LKI POSITION PAPER ON DTI PROPOSED RULE ON ILLEGAL PYRAMID SALES SCHEME

2019-09-29 00:23:44

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September 27, 2019


Consumer Protection and Advocacy Bureau

Department of Trade and Industry

Makati City


Subject: DAO on Article 53 of the Consumer Act


Sir/Madam:


Our comment on the proposed DAO.


  1. Lets us not use the word “pyramid “ in the DAO. By its common meaning , a pyramid is an illegal activity .

  2. In the engagement of stakeholders, it will be appropriate to mention consumer organizations, regional or national , duly recognized by the Department of Trade and Industry under the recently issued DAO in 2018 .

  3. We propose to limit the role of the members of the Direct Selling Association of the Philippines on a need basis as they could give rise to potential conflict of interest or directly in competition with entity that may be subject of investigation by the DTI.

  4. We propose to amend the SEC and DTI Memorandum of Cooperation and to enumerate which illegal activity/ies fall under the exclusive and primary jurisdiction of the DTI, SEC and to include also the Bangko Sentral ng Pilipinas .


Thank you .


Very truly yours,


Atty. Victorio Mario A. Dimagiba, AB, LLB, LLM

President


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