In conclusion, the responding banks raised four points, although different banks focused on some or at least one of the following concerns:
- The referral does not meet the requirements set by the Court's 2020 order, as the Commission failed to present the necessary facts as mandated in the revised referral affidavit.
- The referral does not establish personal and subject matter jurisdiction for peregrini banks, nor does it provide subject matter jurisdiction for incola banks and local peregrini banks.
- The referral is unclear and problematic, lacking sufficient details in the affidavit to prove that the respondent banks were involved in a single overarching conspiracy.
- The Commission improperly included certain respondent banks in the referral.