ASIA PROPERTIES INVESTMENTS INC
F-4/A, EX-99.2, 2000-09-25
REAL ESTATE
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SEC          THE  OFFICE  OF  SECURITIES  AND  EXCHANGE  COMMISSION

                                                 15th July 1999

To   Managing  Director
          ING  (Thailand)  Mutual  Fund  Management  Securities  Co.,  Ltd.

          No. Kor Lor Tor. Nor. 1089/2542 Re: Application for approval to
          ---------------------------------------------------------------
          establish and manage Mutual  Fund  Immovable  Asset  Bangkok  RE  Fund
           ---------------------------------------------------------------------

          Pursuant  to  the letter of your company No. ING. 044/2542, dated 20th
May  1999, No. ING. 059/2542, dated 27th May 1999, No. ING. 088/2542, dated 18th
June  1999,  No.  ING. 106/2542, dated 9th July 1999 and No. ING 107/2542, dated
12th  July  1999,  applying for approval to establish and manage the Mutual fund
Immovable  Asset  Bangkok  RE Fund, which is a mutual fund of immovable asset to
solve  the  problem  in  the  financial institute, the type no repurchase of the
investment  unit, the amount of capital of the project is 1,000 Million Baht and
not prescribing the ending period of the project, as per details already stated:

          The  Office  has  considered  and  would  like  to  state  as follows:
          1.It is approved that your company may establish and manage the Mutual
Fund  Immovable Asset Bangkok RE Fund, which is a mutual fund of immovable asset
to  solve  the problem in the financial institute, the type no repurchase of the
investment  unit, the amount of capital of the project is 1,000 Million Baht and
not prescribing the ending period of the project, as per details already stated,
as  applied  for;
          2. It is  permitted  that Asia Properties Inc. may hold the investment
unit of the Mutual Fund Immovable Asset Bangkok RE Fund for not more than 99% of
the  total  units sold of the Mutual Fund.  This is with the condition that this
Mutual  Fund  will  invest in the immovable asset, which Asia Properties Inc. or
associate  company  is the owner, by not more than One-third of net asset of the
mutual  fund,  and said Mutual Fund shall have holders of the investment unit as
the  institute investors according to the Notification of the SET and Securities
Commission, No. Gor Jor. 13/2539; Re: Submission and exemption of the submission
of  the  particulars and information on the offer to sell securities, dated 12th
September,  B.E.  2539,  for  not  less  than  10  institutes.

          For  your  information

                                   Yours  faithfully,


                                         Signature
                              (Mr.  Pakorn  Malahul  Ayudhaya)
                                   Secretary-General

Investment  Management  Supervision  Department
Tel.  252-3223  ext.  2734


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