September 5, 2018
SEC-OGC OPINION NO. 17-18
RE: APPLICABILITY OF SEC MEMORANDUM CIRCULAR NO. 08-13 TO INVESTMENT HOUSES
Romulo Mabanta Buenaventura Sayoc & De Los Angeles
21st Floor, Philamlife Tower
8767 Paseo de Roxas
Makati City 1226, Philippines
Attention: Atty. Herminio S. Ozaeta, Jr.
Atty. Cristina Collantes-Garcia
Attorneys :
This refers to your letter dated 18 October 2013 requesting for an opinion on behalf of your client, UBS Investment Philippines (hereinafter referred to as "UBS Philippines"), on whether an investment house is covered under the SEC's Memorandum Circular No. 08-13 (hereinafter referred to as "MC No. 08-13") issued pursuant to the rulings on Gamboa v. Teves (Decision) 1 and Heirs of Gamboa v. Teves (Resolution) 2 and whether there is a need to revise or amend the current ownership structure of UBS Philippines in accordance with MC No. 08-13. aDSIHc
You stated that UBS Philippines is an investment house. It is currently structured, such that 100% of the preferred non-voting shares are held by UBS AG, a Swiss national. While 40% of the common voting shares of UBS Philippines are held by Filipino nationals and 60%...
