Adjunct Superintendent for Prudential Supervision Resolution No. 018-2025-SMV/10

PERU Ministry of Economy and Finance

SMV
Securities Market Superintendency
Electronically signed document in the framework of Law No. 27269, Law of Digital Signatures and Certificates, its Regulations and amendments. The integrity of the document and authorship Adjunct Superintendent Resolution SMV No. 018-2025-SMV/10 Lima, April 4, 2025 Subject: EAFC Maquisistema S.A. is sanctioned with a reprimand for having committed one (1) minor infraction typified in Annex I, numeral 3, clause 3.1 of the Sanctions Regulation, for failing to submit the interim financial information of the fund system it administers corresponding to the month of January 2021 within the period established in the applicable regulations. Administered Entity: EAFC Maquisistema S.A Subject: Administrative sanctioning procedure File No.: 2025006297

The Adjunct Superintendent for Prudential Supervision

SEEN:

The administrative file No. 2025006297, and Report No. 355-2025-SMV/10.3, issued by the General Superintendent of Prudential Compliance; as well as the defenses of EAFC Maquisistema S.A; and,

CONSIDERING:

In accordance with Article 1 of Law No. 29782, Law for the Strengthening of Securities Market Supervision, the name of the National Commission for the Supervision of Companies and Securities (CONASEV) is replaced by that of the Securities Market Superintendency (SMV), so that any reference to CONASEV in legal norms shall be understood as referring to the SMV;

I. FACTS

As a result of supervision activities by the SMV, through Letter No. 878-2025-SMV/10.3, notified on February 14, 2025 (hereinafter, CHARGES LETTER), an administrative sanctioning procedure was initiated against EAFC Maquisistema S.A (hereinafter, MAQUISISTEMA EAFC), having verified that it failed to timely submit to the Securities Market Superintendency (SMV) the interim financial information of the collective fund system it administers for the month of January 2021;

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With a written submission presented on February 25, 2025, MAQUISISTEMA EAFC presented the defenses against the charge formulated through the CHARGES LETTER;
The charge formulated, as well as the defenses presented by MAQUISISTEMA EAFC, have been the subject of evaluation by the General Superintendent of Prudential Compliance in Report No. 355-2025-SMV/10.3, which has been submitted to the knowledge of this Adjunct Superintendency;
In observance of the Principle of Due Process contemplated both in Article IV, clause 1, numeral 1.2 of the Preliminary Title, as well as in Article 248, numeral 2, of the Single Text of the General Administrative Procedure Law, Law No. 27444, approved by Supreme Decree No. 004-2019-JUS, published on January 25, 2019 (hereinafter, TUO LPAG), through Letter No. 1386-2025-SMV/10, the administrative file to which this resolution refers was made available to MAQUISISTEMA EAFC for its review;

II. MATTERS TO BE DETERMINED

In the present administrative procedure, in the opinion of this Adjunct Superintendency, it corresponds to determine the following:

a. Whether MAQUISISTEMA EAFC incurred or did not incur an infraction for failing to present the interim financial information of the collective fund system it administers corresponding to the month of January 2021, within the period established in Article 74 of the Regulation of the Collective Fund System and its Administrator Companies, approved by Resolution No. 020-2014-SMV/01 (hereinafter, REGULATION), in force on the date the facts occurred;

b. Whether it corresponds or does not correspond to impose sanctions on MAQUISISTEMA EAFC;

III. ANALYSIS

3.1. Of the Applicable Normative

Regarding the interim financial information that collective fund administrator companies must send to the SMV regarding the collective funds they administer, Article 74, literal a) of the REGULATION establishes the following:

“Article 74.- Information on the Managed Collective Funds

The administrator must send to the SMV the following:

a) Interim financial information corresponding to the close of each month, in accordance with what is established in the Chart of Accounts for Collective Funds, within thirty (30) calendar days following each of them. (…)”;

3.2. Of the Formulated Charge

Through the CHARGES LETTER, one (1) charge was formulated against MAQUISISTEMA EAFC for failing to present, within the period established by the applicable regulations for collective fund administrator companies, the interim financial information of the collective fund system it administers, corresponding to the month of January 2021. It should be indicated that the deadline for the

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submission of this information was March 2, 2021; however, it was sent to the SMV on March 5, 2021 1;

In this sense, it was imputed to MAQUISISTEMA EAFC that it had committed one (1) minor infraction, typified in Annex I, numeral 3, clause 3.1 of the Sanctions Regulation, approved by SMV Resolution No. 035-2018-SMV/01 (hereinafter, SANCTIONS REGULATION);

3.3. Of the Defenses

In response to the CHARGES LETTER, MAQUISISTEMA EAFC states that on March 5, 2021 at 12:50 hours, it sent the interim financial information for January 2021. It adds that this information was approved within legal deadlines and its presentation was entered into conformity in the MVNet system, according to the receipt charge it indicates attaching; however, subsequently, on February 14, 2025, the SMV alleges that the information should have been presented on March 2, 2025, imputing to them an infraction for non-compliance with the obligation provided in literal a) of Article 74 of the REGULATION;
With regard to what was stated, the administrator company mentions that, as indicated in the CHARGES LETTER, the interim financial information of the collective fund system it administers should have been presented on March 2, 2021; however, it was presented on March 5, 2021. In other words, in the opinion of MAQUISISTEMA EAFC, the SMV itself had certified the remediation of the conduct with a date prior to the imputation of charges;
In this context, MAQUISISTEMA EAFC indicates that the conduct intended to be remedied had already been remedied prior to the imputation of charges. Regarding this, it maintains that the recent modifications inserted into Law No. 27444 exempt any responsibility from the administered party that remedies a punishable fact before the imputation of charges. The administrator company adds that this is specifically established in Article 236-A of the aforementioned law. Regarding this, it cites the following:

“Article 236-A.- Exemptions and mitigating factors for responsibility for infractions

1.- The following constitute conditions exempting responsibility for infractions:
(…)

f) The voluntary remediation by the possible sanctioned party of the act or omission imputed as constitutive of an administrative infraction, prior to the notification of the imputation of charges referred to in clause 3) of Article 235”. (Underlining by the administrator company);

MAQUISISTEMA EAFC alleges that voluntary remediation does not seek to reverse the effects of the non-compliance, as specialized courts on contentious administrative matters have stated. Regarding this, the administrator company cites the sentence 2 issued on May 7, 2024, which states the following:

1 File No. 2021004518.
2 Sentence issued by the 25th Specialized Court in Contentious Administrative Matters, in File No. 12459- 2023-0-1801-JR-CA-25, in the lawsuit filed by Alicorp S.A.A. against INDECOPI.

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“ELEVENTH: (…) or, literal f) of Article 257 of the TUO of the LPAG, does not establish in the case of voluntary remediation the reversal of the effects of the period in which the infringing conduct was deployed, to apply the exemption of responsibility.

TWELFTH: For these reasons, since the reversal of the effects of the infringing conduct during the time it took place is not a requirement for the application of the exemption of responsibility for voluntary remediation, it did not correspond for the Administrative Authority to dismiss said request (…); and, on the contrary, upholding it, it should have declared the ex officio complaint followed against the now plaintiff inadmissible”;

With regard to the above, the administrator company states that Article 236-A applies in any situation and before any act or omission imputed as an infraction. In other words, it indicates that if on the date the entity was about to impute the infraction the infringing fact no longer existed, responsibility is exempted and, therefore, no sanction proceeds;
MAQUISISTEMA EAFC alleges that it is not appropriate to sanction a fact that, despite constituting an infraction, had already been remedied by the date of imputation of charges, since at that moment the responsibility of the offender extinguishes. Thus, they indicate that in the case where the monthly interim financial information had been omitted to be presented by March 2, 2021, by the date of imputation of charges said information had already been presented, remedying the infringing conduct;
MAQUISISTEMA EAFC states that the SMV is fully aware that the facts imputed as an infraction do not subsist on the date, since the conduct has been fully remedied. In effect, they emphasize that the monthly interim financial information for January 2021 was presented spontaneously well before February 14, 2025, the date on which they are only now imputing the charges;
The administrator company adds that the SMV's own system allows for spontaneous remediation of the information required in literal a) of Article 74 of the REGULATION. MAQUISISTEMA EAFC specifies that after the deadline to present said information, the reception system remains operational and, therefore, there is no technical or legal impediment to spontaneously comply with the corresponding obligation;
MAQUISISTEMA EAFC indicates that with the same criterion, the Superintendent of the Securities Market through Resolution No. 033-2019-SMV/02 issued on March 19, 2019, has stated the following 3:

“(…) In the present case, MAQUISISTEMA sent the required information before the imputation of charges, therefore (…) it corresponds to apply the exemption of responsibility for voluntary remediation contained in literal f) of clause 1 of Article 257 of the TUO LPAG and archive the charge formulated against MAQUISISTEMA”;

For the reasons stated, MAQUISISTEMA EAFC states that in strict compliance with the protection of the rights of the administered parties that inspire the recent modifications inserted into the General Administrative Procedure Law, it requests that the present procedure be archived;
The administrator company attaches to its defenses a copy of the information receipt charge dated March 5, 2021,

3 Issued in File No. 2017007943.

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corresponding to financial information of the collective fund system as of January 31, 2021;

3.4 Evaluation of the Defenses

This analysis must begin by stating that MAQUISISTEMA EAFC has indicated in its defenses that it presented the interim financial information of the collective fund system it administers on March 5, 2021, that is, after the period established in Article 74, literal a) of the REGULATION;
Regarding the argument referred to the fact that MVNET would allow spontaneous remediation of the financial information established in Article 74, literal a) of the REGULATION, due to the fact that after the deadline the system remains operational, with no technical or legal impediment to comply with the obligation, it should be noted that the fact that the MVNet system allows the sending and reception of various information that includes, for example, that sent late, does not prevent the determination of infractions and sanctions by the SMV;
Furthermore, it must be considered that MVNet is a WEB system for information exchange, which allows information storage, uses digital signature, authentication and channels for secure and efficient information exchange, between the obligated entities and the SMV. Thus, among the options it offers, are those referred to the sending of information that, according to the normative framework, obligated entities must present to the SMV. Likewise, the normative framework establishes exceptions to the use of MVNet, in which cases the information and documentation can be presented through the SMV's Documentary Procedure;
In this sense, both MVNet, and Documentary Procedure, constitute means of continuous exchange and reception of information, which generate receipt charges; being that from the evaluation of information flows, possible indications of infraction or the initiation of administrative sanctioning procedures are determined, among others, based on the respective analysis of opportunity, omission and content;
Therefore, MAQUISISTEMA's argument is not supportable, since the determination of infractions does not depend on the availability of exchange means, such as MVNet;
On the other hand, the administrator company cites Resolution No. 033-2019-SMV/02, issued on March 19, 2019 (hereinafter, RESOLUTION 33) considering that the same would constitute a precedent of acceptance of voluntary remediation to be taken into account in the present case;
Regarding this, it should be specified that RESOLUTION 33 refers to the timeliness in the presentation of the Independent Annual Compliance Report (hereinafter, INDEPENDENT REPORT) as established in Article 35, numeral 35.2 of the Standards for the Prevention of Money Laundering and Financing of Terrorism, approved by CONASEV Resolution No. 033-2011-EF/94.01.1 (hereinafter, PLAFT STANDARDS), that is, regarding information for supervision purposes by the SMV, distinct from the interim financial information subject of the charge imputation, which directly affects the legal good of transparency and therefore the decision-making process of an associate;

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In effect, the infraction type subject of evaluation in RESOLUTION 33 is contained in Annex XIX, clause 2, numeral 2.12 of the Sanctions Regulation, approved by CONASEV Resolution No. 055-2001-EF/94.10 (hereinafter, PREVIOUS SANCTIONS REGULATION), which prescribed as a grave infraction: “Not to present timely, or to do so without observing the money laundering and terrorism financing prevention regulations, to the SMV or to the UIF-Peru, as the case may be, the respective reports or the Special Annual Audit Plan”;
In the present case, a minor infraction established in Annex I, numeral 3, clause 3.1 of the SANCTIONS REGULATION is evaluated: “To present outside the established period, or to do so incompletely, or, without observing the technical specifications approved by the SMV or without communicating the approval by the corresponding corporate body, to the SMV, to the Stock Exchange, to the entity in charge of the centralized negotiation mechanism or to any other entity or subject of the securities market, the audited individual or consolidated financial information, the individual or consolidated interim financial statements, management report, special audit report, material facts, and annual memoranda”;
As can be seen from the previously cited norms, the infractions evaluated in RESOLUTION 33 and in the present administrative sanctioning procedure are of different nature and therefore constitute different factual situations of different nature and different legal consequences, in this sense, it is not legally admissible to maintain that we are facing situations of information of the same nature;
With regard to what was stated by MAQUISISTEMA EAFC, regarding the fact that in the present case the voluntary remediation of the presentation of the information subject of analysis must be evaluated, before the notification of charges, as an exemption of responsibility, it must be indicated that this point will be analyzed in the “Evaluation of the Sanction” section of this Resolution;
Therefore, in the present case, it is verified that MAQUISISTEMA EAFC presented outside the period established in Article 74, literal a), of the REGULATION, the interim financial information of the collective fund system corresponding to the close of the month of January 2021. This financial information should have been presented, at the latest, on March 2, 2021; however, it was presented on March 5, 2021;
In accordance with what has been exposed, it is concluded that MAQUISISTEMA EAFC has not disproven the charge imputed;
Consequently, it is observed that MAQUISISTEMA EAFC has committed one (1) infraction classified as minor, typified in Annex I, numeral 3, clause 3.1, of the SANCTIONS REGULATION according to which it constitutes an infraction: “To present outside the established period, or to do so incompletely, or, without observing the technical specifications approved by the SMV or without communicating the approval by the corresponding corporate body, to the SMV, to the Stock Exchange, to the entity in charge of the centralized negotiation mechanism or to any other entity or subject of the securities market, the audited individual or consolidated financial information, the individual or consolidated interim financial statements, management report, special audit report, material facts, and annual memoranda”;

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IV. EVALUATION OF THE SANCTION

In accordance with what is established in Article 39 of the SANCTIONS REGULATION, the commission of a minor nature infraction is subject to a sanction corresponding to a reprimand or a fine not less than one (1) and up to twenty-five (25) Tax Units (UIT);
Regarding this, taking into account that in the present sanctioning procedure one (1) infraction typified as minor regarding the non-compliance with the presentation period of the interim financial information is evaluated, it must be considered that clause 1 of the “Criteria Applicable to the Administrative Sanctioning Procedure for Non-Compliance with the Norms Regulating the Submission of Periodic or Occasional Information”, approved by SMV Resolution No. 006-2012-SMV/01 and its amendment 4 (hereinafter, SANCTION CRITERIA) provides that the purpose of said criteria is “to establish sanction parameters within the framework of the General Administrative Procedure Law, the Securities Market Law and the Decree Law on Collective Fund Administrator Companies that allow applying sanctions to issuers with values registered in the Public Registry of the Securities Market, legal persons registered in the Registries under the charge of the SMV, and other persons obliged to present periodic or occasional information for non-compliances in the timely submission of said information that are typified as minor infractions in the annexes of the Sanctions Regulation, approved by CONASEV Resolution No. 055-2001-EF-94.10. The criteria that follow are developed exclusively for non-compliances with the norms regulating the submission of periodic or occasional information and do not apply extensively to other cases investigated by this Superintendency”;
Therefore, to evaluate the sanction that must be imposed on MAQUISISTEMA EAFC for the non-compliance with the presentation period of periodic information described in this Resolution, it corresponds to apply the SANCTION CRITERIA;
Likewise, it must be mentioned that the application of the SANCTION CRITERIA observes the principle of proportionality established in the TUO LPAG, since it allows determining in a predictable manner for the administered party, the sanctions to be imposed on issuers of values, on persons registered in the Public Registry of the Securities Market and on collective fund administrator companies, for non-compliances with the periods for the submission of information to which they are obliged by the norms;
For the purpose of determining the sanction that corresponds to the infraction subject of evaluation, and in accordance with what is established in clause 3.2 of the SANCTION CRITERIA, it must be taken into account the evaluation criteria disposed of in Article 248, numeral 3, of the TUO LPAG, in Article 7 of the Decree Law No. 21907 on Collective Fund Administrator Companies,

4 Modified by Article 3 of SMV Resolution No. 010-2014-SMV/01 of May 22, 2014, in force from May 25, 2014.
The aforementioned resolution modified, the first paragraph of the Fourth Criterion of clause 4.1, the numerals (ii), (iv), (v) (vi) and (vii) of clause 4.2 of the Criteria applicable to the administrative sanctioning procedure for non-compliance with the norms regulating the submission of periodic or occasional information, approved by SMV Resolution No. 006-2012-SMV/01.

PERU Ministry of Economy and Finance

5 By Law No. 27659, article 7 of Decree Law No. 21907 was modified, providing that collective fund administrator companies that contravene the provisions of said decree or the regulatory norms issued by the SMV will be sanctioned taking into consideration the offender's background, the circumstances of the commission of the infraction, the damage caused and its repercussion in the market.

PERÚ Ministry of Economy and Finance

SMV
Superintendencia del Mercado de Valores
Document electronically signed digitally under the framework of Law No. 27269, Law of Digital Signatures and Certificates, its Regulations and modifications. The integrity of the document and the authorship directly with the infraction subject of analysis in the present administrative sanctioning procedure;
48. Regarding the probability of detection of the infractions, it must be indicated that in the present case the infraction in which MAQUISISTEMA EAFC has incurred was evidenced as a result of the supervision and control activities carried out by the SMV regarding the compliance with the timely presentation of periodic and eventual information, according to what is established in the applicable regulations; therefore, the probability of detection was high;
49. On the gravity of the damage to the public interest and/or protected legal interest. Regarding this, it must be taken into consideration that regarding the submission of periodic information, any non-compliance with the regulations on its timely presentation, that is, the non-observance of the deadlines established to present said information, affects the transparency of the collective fund system, as this safeguards the right of the members (actual and potential) and the general public to access said information in a timely manner in order to adopt investment decisions or carry out a certain evaluation; likewise, it affects the SMV in the implementation of its supervision and control activities that seek to protect the integrity of the market;
50. Therefore, it can be affirmed that MAQUISISTEMA EAFC has affected the protected legal interest which is the transparency of the collective fund system, since it submitted late the intermediate financial information of the collective fund system it administers, corresponding to the month of January 2021;
51. As for the existence or not of intent in the offender's conduct, it has not been evidenced that MAQUISISTEMA EAFC acted with intent in the commission of the infraction subject of evaluation;
52. Continuing with the analysis, it corresponds to determine the sanction to be imposed on MAQUISISTEMA EAFC for the infraction subject of analysis. In this sense, the SANCTIONS CRITERIA, in force at the time the facts occurred, establish that a reprimand sanction may be imposed when the following guidelines established in subsection 4.2, numeral (ii) of said criteria are met concurrently: (i) the impact on market transparency is minimal; (ii) the infraction committed has not caused concrete prejudice to investors or members; (iii) the offending subject does not have a background or, if it does, it concerns infractions classified as minor offenses imposed in the four (4) years prior to the commission of the infraction being evaluated; (iv) the offending subject has not obtained a benefit from its illegal conduct; and, (v) it has not been proven that the offender acted with intent in the commission of the infraction;
53. Likewise, said SANCTIONS CRITERIA establish that if it does not correspond to apply a reprimand sanction, a fine sanction must be imposed;
54. On this matter, as can be appreciated from the evaluation carried out in this Resolution, it has been verified that MAQUISISTEMA EAFC has no record of sanction background in the four (4) years prior to the commission of the infraction being evaluated;
55. Likewise, it has not been proven that the infraction committed caused concrete prejudice to investors or members, it has not been evidenced that MAQUISISTEMA EAFC obtained a benefit from its illegal conduct, nor that it has been proven that it acted with intent in the commission of the infractions and no recidivism has been observed in the present case;
56. Regarding the condition referred to that the impact on market transparency be minimal, it must be warned in principle and as mentioned in the evaluation of the sanction criteria, that any non-compliance with the regulations regarding the deadlines established to present periodic information affects the transparency of the collective fund system, even more so if this non-compliance persists over time; since said information is relevant not only for the members, but for the market in general. In this sense, it is the obligation of every administrator company to present the periodic information required by the regulations within the established deadlines, that is, in a timely manner;
57. Nevertheless, it must be indicated that the intermediate financial information of the collective fund system administered by MAQUISISTEMA EAFC, corresponding to the month of January 2021, although it presents a delay of three (3) days for its submission, it can be appreciated that during the period in which MAQUISISTEMA EAFC did not report said information to the SMV, the degree of impact on market transparency has been minimal. Without prejudice to the fact that in similar cases, a greater delay in the submission of said information may determine a greater degree of impact on the transparency of the collective fund system;
58. In this sense, as a result of the evaluation carried out, it is observed that MAQUISISTEMA EAFC meets the conditions established in subsection 4.2, numeral (ii) of the SANCTIONS CRITERIA; therefore, according to said criteria, it corresponds to apply a reprimand sanction for the infraction under analysis;
59. On the other hand, it should be noted that in the present procedure no aggravating circumstances contemplated in subsection 4.2, numeral (vi) of the aforementioned SANCTIONS CRITERIA have been determined;
EVALUATION OF EXEMPTIONS AND MITIGATING FACTORS OF LIABILITY
60. In addition to the above, it corresponds to analyze the exemption and mitigating circumstances of liability established in article 257 of the TUO LPAG 6
;
61. On this matter, MAQUISISTEMA EAFC has requested that the exemption of liability for voluntary remediation be applied to its case, since through the submission of the intermediate financial information of the system corresponding to the month of January 2021, on March 05, 2021 before the charging of charges, it would have remedied the conduct that is intended to be imputed to it;
62. Regarding this, it must be indicated that the application of said exemption of liability depends on the constitutive elements of the infraction type, insofar as literal f) numeral 1 of article 257 of the TUO LPAG establishes as an exemption of liability the voluntary remediation of the act or omission imputed as constitutive of infraction; that is, what must be remedied is the act or omission imputed itself, not the consequences of the regulatory infraction;
63. Now, in the present sanctioning procedure, an infraction regarding the timely presentation of information required by the SMV to collective fund administrator companies according to the REGULATION is evaluated, which is typified in Annex I, numeral 3, subsection 3.1 of the SANCTIONS REGULATION, whose text is as follows: "Submit outside the established deadline, (...), to the SMV, (...) the audited individual or consolidated financial information, the individual or consolidated intermediate financial statements, management report, special audit report, material events, and annual reports";
64. In this sense, from the infraction type imputed in the present case, it emerges that the constitutive elements of infractions regarding untimely presentation is precisely the non-compliance with the delivery of information and/or documentation within a determined deadline, so that, taking into account the specific type of infraction, the non-compliance with the timely presentation of the information to which it was obligated could not be remedied with a late submission;
65. On this matter, it is worth highlighting the relevance that said information has for the members (both existing and those that could potentially join the collective fund system) taking into account that, for example, financial information, among others, allow to evaluate and determine the economic and financial situation of the collective fund system under administration, the effects of adopted decisions, perspectives and projections, among others, for which it must be available to members and potential members so that their decisions are based on a timely presentation;
66. In this sense, a late submission causes immediate prejudice and affects transparency in the fund system, as it constitutes essential information for members (actual and potential) and the general public in order to adopt decisions; in this sense, recognizing that late submission of information of this nature (having sent it before the start of the sanctioning procedure) is not sanctionable, could generate inadequate incentives in the market; since any late submission of financial information could be remedied even in longer periods, which would mean a serious detriment to the efficiency and transparency of the collective fund system;
67. On this matter, the Third Specialized Chamber in Administrative Litigation in Resolution No. 7 of File No. 1231-2022: states:
"(...)

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7
"10https://dimensionmercantil.pe/la-subsanacion-voluntaria-de-infracciones-como-eximente-deresponsabilidadel-caso-del-tribunal-de-sanciones-de-susalud/" 8 According to the principle of transparency of the securities market, the information made available to investors and the general public must meet certain conditions, such as truthfulness, sufficiency, and timeliness, in order to protect investors and promote efficient and transparent markets. 9 Established in article 27, literal f) of the SANCTIONS REGULATION.
Article 27.- Exemptions of liability for infractions
Constitute conditions exempting liability for infractions the following:
(...) f) voluntary remediation by the possible sanctioned person of the act or omission imputed as constitutive of administrative infraction, prior to the notification of the charging of charges referred to in the LPAG and always that no communication demanding compliance with the obligation had been issued.

PERÚ Ministry of Economy and Finance

10
"Article 26.- MITIGATING FACTORS OF LIABILITY FOR INFRACTIONS Constitute conditions mitigating liability for infractions the following:
a) Recognition of liability of the offender in an express and written manner, once the administrative sanctioning procedure has been initiated.
(...) b) Contribution of the offender to the clarification of the infraction.
(...)".

PERÚ Ministry of Economy and Finance

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