Article 14.

- 2 -

28 END

the Board of Directors who shall submit their

resolutions through the Provincial Government

of Fukien to the Ministry of Finance for its

approval.

The Bank shall have a Board of Directors which

shall consist of 7 Directors to be appointed by

the Fukien Provincial Government......... .and

in the event of any civilian capital being

admitted in pursuance of Article 6, different

provisions will be made as regards the number of

Directors and the manner of their election.

We are instructed that the full amount of the capital

of $5,000,000 has been entirely subscribed by the Fukien

Provincial Government and so far no civilian capital has been

admitted.

From the above, it would seem that the Bank is wholly

a Government organisation financed by the Chinese Government,

and until its constitution is altered upon the admission of

civilian capital, it does not seem to possess the chief

characteristic of a company, namely, "the association of a number of individuals for some common purpose" (See 5 Hals.

2nd Edn. P. 11 and footnote "a"). It would therefore follow

that no registration would seem to be required under Section

319 of the Companies

Ordinance.

We shall be obliged if you will give this matter your

kind consideration and give us your ruling thereon, as it is our

clients' desire to comply with the Companies Ordinance if

registration is in fact required.

Bank.

We send you a copy in Chinese, of the Rules of the

Yours faithfully,

(Sa.) Ts'o & Hodgson.

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