXD. 4. Letter of Comments (LOC)? indicating material For submission together with the AFS, not later weaknesses on internal control and risk management than 120 calendar days after the close of the system as well as other issues, which may include findings calendar year or fiscal year adopted by the on the quality of governance8, that should be brought to NBFIs/RTCS/MCS/FXDS. the attention of the proprietor/partners/ management /board of directors along with the recommendations for corrective action' Otherwise, a certification by the external auditor that there are no issues noted in the course of the audit to warrant the submission of an LOC. Copy of the board resolution showing the actions on the For submission together with the AFS, not later AFS and the submitted LOC, if any. ln the case of a single than 120 calendar days after the close of the proprietorship RTCs/MCs/FXDs, the proprietor may calendar year or fiscal year adopted by the instead issue a certification or report on action taken. NBFIs/RTCs/MCs/FXDs. 5. The external auditor shall report directly to the Bangko Within fifteen (15) calendar days from discovery. Sentral the following: a. Any material finding involving fraud or error; b. Actual or potential losses the aggregate of which amounts to at least ten percent (10%) of the consolidated total assets ofthe NBFI; c. Significant doubt as to the ability of the NBFI to continue as a going concern; 7 LOC or equivalent letterto proprietor/partners/management/board ofdirectors 8 Reportable issues on the quality of governance shall onlypertaintofinancial reportingmatter.

ANNEX A d. Material breach of laws or Bangko Sentral rules and regulations such as but not limited to prescribed capital and liquidity ratios, significant deficiency in allowance for credit losses, material weaknesses in fair value measurement methodology, significant vulnerabilities to money laundering and countering the financing of terrorism; e. Material internal control weaknesses which may lead to financial reporting problems; and f. Findings on matters of corporate governance that may require urgent action by the Bangko Sentral. In case there are no matters to report (e.g., fraud, Not later than 120 calendar days after the close dishonesty, breach of laws, etc.) a notarized certification of the calendar year or fiscal year adopted by that there is none to report. the N BFls/RTCs/MCs/FXDs. B. Annual Audit Report (MR) - For NBFIs under the concurrent jurisdiction of the Bangko Sentral and COA 1. AAR accompanied bY: Within forty (40) calendar days after receipt of a. Certification by the institution concerned on the the AAR by the board of directors. date of receipt of the AAR by the board of directors; b. Reconciliation statement between the AFS in the AAR and the Balance Sheet and Income Statement of NBFI and trust department submitted to the Bangko Sentral, including copies of adjusting entries on the reconciling items. c. Other information that may be required by the Bangko Sentral. 2. Copy of the board resolution showing the action taken Within 30 banking days after receipt of the AAR on the AAR, as well as on the comments and by the board of directors. observations, including the names of the directors present and absent, among other things'

ANNEX A APPENDIX T-5 CHECKUST OF BANGKO SENTRAT REqUTREMENTS rN THE SUBMISSION OF AUDITED FINANCIAL STATEMENTS AND ANNUAI AUDIT REPORT (Appendix to Subsection 4190T.7) Information/Data Required Deadline for submission A. Audited Financial Statements (AFS) t. AFS Not later than 120 calendar days after the close of the calendar year or fiscal year adopted by the TC' 2. Certification by the external auditor on compliance with For submission together with the AFS, not later than Bangko Sentral requirements on: 120 after the close of the calendar year or fiscal year adopted by the TC. a. Confidentiality clause pertinent to read-only access to the Report of Examination; and b. Disclosure under Subsection 4190T'4 and other information that may be required. 3. Reconciliation statement, including copies of adjusting For submission together with the AFS, not later than entries on the reconciling items, following the formats in 120 calendar days after the close of the calendar Annexes T-5-o and T-5-b of this Appendix, which shall be year or fiscal year adopted by the Tc. between the: (a) AFS and FRP; and (b) AFS and the FRP for Trust Institution (FRPTI) for each of the general categories of contractual relationships (i.e., UITF trust, institutional trust, and individual trust; other fiduciary; institutional-agency, and individual -agency; and special purpose trust) of the TC with its clients. 4. Letter of Comments (LOC)9 indicating material weaknesses For submission together with the AFS, not later than on internal control and risk management system as well 120 calendar days after the close of the calendar as other issues, which may include findings on the quality year or fiscal year adopted by the TC. of governancelo, that should be brought to the attention of the board/management along with the recommendations for corrective action. Otherwise, a certification by the external auditor that there are no issues noted in the course of the audit to warrant the submission of an LOC. Copy of the board resolution showing the actions on the For submission together with the AFS, not later than AFS and the submitted LOC, if any. 120 calendar days after the close of the calendar year or fiscal year adopted by the TC. 6. The external auditor shall report directly to the Bangko Within fifteen (t5)calendar days from discovery. Sentral the following: a. Any material finding involving fraud or error; b. Actual or potential losses the aggregate of which amounts to at least ten percent (10%) of the consolidated total assets ofthe Tc; c. Significant doubt as to the ability of the TC to continue as a going concern; d. Material breach of laws or Bangko Sentral rules and regulations such as but not limited to prescribed e LOC or equivalent letter to management/board of directors 10 Reportable issues on the quality of governance shall onlypertaintofinancialreportingmatter'

ANNEX A capital and liquidity ratios, significant deficiency in allowance for credit losses, material weaknesses in fair value measurement methodology, significant vulnerabilities to money laundering and countering the financing of terrorism; e. Material internal control weaknesses which may lead to financial reporting problems; and f. Findings on matters of corporate governance that may require urgent action by the Bangko Sentral. In case there are no matters to report (e.g., fraud, Not later than 120 calendar days after the close of dishonesty, breach of laws, etc.) a notarized certification the calendar year or fiscal year adopted by the TC. that there is none to report. B. Annual Audit Report (AAR) - For TCs under the concurrent jurisdiction of the Bangko Sentral and COA 1. AAR accompanied by: Within forty (a0) calendar days after receipt of the a. Certification by the institution concerned on the MR by the board of directors. date of receipt of the MR by the board of directors; b. Reconciliation statement, including copies of adjusting entries on the reconciling items, for the differences in amounts between the: (a) AFS and FRP; and (b) AFS and FRPTI for each of the general categories of contractual relationships (i.e., UITF trust, institutional trust, and individual trus| other fiduciary; institutional-agency, and individual-agency; and special purpose trust) of the Tc with its clients; and c. Other information that may be required by the Bangko Sentral. 2. Copy of the board resolution showing the action Within 30 banking days after receipt of the AAR by taken on the AAR, as well as on the comments and the board of directors. observations, including the names of the directors present and absent, among other things.

ANNEX B App. Q-33 Annex Q-33-b Name of Financial Institution Trust Department (Contractual Relationship of TE, e.g., lnstitutional-Trust, etc.) Comparison of Submitted FRPTI Balance Sheet and Audited Financial Statements As of (end of calendar or fiscal year) (ln Thousand Pesos) Accounts FRPTI AFS Discrepancy Explanation for Discrepancy Assets (net! Cash on Hand, Checks and Other Cash ltems Due from BSP Deposit in Banks Financial Assets Designated at Fair Value through Profit or Loss (DFVPL) Available-for-Sale (AFS) Financial Assets Held-to-Maturity (HTM) Financial Assets Unquoted Debt Securities Classified as Loans Investments in Non-Marketable Equity Securities Loans and Receivables and Loans Arising from Repurchase Agreements and Securities Lending and Borrowing Transactions Other Financial Assets Investment Properties and Real and Other Properties Acquired Other Assets Due from Head Office/Eranches/Agencies Abroad Total Assets Accountabilities Principal Accumulated Income Net Unrealized Gains/(Losses) on AFS Financial Assets Other Accountabilities Total Accountabilities Page t of 7

ANNEX B App. S-15 Annex S-15-a Name of Financial Institution Comparison of Submitted Consolidated Balance Sheet and lncome Statement and Audited Financial Statements As of (end of calendar or fiscal year) (ln Thousand Pesos) Submifted Audited Variance/ Reasons for Report Report Discrepancy Discrepancy Cash and Other Cash ltems Due from BSP Due from Other Banks Financial Assets Held for Trading (HFT) Held-to-Maturity (HTM ) Financial Assets Available-for-Sale Financial Assets Loans and Receivables, net Equity Investments in Subsidiaries, Associates & Joint Ventures NSSLA Premises, Furniture, Fixtures and Equipment, net Real and other Properties Acquired (ROPA), net Other Assets Due from Head Office/Branches/ Agencies Abroad Total Assets Deposit Liabilities Bills Payable Accrued Interest, Taxes and Other Expenses Other Liabilities Due to Head Office/Branches Total Liabilities Capital Contribution Surplus (Free) Surplus Reserves Undivided Profits Total Capital Total Liabilities and capital Total Income Total Expenses Net lncome before Income Tax

ANNEX B APP. P-18 Annex P-18-a Name of Financial Institution Comparison of Submitted Consolidated Balance Sheet and Income Statement and Audited Financial Statements (Parent and Subsidiaries) As of (end of calendar or fiscal year) (ln Thousand Pesos) Submitted Audited Variance/ Reasons for Report Report Discrepancy Discrepancy Cash on hand and in banks Pledge loans Financial Assets Held for Trading (HFT) Held-to-Maturity (HTM ) Financial Assets Ava i lable-for-Sa le Fina nci al Assets Equity Investments in Subsidiaries, Associates & Joint Ventures Pawnshop Premises, Furniture, Fixtures and EquiPment, net Other Assets Due from Head Office/Branches/ Agencies Abroad Total Assets Loans Payable Accounts Payable Bonds Payable Unsecured Subordinated Debt (UnSD) Redeemable Preferred Shares Accrued Interest, Taxes and Other Expenses Other Liabilities Due to Head Office/Branches/ Agencies Abroad Total Liabilities Paid-in Capital Stock Additional Paid-ln CaPital Retained Earnings Assigned Capital TotalCapital Total Liabilities and capital Total Income Total Expenses Net Income before Income Tax

ANNEX B App. N-19 Annex N-19-a Name of Non-Bank Financial Institution Comparison of Submitted Balance Sheet and Income Statement and Audited Financial Statements As of (end of calendar or fiscal year) (ln Thousand Pesos) Submitted Audited Variance/ Reasons for Report Report Discrepancy Discrepanacy Cash and Other Cash ltems Due from BSP Deposit in Banks Financial Assets Designated at Fair Value through Profit or Loss (DFVPL) Available-for-Sale (AFS) Financial Assets Held-to-Maturity (HTM) Financial Assets Loans and Receivables, net Loans and Receivable Arising from Repurchase Agreements, Certificates of Assignment/Participation with Recourse Transactions Accrued Interest Income from Financial Assets NBFIs Premises, Furniture, Fixtures and Equipment, net Other Assets Due from Head Office/Branches/Agencies Abroad Total Assets Financial Liabilities Designated at Fair Value through Profit or Loss (DFVPL) Bonds Payable Redeemable Preferred Shares Financial Liabilities Associated with Transferred Assets Finance Lease Payment Payable Accrued lnterest, Taxes and Other Expenses Other Liabilities Paid-in Capital Stock Additional Paid-in CaPital Retained Earnings Other Comprehensive Income Total Capital Total Liabilities and CaPital Total Income Total Expenses Net Income Before Income Tax

ANNEX B App. N-19 Annex N-19-b Name of Non-Bank Financial Institution Trust DePartment (Contractual Relationship of TE, e.g., Institutional-Trust, etc') Comparison of Submitted FRPTI Balance Sheet and Audited Financial Statements As of (end of calendar or fiscal year) (ln Thousand Pesos) Accounts FRPTI AFS Discrepancy Explanation for Discrepancy Assets (netl Cash on Hand, Checks and Other Cash ltems Due from BSP Deposit in Banks Financial Assets Designated at Fair Value through Profit or Loss (DFVPL) Available-for-Sa le (AFS) Financial Assets Held-to-Maturity (HTM) Financial Assets Unquoted Debt Securities Classified as Loans Investments in Non-Marketable Equity Securities Loans and Receivables and Loans Arising from Repurchase Agreements and Securities Lending and Borrowing Transactions Other Financial Assets Investment Properties and Real and Other Properties Acquired Other Assets Due from Head Office/Branches/Agencies Abroad Total Assets Accountabilities Principal Accumulated Income Net Unrealized Gains/(Losses) on AFS Financial Assets Other Accountabilities Total Accountabilities ========= =========== ============--

ANNEX B App. T-5 Annex T-5-a Name of Trust CorPoration Comparison of Submitted Balance Sheet and Income Statement and Audited Financial Statements As of (end of calendar or fiscal year) (ln Thousand Pesos) Submitted Audited Variance/ Reasons for Report Report Discrepancy Discrepancy Cash and Other Cash ltems Due from BSP Deposit in Banks Financial Assets Designated at Fair Value through Profit or Loss (DFVPL) Available-for-Sale (AFS) Financial Assets Held-to-Maturity (HTM) Financial Assets Loans and Receivables, net Loans and Receivable Arising from Repurchase Agreements, Certificates of Assignment/Participation with Recourse Transactions Accrued Interest Income from Financial Assets TC Premises, Furniture, Fixtures and Equipment, net Other Assets Total Assets ====== ======== ========== Financial Liabilities Designated at Fair Value through Profit or Loss (DFVPL) Bonds Payable Redeemable Preferred Shares Financial Liabilities Associated with Transferred Assets Finance Lease Payment PaYable Accrued Interest, Taxes and Other Expenses Other Liabilities ========== ============ Paid-in Capital Stock Additional Paid-in Capital Retained Earnings Other Comprehensive I ncome Total Capital ======== =========== ============= Total Liabilities and CaPital ===----==== ======== =========== ============= Total Income Total Expenses Net Income Before Income Tax ========== ====== ============ =============

ANNEX B App. T-5 Annex T-5-b Name of Trust CorPoration (Contractual Relationship of TE, e.g., Institutional-Trust, etc.) Comparison of Submitted FRPTI Balance Sheet and Audited Financial Statements As of (end of calendar or fiscal year) (ln Thousand Pesos) Accounts FRPTI AFS Discrepancy Explanation for Discrepancy Assets (net) Cash on Hand, Checks and Other Cash ltems Due from BSP Deposit in Banks Financial Assets Designated at Fair Value through Profit or Loss (DFVPL) Available-for-Sale (AFS) Financial Assets Held-to-Maturity (HTM) Financial Assets Unquoted Debt Securities Classified as Loans Investments in Non-Marketable Equity Securities Loans and Receivables and Loans Arising from Repurchase Agreements and Securities Lending and Borrowing Transactions Other Financial Assets Investment Properties and Real and Other Properties Acquired Other Assets Total Assets :========= ========= =========== Accountabilities Principal Accumulated Income Net Unrealized Gains/(Losses) on AFS Financial Assets Other Accountabilities Total Accountabilities Pagel of7

ANNEX C APP'Q'lr Annex Q-33-c DISCTOSURE REQUIREMENTS TO THE AUDITED FINANCIAT STATEMENTS (AFS} (Appendix to Subsection 4790Q.4) QBs shall include the following additional information in the AFS: a. Notes to the financial statements: (1) Capital position on solo and consolidated bases. These shall include Common Equity Tier 1 (CETI) capital, Tier 1 capital, Total Qualifying Capital, Total Risk-Weighted Assets; Capital Adequacy Ratio (CAR), Tier 1 ratio, and CET 1 ratio; (2) Leverage ratio and Total Exposure Measure both on solo and consolidated bases; (b) (3) Liquidity position on solo and consolidated bases. These shall include:(a) Liquidity Coverage Ratio; and Net Stable Funding Ratio. In the case of stand-alone QB only the Minimum Liquidity Ratio shall be disclosed; (4) provisioning methodology and key assumptions in providing allowance for credit losses; and (5) Accounting policies which shall include, but not limited to, general accounting principles, valuation policies for financial instruments and Real and Other Properties Acquired (ROPA), and policies on securitizations, foreign currency translations, and repurchase agreements' b. Supplementary information : (1) Basic quantitative indicators of financial performance such as (a) return on average equity; (b) return on average assets; and (c) net interest margin, using the following formulas: (i) Return on Average EquitY (%) = Net Income (or Loss) after lncome Tax x 100 Average Total CaPital Accounts Where: Average Total = Total Capital Accounts Current calendar/ Capital fiscal year-end balance + Previous Accounts calendar/fiscal vear-end balance 2 (ii) Return on Average Assets (%) = Net Income (or Loss) after lncome Tax x 100 Average Total Assets Where: Average Total = Total Assets Current calendar/fiscal Assets year-end balance + Previous calendar/ fiscal vear-end balance 2 (iii) Net Interest Margin (%) = Net lnterest lncome x 100 Average Interest Earning Assets

ANNEX C Where: Net lnterest Income = Total Interest Income - Total Interest Expense Average = Total Interest Earning Assets Current Interest calendar/fiscal year-end balance + Earning Assets Previouscalendar/fiscalvear-endbalance 2 (2) Description of capital instruments issued; (3) percent (10%) of Tier 1 Significant credit exposures [thirty percent (3O%l of the total loan portfolio or ten capitallas to industry/economic sector; (ii) (4) Breakdown of total loans as to (i) security (secured, including type of security, and unsecured); and status (performing and non-performing) per product line; (5) Breakdown of Exposures to Related Parties and Directors, Officers, Stockholders and their Related Interests (DOSRI) as to: DOSRI lelated Party Loans (inclusive of DOSRI Particulars Loans Loans) 1. Outstanding loans 2. Percent of DOSRI/Related Party loans to total loan portfolio 3. Percent of unsecured DOSRI/ Related Party loans to total DOSRI/Related Pafi loans 4. Percent of past due DOSRI/ Related Party loans to total DOSRI/Re|ated Party loans 5. Percent of non-performing DOSRI/Related Party loans to total DOSRI/Related Party loans (6) Aggregate amount of secured liabilities and assets pledged as security; and (71 Nature and amount of contingencies and commitments arising from off-balance sheet items [include direct credit substitutes (e.g., export Letter of Credit (LCs) confirmed, underwritten accounts unsold), transaction-related contingencies (e.g., performance bonds, bid bonds, standby LCs), short-term self- domestic liquidating trade-related contingencies arising from the movement of goods (e'g', sight/usance LCs, sight/usance import LCs), sale and repurchase agreements not recognized in the balance sheeU interest and foreign exchange rate related items; and other commitments. For items "5", "6", and "7",indicate if there is none to report'

ANNEX C App. S-15 Annex S-15-b DISCTOSURE REQUIREMENTS TO THE AUDITED FINANCIAT STATEMENTS (AFS) (APPendix to Subsection 47725.4) NSSLAs shall include the following additional information in the AFS: a. Notes to the financial statements: (1) Capital po$ition which shall include Total Risk-Weighted Assets and Capital-to-Risk Assets Ratio; (21 Leverage ratio and Total Exposure Measurel; (3) Liquidity position which shall include minimum liquidity ratio' (4) provisioning methodology and key assumptions in providing allowance for credit losses; and (5) Accounting policies which shall include, but shall not be limited to, general accounting principles, valuation policies for financial instruments and Real and Other Properties Acquired (ROPA), and policies on foreign currency translations. b. Supplementary information: (1) (b) return on Basic quantitative indicators of financial performance such as (a) return on average equity; average assets; and (c) net interest margin, using the following formulas: (i) Return on Average EquitY (%) = Net lncome (or Loss) after lncome Tax x 100 Average Total Capital Accounts Where: Average Total = Total Capital Accounts Current calendar/ Capital fiscal year-end balance + Previous Accounts calendar/fiscal vear-end balance 2 (ii) Return on Average Assets (%) = Net Income (or Loss) after Income Tax x 100 Average Total Assets Where: Average Total = Total Assets Current calendar/fiscal Assets year-end balance + Previous calendar/ fiscal vear-end balance 2 (iii) Net lnterest Margin (%) = Net lnterest lncome x 100 Average Interest Earning Assets r Leverage ratio can be computed as: (i) Total Gross Loans/Deposit Liabilities; (ii) Total Loan Portfolio/(Deposit Liabilities + capital Contribution), (iii) Total Liabilities/Average Total Assets, and (iv) Total Liabilities/Average Total capital Accou nts, among others.

ANNEX C Where: Net Interest lncome = Total Interest Income - Total Interest Expense Average = Total Interest Earning Assets Current Interest calendar/fiscal year-end balance + Earning Assets Previouscalendar/fiscalvear-endbalance 2 (iv) Net Interest Margin = Total Interest Income - (Total Inclusive of Interest Expense + Declared Amount Declared Amount for Net Income Distribution) X 100 for Net Income Average Interest Earning Assets Distribution(%) Where: Declared amount for net income distribution refers to the amount declared within the current calendar/fiscal year. (21 Breakdown of total loans as to (i) security (secured, including type of security, and unsecured; and (ii) status (performing and non-performing) per product line; (3) Breakdown of Exposures to Trustees, Officers and their Related Interests (TORI) as to: o Outstanding loans to TORI o Percent of TORI loans to total loan portfolio o Percent of unsecured TORI loans to total TORI loans o Percent of past due TORI loans to total TORI loans r Percent of non-performing TORI loans to total TORI loans (4) Aggregate amount of secured liabilities and assets pledged as security; and (5) Nature and amount of contingencies and commitments arising from off-balance sheet items (include late deposit/payment received, items held for safekeeping/custody, items held as collateral, deficiency claims receivable and other contingent accounts). For items "3" , "4" , and "5" , indicate if there is none to report.

ANNEX C App. P-18 Annex P-18-b DISCTOSURE REQUIREMENTS TO THE AU DITED FINANCIAT STATEM ENTS (AFS) (Appendix to Subsection 4790P.4) pawnshops shall include the following supplementary information at the end of the notes to the financial statements: (a) Details of liabilities or borrowings, particularly: (1) number of creditors; and (2) portion, as of end of the reference calendar year, used for the purpose of acquiring fixed assets for business operations; (b) lf with corollary business, disclosure of total liabilities and income directly attributable to said business. pawnshops with money service business operations shall also comply with disclosures required thereto under Subsection 45l1N.6; and (c) Financial indicators, specifically return on average equity and average assets, and total borrowings to pledge loans ratio. For purposes of computing the financial indicators, the following formulas shall be used: (1) Return on Average EquitY (%) = Net Income (or Loss) after Income Tax x 100 Average Total CaPital Accounts Where: Average Total = Total Capital Accounts Current calendar Capital year-end balance + Previous Accounts calendar vear-end balance 2 (2) Return on Average Assets (%) = Net Income (or Loss) after lncome Tax x 100 Average Total Assets Where: Average Total = Total Assets Current calendar Assets year-end balance + Previous calendar vear-end balance 2 (3) Total Borrowings to Pledge Loans (%) = Total Borrowings Pledge Loans Where: Total borrowings refer to those for the pawnshop business, and exclude borrowings for purposes of acquiring fixed assets used for business operations and for utilization in corollary business, if any.

ANNEX C App. N-19 Annex N-19-c DISCTOSURE REQUIREMENTS TO THE AUDITED FINANCIAT STATEM ENTS (AFS) (Appendix to 4577N.6) l. RTCs/MCs/FXDs/VC Exchange RTCs/MCs/FXDs/VC Exchange shall include the following supplementary information at the end of the notes to the financial statements: (a) Total volume/value of remittance and/or money changing/foreign exchange transactions (absolute amount) for the reference year with breakdown as to: (1) domestic and/or foreign; and (2) transactions facilitated through VC, using the following template: \mount in Amount in Type of Transactions No. oftransactions USD PHP A. International Inward (Payout) Remittance Transactions B. International Outward (Send Out) Remittance Transaqtions C. Domestic Inward (Payout) Remittance Transactions D. Domestic Outward (Send Out) Remittance Transactions E. Foreisn Currencies Bought F. Foreign Currencies Sold G. International Inward (Payout) Remittance Facilitated Through VC H. International Outward (Send Out) Remittance Facilitated Throueh VC L Exchanee of VC to Philippine Peso/Other Currency J. Exchange of Philippine Peso/Other Currency to VC K. Other VC Transactions (please specify) (b) Basic quantitative indicators of financial performance such as return on average equity and return on average assets, using the following formulas: (1) Return on Average EquitY (%) = Where: = Average Total Total Capital Accounts Current calendar/ Capital fiscal year-end balance + Previous Accounts calendar/fiscal vear-end balance 2 (2) Return on Average Assets (%) = Net lncome (or Loss) after lncome Tax x 100 Average Total Assets

ANNEX C Where: Average Total = Total Assets Current calendar/fiscal Assets year-end balance + Previous calendar/ fiscal vear-end balance 2 ll. EMls EMls shall include the following supplementary information at the end of the notes to the financial statements: (a) Details of liabilities or borrowings, particularly on the number of creditors2; (b) lf with corollary business, disclosure of total liabilities and income directly attributable to said business' EMls with money service business operations shall also comply with disclosures required thereto under Subsection 4511N.5; (c) Financial indicators, specifically return on average equity and average assets. For purposes of computing the financial indicators, refer to item l.c above; (d) Liquidity cover for the reference year using the following template: Amount in Amount in Particulars USD PHP A. Deposits and Investments 1. Bank Deposits 2, GovernmentSecurities 3. Others (please sPecifY) B. E-Money Balances Tvpes of E-money cards/lnstruments 1. E-money in PhP 2. E-money in other currencies (please specify) C. Excess (Deficiency) of Liquidity Cover (e) Total volume/value of e-money transactions (absolute amount) for the reference year using the following template: Amount in Amount in No. oftransactions USD PHP Type of Transactions A. E-Money Beginning Balance B. |NFIOWS Conversion to E-Money 1. Conversion from cash centers (OTC/Outlets/Local Partners) 2. ATM/MobileBanking/lnternetBanking 3. Remco Partners Abroad 4. Pre-funding from local partners 5. Others (please sPecifY) c. ouTFtows conversion to currency 1. Conversion from cash centers (OTC/Outlets/Local Partners) 2. ATM/POS Withdrawals 2 Creditors except e-money holders

ANNEX C 3. Sweeping of E-Money Wallet/Account 4. Fund transfer from E-Wallet to Deposit Account 5, Others (please sPecifY) D. NETTNFTOW/(OUTFLOW) E. End of reference year E-Money Balances F. Additionallnformation Usage 1. Pavments to Merchants 2. Bills Pavments 3. Transfers to Other Subscribers (P2PIW2W) 4. Others (please specifY)

ANNEX C App. T-5 Annex T-5-c DISCLOSURE REQUIREMENTS TO THE AUDITED FINANCIAT STATEMENTS (AFS) (Appendix to Subsedion 4790T.4) TCs shall include the following additional information in the AFS: a. Notes to the financial statements: (1) Minimum required capital pursuant to Section 4ILLT; (2') Provisioning methodology and key assumptions in providing allowance for credit losses; and (3) Accounting policies which shall include, but not limited to, general accounting principles and valuation policies for financial instruments and Real and Other Properties Acquired (ROPA). b. Supplementary information: (1) Basic quantitative indicators of financial performance such as return on average equity, return on average assets and percentage of total trust fees to total assets under management (AUM), using the following formulas: (i) Return on Average Equity (/o) = Net Income (or Loss) after Income Tax x 100 Average Total Capital Accounts Where: Average Total = Total Capital Accounts Current calendar/ Capital fiscal year-end balance + Previous Accounts calendar/fiscal vear-end balance 2 (ii) Return on Average Assets (%) = Net Income (or Lossl after Income Tax x 100 Average Total Assets Where: Average Total = Total Assets Current calendar/fiscal Assets year-end balance + Previous calendar/ fiscal vear-end balance 2 (iii) Percentage of total trust fees to total AUM (%) = Total Trust Fees x 100 Total AUM l2l Total outstanding investment, loans and other credit accommodations to TC's DOSRI and related parties with name of DOSRI/related parties, and breakdown, if applicable, as to (i) security (secured, including type of security; and unsecured) and (ii)status (performing and non-performing); (3) Large exposures as defined under Section 4303T; (4) Nature and amount of contingencies and commitments arising from off-balance sheet items, if any; and (5) Aggregate amount of secured liabilities and assets pledged as security. For items "2" , "3" , "4" , and "5", indicate if there is none to report.