Banks, Financial Companies, External Financial Institutions and Financial Intermediation Cooperatives - Additional Information for Opening Foreign Currency Accounts

1 Montevideo, August 20, 2026 Ref: BANKS, FINANCIAL COMPANIES, EXTERNAL FINANCIAL INSTITUTIONS AND FINANCIAL INTERMEDIATION COOPERATIVES - Additional Information for Opening Foreign Currency Accounts

The market is informed that the Superintendent of Financial Services adopted Resolution SSF No. 2026-445 on July 10, 2026. 2026-50-1-01232 Diagonal Fabini 777 - C.P. 11100 - Tel.: (598 2) 1967 - Montevideo, Uruguay - www.bcu.gub.uy JUAN PEDRO CANTERA Superintendent of Financial Services

CIRCULAR NO. 2509

SUPERINTENDENCY OF FINANCIAL SERVICES – RESOLUTION SUPERINTENDENCY OF FINANCIAL SERVICES

VIEWING: The regulations regarding information and communication with clients established in Book IV - Protection of the user of financial services, of the Compilation of Regulations and Control Norms of the Financial System.

RESULTING: I) That within the framework of the activities defined in the 2026 Regulations Plan, a project was developed that introduces the obligation, for institutions authorized to receive deposits, to provide additional information to clients with foreign currency deposit accounts. II) That the project contemplates the recommendation of the Macroprudential Policy Committee of the Central Bank of Uruguay dated November 28, 2025, to provide information to users regarding the financial risks of making deposits in foreign currency. III) That the aforementioned normative proposal was submitted for consultation to supervised institutions and the general public on June 1, 2026, with the deadline for receiving comments expiring on June 15, 2026. IV) That comments were received from the Association of Private Banks of Uruguay (ABPU), the Bank of the Oriental Republic of Uruguay (BROU), Provincia Casa Financiera, and Economist José Antonio Licandro. V) That the main comments referred to the following aspects: scope of the information obligation, text of the communication to the client, and implementation difficulties, especially for existing clients.

CONSIDERING: I) That the comments received from the industry provided elements that allowed improving the original proposal, demonstrating the value the regulator places on the consultation process. II) That considering the aforementioned comments, the normative proposal was reviewed. In particular:

• It was determined that the obligation encompasses resident natural persons and sole proprietorships.
• The text of the information to be provided to the depositor was modified to communicate the exchange rate risk involved more clearly.
• It was enabled that information to existing clients be provided via: email message, a prominent notice on the institution's main website or through its digital channels for a period of no less than ten business days.
• The effective date of the regulation for opening new accounts was extended to October 1, 2026.

ATTENTIVE: To what is established in literal A) of Article 38 of Law No. 16.696 of March 30, 1995, as amended by Article 694 of Law No. 20.446 of December 16, 2025, and to the reports issued by this Superintendent of Financial Services in file No. 2026-50-1-01232.

THE SUPERINTENDENT OF FINANCIAL SERVICES RESOLVES:

1. INCORPORATE into Section II – Information to clients, of Chapter VI – Information and communication with clients, of Title I – Relationship with clients, of Book IV – Protection of the user of financial services of the Compilation of Regulations and Control Norms of the Financial System, the following article:

ARTICLE 353.5 (INFORMATION ON FOREIGN CURRENCY DEPOSITS). Institutions authorized to receive deposits that offer the opening of foreign currency accounts must inform resident natural persons or sole proprietorships, in the documentation to be delivered at the time of account opening, at minimum the following:

“Information on exchange rate risk: This deposit is denominated in [foreign currency of the deposit], and therefore is exposed to exchange rate risk. Although its value in foreign currency does not change, its equivalent in Uruguayan pesos could suffer negative or positive variations as a consequence of exchange rate fluctuations. For more information, consult the website of the Central Bank of Uruguay at: http://www.bcu.gub.uy/Paginas/depositos-en-moneda-extranjera.aspx This information does not constitute financial advice nor an investment recommendation.”

The information shall be contained in a document independent of the general and specific conditions of the contract to be signed, must be displayed prominently, and its receipt by the client must be accredited.

Likewise, it must be notified to resident natural persons or sole proprietorships who have foreign currency accounts open at the time of entry into force of this provision, referencing said accounts, via:

• email message to the email address the client has established with the institution; or
• a prominent notice on the main page of the institution's website or through its digital channels for a period of no less than ten business days.

2. SUBSTITUTE in Title V – Deposits, of Book IV – Protection of the user of financial services of the Compilation of Regulations and Control Norms of the Financial System, Article 386 with the following:

ARTICLE 386 (CONDITIONS IN DEPOSITS). Institutions authorized to receive deposits must establish, at the time of contracting the opening of a checking, notice, or time deposit account, in national or foreign currency, the effective annual interest rate, the capitalization date, the fee for low average balance, and the other specific conditions that regulate its operation. Such conditions shall be contained in the documentation delivered to the depositor.

In particular, when the client contracts the opening of a foreign currency account, the information established in Article 353.5 must be delivered.

When the contract has provided for the reduction of the agreed interest rate in checking or notice deposits, or the increase in the fee for low average balance, the depositary institution must inform such modifications previously to all depositants in the manner provided in the second paragraph of Article 355, with at least five business days' advance notice. Prior notice is not necessary in the case of increases in the interest rate or reduction of the fee for low average balance, nor in the case where an interest rate dependent on a variable factor has been agreed.

It will not be necessary to inform of modifications in the interest rates in effect in the case of automatically renewable time deposits.

For any other modification in the general or specific conditions of the contract, the express consent of the depositor must be required.

3. VALIDITY: The modifications established above shall govern from October 1, 2026. The deadline to notify existing depositors will expire on December 31, 2026.

4. COMMUNICATE the resolution via Circular.

JUAN PEDRO CANTERA Superintendent of Financial Services

RR-SSF-2026-445 Date: 10/07/2026 16:34:15 File 2026-50-1-01232 Publishable: Yes - Signatory: JUAN PEDRO CANTERA SENCIÓN CIRCULAR NO. 2509