SECURITIES AND EXCHANGE SURVEILLANCE COMMISSION

January 26, 2001

      The Securities and Exchange Surveillance Commission (SESC) conducted the inspection of Rabo Securities Asia B V Tokyo Branch (Rabo), based on a provision of the Law on Foreign Securities Firms (LFSF), and found legal violations described below.

      The SESC sent a recommendation to the Prime Minister and the Commissioner of Financial Services Agency (FSA) to take a disciplinary action against Rabo, pursuant to Article 20(1) of the FSA Establishment Law on January 26, 2001.

1. Misstatements concerning securities and other transactions

      On September 22, 1999, when selling a bond to several customers, Rabo erroneously showed its unit price that did not include its accrued interest. Although Rabo should have consulted with all those customers about revising the unit price, it showed a false revised unit price of the bond only to one major customer, hiding the fact that the revised unit price included the accrued interest for the whole customers; Rabo had schemed to make only the customer with larger amounts of dealings bear the whole accrued interest.

(Violation of a Ministerial Ordinance, Article 42 (1) (ix) of the Security and Exchange Law (SEL), including the application of Article 14 (1) of the LFSF)

2. Provision of property gains to increase gains

      In addition to the above action, Rabo offered its unit price substantially lower than the proper price only to the other remaining customers; consequently, to make them acquire property gains, Rabo provided approximately 8,500,000 yen in total to them.

(Violation of Article 42-2 (1) (iii) of the SEL, including the application of Article 14(1) of the LFSF)