Regulations on Financial Consumer Protection to lmplement Republic Act No. 11765, otherwise known as the "Financial Products and Services Consumer Protection Act"

BANGKO SENTRAL NG PILIPINAS OFFICE OF THE GOVERNOR CIRCULAR NO.1160 Series of 2022 Subject: Regulations on Financial Consumer Protection to lmplement Republic Act No. 11765, otherwise known as the "Financial Products and Services Consumer Protection Act" 'The Monetary Board, in its Resolution No. 1683 dated 17 November2022, approved the adoption of the Amended Regulations and Cuidelines on Financial Consumer Protection (FCP) Framework to implement Republic Act No. .|.|765 or the Finonciol Products ond Seryices Consumer Protection Act (FCPA), and accordingly approved the amendments of the relevant provisions of the Manual of Regulations for Banks (MORB) and Manual of Regulations for Non- Bank Financial Institutions (MORN BFI). Sectionl. PartTenoftheMORB/MORNBFlareherebvamendedinitsentiretvandshall now read, as follows: PARTTEN FI NANCIAL CONSUMER PROTECTION REGULATIONS roornool-Q FTNANCTAL coNsuMER PROTECTTON FRAMEWORK (FRAMEWORK) Policy Stotement lt is the policy of the Bangko Sentral to ensure that appropriate mechanisms are in place to protect the interest of consumers of financial products and services under the conditions of transparency, fair and sound market conduct and effective handling of Financial Consumer disputes, aligned with global best practices. Towards this end, in line with its responsibility under Section 3 of Republic Act (R.A.) No. 7653 as amended, to promote broad and convenient access to high quality financial services and consider the interest of the general public, the Bangko Sentral adopts the Framework to implement R.A. No. 11765 otherwise known as the Finonciol Products ond Services Consumer Protection Act or FCPA. fhe Framework shall implement measures to protect the following rights of Financial Consumers: o. Right to equitable and fair treatment; n Right to disclosure and transparency of financial products and services; Right to protection of consumer assets against fraud and misuse; d. Right to data privacy and protection; and Right to timely handling and redress of complaints The Framework establishes the guidelines and expectations from Bangko Sentral-Supervised lnstitutions (BSls) to institutionalize consumer protection as an

integral component of corporate governance and culture as well as risk management. The objective of the Framework is for BSls to manage risks and potential harms to Financial Consumers, prevent unfair business practices, achieve fair and beneficial consumer outcomes and empower Financial Consumers to make better and informed financial decisions. These mechanisms reinforce confidence in the financial market and foster the stability of the Philippine financial system. Scope and Applicobility. The Framework shall apply to all financial products or services created, developed, offered or marketed by a BSl. The BSls' adoption of the Framework shall be proportionate to their asset size, structure, nature of products and services, and complexity of operations. Definition of Terms.As used in this Framework, the following terms shall mean: Bongko Sentro/-Supervised lnstitution (BSl) - refers to a person, natural or juridical, that provides financial products or services under the jurisdiction of the Bangko Sentral, as provided in existing laws, rules and regulations. b. Electronic Fund Tronsfer (EFT) - refers to transfers of funds between two accounts in the same or different BSls which are initiated and received using electronic devices and channels to transmit instructions. For purposes of the FCPA and its lmplementing Rules and Regulations (lRR), this term is synonymous to electronic payment and includes remittance tra nsactions. a Erroneous Tronsoction - refers to EFTs sent to an incorrect beneficiary account due to erroneous encoding of beneficiary account number and/or amount by the sender. d Finonciol Consumer or Client - refers to a person or entity, or their duly- authorized representative, who is a purchaser, lessee, recipient or prospective purchaser, lessee, or recipient of financial products or services of BSls. lt shall also referto any person, natural or juridicalwho had or has a current or prospective financial transaction with a BSI pertaining to its financial products or services. Finonciol Consumer Comploint - refers to an expression of dissatisfaction submitted by a Financial Consumer against a BSI about a financial product or service of a BSI and/or rts authorized third-party agent or representative, in which a response or resolution is expected. Finonciol Product or Service - refers to financial products or services created, developed and/or marketed by a BSl. These include, but are not limited to deposits, investments, fund transfers, trust products, loans, payments, remittances and digital financial products or services which pertain to the broad range of financial services accessed and delivered through digital channels. These include products that are authorized to be cross-sold by BSls. 9. Morketing - refers to the act of communicating, offering, promoting, advertising, or delivering of financial products or services by BSls.

n. Originoting Finonciol Institution (OFI) - refers to a BSI that sends EFTs to another BSl. lt holdsthe source account. Privocy lmpoct Assessment - refers to an instrument for assessing the potential impacts on privacy of a process, information system, program, software module, device or other initiative which processes personal information; and in consultation with stakeholders, for takinq actions as necessary to treat privacy risk. j Product Oovernonce - refers to the systems, procedures and controls in place to design, approve, distribute and assess financial products. K. Public Notlce - refers to a notice providing information for the public that is widespread throughout alltypes of media. t. Receiving Finonciol lnstitution (RFl) - refers to a BSI that accepts EFTs from an OFl. lt holds the beneficiarv account. m. Responsible Pricing - refers to the pricing, terms, and conditions of financial products or services that are set in a way that is both affordable to Clients and sustainable for BSls by taking into account, among others, Client needs, the pricing schemes of competitors and publicly available information on competitive pricing which conforms to existing laws, rules and regulations. n. Stotement of Account or Billing Stotement - refers to the periodic statement provided to the accountholder, which contains a listing of the transactions, purchases, payments and other debits or credits on the account, and the balance within the billing cycle or prescribed period. o. Third-Porty Agent or Representotive - refers to a qualified service provider duly-authorized and/or contracted by the BSI to perform designated activities on its behalf, in accordance with existing Bangko Sentral regulations. p. Unouthorized Tronsoction - refers to any transaction initiated by any person without the actual or imputed knowledge and consent of the account owner or holder. q. Vulneroble - refers to the poor and/or transient poor, children, women, persons with disabilities (PWDs), indigenous peoples, overseas Filipinos and their families, and older persons. Persons who face economic risks such as low and irregular incomes, financial and economic crises or risks brought about by environmental and natural hazards, and governance and political risks are also deemed vulnerable.

I, I rooznoo2-Q DUTTES OF BSts AND AUTHORTZED THTRD PART|ES Consumer Protection Risk Monogement System (CPRMS). A BSI should have a CPRMS that is integrated into the BSI's enterprise-wide risk management processes and risk governance framework. The CPRMS includes the governance structure, policies, processes, measurement and control procedures to ensure that Financial Consumer protection-related risks are identified, measured, monitored, and mitigated. A carefully devised, implemented, and monitored CPRMS provides the foundation for ensuring the BSI's adherence to Consumer Protection Standards of Conduct (Standards) in reference to Sec. lOO3f OO3-Q of this Circular and compliance with the FCPA and relevant laws, rules and regulations, thereby, ensuring that identified risks to the BSI and associated risks of financial harm or loss to Financial Consumers are properly managed. The CPRMS and Financial Consumer Protection Assistance Mechanism (FCPAM), in reference to Sec. lOO3/'loO3-Q of this Circular should ensure systematic application of policies and procedures, including the Standards. Board ond Senior MonagementOversight The Board of Directors (Board) and the members of Senior Management of BSls shall provide the means by which they shall identify, measure, monitor, and mitigate Financial Consumer Protection (FCP) risks inherent in their operations, in accordance with the Standards and all other applicable laws, rules and regulations. a. Responsib ilities of the Boord. The Boardr shall be primarily responsible for approving and overseeing the implementation of the BSI's CPRMS. The Board's responsibilities shall include the following: ' (1) Approve the CPRMS and FCPAM that take into consideration the BSI's business model, market, product lines, and relationships with third parties that may give rise to risks to Financial Consumers; (2) Promote a culture of ethical behavior and ensure adherence to the Standards and all relevant laws and regulations; (3) Provide adequate resources and adopt policies to effectively implement training and competency requirements for officers and personnel, authorized representatives or any other party acting on behalf of the BSI; (4) Approve a policy on remuneration and compensation packages structured to encourage responsible business conduct, fair treatment and avoidance/mitigation of conflicts of interes! and performance review which includes provisions for incentives on positive reviews/assessment that could also serve as basis for renewal of contract of third-party service providers; (5) Approve product oversight and governance mechanisms designed to ensure that financial products or services meet the needs of I lf there is no Board of Directors, the equivalent highest-ranking body or officer (if a single individual) is required 1o discharge these requirements. Likewise, the next highest body or officer will be the equivalent of Senior Management.

Financial Consumers in target markets or market segments, as well as universal products which are simple to access so as not to exclude vulnerable groups; (6) Adopt a policy on the imposition of any fees and/or charges of the BSI's financial product or service which shall include among others, the basis and quantitative support for the setting of the fees/charges and rationalization of the fee structure or amount; (7 ) Approve and periodically review a Code of Conduct applicable to all BSI directors, officers, staff and third-party agents. The Board shall define the BSI's corporate culture and values. lt shall establish standards of conduct and ethics and shall institutionalize a system that will allow reporting of concerns or violations to an appropriate body; and (8) Review periodically the implementation and effectiveness of the CPRMS, including how findings are reported and whether the audit mechanisms are in place to enable adequate oversight; and put in place a regular mechanism to review the relevance of the CPRMS in case of changes in the BSI's business model and/or operating environment. l-\ Responsibilities of Senior Monogement. The Senior Management shall be responsible for ensuring that the practices of the BSI and their third-party agents/representatives are aligned with the BSI's approved FCP policies and risk management system; and consistently displayed throughout the BSI's place of business particularly across all business units that deal directly with Financial Consumers. In this regard, the Senior Management sha ll: 0) Ensure that approved CPRMS and FCPAM policies and procedures are clearly documented and appropriately implemented across all levels and business units. This includes the responsibility of identifying the officer which will head the internal complaints handling unit or handle the implementation and regular reporting of consumer-related issues to the Board: (2) Establish an effective monitoring and management information system to promptly identify, regularly measure, aggregate, and analyze FCP-related issues to determine the level of Financial Consumer risks. An appropriate and clear reporting and escalation mechanism should also be integrated in the risk governance framework from any area of the BSI to Senior Management and/or from Senior Management to the Board. The management information system should be able to: (a) Provide adequate information on the performance and quality of the BSI's FCPAM and other internal processes that can provide relevant information that allows for identification of emerging Financial Consumer issues and root cause analysis;

(b) Determine the level of FCP risk exposure through assessment of its implementation of the Standards; (c) ldentify and monitor, in a timely manner, risks that may result in financial loss of Financial Consumers or result to consumer detriment. Financial Consumer complaints, data from consumer redress mechanisms and reports of fraud are kev indicators to monitor such risks: and (d) ldentify and assess emerging or increasing FCp-related risks that affect the BSI's Financial Consumers such as social engineering schemes, social media monitoring and market monitoring; (3) Ascertain that weaknesses in the FCP practices or emerging risks are addressed and corrective actions are taken in a timely manner; (4) Ensure observance of expectations and requirements prescribed under relevant regulations on compliance and internal audit; and (s) Ensure that adequate information and actions taken are reported to the Board on a regular basis in terms of the measurement of FCp- related risks, reports from the FCPAM, compliance with the Standards and requirements, as well as other material FCP-related developments that will impact the BSI's Financial Consumers. This includes the responsibility to put in place an effective system where reporting lines are established to promptly detect, analyze, and respond to Financial Consumer concerns and serious infractions. too3noo3-Q coNsuMER PROTECTTON STANDARDS OF CONDUCT The Standards are the core principles which BSls must adhere to at all times in dealing with Financial Consumers, which should be embedded in the BSls' conduct and culture. These are specific parameters used to gauge the efficiency of a BSI's CPRMS and FCPAM, modelled after international best practices. The Standaros are: a. Disclosure a nd Transpa rency; Protection of Client Information: c. Fair Treatment; o. Effective Recourse; a nd c. Protection of Consumer Assets against Fraud and Misuse Disclosure ond Tronsporencyi - Under this Standard, BSls must ensure that their Financial Consumers have a reasonable comprehensive understanding of the financial products and services which they may be acquiring or availing. In this context, full disclosure and utmost transparency, to the extent allowed under applicable laws and regulations, are the critical elements that empower the Financial Consumer to 'Z This Section should be read in conjunction with existing regulations related to disclosure and transparency of key information on loan and investment products and services, regulations on the conduct of treasury and trust activities of BSls and regulations governing fees on retail bank product/services and dormant deposit accounts.

make comparisons and informed financialdecisions. This is made possible by providing the Financial Consumer, through its verified communication channels in traditional and digital platforms, information that accurately represents the nature and structure of the product or service, its terms and conditions, as well as its fundamental benefits and risks. The standards for disclosure and transparency shall be applicable even to financial products and services offered electronically, as well as to financial products catering to different market segments with particular consideration for segments that may have limited financial literacy. The BSI demonstrates adherence to appropriate and adequate disclosure and transparency when: The manner of disclosure, whether in advertising materials, terms and conditions, and other forms of communication, is clear, concise, accurate. understandable and not misleading. Sufficient product disclosure must be provided before the contracting of the financial product or service to give the Client enough basis and time for review. At the pre-contractual stage, information on the type and amount of fees, charges and interests, as well as the standard terms and conditions, must be made available to the client through various kinds of communication channels, including all digital channels. Disclosure of information on financial products or services should be available to the public through printed materials, mass media, websites or digital platforms. For digital financial products and services, the manner of disclosure should be easily accessible, especially where the terms and conditions tend to be deeply embedded and hard to access without scrolling or clicking through multiple screens. Information should be disclosed and properly documented before and during a sale of a financial product or service and during key stages of the relationship with the Financial consumer. BSls must provide the most up- to-date information at the stages that information will be most useful for their Client. This requirement includes information provided in advertisements during the pre-contractual stage, at the point of entering a contract and during the term of the contract. The terms and conditions must clearly state whether interest, fees, charges, and penalties can change over time. clients should also be effectively notified of any changes or amendments to the terms and conditions at least sixty (60) days prior to such amendments by public notice, unless the amendments are directed by the Bangko sentral to take effect immediately or unless otherwise provided in existing laws, rules and regulations. Complementary individual notices to a Client shall also be sent within the same period if the amendments pertain to or will result to fees to be paid or charged on the account of the Client. The method for computing said interest, fees, charges, and penalties shall be disclosed consistent with existing laws, rules regulations. Clients may be allowed to pre-terminate the contract on the financial products or services availed if they do not agree with the significant amendments to the terms and conditions as PageT of 26

initiated by the BSl, or if they fail to receive any proper notice on the changes in terms and conditions. Terms and conditions must contain all significant provisions of the financial product or service giving prominence to key featuresffacts. The terms and conditions should contain the following details and possess these cha racteristics: (l) Information on risks, return, caveat about the financial product or service, any waiver of rights and limitations of liabilities except the rights mentioned under Section .12 of the FCPA, after-sales service, Financial Consumers' rights and responsibilities, consequences of failure to meet obligations, rights and responsibilities of the BSl, involvement of authorized agents, any conflict of interest by BSI staff, cancellation and product portability, among others. (2) The above minimum required disclosures shall always be in writing or available by electronic means. They shall follow a standard format and written in plain language to provide the Financial consumers key information and disclosures that will facilitate better understanding and comparison among the products offered by different BSls A BSI shall require its Client to sign the written or electronic disclosure statement as affirmation of the client's receipt and understanding of the disclosure statement. A BSI may use any methodology or procedure that allows the Client to indicate the intention of authenticating, approving, or accepting an electronic document, consistent with R.A. No. 8792or the Electronic Commerce Act of 2OOO, and other relevant laws, rules, and issuances of the Bangko Sentral. A BSI may opt to draft an individual or separate disclosure statement for its Client or incorporate the same in the main tra nsaction ag reement/contract.3 (3) For more complex products, such as but not limited to investment products, the key features as well as costs and risks shall be highlighted in a key facts statement or product Highlight Sheet (PHS). The PHS shall enable comparison with other financial products and shall be provided at no additional cost. Before the signing of any contract, the BSI should ensure that the Financial Consumer has freely signed a statement to the effect that said Financial Consumer has duly received, read, and understood the PHS. d. Advertising materials shall not be false, misleading, or contain deceptive statements or omit key information that may materially and/or adversely affect the decision of the Financial Consumer to avail or acquire a financial product or service. BSls are legally responsible for all statements made in 3 This provision should be read in conjunction with existing regulations on product-specific minimum disclosures under Sec. 612/612-Q of the MORB/MORNBFI on Sales and Marketinq Cuidelines for Financial Products and Sec. 306 of the MORB on the requirements for Truth in Lending Act (TILA).

the marketing and sales materials that they produce relative to their financial products or services.4 In their advertising materials, BSls shall disclose the contact information of their FCPAM or appropriate internalconsumer assistance unit handling Financial Consumer concerns or complaints. BSls shall also disclose that they are regulated, and the advertising materials must identify the Bangko Sentral as financial regulator. The terms and conditions, public notices and other communications to Clients must contain the following: 0) Contact information of the BSI's FCPAM or appropriate internal consumer assistance unit handling Financial Consumer complaints or concerns; and (2) Statement that the BSI is a regulated entity by the Bangko Sentral and Bangko Sentral's contact information. Communication of the BSI officers, staff, authorized agents or any other party acting on the BSI's behalf is conducted in such a manner that Clients can understand the terms of the contract and their rights and obligations. Client segments that may have financial literacy limitations or subject to certain disabilities or infirmities preventing them from reading or understanding a proposed written contract should be given a clear verbal explanation of the terms and conditions, as well as its features, risks and costs, in a language they can understand. q. Adequate time is given to Financial Consumers to review, ask questions and receive information to fully understand the terms and conditions prior to signing the contract or agreement or executing the transaction. BSls should ensure that documents signed by the Financial Consumer are completely-filled out and have no blank terms provided, that the Financial Consumer is not precluded from readily availing of the BSI's financial product or service and accepting the BSI's terms and conditions, signing the contract or agreement, or executing the transaction upon his/her sole discretion. The Financial Consumer should be given a copy of each of the documents he/she signed including, but not limited to the contract, with all terms and conditions and/or proof of the transaction, whether printed or in electronic copy, at the option of the Financial Consumer, or in the manner or channel through which the product or service was accessed, immediately after the contract or agreement was executed or transaction was completed. Statements of Account or Billing Statements are provided regularly in a convenient manner to the Financial Consumer, or through the channel through which the product was sold, commensurate to the type of product and terms. The statement must bear an official seal and/or include the letterhead of the BSl. In general, statements for transaction a This provision should be read in conjunction with the Sales and Marketing Ouidelines for Financial Products; under Sec. 612/612-Q of the MORBiMORNBFI as weil as Appendix e;lQ-4g of the MORB/MORNBFI on the basic standards on the administration of trust accounts.

accounts, including loan accounts, with regard to the period covered, and depending on the type of product, should include the following information: (r) the opening and closing balances; (2) any transactions made during the period, such as but not limited to deposit, withdrawal, fund transfer, investment, remittance and/or paymenr; (3) the merchant or counterpart of each transaction, if any; (4) details of the interest rate applied to the account, if any; (s) details of the fees, exchange rate and other charges incurred by the customer in each transaction, if any; and (6) any changes applied to the interest rates, charges or fees, if any. The frequency with which statements are provided should be commensurate with the type of service and its term, to allow Clients to become aware of anv una uthorized tra nsactions. Upon culmination or termination of the contract or agreement, BSls are required to immediately provide the Financial Consumer with a written or electronic notice, certification or other closing statement, without need of written or verbal demand. Responsible pricing. BSls should establish and follow internal policies and procedures for setting prices for their products and services, based on, among others, the principle of responsible pricing. Pricing procedures and documentation should provide the rationale for why and how prices have been set. Pricing procedures must consider publicly available information on competitive pricing, except in special instances of tailor-fit and/or pioneering products and/or services, the cost to provide the financial product or service and affordability to Clients, and the reasons for setting the price of each financial product or service must be duly-documented. The BSI's pricing mechanism or policy shall adhere to existing laws, rules and regulations of the Bangko Sentral. BSls may also opt to have their product governance mechanism assess whether algorithms that influence or determine pricing may be unfairly biased toward certain groups of people, especiallyvulnerable segments. Fqir trestment. BSls shall have the right to select their Clients: Provided, that they shall not discriminate against Clients on the basis of race, age, financial capacity, ethnicity, origin, gender, disability, health condition, sexual orientation, religious affiliation and practice, or political affiliation: Provided, further, that BSls may provide distinction, as necessary, when making a risk assessment on a specific financial product or service. This Standard ensures that Financial Consumers are treated fairly, honestly, and professionally at all stages of its relationship with the BSl. BSls shall adopt mechanisms to safeguard the interest of their Clients, which shall include rules regarding ethical

staff behavior, acceptable selling practices, fair and equitable terms and conditions, provision of products and services appropriate to the capacity and risk appetite of Financial Consumers, among others; and incorporate the same in their policies and procedures, control functions and agreements with outsourced third parties. The BSI demonstrates the Standard of fair treatment towards Financial Consumers if its policies and practices observe the followinq: Terms and conditions are not unfair when there is no significant imbalance in the parties' rights and obligations under the contract, to the detriment of the Financial Consumer. Except where expressly permitted by law, in any agreement with a Financial Consumer, a term should be deemed as unfair if it exempts or absolves a BSI from acting with skill, care, diligence, or professionalism toward the Financial Consumer in connection with the provision of any product or service, and/or any liability for failing to do so. Ambiguities in contractual terms and conditions should be construed in favor of the Financial Consumer. A term and/or condition is deemed unfair when it includes, but is not limited to, the following circumstances: (1) it amends the terms of the contract without adequate notice and/or without specifying the circumstances in which this may occur and/or does not provide a right of termination when such amendment occurs; (2) it renews a fixed term contract without reasonable notice or conversely, terminates an open - ended contract without adequate notice to the Financial Consumer: (3) it permits the BSI to unilaterally determine whether the contract has been breached or imposes an unreasonable penalty for a breach of the contracU (4) it binds the Financial Consumers to other terms that the Financial Consumers cannot realistically familiarize themselves with before the contract is executed, or (5) it permits the BSI to assign the contract to the detriment of the Financial Consumers without their consent. n BSls are prohibited from employing abusive collection or debt recovery practices against Financial Consumers. BSls or their collection agencies, counsels and other third-party agents may resort to all reasonable and legally permissible means to collect amounts due them. However, in doing so, they must observe good faith and reasonable conduct and refrain from engaging in unscrupulous or untoward acts.s s This provision should be read in conjunction with existing regulations on Management Contracts and Outsourcing in Sec. ll2nll-Q, Appendices 78/Q-65 and lo3/Q-36 of MoRB/MoRNBFI; and on debt recovery or collection practices:uch as Sec. 3Ol/3Ol-Q and Sec.312 of the MORB/MORNBFt.

BSls shall adhere to existing Bangko Sentral guidelines on outsourcing, as well as relevant laws, rules and regulations. BSls shall ensure that all data being handled, processed, and/or stored through an outsourcing arrangement are included in its data inventory and data classification process. To this end, BSls shall retain exclusive ownership of its Client records and data already referred to its collection agencies, courrsels and other authorized third-party agents. BSI's external collection agencies, counsels or other authorized third-party agents are indispensable parties in complaints involving unfair collection practices. The BSI staff and authorized third-party agents or representatives must treat Financial Consumers with professionalcompetence and in a manner that is fair and reasonable. The BSlshall: (1) Establish a Code of Conduct applicable to all BSI directors, officers, staff and third-party agents, setting forth the organizational values and standards of professional conduct that uphold protection of Financial Consumers, appropriate to its structure, operations, and risk orofile. (2) Align its recruitment and training policies around professional, fair and responsible treatment of clients, compliance with FCP requirements, and mitigation of consumer risks, for instance: t:l BSI staff and third party-agents or representatives must receive adequate training suitable for the complexity of the fina ncial prod ucts or services they sell to ensure u nderstanding of their key features, risks, terms and costs, relevant FCP standards and requirements, including statutory and regulatory requirements and related internal policies and procedures that might impact their Financial Consumers, including those pertaining to consumer risks arising from cybersecurity and/or digital financial products and services. Aside from trainings for frontline service personnel, trainings shall also be made available to compliance and internal audit officers and staff. (b) BSI staff, as well as authorized third-party agents or representatives contracted for sales and marketing purposes, do not use deceptive or high pressure/aggressive sales techniques and should not force clients to sign contracts or rush into a financial deal without the benefit of shopping around. (c) BSI staff involved in collections, as well as authorized third- party agents or representatives contracted for the purpose, receive training in acceptable debt collection practices and loan recovery procedures, consistent with existing relevant regulations. Page L2 of 26

(d) BSI staff, as well as authorized third-party agents or representatives, do not employ practices that discriminate or take advantage of difficulties faced by vulnerable groups. (e) Establish policies and procedures that aim to protect Financial Consumers' deposits and other assets, against internal or external fraud or misuse. (3) Ensure that the performance evaluation, remuneration structure and compensation practices for staff of BSI and authorized third- party agents or representatives encourage responsible business conduct, fair treatment and avoidance/mitigation of conflicts of i nterest. (4) Have in place mechanisms to manage and resolve actual conflicts of interest with respect to compensation or remuneration policies that arise in the interaction between their staff and agents and their Financial Consumers and potential Clients. This is demonstrated when the staff or authorized aoent: (a) Discloses properly to the Financial Consumer prior to the execution of the transaction that the BSI or its staff/agent has an interest in a direct/cross transaction with a Financial Consumer. (b) Discloses the limited availability of products to Financial Consumers when the BSI only recommends products which are issued by their related companies, subsidiaries or affiliates, particularly when commissions or rebates are the primary basis for recommending the particular product to Financial Consumers. (c) Discloses the basis on which the BSI is remunerated at the pre-contractua I stage. (d) Ensures that adequate systems and controls are in place to promptly identify issues and matters that may be detrimental to a Client's interest, for instance: cases in which advice may have been given merely to meet sales targets or may be driven bv financial or other incentives. (5) Develop and adopt a risk-focused screening process for its pre- employment or background screening based on factors like the position to be filled, responsibilities associated with such position, reputational and FCP risk implications. Such process may, among others. involve: (a) Inclusion of ethical behavior, professional conduct, and quality of interaction with Financial Consumers as part of staff oerformance evaluations.

(b) Conduct of appropriate due diligence before selecting the authorized agents/outsourced parties, taking into account the agents' integrity, professionalism, financial soundness, operational capability and capacity, compatibility with the BSI's corporate culture, and ability to implement controls to monitor the agents' performance on a continuous basis. The criteria for selection of authorized agents/outsourced parties should include the presence of an established mechanism to address Clients' complaints aqainst an authorized a g ent/representative. Liobility of o BSI on the c'cts or omissions of its quthorized agents ond rePresentotives. The BSI shall be responsible for the acts or omissions of its directors, trustees, officers, employees, or agents, in offering, marketing and transacting with Financial Consumers for its financial oroducts or services. The BSI shall be solidarily-liable with the accredited or authorized agents, representatives or third-party service providers for their acts or omissions in marketing and transacting, which may include, but not limited to debt collection, with Financial Consumers for its financial products or services. Privocy ond protection of client do'tq.6 BSls must ensure that they adhere to the general data privacy principles of transparency, legitimate purpose and proportionality under R.A. No. lOl73 or the Data Privacy Act of 2012 and its lRRs. The principles include having well-articulated privacy notices and policies, specifying and declaring the purpose/sfor processing and criteria being relied on asthe lawful basis for processing Client data, ensuring that the processing is necessary and not excessive in relation to the purpose, and implementing reasonable and appropriate information security measures and well-defined protocols for upholding data subject rights, among others. Procedures in handling the personal information of the Financial Consumers should be periodically evaluated. This should be an end-to-end process that should cover, among others, the array of information that will be pre-identified and collected, the purpose and manner of gathering each information, and the Information TechnoloQy (lT)-security infrastructure of the BSls. Protocols for processing and disclosure shall be strictly observed and implemented both within the BSI and to third parties in accordance with the Data Privacy Act, its IRR and other applicable rules and regulations on data privacy. Provided, that, the criteria for lawful processing of information and protocol for storage, destruction, disclosure, both within the BSI and to third parties, are in accordance with the Data Privacy Act and other applicable laws, rules and regulations. Protection of Client lnformqtion. Under this consumer orotection standard on client information, Financial Consumers have the right to expect implementation of the most appropriate safeguards ensuring the confidentiality, integrity, and 6 This Section should be read in conjunction wlth existing regulations on lT Risk Management System and applicable laws, rules and regulations on data privacy.

availability of their financial transactions, as well as expect that all relevant personal information lawlully disclosed in the course of a transaction, are kept confidential and are secureo. The BSI demonstrates the ability to protect Financial Consumers' information when, among other things, it is able to. d. Have a declared and published privacy policy to safeguard its Financial Consumers' personal information. This policy should govern the collection, processing, use, distribution, storage, and eventual disposal of Client information, and the identification of levels of permissible access to Clients' data for BSls' employees and their third-party service providers. BSls should ensure that privacy policies and sanctions for violations are implemented and strictly enforced. BSls shall ensure the accessibility of their external privacy notice on their website and other official communication channels and digital platforms. b. Ensure that privacy policies are regularly observed, periodically reviewed and updated, and communicated throughout the organization. Privacy policies shall be subject to regular review to ensure that these are attuned to the current processing activities, taking into account the use of new technologies and changes in the pertinent standards and/or legal req u i rements, where appl ica ble. Have appropriate systems or risk mitigation measures in place to protect the confidentiality and security of the personal data of its Financial Consumers against any threat or hazard to the security or integrity of the information, and against unauthorized access. This includes a detailed written security plan, based on the results of the Privacy lmpact Assessment (PlA) conducted to identify risks in the processing of personal data. Such plan must also include a system for responding to possible security vulnerabilities and/or breaches. The plan must be proportionate to their asset size, structure, nature of products and services, complexity of operations and sensitivity of Financial Consumer information that they handle. These security measures should be regularly evaluated, monitored, and updated by BSls to ensure effectiveness. Adopt and implement information security standards and privacy by design principles to ensure the safety and protection of the privacy, confidentiality, integrity, availability, authenticity and non-repudiation of Clients' information and financial transactions. End-to-end security protocols, such as but not limited to encryptions and/or security-by- default, between Clients and the internal systems of the BSI should be implemented. In addition to existing applicable regulations, the Bangko Sentral may prescribe additional minimum information security standards for compliance by BSls. This may include network and software design, as well as information processing, database storage, transmission, retrieval, and disposal. Security must be maintained throughout the life-cycle of Financial Consumers' information, from data acquisition to disposal. BSls should have clear policies and procedures on data breaches includinq mechanisms to address external threats and

internal threats, including those coming from BSI personnel or agents that unlawfully access Client data. subject to the provisions of existing laws, rules and regulations on data privacy, communicate to its Financial consumers the extent of personal information to be used and purpose for which they are to be processed, the recipients to whom they are or may be disclosed, and the period for which they will be stored. Financial Consumers shall be given an opportunity to retract or cancel their consent, for purposes other than those that are governed by existing laws, rules and regulations. cive Financial Consumers opportunity to exercise all their rights as data subjects by implementing mechanisms which enable the free exercise of the same through procedures which are clear, simple, straightforward, and convenient. Data subjects' rights include the right to be informed, right to access their information, right to object, right to rectification or to challenge the inaccuracy and completeness of the information, and right to have their information amended or corrected as appropriate, right to request for deletion or blocking, right to file a complaint, and right to data portability. clients have the right to review their own data to ensure that inaccuracies or deficiencies are corrected or amended, refuse the sharing of their information to a third party, and request the removal of their data from the BSI's system if they wish to be excluded from receiving advertisements and other notifications, or they no longer wish to use the BSI's services, subject to certain limitations. This is without prejudice to compliance with existing laws, rules and regulations on data retention. BSls must provide Financial consumers with information on how they may request to be deleted from the BSI's database, or to be excluded from receiving advertisements and other notifications. :,. Notify Financial Consumers, as soon as practicable, when privacy breaches occur, that may leave their data vulnerable; and provide means for Financial Consumers to prevent and respond to privacy breaches. BSls must ensure that when data is shared across authorized parties, the data is transferred securely and used in a manner consistent with their privacy policy and relevant rules and regulations. BSls must provide clear policies and procedures on addressing data breaches, from discovery of breaches or detection of security incidents, its evaluation and investigation, documentation, notification to affected Financial Consumers, compensation to Financial Consumers, and compliance with the reportorial requirements of regulatory bodies, including the National Privacy Commission. Effective f,lecourse. Under this Standard, Financial Consumers should be provided with accessible, independent, fair, accountable, timely, and efficient means for resolving concerns, inquiries and requests about their financial transactions. BSls 'should have in place mechanismsforcomplaint handling and redressand mayemploy various modalities or technological innovations for complaints handling. Page 16 of26

. Finqncial Consumer Protection Assistonce Mechonism (FCPAM). Each BSI must establish a single FCPAM, commensurate to the size, structure, nature of products and services, and complexity of operations, to provide free assistance to Financial Consumers on their concerns about the BSI's financial products, services and/or transactions. This shall include handling of complaints, inquiries and requests. The BSI's FCPAM is a first-level recourse mechanism for Financial Consumers who are dissatisfied with the financial product or service of a BSI or its third-party agent or repreqentative. Financial Consumers are first required to report their complaints, . inquiries or requests, through the FCPAM of the concerned BSl. As the first-level recourse, BSls shall adopt simplified requirements and procedures for the availment of their FCPAM by Financial Consumers. The complaints-handling process of each BSl, including the turn-around time (TAT), must be proportionate to their asset size, structure, nature of products and services and complexity of operations. Each BSI shall provide in detail the steps necessary to complete the complaints-handling process, including a flow chart indicating the end-to-end process, with the TAT for each step. BSls shall ensure adequate manpower and resources to carry out the FCPAM. Each BSI shall also provide Financial Consumers with information on the status and final resolution of their ' complaints, inquiries or requests. Financial Consumers who are dissatisfied with the BSI's handling of their complaints, inquiries or requests, may escalate their concerns with the Bangko Sentral Consumer Assistance Mechanism (CAM). Reporting the concern with the BSI's FCPAM is a condition precedent to the filing of a complaint to initiate the Bangko Sentral CAM. A BSI shall: a. Establish an effective internal complaints-handling unit or FCPAM designed to receive, record, evaluate, resolve, monitor and report consumer complaints, concerns, inquiries or requests to be implemented by a designated officer, unit, group or department, commensurate to the size, structure, nature of products and services, and complexity of operations, ensuring that there is no conflict of interest. b. Establish, maintain and implement formalized, written internal policies and processes, procedures and practices for reasonable and prompt handling of consumer concerns. This includes clear policies on i nvesti g ation, resol ution a nd restitution of com pla i nts. c. Make available multiple channels or platforms for lodging complaints, inquiries and requests; taking into consideration Financial Consumer needs to be served; and put in place a dedicated helpdesk or hotline for . the said purpose. Channels or platforms shall be functional, accessible and efficient. The complaints handling service should be free of charge to Financial Consumers, and enable a complaint to be submitted via oral, written or digital formats. A simple and easy-to-use guide about the procedures should be made available to Financial Consumers, either on request or when they want to make a complaint. The procedures should be accessible and be made available to clients via website, social media, marketing materials in . printed or digitalform. Page L7 of 26

d. Ensure that channels or platforms for submitting complaints are adapted to Financial Consumer needs (i.e. level of literacy, accessibility) and local specifications (i.e. language or dialect). Channels used to submit complaints can include telephone, fax, email, complaint/suggestion ' boxes, web presence, mobile phone apps, and in person. To the extent possible and employing a proportionate approach, BSls should make available a toll-free number, free-response SMS texting or free data for apps or live-chat to encourage access. A dedicated 2417 customer-care telephone line, especially for fraud-related concerns should be put in olace. For BSls with simpleT operations, Clients may submit their complaint tickets through email and/or other messaging modes provided that the same are addressed or attended to by the BSI within 24 hours. Maintain a management information system for the complaints from Financial Consumers that allows for consolidation, comparison and analysis on a regular basis, including investigating whether complaints indicate an isolated issue or a more widespread issue for Financial Consumers. This analysis and reports of Financial Consumer complaints must have clear reporting and escalation structure within the BSI's risk governance framework and covered in its CPRMS. The complaints reports shall be submitted to Banqko Sentral in accordance with relevant regulations. Obtain the Financial Consumers' consent to share oersonal information and details of their complaints, evidenced by written, electronic or recorded means, subject to requirements under the FCP Framework, the Data Privacy Act and its lRR, and other relevant rules and regulations on data privacy, personal information processing, and rights of data subjects, among others. For Financial Consumers from vulnerable groups who might not be able to give informed consent, BSls shall ensure reasonable accommodations for their easy access to the FCPAM. Protection of Consumer Assets Agoinst Frqud qnd Misuse. To mitigate the risks of fraud and misuse faced by Financial Consumers, BSls, to the extent allowed by existing laws, rules and regulations, must provide necessary assistance, including the provision of relevant information relating to fraudulent or unauthorized transactions. Further, BSls must provide clear information on the actions taken or to be taken on a complaint, inquiry or request from a Financial Consumer involving fraudulent or unauthorized transactions. BSls shall adequately inform Financial Consumers of their responsibilities, as users of financial products and services, and provide timely transaction notifications which are essential in curtailing and detecting fraudulent or unauthorized tra nsactions. 7 Simple BSls pertain to those that are not classified as comnlex Banks/Non-Bank Financial Institutions as defincd in Sec. l3l of MORB/ Sec. ]33-Q of MORNBFI. Page 18 of26

Cloims ossesstnent qnd investigotion. A BSI should evaluate any claim made by any accountholder in relation to any disputed transaction for purposes of resolving the claim or assessing the parties' liability in accordance with the FCP Framework, and other existing laws, rules and regulations. BSls should resolve a claim in a fair and reasonable manner. The claim resolution process should also be communicated to the accountholder in a timely and transparent manner. Fraud-related concerns should be given utmost priority and should be resolved within a reasonable time commensurate to the complexity of the circumstances. Reporting Chqnnels. BSls should provide its Clients with a free and active reporting channel/s which may consist of a manned phone line, -mobile number online portal, email, chatbot, instant messaging, or other closely-monitored communication channels which should be available on a 2417 basis. Any Financial Consumer who contacts the reporting channel should receive an immediate written acknowledgement through the same channel. Unauthorized Trqnsactions.s Concerns or disputes about fund transfers or alleged unauthorized transactions shall be filed with the Originating Financial Institution (OFl). The OFI is primarily responsible for providing assistance and redress to its Clients. Upon receipt of fund transfer disputes or alleged unauthorized transactions, the OFI shall immediately inform and provide relevant details to the Receiving Financial . Institution (RFl). OFls and RFls should then implement the following, pending the result of the investigation of the dispute or allegation: d, Suspend the imposition of interest, fees or charges, if applicable; b. Hold the disputed funds, if still intact, in compliance with BSI policies, existing Bangko Sentral rules and regulations, or industry conventions; Provide reasonable accommodations to the Financial Consumer, such as a non-withdrawable provisional credit of the disputed amount or temporary hold of the disputed amount within a given period as determined by the BSI; and d Perform such other necessary actions to protect the Financial Consumer's interest and/or assets, such as but not limited to, account blocking or freezinq of funds. Within three (3) banking days from the conclusion of the investigation, the BSI must inform the Client formally of the result. The information should include, among others, a notification of debiting the provisionally-credited amount if there is sufficient proof that no unauthorized or erroneous transaction occurred. lf after the investigation, the disputed transaction is found to be an unauthorized or fraudulent transaction, the BSI should immediatelv: 8 These guidelines should be read in conjunction with existing regulations on lT Risk Management System, Standards and Cuidef ines, BSP Circular 1.140, Series of 2022 and regulations on National Retail Payments Systems, and other relevant rules and regulations. Page 19 of26

d. Correct or reverse the transaction found to be unauthorized or fraudulent, including any related interest, charges and fees imposed thereon: and/or Make permanent the provisionally-credited amount, if any. Subject to proportionality principle, BSls should implement fraud test mechanisms or measures under their CPRMS to distinguish fraudulent from legitimate transactions. Liobility for losses orising from unquthorized transqctions. In determining liability for losses, BSls may consider, among others, the following factors: a. Actions of the accountholder before, during and after the unauthorized tra nsaction; l-\ Acts or omissions of the BSl, its employees, third-party agent, outsourced entity or service provider acting on behalf of the the BSI; and/or Non-compliance by the BSl, its employees, agents or service providers, with any requirement under the FCP Framework and other existing rules and regulations applicable to the BSI's provision of any financial product or service: and/or Erroneous Trqnsoctions. In case an accountholder transfers funds to a payee account other than the intended recipient account, he/she should immediately report the error to the OFI with the followinq details: Name, contact number, and other credentials of the payor; b. Account from which the payment was made; Payee account details; o. Transaction amount; and E. Transaction date and time. In case the OFI and RFI involved in an erroneous transaction are diffe,rent BSls, the OFI must immediately inform the PFl. Both the OFI and RFI should make r':asonable efforts to recover the sum sent in eryor in accordance with existing regulations and industry conventions. IOO4f.OO4-Q APPROPRIATE DESIGN AND DELIVERY OF FINANCIAL PRODUCTS AND SERVICES As far as practicable, BSls are expected to ensure that their financial p'oducts or services are adequately aligned with the Financial Consumers' nee,ls, goals, understanding and financial capabilities. BSls shall gather consumer insiglrts and/or analytics on consumer behavior, characteristics and constraints to properly identify a target market, design and deliver or distribute their financial products an(l services accordingly, with attention to the needs of vulnerable segments. BSls shall put in place internal product oversight and governance arrafrgements designed to ensure that their financial products and services meet the needs o:'Financial Consumers in their target markets. Clearly articulated policies, decisicn-making Page 2O of 26

processes, roles and responsibilities of Senior Management and all relevant i'unctional units involved in product design and distribution must be set in place. Following any product launch, t he BSls together with third-party distrikrutors and other key stakeholders, may be requircd to periodically review the product design and related disclosure materials. BSI's product development, review or e,valuation, distribution, and after sales process shall continuously take into consideratiorr possible risks to Financial Consumers, evolving and sophisticated technology platf,:rms and delivery channels. BSls are expected to exercise control over the features and innovatiors of their digital financial products and services, including those developed in collaboration or partnership with third party service providers. BSls must not take advantage of Clients' inexperience and inability to access ancJ use such digital financial services. BSls shall imolement the follolnrinq measures: Affordobility ond suitobility ossessrnents - BSls should have written procedures for determining whether a particular financial product or service is suitable and affordable for their Clients. This shall include the determination of whether the amount and terms of the offered financial product or service allow various Clients to meet their respective obligations with a low probability of a serious hardship, and that there is a reasonable prospect that the financial product or service will provide value to the Client. For the purpose of extending credit, this assessment should include measures to orevent over-indebtedness.e When making a recommendation to a Financial Consumer: 0) BSls that will conduct suitability assessment should inform their Clients, clearly and simply, about the suitability assessment, its purpose, and the BSI's responsibility to conduct the assessment under relevant regulations so that Clients understand why they are asked to provide certain information. BSls should encourage Clients to provide accurate and sufficient information about their knowledge, experience, financial situation, financial capability, ability to bear losses, investment objectives, and risk tolerance. (2) BSls should offer products or services that are in line with the risk profile and/or preferences of their Clients. The BSls should allow Clients to choose from a range of available products and services that are most suitable to their needs, requirements or preferences. This may include preferences on payment dates, loyalties or average balances. BSls should provide suflicient and accurate information to enable their Clients to select the most suitable and affordable product or service.ro (3) BSls should advise their Clients that in case of incomolete information or misrepresentations made in the suitability assessments, the BSI is e This provision should be read in conjunction with Section 612 of the MORB on sales and marketing guidelines of financial products specifically on client suitability guidelines. io This provision should be read in conjunction with existing regulations on debt recovery or collection practices such as Sec. 3ol/3o',1-Q and Sec.3l2 of the MORB and MORNBFI. Page 2L of 26

not in a position to accurately determine whether the product or service is appropriate for them. This advice may be provided in a standardized format. lf the requested products do not match a Client's risk tolerance assessment results, the BSI should draw attention to the risk mismatch and provide a disclosure of consequences, either in digital or written format, for acceptance by the Client. Product bundling. When bundling products and services, BSls should also take into consideration product suitability and should not unduly limit consumer choice. When Financial Consumers are required by a BSI to purchase a product, such as a checking account or an insurance policy, as a precondition for receiving a loan, they should be free to choose the provider of the secondary product, subject to reasonable standards set by the BSl, which shall be disclosed and made available to their Clienrs. Information regarding the bundled product and the right of choice should be made known to clients during the shopping and pre-contractual phases. The BSI should not sway or pressure its Clients toward a particular provider on the basis of its own commercial agreement with that provider. When a choice among different providers for the secondary product is unavailable, the BSI shall not be prohibited from offering the bundled products, but all key features, including the identity of the provider of the secondary product, should be fully-disclosed to the Client. BSls should offer product bundles with market-based pricing. BSls must focus on accelerating their digitization strategies to better understand customer preferences and behavior and offer personalized, relevant, flexible and intuitive bundled product offers. b. Cooling-off period - BSls must set in place a cooling-off policy for specific products and services, based on the BSI's assessment of the reasonable time that allows a Client to consider the costs and risks of a financial product or service, free from pressure of the BSI sales team and/or its third-party agents and service providers. Financial Consumers shall be allowed to terminate, withdraw or return the product/service contract anytime within the cooling- off period immediately following the execution of any agreement or contract entered into for the availment of any such product or service covered by mandatory cooling-off period. Provided that such a policy includes a mandatory cooling-off period of a minimum of two (2) banking days for products and services that are marketed, offered or sold in retail to Financial Consumers who are: (1) individuals, regardless of income, or (2) Micro or Small Enterprises, as defined in applicable Department of Trade and Industry (DTl) regulations, and which possess any of the following characteristics: (a) Are consumer credit and retail banking products sold to or entered into by the above Financial Consumers for the first time, such as but not limited to credit cards; loans; pawning;trust products and other financial instru ments;

(b) Are marketed, offered or sold via remote means and/or subjected to high-pressure sales or marketing; (c) Are governed by contracts with a term or duration of more than one (l)year;or (d) Have other features that may be specified by the Bangko Sentral; Provided, further, That, in the case of bancassurance, the mandatory cooling-off period prescribed by the lnsurance Commission on the insurance product being sold, shall apply. In their cooling-off policy, BSls may specify products and services that have a cooling-off period of more than the minimum requirement of two (2) banking days, up to a maximum of 15 banking days, following the principle that the more complex and long-term the product or service is, the longer the cooling-off period should be. Products and services with any of the following features are exempt from the cooling-off period: 0) Products and services marketed, offered or sold to a BSI's corporate clients, and medium-sized enterprises, as defined in applicable DTI regulations; (2) Financial instruments with a remaining term of less than one (1) year; (3) Financial instruments with aggregate investment size of PSOO,OOO and above; (4) Securities "traded" or "to be traded";or (5) Short-term and one-off transactions, such as but not limited to foreign currency exchange, remittances, fund transfers, or payments a nd si m la r tra nsactiona I prod ucts/services. i In cases when a Financial Consumer withdraws or returns a product/service contract, the BSI must refund or return to the Financial Consumer the amounts paid or invested, including documents submitted, without undue delay and within a maximum period of fifteen (15) banking days after receipt of notice to withdraw or return. The BSI may charge and withhold from the refund due to the Financial Consumer, the fees or charges that are not greater than the actual or reasonable approximation of costs incurred by the BSl. Further, the BSI should provide the Financial Consumers with clear and comprehensible information at pre-contractual and contracting stages regarding the availability of cooling-off rights, the period within which these rights can be exercised, practical instructions on how they may be exercised, the amounts of charges or fees which may be required if exercising them, and the consequences of not exercising them. BSls must provide Financial Consumers with appropriate, easily accessible means or channels to communicate their exercise of cooling-off rights. Prepoyment of loons ond other credit ctccommodotions - BSls shall allow a borrower, at any time prior to the agreed maturity date, to prepay in whole or in part, the unpaid balances of a loan or other credit transactions; Provided, That costs or fees charged to the borrower for such pre-payment,

. if any, shall be disclosed in accordance with the Standard of Transparency and Disclosure, and responsible pricing principles, as required under this Section, and subject to such reasonable terms and conditions as may be agreed upon between the BSls and the borrower. Disclosure must be given before the contract is signed, at the time of contract signing, and during the life of the contract. BSls may charge reasonable administrative costs for the early payment of fixed and variable interest rate loans. Further, for fixed rate loans, BSls may separately charge costs to recover losses based on the difference between the annual percentage rate and the current market rate. For loans with variable interest rate, BSls are not permitted to charge foregone future interest. A BSI should be able to show how it calculated or determined the amount of prepayment charges, consistent with the relevant restrictions under this Framework. ' The BSI would need to take into account factors such as the amount being prepaid, the remaining term of the loan, the fixed interest rate (or rates, if multiple rates apply), and the current relevant market rates. roos^oos-Q ENFoRCEMENT AND ADM|N|STRAT|VE SANCTTONS Enforcement Consistent with Sec. OO2/OO2-Q of the MORB/VOpNgft, the " Bangko Sentral shall have the authority to impose enforcement actions on BSls for non- compliance with the FCP Framework, and other existing rules and regulations on FCP. ln addition to the enforcement actions under Sec. OO2/OO2-Q of the MORB/MORNBFI, the Bangko Sentral may also exercise the powers provided under Section 6(d) of the FCPA: a. Restriction on the ability of the BSI to continue to collect excessive or unreasonable interests, fees or charges, including other interests, fees and charges that are covered under Republic Act No. 1OB7O, otherwise known as the "Philippine Credit Card Industry Regulation Law;" b. Disgorgement.In any proceeding in which the Bangko Sentral may impose a penalty for non-compliance with or breach of the FCPA, its IRR and other existing laws, rules, regulations the Bangko Sentral may, in addition to imposing a fine, enter an order requiring accounting and disgorgement of . profits obtained, or losses avoided, as a result of a violation of the FCPA, its IRR and other existing laws, rules, and regulations under its jurisdiction, including reasonable interest. The Bangko Sentral shall adopt guidelines concerning the creation and operation of a disgorgement fund, payments to Financial Consumers, rate of interest, period of accrual, and such other matters as it deems appropriate to implement this provision.

Administrotive Sonctions. Without prejudice to the enforcement actions prescribed under FCPA Section 6 (d) and the criminal sanctions provided under FCPA .l5, Section the administrative sanctions under RA No. 7653, as amended, shall be made applicable to the BSl, its directors, trustees, officers, employees or agents for violation of the FCPA, its IRR and any related rules, regulations, orders or instructions of the Bangko Sentral. Provided, further, That in case profit is gained or loss is avoided as a result of the violation of the FCPA, a fine not more than three (3) times the profit gained or loss avoided may also be imposed by the Bangko Sentral; Provided, finolly, That in addition to the administrative sanctions that may be imposed, the authority of the BSI to operate in relation to a particular financial product or service may be suspended or cancelled by the Bangko Sentral. . No Waiver of Rights. No provision of a contract for a financial product or service shall be lawful or enforceable if such provision waives or otherwise deorives a Client of a legal right to sue the BSl, receive information, have their complaints addressed and resolved, or have their Client data protected. Such a waiver may cover agreements/contracts that limit the following:the BSI's liability for the acts or omissions of its directors, trustees or officers, employees or agents; obligations of the BSI; or the right of the Financial Consumer to exercise any rights under the FCPA, its IRR or any relevant laws, rules and regulations. Section 2. Applicability to other non-bank financial institutions (NBFls). The provisions under Section I of this Circular shall likewise apply to NSSLAs, pawnshops, credit card, trust corporations and other NBFIs with trust license, insofar as these are applicable to their operations. In this regard, the following amendments shall apply to specific MORNBFI set of reg ulations as follows: l. Part Seven of S-Regulations/Part Six of P-Regulations/Part Seven of N- Regulations shall adopt the new title of Part Ten of the Q-Regulations as provided in Section I of this Circular, and all Sections under its corresponding Part including the provisions therein shall all be deleted, and will be replaced with the following provision: The Financial Consumer Protection Framework of the Bangko Sentral as stated under Part Ten of the Q-Regulations shall be adopted insofar as these are a ppl ica ble to the N SS LAs's/pawnshops's/ru g f l's/cred it ca rd's operations. 2. The provisions under Section 1Ol-T of the T-Regulations, in particular the cross- reference to Part Ten of Q-regulations shall be amended to align with the new title of Part Ten of the Q-Regulations as stated in Section I of this Circular. 3. The title of Sec. l2l-CC of the CC-Regulations shall be amended to adopt the new title of Part Ten of the Q-Regulations as provided in Section I of this Circular, and the provision under the said Section is hereby amended in its entirety, and shall now read as follows:

The Financial Consumer Protection Framework of the Bangko Sentral as stated under Part Ten of the Q-Regulations shall be adopted insofar as these are applicable to the credit card's operations. Section 3. All references to deleted Sections of the MORNBFI as orovided in Section 2 of this Circular shall now refer to its new corresponding Part Ten of the MORNBFI. Moreover, all references to the old Part Ten of the MORB/MORNBFI (Q-Regulations) shall now refer to the new Part lO of the MORB/MORNBFI (Q-Regulations) as provided under Section 'l of this Circular. Section 4. The Bangko Sentral may revise and supplement these rules and regulations and issue related guidelines, circulars, and other issuances as it deems necessary for the effective implementation of the various provisions of the FCPA consistent with existing laws, rules and regulations. . Section 5. Reportorial Requirements. Specific guidelines on the required reports, including the mode and manner of submission, shall be covered by a separate memorandum issuance. Section 6. The following transitory provision shall be incorporated as footnote to Sec. loolnool-Q of the MoRB/MoRNBFt as follows: BSls shall be given six (6) months from the effectivity of this Circular to: (l) perform .a gap analysis of their current CPRMS, FCPAM and related financialconsumer protection practices vis-d-vis the provisions of this Circular; and (2) propose an action plan duly- approved by its Board of Directors to achieve full compliance within a reasonable period of time but not longer than one (1) year from the effectivity of this Circular. A BSI should be able to show its plan of action with specific timelines, as well as the status of initiatives being undertaken, to fully comply with the provisions of this Circular, upon request of the Bangko Sentral. Section 7. This Circular shall take effect fifteen (15) days after its publication in the Official Cazette or in a newspaper of general circulation. FOR THE MONETARY BOARD: It Lt- l< q,--' FELIPE M. MEDALLA Covernor d Nou"-ber2022