Agreement of the Board of Directors of the National Commission for the Retirement Savings System Establishing Policies and Criteria on Commissions

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DOF: 21/05/2021

AGREEMENT of the Board of Directors of the National Commission for the Retirement Savings System, by which it issues Policies and Criteria on the matter of commissions.

At the margin, a seal with the National Coat of Arms, which says: United Mexican States.- TREASURY.- Ministry of

Treasury and Public Credit.- National Commission for the Retirement Savings System.

AGREEMENT of the Board of Directors of the National Commission for the Retirement Savings System,

by

which it issues Policies and Criteria on the matter of commissions.

The Board of Directors of the National Commission for the Retirement Savings System, in the First

Extraordinary Session of 2021, held on February 12, 2021, and the Second Ordinary Session

held on April 28, 2021, based on the provisions of Articles 1st, 2nd, 8th, last

paragraph, 18th second paragraph, 37th fifth, sixth, seventh, eighth, and sixteenth paragraphs, and 37-B of the

Law of the Retirement Savings Systems;

6th, 7th, 8th, 9th, 11, 12, and 13 of the Regulations of the Law of the

Retirement Savings Systems;

Tenth Transitory of the DECREE by which various provisions of the Social Security Law and the Law of the Retirement Savings Systems are reformed, added to, and repealed, published in the Official Gazette of the Federation on December 16, 2020, 1, 2

fraction I, 3, 4, 5, and 8 of the Internal Regulations of the National Commission for the Retirement Savings System, and

CONSIDERING

That the Retirement Savings System is a pillar of the country's social security system for the

well-being and peace of mind of Mexican workers. That through it, workers who contribute or

have contributed to the Mexican Social Security Institute (IMSS) or the Institute for Social Security and Services for State Workers (ISSSTE) accumulate the mandatory tripartite contributions

made by the Federal Government, employers, and workers during their working lives as well as those

made voluntarily in order to be able to use the resources in their retirement stage, which is why it is fundamental to maximize such savings;

That the commissions charged by Retirement Fund Administrators (AFORE) are a percentage

of the resources under their custody, and that the Board of Directors of the National Commission for the Retirement Savings

System (CONSAR) is responsible for authorizing or denying the requests that AFOREs submit in

November of each year, to set their amount;

That to authorize, if applicable, the commissions presented by the AFOREs, the Board of Directors of the

National Commission for the Retirement Savings System considers the amount of assets in administration;

the income obtained by the Administrators; the cost structure of the AFOREs; the level of other

commissions existing in the market, and the other elements that said governing body deems

pertinent;

That the AFOREs, in light of their fiduciary responsibility, must seek the highest possible efficiency in

their operational, administrative, commercial, investment, and any other type of costs, taking advantage

thereof of the economies of scale derived from the amount of resources that each of them manages both

in terms of amounts and the number of individual accounts under their management. Likewise, any possible

inefficiencies, in no case, shall be transferred to the savers of the Retirement Savings System in the form of commissions;

That the industries of Retirement Fund Administrators in individual capitalization systems,

both in Mexico and in other countries with pension systems and similar economic and

demographic characteristics, are characterized by the presence of significant economies of scale, as

demonstrated by studies and publications of the Organization for Economic Co-operation and Development

(OECD) and the International Organization of Pension Supervisors (IOPS);

That the presence of economies of scale in a context of imperfect markets generates

consolidations, imposes barriers to entry for new competitors, acts to the detriment of smaller AFOREs, promotes the existence of extraordinary rents, as well as operational, administrative, and financial inefficiencies of the AFOREs, which can in turn create incentives for collusion between

such financial entities, as well as the adoption of unfair commercial practices to the detriment of the interests of savers;

That savers of the Retirement Savings System can freely choose among AFOREs

in terms of their pension expectation, returns, commissions, customer service, and any other

consideration that contributes to their well-being;

That given the characteristics of the industry of individual capitalization systems in Mexico,

typically workers do not consider all sufficient elements to make the best decisions

for their retirement;

That although the procedures for commission requests and authorization established in paragraphs

fifth and sixth of Article 37 of the Law of the Retirement Savings Systems have been effective in

reducing the commissions charged by the Administrators, this has not been successful in promoting competition

via lower commissions among them. On the contrary, competition among Administrators occurs

mainly through excessive commercial spending on sales force that has benefited the worker little. This commercial spending represents an economic loss of the resources administered by the

AFOREs to the detriment of the worker. That Administrators should not transfer this type of expense to workers via the charging of their commissions and that the payment thereof by the worker should fundamentally focus on covering the adequate management and investment of their savings;

That healthy and free competition among AFOREs should occur in such terms as to dissuade

collusion and other unfair practices such as price discrimination, and notably, tied sales. The foregoing is especially relevant for AFOREs that have links or are part of financial and commercial groups;

That since the creation of the Retirement Savings System, important efforts have been made to

achieve a constant decrease in the commissions that AFOREs charge workers for the management of their individual account;

That to achieve a greater decrease in the charging of commissions, on August 22, 2019, it was published

in the Official Gazette of the Federation the "Agreement of the Board of Directors of the National Commission for the Retirement Savings System, by which it issued policies and criteria on the matter of commissions", through which it was proposed to achieve a gradual and continuous decrease in commissions so that by the year 2024, international standards in the matter of commissions would be reached;

That in the "Single Annex: International Market Standards in the Matter of Commissions in Defined Contribution Systems" of the Agreement indicated in the previous Consideration, with the aim of positioning

Mexico in the international landscape, reference was made to defined contribution systems that

by their age, objective, and industrial organization are most similar to the scheme operating in Mexico; among

such systems stand out those of Chile, Colombia, and the United States of America;

That the head of the Federal Executive presented to the Chamber of Deputies on September 25, 2020, the

Initiative with draft Decree by which various provisions of the

Social Security Law and the Law of the Retirement Savings Systems are reformed, added to, and repealed. That said Initiative, as it

derives from its statement of reasons, was based on what is determined in the "Single Annex: International Market Standards in the Matter of Commissions in Defined Contribution Systems" of the Agreement of the

Board of Directors of the National Commission for the Retirement Savings System cited above;

That in the aforementioned statement of reasons, it was considered that "the charging of commissions in Mexico would have

to be similar to the average charged in Chile, Colombia, and the United States of America, given that the first two countries in the contribution system have the same objective, while their industrial organization, as well as the degree of development of their financial system, are very similar to that of our country" and with respect to the United States of America, it considered "that it is the level that Mexico should aspire to

for being a member of the Treaty between Mexico, the United States, and Canada (USMCA), which keeps us in a permanent effort of competitive integration and improvement of labor conditions, in addition to being the country with which the Mexican financial system has the greatest relationship";

That as a result of the legislative process, the Congress of the Union approved the initiative presented by the Head

of the Federal Executive, resulting in the "DECREE by which various provisions of the Social Security Law and the Law of the Retirement Savings Systems are reformed, added to, and repealed", published in

the Official Gazette of the Federation on December 16, 2020, and which entered into force on January 1, 2021, through which, among other reforms, an eighth paragraph was added to Article 37 of the Law of the Retirement Savings Systems, which establishes verbatim the following: "The commissions charged by retirement fund administrators shall be subject to a maximum, which will result from the arithmetic average of the charges in the matter of commissions in defined contribution systems of the United States of America, Colombia, and Chile, in accordance with the policies and criteria issued to that effect by the Board of Directors of the Commission in accordance with the previous paragraph. To the extent that commissions in these countries have downward adjustments, the same reductions shall be applicable, and otherwise, the average being applied at the time shall be maintained";

That in compliance with the eighth paragraph of Article 37 of the Law of the Retirement Savings Systems,

and of the Tenth Transitory Article of the indicated Decree, it is necessary to issue a new Agreement

by which Policies and Criteria are issued that allow calculating and establishing a maximum to which the

commissions charged by AFOREs shall be subject, which will result from the arithmetic average of the charges in the matter of

commissions of investment vehicles in defined contribution systems of the United States of

America, Colombia, and Chile, and that to the extent that commissions in said countries have downward adjustments, the same reductions shall be applicable, and otherwise, the average being applied at the time shall be maintained. Such Policies and Criteria will begin to apply from the commission authorization process that will take place in the months of November and December 2021, and will be charged to workers

starting from the fiscal year 2022;

That for the determination of the methodology to calculate the maximum to which the commissions

charged by AFOREs to workers in the SAR shall be subject, various elements and

characteristics of the systems in the United States of America, Colombia, and Chile must be taken into account;

That the pension fund system in the United States of America is mostly of

Defined Benefit State Funds; however, the market for defined contribution pension plans, more similar to the Retirement Savings System, is constituted by Employer-Sponsored Occupational Plans (401k) and individual retirement accounts (IRA), in virtue that it is in said voluntary defined contribution plans where the employer (occupational plans) or the worker (individual plans) hires a financial services provider for the management of their savings or investments. With regard to financial companies that in the United States of America offer their services to plan sponsors or to individuals with IRAs, they charge a cost to their clients as a percentage of the assets managed in these funds;

That defined contribution plans in the United States of America cover more than 100 million

North Americans (approximately 60 percent of its Economically Active Population, EAP) (1). Of this universe, 37 million participants allocate all their savings to Target Date Funds, and 79 million maintain some percentage in this type of Funds. The Target Date Fund market in the United States of America currently has 33 private firms that, collectively, manage 1.6 trillion dollars of IRA and 401k plans administered through approximately 2,500 funds (2). However, this Target Date Fund market is concentrated in 10 providers that manage 95 percent of the assets (3). In addition, the management of Target Date Funds in the United States of America is carried out through Mutual Funds, being this a direct reference for AFOREs in Mexico, since from December 13, 2019, the Retirement Savings System adopted the Target Date Fund scheme for the investment of workers' resources (4). Therefore, the commission charging scheme of these vehicles and the mechanism of investment of resources that must be taken into account for the establishment of the maximum commissions to be charged in the Retirement Savings System is that of Target Date Funds in the United States of

America, as it constitutes the most direct reference with AFOREs in Mexico;

That the commissions charged in Colombia and Chile are defined from a percentage of the worker's

eligible or taxable salary, and that although in these last two countries the pension regime for workers in the formal private sector is similar to that of our country, there are certain demographic and structural differences in the labor market between these two countries and the case of Mexico;

That pension systems in Chile and Colombia present characteristics similar to the Retirement Savings System in Mexico with respect to the defined contribution model and its industrial organization (private firms that manage individual retirement and social security accounts). In both countries, there are private entities known as "Pension Fund Administrators" (AFPs). In the case of Chile, there are 7 AFPs that manage around 160,610 billion Chilean pesos (equivalent to 4.3 trillion Mexican pesos) for a total of 11.1 million savers, while in the case of

Colombia, the AFPs manage assets for an amount of 293,801 billion Colombian pesos

(equivalent to 1.6 trillion Mexican pesos) from 16.9 million affiliates;

As is known, in the case of Mexico, there are nine AFOREs, plus one public institution that performs

similar functions, and which collectively manage around 4.7 trillion Mexican pesos of savings of 67.6 million workers;

That in the case of Mexico, there is a single commission on the balance of the worker's individual account,

while in Chile and Colombia, AFPs charge a commission on flows as a percentage of the eligible or taxable salary of the account holder, the latter being comparable to the base salaries of workers who contribute to IMSS and ISSSTE, so it is necessary to consider these elements in the methodology so that this Board of Directors of CONSAR defines the maximum that AFOREs in Mexico will charge;

That knowing the comments presented through the public consultation mechanisms

established by the National Commission for Regulatory Improvement, based on the General Law for Regulatory Improvement, it is

necessary to adjust the methodology that allows calculating the maximum to which the commissions charged by AFOREs shall be subject, considering that their decrease should only occur when there is a decrease in commissions in the United States of America, Colombia, or Chile. Likewise, that in the received comments, greater clarity and precision were requested in some of the expressions relative to the description of the

methodology for calculating the maximum presented in the Single Annex of this Agreement;

That the methodology for calculating the maximum to which the commissions charged by AFOREs shall be subject,

has the purpose of benefiting workers and does not limit the annual growth of income generated

by commissions to continue with the operation of the SAR, considering the natural increase of the average balances of individual accounts and the increase in employer contributions derived from the Reform to the Social Security Law, published in the Official Gazette of the Federation on December 16, 2020, as well as

the

incorporation of new workers to the SAR, and their permanence in the same;

That without prejudice to the foregoing, in the event that the Board of Directors estimates that, as a whole, the

commission proposals of AFOREs are not excessive for workers, it is empowered to exercise the attributions to guarantee their competitiveness in accordance with Articles 37 and 37-B of the Law of the Retirement Savings Systems, and

That in compliance with what is established in Article 78 of the General Law for Regulatory Improvement, it must

be considered for the present Agreement, the simplification carried out through the very issuance of the present and through the Modifications and Additions to the General Provisions in the Matter of Operations of the Retirement Savings Systems, published in the Official Gazette of the Federation on May 15,

2020, specifically those contained in Article 13 of said regulation, has deemed it appropriate to issue

the

following:

AGREEMENT OF THE BOARD OF DIRECTORS OF THE NATIONAL COMMISSION FOR THE

RETIREMENT SAVINGS

SYSTEM, BY WHICH IT ISSUES POLICIES AND CRITERIA

ON THE MATTER OF COMMISSIONS

POLICIES AND CRITERIA ON THE MATTER OF COMMISSIONS

First.- The Board of Directors of the National Commission for the Retirement Savings System in exercise

of the attribution granted to it by paragraphs sixth, seventh

and eighth

of Article 37 of the Law of the Retirement Savings Systems, issues these Policies and Criteria, with the object of defining clear guidelines in the matter of commissions, particularly regarding the maximum dispersion permitted in the Retirement Savings System between the lowest and highest commission, as well as the cases in which the commissions to be charged for the administration of the individual accounts of the Retirement Savings Systems are considered excessive for the interests of workers; and in accordance with the eighth paragraph of Article 37 of the Law of the Retirement Savings Systems, to calculate and establish a maximum to which the commissions charged by Retirement Fund Administrators shall be subject, which will result from the arithmetic average of the charges in the matter of commissions in defined contribution systems of the United States of America,

Colombia, and Chile, and that, to the extent that commissions in these countries have downward adjustments, the same reductions shall be applicable to the commissions charged by Mexican Retirement Fund Administrators, and otherwise, the average being applied at the time shall be maintained.

Second.- In accordance with paragraphs fifth and sixth of Article 37 of the Law of the Retirement Savings Systems, Retirement Fund Administrators must present to the Board of Directors

of the National Commission for the Retirement Savings System, their commissions for authorization each year within the first ten business days of the month of November, to be applied in the following calendar year, without prejudice to being able to request a new commission authorization at any other time.

Retirement Fund Administrators, in their request, may include documents or studies on the state of the retirement savings systems that they deem relevant for the consideration of the Board of Directors of the National Commission for the Retirement Savings System.

In order to guarantee legal certainty to Retirement Fund Administrators, and in

congruence with the annual procedure for commission authorization request and approval or denial established in paragraphs fifth and sixth of Article 37 of the Law of the Retirement Savings Systems,

the charges in the matter of commissions in the United States of America, Colombia, and

Chile will be reviewed annually with data available until the end of the month of September. Based on said information, the Board of Directors of the National Commission for the Retirement Savings System will make known by the last business day of the month of October of each year, the maximum of the commissions that Retirement Fund Administrators may charge starting from the following calendar year. The National Commission for the Retirement Savings System will notify by official letter to Retirement Fund Administrators the modification or ratification of the maximum of commissions and publish it on its website. Likewise, the Commission will make known on the same date the values of the parameters used in the calculation of the maximum of commissions.

In the event that between October of the year in question and September of the following year, a

decrease in the commissions charged in the United States of America, Colombia, or Chile occurs, this will be

incorporated into the calculation of the maximum of commissions that will be made known in the month of October of the following year.

Likewise, the Board of Directors of the National Commission for the Retirement Savings System, once

analyzed the request, may demand additional information as well as clarifications, adjustments or, if applicable, deny the respective authorization when the commissions submitted for its authorization result excessive for the interests of workers, considering the amount of assets in administration; the income

obtained by Retirement Fund Administrators; the cost structure of Retirement Fund

Administrators; the level of other commissions present in the market, and the other elements that

said governing body deems pertinent.

The Board of Directors of the National Commission for the Retirement Savings System must resolve

expressly, founding and motivating, on the requested authorization within the term provided in Article

119 of the Law of the Retirement Savings Systems, except in the case of authorization requests

annual, in which case it must resolve by the last business day of December. Increases in commissions above the average of the rest of the authorized commissions shall not be authorized.

Third.- In accordance with the foregoing, the Policies and Criteria established in this Agreement shall begin to apply from the commission authorization process that will take place in the months of November and December 2021, and will be charged to workers starting from the 2022 fiscal year.

Fourth.- The Board of Directors of the National Commission for the Retirement Savings System, taking as a Criterion the interest of workers regarding the reduction of commissions charged by Retirement Fund Administrators for the administration of their individual account to access better pensions and to prevent their interests from being harmed by excessive commission charges, dictates as a Policy that the permitted dispersion between the lowest and highest authorized commission of the total of Retirement Fund Administrators may vary in terms of what is established in the seventh paragraph of Article 37 of the Law of the Retirement Savings Systems, taking into consideration that it is congruent with healthy competition among Retirement Fund Administrators and with the market structure of the Retirement Savings System, but above all seeking the interest of the Worker.

Fifth.- The Board of Directors of the National Commission for the Retirement Savings System will continue to follow as a guiding Criterion what is established in the Single Annex of this Agreement to determine the maximum referred to in the eighth paragraph of Article 37 of the Law of the Retirement Savings Systems.

Sixth.- The annual analysis of the commission requests submitted by Retirement Fund Administrators for authorization by the Board of Directors of the National Commission for the Retirement Savings System will be carried out individually for each of them in the months of November and December of each year.

Seventh.- In order to promote healthy competition in matters of commissions among Retirement Fund Administrators, at any time and on occasions it deems convenient, each Retirement Fund Administrator may request from the Board of Directors of the National Commission for the Retirement Savings System an additional decrease in its authorized commissions for the year in question.

Eighth.- The National Commission for the Retirement Savings System, in exercise of its supervisory powers, must verify that Retirement Fund Administrators do not fail to comply with their regulatory obligations and, if applicable, will initiate the corresponding sanctioning procedures, informing its Board of Directors about such non-compliances. Likewise, it will evaluate and inform this governing body of the expense reallocations carried out by Retirement Fund Administrators due to the application of the maximum limit to commissions referred to in Article One of this Agreement.

Ninth.- For the authorization of commissions requested by Retirement Fund Administrators, in the annual commission evaluation process, they must provide the elements for the evaluation carried out by the Board of Directors of the National Commission for the Retirement Savings System, considering the evolution shown by each Retirement Fund Administrator in the terms provided in Article 37 of the Law of the Retirement Savings Systems.

TRANSITORY PROVISIONS

FIRST.- This Agreement will enter into force on the next business day following its publication in the Official Gazette of the Federation and will be applied in accordance with what is established in point Third of this Agreement.

SECOND.- The Agreement of the Board of Directors of the National Commission for the Retirement Savings System, by which it dictates policies and criteria in matters of commissions, published in the Official Gazette of the Federation on August 22, 2019, is hereby repealed. This leaves without effect any provision that contravenes this Agreement.

THIRD.- The maximum to which the commissions charged by Retirement Fund Administrators will be subject, will be notified to them by official letter and published on the website of the National Commission for the Retirement Savings System, for the first time no later than the last business day of October 2021. Subsequently, said maximum will be notified annually as established in Article Two, third paragraph, of this Agreement.

Mexico City, May 13, 2021.- Based on the provisions of Articles 8, last paragraph, 9, third paragraph, 11 and 12, fractions I, VIII, XIII and XVI of the Law of the Retirement Savings Systems; 2, fraction III, 4, third and fourth paragraphs and 8, first paragraph of the Internal Regulations of the National Commission for the Retirement Savings System, the President of the National Commission for the Retirement Savings System, Abraham E. Vela Dib. - Rubric.

SINGLE ANNEX: METHODOLOGY FOR THE CALCULATION OF THE MAXIMUM COMMISSIONS.

After an exhaustive analysis of the characteristics of defined contribution systems in the United States of America, Colombia and Chile, especially regarding commission schemes for administration and the evolution of said systems, the Board of Directors of the National Commission for the Retirement Savings System has agreed on the methodology for determining commissions for each of these countries, which will be used as a reference for the calculation of the arithmetic average that determines the maximum commission referred to in the eighth paragraph of Article 37 of the Law of the Retirement Savings Systems.

1. UNITED STATES OF AMERICA

In the United States of America, the Target Date Funds market is characterized by a situation in which administrators with the largest asset scale do not necessarily charge the lowest commissions per fund. This is a consequence of the fact that in the mutual fund industry there are several series per fund with different commission levels depending on the distribution channel to the end customer. In contrast, by observing the average costs by series type and their relationship with the market participation of assets, it is possible to observe that commissions are inversely related to those series in which the largest number of assets are managed. For the different types of series, the median of commissions as a percentage of the percentage of assets in each of them fluctuates between 0.15% and 1.68%. The management of Target Date Funds is carried out through Mutual Funds, being a direct reference for retirement fund administrators and the public institution that performs similar functions in Mexico. The Target Date Funds market in the United States of America is integrated by approximately 2,500 funds as of the end of December 2020 (5). The Universe of 2,500 mutual funds is integrated by open funds to receive investments, domiciled in the United States of America for exclusive distribution in the same country, classified by Morningstar in the category of "Target Date Funds".

In view of the foregoing, the Board of Directors of the National Commission for the Retirement Savings System, for the purposes of this methodology, considers taking as the sector cost standard, the 50th percentile of the cost distribution of the 2,500 funds in the market, which results in the relevant commission for the calculation of the arithmetic average referred to in the eighth paragraph of Article 37 of the Law of the Retirement Savings Systems.

2. CHILE and COLOMBIA

In Chile and Colombia, commissions as a percentage of the worker's taxable salary are an arithmetic average of 1.17 and 1.23 percent at the end of 2020, respectively. In the case of Mexico, the commissions authorized by the Board of Directors of the National Commission for the Retirement Savings System for 2021 are an arithmetic average on worker savings balances of 0.808 percent (0.922 percent at the end of 2020).

Given the differences between commission charging schemes, the Board of Directors of the National Commission for the Retirement Savings System has considered it necessary to establish an equivalence between commissions on flow in Chile and Colombia (percentage on salary) and balance (percentage on amount saved) in Mexico. This approach was used in 2008 resulting from the modification to the Law of the Retirement Savings Systems published in the Official Gazette of the Federation on June 15, 2007, to establish a single commission on balances. Likewise, various studies that perform international comparisons on commission charges have followed this approach.

Chile and Colombia: Administration Commission on Worker's Salary and Market Participation of Managed Assets (December 2020)

Chile Colombia Source: Own elaboration with data from the Pension Superintendence of Chile and the Financial Superintendence of Colombia.

Mexico: Administration Commission on Balances and Market Participation of Managed Assets (2020-2021) Source: CONSAR

For the purposes of determining the relevant commissions of Chile and Colombia that must be used in the arithmetic average referred to in the eighth paragraph of Article 37 of the Law of the Retirement Savings Systems, the Board of Directors of the National Commission for the Retirement Savings System has decided to use the following methodology based on the following parameters:

a) Variables to consider

Commission on flow: corresponding to the arithmetic average of Chile and Colombia (6) Contribution density (7) Contribution salary (8) Initial individual account balance: o Worker 1: average balance of the system in the year in which the equivalent commission on balance is calculated (9) o Worker 2: initial balance of zero Time horizon for commission equivalence ( ) for Worker "T", T=1 and 2: o Worker 1: n 1 = 40 years o Worker 2: n 2 = 40 years Annual real return rate: o Worker 1: 551 simulations of annual real return rates starting at 2% with increments of 0.01% up to 7.5% o Worker 2: 551 simulations of annual real return rates starting at 2% with increments of 0.01% up to 7.5% Contribution to individual account: b) Methodology for projecting Balances with the charging of the commission on Flow (F)

Where: c) Methodology for projecting Balances with the charging of the commission on Balance (S) d) Methodology for the equivalence between the commission on Flow and commission on Balance

The equivalence between the commission schemes can be found by equating the accumulated Balances in the individual account, in a time horizon "n T", provided that equation (1) is met:

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1 OECD, Pensions Outlook 2019. 2 Vanguard, How America Saves 2020 and Morningstar. 3 Calculations by CONSAR with Morningstar information. 4 General Provisions in Financial Matters of the Retirement Savings Systems, published in the Official Gazette of the Federation on September 18, 2019 5 Own calculations with Morningstar data. The commissions mentioned include administration commissions, sales commissions, distribution commissions and custody cost. They do not include intermediation costs. 6 Pension Superintendence Chile and Financial Superintendence of Colombia. 7 Contribution density corresponding to the last three years (36 months), Third Quarterly Report 2020, presented by CONSAR to the Congress of the Union, 8 System average estimated by CONSAR 9 System average estimated by CONSAR

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