Circular 41/2022/TT-BTC on guiding the accounting regime applicable to social and charity activities

CIRCULAR

Guiding the accounting regime applicable to social and charity activities

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Pursuant to the Law on Accounting dated November 20, 2015:

Pursuant to the Decree No. 174/2016/ND-CP dated December 30, 2016 of the Government on detailing a number of articles of the Law on Accounting;

Pursuant to the Decree No. 93/2019/ND-CP dated November 25, 2019 of the Government on the organization and operation of social funds and charity funds;

Pursuant to the Decree No. 93/2021/ND-CP dated October 27, 2021 of the Government on mobilization, receipt, distribution and use of voluntary contributions to help people overcome difficulties caused by natural disasters, epidemics or incidents; support patients suffering fatal diseases;

Pursuant to the Decree No. 87/2017/ND-CP dated July 26, 2017 of the Government defining the functions, tasks, powers and organizational structure of the Ministry of Finance;

At the proposal of the Director of Accounting and Auditing Supervisory Department;

The Minister of Finance promulgates the Circular guiding the accounting regime applicable to social and charity activities.

Chapter I

GENERAL REGULATIONS

              Article 1. Scope of regulation

This Circular guides the implementation of accounting for social and charity activities of organizations, agencies and units and the making of entries and the making of reports for social and charity activities of individuals in accordance with law, including:

1. Activities of social funds and charity funds in accordance with the Decree No. 93/2019/ND-CP dated November 25, 2019 of the Government on the organization and operation of social funds and charity funds.

2. Activities of receiving, distributing and using voluntary contributions from domestic and foreign organizations, agencies, units and individuals in accordance with the Decree No. 93/2021/ND-CP dated October 27, 2021 of the Government on mobilization, receipt, distribution and use of voluntary contributions to help people overcome difficulties caused by natural disasters, epidemics or incidents; support patients suffering fatal diseases.

3. Activities of receiving, distributing and using voluntary contributions from other domestic and foreign organizations, agencies, units and individuals for the purpose of providing assistance to persons falling in difficult or disadvantaged circumstances with required accounting according to regulations, the provisions of this Circular shall be applied.

Article 2. Subjects of application

The subjects of application of this Circular include:

1. Social funds and Charity funds established and operating in accordance with law.

2. Mobilization board of the "For the Poor" Fund at all levels (at the Central, Provincial, District, Commune levels).

3. Organizations, agencies, units and individuals mobilizing, receiving, distributing and using voluntary contributions to carry out social and charity activities.

Article 3. Principles and requirements for accounting for social and charity activities

1. Principles

All organizations, agencies, units and individuals engaged in activities related to mobilization, receipt, distribution and use of voluntary donations to carry out social and charity activities must open accounting book to fully reflect arising economic operations, make reports and supply information in a transparent manner in accordance with this Circular and relevant laws.

2. Requirements

a) The organizations, agencies and units engaged in social and charity activities with independent accounting organization for activities of mobilization, receipt, distribution and use of voluntary donations shall open accounting book to fully reflect and make cost accounting of arising economic operations, make financial statements in a sufficient and transparent manner in accordance with this Circular.

b) The organizations, agencies and units concurrently performing social and charity activities, without independent accounting organization for cost accounting of mobilization, receipt, distribution and use of voluntary donations shall make cost accounting on the same accounting book system of them, according to their applicable accounting regime. They must open a detailed accounting book to monitor these activities separately to ensure proper management and use. Annual or periodical reports on revenues and expenditures of social and charity activities of the unit must be made as prescribed in this Circular; the unit must publicize data according to the provisions of law, at the same time, data of social and charity activities must be separately disclosed in the unit's general financial statements in a clear and transparent manner.

c) Individuals engaged in social and charity activities in charge of opening a record book with sufficient information on the results of receipt, distribution and use of voluntary donations must comply with the provisions of this Circular; at the same time, make reports and publicize the status of receipt, distribution and use of donations in accordance with the law.

Chapter II

SPECIFIC REGULATIONS

Section 1

FOR ORGANIZATIONS, AGENCIES AND UNITS WITH INDEPENDENT ACCOUNTING ORGANIZATION FOR SOCIAL AND CHARITY ACTIVITIES

              Article 4. Regulations on accounting documents

The units are allowed to design their own document forms to reflect arising economic operations. The self-designed document forms must satisfy at least 7 contents specified in Article 16 of the Law on Accounting, in accordance with the recording and management requirements of the unit.

For direct support expenditures for beneficiaries (funding in cash, distribution of goods and in kind), the documents serving as the basis for expenditures (or the attached list) must be signed by the recipient, certified by the responsible local unit in accordance with current law.

Article 5. Regulations on accounting accounts

1. The accounting accounts reflect regularly, continuously and systematically the situation of assets, capital sources and liabilities; receipts and use of funding sources for supports, contributions from organizations and individuals, supports from the state budget and other funding sources; the results of operations and other economic operations arising at the units.

2. Classification of system of accounting accounts

a) On-balance sheet accounts including type 1 to type 9 and to be double recorded (with the making of reciprocal entries between accounts); Used to reflect and account the status of assets, liabilities, capital sources, revenues, expenses, surplus (deficit) of the unit in the accounting period.

b) Off-balance sheet accounts reflecting economic targets that are reflected in the on-balance sheet accounts but need to be tracked to serve management requirements or track other assets under the unit’s management such as outsourced assets, pending-for-sale in-kind donations, etc. Off-balance sheet accounts accounted for by the single-entry method (without the making of reciprocal entries between accounts).

c) In case the budget for the apparatus management is deducted proportionally from the source of funding or contributions or in case the competent authority requests the preparation of a final report on receipt and use of funds for the apparatus management, the accountant must simultaneously account for the on-balance sheet account and off-balance sheet account to track the receipt, use and the remaining unused funds carried forward to the next year for the budget for the apparatus management.

3. Selection of account system

a) The units shall base on the system of accounting accounts promulgated in this Circular to select the applicable accounting accounts suitable to their operations and the financial mechanism as prescribed.

b) The unit may add an accounting account in the following cases:

- Add a detailed account for the accounts specified in the list of accounting account system (Appendix No. 01) attached to this Circular to serve the management requirements of the unit.

- The addition of accounts at the same level with those specified in the list of accounting accounts system (Appendix No. 01) attached to this Circular shall be implemented only after obtaining written opinions from the Ministry of Finance.

4. The list of the system of accounting accounts, the explanation of the content, structure and method of recording accounting accounts are specified in Appendix No. 01 to this Circular.

Article 6. Regulations on accounting books

1. The unit must open accounting books to record, systemize and store all arising economic and financial operations related to the accounting unit. The preservation and archival of accounting books shall comply with the provisions of law on accounting, relevant documents and this Circular.

2. Types of accounting books

a) Each unit uses only one accounting book system for an annual accounting period, including general accounting books and detailed accounting books.

Under the accounting form applied by the unit, the unit must fully open general accounting books and detailed accounting books and fully and correctly perform the contents, order and recording methods for each accounting book form.

b) General accounting book form:

- The logbook is used to record economic and financial operations arising in chronological order. If necessary, it is possible to combine the recording in chronological order with the classification and systematization of arising economic and financial operations according to economic content. The data on the logbook reflects the total number of economic and financial activities arising in an accounting period.

- The ledger is used to record economic and financial operations arising according to economic content (according to accounting accounts). In the ledger, it is possible to combine recording in chronological order and recording according to economic content of economic and financial operations. The data on the ledger reflects the aggregate situation of assets, capital sources, liabilities, revenues and expenses of the unit.

c) Form of detailed accounting books and cards:

The detailed accounting books and cards are used to reflect and track detailed information of the unit under the management requirements. The data in the detailed accounting books provide specific information for the internal management of the unit and the calculation and setting of criteria in the financial statements and other reports (if any).

Based on the management requirements and the accounting requirements of each specific accounting subject, the unit may add additional criteria (columns, rows) on the detailed accounting books to serve the preparation of financial statements and other reports under the management requirements.

3. Responsibilities of persons keeping and recording accounting books

a) The accounting books must be made in a timely, clear and complete manner according to the contents of the books. Information and data recorded in accounting books must be accurate, truthful and consistent with corresponding accounting documents used for book entry.

b) The making of entries must follow the chronological order of arising economic and financial operations. Information and data recorded in the accounting books of the sequential year must follow the information and data recorded in the accounting books of the preceding year, ensuring continuity from the opening of the books to the closing of the books.

c) The accounting books must be strictly managed, with a clear assignment of responsibilities of persons keeping and recording books, the persons assigned to the accounting books must be responsible for the contents recorded in the books during the period of keeping and recording books. Upon change of persons keeping and recording accounting books, the chief accountant or persons in charge of accounting must organize the handover of responsibility for managing and recording accounting books between the old accountant and the new accountant. The old accountant must be responsible for all contents recorded in the books during the period of keeping and recording the books, the new accountants shall take responsibilities from the date of handover. The handover minutes must be signed for certification by the chief accountant or persons in charge of accounting.

4. Setting up of accounting book

a) Principles on setting up of accounting book

The accounting book must be set up at the beginning of the annual accounting period or right after the grant of the decision on establishment and operation of the unit. The accounting book is set up at the beginning of the new financial year to transfer the balance from the old year's accounting books and immediately make entries of new economic and financial operations arising from January 1 of the new fiscal year. The unit is allowed to open more detailed accounting books at the management requirements of the unit.

b) Manual opening of accounting books:

The unit must complete the legal procedures of the accounting books as follows:

- For accounting books bound into a book form:

+ Cover’s left corner must bear the accounting unit’s name, cover’s middle must bear book’s name, dates of setting up and closing book, full name and signature of the person setting up the book, signatures and seals of chief accountant or accountant in charge and unit head; dates of closing or transferring book.

+ Pages of accounting book must be numbered from 1 to the last page, any two pages must be affixed with seal of the accounting unit.

+ The accounting book is not considered legitimate until the above procedures are completed.

- For accounting book in separate sheet form:

+ Each separate-sheet book must bear the unit’s name, page number, book’s name, month of use, full name of persons keeping and recording the accounting book at the beginning part.

+ The separate-sheet book must bear signature and seal of the unit head and be registered before being used.

+ The separate-sheet book must be arranged in the account order and kept in a safe and easily-seen place.

c) Setting up of electronic accounting books:

The electronic accounting book must contain elements of an accounting book in accordance with law on accounting. If the accounting book is kept in the electronic device, a printed and bound general accounting book is still required and all procedures prescribed in Point b, Clause 4 of this Article must be completed.

If the remaining accounting books are not printed but kept in electronic devices, the head of accounting unit must ensure that data must be safe, secured and accessible during the keeping period.

5. Making of accounting entries

a) The making of accounting entries must be based on accounting documents, all data recorded in accounting books must be proved by valid and lawful accounting documents.

b) If the entries are made manually, the indelible ink must be used, no red ink is allowed (except for adjusting entries). Procedures for recording and forms of accounting books must be done in accordance with Appendix No. 01. When all pages are fully written, the data of each page must be sum up and the total must be carried over to the top of the succeeding page, no interlineations on the top or bottom of current page is allowed. If a page is not fully written, blank section must be crossed out; no erasures or no chemicals intended for correction are allowed.

6. Closing of accounting books

a) Closing of accounting book means calculation to determine total accrual debits, total accrual credits, and closing balance of each account, or total revenue, expenditure, fund balance, receipt, discharge, and inventory.

b) A cash fund book must be closed at the end of each day of transactions. After closing the book, it must make reconciliation between the cash book of the accountant, the cashier's cashbook and the cash in the safe to ensure they are accurate and matched. On the last day of the month, a cash inventory statement must be drawn up. After the inventory, the cash inventory statement shall be kept together with the cash accounting book on the last day of the month.

c) A bank/treasury deposit book must be closed at the end of the month for reconciliation purpose; the reconciliation table (certified by the bank/treasury) shall be kept together with monthly bank/treasury deposit book.

d) The unit must close its accounting books at the end of the accounting period of the fiscal year before making the financial statements. In addition, the unit must close the accounting books in case of stocktaking/making an inventory on an ad-hoc basis or in other cases as prescribed by law.

7. Storage of accounting books and other accounting documents: Comply with the provisions of the Law on Accounting and relevant guiding documents.

8. The list of accounting books, book form, instructions for making accounting books are specified in Appendix No. 01 attached to this Circular.

Article 7. Financial statements

1. Subjects of preparation of the financial statements

The organizations, agencies and units with independent accounting organization for social and charity activities must prepare financial statements in accordance with law.

2. Purposes of financial statements

Financial statements are used to provide information about the financial position, financial performance and cash flow from the unit's operations, facilitate the comparison with the financial statements of previous periods and of other units. The information of financial statements helps to improve the accountability and transparency of the unit's information on the receipt and use of funding, contributions and other resources managed by the unit in accordance with the law.

3. Reporting period

The unit must prepare financial statements at the end of the annual accounting period in accordance with the Law on Accounting.

4. In case the unit has affiliated units, it must make a combined financial statement, including the data of its own unit and all financial information of its affiliated units, including its and its inferior unit’s financial statements, excluding figures arising out of internal transactions between superior and inferior units and between inferior units.

5. Time limit of submission of the financial statements

The unit's annual financial statements must be submitted to competent state agencies within 90 days from the end of the annual accounting period as prescribed by law.

6. Disclosure of financial statements

a) The financial statements of the Social Funds and Charity Funds must be made public in accordance with the Decree No. 93/2019/ND-CP dated November 25, 2019 of the Government on the organization and operation of social funds and charity funds; the financial statements of other organizations and units shall be made public in accordance with law.

In addition, the organizations and units mobilizing, receiving, distributing and using voluntary contributions must also make public information in accordance with the Decree No. 93/2021/ND-CP dated October 27, 2021 on mobilization, receipt, distribution and use of voluntary contributions to help people overcome difficulties caused by natural disasters, epidemics or incidents; support patients suffering fatal diseases.

b) Time limit of disclosure: The unit must disclose the annual financial statements within 30 days from the date of submission of financial statements in accordance with the Law on Accounting.

7. List of reports, report form, explanation of financial statement preparation method is specified in Appendix No. 01 attached to this Circular.

Section 2

FOR ORGANIZATIONS, AGENCIES AND UNITS WITHOUT INDEPENDENT ACCOUNTING ORGANIZATION FOR SOCIAL AND CHARITY ACTIVITIES

              Article 8. Setting up of accounting book

1. The organizations, agencies and units performing social and charity activities, without independent accounting organization for cost accounting of mobilization, receipt, distribution and use of voluntary donations shall make cost accounting on the same accounting book system of them, according to their applicable accounting regime; Open a detailed book to separately monitor revenues and expenditures for these activities, including: amounts received, amounts distributed, use of voluntary contributions for social and charity purposes in accordance with the law, in a clear and transparent manner.

2. For funding in cash

a) The unit must keep a full record of the amounts received according to the actual contribution time, according to the detailed donors. The unit must open a separate account at a bank or treasury to receive, distribute and use contributions to carry out social and charity activities, and cannot use the same account with other activities of the unit. In case of construction, repair, maintenance, restoration of works from voluntary contributions, it must comply with current regulations of relevant laws.

b) For the distribution and use of contributions to carry out social and charity activities, all information must be recorded in the accounting books, including: Time, decision and content of expenditure, full name and address of the recipient. In addition:

- In case of funding in cash to sponsor directly to the beneficiaries, the statements and documents used as the basis for recording the expenditure must be signed by the beneficiaries and certified by the responsible unit in the locality.

- In case of funding on purchase of goods, in kind for sponsorship or procurement of supplies, etc. for the construction and repair of works, there must be all valid and lawful invoices and purchase documents as prescribed. When donating goods and in kind directly to the beneficiaries, a list must be made with the signature of the beneficiaries and certification of the responsible unit in the locality.

3. For funding in kind

The unit is responsible for preservation and timely distribution of the number of in-kind fundings to the locations receiving support. Make cost-accounting and fully record the number of in-kind contributions received; and the distribution of these in-kind fundings on the basis of lists and documents signed by the recipient, certified by the responsible unit in the locality in accordance with the law. In case the funding value cannot be determined, a separate detailed accounting book shall be opened to make a report.

Article 9. Report preparation and disclosure of data

1. Every year or at the end of the mobilization period, the unit must make reports on revenues and expenditures for social and charity activities according to the form specified in Appendix No. 02 (attached to this Circular) and send it to relevant units in accordance with the Decree No. 93/2021/ND-CP dated October 27, 2021 of the Government on mobilization, receipt, distribution and use of voluntary contributions to help people overcome difficulties caused by natural disasters, epidemics or incidents; support patients suffering fatal diseases and related documents (if any).

2. Every year, the unit must explain in detail the revenue and expenditure data of the year, the balance at the beginning of the year and the unused remaining balance at the end of the year for contributions for social and charity activities on the financial statements of the unit according to regulations.

3. The unit must publicize data related to the mobilization, receipt, distribution and use of voluntary contributions in accordance with the Law on Accounting; the Decree No. 93/2021/ND-CP dated October 27, 2021 of the Government on mobilization, receipt, distribution and use of voluntary contributions to help people overcome difficulties caused by natural disasters, epidemics or incidents; support patients suffering fatal diseases and related documents (if any).

Section 3

REGULATIONS ON RECORDING AND REPORTING FOR INDIVIDUALS ENGAGED IN SOCIAL AND CHARITY ACTIVITIES

              Article 10. Opening of the logbooks

Individuals mobilizing, receiving, distributing and using voluntary contributions to carry out social and charity activities must comply with the following regulations:

1. Must open books to record accurately, honestly the voluntary contributions received from donors; the amounts distributed and used from this source to carry out social and charity activities, ensuring publicity and transparency.

2. The recording of logbooks must be implemented right after starting the activities of mobilizing, receiving and distributing voluntary contributions to carry out social and charity activities, the data must be recorded continuously in chronological order and fully reflect the information required for data disclosure. When all pages are fully written, the data of each page must be sum up and the total must be carried over to the top of the succeeding page, no interlineations on the top or bottom of current page is allowed. If a page is not fully written, blank section must be crossed out, it is strictly forbidden to erase or modify information and data recorded in the logbook.

3. At the end of period of mobilizing, receiving and distributing contributions to carry out social and charity activities, the individuals must close the books, add up all revenue and expenditure data and calculate the unused balance to make reports and publicize the data in accordance with law. For the contributions received and used through a bank deposit account, it must perform data reconciliation with the bank where the account is opened on a monthly basis and at the end of the mobilization period. The data reconciliation with the bank or the detailed deposit account book sent by the bank must be archived and made public at the end of the mobilization period.

4. For the contributions received from sponsors to carry out social and charity activities:

a) In case of funding in cash:

- The individuals must open a separate account for social and charity purposes at the bank according to regulations, not receive money for social or charity purposes into the same account for personal spending of such individuals.

- In case of funding in cash: The individual receiving the funding is responsible for storage of in-cash contributions; In case of unused contributions, they can be deposited into a separate account for social and charity purposes at the bank.

- In case of receiving funding in foreign currency to carry out social and charity activities in the country: The individuals receiving the funding shall sell foreign currency to commercial banks and manage and use Vietnamese currency to carry out social and charity activities according to regulations.

- Interests on deposits after deducting payment costs shall be added to increase funding.

- Making of summary of data recording:

A record of funding in cash received from donors must be made according to the actual contribution time, including: information of donors (such as full name, address, etc. ); contribution amount; forms of contributions including contributions to accounts at banks, contributions in cash (stating details in Vietnamese currency and foreign currencies); time of receiving contributions (in case of receiving contributions via bank account, write the date on the bank's credit report); locations receiving support (if the donor specifies the locations receiving support) and other necessary information (if any) according to the form "Summary of data on receiving in-cash contributions" (Form No. S01CN/XH-TT) specified in Appendix No. 03 attached to this Circular.

b) In case of funding in kind:

- Under the conditions of warehouse and yard, storage and transportation capacity, the individuals shall make decision on receiving in-kind contributions.

- When receiving in-kind contributions, the individuals must be responsible for preservation and timely distribution of the number of in-kind fundings to the locations receiving support.

- Open a separate "Summary of data on receiving in-kind contributions", which fully records the number of contributions received, including the date of receipt, the name and address of the contributor, the contribution type, the quantity received, the designated support locations (if any) according to the Form No. S02CN/XH-TT specified in Appendix No. 03 attached to this Circular.

5. For the amounts distributed and used from voluntary contributions to carry out social activities

It must be fully documented, including: Time of support, full name and addresses of the beneficiaries, form of support including support in cash, in kind (specify type of supported kind) or support by construction or repair items, etc. and the signature of the beneficiaries according to the form "Summary of funding distribution data" (Form No. S03CN/XH-TT) specified in Appendix No. 03 attached to this Circular. In addition, it is possible to certify on this form or make a separate document if the law provides for certification by a competent local authority.

For expenses on purchase of goods, in kind for sponsorship or procurement of supplies, etc. for the construction and repair of works, there must be all valid and lawful invoices and purchase documents as prescribed by law.

6. In addition to the forms on the data summaries as prescribed in Appendix No. 03 attached to this Circular, the additional accounting books can be opened to monitor details of activities (if necessary).

Article 11. Report preparation and disclosure of data

At the end of the mobilization period, the individuals participating in the mobilization, receipt, distribution and use of voluntary contributions to carry out social and charity activities must make a report on revenues and expenditures and publicize the data in accordance with the Decree No. 93/2021/ND-CP dated October 27, 2021 of the Government on mobilization, receipt, distribution and use of voluntary contributions to help people overcome difficulties caused by natural disasters, epidemics or incidents; support patients suffering fatal diseases and related documents (if any).

The form of final settlement report of the social or charity mobilization period, applicable to individuals, shall be made according to the Form No. B08CN/XH-TT specified in Appendix No. 03 to this Circular.

Article 12. Document storage

Individuals participating in the mobilization, receipt, distribution and use of voluntary contributions to carry out social and charity activities shall be responsible for archiving the documents prepared as prescribed in Article 10, Article 11 of this Circular and other relevant documents to ensure full disclosure of information as prescribed by law.

Chapter III

ACCOUNTING INSPECTION AND SUPERVISION

              Article 13. Accounting inspection and supervision

1. Organizations, agencies and units involved in mobilization, receipt, distribution and use of voluntary contributions to carry out social and charity activities shall be subject to the inspection and supervision of accounting work by competent agencies in accordance with the accounting law.

2. The accounting inspection and supervision shall include the following contents:

a) For organizations, agencies and units with independent accounting organization for activities of mobilization, receipt, distribution and use of voluntary donations to carry out social and charity activities: Inspect and supervise the implementation of accounting work contents; organization of the accounting apparatus, accountants and the compliance with other provisions of the law on accounting according to current regulations applicable to accounting units.

b) For organizations, agencies and units concurrently performing social and charity activities, without independent accounting organization for cost accounting of mobilization, receipt, distribution and use of voluntary donations: Inspect and supervise the opening of separate detailed accounting books for the receipt, distribution and use of voluntary contributions to carry out social and charity activities on the basis of the accounting regime applied by the units, the preparation of reports and data disclosure according to current regulations.

Chapter IV

IMPLEMENTATION ORGANIZATION

              Article 14. Effect

1. This Circular takes effect from September 01, 2022.

2. The Circular No. 103/2018/TT-BTC dated November 14, 2018 of the Ministry of Finance guiding the accounting regime applied to the "For the Poor" Fund ceases to be effective from January 1, 2023.

3. In case the documents referenced in this Circular are amended, supplemented or replaced, such amending, supplementing or replacing documents shall be applied.

             Article 15. Transitional provisions

1. The organizations, agencies and units engaged in social and charity activities with independent accounting organization for activities of mobilization, receipt, distribution and use of voluntary donations shall continue implementing the applicable accounting regime until the end of fiscal year 2022. From the fiscal year 2023, the accounting books must be transferred and comply with the provisions of this Circular.

2. The Mobilization Boards of the "For the Poor" Fund at all levels that apply the Circular No. 103/2018/TT-BTC dated November 14, 2018 of the Ministry of Finance to the end of fiscal year 2022 must transfer accounting books and comply with the provisions of this Circular from fiscal year 2023.

3. Other organizations, agencies, units and individuals not specified in Clauses 1 and 2 of this Article involved in mobilization, receipt, distribution and use of voluntary contributions to carry out social and charity activities shall comply with the provisions of this Circular from its effective date.

Article 16. Implementation organization

1. The Ministries, sectors and People's Committees of provinces and centrally run cities are responsible for directing and implementing this Circular to units, organizations and individuals participating in mobilization, receipt, distribution and use of voluntary contributions to carry out social and charity activities under their responsibility or management.

2. The Director of Accounting and Auditing Supervisory Department, the Director of Public Sector Department, the Director of State Budget Department, the Chief of the Ministry Office and the heads of the relevant units under the Ministry of Finance shall take responsibilities for the dissemination, guidance, inspection and implementation of this Circular./.

* All Appendices are not translated herein.