Chapter 1: General Concepts
receivables or other obligations
Definition
Banks entities engaged in the lending of funds obtained in
the form of deposits. It is required that banks are stock
corporation and that its funds are obtained from the public
(deposits of 20 persons or more)
Banks moneyed institute founded to facilitate the
borrowing, lending, and safekeeping of money and to deal in
notes, bills of exchange and credits
Banks any person engaged in the business carried on by
banks of deposit, of discount, or of circulation is doing a
banking business, although but one of these function is
exercised
Quasi-Banks
Quasi-banking entities engaged in the borrowing of funds
through issuance, endorsement, or assignment with
recourse or acceptance of deposit substitutes for purposes
of relending or purchasing of receivables and other
obligations
Deposit substitutes alternative forms of obtaining funds
from the public, other than deposits, through the issuance,
endorsement, or acceptance of debt instruments for the
borrowers own account, for the purpose of relending or
purchasing or receivables and other obligations
Universal Banks and Commercial Banks may exercise quasi-
banking functions without securing prior authority from the
Monetary Board while other banks must secure such
authority
Quasi-banking elements:
o Borrowing funds for the borrowers own account
o Twenty (20) or more lenders at any one time
o Methods of borrowing are issuance, endorsement, or
acceptance of debt instruments of any kind
o Purpose of which is to relending or purchasing
NOT Quasi-banking if the borrowing is made by
commercial, industrial and other non-financial companies for
the limited purpose of financing their own needs or the needs
of their agents or dealers
NOT Quasi-banking institution is engaged in buying and
selling of without recourse instruments
Nature of Business
Public confidence is the anchor of any banking system
Banking business is in the nature of public trust
Utmost Diligence
Required to exercise utmost diligence in the handling of
deposits
Strikes and Lockouts
Any strike or lockout involving banks, if unsettled after 7
calendar days shall be reported by the BSP to the Secretary
of Labor who has 2 options:
o He may assume jurisdiction over and decide the
dispute
o He may certify the same to the National Labor
Relations Commission for compulsory arbitration
Law allows the President of the Philippines to, at any time,
intervene and assume jurisdiction over such labor dispute in
order to settle or terminate the same
Presidents or Chief Executive Officers of banks are required
to immediately inform the Deputy Governor of the
Supervision and Examination Section of the BSP on the
status of the strike and lockout in their bank stating the
cause thereof, the banks position on its legality and the bank
operations affected thereby
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Governing Law
Banks are governed by RA No. 8791 aka General Banking
Law of 2000
Took effect on June 13, 2000
RA No. 7653 aka The New Central Bank Act prevails over
general laws, like the Corporation Code, in the regulation of
banks
Primary law of Rural Banks is RA 7353
Primary law for Thrift Banks is RA 7906
Law for Islamic Banks is RA 6848

Authority To Operate
Incorporation Stage: Banking or Quasi-banking corporation
cannot be incorporated without the authority from the
Bangko Sentral ng Pilipinas
Operation: An entity performing banking or quasi-banking
function cannot operate without a certificate of authority from
the BSP
Determination of whether a person or entity is performing
banking or quasi-banking functions without BSP authority
shall be decided by the Monetary Board
Monetary Board shall resolve, through the appropriate
supervising and examining department of the BSP, by
examining, inspecting or investigating the books and records
of such person or entity

Cases
Republic of the Philippines vs. Security Credit and
Acceptance Corporation, et al
Central Bank of the Philippines vs. the Honorable Judge
Jesus P. Morfe, et al

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Chapter 2: Classification of Banks
Universal Banks
Universal Banks have the authority to exercise, in addition
to the powers of a commercial bank, powers of an
investment house, and the power to invest in non-allied
enterprises
Has the power to own up to 100% of the equity in a thrift
bank, rural bank, financial allied enterprise, or a non-financial
allied enterprise
In case of publicly listed universal banks, the power to own
up to 100% of the voting stock of only one other universal
bank or commercial bank
Required to offer to sale equity shares to the public
stockholders
Public stockholders refer to all stockholders excluding the
banks directors, shareholders owning up to 20% or more of
the banks subscribed capital stock together with those of
their relatives within the fourth degree of consanguinity or
affinity, and corporations controlled or affiliated with them
Required minimum public stock offering is 10% of the
required minimum capital
Investment House
Investment House enterprise which engages or purports to
engage, whether regularly or on an isolated basis, in
underwriting of securities of another person or enterprise
Underwriting of securities act or process of guaranteeing
distribution and sale within the Philippines of securities of the
Government or its instrumentalities
Universal Bank may perform the functions of an investment
house directly or indirectly through a subsidiary investment
house; subjected to the following rules:
o Underwriting or equity securities and securities
dealing shall be subject to the pertinent laws and
regulations of the Securities and Exchange
Commission
o If the investment house functions are performed
directly by the universal bank, such functions shall
be undertaken by a separate and distinct department
or other similar unit in the bank
o It cannot perform functions of an investment house
both directly and indirectly. This means that if it
already exercises the functions of an investment
house through a subsidiary, the universal bank can
no longer open a department or a unit within the
same bank to act as an investment house
Non-allied Enterprise
Broad category of non-allied undertakings in which a
universal bank may invest directly or through its subsidiary
shall require prior approval of the Monetary Board
No prior approval is necessary if investment is to be made in
any of the following broad categories:
o Enterprise engaged in physically productive activities
in agriculture, mining and quarrying, manufacturing,
public utilities, construction, wholesale trade and
community and social services following the
industrial groupings in the Philippine Standard
Industrial Classification
o Industrial park projects and/or industrial estate
developments
o Financial and commercial complex projects arising
from or in connection with Governments
privatization program
o Such other broad categories as the Monetary Board
may declare as appropriate
Commercial Banks
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 Commercial banks perform general powers incident to
corporations and investment banking
Functions: accepting drafts; issuing letters of credit;
discounting and negotiating promissory notes, drafts, bills of
exchange, and other evidences of debt; accepting or
creating demand deposits; receiving other types of deposits
and deposits substitutes; buying and selling foreign
exchange and gold or silver bullion; acquiring marketable
bonds and other debt securities; extending credit, subject to
the rules of Monetary Board
Cooperative Banks
Cooperative Banks organized primarily to provide financial
and credit services to cooperatives. It may perform any or all
services provided by a rural bank
Membership of a cooperative bank shall include ONLY
cooperative and federations of cooperatives
Rural Banks
Rural banks banks that promote rural development
Thrift Banks
Thrift banks encourages the industry, frugality and
accumulation of savings of the public
Islamic Banks
Islamic banks promote socio-economic development in
autonomous region by performing banking and investing
function based on Islamic concept of banking
Other Banks
Government-owned and controlled that are created by
special laws for specific purposes
Philippine Veterans Bank created to provide government
depository to veterans for appreciation of grateful nation
Land Bank of the Philippines finance distribution of estate
to resale to small landowners
Development Bank of the Philippines provide credit
facilities for development in agriculture, commerce, and
industry
Foreign Banks
Entry of foreign banks in the Philippines through the
establishment of branches shall be governed by the
provisions of the Foreign Banks Liberalization Act
To create a more competitive environment and encourage
greater foreign participation
Philippine laws shall not reply to the following matters:
o Creation, formation, organization, or dissolution of
corporations
o Fixing of the relations, liabilities, responsibilities
o Duties of stockholders, members, directors or
officers of corporations to each other or to the
corporation
MB may revoke:
o Foreign bank is insolvent
o Imminent danger of insolvency
o Its continuance in business will involve probably loss
to those transacting with it
License must be renewed or reissued again
Foreign banks may enter in the Philippines with prior
approval of the BSP through the following modes:
o Acquiring, purchasing or owning up to 60% of the
voting stock of an existing domestic bank
o Investing in up to 60% of the voting stock of a new
banking subsidiary incorporated under the laws of
the Philippines
o Establishing branches with full banking authority
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Chapter 3: Deposit Function
Bank
Basic functions: acceptance of deposits from the public and
lending the funds obtained from deposits
Not a bank if deposit function is absent
Although other entities or persons may extend loans, they
will not be considered performing banking business if they do
not accept deposits from the public
Voluntary Creditor-Debtor Relationship
Contract of loan contract entered into between bank and
depositor
Depositor one who pays money into the bank in the usual
course of business, to be placed to his credit, and subject to
his check or beneficiary held by the bank
Voluntary Agreement
Contracts by their nature are voluntary
May be liable only if the non-acceptance is discriminatory or
contrary to law, morals, and good customs
Bank is not bound to receive deposits from any one, but may
choose those whom it will accept as depositors and the
terms and conditions on which it will accept deposits
BSP instructed banks to adopt Know-Your-Customer
standards
Basic rule in the Manual of Regulations for Banks is for the
depositor to submit necessary specimen signatures and
proper documents for identification
Capacity of Depositor
Incapacitated persons are generally not allowed to open an
account with the bank
Minors are allowed to open savings and time deposits
provided that they are:
o At least 7 years of age
o Able to read and write
o Have sufficient discretion
Married women are allowed to open bank accounts without
the assistance of their husbands. Women of legal age,
regardless of civil status, shall have the capacity to act and
enter into contracts
Corporations are required to open an account before its life
commences. Life starts from the issuance of the Certificate
of Incorporation by the Securities and Exchange
Commission which can only be issued upon the approval of
the Articles of Incorporation
Bank as Debtor
Bank has no duty to preserve the amount deposited
Money deposited belongs to the bank and may be used for
any lawful purpose as it may deem fit
Since the contract is governed by rules on simple loan and
not contract of deposit, the money received by the bank is
not being held for safekeeping for the depositor
Relationship: creditor(client)-debtor(bank)
o Bank can make use of the money deposited. Amount
is not being held in trust for the depositor nor is it
being kept for safekeeping
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 o Third persons who may have the right to the money
deposited cannot hold the bank responsible unless
there is a court order or garnishment
o Banks deposits are not preferred credits under the
Civil Code
o Bank has the right to compensation
Obligation of the bank is to return the same value to the
depositor and not to return exactly the same thing that was
given
Legal Compensation
Bank has the right to set off the deposits in its hands for the
payment of the indebtedness of the depositor provided that
all the requisites for a valid legal compensation are present
If the indebtedness was the result of payment against
uncollected deposit of checks, the bank may debit another
account of the depositor in the same bank if the account
where the check was originally deposited is already closed
If a depositor placed a time deposit in a bank, the depositor
has the right to expect that the bank accurately recorded his
transactions with it
Deposit Not Trust Under The Civil Code
Banks relationship with the depositor is not a trustor-trustee
relationship under Title V of the New Civil Code
In a deposit, the bank becomes the owner of the cash that
was deposited subject to the obligation to pay the depositor
Basic Obligations To Depositor
Depository bank owns the deposited monies in the account
of the depositor because the deposit of money in banks is
governed by the Civil Code provisions on simple loan
Even though the depository bank owns the deposits, it
cannot prevent the depositor from demanding payment of
the depository banks obligation
Unilateral Freezing Of Account Not Allowed
Person whose name appears as depositor in the passbook
and other bank documents is presumed to be the owner of
the money in the bank account
Depository bank does not have a unilateral right to freeze the
accounts of its depositor based on its mere suspicion that
the funds therein were proceeds of fraudulent acts.
Banks do not owe any obligation to third persons another
reason why banks cannot likewise freeze the account of its
depositor to honor the claim of third persons
Article 559 does not apply
Liability For Trust Account
Bank cannot stop the withdrawal of funds from an account
on the basis of an allegation that the money deposited in the
account is held in trust by the depositor for another person
and that the withdrawal is in breach of such trust
Cause Of Action Against Banks In Case Of Breach Of Trust
A bank may be held liable if it took part in committing the
fraudulent act
Dishonest Assistance
Requisites for dishonest assistance:
o There must be a trust or other fiduciary relationship
o There must be a breach of trust
o Person upon whom liability is to be imposed must as
a matter of fact have been an accessory or assisted
in the misfeasance or breach of trust
o Accessory must be dishonest
Knowing Receipt
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 Another exception involving disposition in breach of trust that
is recognized in common law is when there is knowing
receipt
Under this exception, claimant must show the ff:
o Disposal of the claimants assets in breach of
fiduciary duty
o Beneficial receipt by the defendant of assets which
are traceable as representing assets of the claimant
o Knowledge on the part of the defendant bank that
the assets he received are traceable to a breach of
fiduciary duty
Court Order Or Garnishment
Bank may be liable if there is already a court order which
recognizes the right or third person or which effectively
prohibits the bank from releasing funds from the account
Effect of Insolvency On Deposit
In the excess amount covered by the insurance (provided by
PDIC), the deposit is treated as an ordinary unsecured credit
Kinds Of Deposits
Demand Deposits liabilities of banks which are
denominated in Philippine currency and are subject to
payment in legal tender upon demand by presentation of
checks
o Only universal banks or commercial banks can
accept or create demand deposits. Other banks
cannot accept unless MB approves.
Savings Account has an investment feature because
savings accounts are normally opened for the purpose of
earning interest
Negotiable Order Of Withdrawal Accounts (NOW) interest-
bearing deposit accounts that combine the payable on
demand feature of checks and investment feature of savings
accounts
Time Deposits payment of which generally cannot legally
be required within a specified number of days. No time
deposit shall be accepted for a term of less than 30 days.
o Minimum maturity is 731 days
Solicitors
Bank may be authorized by the BSP to solicit and accept
deposits outside the bank premises through deposit solicitors
Passbook shall be returned to the depositor not less than the
following business day
Deposit
Contract of loan is real contract
Deposit slips proof that an amount was deposited in an
account
Bank must exercise due diligence in proper validation of
bank deposits
Withdrawal
When cash is deposited in the account, the depositor can
withdraw the amount at any time provided that he complies
with the prescribed procedure
Demand deposits withdrawn through duly issued checks
Savings account presenting deposit slips duly signed by
the depositor
Bank is liable if it allows withdrawal of funds on the basis of
forged signatures in withdrawal slips
Combo Plan account depositor maintains a saving account
and a checking account with the same bank and agree that
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 funds may be automatically transferred from the savings
account
Effect Of Miscredit
Depositor is entitled to recover from the bank the amount
which was erroneously deducted from his account and
without his authority
Depositor has no right to withdraw the amount which was not
actually deposited
Consumer Protection
BSP requires banks to establish and maintain
comprehensive information security program and ensure that
they are properly implemented and strictly enforced
Interest On Deposits
Demand, savings, NOW accounts, time deposits and deposit
substitutes shall not be subjected to interest ceilings
Interest or yield on time deposit/deposit substitute may be
paid at maturity or upon withdrawal or in advance. However,
interest or yield paid in advance shall not exceed the interest
for 1 year
Matured Time Deposits/Deposit Substitutes
Time deposit not withdrawn or renewed on its due date shall
be treated as a savings account and shall earn interest from
maturity to the date of actual withdrawal or renewal at a rate
applicable to savings deposits
A deposit substitute instrument not withdrawn or renewed on
its maturity date shall from said date become payable on
demand and shall earn an interest or yield from maturity to
actual withdrawal or renewal at a rate applicable to a deposit
substitute with a maturity of 15 days
Disclosure Requirement
Banks are required to disclose to depositors the ff
information on interest computation and payments:
o Type/kind of deposit
o Nominal rate of interest and period covered
o Manner of interest payment i.e. whether credited in
advance or otherwise
o Basis of interest payment
o Effective rate of interest
Joint Accounts
Joint accounts whenever 2 or more persons open an
account
Presumed that depositors own equal shares in the deposit
Anonymous Accounts
Anonymous accounts accounts under fictitious names
Exception: Foreign Currency Deposit Act where the law
allows the opening of numbered accounts for foreign
currency deposits
Deceased Depositor
If a depositor dies, heirs cannot withdraw the balance of the
account unless the estate of the deceased is settled
A bank that is aware of a depositors death must not allow
withdrawal of the balance of the account unless a certificate
of payment of the estate tax is submitted
o Exception: allows the withdrawal not exceeding
P20,000
Survivorship Agreements
In case of death of one the depositors in a joint account, it is
presumed that the depositors own the account share and
share-alike
Survivorship agreement contract supported by
consideration where the joint depositors agree to permit
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 either of them to withdraw the whole deposit during their
lifetime and transferring the balance to the survivor upon the
death of one of them
Closure Of Accounts
Bank can expressly reserve the right to close an account
(even without prior notice) whenever certain identified events
will occur
Duty Of Care
Banks are required to exercise the highest degree of care in
the handling of deposits by their clients
Garnishment
Secrecy Of Bank Deposits
RA No. 1405
To encourage deposit in banking institutions
To discourage private hoarding so that bans may lend such
funds and assist in the economic development of the country
Do not apply to foreign currency deposits whether owned by
Filipinos or aliens
Deposits Covered
All bank accounts of whatever nature
Investments in bonds issued by the Philippine government,
its branches, and institutions
Exceptions
When there is written permission of the depositor or investor
Impeachment cases
Upon the order of a competent court in cases of bribery or
dereliction of duty of public officials
Upon the order of a competent court in cases where the
money deposited or invested is the subject of litigation
Cases involving unexplained wealth
Inquiry by the Commissioner of Internal Revenue for the
purpose of determining the net estate of a deceased
depositor
Money laundering
Dormant deposits for at least 10 years under the Unclaimed
Balances Act
Upon order of Court of Appeals when there is probable
cause under the Human Security Act
Inquiry or examination by the PDIC/BSP
Garnishment of bank deposits does not violate RA 1405
When a bank account is garnished, no real inquiry is made
on the account and the disclosure of the deposit made by the
bank is purely incidental
Foreign currency are exempt from attachment or
garnishment
Bank is not liable whenever it releases the amount garnished
as ordered by a court of competent jurisdiction
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Deposit Insurance
Governed by RA No. 3591 created Philippine Deposit
Insurance Corporation which administers the mandatory
deposit insurance system in the country
Rationale
Provides a safety net to depositors against the risk of losing
the amount they deposited with a bank
Safety net contributes to economic stability because it
prevents bank runs in times of financial instability
Covered Banks
All banks and banking institutions which are engaged in the
business of receiving deposits are mandatorily insured with
the PDIC
Insured Deposit
Insured deposit does not exceed P500,000
If the deposit is less than P500,000, it is covered by the
insurance
Even foreign currency deposits are covered by the insurance
Separate Deposits In Branches
Sum of all deposits in all branches in the Philippines shall be
used in determining if the deposit exceeds P500,000
Excluded however the deposits in foreign branches of the
same bank
Same Right And Capacity
PDIC will add all deposits in the bank maintained in the
same right and capacity for his benefit either in his own
name or in the name of others
In Joint Accounts
Joint accounts shall be insured separately from any
individually-owned deposit account
Maximum insured deposit shall be divided into as many
equal shares
However total amount of the share in each joint-account
should not exceed P500,000
If the account is held by a juridical person or entity jointly
with one or more natural persons, the maximum insured
deposit shall be presumed to belong entirely to such juridical
person or entity
Kinds Of Deposits
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 Law does not make distinction as to the type of deposit that
is insured
Covers all deposit accounts
Deposit Not Covered By Insurance
Excess of P500,000
Deposit in foreign branches
Investment products such as bonds and securities, trust
accounts, and other similar instruments
Deposit accounts or transactions that are unfounded,
fictitious, or fraudulent
Deposit accounts or transactions constituting unsafe and
unsound banking practices
o Determined by PDIC with BSP consultation
Proceeds of an unlawful activity
Deposit accounts that resulted from splitting of deposits
Risks Insured Against
Risk involved is the closure and takeover of the bank by the
Monetary Board (under BSP)
PDIC shall take charge of the bank assets and liabilities of a
bank upon:
o Bank is unable to pay its liabilities
o Bank has insufficient realizable assets
o Bank cannot continue in business without involving
probable losses
o Bank has willfully violated a cease and desist order
involving acts which amount to fraud and dissipation
of the assets
Filing Of Claim
Depositor is required to file a claim within 2 years from actual
takeover of the bank
Notice shall be published in a newspaper of general
circulation that the depositor is already required to file a
claim
If such a claim is made, PDIC is required to pay the
depositor within 6 months from the filing of the claim.
Responsible PDIC officer may be held criminally liable if the
claim is not settled within such period
Failure on the part of the depositor to file a claim, depositor
is no longer entitled to the insurance proceeds
Computation Of Claims
Insured amount = Deposit + Interests Unpaid Obligations
WHT
Interest Computation
6% - from the time it is judicially demanded
Remedy For Denial Of Insurance Claim
No appeal is given under the law on the denial of an
insurance claim by PDIC
Decision of PDIC is final and executor
Only remedy: special civil action for certiorari
Remedy Of Depositors For Amount In Excess Of Coverage
If PDIC paid an insurance claim of P500,000 but the deposit
is more than such amount, the depositor may claim the
balance from the remaining assets upon liquidation of the
closed bank
Uncovered deposit insurance is considered as an ordinary
credit
Splitting Of Deposits
Splitting of deposits whenever a deposit account with an
outstanding balance of more than the statutory maximum
amount of insured deposit maintained under the name of
natural or juridical persons is broken down and transferred
into 2 or more accounts
Unclaimed Balances
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 Deposits that have become dormant for a period of 10 years
may be escheated in favor of the government
Bank is required to report to the Treasurer of the Philippines
Treasurer would inform the Solicitor General
Meant to stop not only the practice of money laundering in all
its stages but more importantly the crimes that generated the
proceeds that are being laundered
Placement Stage proceeds of the crime are deposited in a
financial institution
Layering Stage proceeds are moved so as to sever any
audit trail to make the tracing of the source harder
Integration Stage criminal resumes control of the proceeds,
free from any link to the criminal source

Economic Rationale
Depriving potential money launderers of access to financial
markets helps those markets maintain a reputation for
integrity which enhances their stability and attractiveness

The Offense
Money Laundering Offense crime whereby the proceeds of
an unlawful activity are transacted in such a way it would
appear that they come from a legitimate source
Committed by the following:
o Any person knowing that any monetary instrument or
property represents, involves or relates to, the
proceeds of any unlawful activity, transacts or
attempts to transact said monetary instrument or
property
Anti-Money Laundering Act o Any person knowing that any monetary instrument or
Policy of the State to protect and preserve the integrity and property involves the proceeds of any unlawful
activity, performs or fails to perform any act as a
confidentiality of bank accounts and to ensure that the
result of which is facilitates the offense of money
Philippines shall not be used as a money laundering site for
laundering
the proceeds of any unlawful activity
o Any person knowing that any monetary instrument or
Covered entities: all supervised or regulated by the Bangko
property is required under this act to be disclosed
Sentral ng Pilipinas
and filed with the Anti-Money Laundering Council,
fails to do so
Deterrence Function
All cases on money laundering: Regional Trial Court

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 Committed by public officers and private persons who are
conspiring with public officers: Sandiganbayan
Terms Defined
Covered transaction transaction in cash or other equivalent
monetary instrument involving a total amount in excess of
P500,000 within 1 banking day
Suspicious transaction transaction with covered
institutions, regardless of the amounts involved, where any
of the following may exist:
o No underlying legal or trade obligation, purpose or
economic justification
o Client is not properly identified
o Amount involved is not commensurate with the
business or financial capacity of the client
o Clients transaction is structured in order to avoid
being the subject of reporting requirements under
this act
o Transaction which is observed to deviate from the
profile of the client and/or the clients past
transaction with the covered institution
o Transaction is in any way related to an unlawful
Prevention
activity or offense under this act that is about to be,
is being, or has been committed
o Any transaction that is similar or analogous to any of
the foregoing
Monetary Instrument coins or currency of legal tender of
the Philippines or of any other country; drafts, checks and
notes; etc
Insurance Companies, regulated by Insurance Commission
Security dealers, brokers, salesmen, and other similar
persons managing securities or rendering services as
investment agent, advisor or consultant
Investment companies (trust fund, mutual fund, etc)
Entities administering or dealing in currency
Jewelry Dealers in precious metals and precious stones
Persons who provide the ff services:
o Managing of clients money and assets
o Management of banks, savings, or securities
account
o Organization of contributions for the creation or
operations of companies
o Creation, operation or management of juridical
persons or arrangements and buying and selling
entities
Excluded: lawyers and accountants acting as independent
legal professionals in relation to information concerning their
clients or where disclosure of information would compromise
clients confidences or the attorney-client relationship
Customer identification based on official documents
Record keeping records of all transactions of covered
institutions shall be maintained and safely store for 5 years
Reporting of covered and serious transactions covered
institutions shall report to the AMLC all covered or suspicious
transactions within 5 working days

Covered Institutions
Freezing Of Monetary Instrument Or Property
Banks, non-banks, quasi-banks, trust entities, foreign
Person whose account has been frozen may file a motion to
exchange dealers, pawnshops, money changers, remittance
and transfer companies and other similar entities and all life the freeze order and the court must resolve this motion
other persons and their subsidiaries and affiliates supervised before the expiration of the 20 day original freeze order
and regulated by the BSP

13
 No court shall issue a temporary restraining order or a writ of
injunction against any freeze order, except the Supreme
Court

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