FORECLOSURE: LEGAL ASPECTS Ill. REMEDIES OF MORTGAGEE 1. Foreclosure of the mortgage or 2. Ordinary suit for collection _ —FORECLOSURE:LEGAL ASPECTS FORECLOSURE OF REAL ESTATE MORTGAGE: 1) EXTRAJUDICIAL FORECLOSURE -Act 3135 Where the right of redemption is for 12 months if the mortgagor regardless of whether the mortgagee is a juridical or a natural person. EXCEPTION © IF THE MORTGAGEE IS A BANK AND THE MORTGAGOR IS A CORPORATION, THE REDEMPTION PERIOD IS NINETY DAYS FROM DATE OF EXECUTION OF THE CERTIFICATE OF SALE OR ANNOTATION OF ‘COS WHICHEVER IS EARLIERPROCEDURE ON JUDICIAL FORECLOSURE OF REM > SECTION 63 PD 1529. » CERTIFIED COPY OF FINAL ORDER OF THE COURT TO BE PRESENTED SHALL BE FILED WITH THE REGISTER OF DEEDS CONFIRMING THE SALE . » REDEMPTION-1 YEAR FROM REGISTRATION EEGBL 2000 LOANS >» FORECLOSURE OF REM ( SECTION 47-GBL ) > IF CORPORATE BORROWER - REDEMPTION ALLOWED UNTIL BUT NOT AFTER THE REGISTRATION OF THE COS WITH REGISTER OF DEEDS AND SHALL NOT BE MORE THAN 3 MONTHS AFTER FORECLOSURE WHICHEVER IS EARLIER. > IF MORTGAGOR IS NATURAL PERSON , REDEMPTION RIGHT IS NOT LESS THAN 12 MONTHS FROM DATE OF REGISTRATION OF cos. PECONSEQUENCE OF FORECLOSURE OF REM FOR SALE |FORECLOSURE OF MORTGAGE PROCESSWOP AFTER EFREM » WOP-AFTER CONSOLIDATION OF THE TITLE IN MORTGAGEE’S NAME IS A MATTER OF RIGHT. EX-PARTE . >» CAN AN ANNULMENT OF FORECLOSURE BE FILED SIMULTANEOUSLY WITH THE WOP? YES » CAN A PETITION FOR WOP BE RESTRAINED OR ENJOINED BY THE TRIAL COURT? NO. SUMMARY HEARING. MANDATORY FOR COURT TO ISSUE. » OCA CIRCULAR 19-2021 - SUSPENSION OF HEARINGS BECAUSE THIS IS NOT INITIATORYREPOSSESSIONS BY BANK’S WOPDO YOU WANT TO BORROW OR LEND? “NEITHER A BORROWER NOR A LENDER BE.” - WILLIAM SHAKESPEAREThe Truth in Lending Law= DEC 5, 2021 >» 1.NATURE OF THE LAW >» 2. ELEMENTS OF THE LAW > 3. CASE LAW |The Truth in Lending Act of the Philippines >» TRUTH IN LENDING - RA 3765 » An act requiring the disclosure of finance charges in connection with the extension of credit. » Policy of the Law - to protect the people from lack of awareness of the true cost of credit by assuring 1) full disclosure of such cost,: 2) to prevent the uninformed use of credit to the detriment of the national economy. |TRUTH IN LENDING LAW » Covered Persons : ANY CREDITOR » DEFINE CREDITOR : ANY PERSON ENGAGED IN THE BUSINESS OF EXTENDING CREDIT EITHER AS A LENDER OR A SELLER ON INSTALLMENTS DEFINE CREDIT- 1) LOAN, 2) MORTGAGE, 3)DEED OF TRUST, 4)CONDITIONAL SALES CONTRACT, 5)CONTRACT TO SELL INVOLVING DELIVERY OF PROPERTY OR MONEY, 6) ANY PURCHASE OR UISITIONN OF OR CREDIT UPON NY OBLIGATION OF CLAIM ION WITH SIMILARTRUTH IN LENDING LAW OBJECT OF THE Law. CADICTOFINCHARP CREDITOR MJUST FURNISH PRIOR TO CONSUMMATION OF TRANSACTION THE FF ITEMS: A) CASH PRICE OF DELIVERED PROPERTY OR SERVICE; B) AMOUNTS TO BE CREDITED AS DOWN PAYMENT OR TRADE-IN; C)DIFFERENCE B/WEEN A & B); D) CHARGES TO BE PAID NOT INCIDENT TO THE CREDIT ; E) TOTAL AMOUNT TO BE FINANCED ; F) FINANCE CHARGE IN ABSOLUTE PESO AMOUNTS ;G) PERCENTAGE OF FINANCE VERSUS TOTAL AMOUNT TO BE FINANCED IN ANNUAL RATE ON THE O/S UNPAID BALANCE |TRUTH IN LENDING LAW » AGENCY TO IMPLEMENT: BSP MB » EFFECTS ON PN FOR VIOLATION ( SEC. 6 ) - 1. NO EFFECT ON THE VALIDITY OR ENFORCEABILITY OF THE OBLIGATION BUT THE UNDISCLOSED CHARGES OR OTHER CREDIT TERMS WILL BE SUBJECT TO COURT ACTION IF DELETION OR REDUCTION PER CASE LAW. 2. CREDITOR SUFFERS FROM PERSONAL LIABILITIESTRUTH IN LENDING IRR » PENALTIES = » PESOS 100 OR DOUBLE THE AMOUNT OF FINANCE CHARGE WHICHEVER IS HIGHER; » FINE UP TO 2000 PESOS ; > IMPRISONMENT OF MINIMUM 6 MONTHS TO MAXIMUM OF 1 YEAR PaIMPLEMENTING RULES » BSP CIRCULAR 755 ISSUED ON 1 JULY 2012 » REITERATES THE POLICY OF RA 3765; » GOAL : TO ENSURE TRANSPARENT PRICING NOT TO SET LIMITS ON RATES BUT TO MAKE THESE RATES KNOWN AND UNDERSTOOD BY CLIENTS EXPANDS GOVT’ AGENCIES TO IMPLEMENT — SEC - LENDING COMPANIES AND FINANCING INSTITUTIONS ; |TRUTH IN LENDING IRR » -INSURANCE COMPANIES - GRANTS LOANS SECURED BY INSURANCE POLICIES; » COOPERATIVE DEVELOPMENT AUTHORITY— FOR THOSE MULTI-PURPOSE COOPERATIVES GRANTING LOANS AND CREDIT LIKE SAVINGS AND LOAN ASSOCIATIONS » WHY: TO PROMOTE HEALTHY COMPETITION AMONG CREDIT PROVIDERS FOR CLIENTS TO COMPARE PRODUCTS AND SERVICES eeTRUTH IN LENDING IRR » -INSURANCE COMPANIES — GRANTS LOANS SECURED BY INSURANCE POLICIES; » COOPERATIVE DEVELOPMENT AUTHORITY— FOR THOSE MULTI-PURPOSE COOPERATIVES GRANTING LOANS AND CREDIT LIKE SAVINGS AND LOAN ASSOCIATIONS » WHY: TO PROMOTE HEALTHY COMPETITION AMONG CREDIT PROVIDERS FOR CLIENTS TO COMPARE PRODUCTS AND SERVICES PeTRUTH IN LENDING ACT » HELD: THE INTEREST RATES ARE VOID FOR BEING VIOLATIVE OF THE TRUTH IN LENDING ACT; AFFIRMED THE DECISION OF RTC AND COURT OF APPEALS IN FAVOR OF SPOUSES BELUSO BUT THE SC RULED THAT THE EFREM WAS VALID AS THE VIOLATION OF THE TRUTH IN LENDING LAW WAS NOT A GROUND FOR ANNULMENT OF EFREM. BELUSO WAS ORDERED TO PAY UCPB ON A REDUCED AMOUNT. |C DECISIONS INTERPRETING TRUTH IN LENDING ACT >» 1. DBP VS. ARCILLA , JR. 462 SCRA 599 (2005) » — non Disclosure of the terms of credit prior to the consummation of the loan availment or drawdown, creditor will have no right to collect interest and charges even if stated in the Promissory Note ( PN) . >» QUERY © WHAT IS THE EFFECT ON THE CONTRACT? RECISSIBLE OR STILL VALID? | —SC DECISIONS INTERPRETING TRUTH IN LENDING ACT » 2, CONSOLIDATED BANK AND TRUST CO. VS COURT OF APPEALS, 246 SCRA 193 (1995 ) > BANK DID NOT INDICATE IN THE BORROWER’S PROMISSORY NOTE HANDLING CHARGES OR FEES. BANK REQUIRES THE COLLECTION OF HANDLING FEES PER BSP CIR 504 FOR BANKS WITH LOANS MORE THAN 500,000 PESOS. » RULING OF THE SC : IS BORROWER LIABLE ? PeSC DECISIONS INTERPRETING TRUTH IN LENDING ACT » 2. CONSOLIDATED BANK AND TRUST CO. VS COURT OF APPEALS, 246 SCRA 193 (1995 ) » BANK DID NOT INDICATE IN THE BORROWER’S PROMISSORY NOTE HANDLING CHARGES OR FEES. BANK REQUIRES THE COLLECTION OF HANDLING FEES PER BSP CIR 504 FOR BANKS WITH LOANS MORE THAN 500,000 PESOS. » RULING OF THE SC : IS BORROWER LIABLE ? |C DECISIONS INTERPRETING TRUTH IN LENDING ACT >» 1. DBP VS. ARCILLA , JR. 462 SCRA 599 (2005) » — non- Disclosure of the terms of credit prior to the consummation of the loan availment or drawdown, creditor will have no right to collect interest and charges even if stated in the Promissory Note ( PN) . » QUERY : WHAT IS THE EFFECT ON THE CONTRACT? RECISSIBLE OR STILL VALID? |SC DECISIONS INTERPRETING TRUTH IN LENDING ACT > 3.NEW SAMPAGUITA BUILDERS VS PNB , GR. NO.148753 JULY 30, 2004 >» BORROWER’S CLAIM LOAN IS BLOATED BECAUSE BANK COLLECTED EXCESSIVE INTEREST RATES AND PENALTY FEES NOT DISCLOSED IN VIOLATION OF RA 3765 » PNB CONTENDS INCREASED RATES ARE IN ACCORDANCE WITH THE CREDIT AGREEMENT, PN’S AND DISCLOSURE STATEMENT |SAMPAGUITA BUILDERS VS PNB > RULING OF SC > WHILE THE ESCALATION CLAUSE IS PROVIDED FOR IN THE CREDIT AGREEMENTS BUT DOES NOT GIVE TO THE BANK CARTA BLANCHE POWER TO INCREASE THE RATES WITHOUT CLIENT’S CONSENT ESPECIALLY IF THE RATES ARE UNREASONABLE TO ENSLAVE CLIENT; » WHAT ABOUT THE DISCLOSURE STATEMENTS ON GIVING THE POWER TO THEBANK TO CHARGE INCREASED RATES? aTRUTH IN LENDING ACT » UCPB VS SPS BELUSO , GR 159912, AUG 17, 2007 » UCPB GRANTED LOANS TO SPS BELUSO FOR 1.2. MILLION WHICH WERE RENEWED SEVERAL TIMES UNDER 4 PROMISSORY NOTES AMOUNTING TO THE TOTAL OF PHP 2 MILLION AS PRINCIPAL WITH INTEREST RATE RANGING FROM 18-34 % p.a. in 1997-98, » When the loans were not paid, penalty rates of 32 % p.a. were also imposed which by 2000, the total amount unpaid ballooned to Php 3.8 Million. Borrower had already paid Php 795, 000. PESPOUSES SILOS VS PNB > QUESTIONS - + DID THE SC VOID THE REM AND THE PNS? » WHAT HAPPENED TO THE FORECLOSURE OF MORTGAGE? » WHAT WAS THE RULING OF THE SC INSOFAR AS THE LOAN OBLIGATION OF SILOS? » IS PNB ALLOWED TO CONSOLIDATE ITS OWNERSHIP OVER THE PROPERTY? PeTRUTH IN LENDING ACT » HELD: THE INTEREST RATES ARE VOID FOR BEING VIOLATIVE OF THE TRUTH IN LENDING ACT; AFFIRMED THE DECISION OF RTC AND COURT OF APPEALS IN FAVOR OF SPOUSES BELUSO BUT THE SC RULED THAT THE EFREM WAS VALID AS THE VIOLATION OF THE TRUTH IN LENDING LAW WAS NOT A GROUND FOR ANNULMENT OF EFREM. BELUSO WAS ORDERED TO PAY UCPB ON A REDUCED AMOUNT. PeSC DECISION INTERPRETING TRUTH IN LENDING ACT » 4. BPLVS NORMAN YU AND TUASON BUILDERS :GR NO.184122, JANUARY 20 , 2010 » ISSUE IS SUMMARY JUDGMENT FILED BY BORROWER CLAIMING THE FORECLOSURE OF REM VIOLATES THE TRUTH IN LENDING ACT FOR FAILURE TO INDICATE THE RATE OF PENALTY CHARGES IN THE DISCLOSURE STATEMENT » INVOKES SAMPAGUITA BUILDERS CASE RULING WHERE THE LOAN BALANCE WAS ORDERED RECOMPUTED PRIOR TO EFREMBPI VS. NORMAN YU ET AL » RULING OF THE SC : SUMMARY JUDGMENT PROPER. » THE ADMISSION OF BPI THAT THE RATE OF PENALTY CHARGES OF 36 % AND ATTORNEYS FEES OF 25 % ARE NOT STATED IN THE LOAN DISCLOSURE STATEMENT BUT IN THE PN AND REM. * ISSUE :RATE IN PN VERSUS NO RATE IN DISCLOSURE STATEMENT. . |SC DECISION INTERPRETING TRUTH IN LENDING ACT » 6. SPOUSES EDUARDO SILOS VS PNB , GR NO. 181045,JULY2, 2014 (J.DEL CASTILLO ) » REITERATED RULING IN SAMPAGUITA BUILDERS’ CASE, » REITERATED RULING IN UCPB VS. BELUSO , 530 SCRA 567 (2007). APN WHICH GRANTS UNILATERAL RIGHT TO THE CREDITOR TO FIX INTEREST RATE IS ILLEGAL NOT BECAUSE IT VIOLATES CIVIL CODE ON MUTUALITY OF CONTRACT BUT ALSO BECAUSE IT VIOLATES THE TRUTH IN LENDING LAW. |SPOUSES SILOS VS PNB » QUESTIONS - » DID THE SC VOID THE REM AND THE PNS? » WHAT HAPPENED TO THE FORECLOSURE OF MORTGAGE? > WHAT WAS THE RULING OF THE SC INSOFAR AS THE LOAN OBLIGATION OF SILOS? » IS PNB ALLOWED TO CONSOLIDATE ITS OWNERSHIP OVER THE PROPERTY? |JESINOWSKI VS BANK OF AMERICA (US SUPREME COURT , JULY 2015) » THIS IS RECENT CASE DECIDED BY US SUPREME COURT ALLOWING THE BORROWER TO RESCIND THE LOAN IF THE CREDITOR FAILED TO DISCLOSE THE TERMS OF THE LOAN IN VIOLATION OF THE US TRUTH IN LENDING LAW. Congress passed the Truth in Lending Act, 82 Stat. 146,as amended, to help consumers “avoid the uninformed use of credit, and to protect the consumer against inaccurate and unfair credit billing.” U.S. C. §1601(a). §1635(a) (2006 ed.).JESINOWSKI VS BANK OF AMERICA » To this end, the Act grants borrowers the right to rescind a loan “until midnight of the third business day following the consummation of the transaction or the delivery of the [disclosures required by the Act], whichever is later, by notifying the creditor, in accordance with regulations of the [Federal Reserve] Board, of his intention to do 50."§1635(a) (2006 ed.). |JESINOWSI VS BANK OF AMERICA >This regime grants borrowers an unconditional right to rescind for three days, after which they may rescind only if the lender failed to satisfy the Act’s disclosure requirements. Pe =JESINOWSKI VS BANK OF AMERICA > But this conditional right to rescind does not last forever. Even if a lender sever makes the required disclosures, the “right of rescission shall expire three years after the date of consummation of the transaction or upon the sale of the property, whichever comes first.” NOTA BENE: COMPARE THIS RULING TO THE UCPB VS BELUSO CASE. ( 2007 ) | —JESINOWSKI VS BANK OF AMERICA > But this conditional right to rescind does not last forever. Even if a lender sever makes the required disclosures, the ‘right of rescission shall expire three years after the date of consummation of the transaction or upon the sale of the property, whichever comes first.” NOTA BENE: COMPARE THIS RULING TO THE UCPB VS BELUSO CASE. ( 2007 ) EECASE LAWS ON TRUTH IN LENDING » The Consolidated Bank and Trust Corporation v. Court of Appeals, G.R. No. 91494, 14 July 1995, (246 SCRA 19 ' » Development Bank of the phulppinies v. Arcilla, Ir., G.R. No. 161397, 30 June 2005 (462 SCRA 509) , » United Coconut Planters Bank v. Beluso G.R. No. 159912, 17 August 2007, (530 SCRA 567) , » Spouses Silos v. Philippine National Bank, G.R. No. 181045, 02 July 2014, (728 SCRA 617) |COLLECTION LAWS FOR BANKS a} CIVIL CODE ON LOANS AND MORTGAGES b) ACT 3135 EXTRA JUDICIAL FORECLOSURE OF MORTGAGE ACT ACT 3815 — REVISED PENAL CODE ON ESTAFA FOR NON PAYMENT OF LOANS ETC SECTION 78 GEN BANKING LAWS ON REDEMPTION ACT REAL ESTATE MORTGAGE LAW e) RA 11057- PERSONAL PROPERTY ACT ( 2017). LE * *“NEITHER A BORROWER NOR A LENDER BE.” - WILLIAM SHAKESPEAREGBL 2000-OPERATIONS » RIGHT OF EMPLOYEES » BANK EMPLOYEES MAY STRIKE OR LOCK-OUT BUT IF UNSETTLED AFTER 7 CALENDAR DAYS , THE BSP SHALL REPORT TO THE SECRETARY OF LABOR WHO WILL ASSUME JURISDICTION OR DISMISS OR REFER TO NLRC FOR COMPULSORY ARBITRATION » PRESIDENT OF THE PHILIPPINES CAN INTERVENE AT ANY TIME AND ASSUME JURISDICTION TO SETTLE OR TERMINATE THE DISPUTE aGBL 2000-OPERATIONS » BANK PREMISES » BANKING HOURS AND DAYS: OPEN ON WORKING DAYS FOR AT LEAST 6 HOURS ; » IFSATURDAYS OR SUNDAYS -ONLY FOR 3 HOURS PER DAY, » IF ON ANY DAY OTHER THAN WORKINGDAYS , MUST REPORT TO BSP ADDITIONAL DAYS THAT WILL BE OPEN » WORKING DAYS MEAN MONDAY TO FRIDAY EXCEPT IF SUCH DAY IS A HOLIDAYGBL 2000-OPERATIONS » BANK PREMISES >» BANKING HOURS AND DAYS: OPEN ON WORKING DAYS FOR AT LEAST 6 HOURS ; > IFSFATURDAYS OR SUNDAYS -ONLY FOR 3 HOURS PER DAY; > IF ON ANY DAY OTHER THAN WORKINGDAYS ; MUST REPORT TO BSP ADDITIONAL DAYS THAT WILL BE OPEN >» WORKING DAYS MEAN MONDAY TO FRIDAY EXCEPT IF SUCH DAY IS A HOLIDAYGBL 2000-OPERATIONS >» BANK PREMISES » BANKING HOURS AND DAYS: OPEN ON WORKING DAYS FOR AT LEAST © HOURS ; » IFSATURDAYS OR SUNDAYS -ONLY FOR 3 HOURS PER DAY, » IF ON ANY DAY OTHER THAN WORKINGDAYS , MUST REPORT TO BSP ADDITIONAL DAYS THAT WILL BE OPEN » WORKING DAYS MEAN MONDAY TO FRIDAY EXCEPT IF SUCH DAY IS A HOLIDAYBANKING DEPOSITS LAWS » DEPOSIT TAKING ACTIVITIES OF BANKS UNDER GEN BANKING LAW >» PDIC JUNE 2016 >» ANTI MONEY LAUNDERING ACT OF 2001 » REMEDIES AGAINST BANKS » RIGHTS OF BANKS PeNOV 26- DEPOSIT TRANSACTIONS » WHAT ARE DEPOSITS >» WHAT ARE DEPOSIT SUBSTITUTES » WHAT ARE TRUST ACCOUNTS » CASE LAWS |GBL 2000 DEPOSIT FUNCTIONS >» KINDS OF DEPOSITS : » DEMAND -LIABILITIES OF BSP AND BANKS FOR FUNDS DEPOSITED BY CLIENTS DENOMINATED IN PHIL CURRENCY AND SUBJECT OF WITHDRAWAL UPON PRESENTATION OF DEPOSITOR’S CHECK >» SEE PHIL BANK OF COMMERCE VS CA, GR NO 97626 , MARCH 14, 1997 - MANNER OF MAKING AND WITHDRAWING DEPOSIT |GBL 2000 DEPOSIT » TEMPORARY OVERDRAWINGS OF CHECKS DRAWN AGAINST UNCOLLECTED DEPOSITS (DAUD ) -NOT ALLOWED EXCEPT IF DRAWINGS ARE MADE AGAINST UNCOLLECTED CHECK ISSUED TO THE DEPOSITOR LIKE MC’S , ON US CHECKS , TREASURY CHECKS , CASHIER CHECKS OR POSTAL MONEY ORDER STILL FOR CLEARING | —GBL 2000 DEPOSIT » TEMPORARY OVERDRAWINGS OF CHECKS DRAWN AGAINST UNCOLLECTED DEPOSITS (DAUD ) -NOT ALLOWED EXCEPT IF DRAWINGS ARE MADE AGAINST UNCOLLECTED CHECK ISSUED TO THE DEPOSITOR LIKE MC’S , ON US CHECKS , TREASURY CHECKS , CASHIER CHECKS OR POSTAL MONEY ORDER STILL FOR CLEARING ——GBL 2000 DEPOSITS » DUTIES OF BANKS » TO HONOR THE CHECKS AND PAY IF THE ACCOUNT IS FUNDED, » TO KNOW THE SIGNATURE OF THE DRAWER OF THE CHECK -SEE San CARLOS MILLING VS BPI, 59 PHIL DEC 11 , 1933 » NO DUTY TOMAKE PARTIAL PAYMENT ON THE CHECK IF ACCOUNT IS PARTIALLY FUNDED PEGBL 2000 DEPOSITS » DUTIES OF BANKS : > TO HONOR, THE CHECKS AND PAY IF THE ACCOUNT |S FUNDED; » TO KNOW THE SIGNATURE OF THE DRAWER OF THE CHECK -SEE San CARLOS MILLING VS BPI, 59 PHIL DEC 11, 1933 » NO DUTY TOMAKE PARTIAL PAYMENT ON THE CHECK IF ACCOUNT IS PARTIALLY FUNDEDGBL 2000 DEPOSIT » NO DUTY TO MAKE UP DEFICIENCY FROM OTHER ACCOUNTS - SEE MORAN VS CA, GR NO. 195836, March 7, 1994 » CROSS CHECK MEANS THAT THECHECK NEEDS TO BE DEPOSITED BUTMAY BE NEGOTIATED ONLY ONCE TO THE ONE WHO HAS AN ACCOUNT IN THE BANK AND A WARNINGTHAT THECHECK ISFOR AN INTENDED PURPOSE ( SEE STATE INVESTMENT VS IAC, GR NO. 72764 JULY 13,1989 aGBL 2000 DEPOSIT » RIGHT OF SET-OFF - RIGHT OF THE BANK TO DEBIT PERSONAL ACCOUNT OF THE DEPOSITOR FOR THE AMOUNT CREDITED TO THE OTHER ACCOUNTOF THE DEPOSITOR SOLELY . SEE BPI VS CA,GR NO. 136202, JANY 25,2007. » LEGAL RELATIONSHIP OF PAYEE OF CHECK AND ACCEPTING BANK FOR COLLECTION : PRINCIPAL - AGENT WHERE THE BANK ACTS AS AGENT TO COLLECT THE PROCEEDS OF THE CHECK b |GBL 2000 DEPOSIT » RIGHT OF SET—-OFF — RIGHT OF THE BANK TO DEBIT PERSONAL ACCOUNT OF THE DEPOSITOR FOR THE AMOUNT CREDITED TO THE OTHER ACCOUNTOF THE DEPOSITOR SOLELY . SEE BPI VS CA, GR NO. 136202, JANY 25,2007. » LEGAL RELATIONSHIP OF PAYEE OF CHECK AND ACCEPTING BANK FOR COLLECTION : PRINCIPAL - AGENT WHERE THE BANK ACTS AS AGENT TO COLLECT THE PROCEEDS OF THE CHECK b aBANK EXAMINATION BY BSP » TO ENFORCE PROMPT CORRECTIVE ACTION. » PROVIDES DEFINITION OF QUASI-BANKS: —-REFERS TO ENTITIES ENGAGED IN BORROWING OF FUNDS , ENDORSEMENT OR ASSIGNMENT THRU ISSUANCE OF DEPOSIT. SUBSTITUTES AS DEFINED IN SECTION 95 OF RA 7653. (PN’S , PARTICIPATIONS , CERTIFICATES OF ASSIGNMENT WITH OR WITHOUT RECOURSE ETC ) | :BANK EXAMINATION BY BSP » TO ENFORCE PROMPT CORRECTIVE ACTION. » PROVIDES DEFINITION OF QUASI-BANKS: —-REFERS TO ENTITIES ENGAGED IN BORROWING OF FUNDS , ENDORSEMENT OR ASSIGNMENT THRU ISSUANCE OF DEPOSIT SUBSTITUTES AS DEFINED IN SECTION 95 OF RA 7653. (PN’S , PARTICIPATIONS , CERTIFICATES OF ASSIGNMENT WITH OR WITHOUT RECOURSE ETC ) 10 vaisi2021 5