Wednesday, September 28, 2016


A Bulacan cooperative claimed it experienced "mass withdrawals", "mass resignation"  and non-payment of members' loan obligations following the holding of its General Assembly (GA) last April 2016.

This was contained in letters signed by all members of the cooperative's Board of Directors (BoD), sent to a number of members, who were asked to explain why they should not be expelled from the cooperative for alleged actions during the GA which were reported to have contributed to the above claims of the BoD.

"The following days after the General Assembly, there were mass resignations, mass withdrawals and non-payment of members' loan obligations that left the finances of the ______
 (name of cooperative) negatively affected," the Bod in the letters said.

Some of the members who were sent letters were charged by the BoD, among other things, with "indecent and provocative display of conduct that was carried out during the General Assembly.." (sic).

Seeking an audience with the cooperative officers to verify if there were indeed records of "mass withdrawals", "mass resignations", or non-payment of loan obligations beyond the normal levels as alleged, a group of members sent such show-cause letters, said  that they failed to be granted such audience requested.

Some  co-op members also questioned before the Cooperative Development Authority the propriety of the election of officers during the 2016 GA of the cooperative, which used new election rules formulated prior to the said GA.   Others  claimed these should be implemented only during the GA in 2017 after the 2016 GA has been consulted and had passed upon said rules.

The cooperative had been electing eleven members of its BoD at least for the last decade, until the new set of officers reduced the number to seven by virtue of a board resolution. Many members argue that this should have been done instead through the amendment of the cooperative's Articles of Cooperation and By-laws.

The seven members of the current BoD, are composed of four who were elected, and three which were appointed, according to reports.  (END).

Tuesday, September 27, 2016


Circular No. 2016-03 Series of 2016
Pursuant to Republic Act ("R.A.") No. 9510 entitled: An Act Establishing the Credit Information System and for Other Purposes otherwise known as the Credit Information System Act, and its Implementing Rules and Regulations ("IRR"), this Circular is hereby issued to serve as an amendment to the deadline for the production submission of credit data set in CIC Circular No. 2015-02.
SECTION 1. Scope
Rule 4.1 of the IRR of R.A. No. 9510 authorizes the Credit Information Corporation ("CIC") to collect current, objective, factual, and basic credit data, both positive and negative, on all their data subjects. It also authorizes the CIC to allow a phasing in, thus, this Circular shall cover entities to submit all credit data in their possession for the last five (5) years prior to the effectivity of this Circular.'
1.6 Government-owned and-controlled corporations engaged in lending activities
SECTION 2. Discussion
Under CIC Circular No. 2015-02, the deadline for production submission of current credit data for GOCCs engaged in lending was originally set at 30 September 2016. Due to reasons inherent in the transition of administration in the Philippine Government, the original deadline is hereby amended. With the transition comes the change in leadership in the various GOCCs which entails the transfer of mandate carefully brought about in order to ensure that government services are not hampered; the CIC is knowledgeably aware of such careful change and thus it gives a wider latitude with regard to the compliance with the submission of basic credit data.

Circular No. 2016-03 Series of 2016 Page 1

The change in leadership of the various GOCCs is accompanied by a change in the composition of their respective board of directors / trustees. In order to develop a good working relationship, members of the various boards must be acquainted with each other through their corresponding board meetings. As one of the technical requirements in the submission of basic credit data, the Secretary's Certificate may only be accomplished as evidence of the resolution reached by the board pertaining to the authorized persons with whom the CIC will be exclusively dealing with.
SECTION 3. Updated Deadline for Production Submission
Updated Deadline for Production Submission
Also, please be guided of the following steps leading to the submission of data to the CIC:
1. Registration - this is the stage when the CIC requires the GOCC to submit their Submitting Entity Information Sheet (SEIS). They should send an e-mail to: so the CIC can send them the necessary documents and requirements.
This is also the stage where the GOCC defines who are the responsible individuals who will be dealing with the CIC on a regular basis. CIC will then create the account of the operators listed in their accomplished SEIS. The username/ s and password/ s will be sent through email so that they can start submitting test data.
2. Testing - For the Testing Phase, this is the stage when the GOCC can submit sample or dummy data. This will assure the CIC that the GOCC is aware of the correct file format necessary to complete a transaction with the CIC and they can connect to the CIC. In this phase, the GOCC may submit dummy data or a snapshot of their production data.
Results of their submission are automatically forwarded to the GOCCs so that they are aware of any errors in their submission and can correct the same.

Circular No. 2016-03 Series of 2016 Page 2

3. Validation - After successfully passing the Testing Phase, the GOCC' s sample data will be loaded to the system. Please note that the GOCCs need to have three successful loading to ensure that the data mapping activity that they performed is in compliance with the prescribed Data Format of the CIC.
The GOCCs will then be provided a web access where they will have to search for the data subject that they submitted. They need to generate sample Credit Reports and validate that the data appearing therein is correct.
The Primary Contact Person listed in the SEIS shall forward to the CIC the validated sample Credit Reports and attest to the correctness of the data. The CIC in return shall acknowledge the validated Credit Reports.
This will be the last activity to make the GOCC become eligible for Production. Note that the Production Phase can only be reached after the Testing Phase is completed and authorization from the CIC is received.
4. Production Phase - This is the phase wherein the GOCC will have to submit actual live data. Also, the Error Report that the GOCC receives from the CIC will be actual errors found in their live data submission and should be used to guide them in understanding any deficiencies their reports may have.
The GOCCs must submit all the available fields in their records/ system especially for the subject details to have a higher rate of matching. If they do not have the required IDs i.e. TIN or SSS or GSIS, they should not use any dummy or default value for the ID Number. Instead, they must provide all the IDs reflected in their system. Although the records with no TIN or SSS or GSIS Number will not be loaded but this will help the CIC understand the condition of the records in all the financial institutions.

Circular No. 2016-03 Series of 2016 Page 3

SECTION 4. Sanctions
Non-submission of reports, and/ or delayed submission of reports as well as submission of erroneous data shall subject the entity to sanctions, as hereinafter promulgated by the CIC.
SECTION 5. Repealing Clause
All issuances, orders, rules and regulations or parts thereof that are inconsistent with the provisions of this Circular are hereby repealed, amended or modified accordingly.
SECTION 6. Separability Clause
Should any provisron of this Circular be declared invalid or unconstitutional, the other provisions not affected thereby shall remain valid and subsisting.
SECTION 7. Effectivity
This Circular shall be effective fifteen (15) calendar days after the date of its publication either in the Official Gazette or in a newspaper of general circulation in the Philippines and upon filing with the University of the Philippines Law Center of three (3) certified copies.
For your information and due compliance.


Circular No. 2016-03 Series of 2016 Page 4

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Saturday, September 24, 2016


    This embattled cooperative in Region III has started expulsion proceedings against a number of its notable members.

    And for what reasons?  For, among others things, speaking their minds, and for commenting on the official actions of the cooperative's officers during the year in review, during its General Assembly (G.A.), last April 2016.

    How can I say that?  I have seen copies of these expulsion letters.  They all begin with the following preface/introduction (as in the first paragraphs), or variations thereof, to wit:

    "During the (cooperative's name)'s __th General Assembly, you were seen and heard in an unedited video, as saying.., etc.."

    And what is are the "violations" cited in the pro-forma allegations in said expulsion letters?  Here is one:  

    "..Due to your damaging actions against the cooperative, the next days after the _th General Assembly, there were mass withdrawals; mass resignations; and non-payment of loan obligations..."

    (Yes, I was told that in the anticipation of the negative comments expected from concerned members, the cooperative hired a videographer to capture the whole G.A. proceedings.  Sneaky, is it not?)  In fairness to its members, the cooperative should have warned the G.A. participants that they are being videographed/taped, and that anything they say may be used against them later on.  

    CDA Region III or Main should have a copy of this video, to verify the reported irregularities committed by the cooperative management during the said G.A., against the complaints filed by the cooperative members being expelled. Right?)

    I ask myself, was there a bank run after the G.A.?  How much must constitute "mass withdrawal", of savings deposits?  Aren't these deposits withdrawable anytime upon demand, no questions or reasons asked.  How many must request to voluntary terminate their membership with the cooperative, to be called a "mass resignation"?  The cooperative did not mention the exact figures.

    If these were not pigments of the imagination, or of hasty generalization by the members of the cooperative's Board of Directors (BoD, yes the expulsion letters were purportedly signed by them) they should present the members being charged, of the copies of letters of voluntary membership withdrawals (these are required to be in the written form, citing the reason thereof).  Let's see what caused the membership withdrawals.

    These officers, who signed the expulsion letters,  must also present the accused member of the cooperative's Cash Flow Statement for the period alleged, for the reported mass withdrawals of deposits.  You must prove your allegations, right?

    As to the reported non-payment of loan obligations, I was told, that prior to the General Assembly, the cooperative's delinquency rate (PAR) is above 50% of all assets (loan receivables).  I do not believe it to be that worse, but the cooperative must show the proof to the contrary.  

    These are part of the cooperative's official records that should be accessible to members.  This high delinquency rate, reportedly is "normal" among many cooperatives not only in Region III, but nationwide.  If that were so, and the cooperative's annual reports should bear this out, no more harm could be done there, I suppose.

    By way of context, records with CDA Region III and Main Office, show that this cooperative is subject of a number of complaints from members relating to the reported "poor governance practices" of this cooperative's recent set of management, and elected/appointed officers.

    One complaint, I was told, questions the legitimacy of the election of the 2016-2017 set of officers and the immediate prior years.  Before  to the 2016 General Assembly of the cooperative, a number of its members wrote CDA Region III to clarify a number of issues pertaining to official actions of this set of management/officers.  

    CDA Main wrote the clarification, signed no less than by CDA's Deputy Executive Director, citing among other things, that if the cooperative's By-Laws provide that no candidate for officers, who are related to each other within the 3rd degree of consanguinity may be qualified to run during the elections, this must be respected.  This is regardless of whether R.A. 9520  allows this now.  

    The cooperative's present officers defied this.  They formulated new election rules, while not yet presented nor approved prior by the General Assembly, these nonetheless were implemented during the April 2016 General Assembly, which was met by opposition during the General Assembly.  The new election rules reportedly are so restrictive, and tailor-fit, so that only the present set of officers and their cabal may qualify as candidates.

    Going back to the expulsion, after the General Assembly, the BoD of this cooperative submitted to CDA Region III for registration the proposed amendments to its Articles of Incorporation and By-Laws.  As this was also subject of the complaint that the said amendments allegedly were not actually approved during the said G.A., CDA Region III, per reports,  made verifications on the ground, and ruled that the said amendments were "not properly presented" to the G.A.  I will leave it to you to interpret that CDA ruling.

    Recently, I heard that for these alleged violations, among which is reportedly submitting to CDA annual compliance documents, including proposed AIBL amendments (as in making it appear that the AIBL amendments were approved, if in fact it was not), CDA Region III is giving the officers of this cooperative a tap on the wrist, a mere warning, as penalty.

    Theoretically speaking, the academic question may be asked, if some people (not the officers of the cooperative being talked about above) could officially do that to the regulator and get away with a mere tap on wrist, God help the members of such an organization. Could they also be as less than truthful to their members?

    There are more complaints of violations officially submitted to CDA.

    What has a chilling effect on the cooperative members is that these reported infractions allegedly committed by the members, now being expelled, arose from discussions of the agenda, and of official actions of the cooperative's officers, DURING THE GENERAL ASSEMBLY.

    Is not the General Assembly the most powerful body enshrined in the cooperative organization?

    Imagine, as a member of the cooperative, you were invited, nay, commanded (under pain of some penalties for failure to attend) to be part of the General Assembly.  And you are NOT an ordinary member.  You are a member in good standing.  You have the capacity to vote.  And you, along with other members, were called upon to constitute the G.A., the cooperative's highest governing/ruling body, to discharge your solemn duty to the cooperative and its members.

    If one recalls, such duty and privilege include participating in the Open Forum, in the free and unfettered discussion of the G.A. agenda; issues related thereto; including on the actions of the cooperative's officers (appointed, or elected), as these pertain to their discharge of their official functions for which they were put to office.

    And for doing their duty, these members, concerned enough about the state and future of their cooperative to risk reprisals, as is now happening, as to express themselves in this General Assembly, they are now being told to explain why they should not be "involuntarily terminated".

    What will the cooperative regulator, whose mission is to protect the safety of cooperatives, do about this. Hmmm..

    If you ask me, it this is the way the officers of this cooperative treat the members of their highest governing body, maybe it is to the best interest of the cooperative members to give these officers their satisfaction, and accept their "involuntary termination", or voluntarily resign.  What do you think?  (END).

CIC: CO-OP DATA DUE 06/30/17

     It's official! 

    The deadline for submission of co-ops members' credit data to the Credit Information Corporation (CIC) has been extended up to June 30, 2017.

    In its Circular No. 2016-04, series of 2016, and signed on August 19, 2016, CIC said the new deadline involves the "production submission of both current and historical data of borrowers, belonging to large and medium cooperatives.

    Prior to this, the original deadlines were: October 30, 2016 for large cooperatives, and December 31, 2016 for medium cooperatives.

    According to the Cooperative Development Authority, large cooperatives are those with total value of assets of over Php100-million; and over Php15-million up to Php100-million for medium cooperatives.  The list of the names of these cooperatives was contained in CIC Circular No. 2016-01.

    Among the reasons cited for the extension is the absence of the Tax Identification Numbers (TINs) of some cooperative members.  This, according to CIC had been remedied.

    Other reasons which reportedly affected early compliance include limited access to the Internet; lack of technological capacity; and antiquated/manual systems used by the cooperatives.

    The additional time given is seen to be "generous enough" to fully address the challenges faced, CIC said.

    CooperativesPhilippines checked the CIC website, but as of this writing (September 24, 2016), the said Circular is not yet uploaded.  However it was posted in the CIC Facebook page.  (END).




Wednesday, September 21, 2016


(CooperativesPhilippines:  We may think, rightly or wrongly, that the cooperatives' compliance with CISA comprises only and simply of  submitting cooperative members' data to the Credit Information Corporation.

Here comes the Implementing Rules and Regulations of the Data Privacy Act, as assayed in the reposted item below, and which reportedly took effect on September 09, 2016.

Are cooperatives considered as "Personal Information Controllers" (PIC), or "Personal Information Processors" (PIP}, under the above-mentioned IRR?

Either way, it appears from the item below, that cooperatives,  as "PIC", or "PIP", and to comply with the CISA requirement, has to undertake a number of measures, including but not limited to, register with the National Privacy Commission, and undertaking measures to assure the privacy of cooperative-members' credit data.

While we are at it, is the Credit Information Corporation (CIC), a "PIC", or "PIP"?  And what is CIC undertaking to do under the Data Privacy Act, to protect the privacy of cooperatives' credit data?

Anyway, here is the reposted item, from BusinessWorld, Sept. 22, 2016 issue, for the guidance of cooperatives.):


Obey or pay: Implications for personal information controllers and processors

 0  0 Google +0  0

Taxwise or Otherwise
By Menen E. Miranda

Posted on September 22, 2016

A couple of months ago, I wrote about the draft Implementing Rules and Regulations (IRR) of the Data Privacy Act (DPA) of 2012 and the rights of the data subject. As promised, here is the second part where I will share my thoughts on how the IRR will impact organizations as either personal information controllers (PICs) or personal information processors (PIPs).


Taxwise or Otherwise -- By Mark Aurelius V. Bantay: "The Culprit: More than meets the eye"
Taxwise Or Otherwise -- By Realyn M. Postrado-dela Cruz: "Tax sparing spared"
Taxwise Or Otherwise -- By Stacy G. Quinsay: "Swipe right: Know the credit card law"
Taxwise Or Otherwise -- By Floredee T. Odulio: "Buttlegging"

The final IRR was published in the Official Gazette last Aug. 25. It took effect last Sept. 9, a date worth noting because it signifies the start of the one-year period for PICs or PIPs to meet certain requirements under the law and the IRR. So, what are these requirements?

According to Section 46 of the IRR, PICs are required to perform the following actions to ensure that they comply with their obligations under the law:

• Register with the National Privacy Commission (the Commission) their personal data processing systems operating in the country that involves accessing or requiring sensitive information of at least 1,000 individuals, including the data processing system of contractors, and their personnel, entering into contracts with government agencies;

• Notify the Commission of their automated processing operations where processing becomes the sole basis of making decisions that would significantly affect the data subject;

• Report annually to the Commission a summary of their documented security incidents and personal data breaches; and

• Comply with other requirements that may be imposed by the Commission in other issuances.

Looks simple? It depends on who you ask and on how mature an organization’s privacy life cycle is.

An organization that lacks privacy-consciousness may view the DPA and its IRR like an enormous beast to deal with. There are many elements to assess and questions to answer -- the most fundamental of which are “What do we do?” and “Where do we begin?”

In contrast, an organization that has taken steps towards privacy maturity, either as a response to their customers’ privacy requirements (e.g. BPO industry) or to the enactment of the DPA in 2012, may be in a place where they can begin to measure their readiness to comply with the specifics of the law. ‘Where are we now?’ is the likely question this organization may ask itself.

Another type of organization would be one that is focused on and invested in securing their information in general. This entity will be able to leverage their information security policies, processes, and technologies to become compliant with the requirements of the DPA and its regulations.

And perhaps the organization well positioned to comply with the law is one with a functioning governance framework, if such an organization exercises governance over the information.

Irrespective of where an organization may be as regards to privacy, there are actions prescribed in the IRR that PICs better observe to satisfy what’s required of them. Rule VI lays down the security measures for the protection of personal data by a PIC, summarized as follows:

• Assign someone to function as data protection officer, compliance officer or any other officer accountable for ensuring compliance with applicable laws and regulations on data privacy and security;

• Implement appropriate data protection policies that provide for organization, physical, and technical security measures;

• Maintain records that sufficiently describe their data processing system and identify the duties and responsibilities of those individuals who will have access to personal data;

• Select, train and supervise their employees, agents, or representatives who will have access to personal data;

• Develop, implement and review policies and procedures for the collection and processing of personal data, for data subjects to exercise their rights under the DPA, access management, system monitoring, protocols for security incidents or technical problems, and data retention;

• Ensure through appropriate contractual agreements that their personal information processors shall also implement the security measures required by the law and the IRR;

• Comply, where appropriate, with physical security guidelines set forth in the IRR; and

• Adopt and establish technical security measures such as, but not limited to, security policy for the processing of personal data; safeguards to protect their computer network, periodic evaluation of security measures’ effectiveness; and personal data encryption.

The Commission intends to monitor PIC and PIP security measures against the guidelines provided in the IRR and subsequent issuances. The determination of the appropriate level of protection by a PIC or PIP will take into account various factors such as the nature of the personal data, the risks posed by the processing, size of the organization, complexity of operations, current data privacy best practices, and the cost of security implementation. Simply put, organizations should employ a risk-based approach to privacy. In my honest opinion, this is the way that PICs and PIPs should go since protecting personal data can come at a hefty price if controls are implemented without properly assessing risks.

There may be questions surrounding the Commission’s readiness in performing its compliance and monitoring functions. “Has it built the capacity to enforce the law and its regulations?” “Does it have the right people to fulfill its mandate? Or is the Commission also just starting to form its own teams, processes and procedures that will support its various functions?” As for me, I would like to believe that the Commission is working doubly hard to prepare for the onslaught of privacy concerns that will come from data subjects, PICs, PIPs, and other stakeholders.

In these early days of privacy in the Philippines, organizations may view privacy as something they must comply with, at any cost. I have no qualms about that. Who wants to be slapped with fines and imprisonment? Rule XII of the IRR specifies the penalties for violations pertaining to personal information and sensitive personal information that include unauthorized processing, accessing due to negligence, improper disposal, processing for unauthorized purposes, unauthorized access or intentional breach, concealment of security breaches, malicious disclosure, and unauthorized disclosure. There are corresponding fines and periods of imprisonment for each of these violations, ranging from P100,000 to P5,000,000 and between six months and seven years. These consequences show how serious the Philippine Government is about the business of privacy.

Obedience will drive organizations to uphold privacy. However, organizations that understand their need for privacy that can be trusted (beyond compliance) may get more out of protecting privacy than just avoiding penalties. Customers are data subjects and as the data subjects become more aware of their right to privacy, there will be increased demand and pressure on organizations to uphold that right. Investors always want to protect their business interests, therefore they will choose to do business with organizations that can demonstrate their ability to manage all types of risks, including privacy risk. Privacy also impacts the top and bottom lines by way of the fines imposed by the Commission and from the reputational costs of lost revenue.

It is apparent that heads will roll if and when privacy is breached. Therefore it is imperative for organizations to start or continue their privacy journey to be compliant with the law, and more importantly, to emerge as champions of data privacy that people can trust.

The views or opinions expressed in this article are solely those of the author and do not necessarily represent those of PwC Consulting Services Philippines Co. Ltd. The firm will not accept any liability arising from the article.

Menen E. Miranda is a manager at the Technology and Risk Consulting practice of PricewaterhouseCoopers Consulting Services Philippines Co. Ltd., a Philippine member firm of the PwC network. She is an experienced professional in the privacy and information security domains, having serve clients locally and abroad.

+63 (2) 845 2728 ext. 3245

Tuesday, September 20, 2016


Co-ops can help boost farm productivity–PhilRice

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Agricultural cooperatives are effective motivators for farmers to adopt farming technologies to boost their farm productivity, according to a recent study conducted by the Philippine Rice Research Institute (PhilRice).
The study, titled “Agricultural cooperatives: Key partners in technology promotion and rural development,” was conducted by a PhilRice research group.
“What makes agricultural cooperatives unique is that they have a unified action to become viable, while helping individual members improve. When the cooperative is able to prove that a specific technology is efficient, it is certain that the farmer-members will adopt it in a sustainable manner,”  Christian Flor Guittap said in a statement.
The PhilRice research group introduced various farm technologies to Lupao, Nueva Ecija-based Parista Barangay Defense System Multipurpose Cooperative (PBDS-MPC) in 2014, to determine the efficacy of the said cooperative in promoting, evaluating and adopting farm technologies in their respective community.
“During our discussion with PBDS-MPC, we found that the cooperative practices conventional farming such that its members do not use quality rice seeds and other technologies, and apply fertilizers without assessing their soil needs,” Guittap said. Among the farming technologies introduced by PhilRice to PBDS-MPC were  use of certified seeds, Minus One Element Technique (MOET), leaf color chart (LCC), and integrated pest management and rice-based farming systems.
MOET is a diagnostic tool to determine deficiency of key nutrients in paddy soil, while LCC assesses nitrogen status of rice plants which can save farmers of up P2,000 per hectare in nitrogen-fertilizer use, according to PhilRice.
At least 46 farmers, or 78 percent, of the 59 farmer-members of PBDS-MPC who participated in the research project adopted the technologies promoted by the PhilRice research project during the 2015 wet season and 2016 dry season, PhilRice said.
“This percentage equates to high level of adoption. In 2016 DS, we also found that 73 percent of the participating co-op members achieved an average yield increase of 0.5 ton per hectare, while 22 percent of farmers attained more than 1 ton per hectare, increase in yield,” said Joel Pascual, head of the said PhilRice study.
Ferdinand C. Orate, PBDS-MPC farmer-cooperator, said his harvest increased by 40 percent when he used the rice variety NSIC RC308 endorsed by PhilRice.
“Along the banks and dikes, I also tried planting cash crops, such as saluyot, string beans and okra, that we now sell in  Lupao market,” Orate said.
Dr. Aurora Corales, project lead of the PhilRice study, said the partnership with the cooperative empowered farmers toward community welfare.
“This model may serve as a guide in implementing developmental activities, promoting location-specific rice and rice-based technologies to improve farmers’ lives,” Corales said.

Monday, September 19, 2016


an invitation to Luzon-wide Coop Covergence on September 29th:
The Cooperative Development Authority (CDA) in collaboration with the Local Government Unit (LGU) of the Province of Batangas thru the Provincial Cooperatives Livelihood Enterprise and Development Office (PCLEDO)-Batangas will be holding a Luzon-wide Convergence of Cooperatives on September 29, 2016 (Thursday); 8:00a.m. to 5:00 p.m. at the Provincial Cooperative Development Center, Provincial Capitol Compound, Batangas City. In this regard, we would like to invite you or your representative to the said affair, free of charge.
The said event aims to a) provide updates on the current state of cooperatives; b) gather issues and concerns of the group; and c) set/formulate a plan to strengthen and fortify the sector under the current administration of President Rodrigo R. Duterte.
For confirmation or inquiries, please contact Mr. Naddy Acompañado (Cp #0921-4875353) or Zaldy Bermejo (Cp #0920-5536300) or @CDA Naga Ext’n Office telephone number 473-9053.
Cooperative :_______________________________________________
Address :_______________________________________________
Tel. No. :_______________________________________________
Email Address:_____________________________________________

Note: Please fax to (054) 473-9053 or email to
(Only 25 participants is allotted for Region 5; Delegates will be accommodated on a first come first served basis)
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