Title
Revised BSP guidelines on currency risk protection
Law
Bsp Circular No. 470, S. 2005
Decision Date
Jan 17, 2005
The Bangko Sentral ng Pilipinas introduces revised guidelines for the Currency Rate Risk Protection Program, allowing banks to offer non-deliverable USD/PHP forward contracts to clients for hedging eligible foreign currency obligations without requiring a derivatives license.
A

Coverage and Eligible Obligations

  • Applicable to unhedged foreign currency obligations of at least US$50,000.
  • Only current and outstanding obligations qualify; past due obligations are excluded.
  • Unhedged means no existing hedge through forward contracts, options, or matched assets.
  • Partially hedged obligations evaluated case-by-case.
  • Eligible obligations include various BSP-registered FCDU loans, short-term trade-related borrowings, US dollar trust receipts, foreign currency import bills, and properly reported documents against acceptance or open account.
  • Some obligations incurred after December 31, 2003, are eligible upon case-by-case approval.

Terms and Conditions

  • Detailed terms are specified in the implementing guidelines (Annex 1).

CRPP Application Process

  • Applications must be fully completed; incomplete forms are rejected.

Reporting Requirements

  • Banks must submit daily reports on CRPP transactions to BSP-Supervision & Examination Department by 4:30 P.M. of the next banking day.
  • Reports require joint sworn certification by a senior executive and compliance officer.
  • Reports classified Category A-1 for penalties on delays/errors.

Pretermination of CRPP Contracts

  • Pretermination allowed under prescribed rules including settlement of net difference in pesos.

Sanctions

  • Illegal pretermination incurs monetary penalties.
  • Ineligibility found post-maturity results in daily monetary penalties of Php30,000 until contract maturity.

Repealing Clause

  • This Circular supersedes BSP Circulars Nos. 292 and 300 and inconsistent parts of other circulars.

Effectivity

  • Effective 15 calendar days post-publication in official publication.

Application Mechanics

  • Clients apply through banks certifying unhedged FX obligations under oath.
  • Banks coordinate with BSP-Treasury to quote CRPP rates during fixed time windows.
  • Deals must be reported to BSP-SED departments with evidence.
  • BSP confirms deals after verifying documentary requirements.

Documentary Requirements

  • Various certified true copies needed depending on obligation type, including loan registrations, promissory notes, certifications, import/export documents, and letters of undertaking especially for oil companies.
  • Specific documentation obligations tied to imports, credits, and financing structures.

Tenors

  • Contract periods range from 10 days up to 12 months, not exceeding maturity of the FX obligation.
  • Obligations exceeding 12 months may be hedged through successive contracts.

Pricing Methodology

  • Pricing formula based on spot rate adjusted by peso and USD interest rates for the tenor.
  • Spot rate reference varies depending on deal timing (morning/afternoon sessions).

Fixing Date and Settlement

  • Fixing rate agreed one business day before maturity using PDS weighted average spot rate.
  • Peso net settlement amount is calculated by applying the rate difference to the notional USD amount.
  • Settlement is executed through the bank's BSP demand deposit account on maturity.

Pretermination Procedures

  • Client pretermination requires proof of full or adequate FX obligation payment, excluding loan renewal as payment.
  • BSP-Treasury provides NDF reversal rate to determine net settlement on pretermination.
  • Penalties apply for false claims or misuse.
  • BSP may preterminate contracts upon finding ineligible obligations or early FX obligation payment without pretermination request, imposing penalties.

Matured Contracts and Refund Obligations

  • BSP payment on matured contracts later found ineligible must be refunded with interest calculated at BSP overnight lending rate until refund date.

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