Title
Credit Card DOSRI Rules Amendments
Law
Bsp Circular No. 232
Decision Date
Mar 23, 2000
BSP Circular No. 232 allows banks and non-bank financial institutions to exempt credit card operations from DOSRI regulations for directors, officers, and stockholders, provided they fully reimburse the billed amount by the due date and that credit privileges are available to all qualified applicants.

Applicability of DOSRI Rules to Bank Credit Card Operations

  • Subsection X328.1 of the Manual of Regulations for Banks was amended.
  • Credit card transactions of banks are exempt from DOSRI regulations if:
    • Credit card privileges are equally open to all qualified applicants under uniform selective criteria.
    • Directors, officers, stockholders, or their related interests pay their billed credit card balances in full by the due date, consistent with other cardholders.
  • Transactions become subject to DOSRI rules if:
    • The credit cardholder who is a director, officer, or stockholder fails to pay in full by the due date.
    • The credit cardholder opts for a deferred payment plan from the outset and the transaction is recorded by the bank.

Applicability of DOSRI Rules to Non-Bank Financial Institutions' Credit Card Operations

  • Section 4328Q of the Manual was amended with the addition of Subsection 4328Q.1.
  • Credit card operations of authorized non-bank financial institutions are similarly exempt from DOSRI rules provided:
    • The privilege of holding a credit card is offered to all qualified applicants subject to the institution's selective criteria.
    • The director, officer, stockholder, or related interests pay the full billed amount by the due date as set for other cardholders.
  • Subject to DOSRI rules if:
    • Full payment is not made by the due date.
    • A deferred payment scheme is chosen and booking of the transaction by the institution occurs.

Procedures and Compliance

  • Banks and non-bank financial institutions must apply uniform criteria when granting credit cards to ensure fairness.
  • Payment terms and deadlines must be uniformly enforced for all credit card holders including DOSRI persons.

Legal Effect and Enforcement

  • These amendments clarify and regulate the extent to which DOSRI provisions govern credit card transactions involving insiders and related interests.
  • The Circular took effect immediately upon its issuance on 23 March 2000.

Important Legal Concepts

  • "DOSRI" denotes individuals occupying key roles or owning interests in the bank or financial institution plus related entities.
  • The exemptions hinge on full payment compliance and equitable treatment of insider credit card holders.
  • Deferred payment schemes involving insiders trigger automatic applicability of DOSRI regulations, ensuring stringent oversight.

Penalties and Consequences

  • Failure to comply with payment conditions causes credit card transactions to fall under DOSRI regulations, which entail increased scrutiny and regulatory requirements.
  • The Circular enforces transparency and accountability in credit card operations of financial institutions concerning insiders and related parties.

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