Circular LISOL 1-1129, OPRAC 1-1300, REMON 1-1147, RUNOR 1-1939, CREFI 2-141: Financial Entity Authorities. Minimum Capital. Minimum Cash. Large Credit Risk Exposures. Risk Management Guidelines. Update.

"Year of the Reconstruction of the Argentine Nation" COMMUNICATION “A” 8383 30/12/2025 TO FINANCIAL ENTITIES: Ref.: Circular LISOL 1-1129, OPRAC 1-1300, REMON 1-1147, RUNOR 1-1939, CREFI 2-141: Authorities of Financial Entities. Minimum Capital of Financial Entities. Minimum Cash. Large Credit Risk Exposures. Guidelines for Risk Management in Financial Entities. Update.

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We address you to deliver the attached sheets, which replace those previously provided and must be incorporated into the organized texts on Authorities of Financial Entities, Minimum Capital of Financial Entities, Minimum Cash, Large Credit Risk Exposures, and Guidelines for Risk Management in Financial Entities, based on the provisions disclosed by Communication A 8364. Furthermore, points 7.2 and 7.3 (last paragraph) of the organized text on Minimum Capital of Financial Entities are updated due to an omission made when disclosing Communication A 8329. Please note that on this Institution’s website www.bcra.gob.ar, by accessing “Sections - Financial System – LEGAL AND REGULATORY FRAMEWORK – Organized texts and summaries – General regulatory organized texts”, you will find the modifications made with texts highlighted in special characters (strikethrough and bold). We salute you attentively. BANCO CENTRAL DE LA REPUBLICA ARGENTINA Pablo D. Montero / Darío C. Stefanelli Issuance Manager / Norms Manager in charge Principal Issuance and Norm Applications Manager ANNEX

The separation of executive and administrative functions shall be carried out based on the group in which the financial entity is classified, according to the classification provided in point 4.1 and in accordance with what is established in point 4.2. For these purposes, administrative functions shall be understood as those inherent to the Board of Directors (or equivalent authority of the financial entity), and executive functions as those relating to the implementation of policies set by the administrative body, such as the function of the general manager, executive director, and managers, which imply a functional subordination relationship with respect to the president (or equivalent authority) of the entity. 4.1. Classification of entities. The classification, into Group A or B, shall be determined based on the indicator resulting from the sum of i) the average of assets corresponding to 12 consecutive months between October of the second preceding year and September of the preceding year, and ii) the average of daily balances of deposits corresponding to 12 months of the aforementioned period, in accordance with data arising from the respective reporting regimes. 4.1.1. Group A: integrated by entities in which the indicator is greater than or equal to 1% of the total financial system. 4.1.2. Group B: integrated by entities not included in Group A. The indicator shall be considered individually, except for controlling financial entities subject to consolidated supervision, in which case it shall be calculated on a monthly consolidated basis. 4.2. Separation of executive and administrative functions. 4.2.1. Group A entities: separation between executive and administrative functions shall be required. 4.2.2. Group B entities: separation of executive and administrative functions shall not be required. 4.3. Periodicity. The classification of the entity in the groups indicated in point 4.1 shall be carried out once a year and shall govern for the calendar year following the computation year. The Superintendence of Financial Entities and Currency Exchanges (SEFYC) shall annually publish the list of classified financial entities. B.C.R.A. AUTHORITIES OF FINANCIAL ENTITIES Section 4. Separation of executive and administrative functions. Version: 4th COMMUNICATION “A” 8383 Validity: 01/01/2026 Page 1

4.4. SEFYC intervention. For those entities in which directors perform executive functions, if after one year of performing said functions SEFYC observes substantially unfavorable changes in the entity’s internal controls, this may lead to the cessation of that executive function, without implying that the person involved must necessarily conclude their term as director. 4.5. Public financial entities. Public financial entities –defined in point 1.3 of the TO on Authorization and Capital Composition of Financial Entities–, regardless of the group to which they belong, shall have separation between executive and administrative functions. 4.6. New entities. New financial entities shall be considered included in Group B –point 4.1.2.– until the necessary information is available to perform the calculation provided in point 4.1. At the time of holding the respective assembly or meeting of the supervisory body, as applicable, in which the proposed persons for the administrative body are appointed, it must be recorded in the minutes that the proposed persons do not violate these provisions. B.C.R.A. AUTHORITIES OF FINANCIAL ENTITIES Section 4. Separation of executive and administrative functions. Version: 4th COMMUNICATION “A” 8383 Validity: 01/01/2026 Page 2

7.1. Financial entities that are reclassified as a result of what is established in point 4.1 shall comply from 01/07/26 with what is provided in point 4.2 –referring to the separation of executive and administrative functions–, as well as apply the other provisions of this BCRA corresponding to their entity group, except what is provided in the TO on Minimum Cash. B.C.R.A. AUTHORITIES OF FINANCIAL ENTITIES Section 7. Transitional provisions. Version: 4th COMMUNICATION “A” 8383 Validity: 01/01/2026 Page 1

TEXTO ORDENADO (Organized Text)	NORMA DE ORIGEN (Originating Regulation)	OBSERVACIONES (Observations)
3.	3.1.3. 1° “A” 3700 I 1.	According to Com. “A” 5785 and 6304.
3.1.3.1. “A” 3700 I 1.	According to Com. “A” 5785 and 5803.
3.1.3.2. “A” 3700 I 1.	According to Com. “A” 5345, 5785 and 5803.
3.1.4. “A” 2241 I 1. 1.2.2.6. y 1.2.2.7.	According to Com. “A” 5248, 5485, 5785, 5803, 6111, 6290 and 6304. Includes “A” 3700 1. interpretative clarification.
3.1.5. “A” 3700	According to Com. “A” 5785, 6111 and 6304. Includes interpretative clarification.
3.1.6. “A” 3700 I 1.	According to Com. “A” 4490, 5345, 5785, 5803 and 6111.
3.1.7. “A” 4490	According to Com. “A” 5785.
3.2. “A” 5785	According to Com. “A” 5785.
3.3. “A” 3135 3°	According to Com. “A” 4499, 5785 and 6304.
3.4. “A” 5785 único	According to Com. “A” 5785.
3.5. “A” 5485 7.	According to Com. “A” 5785 and 6304.
3.6. “A” 6304 2.	According to Com. “A” 6304.
4.	1° “A” 5106 1.	According to Com. “A” 6475.
2° “A” 5106 1.	According to Com. “A” 6475.
4.1. 1° “A” 8364 1.	According to Com. “A” 8364.
4.1.1. “A” 5106 1.	According to Com. “A” 6475, 7108, 7143 and 8364.
4.1.2. “A” 5106 1.	According to Com. “A” 6475, 7108, 7143 and 8364.
4.1. último “A” 5106	According to Com. “A” 7143.
4.2. “A” 5106 1.	According to Com. “A” 6475.
4.2.1. “A” 5106 1.	According to Com. “A” 6475.
4.2.2. “A” 5106 1.	According to Com. “A” 6475, 7108, 7143 and 8364.
4.3. “A” 5106 1.	According to Com. “A” 6475, 7108 and 7143.
4.4. “A” 5106 1.	According to Com. “A” 5106.
4.5. “A” 6475 único 1.	According to Com. “A” 6475.
4.6. “A” 5106	According to Com. “A” 6475, 7108, 7143 and 8364.
último “A” 5106 1.	According to Com. “A” 6475.

TEXTO ORDENADO (Organized Text)	NORMA DE ORIGEN (Originating Regulation)	OBSERVACIONES (Observations)
5.	5.1. “A” 2282 1.	According to Com. “A” 2282.
5.2. “A” 2282 1.	According to Com. “A” 2282.
5.2.1. “A” 2282 1.	According to Com. “A” 2282.
5.2.2. “A” 2282 1.	According to Com. “A” 2282.
5.2.3. “A” 2282 1.	According to Com. “A” 5671 and 6690.
5.2. últimos “A” 2282 1.	According to Com. “A” 2282.
6.	6.1. “A” 5485	According to Com. “A” 5785, 5803, 6111 and 6304. Includes interpretative clarification.
6.2. “A” 2241 I 1. 1.2.2.7.	According to Com. “A” 5485 and 6111.
6.3. “A” 3700 I 1.	According to Com. “A” 5785 and 6304.
6.4.1. “A” 3700 I 1.	According to Com. “A” 3700.
6.4.2. “A” 2241 I 1. 1.2.2.7.	According to Com. “A” 5485.
6.4.3. “A” 2241 I 1. 1.2.2.7.	According to Com. “A” 5485.
6.5. “A” 2241 I 1. 1.2.2.7.	According to Com. “A” 5485 and 6111.
6.6. “A” 6304 2.	According to Com. “A” 6304.
7.	7.1. “A” 8364 5.	According to Com. “A” 8364.

TEXTO ORDENADO (Organized Text)	NORMA DE ORIGEN (Originating Regulation)	OBSERVACIONES (Observations)
6.1. Entidades alcanzadas (Covered entities).	Financial entities included in the list of Annex II of Communication A 7859.
6.2. Cupo Mínimo (Minimum Quota).	The covered entities, from 01/04/24, for compliance with this quota must maintain a quarterly average of daily balances (April-June; July-September; October-December and January-March of the following year) of included financings that is, at minimum, equivalent to 7.5% of the entity’s private non-financial peso deposits subject to fractional reserve requirements –excluding deposits provided in points 3.12 and 3.13 of the TO on Savings, Salary, and Special Accounts–, calculated based on the monthly average of daily balances of the penultimate preceding month (February, May, August, and November, respectively). If they are entities included in Group B –according to what is provided in Section 4 of the TO on Authorities of Financial Entities, for which the indicator in point 4.1 of those regulations shall be computed, for all financial entities, solely on an individual basis–, the minimum percentage to apply shall be 25% of that previously provided. For these purposes, existing residual balances of applied financings are computable: i) to quotas 2020, 2021, 2021/2022, 2022, 2022/2023, 2023 and 2023/2024 of the TO on Financing Line for Productive Investment for Micro, Small and Medium Enterprises; ii) in points 7.2.1 and 7.2.2 that have been disbursed until 15/10/2020, and iii) to the preceding quarters of this quota. Additionally, to comply with the Minimum Mipyme Quota, at least 30% of it must be allocated to what is provided in point 6.4.1. Covered entities that comply with this Minimum Mipyme Quota may compute the reduction in the minimum cash requirement in pesos provided in point 1.5.1 during the following quarter.
6.3. Destino (Destination).	Included financings must be granted to Mipyme clients according to the current definition in the TO on Determination of Micro, Small or Medium Enterprise Status. Excluded from the Minimum Mipyme Quota calculation: 6.3.1. regarding destinations in points 6.4.1 and 6.4.2: Mipyme with agricultural activity registered in the Simplified Agricultural Information System (SISA) as Producers with accumulation of wheat and/or soybean production, except that they are categorized as micro-enterprises –according to the definition of the former Secretariat for Small and Medium Enterprises and Entrepreneurs– and the value of that accumulation does not exceed 5% of their annual harvest capacity, estimated based on yields published by the Secretariat.
B.C.R.A. EFECTIVO MÍNIMO (MINIMUM CASH)
Section 6. Minimum Mipyme Quota.
Version: 4th COMMUNICATION “A” 8383 Validity:
01/01/2026 Page 1

TEXTO ORDENADO (Organized Text)	NORMA DE ORIGEN (Originating Regulation)	OBSERVACIONES (Observations)
3.	3.1.4. “A” 3274 II 3. 3.1.4.	According to Com. “A” 3274.
3.2. “A” 3274 II 3. 3.2.	According to Com. “A” 6719 and 7046.
3.2.1. “A” 3274 II 3. 3.2.2.1.	According to Com. “A” 4449, 6349, 6719 and 8302.
3.2.2.1. “A” 3274 II 3. 3.2.2.1.	According to Com. “A” 4449, 6349 and 6719.
3.2.2.2. “A” 3274 II 3. 3.2.2.2.	According to Com. “A” 4449 and 6349.
3.3. “A” 3274 II 3. 3.3.	According to Com. “A” 3498.
3.3.1. “A” 3274 II 3. 3.3.1.	According to Com. “A” 4771 and 6275.
3.3.2. “A” 3274 II 3. 3.3.2.	According to Com. “A” 3274.
4.	4.1. “A” 3274 II 4. 4.1.	According to Com. “A” 3274.
5.	5.1. “A” 3274 II 5. 5.1.	According to Com. “A” 3498, 5693 and 6832.
5.2. “A” 3905 5.	According to Com. “A” 5356 and 5693.
5.3. “A” 3905 5.	According to Com. “A” 4449, 6167 and 7944.
6.	6.1. “A” 7983 1.	According to Com. “A” 7983.
6.2. “A” 7983 1.	According to Com. “A” 8018, 8364 and 8383.
6.3. “A” 7983 1.	According to Com. “A” 7983.
6.4. “A” 7983 1.	According to Com. “A” 7983.
6.4.1. “A” 7983 1.	According to Com. “A” 7983.
6.4.2. “A” 7983 1.	According to Com. “A” 8021.
6.4.3. “A” 7983 1.	According to Com. “A” 7983.
6.5. “A” 7983 1.	According to Com. “A” 7983.
6.5.1. “A” 7983 1.	According to Com. “A” 7983.
6.5.2. “A” 7983 1.	According to Com. “A” 7983.
7.	7.1.1. “A” 5246 3.	According to Com. “A” 5246.
7.1.2. “A” 5312	According to Com. “A” 5333.
7.2. “A” 7536 2.	According to Com. “A” 7536.
7.2.1. “A” 6858 1.	According to Com. “A” 6901, 6907 and 7536.
7.2.2. “A” 6937 2.	According to Com. “A” 6943, 7054, 7140, 7155, 7536 and 8252.
7.2.3. “A” 6993 2.	According to Com. “A” 7082, 7157, 7536 and 8252.
7.2.4. “A” 7342 2.	According to Com. “A” 7536.
7.2. último “A” 6858 2.	According to Com. “A” 6965, 6993, 7006, 7140, 7132, 7155, 7157, 7161, 7254, 7342 and 7536.
7.3. “A” 7983 3.	According to Com. “A” 7983.
7.4. “A” 5631 1.	According to Com. “A” 5638, 6217, 6531, 6857, 6910, 6937, 7114, 7334, 7448, 7951, 7983 and 8026.
7.5. “A” 8062 2.	According to Com. “A” 8124.
7.6. “A” 7161 5.	According to Com. “A” 7432, 7459, 7474, 7491, 7536, 7561, 7983 and 8159.
7.7. “A” 7254 1.	According to Com. “A” 7287, 7536, 7970, 8057 and 8159. Includes normative clarification.
7.8. “A” 8302 4.	According to Com. “A” 8355.
B.C.R.A. CAPITALES MÍNIMOS DE LAS ENTIDADES FINANCIERAS (MINIMUM CAPITAL OF FINANCIAL ENTITIES)
Section 7. Minimum capital for operational risk.
Version: 2nd COMMUNICATION “A” 8383 Validity:
31/12/2025 Page 7

7.2. Minimum capital requirement for operational risk for Group 2 entities. It shall be determined monthly by applying the following expression: [Expression] Where: CRO: minimum capital requirement for operational risk. α: 15%. n: number of periods of 12 consecutive months in which IB is positive, considering the last 36 months preceding the month in which the calculation is made. The maximum value of n is 3, with no overlapping months allowed in forming the periods. When n equals zero (n=0), a requirement equivalent to the limit provided in point 7.3 shall be observed. IBt: gross income of periods of 12 consecutive months –always when positive–, corresponding to the last 36 months preceding the month in which the calculation is made, expressed in homogeneous currency of the month prior to that in which the calculation is made. IB is defined as the sum of: i) financial and service income minus financial and service expenses, ii) other profits minus other losses, and iii) total monetary result. From the accounting items mentioned in i) and ii), the following concepts –included in those items– shall be excluded, as applicable:

• charges from the establishment of provisions, derecognition of provisions established in prior years, and credits recovered in the current year but written off in prior years;
• income from participations in financial entities and companies, to the extent that they are concepts deductible from computable net worth; and
• income from the sale of classified assets measured at amortized cost or fair value with changes in OCI. B.C.R.A. CAPITALES MÍNIMOS DE LAS ENTIDADES FINANCIERAS (MINIMUM CAPITAL OF FINANCIAL ENTITIES) Section 7. Minimum capital for operational risk. Version: 2nd COMMUNICATION “A” 8383 Validity: 31/12/2025 Page 7

7.3. Limit for Group 2 entities. The requirement determined through the application of the expression described in point 7.2 shall not exceed: 7.3.1. 20% in the case of Group A entities, of the average of the last 36 months –preceding the month to which the requirement determination corresponds– of the minimum capital requirement for credit risk calculated as provided in Section 2., expressed in homogeneous currency of the month prior to that in which the calculation is made. 7.3.2. 17% in the case of Group B entities, of the average of the last 36 months –preceding the month to which the requirement determination corresponds– of the minimum capital requirement for credit risk calculated as provided in Section 2., expressed in homogeneous currency of the month prior to that in which the calculation is made. The maximum limit established above shall be reduced to 11% when the financial entity holds rating 1, 2, or 3 according to the valuation granted by SEFYC, during the last inspection conducted, regarding all of the following aspects: the entity as a whole, its information systems, and the work of those responsible for evaluating their internal control systems. In cases where the financial entity holds rating 1 or 2 in all cited aspects, the maximum limit shall decrease to 7%. For this effect, the last rating reported for calculating the requirement that should be integrated into the third month following that in which notification occurs shall be considered. 7.4. New entities. The monthly minimum capital requirement for operational risk of financial entities in groups 1 and 2 corresponding to the first month shall be equivalent to 10% of the sum of requirements determined by credit and market risks –in this case, for positions on the last day– of that month. From the second to the thirty-sixth month, the monthly requirement shall be equivalent to 10% of the average of requirements determined for the months elapsed until the calculation period –inclusive–, resulting from considering the risks mentioned in the preceding paragraph, according to the following expression: [Expression] B.C.R.A. CAPITALES MÍNIMOS DE LAS ENTIDADES FINANCIERAS (MINIMUM CAPITAL OF FINANCIAL ENTITIES) Section 7. Minimum capital for operational risk. Version: 3rd COMMUNICATION “A” 8383 Validity: 01/01/2026 Page 8

12.1. Financial entities in operation as of 01/06/24 shall observe the basic capital requirement provided in the table of point 1.2 –according to the corresponding category– from 01/01/25. From 01/06/24 to 31/12/24, such operating entities shall apply the requirements arising from the following table:

Período (Period)	Bancos (Banks)	Restantes entidades (salvo Cajas de Crédito Cooperativas) (Remaining entities (except Cooperative Credit Unions))
01/06/24 al 31/12/24	1.500 (in millions of pesos)	700 (in millions of pesos)
The financial entities in operation as of 01/06/24 that do not comply with the integration of the basic capital requirement as provided in the preceding paragraph and/or the basic capital requirement from 01/01/25 according to their business plan and projections and capital self-assessment report shall submit to SEFYC a compliance program within 20 calendar days following the registration or projection of non-compliance, respectively, which shall not exceed 6 months to comply with the basic requirement.
12.2. From 01/01/25 to 31/12/25, financial entities classified in group 2 according to what is provided in Section 2 that as of 01/01/25 belong to groups B and C –based on what is established, with validity until 31/12/25, in Section 4 of the TO on Authorities of Financial Entities–, shall convert “commitments capable of being cancelled at the discretion and unilaterally by the financial entity, or that are automatically cancelled in case of deterioration of the debtor’s solvency” into credit equivalents by applying CCFs according to the following schedule:
Período (Period)	CCF
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01/01/25 al 30/06/25	0%
01/07/25 al 31/12/25	5%
12.3. For those financial entities that are reclassified from 01/01/2026 as a result of what is established in point 4.1 of the TO on Authorities of Financial Entities, the minimum capital requirement for operational risk for Group 2 entities determined through the application of the expression described in point 7.2 until 30/06/26 shall not exceed:
17% in the case of Group B entities and 14% in the case of Group C –based on what is established, with validity until 31/12/25, in Section 4 of the TO on Authorities of Financial Entities–, of the average of the last 36 months –preceding the month to which the requirement determination corresponds– of the minimum capital requirement for credit risk calculated as provided in Section 2., expressed in homogeneous currency of the month prior to that in which the calculation is made.
The maximum limits established above shall be reduced to 11% and 8%, respectively, when the financial entity holds rating 1, 2, or 3 according to the valuation granted by SEFYC, during the last inspection conducted, regarding all of the following aspects: the entity as a whole, its information systems, and the work of those responsible for evaluating their internal control systems.
B.C.R.A. CAPITALES MÍNIMOS DE LAS ENTIDADES FINANCIERAS (MINIMUM CAPITAL OF FINANCIAL ENTITIES)
Section 12. Transitional provisions.
Version: 4th COMMUNICATION “A” 8383 Validity:
01/01/2026 Page 1

In cases where the financial entity holds rating 1 or 2 in all cited aspects, the maximum limit shall decrease to 7% or 5%, depending on whether it belongs to Group B or C, respectively. For this effect, the last rating reported for calculating the requirement that should be integrated into the third month following that in which notification occurs shall be considered. B.C.R.A. CAPITALES MÍNIMOS DE LAS ENTIDADES FINANCIERAS (MINIMUM CAPITAL OF FINANCIAL ENTITIES) Section 12. Transitional provisions. Version: 1st COMMUNICATION “A” 8383 Validity: 01/01/2026 Page 2

TEXTO ORDENADO (Organized Text)	NORMA DE ORIGEN (Originating Regulation)	OBSERVACIONES (Observations)
6.	6.7. “A” 2461 único III	According to Com. “A” 3161, 4172, 5272, 5867 and 6690.
6.8. a 6.10. “A” 5867 1.	According to Com. “A” 6690.
6.11. “A” 2461 único VI	According to Com. “A” 4172, 6690 and 6832.
6.12. “A” 5867 1.	According to Com. “A” 6690.
7.	1° “A” 8068 único	According to Com. “A” 8068.
7.1. “A” 8068 único	According to Com. “A” 8068.
7.2. “A” 5272 2.	According to Com. “A” 6327, 8068, 8329 and 8383.
7.3. “A” 5737 2.	According to Com. “A” 5746, 6260, 6475 (point 4.), 6633, 7108, 7143, 8068, 8329, 8364 and 8383.
7.4. “A” 5272 2.	According to Com. “A” 5369, 5580, 5737, 5867 and 8068.
8.	8.1. “A” 414 LISOL-1 VI 3.1. 1º	According to Com. “A” 2279, 2453, 2793, 2914, 3039, 4172 and 5369 (Annex I).
8.2.1. “A” 414 LISOL-1 VI 3.1.1.	According to Com. “A” 2223, 2227, 4296 (point 2.), 4576 (point 1.), 4665, 5369 (Annex I), 6327, 6396 and 6428.
8.2.2. “A” 5369 I	According to Com. “A” 5369.
8.2.3. “A” 414 LISOL-1 VI 3.1.2.	According to Com. “A” 2223, 2768, 2948, 4172, 4576 (point 3.), 4665, 4702, 5369 (Annex I) and “B” 9074.
8.3. “A” 5369 I	According to Com. “A” 5369.
8.3.1. “A” 5369 I	According to Com. “A” 5369.
8.3.2. “A” 4576 2.