Agreement No. 7 (2026) Modifying Articles 4 and 5 of Agreement No. 4-2011 on Banking Commissions and Surcharges

Republic of Panama Superintendency of Banks of Panama AGREEMENT No. 7-2026 (August 25, 2026) "By which articles 4 and 5 of Agreement No. 4-2011, which dictate rules for the collection of certain commissions and surcharges by banking entities, are modified" THE BOARD OF DIRECTORS In use of its legal powers, and WHEREAS: That following the issuance of Decree Law No. 2 of February 22, 2008, the Executive Body prepared a systematic ordering in the form of a Single Text of Decree Law No. 9 of 1998 and all its modifications, which was approved by Executive Decree No. 52 of April 30, 2008, hereinafter the Banking Law; That in accordance with subparagraphs 3 and 4 of article 5 of the Banking Law, the objectives of the Superintendency of Banks are to promote public confidence in the Banking System and to ensure the legal balance between the banking system and its clients; That in accordance with subparagraph 5 of article 11 of the Banking Law, it is the responsibility of this Superintendency to establish, in the administrative sphere, the interpretation and scope of legal or regulatory provisions in banking matters; That in accordance with subparagraph 19 of article 16 of the Banking Law, the Superintendent of Banks has the power to ensure that banks provide their clients with information that ensures the greatest transparency of banking operations; That the principles established in titles V and VI of the Banking Law are intended to provide the contractual relationship with the necessary and desired equity to guarantee the balance of the parties; That by Agreement No. 4-2011, rules were established for the collection of certain commissions and surcharges by banking entities; That in working sessions of this Board of Directors, the need and convenience of modifying articles 4 and 5 of Agreement No. 4-2011, regarding the collection of certain commissions and surcharges in passive and active operations, has been highlighted in order to guarantee the balance between the client and banking entities. AGREES: ARTICLE 1. Literals "l", "m", "n", and "o" are added to article 4 of Agreement No. 4-2011 of May 4, 2011, as follows: "ARTICLE 4. RULES FOR THE COLLECTION OF CERTAIN COMMISSIONS OR SURCHARGES IN PASSIVE OPERATIONS. In accordance with the provisions contained in Article 192 and subparagraph 4 of Article 193 of the Banking Law, banks shall follow the following guidelines regarding the collection of commissions or surcharges for the concepts described below: Agreement No. 7-2026 Page 2 of 3 ... l. No commissions or charges shall be collected for cash withdrawals from savings or current accounts when these are made in person at the banking entity; m. No commissions or charges shall be collected for cash deposits made into savings or current accounts when the depositor appears in person at the banking entity during business hours. The handling of high volumes of cash is excluded from this provision. For the purposes of this literal, the handling of high volumes of cash shall be understood as when the depositor makes one or more deposits that, when summed, exceed ten thousand balboas (B/.10,000.00) in a calendar month; this provision shall also apply in cases of coin deposits, including one balboa coins, when these exceed five thousand balboas (B/.5,000.00) in a calendar month; n. No commissions or charges shall be collected for the designation or change of beneficiaries in savings, current, or fixed-term accounts; o. No commissions or charges shall be collected for the issuance of the SWIFT message confirmation." ARTICLE 2. Literals "e" and "p" of article 5 of Agreement No. 4-2011 of May 4, 2011, are modified as follows: "ARTICLE 5. RULES FOR THE COLLECTION OF CERTAIN COMMISSIONS AND SURCHARGES IN ACTIVE OPERATIONS. Banks shall follow the following guidelines regarding the collection of certain commissions or surcharges in active operations: ... e. No commissions or charges shall be collected for early cancellation, extraordinary payments, or for migration of a housing mortgage loan to another banking entity in the market, when more than five (5) years of the originally agreed term have elapsed. In cases of consumer credit, agricultural credit, and housing mortgage loans covered by special preferential interest laws, no commissions or charges shall be collected, at any time, for early cancellation, extraordinary payments, or for migration of these credits. In cases of housing mortgage loans, when the banking entity, in use of its contractual powers, modifies the clauses of the original contract, increasing the nominal interest rate, during the first five (5) years of the granting of the credit facility, the client shall not be charged commissions or charges for early cancellation or for migration of the credit to another banking entity; ... p. No commissions or charges shall be collected for the issuance and delivery of the certificate of the debtor's credit situation or balance letter; ..." ARTICLE 3. Literals "r", "s", "t", "u" and paragraph 2 are added to article 5 of Agreement No. 4-2011 of May 4, 2011, as follows: "ARTICLE 5. RULES FOR THE COLLECTION OF CERTAIN COMMISSIONS AND SURCHARGES IN ACTIVE OPERATIONS. Banks shall follow the following guidelines regarding the collection of certain commissions or surcharges in active operations: ... Agreement No. 7-2026 Page 3 of 3 r. No commissions or charges shall be collected for making payments in person at the banking entity; s. No commissions or charges shall be collected for the issuance of the bank reference letter; t. No commissions or charges shall be collected for the issuance of the payment history requested by the client when it is required once a year; u. In compliance with the provisions of article 241, subparagraph 16 of Law No. 12 of 2012 which establishes obligations for insurers, no commissions or charges shall be collected from a client for not presenting the renewal of the insurance policy to the banking entity. In cases where the insurer, in compliance with its obligations, notifies the banking entity of the cancellation of the policy or suspension of coverage and the client does not present the new policy to the banking entity, if the bank includes the guaranteed asset within the collective policy, it must ensure that the corresponding notifications are made to the client in accordance with the provisions of article 11-A of Agreement No. 1-2011. In the event that the client demonstrates that the new policy was presented to the banking entity and the bank has collected the commission or charge, it must proceed with the immediate reversal of the charge made. Likewise, in the event that the bank proceeds to include the guaranteed asset in the collective policy, and the client demonstrates that they maintain an individual policy which had been presented to the banking entity, the bank must proceed with the reversal of the corresponding charge. PARAGRAPH 1. In cases of default in the payment of obligations, the bank may not restrict the client's access to information on the defaulted credit through the electronic banking service. PARAGRAPH 2. In cases of amortizable loans through periodic payments, when the client is up to date in the fulfillment of their obligations and makes payments or installments for an amount greater than the agreed installment, the banking entity must apply the excess or remainder to the outstanding principal of the obligation, without applying it to interest or future unmatured installments or payments." ARTICLE 4. EFFECTIVE DATE. The provisions of this Agreement will come into force starting from January four (4), 2027. Given in Panama City, on the twenty-fifth (25th) day of the month of August of two thousand twenty-six (2026). COMMUNICATE, PUBLISH, AND COMPLY. THE PRESIDENT, THE SECRETARY, Felipe Echandi Lacayo David Alberto Davarro