Title
Amended Rules on Interlocking Directorships
Law
Bsp Circular No. 592
Decision Date
Dec 28, 2007
BSP Circular No. 592 establishes amended regulations governing interlocking directorships and officerships within banks, quasi-banks, and non-bank financial institutions to prevent excessive economic power concentration, conflicts of interest, and ensure effective governance while allowing for certain organizational synergies.
A

Definitions and Clarifications

  • Husband and wife are considered as one person for limitations on concurrent positions.
  • Secondment refers to the temporary assignment of an employee from one organization to another, with employment maintained by the original employer.
  • Officers include members of management committees or subcommittees performing functions typical of regular officers.

Interlocking Directorships

  • No concurrent directorships allowed between banks, or between a bank and a QB, except by Monetary Board authorization.
  • Concurrent directorships allowed without approval in cases involving:
    • Banks of different categories, provided not more than one has quasi-banking functions.
    • A bank and an NBFI.
    • A bank without quasi-banking functions and a QB.
    • A bank and its subsidiaries (banks, QBs, NBFIs).

Interlocking Directorships and Officerships

  • No concurrent directorships and officerships allowed between banks or between a bank and a QB or NBFI, except by Monetary Board approval.
  • Allowed without prior approval between a bank and its subsidiaries (banks, QBs, NBFIs) excluding investment houses.

Interlocking Officerships

  • Generally prohibited between banks or between a bank and a QB or NBFI, including secondments, due to risks of conflicts of interest and poor governance.
  • Exceptions allowed with Monetary Board approval, including:
    • Between a bank and up to two of its subsidiaries (excluding investment houses).
    • Between two banks or a bank and a QB/NBFI if at least 20% equity is owned by a holding company or related bank/QB for managerial or technical assistance.
    • Concurrent officerships in non-management positions (e.g., corporate secretary, internal auditor) allowed between a bank and subsidiaries or among related financial institutions with at least 20% shared equity ownership.

Conditions on Concurrent Officerships

  • Positions must not involve functional conflicts of interest.
  • Officers holding top executive roles (President, CEO, COO, CFO) cannot hold similar positions concurrently.
  • The officer, spouse, close relatives, or entities controlled by them must not own more than 20% of the subscribed capital stock of financially related institutions.
  • Full-time positions require adequate justification to the Monetary Board.

Corporate Governance and Oversight

  • The Corporate Governance Committee must conduct annual performance evaluations of the board and senior management.
  • When a director or officer holds multiple positions, the committee must assess capacity and performance and recommend necessary changes.

Application to Government Representatives

  • Provisions apply to government or government-owned entity representatives unless existing laws provide otherwise.

Implementation and Effectivity

  • Provisions incorporated into the Manual of Regulations for Non-Bank Financial Institutions (MORNBFI).
  • Effective fifteen calendar days after publication in the Official Gazette or widely circulated newspaper.
  • Adopted by the Monetary Board on December 28, 2007.

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