Republic of the Philippines 
HOUSE OF REPRESENTATIVES 
Quezon City 
NINETEENTH CONGRESS 
First Regular Session 
HOUSE BILL NO. _______ 
Introduced by HON. GUS S. TAMBUNTING 
AN ACT 
MANDATING BANKING INSTITUTIONS TO STRENGTHEN THE FINANCING SYSTEM 
FOR AGRICULTURAL, FISHERIES, AND RURAL DEVELOPMENT IN THE PHILIPPINES 
EXPLANATORY NOTE 
Based on 2019 data from Philippine Statistics Authority, the agriculture sector grossed around 
Php 800 billion in 2018, which contributed 8.1 percent of the country’s gross domestic product1. 
Despite this, agricultural growth did not even reach one percent (1%)—far from the projected 
target which is around 2-4%2. The Department of Agriculture has been trying to address this 
concern through the modernization of agriculture, promotion of exports, road and infrastructure 
development, higher budget allocation, and legislative support for proposed policies related to 
agricultural and rural development.3 Republic Act No. 10000 or the Agri-Agra Reform Credit Act 
of 2009 was enacted to promote rural development by enhancing access of the rural agricultural 
sector to financial services and programs that increase market efficiency and promote 
modernization in the rural agricultural sector. 
However, a study from the Philippine Institute for Development Studies recognized that there 
remains an unmet demand for credit, especially for landless farm workers who are also tilling the 
land4. Some challenges include tedious documentary requirements, lack of information on 
processes and awareness of financial institutions, and perceived high-interest rates on bank 
loans5. These challenges make it difficult for our farmers and fishermen to avail of the financing 
they desperately need to continue their business. Moreover, most financial institutions opt to pay 
mandated penalties than lend to beneficiaries from the agriculture sector due to the risk of non-
return of investments. These difficulties discourage farmers from growing their crops, which leads 
to a decrease in productivity in the agriculture sector.   
1 https://psa.gov.ph/sites/default/files/Selected%20Statistics%20on%20Agriculture%202019.pdf 
2 https://rappler.com/business/philippine-agriculture-misses-growth-target-2019 
3 https://rappler.com/business/william-dar-aims-agriculture-growth-double-income-farmers 
4 https://dirp4.pids.gov.ph/websitecms/CDN/PUBLICATIONS/pidsdps1648.pdf 
5 Ibid. 
September 5, 2022
9:03 am
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This measure is hereby proposed to make private financial institutions and programs more 
accessible to our local farmers and fisherfolk by creating a special fund that may be used to 
finance agricultural-related activities, capacity, and institution-building programs for rural 
cooperatives. This shall also establish a Finance and Capacity-Building Council which shall be 
responsible for the management, implementation, and assessment of the special fund and the 
identification of eligible beneficiaries and activities that may be financed by the fund.  
On behalf of the people of Parañaque City’s Second District, and for the common good of the 
Filipino people, the approval of the said measure is earnestly sought. 
REP. GUS S. TAMBUNTING 
2nd District, Parañaque City 


Republic of the Philippines 
HOUSE OF REPRESENTATIVES 
Quezon City 
NINETEENTH CONGRESS 
First Regular Session 
HOUSE BILL NO. _______ 
Introduced by HON. GUS S. TAMBUNTING 
AN ACT 
MANDATING BANKING INSTITUTIONS TO STRENGTHEN THE FINANCING SYSTEM 
FOR AGRICULTURAL, FISHERIES, AND RURAL DEVELOPMENT IN THE PHILIPPINES 
Be it enacted by the Senate and House of Representatives of the Philippines in Congress 
assembled: 
SECTION 1. Short Title. – This Act shall be known as "The Rural Agricultural and Fisheries 
Financing Enhancement System Act'. 
SEC. 2. Declaration of Policy. – It is hereby declared the policy of the State to promote 
inclusive and broad-based economic growth by ensuring equal access to opportunities under an 
environment of sustained growth and expanding productivity as the key to raising the quality of 
life for all. Towards this end, the State shall promote rural development by enhancing access of 
rural communities and agricultural and fisheries households to financial services and programs 
that increase productivity, enhance market efficiency, promote modernization and improve the 
welfare and economic prospects of beneficiaries in rural communities through active participation 
of banking institutions. 
SEC. 3. Definition of Terms. – As used in this Act, the following terms shall mean: 
(A)
Agrarian Reform Beneficiary (ARB) refers to a farmer who was granted land under
Presidential Decree No. 27, the Comprehensive Agrarian Reform Law, and Republic
Act No. 9700 or the "Comprehensive Agrarian Reform Extension with Reforms" and a
regular farm worker who is landless, irrespective of tenurial arrangement, who
benefited from the redistribution of land, regardless of crops or fruits produced, to
include the totality of factors and support services designed to lift the economic status
of the beneficiary and all other alternative arrangements to the physical distribution
of lands, such as production or profit sharing, labor administration, and the distribution
of shares of stock which will allow the beneficiary to receive a just share of the fruits
of the lands one works. The term shall also include registered agrarian reform
beneficiaries' cooperatives/associations/other farm groups, respectively endorsed as
comprising of agrarian reform beneficiaries by the nearest office of the DAR, as well
as ARB households.
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(B) 
Agrarian Reform Community (ARC) refers to a barangay or a cluster of barangays 
primarily composed and managed by agrarian reform beneficiaries who shall be willing 
to be organized and undertake the integrated development of an area and/or their 
organizations/cooperatives. 
 
(C) 
Agri-Business refers to agriculture and fishery-related activities that put farmers, 
fisherfolk processors, distributors, and consumers within a system that produces, 
processes, transports, markets, and distributes agricultural and fishery products. It 
encompasses input production, farm and fishery operations, and management, 
equipment and supplies manufacturing, food/non-food processing, trading, and 
retailing.  
 
(D) 
Agri-Tourism, also referred to as "Farm Tourism" under Republic Act No. 10816, refers 
to the practice of attracting visitors and tourists to farm areas for production, 
educational and recreational purposes. It involves any agricultural- or fishery-based 
operation or activity that brings to a duly-accredited farm tourism camp, visitors, 
tourists, farmers, and fisherfolk who want to be educated and trained on farming and 
its related activities.  
 
(E) 
Agricultural Lessee refers to any person who, with or without help from his/her 
immediate farm household, cultivates the land owned by another for a certain price in 
money, in produce, or both.  
 
(F) 
Agricultural or Fisheries Household - a household is considered to be an agricultural 
or fisheries household when at least one member of the household is a farmer, a 
fisherman, an agrarian reform beneficiary, a settler, an agricultural lessee, an 
amortizing owner, a farmworker, a fish worker, an owner-cultivator, a compact farmer, 
or a tenant farmer.  
 
(G) 
Agricultural Value Chain (AVC) refers to a set of actors/players, such as producers 
(farmers, fisherfolks), traders, suppliers, processors, and aggregators, who conduct a 
linked sequence of value-adding activities involved in converting an agricultural 
product from its raw material to final form and bringing it to consumers.  
 
Agricultural Value Chain Financing (AVCF) refers to financing to an AVC following the 
identification and analysis of AVC and the design of appropriate financial products and 
services for actors/ players that form part of the AVC.  
 
(H) 
Agro-Industry Modernization Credit and Financing Program (AMCFP) refers to the 
umbrella credit/financing program of the government for the agriculture and fisheries 
sector created under Republic Act No. 8435.  
 
(I) 
Amortizing Owners refer to landowners who amortize payment for the land to a private 
individual or the State. 
 
(J) 
Compact Farmers refer to those farmers with adjoining farms operating as a single 
unit under one management, farm plan, and budget.  


 
(K) 
Farmer refers to a natural person whose primary livelihood is the cultivation of land or 
the production of crops, agroforest products, or livestock, either by oneself or primarily 
with the assistance of their immediate farm household, whether the land is owned by 
them or by another person under a leasehold or share tenancy agreement or 
arrangement with the owner thereof.  
 
(L) 
Farmworker refers to a natural person who renders service for value as an employee 
or laborer in an agricultural enterprise or farm regardless of whether their 
compensation is paid on a daily, weekly, monthly, or "pakyaw" basis. The term 
includes an individual whose work has ceased as a consequence of, or in connection 
with, a pending agrarian dispute who has not obtained substantially equivalent and 
regular farm employment.  
 
(M) 
Farmers' Cooperatives refer to organizations composed primarily of small agricultural 
producers, farmers, farm workers, or other agrarian reform beneficiaries who 
voluntarily organize themselves for pooling land, manpower, technological, financial, 
or other economic resources, and operate on the principle of one member, one vote. 
A juridical person may be a member of a cooperative, with the same rights and duties 
as a natural person.  
 
(N) 
Farmer's and Fisherfolk's Organizations or Associations refer to farmer's and 
fisherfolk's cooperatives, associations, or corporations duly registered with appropriate 
government agencies and which are composed primarily of small agricultural 
producers, farmers, farmworkers, agrarian reform beneficiaries, fisherfolk who 
voluntarily join together to form business enterprises or non-business organizations 
which they own, control and patronize.  
 
(O) 
Farm-To-Market Road refers to a road linking the agriculture and fisheries production 
sites, coastal landing point, and post-harvest facility to the market and arterial road 
and highway.  
 
(P) 
Financial Services refer to services extended by banks/financial institutions such as 
but are not limited to, credit/lending, deposits, rediscounting, and insurance.  
 
(Q) 
Fisherfolk refers to people directly or personally and physically engaged in catching 
and/or culturing and processing fishery and/or aquatic resources.  
 
(R) 
Fish worker refers to a person whether or not regularly employed in commercial fishing 
and related industries, whose income is either from wages, profit sharing, or stratified 
sharing basis, including those working in fish pens, fish corral/traps, fishponds, prawn 
farms, sea farms, salt beds, fish ports, fishing boat or trawlers, or fish processing 
and/or packing plants, but excluding administrators, security guards and overseers. 
 
(S) 
Green Finance refers to financial services and products designed to promote the flow 
of finance toward green economic activities and projects. Aside from financing to 
promote climate change adaptation and mitigation, green finance also covers 


environmental improvement and efficiency improvement in natural capital 
preservation and resource mobilization.  
 
(T) 
Micro, Small, and Medium enterprises (MSME) refer to any business activity or 
enterprise defined as such under existing laws.  
 
(U) 
Newly-Established Bank refers to a domestic or foreign bank without a banking 
presence in the Philippines before the issuance of its certificate of authority to operate. 
It shall not include banks that have been formed through the acquisition, purchase of 
ownership of the voting stock of an existing domestic bank, or the merger or 
consolidation of banks.  
 
(V) 
Owner-Cultivators refer to natural persons who own lands by purchase, inheritance, 
or land distribution by the State. Owner-Cultivators can operate the farm themselves, 
supervise wage labor, or delegate operations to farmers.  
 
(W) 
Philippine Crop Insurance Corporation (PCIC) refers to a government-owned and -
controlled corporation that provides insurance protection to the country's agricultural 
producers, particularly the subsistence farmers against crop losses arising from natural 
calamities such as typhoons, rising sea levels, floods, drought, earthquakes, volcanic 
eruptions, plant diseases and pest infestation, and non-crop agricultural asset losses 
due to perils for which the asset has been insured against.  
 
(X) 
Post-Harvest Activities refer to threshing, drying, milling, grading, storing, and 
handling of products and other activities of a similar nature such as stripping, 
winnowing, chipping, and washing.  
 
(Y) 
Post-Harvest Facilities refer to threshers, moisture meters, dryers, weighing scales, 
milling equipment, fish ports, fish landings, ice plants and cold storage facilities, 
processing plants, warehouses, buying stations, market infrastructure and 
transportation facilities, and such other facilities, supporting post-harvest activities.  
 
(Z) 
Public Rural Infrastructure refers to infrastructure in rural communities such as 
highways, streets, bridges, tunnels, railways, railroads, transport systems, ports, 
airports, hydropower projects, canals, dams, irrigation, government buildings and 
housing projects, public schools, public hospitals, public health centers, public 
markets, slaughterhouses, warehouses, solid waste management, sewerage, flood 
control, drainage, dredging, and other similar infrastructure projects.  
 
(AA) 
Rural Community refers to areas that are defined as such by the Philippine Statistics 
Authority (PSA).  
 
(BB) 
Rural Financial Institution (RFI) refers to any financial institution established and 
operating in a rural community.  
 
(CC) 
Settlers refer to persons who range from the forest-clearing pioneers, including 
indigenous people, with a subsistence economy to the better equipped and more 
experienced farmers. 


 
(DD) 
Tenant Farmer refers to one who cultivates another's land under a sharing or leasehold 
agreement. 
 
ARTICLE II 
AGRICULTURAL FISHERIES AND RURAL FINANCING SYSTEM 
 
SEC. 4. Agriculture, Fisheries and Rural Financing System. – There shall be an agricultural, 
fisheries, and rural financing system to improve the welfare, competitiveness, income, and 
productivity of the rural community beneficiaries, particularly the farmers, fisherfolk, agrarian 
reform beneficiaries, agrarian reform communities, settlers, agricultural lessees, amortizing 
owners, farmworkers, fish workers, owner-cultivators, compact farmers, tenant farmers, and 
members of their households and their MSMEs, as well as farmers and fisherfolk's cooperatives, 
organizations and associations, through government and private banking institutions. 
 
Agricultural, fisheries, and rural financing, as used herein, shall consist of loans, investments, and 
grants to finance activities that shall enhance productivity and increase the income of an 
agricultural and fisheries household, thereby promoting agricultural sector productivity and 
competitiveness, as well as sustainable development of rural communities. These shall include, 
but not be limited to, activities identified under the AMCFP as enumerated under Chapter 3 Section 
23 of Republic Act No. 8435, off-farm/fishery activities, agricultural mechanization/ 
modernization, Agri-tourism, green finance projects, acquisition of lands authorized under the 
Agrarian Reform Code of the Philippines and its amendments, efficient and effective marketing, 
processing, distribution and storage of agricultural and fishery commodities, public rural 
infrastructure, as well as programs that shall address the developmental needs of rural 
communities, such as but not limited to, projects that promote the livelihood, skills enhancement, 
and other capacity-building activities of the rural community beneficiaries and all other activities 
consistent or analogous to the foregoing, as may be determined by the Agricultural and Fisheries 
Finance and Capacity-Building Council (AFFCC).  
 
SEC. 5. Rural Community Beneficiaries. – The financing mentioned in the preceding section 
shall be extended to the rural community beneficiaries named therein or to cooperatives, 
associations, MSMEs, or organizations in good standing of such beneficiaries, regardless of 
capitalization based on the feasibility of the project and their paying capacity, their estimated 
production, and/or securities they can provide as well as such assets as may be acquired by them 
from the proceeds of the loan, investments, and grants.  
 
SEC. 6. Credit Quota. – All banking institutions, whether government or private, except newly-
established banks for a period of five (5) years from the date of commencement of the banks' 
operations, shall set aside a credit quota, or a minimum mandatory agricultural and fisheries 
financing requirement of at least twenty-five percent (25%) of their total loanable funds.  
The total loanable funds generated by a banking institution shall be defined by the BSP. During 
the first year of effectivity of this Act, the total loanable funds generated shall be computed 
starting from 20 April 2010, the effectivity of Republic Act No. 10000, after which the bank's total 
loanable funds shall be determined based on funds generated starting from the second year of 
effectivity of this Act.  
 


SEC. 7. Modes of Compliance. – Banks may comply with the mandatory credit requirement by 
lending to rural community beneficiaries, to finance agricultural and fishery-related activities 
identified under the AMCFP as enumerated under Chapter 3 Section 23 of Republic Act No. 8435, 
off-farm/fishery activities, agricultural mechanization/modernization, Agri-tourism, green finance 
projects, marketing, processing, distribution and storage of agricultural and fishery commodities, 
livelihood projects, skills enhancement or capacity-building programs.  
 
Banks may also comply with the mandatory financing requirement through other means as 
follows: 
 
a) Invest in debt securities, including those issued by the Development Bank of the 
Philippines (DBP) and the Land Bank of the Philippines (LBP): Provided, That the proceeds 
from said debt securities shall be used to finance activities under Section 4 hereof: 
Provided, further, That the proceeds from debt securities issued by the DBP and the LBP 
shall be separately accounted for and shall not be considered for purposes of computing 
the loanable funds under Section 6 hereof of the said banks; 
b) Open deposit accounts with rural financial institutions: Provided, That the deposit 
accounts shall be separately accounted for by the depository bank and shall not be 
considered for purposes of computing the loanable funds under Section 6 hereof of the 
said banks; 
c) Rediscount with banks eligible paper covering agriculture, fisheries, and agrarian reform 
credits: Provided, That rediscounted paper shall no longer be eligible as compliance on 
the part of the originating bank; 
d) Invest directly in shares of stock of rural financial institutions, subject to prevailing laws, 
rules or regulations, or lend wholesale to rural financial institutions: Provided, That the 
wholesale loans shall be credited as compliance of the bank acting as wholesale lender 
alone; 
e) Lend for the construction and upgrading of infrastructure, including but not limited to, 
farm-to-market roads, as well as the provision of post-harvest facilities and other public 
RURAL infrastructure that will benefit the agriculture, fisheries, and agrarian reform 
sector; 
f) Lend to agri-business enterprises that maintain agricultural commodity supply-chain 
arrangements directly with rural community beneficiaries; 
g) Undertake agricultural value chain financing to actors/ players in the AVC that benefits 
rural communities; and 
h) Invest in shares of stock of the PCIC or in companies that primarily engage in activities 
under Section 4 hereof that benefit rural community beneficiaries: 
 
Provided That, the loans and investments that are counted as compliance are not funded by 
proceeds from the issuance of debt securities, and/or lending of other banks that have been 
counted as compliance with the mandatory credit: Provided Further, that loans to finance 
activities that shall generally benefit agrarian reform beneficiaries, agrarian reform communities, 
or other priority sectors, as may be determined by the AFFCC, shall be counted at not more than 
ten times (10x) their outstanding amount, or as otherwise prescribed by the BSP, for purposes of 
determining compliance with the mandatory agricultural and fisheries financing requirement.  
 


SEC. 8. The modes of compliance enumerated in the preceding section shall be subject to review 
by the AFFCC to alter implementation to determine whether these are adequate to support the 
financing requirements of rural communities and recommend to Congress for appropriate action.  
 
SEC. 9. Annual Reports. – The BSP shall furnish reports on compliance with the mandatory 
agricultural and fisheries financing requirement to Congress every year. The BSP shall, as part of 
its regulatory functions, monitor the compliance of the banks with the requirements of this Act.  
 
SEC. 10. Penalty Clause. – The BSP shall impose administrative sanctions and other penalties 
on the lending institutions for violation of any of the provisions of this Act. Penalties for non-
compliance or under-compliance with the mandatory agricultural and fisheries financing 
requirement shall be computed at one-half of one percent (0.5%) of non-compliance or under-
compliance, or rates prescribed by the BSP Monetary Board. Upon collection of the penalties, the 
BSP shall remit the same to the AFFCC for deposit to the special fund created under Article III of 
this Act. Ten percent (10%) of the penalties collected shall be retained by the BSP to cover 
administrative expenses. 
 
ARTICLE III 
AGRIBUSINESS MANAGEMENT CAPACITY AND INSTITUTION-BUILDING FUND AND PROGRAM 
 
SEC. 11. There shall be created an Agribusiness Management Capacity And Institution-Building 
Fund (Special Fund) to finance agricultural- and fishery-related activities as well as organizational-
, capacity- and institution-building programs of cooperatives and other duly-registered 
organizations of rural agricultural and fisheries households. The Special Fund shall be sufficient 
to ensure the effective implementation of the aforementioned activities and programs. For this 
purpose, banks may comply with the mandatory credit requirement by providing contributions to 
the Special Fund.  
 
SEC. 12. The initial amount of the Special Fund shall at least be Pl0 billion and shall include 
penalties due from banks on their non-compliance or under-compliance with the mandatory Agri-
Agra credit requirement under Republic Act No. 10000, collected alter the effectivity of this Act, 
net of the ten (10) percent amount to be retained by the BSP. In case of a shortfall, the banks 
shall advance a maximum amount of P2 billion, which shall be chargeable against future penalties 
under this Act, and shall not be considered as a mode of compliance under Section 11 hereof.  
 
SEC. 13. The AFFCC shall enter into an agreement with the banking industry on the management 
of the Special Fund as well as the implementation of the activities and programs of the Special 
Fund, by the approval of and guidelines prescribed by the AFFCC. The agreement shall also 
require the banking industry to monitor and evaluate the activities financed by the Special Fund, 
and report its findings to the AFFCC.  
 
SEC 14. Banks, duly-registered training and capacity-building organizations, cooperatives, and 
other duly-registered organizations of, or that support rural agricultural and fisheries households 
may apply with the AFFCC for funding for their capacity and institution-building programs and 
activities.  
 
 
 


 
 
ARTICLE IV 
AGRICULTURAL AND FISHERIES FINANCE AND CAPACITY-BUILDING COUNCIL (AFFCC) 
 
SEC. 15. Agricultural and Fisheries Finance and Capacity-Building Council (AFFCC). – 
There shall be created an Agricultural and Fisheries Finance and Capacity-Building Council 
(AFFCC) which shall be composed of the  designated representatives of the following 
agencies/groups/sectors :  
 
1. the Department of Agriculture (DA), as Chair; 
2. the Bankers Association of the Philippines (BAP), as Vice Chair; 
3. the Bangko Sentral ng Pilipinas (BSP);  
4. the Department of Agrarian Reform (DAR);  
5. the Cooperative Development Authority (CDA);  
6. the Land Bank of the Philippines (LBP);  
7. the Development Bank of the Philippines (DBP); and  
8. Nine (9) representatives from the private sector as members, one of whom shall be 
appointed as Vice-Chair. The private sector representatives shall include the heads or their 
designated representatives of the Rural Bankers Association of the Philippines (RBAP); the 
Chamber of Thrift Banks (CTB); the Cooperative Banks Federation of the Philippines 
(BANGKOOP); the Microfinance Council of the Philippines, Inc. (MCPI); the Philippine 
Chamber of Commerce and Industry (PCCI); and a representative each from the 
cooperative sector, the farmers, and the fisherfolk sector.  
 
SEC. 16. Powers/ Duties and Functions of the AFFCC. – The AFFCC shall have the following 
powers, duties, and functions: 
 
a) to set the target amount for the Special Fund to meet the organizational- and capacity-
building requirements of cooperatives and other duly- registered organizations of rural 
agricultural and fisheries households over a period of ten (10) years; 
b) to determine the annual requirement of the Special Fund;  
c) to identify eligible recipients of the Special Fund; 
d) to identify eligible agricultural- and fishery-related activities and capacity-building 
programs that may be financed by the Special Fund; 
e) to ensure the effective implementation and programs financed by the Special Fund; 
f) to periodically assess the adequacy of the fund capital in financing the capacity-building 
requirements of rural cooperatives and other duly- registered organizations of rural 
agricultural and fisheries households; and 
g) to ensure compliance with the reporting, monitoring, evaluation, and audit requirements 
of the Special Fund and activities financed. 
 
ARTICLE V 
MISCELLANEOUS PROVISIONS 
 
SEC. 17. Audit. – The Special Fund shall be audited by the Commission on Audit (COA) by 
existing auditing laws, rules, and regulations.  


SEC. 18. Oversight Committee. – There shall be an oversight committee to oversee the 
implementation of this Act composed of the following:  
1. A Member of the House of Representatives to be designated by the House of 
Representatives as Chair;  
2. A Member of the Senate to be designated by the Senate as Vice-Chair;  
3. A representative from the Office of the President; and   
4. Two representatives from the Commission on Audit (COA) 
SEC. 19. Sunset Provisions. – The provisions related to the mandatory credit quota under 
Article II as well as the management and administration of the special fund under Article III shall 
cease to have an effect, ten (10) years from approval of this Act.  
SEC. 20. Repealing Clause. – The provisions of Republic Act No. 10000, Executive Order No. 
113, and any other laws, presidential decrees, executive orders, rules, and regulations, or parts 
thereof inconsistent with the provisions of this Act are hereby repealed or modified accordingly.  
SEC. 21. Separability Clause. – If any part, section, or provision of this Act is held invalid or 
unconstitutional, other provisions not affected thereby shall remain in force and effect.  
SEC. 22. Transitory Provision. – The BSP shall promulgate such rules and regulations as may 
be necessary to implement Articles I and II of this Act within ninety (90) days after the effectivity 
of this Act. Before the effectiveness of the implementation of rules and regulations of Articles, I 
and II of this Act, the provisions of Republic Act No. 10000 shall remain in force. 
The BSP shall organize a Task Force which shall promulgate such rules and regulations as may 
be necessary to implement Articles III and IV of this Act within ninety (90) days after the 
effectivity of this Act.  
SEC. 23. Effectivity. – This Act shall take effect fifteen (15) days after its publication in the 
Official Gazette or a newspaper of general circulation. 
Approved,