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TMI BlogMaster Circular on External Commercial Borrowings and Trade CreditsX X X X Extracts X X X X X X X X Extracts X X X X ..... arge INDEX PART I EXTERNAL COMMERCIAL BORROWINGS (ECB) I.(A) AUTOMATIC ROUTE i) Eligible Borrowers ii) Recognised Lenders iii) Amount and Maturity iv) All-in-cost ceilings v) End-use vi) Payment for Spectrum Allocation vii) End-uses not permitted viii) Guarantees ix) Security x) Parking of ECB proceeds xi) Prepayment xii) Refinancing of an existing ECB xiii) Debt Servicing xiv) Corporates Under Investigation xv) Procedure I.(B) APPROVAL ROUTE i) Eligible Borrowers ii) Recognised Lenders iii) Amount and Maturity iv) All-in-cost ceilings v) End-use vi) Repayment of Rupee loans and/or fresh Rupee capital expenditure for companies with consistent forex earnings vii) ECB for Low Cost Affordable Housing viii) 3G Spectrum Allocation ix) End-uses not permitted x) Guarantee xi) Security xii) Parking of ECB proceeds ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... convertible preference shares) availed of from non-resident lenders with a minimum average maturity of 3 years. (ii) Foreign Currency Convertible Bonds (FCCBs) mean a bond issued by an Indian company expressed in foreign currency, and the principal and interest in respect of which is payable in foreign currency. Further, the bonds are required to be issued in accordance with the scheme viz., "Issue of Foreign Currency Convertible Bonds and Ordinary Shares (Through Depositary Receipt Mechanism) Scheme, 1993 , and subscribed by a non-resident in foreign currency and convertible into ordinary shares of the issuing company in any manner, either in whole, or in part, on the basis of any equity related warrants attached to debt instruments. The ECB policy is applicable to FCCBs. The issue of FCCBs is also required to adhere to the provisions of Notification FEMA No. 120/RB-2004 dated July 7, 2004 , as amended from time to time. (iii) Preference shares (i.e. non-convertible, optionally convertible or partially convertible) for issue of which, funds have been received on or after May 1, 2007 would be considered as debt and should conform to the ECB policy. Accordingly, all the nor ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... heir own requirement. However, they cannot transfer or on-lend ECB funds to sister concerns or any unit in the Domestic Tariff Area (DTA). (c) Non-Government Organizations (NGOs) engaged in micro finance activities are eligible to avail of ECB. (d) Micro Finance Institutions (MFIs) engaged in micro finance activities are eligible to avail of ECBs. MFIs registered under the Societies Registration Act, 1860, MFIs registered under Indian Trust Act, 1882, MFIs registered either under the conventional state-level cooperative acts, the national level multi-state cooperative legislation or under the new state-level mutually aided cooperative acts (MACS Act) and not being a co-operative bank, Non-Banking Financial Companies (NBFCs) categorized as Non Banking Financial Company-Micro Finance Institutions (NBFC-MFIs) and complying with the norms prescribed as per circular DNBS.CC.PD.No. 250/03.10.01/2011-12 dated December 02, 2011 and Companies registered under Section 25 of the Companies Act, 1956 and are involved in micro finance activities. (e) NGOs engaged in micro finance and MFIs registered as societies, trusts and co-operatives and engaged in micro finance (i) should ha ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... e foreign equity holder in the term ECB liability-equity ratio. Where there are more than one foreign equity holder in the borrowing company, the portion of the share premium in foreign currency brought in by the lender(s) concerned shall only be considered for calculating the ECB liability-equity ratio for reckoning quantum of permissible ECB. For calculating the ECB liability , not only the proposed borrowing but also the outstanding ECB from the same foreign equity holder lender shall be reckoned. Overseas organizations and individuals providing ECB need to comply with the following safeguards: Overseas Organizations proposing to lend ECB would have to furnish to the AD bank of the borrower a certificate of due diligence from an overseas bank, which, in turn, is subject to regulation of host-country regulator and adheres to the Financial Action Task Force (FATF) guidelines. The certificate of due diligence should comprise the following (i) that the lender maintains an account with the bank for at least a period of two years, (ii) that the lending entity is organised as per the local laws and held in good esteem by the business/local community and (iii) that there is no ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... reign currency except commitment fee, pre-payment fee, and fees payable in Indian Rupees. The payment of withholding tax in Indian Rupees is excluded for calculating the all-in-cost. The existing all-in-cost ceilings for ECB are as under: Average Maturity Period All-in-cost Ceilings over 6 month LIBOR* Three years and up to five years 350 basis points More than five years 500 basis points * for the respective currency of borrowing or applicable benchmark In the case of fixed rate loans, the swap cost plus margin should be the equivalent of the floating rate plus the applicable margin. v) End-use ECB can be raised for investment such as import of capital goods (as classified by DGFT in the Foreign Trade Policy), new projects, modernization/expansion of existing production units in real sector - industrial sector including small and medium enterprises (SME), infrastructure sector and specified service sectors, namely, hotel, hospital and software in India. Infrastructure sector is defined as (i) power, (ii) telecommunication, (iii) railways, (iv) roads including bridges, (v) sea port and airport, (vi) industrial ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... -how and payment of license fees: The companies in the manufacturing and infrastructure sectors may import services, technical know-how and payment of license fees as part of import of capital goods subject to certain conditions. vi) Payment for Spectrum Allocation (a) Relaxation for the successful Bidders of 2G spectrum Re-auction (i) to make the upfront payment initially out of Rupee loans availed of from the domestic lenders and refinance such Rupee loans with a long-term ECB provided such ECB is raised within a period of 18 months from the date of sanction of such Rupee loans for the stated purpose from the domestic lenders. (ii) Availing of short term foreign currency loan in the nature of bridge finance for the purpose of making upfront payment and replace the same with a long term ECB subject to condition that the long term ECB is raised within a period of 18 months from the date of drawdown of the bridge finance. (iii) ECB can be availed of from their ultimate parent company without any maximum ECB liability-equity ratio subject to the condition that the lender holds minimum paid-up equity of 25 per cent in the borrower company, either directly or indirectly. v ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... The no objection for creation of charge on immovable assets may be conveyed under FEMA, 1999 either in favour of the lender or the security trustee, subject to the following conditions: No objection shall be granted only to a resident ECB borrower. The period of such charge on immovable assets has to be co-terminus with the maturity of the underlying ECB. Such no objection should not be construed as a permission to acquire immovable asset (property) in India, by the overseas lender / security trustee. In the event of enforcement / invocation of the charge, the immovable asset (property) will have to be sold only to a person resident in India and the sale proceeds shall be repatriated to liquidate the outstanding ECB. b) AD Category I banks may convey their 'no objection' under FEMA, 1999 to the resident ECB borrower for pledge of shares of the borrowing company held by promoters as well as in domestic associate companies of the borrower to secure the ECB subject to the following conditions: The period of such pledge shall be co-terminus with the maturity of the underlying ECB. In case of invocation of pledge, transfer shall be in accordance with the ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... less than AA (-) by Standard and Poor/Fitch IBCA or Aa3 by Moody s (b) Treasury bills and other monetary instruments of one year maturity having minimum rating as indicated above, and (c) deposits with overseas branches / subsidiaries of Indian banks abroad. The funds should be invested in such a way that the investments can be liquidated as and when funds are required by the borrower in India. The primary responsibility to ensure that the ECB proceeds meant for Rupee expenditure in India are repatriated to India for credit to their Rupee accounts with AD Category- I banks in India is that of the borrower concerned and any contravention of the ECB guidelines will be viewed seriously and will invite penal action under the Foreign Exchange Management Act (FEMA), 1999 . The designated AD bank is also required to ensure that the ECB proceeds meant for Rupee expenditure are repatriated to India immediately after drawdown. xi) Prepayment Prepayment of ECB up to USD 500 million may be allowed by AD banks without prior approval of Reserve Bank subject to compliance with the stipulated minimum average maturity period as applicable to the loan. xii) Refinancing of an existing ECB ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... gencies and international banks to finance import of infrastructure equipment for leasing to infrastructure projects. Infrastructure Finance Companies (IFCs) i.e. Non-Banking Financial Companies (NBFCs), categorized as IFCs, by the Reserve Bank, are permitted to avail of ECBs, including the outstanding ECBs, beyond 75 per cent of their owned funds, for on-lending to the infrastructure sector as defined under the ECB policy, subject to their complying with the following conditions: i) compliance with the norms prescribed in the DNBS Circular DNBS.PD.CCNo.168 / 03.02.089 / 2009-10 dated February 12, 2010 ii) hedging of the currency risk in full. Designated Authorised Dealer should ensure compliance with the extant norms while certifying the ECB application. While forwarding such proposals to the Reserve Bank of India, designated AD Category I banks should certify the leverage ratio (i.e. outside liabilities/owned funds) of IFCs. Foreign Currency Convertible Bonds (FCCBs) by Housing Finance Companies satisfying the following minimum criteria: (i) the minimum net worth of the financial intermediary during the previous three years shall not be less than Rs. 500 crore, (ii) a lis ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... mall Industries Development Bank of India (SIDBI) is eligible to avail of ECB for on-lending to MSME sector, as defined under the Micro, Small and Medium Enterprises Development (MSMED) Act, 2006, beyond 50 per cent of their owned funds, subject to a ceiling of USD 500 million per financial year provided such on-lending by SIDBI shall be to the borrowers for permissible end-use and having natural hedge by way of foreign exchange earnings. SIDBI may on-lend either in INR or in foreign currency (FCY). In case of on-lending in INR, the foreign currency risk shall be fully hedged by SIDBI. Low Cost Affordable Housing Projects: Developers/builders / Housing Finance Companies (HFCs) / National Housing Bank (NHB) may avail of ECB for low cost affordable housing projects [refer to para I B (vii) ibid]. Corporates Under Investigation: All entities against which investigations / adjudications / appeals by the law enforcing agencies are pending, may avail of ECBs as per the current norms, if they are otherwise eligible, notwithstanding the pending investigations / adjudications / appeals, without prejudice to the outcome of such investigations / adjudications / appeals. Accordingly, in c ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... lculating the ECB liability , not only the proposed borrowing but also the outstanding ECB from the same foreign equity holder lender shall be reckoned. The total outstanding stock of ECBs (including the proposed ECBs) from a foreign equity lender should not exceed seven times the equity holding, either directly or indirectly of the lender (in case of lending by a group company, equity holdings by the common parent would be reckoned). iii) Amount and Maturity Eligible borrowers under the automatic route other than corporates in the services sector viz. hotel, hospital and software can avail of ECB beyond USD 750 million or equivalent per financial year. Corporates in the services sector viz. hotels, hospitals and software sector are allowed to avail of ECB beyond USD 200 million or its equivalent in a financial year for meeting foreign currency and/ or Rupee capital expenditure for permissible end-uses. The proceeds of the ECBs should not be used for acquisition of land. An illustration of average maturity period calculation is provided at Annex VI. iv) All-in-cost ceilings All-in-cost includes rate of interest, other fees and expenses in foreign currency except co ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... cognized lender, all-in-cost, average maturity, etc. should be complied with. e. The first stage acquisition of shares in the disinvestment process and also in the mandatory second stage offer to the public under the Government s disinvestment programme of PSU shares.The first stage acquisition of shares in the disinvestment process and also in the mandatory second stage offer to the public under the Government s disinvestment programme of PSU shares. f. Repayment of Rupee loans availed of from domestic banking system: Indian companies which are in the infrastructure sector ( except companies in the power sector), as defined under the extant ECB guidelines , are permitted to utilise 25 per cent of the fresh ECB raised by them towards refinancing of the Rupee loan/s availed by them from the domestic banking system, subject to the following conditions: (i) at least 75 per cent of the fresh ECB proposed to be raised should be utilised for capital expenditure towards a 'new infrastructure' project(s) (ii) in respect of remaining 25 per cent, the refinance shall only be utilized for repayment of the Rupee loan availed of for 'capital expenditure' of earlier completed infrastr ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... CBs for repayment of outstanding Rupee loans availed of for capital expenditure from the domestic banking system and/or fresh Rupee capital expenditure provided they are consistent foreign exchange earners during the past three financial years and not in the default list/caution list of the Reserve Bank of India. The overall limit for such ECBs is USD 10 billion and the maximum ECB that can be availed by an individual company or group, as a whole, under this scheme will be restricted to USD 3 billion. Further, the maximum permissible ECB that can be availed of by an individual company will be limited to 75 per cent of the average annual export earnings realized during the past three financial years or 50 per cent of the highest foreign exchange earnings realized in any of the immediate past three financial years, whichever is higher. In case of Special Purpose Vehicles (SPVs), which have completed at least one year of existence from the date of incorporation and do not have sufficient track record/past performance for three financial years, the maximum permissible ECB that can be availed of will be limited to 50 per cent of the annual export earnings realized during the past financ ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ousing unit shall not exceed INR 30 lakh. The ECB should be swapped into Rupees for the entire maturity on fully hedged basis. HFCs while making the applications, shall submit a certificate from NHB that the availment of ECB is for financing prospective owners of individual units for the low cost affordable housing and ensure that the interest rate spread charged by them to the ultimate buyer is reasonable. (d) NHB is also eligible to raise ECB for financing low cost affordable housing units of individual borrowers. Further, in case, a developer of low cost affordable housing project not being able to raise ECB directly as envisaged above, National Housing Bank is permitted to avail of ECB for on-lending to such developers which satisfy the conditions prescribed to developers / builders subject to the interest rate spread set by RBI. ECB proceeds shall be utilized only for low cost affordable housing projects and shall not be utilized for acquisition of land.(e) Interest rate spread to be charged by NHB may be decided by NHB taking into account cost and other relevant factors. NHB shall ensure that interest rate spread for HFCs for on-lending to prospective owners of individual ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... a view to facilitating capacity expansion and technological upgradation in Indian textile industry, issue of guarantees, standby letters of credit, letters of undertaking and letters of comfort by banks in respect of ECB by textile companies for modernization or expansion of textile units will be considered under the Approval Route subject to prudential norms. xi) Security The choice of security to be provided to the lender / supplier is left to the borrower. However, creation of charge over immovable assets and financial securities, such as shares, in favour of the overseas lender is subject to Regulation 8 of Notification No. FEMA 21/RB-2000 dated May 3, 2000 and Regulation 3 of Notification No. FEMA 20/RB-2000 dated May 3, 2000 as amended from time to time, respectively. Powers have been delegated to Authorised Dealer Category I banks to issue necessary NOCs under FEMA as detailed in paragraph I (A) (x) ibid. xii) Parking of ECB proceeds Borrowers are permitted to either keep ECB proceeds abroad or to remit these funds to India, pending utilization for permissible end-uses. The proceeds of the ECB raised abroad meant for Rupee expenditure in India, such as, lo ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... the all-in-cost ceiling prescribed as per the extant guidelines. xv) Debt Servicing The designated AD bank has general permission to make remittances of installments of principal, interest and other charges in conformity with the ECB guidelines issued by Government / Reserve Bank from time to time. xvi) Procedure Applicants are required to submit an application in form ECB through designated AD bank to the Chief General Manager-in-Charge, Foreign Exchange Department, Reserve Bank of India, Central Office, External Commercial Borrowings Division, Mumbai 400 001, along with necessary documents. xvii) Foreign Currency Exchangeable Bonds Foreign Currency Exchangeable Bond (FCEB) means a bond expressed in foreign currency, the principal and interest in respect of which is payable in foreign currency, issued by an Issuing Company and subscribed to by a person who is a resident outside India, in foreign currency and exchangeable into equity share of another company, to be called the Offered Company, in any manner, either wholly, or partly or on the basis of any equity related warrants attached to debt instruments. The FCEB may be denominated in any freely convertible ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... prices of the shares of the offered company quoted on the stock exchange during the six months preceding the relevant date; and (ii) The average of the weekly high and low of the closing prices of the shares of the offered company quoted on a stock exchange during the two week preceding the relevant date. Average Maturity: Minimum maturity of FCEB shall be five years. The exchange option can be exercised at any time before redemption. While exercising the exchange option, the holder of the FCEB shall take delivery of the offered shares. Cash (Net) settlement of FCEB shall not be permissible. Parking of FCEB proceeds abroad : The proceeds of FCEB may be retained and / or deployed overseas by the issuing / promoter group companies in accordance with the policy for the ECB or repatriated to India for credit to the borrowers Rupee accounts with AD Category I banks in India pending utilization for permissible end-uses. It shall be the responsibility of the issuing company to ensure that the proceeds of FCEB are used by the promoter group company only for the permitted end-uses prescribed under the ECB policy. The issuing company should also submit audit trail of the end-use of t ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... conversion price will, however, be considered under the approval route depending on the merits of the proposal. B. Buyback / Prepayment of Foreign Currency Convertible Bonds (FCCBs) The proposal of Buyback / prepayment of FCCBs from Indian Companies may be considered subject to condition that the buyback value of the FCCBs shall be at a minimum discount of five per cent on the accreted value. In case the Indian company is planning to raise a foreign currency borrowing for buyback of the FCCBs, all FEMA rules/ regulations relating to foreign currency borrowing shall be complied with. The entire process of buyback should be completed by December 31, 2013 after which the scheme will stand discontinued. III. REPORTING ARANGEMENTS AND DISSEMINATION OF INFORMATION i) Reporting Arrangements With a view to simplifying the procedure, submission of copy of loan agreement is dispensed with. For allotment of Loan Registration Number (LRN), borrowers are required to submit Form 83 , in duplicate, certified by the Company Secretary (CS) or Chartered Accountant (CA) to the designated AD bank. One copy is to be forwarded by the designated AD bank to the Director, Balance of Pay ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... esident outside India, who has met the liability under a guarantee. Accordingly, in cases where the liability is met by the non-resident out of funds remitted to India or by debit to his FCNR(B)/NRE account, the repayment may be made by credit to the FCNR(B)/NRE/NRO account of the guarantor provided, the amount remitted/credited shall not exceed the rupee equivalent of the amount paid by the non-resident guarantor against the invoked guarantee. AD Category-I banks are required to furnish such details by all its branches, in a manner specified by the Reserve Bank of India (RBI) to the Chief General Manager, Foreign Exchange Department, ECB Division, Reserve Bank of India, Central Office Building, 11th floor, Fort, Mumbai 400 001 so as to reach the Department not later than 10th day of the following month. The facility of credit enhancement by eligible non-resident entities to domestic debt raised through issue of capital market instruments, such as Rupee denominated bonds and debentures, is available to all borrowers eligible to raise ECB under automatic route subject to the following conditions: i) credit enhancement should be provided by eligible non-resident entities; i ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... e domestic bank financing the infrastructure project should comply with the extant prudential norms relating to take-out financing. iv. The fee payable, if any, to the overseas lender until the take-out shall not exceed 100 bps per annum. v. On take-out, the residual loan agreed to be taken out by the overseas lender would be considered as ECB and the loan should be designated in a convertible foreign currency and all the extant norms relating to ECB should be complied with. vi. Domestic banks / Financial Institutions will not be permitted to guarantee the take-out finance. vii. The domestic bank will not be allowed to carry any obligation on its balance sheet after the occurrence of the take-out event. viii. Reporting arrangement as prescribed under the ECB policy should be adhered to. VI. COMPLIANCE WITH ECB GUIDELINES The primary responsibility to ensure that ECB raised/utilised are in conformity with the ECB guidelines and the Reserve Bank regulations / directions is that of the borrower concerned and any contravention of the ECB guidelines will be viewed seriously and will invite penal action under FEMA 1999. The designated AD bank is also required to ensure th ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ation of repayment period for loans raised under the erstwhile USD 5 Million Scheme, provided there is a consent letter from the overseas lender for such reschedulement without any additional cost. Such approval with existing and revised repayment schedule along with the Loan Key/Loan Registration Number should be initially communicated to the Chief General Manager-in-Charge, Foreign Exchange Department, ECB Division Reserve Bank of India, Central Office, Mumbai within seven days of approval and subsequently in ECB - 2. X. RATIONALIZATION OF PROCEDURES - DELEGATION OF POWERS TO AD Any changes in the terms and conditions of the ECB after obtaining LRN from DSIM, RBI required the prior approval of RBI. The powers have been delegated to the designated AD Category-I banks to approve the following requests from the ECB borrowers, subject to specified conditions: (a) Changes/modifications in the drawdown/repayment schedule Designated AD Category-I banks may approve changes/modifications in the drawdown/repayment schedule of the ECBs already availed, both under the approval and the automatic routes, subject to the condition that the average maturity period, as declared while o ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... es. The changes should be promptly reported to the Department of Statistics and Information Management, Reserve Bank of India in Form 83 . (e) Change in the recognized lender Designated AD Category-I banks may approve the request from the ECB borrowers with respect to change in the recognized lender when the original lender is an international bank or a multilateral financial institution (such as IFC, ADB, CDC, etc.) or a regional financial institution or a Government owned development financial institution or an export credit agency or supplier of equipment and the new lender also belongs to any one of the above mentioned categories, subject to the Authorised Dealer ensuring that the new lender is a recognized lender as per the extant ECB norms, there is no change in the other terms and conditions of the ECB and the ECB is in compliance with the extant guidelines. The changes in the recognized lender should be promptly reported to the Department of Statistics and Information Management, Reserve Bank of India in Form 83 However, changes in the recognized lender in case of foreign equity holder and foreign collaborator would require the prior approval of the Reserve Bank. ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... directly by the overseas supplier, bank and financial institution for maturity of less than three years. Depending on the source of finance, such trade credits include suppliers credit or buyers credit. Suppliers credit relates to credit for imports into India extended by the overseas supplier, while buyers credit refers to loans for payment of imports into India arranged by the importer from a bank or financial institution outside India for maturity of less than three years. It may be noted that buyers credit and suppliers credit for three years and above come under the category of External Commercial Borrowings (ECB) which are governed by ECB guidelines. a) Amount and Maturity (i) AD banks are permitted to approve trade credits for imports into India up to USD 20 million per import transaction for imports permissible under the current Foreign Trade Policy of the DGFT with a maturity period up to one year (from the date of shipment). For import of capital goods as classified by DGFT, AD banks may approve trade credits up to USD 20 million per import transaction with a maturity period of more than one year and less than three years (from the date of shipment). No roll- ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ails of approvals, drawal, utilisation, and repayment of trade credit granted by all its branches, in a consolidated statement, during the month, in form TC (format in Annex IV) from April 2004 onwards to the Director, Division of International Finance, Department of Economic Policy and Research, Reserve Bank of India, Central Office Building, 8th floor, Fort, Mumbai 400 001 (and in MS-Excel file through email ) so as to reach not later than 10th of the following month. Each trade credit may be given a unique identification number by the AD bank. AD banks are required to furnish data on issuance of LCs / Guarantees / LoU / LoC by all its branches, in a consolidated statement, at quarterly intervals (format in Annex V) to the Chief General Manager-in-Charge, Foreign Exchange Department, ECB Division, Reserve Bank of India, Central Office Building, 11th floor, Fort, Mumbai 400 001 (and in MS-Excel file through email ) from December 2004 onwards so as to reach the Department not later than 10th of the following month. Appendix List of Notification/ A.P. (DIR Series) Circulars consolidated in the Master Circular on External Commercial Borrowings and Trade Credits ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... R Series) Circular No.10 September 26, 2007 19 A.P.(DIR Series) Circular No.42 May 28, 2008 20 A.P.(DIR Series) Circular No.43 May 29, 2008 21 A.P.(DIR Series) Circular No.46 June 2, 2008 22 A.P.(DIR Series) Circular No.1 July 11, 2008 23 A.P.(DIR Series) Circular No.16 September 22, 2008 24 A.P.(DIR Series) Circular No.17 September 23, 2008 25 A.P.(DIR Series) Circular No.20 October 8, 2008 26 A.P.(DIR Series) Circular No.26 October 22, 2008 27 A.P.(DIR Series) Circular No.27 October 27, 2008 28 A.P.(DIR Series) Circular No.39 December 8, 2008 29 A.P.(DIR Series) Circular No.46 January 2, 2009 30 A.P.(DIR Series) Circular No.58 March 13, 2009 31 A.P.(DIR Series) Circular No.64 April 28, 2009 32 A.P.(DIR Series) Circular No.65 April 28, 2009 33 A.P.(DIR Series) Circular No.71 June 30, 2009 ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... 13 April 24, 2012 66 A.P.(DIR Series) Circular No.119 May 07, 2012 67 A.P.(DIR Series) Circular No.134 June 25, 2012 68 A.P.(DIR Series) Circular No.136 June 26, 2012 69 A.P.(DIR Series) Circular No. 1 July 5, 2012 70 A.P.(DIR Series) Circular No. 20 August 29, 2012 71 A.P.(DIR Series) Circular No.26 September 11, 2012 72 A.P.(DIR Series) Circular No.27 September 11, 2012 73 A.P.(DIR Series) Circular No.28 September 11, 2012 74 A.P.(DIR Series) Circular No.39 October 9, 2012 75 A.P.(DIR Series) Circular No.40 October 9, 2012 76 A.P.(DIR Series) Circular No.48 November 6, 2012 77 A.P.(DIR Series) Circular No.54 November 26, 2012 78 A.P.(DIR Series) Circular No.58 December 14, 2012 79 A.P.(DIR Series) Circular No.59 December 14, 2012 80 A.P.(DIR Series) Circular No.60 December 14, 2012 81 A.P.(DIR Series) C ..... X X X X Extracts X X X X X X X X Extracts X X X X
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