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

Cell No. : +63
917-812-5546

Email :
labankonsyumer@gmail.com

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Konsyumer Inc.

Website :
www.labankonsyumer.com

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