Title
Guidelines on SEC Legal Opinion Requests
Law
Sec Memorandum Circular No. 15, Series Of 2003
Decision Date
Dec 16, 2003
The SEC establishes guidelines for expediting legal opinion requests, emphasizing the need for specific legal questions, complete factual circumstances, and relevant documentation while outlining limitations on the types of issues it will address.

Law Summary

Requirement of Complete Factual Circumstances

  • Requesting party must present complete factual background.
  • The legal issues should depend on facts that are clearly discernible from the query.

Submission of Pertinent Documents

  • All necessary documents must be submitted to aid resolution of the query.
  • Examples include Articles of Incorporation, By-laws, General Information Sheets, applicable laws, and administrative rules.

Contact Information of Requesting Party

  • Accurate business address, telephone, facsimile numbers, and e-mail address must be indicated.

Matters on Which the Commission Will Refrain from Rendering Opinions

  • Issues previously decided by courts or currently pending in courts.
  • Matters involving substantive and contractual rights of private parties likely to contest adverse opinions.
  • Matters requiring contract review or opinions on contract validity.
  • Questions that are too general, hypothetical, abstract, speculative, anticipatory, or pertain to undisclosed entities.
  • Queries involving review of presidential issuances or official acts of the President.
  • Requests involving interpretation of administrative rules and issuances by other government agencies.
  • Requests requiring review of acts and rulings of other government agencies.
  • Queries necessitating determination of factual issues.
  • Matters involving business discretion or judgment properly within management competence.
  • Requests that involve gathering legal materials or writing abstract essays resembling private legal counsel.

Exception to Non-Compliance with Requirements

  • The Commission may process opinions despite non-compliance when circumstances warrant.

Nature and Limitations of the Legal Opinion Rendered

  • Opinions are based solely on the facts disclosed.
  • Opinions relate only to the specific issues raised.
  • Opinions are not standing rules binding on the Commission in other cases.

Responsible Authority

  • Chairperson of the Commission is responsible for the memorandum issuance.

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