Riggs National Corporation & Subsidiaries (f.k.a. Riggs National Bank and Subsidiaries) - Page 47

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               For higher consideration.                                              
               Brasilia,                                                              
               /Eivany Antonio da Silva/                                              
               Assistant Secretary of  *  *  * [the Brazilian IRS]                    
               I agree with the above Opinion, which I approve.                       
               For the consideration of the Minister of Finance.                      
               Brasilia,                                                              
               /Luiz Romero Patury Accioly/                                           
               Acting Secretary of  *  *  *  [the Brazilian IRS]                      
          R.  Foreign Lenders' Efforts During the Phase III Negotiations To           
          Have the Central Bank Issue Them DARF's in Other Situations Not             
          Covered in the March 1984 Brazilian IRS Ruling                              
               During the phase III negotiations, a number of foreign lenders         
          sought to have the Central Bank issue them DARF's with respect to           
          all of its net loan interest remittances to them, and not just on           
          its restructuring debt interest remittances during the relending            
          periods of the DFA's and the CGA's.  The Brazilians rejected these          
          efforts to have the Central Bank issue DARF's to the foreign                
          lenders in additional situations outside the scope of the                   
          borrowers-to-be theory employed in the March 1984 Brazilian IRS             
          ruling to the Central Bank.  However, the Brazilians did indicate           
          some willingness to negotiate a longer relending period with                
          respect to the proposed phase III DFA.                                      
               On January 5, 1985, the Brazilians submitted their written             
          comments to a proposed draft of certain phase III basic business            
          terms that had been prepared by the BAC.  Their comments with               
          respect to the Central Bank's provision of DARF's were as follows:          
               WITHHOLDING TAX RECEIPTS                                               
               In the first place, Pricing and Withholding Tax Receipts               
               are intimately linked and shall be dealt with altogether.              



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