Government of Pakistan SECURITIES AND EXCHANGE COMMISSION OF PAKISTAN Iskamabac, 26" dy, 2077 NOTIFICATION SRO, OG (1y2017.- In exercise of the powers conferred by subv-sectivn (1) of section 512 read with ssetion 10, 14, 16 and 17 of the Compantes Act, 2017 (XIX of 2017), the Securities and Fxchange Commission of Pakistan is pleased to notify the following Companies (Invorporation} Regulations, 2017, the same having besa previous published vide notification. R. O 423 (1¥2017 dated une 0S, 2017, namely’ CHAPTER I PRELIMINARY 1. Short title and commeneement— (1) These Regulations shall be called the Companies (Incorporation) Regulations, 2017 (2) They shall come inte-fores on Aupust 14, 2017, eubtent, 2, Definitions, ~(1) In these regulations, unless there is anytime repugnant in the subject (2) “Act” means the Companies Act, 2017 (XIX of 2017); (i) “annexure” means a form attached to these Regulations Gil) “Commission” means the Securities and Exchange Commission of Pakistan established under the Securities and Exchange Commission of Pakistan Act, 1997 (XLILof 1997}. {i6) “regulations” means the Companies (lneonparalion) Regulations: 201% (2) Words and expressions used fut mot defined in these regulations shall have the same ‘meaning as assigned co them in ihe Act, the Securities and Exchange Commission of Pakistan Act, ‘Acl, 2013 end uny rules made 1997, the Limited Liability Parcership Act, 2017, the Securiti thereunder. CHAPTER RESERVATION OF NAME 3. Reservation of Name, (1) Any person desirous of forming a company shall have the option ta file either separate or eombined application for reservation of sume and inearparation of company -serviee or in physieal form, Provided that the application shall be fled either throu jon shut made in the following manner, (2) The combined applies Page tof 22| | (i) application for reservation of name us per Annexure-t of the regulations slong with non- refundable application fee as specified in Seventls Schedote of the Act shall be dled with theregistrar; Gi) the applicant shall propose thres names for the company in the order of priority, out of ‘which any ome may be approved by the registrar subject to Culitiment aFecteria mentioned in these reguistings and section 10) of the Act Provided that in cuse of refusal of the proposed nantes, the reuiatei shall fssue the orclee ‘of refusal as per Annetwre-ILL und application fos inewtporacion ef company shall be held pending tll sueh time the nate of company is reserved, (iii) application for incorporation of company: mentioning name of company’ as per option | contained in Annexurest along with all relevant documents as specified in regulation Ss Provide it case the ames per option | is net available, the registrar shall enter he name from amongst other two options centsined in Aumecuret, If deerted appropriate, in all the relevant forms or documents in cases where combined application is fled (3). Separate application for reservation of namie in term's oF sub-section {49 af section 10 af the Act shall be made inthe following manners (1) application ws per Annexure-1 of the regulations along with non-refundable applicstion fee as specified in Seventh Schule of the Act shall be filed with the registrar, criteris specified in section. (ii) theapplicant shall ensure that the proposed nacre shall fal 10 of the Acc and these regulations (4) The registrar, if satisfied thae the proposed name ‘ilfils the criteria specified in the Act and these regulations, may issue availability of name ns per AnnexurestI for a period of sixty days from the date of availability of name letter, (5). Utheapplicaat fails to file application for ineorporatinn nf company wi the name shall not remain avatieble, hin thesaid period, (6) In case of refusal of the peopased name, she registrar shall Issue the order ofreiusal ax per Annexure-IIL (2) The registrar, while considering the application for seseivative of namie nay require the applicant to furnish such additional information as deemed appropriate. Prohibition of certain aanies.— (1) Subject 10 section (0 of the Act the following words aad combinations thereat shall not be used in the name ef a company in Eaglish or any of the languages depixting the same meaning, {i) Federal Government, Peovibeial Government, Name depicting assncietion wih aay foreign government, Neme suggesting ossociation wilh uny political persunality, Commission, Authority, Register or Repistered, Co-operative, Hureau, Division, Deparment, Underaking, Municipal, Unina, Republic, Nation, President, Governor, Prime Minister, Chief Minister, Minister, Cabinet, Senate, National Assent sent! Paclfarnentary, Staite! Stat Court! Hudiciery? Jude, Adrainiscar. (i) Names of Inteenetional bodies and abbr buat not limited to, © Nations, Sougi Asian Association for Regional Cooperation, Organization of Isle Page 2 of 22(2) Subject to section 10 of th used in thename ofa company sub a ity w o> (viiy (vii) i) (s) (x) xi) (xiii) bi) Conference, World Bank, International Finanse Corporation, Asian Development Bank, Islamie Development Bank, Inlemtalional Monetary Fund, Red Crass, Red Crescent. Provided that the Commission may allow any of the above names under special cizcumstances on he request of any government ar autherity ‘Act athe following words and combinations terval may only Ine the criteria men Association or Foundation = In case of companies wo be established on grant of license hy the ‘Commission under section 42 of the Aet or witich are licensed by the Directorate General of “Trade Organizations under the Trade Organi Fund In case of a public sector company, # teade organization, a Non-Banking Finance ‘Company tobe established! to undertske asset rearnuement services oF private equity and venture capital fund menagement services subject to prior approval of the Commission or a eampany to bbe established on grant of license by the Commission under section £2 of the Act Council «in case of a campany (0 be established on grant of license by the Commission under section 42 of the Act. Moreover, this expression may'alsa be allowed to Sports Association, Trade ‘Onganization or a Prafessional Borly, Chamber = In case of an entity which is to be established as a Trade Organization under ‘Trade Onganizations Act, 2013 Trust ~ In ease of Nom-Banking Finatce Company to be established to undertake REI management services or asset management services subject to priar approval by the Commission Scie = In case of a company if proper justification is provided to the satisfaction oF the registrar. ‘Assurer/Insuranice/urcr/Re-AssurancelRe-Assurer/Re-Insurance’Re-fasurer — In nee, Assurance, Reinsyranee ‘Assuran case of companies ta be established to undertake business of Tnsui and Re-essuranos subject 19 prior approval of the Commission Board = [n case of a company desirnus to engage in the business of Paper andior Loard or 10 public sector companies. Boohrie/Askeri/Pauji’FezmiyeCndet/Acmed Forces. ar ——_“FonceavArmy/Nawy/ANir Furce/StuheeniM ilitary/Defence - In ease of companies to be established by the relewuns auency, Bank‘Banking/Ranker - In case of companies ta be established fo undertake banking, business subject to priar ppraval of State Bunk of Pakistan or un investment bank subject to prior approval of he Commission Charter/Chartered ~ In case of companies having chacter from the sovereign authority of the Federation or the Province Corporation « tn case of companies where praper justification is submitted to the satisfaction of registra, Exchange/Bourse ~ In case of Securities Fxchange, Commodity Exchange, Mercantile Exchange iwe Company, subject (o prior eparoval from the relevant authosity and Fach in case ofa earnpany where peemission af familiar trade niery evidence of ownership’ use ef trade Familier Trade Names or Brand Name nhame-or brand name user is provided or proper docu name o¢ brand name is Furnished by Lhe applicant tu the satisfaction of the registrar, Page 3 of 22(ov) Famous/Distinet Personalities - In ease ata company whore proper justification is submitted Lo (xvi) Federation - In cese of a company licensed under section #2 of the Act ar tra (xvi) Federal - fr case of a company’ where it has a con Aaviil) Province Provincial’s (xix) Group In ease of a oo) Holding (xsi the satisfaction of registrar. Je hades under ‘Trade: Onguntzations Act, 2015. tion with or patronage of the Pederal Government subject to priar approval of the Commi indb/Punjab/Baluchistan/Khyber Pakheunklws of KPK/FATAIGilgit ‘Azad Jammu & Kashmir or AJK, let ease of a comp, vetnedl Government subject to y where i has a jor epproval of the Baltistan or PANA connection with or patronage Of the Commission, curporate D with two pany where this word implies several companies under sine! relator ownership and applicants have to provide evidence af susie or mone companies. Incase of a company where it qualifies to be a holding company us defines in stause 37 of sub-section (|) of section 2 of the Act Io the satisfaction of the registrar, tilute/lastitutiog ~ In ease af company where it hes subminted proper jusstication 0 the satisfaction of the registrar, (xxii) Finanee, Financial, Investment Finance, Investment Advisory, Leasing, Asset. Menagement (xsi Housing Finaee, Modaraba, Ve ‘Banking Finance Company, investment company, Medaraba company, brokerage house subject to approval by the Commission. In case of any pubis seotor Tanna) institution subject to pros approval by she Commission oF State Bank of Pakistan, a the case may be. ) ame of Company contiaing country name or nationality sther than Pakistan - In case of the companiss where appropriate ju to the satisfaction of the regis (xsiv) Name of Company comaining names of two countries Le,, Pakistan/Pak and sey other foreign fxav) New/Modem/The/Al/intematianul Company! Co Ine; country - fn case of companies where docemenmary evidence is provided to the satistnetion of the registrar to support the tact hat the company is Joint Venture of Iwo Governments or companies of to countries, mvPortnership/LLPILLCIPropriter Enterprise’ Mills Factory ~ In ease of a company where proper justification is submitted to the satiafaction of the repistrar, However, these expressions sil not he acceptable if used te make propased company name distinctive from existing companies, {axvi), Stale In ease of public sector companies, (jseeii) University - In case of University Wtanagemeat Company for the sranagenent of University in 3) eins of guidelines of Higher Education Commission. Therame shall be considered undesirable, if (i) fe inctudes the narie ofa rpistered trade mark of a ade mark which is subject ofan application for registration, unless the consent of the owner or app ican’ for tegistrarion of he trade mark as the ease may be, has heen obtained snd produced by the promaters includes any word or words which are offensive to any section of the people; Pages of 22(iii) its identical with or resemble lar to name of Limited Liability Parmership registered under che Limited Lisbifity Partnership et, 2017; undesirable, (iv) any other wont which in the opinion of repistray CHAPTER I INCORFORATION OF COMPANY 8. Application for incorporation of company. ~ (1) An upplicant shall make an application for incorporation of company as per ber through ceservice or in physical form 10 the rey Annexure-1V along with the following dacuments,- () Memorandum of Association; (i) Articles af association, where required; (iil) Copies oF CNIC/NICOP of the subscribersidirectors'chief executive officer oF copies of Passport in case ata foreigner; (i) Copy of CNICINICOP of Nomnince only in case of single member company ar copy of Passpact in cese ofa foreigners (8) Copy of CNIC of witness in ease of physical fling: {v3 Authorization for filing of docuinents for the proposed company by the subseribers as per Annexure-¥ in favor of either one of them ar registered interniediary {vil} NOC/Letter of Intent! License 4iF any) of the relevant regulatory authority in case of specialized busintess as mentioned in regulation 4; and (viii) Original paid benie-challan evidencing the payment of fee specitied in Seventh Sel of the Act 6, Memerandum of Asseciation. —{1) ‘The memorandums vf association shall be in conformity swith Table B,C, D, or F of the Fisst Schedule to the Act anid uny ther rules and regulations notified by the Commission/Pederal Government, as applicable to the kind of the company. tt shall contain an undertaking that the earspany shall not engage in any of the restricted business, launch mul marketing (MLM), Pyramid and Pomai Schemes, or other related activities‘businesses or uny business, or engage in any of the permissible business unless ¢xe requisite approval, permission, tr license is obtained from competent authority as may be required under any law for the time being in force. Explanation Fos the purposes of this regulation, “restricted business" means undertakin indulging, directly or indirectly. in the business of a Banking Company, Non-Benking Finance Company, Mutual Fund, Private Fund, Leasing, Investenest Company, Investment Advisor, REIT Management Company, Housing Finance Company, Discounting Services, Microfinance or Microcredit business, Insurance Business, Modaraba Munigement Company, Stock Brokerage business, forex, manazing agency, business of providing the serviges of seeuriy guunds, securities broker, securities adviser, securities manager, share rexistrar, credit rating companys belloter, underesiter, debt securities trustee or any other busines restsicted undes any law forthe time being ip force or as may be notified by the Commission, (2) The memocanduny of association of the company shall te signed try each subscriber to the memorancum, (3) Where the subseriber to she memorundum is a nady corporate, the memorandum of association shall besigned by & natural person duly'authaeized inthis bebalf by # resolution of the board af elrectors af the body sorporats oF design ated partzier in case of limited liability partnership. Page 5 of 22| (4) The memorandusa fled in pliysical form under sub-section (1) ofsestion [6 ofthe Act shall be properly stamped as requiced by the Stamp Act, 899 (IE of 1890}, ifapplicable, dulysubserbed ind sitiessed alora with the deslevatinn mae thereunder: Provided that in ease of electronic substission of memorandum of association, the stamp duty shall not be paid til the time the Provincial Gavennmeats devise andl inp priate meisares yment and recovery of stamp dury through electronic means in terms. ‘Transuctivns Ordinance, 2002 (L1 of 2002), eanly perso who mekes't declaration under sub-section (1) af scetion 16 of tke Act of is 8 promoter or director of the proposed compeny or is a witness to the signatures ofthe subseribers to the memorandum to furnish such Information, clarification ar decunie fas he may deein necsscary to sutisfy himself fer purposes of sub-sections (2) and (4) of section 16 af the Act, (3) ‘The rewistrar may req 7. Articles of Asvociation.—{1) The subscribers of the company timated by shares may adopt the antieles of association as per Table A of First Schedale to the Act and notify the same to the segistrar concerned as per Anmexure-1V: Provided that inthe situation mentioned hereinabove, fling of articles oF assneiation separately shall not be required. -chedle tothe igned by the Provided further that in case articles oF assocfationas per Table & of the First ‘Act are not adopted, the company Limited by shares shall file the articles of asseetarion rs to the memnrandum with the registrar along. wih xpplication far ineurporaton (2) Inthe case af x company limited by goarantee or an unlimited company, the company shall file the articles of association signed by the subscribers to the memorandum with the registrar ‘along with application for incorporatien. (3) Where the subscriber is a hady corporate the urticles of association shall be signed by fa natural person duly authorized in this behalf by a resolution of the beard of directors of the body Cpoxporate or designated partner of the limited liability partnership. ers to the in terms of 8. Appointment of First Directors and Chiet Executive Officer. memorandum shall determine the ruber of directors and the names of ¢ jon £57 of the Act provisions of (2) The subscriter execute officer in terms of provisi the memorandum shall alo determine the name of the first chief sat section 186 af she Act @) The aumber of directors ax determined by the subseribers and particulars of first directors and first chief executive offices shall be stated in the application for incorporation of company (1) In addition to the particulars ef subscribers: as provided in section 31 and 37 of the Act following further information shall be provided namely: (i) a subscriber, in ease ofa Pakissani national, shallelso specify his national identity card namber and in the case of foreign nex ional, his passport numbers (iid inease of « person other hana natucul person, the axddress af ils registered ofice ar prinetpel affice shall he mentioned and the authorized repeesentelive: signing the documents shall provide his particulars Page 6 of 22‘nl (I) In case of electronic submission ms of Section 3 of 10, Witness in case of physical submission af a dac of dacumients for incorporation of a company & Electronic Transactions Ordinance, 2002. sx is not required i 1 of documents for incarporation af'a company, the same shal be witnessed hy'a Pakistani National having valid CNIC: Provided that where a decument is required to be aliested by a notary public or am oath comatissioner or elass | magistrate, the same shall be witnessed in sccordance with the relevant law. 11, Examination #f dacuments by the registrar (1)The registrar shall examine the dacuments submitted for rezistration af « company and if he’she is satisfied that the same are complete in all respects and all the requirements of the Act and regulations relating to incorporation af the company have been eamplied with, he shall repisier the memorandum ond other documents dclivered 10 bir ‘orved by the registrar in the documents for resolution and the applicant shall (2) In sase any discrepancies and defickeneies ure ol filed the seme shall be corsmunicated to the applicans in wr remove the discrepancies and provide requisite informution within seven days of date of written communication from the register. (3) In ease no response is received within stipulated time period, a first reminder shall be issued and a Final reminder shall be issued seven days thereafter by the registrar concerned leant fails to remove (4) In case na response is received from the applicant or the ay iscrepancies ar provide requisite information to the satisfaction of registrar within seven days of issue of final reminder, the registration of the memorandum may be refiased, 12, [ssuunee of Certificate of Incorporation. (1) On regisration of memorandum of association of a company, the reuistrar shall fssue-a certificate oF incorporation, under his signatures or authenticutex by his official seal, as per Anmexure VF, which shall be conclusive evidenee that tae requirements of the Actas to registration have been complied with and that the company is duly incorporated under Act (2) The certificate of incorporation may be issued electronically ar in physical form. 13, Additional requirements for a single member company.+ (1) A perseit desirous of forming 4a single member company shal! comply with all the requirements for incorpuration of a company as pet regulation 5 of these Regulatlons, (2) The person ta be nominated under section 14 of the Act shall be in accordance with sub= Section (3) of Section 79 of the Act. 14, Additional requirements for an assoeiation ont fer profit- The subscribers to the memorandum of an assaciation net for peofie shall ohiain license as per Associations with charitabl and not for profit objects (Licensing and Corporate Governance) Regulations, 2017, before fl application in terms.of regulation $ of these regulattons foreign subscribers and security clearance, ()}In case the fon fs required by the registrar including but not oF origin, 15. Add requirements fe subscriber is a foreign company, additional info: limited fo, the profile af the company, detail o copy ofits charter, stature oe memorandum and ar directors, their nationality and coun statue, memorandum, articles or other instrament, swith the regi Provided that the copy of any chart constituting or defining the constitution af foreign cainpany required tu be shall be duly certified to trea truc copy by Page 7 of 22(i) the publicioff{cer in the county where the company’ is incorporated to whawe custody the original is committed; or a Natary public of the couatry where the company ts incorporates nr )) an affidavit of a responsible officer of the company in the country where tie comipany is incorporated. Provided further that the sigs ed to in elause (i} or the cersficate of the Notary Public referred to in clause (ii) above shall be wulhealicated by: a Pabistant diplomatic consular or consulate officer and the certificale ofthe afficer of the eompany referred clause (ii) shove shal! he signed before a Pakistan diplomatic consular or consulate officer. (2) In ease the subscriber to the memorandum is 3 foreign ntionel residing outside sas deemed necessary hy the registrar end hhisther signatures and address on the memorandum and articles of essuciation shall be identical with he details appearing in his passport (3) The Commission shall obtain security cleenmee from Ministry af Interior (Mol) in Tollowing cases and in the manner prescribed hereunder: (i) companies having forcten fethee thon Afghan and Indian national or ori subscridersvufficers will be incorporated and case shall be forwarded for security cle Provided that in case name of subscriberfoffiees is not scuusity cleared by MOI, he or she stall take immediate steps for replacement as subseriherco‘¥icer and shall transfer shares hel hy hitm to another eligi ie person; (ii), Companies having foreign subscribers’ officers who are AGghan or Indias netignal or of ‘Afghan o+ Indian Origin will be incorporated alter reeeipt of security clearance (iif) Private security companies, will be incorporaied alter receipt of security clearance, 16. Filing of Certificate for receipt of share maney.- (1) ‘The company shall report receipt of subseription money from the subscribers along with nertifcate hy a practicing chartered accountant or a cost and management accountant verifying receipt nf the money 36 subscribed forty fre ays som the date of incorporation af the company as per Anneaure VIR. (2) The shares of the subseriher shall be deemed to be cancelled where. (i) the company fins reported non-toceipt of share money or receipt ef less than required shure money as per Annexure-VIL; oF Gi) the company has not filed Amnexure-VIL within forty five days of incorporation as th i share money. (3) The rogistcar shall give Following direetinn to the companys (i) to comove the name of the subseriber from the register who has tailed to pay the subscriptioa mioneys (ij either add another shareholder with evidence of payment of share meney ur techunge status of the sompany, if required: Provided thot before waiving any such direction, a opportunity of hearing shall be granted by the rogistrar ta the company and the subscriber who hav failed 1s zy share money, Page a of 22(4) ‘The companys appropri IV be required to comply with the dircetien within fourtees days, failing which fe action unider the Act would be initiated by’ the registrar against the company: Provided that the company shall submit revised information: in pursuance of the direction as per Annexure-TV along withthe relevant dneu ments within seven day’ from the last date the direction was requized ta be eomplied with. Page 90722COMPANIES (NCORFORATION) REGULATIONS, 2017 {See Regulation 3} APPLICATION FOR RESERVATION OF NAME, (To be completed by appticant in block testers.) Detatls 1.1 Challan No Fee Payne 12 Propose three options for name (mandatary in cave of combined | Option 2 application otherwise sbugle srame may be provided) (Please enter she name without kind af company ex. (Put Limited, Limited ete.) kind of propesed company a | Private Limited Company | Single Member Company © | Public Limited Company @. | Association Not for-profit under section 42 uf the Companies Aci, 201? Other (Please specify) Principal line of business for proposed ‘company Meaning f Significance of proposed name [6 Many compeny or entity exists with identical ] or similar name, plesse mention your Yeiatiunshin with such company or entity along with board zesolution/ NOC shawing ne pjection on registration of a company swith similer name, 7, Deelaration information provided in the form is trus and eoerect and nothing is concealed and that the proposed neens, if reserved, shall be used only for the purpose af _tesistration of company 8. Name of Proposed Subscriber/Authorized Intermediary iw I applicable Hi, NAC No, where the applicant is ] proposed subscritxcr Maxsport Nain sate of foreign mational) Day Monti: Your mom iS ESS eae) Enclosures: 1. Original patd bank challan evidencing px 2. Copy of NOC/permissionvletter of intent of earmpatent azthovity (iPappliceble) 4. Any other dacument deemed necessary, 1 OF fee Page 12 of 22Annexure Ul Securities and Exchange Commission of Palistan Company Registration Office “ os the above subject. 2. The above proposed time appears io be aveilable for regisiration under the provisions af the Companies Act, 2017 and the Companies (Ineorporition) Regulations, 2017. The proposed name shall he reserved fora period of sixty days ony and the poposed company shall be registered with the said this period, However, afler the lapse of the name ifthe documents for registration are presented with period, zis office shall not take ay responsibility 1Pthe name does not remain available for registration. Registrar> Page 12 of 22Annexure 4 Secu und Exchange Commission of Pal Company Registration Office Applicant Name Applicant Address> REFUSAL OF NAME Dear Siré Madam, 1 This is with re noe to your name rese-vation request Uated one of subse‘ direetor of the propased Company: or > a registered intermediary whuse specimen signature is appended herein below io Me the docussents for ineorparation of the proposed company and to correct fy amend the Memorandum and Article of Association and other documents and 10 collect certificate of incorporation of she company fom Company Registration ‘Name and signature af subscriber-1 ature of subscriher2 Name and signature Name and signature of subscriber ‘Seal and \ signature of Notary Public Page 18 of 22ANNEXURE VI COMPANY REGISTRATION OFFICE SECURITIES AND EXCHANGE COMMISSION OF PAKIS [Under section 16 of the Companies Act, 2017 (XIX of 2017)] Conporate Usiversal lisntification No. | hereby certify that (COMPANY NAME) is this day incorporated under the Cam aniies Act ‘2017 (XTX of 2017) and ther the eompany is { COMPANY TYPED en at (LOCATION) this (DAY any of (MONTH), Two Thousand and VE REGISTRAR Signan re Page 19 of 22COMPANIES (INCORPORATION) Annexure VIL REGULATIONS, 2017 [See Regulation 16] REPORTING OF RECEIPT OF SUBSCRIPTION MONEY PAR (Please complete in syeaseript or im boid block eopirate) LA CUIN (Ineorporation Number) i | 1.2. Name of the Company 1.3 Fee Payment Details 13. Chalten No [ Challan Amount PARTS 2.1 Total amount receivable against substrigtion — (Rs.) = Total aniount received ayainst subscription 23 Due of receipt 24 Particulars of persons winw have net deposited the jame of subscriber Number of shares 3.1 Name of Autiurized OficectAuthociaed intermediary 32 Signacures iRs) Page 20 of 22Registration No of Authorized Intermediary, if applicable ee Duy Menth Year 34 Date I I |) Enclosures: L. Original paid bank challan evidencing p ment of fee Certificate of receipt ef subscription money Page 21 of 22| Annexure-VIE COMPANIES (INCORPORATIONS) REGULATIONS, 2017 [See Regulation 16] CERTIFICATE OF RECEIPT OF SUBSCRIPTION MONEY | 1 é Wer have examined the bank deposit slips) ¢ youeler(s) / reeeipits) of secount No. issued by being ‘pintained in the nasne of M/S- hes been deposited on ‘cunt of the eompeny as per Following money into the | Numbers aS undertaken in Memorandum of Association SN Name of Subscriber Amount Paid Payment date | Signature & seul of the Chortered Avcoumut Cost & Management Accurtant Date: [No. CLENCEDPRE2}201 7] ! \i iy! Seereiary to che Cam Page 22 of 22