Circular 105-2 – To Financial Institutions

Bank of the Republic of Haiti

CIRCULAR
No. 105-2

TO FINANCIAL INSTITUTIONS

Pursuant to Articles 87 and 179 of the Law of May 14, 2012, on Banks and Other Financial Institutions, Article 69 of the Decree of June 5, 2020, on the Organization and Operation of Microfinance Institutions (MFIs), and Article 12 of the Law of June 26, 2002, on the Constitution, Organization, Control, and Supervision of Savings and Credit Cooperatives (SCCs) and Federations of Savings and Credit Cooperatives, this Circular determines the conditions for transmitting information on credits granted to clients of financial institutions to the Credit Information Bureau (BIC) established by the Bank of the Republic of Haiti (BRH).

1.- For the purposes of this Circular, the following definitions apply:

Financial Institution: any institution authorized by the BRH and affiliated with the BIC, including: banks, credit card companies, development finance companies, leasing companies, savings and credit cooperatives, microfinance institutions, and any other institution designated by the BRH.

Bank Subsidiary: any enterprise controlled by a bank, either through a capital contribution of more than 50%, or through the holding of voting rights of more than 50%, or through a determining interest allowing the bank to exercise effective control over the management or policy of said subsidiary.

2.- Financial institutions are required to transmit to the BIC, by the tenth (10) of each month at the latest, information from the previous month concerning all credits granted to their clients (natural or legal persons). Included in this regard are: all loans, cash advances, acceptances, or any other claims (on-balance sheet and off-balance sheet) with or without collateral that constitute the credit portfolio. This information must be communicated in electronic format.

3.- Financial institutions are required to automatically notify the BIC of all information regarding checks returned for insufficient funds issued by natural or legal persons, regardless of their status.

Furthermore, they must transmit to the BIC a monthly report on said checks, by the tenth (10) of the following month at the latest.

4.- The information required under this Circular must be transmitted by all financial institutions regardless of their size or the nature of their activities, in accordance with the specifications and format attached to this document. The mandatory information listed in Annex 2 must be collected for any new credit and any returned check for insufficient funds.

5.- Financial institutions must additionally:
a) correct any information that proves to be erroneous concerning a natural or legal person within five (5) business days from the date of receipt of the request for correction; b) use the data and information systems of the BIC with due diligence and in accordance with international best practices; c) create, at their own expense, conditions conducive to the collection, processing, and submission of information; d) keep up-to-date the information on credits concerning natural or legal persons held by them; e) secure the information collected and transmitted to the BIC.

6.- All financial institutions are required to submit real, accurate, up-to-date, and complete information.

In the event of transmitting information that proves to be false, inaccurate, or outdated, the BRH reserves the right to impose sanctions against them in accordance with existing laws and regulations.

Any partial transmission of information by a financial institution will be considered a failure to transmit and penalized in accordance with the provisions of this Circular.

7.- As of October 15, 2025, financial institutions must obtain, for any new credit application, the duly signed consent of the loan applicant authorizing the exchange at any time of personal and financial credit information, with the BIC or any other credit bureau legally authorized to operate in Haiti or abroad.

Furthermore, financial institutions are required to integrate, into any new credit contract, an express consent clause from the borrower authorizing the transmission of their data to the BIC or any other credit bureau legally authorized to operate in Haiti or abroad. This consent, collected at the time of concluding the contract, forms an integral part of it and remains valid until the complete extinguishment of the borrower's obligations.

8.- All financial institutions are obligated to consult and keep a copy of the credit report of any client for the purpose of risk assessment during:
a) the granting, renewal, monitoring, and extension of credit; b) the modification of the terms of a credit contract; c) the issuance of payment instruments.
Information appearing in credit reports cannot be used for commercial prospecting or marketing purposes.

The credit report has a validity period of one (1) month from the date it was generated.

9.- In the event of non-compliance with the provisions of this Circular, the financial institutions concerned are subject to the following penalties:

9.1. Late Transmission

Failure to transmit all information required within the timeframe established in Article 2 of this Circular subjects the financial institution to a fine of one hundred thousand gourdes (HTG 100,000.00) per day of delay until the 15th day of the month if it is a bank or a bank subsidiary. The fine amount is fifty thousand gourdes (HTG 50,000.00) per day of delay for any other category of financial institution.

Beyond the fifteenth day of the month, the financial institution is subject to a fine of one hundred fifty thousand gourdes (HTG 150,000.00) per day of delay if it is a bank or a bank subsidiary, and seventy-five thousand gourdes (HTG 75,000.00) per day of delay for any other category of financial institution, until the complete transmission of the information required to the BIC.

9.2. Late Correction

Failure to correct information requested by the BIC within the established deadlines subjects the financial institution, if it is a bank or a bank subsidiary, to a fine of fifty thousand gourdes (HTG 50,000.00) per day of infraction from the date the infraction was notified. This fine is twenty-five thousand gourdes (HTG 25,000.00) per day of infraction for any other category of financial institution.

9.3. Absence of Credit Reports

If the BRH finds, during an inspection, the absence of a credit report in a client's file, the concerned financial institution will be sanctioned with a fine of two hundred thousand gourdes (HTG 200,000.00) for each case found.

9.4. Absence of Consent for Information Sharing

If the BRH finds, during an inspection or under other circumstances, the absence of duly signed consent for sharing credit information in a client's file as required in Section 7 of this Circular, the concerned financial institution will be subject to a fine of two hundred thousand gourdes (HTG 200,000.00) for each absence noted.

9.5. Other Infractions

For any other infraction noted, the BRH will require the immediate cessation of the incriminated practice, will take administrative sanctions notably by issuing a letter of reprimand against the faulty institution, and may apply, for each fact noted, a fine of two hundred thousand gourdes (HTG 200,000.00).

10.- Any fine will be automatically deducted from one of the accounts at the BRH of the faulty institution. The payment of any fine by a financial institution not holding an account at the BRH will be made by a cashier's check payable to the Bank of the Republic of Haiti, at the latest

five (5) business days, after receipt of the notice requiring payment. In case of non-payment within the required timeframe, a penalty of two thousand five hundred gourdes (HTG 2,500.00) will be applied per day of delay.

11.- Any newly affiliated institution to the BIC benefits from a grace period of four (4) months from the date of its affiliation. During this period, it is not subject to the penalties normally applicable. After this deadline, the application of sanctions will follow the existing provisions.

12.- This Circular repeals Circular 105-1 dated April 3, 2017, and enters into force on October 15, 2025.

Port-au-Prince, September 15, 2025.

Ronald Gabriel
Governor

List of Annexes:

Annex 1 - Specifications for File Transfer
Annex 2 - Specifications for Data Collection Files
Annex 3 - Reference Data

ANNEX 1

A) SPECIFICATIONS FOR FILE TRANSFER

1. INTRODUCTION

For file transfer, financial institutions must take into account these specifications which constitute the main technical details necessary for establishing a connection to the file server using the secure file transfer protocol for file transmission.

The operating system installed on the server offers a high level of security.

2. SFTP CONNECTIVITY

The IP address of the SFTP/SSH server must be configured on the institution's client workstation as the destination address to transfer files. It is important to emphasize that any financial institution must previously have a VPN¹, WIMAX², Fiber optic, VSAT³ link with the BRH and that the routing and access rules to the server are well defined, configured, tested, and certified by the BRH.

All files deposited in the directories must have unique names following the nomenclature defined by the BRH (see data collection file specification document).

3. TRANSMISSION PROCESS

Any financial institution must ensure that the link is well established before starting any transmission. Once the connection is established, the file transfer software, client part (SSH Secure File Transfer, WinSCP, Filezilla, etc.), must be launched.

To connect to the BRH server, the financial institution must fill in the fields: username, password, server IP address, and port number. These information will be communicated to institutions by the BRH.

Successful authentication places the financial institution in the directory designated for it. Any access is recorded in the log register.

4. DIRECTORIES

The BIC uses a nomenclature to name the directories of each affiliated financial institution. No financial institution is authorized to consult the content or access the directory of another institution.

¹ Virtual Private Network
² Worldwide Interoperability for Microwave Access ³ Very Small Aperture Terminal

ANNEX 2

B) SPECIFICATIONS FOR DATA COLLECTION FILES

1. Company/Manager/Shareholder/Credit

File Name 1: ent_resp_act_credit_yyyymmddcredittype.csv

Credit Type Abbreviation:

Term Loan	PT		Credit Card	CC
Credit Line	LC		Micro Credit Line	MCL
Micro Credit	MC

4 segments per record:

• Company: mandatory segment
• Manager: mandatory segment (except for credit cards)
• Shareholder: optional segment
• Credit: mandatory segment

Ref.	Field	Data Type	Size	Mandatory	Description
Segment: COMPANY
1.	Company Name	Char	2-75	√	The denomination or trade name of the company.
2.	Patent Number	Char	5-20		The Number appearing on the patent certificate issued by the General Directorate of Taxes after payment of the tax.
3.	Company Tax Identification Number (NIF)	Char	10	√	The tax ID number issued by the General Directorate of Taxes to a company exercising any activity on the territory of Haiti.
					Except in the case where Legal Form [5] = 1000
4.	Sector of Activity	Code. Ref. Table 1		√	The code of the sector of activity in which a company is classified based on its activities. See Table 1

5.	Legal Form	Code. Ref. Table 4		√	The code allowing to categorize a company. See Table 4
6.	Phone 1	Char	8-11		The phone number assigned essentially to the company's activities. Format: country code followed by phone number
7.	Phone 2	Char	8-11		Another phone number assigned to the company's activities. Format: country code followed by phone number
8.	Phone 3	Char	8-11		Another phone number assigned to the company's activities. Format: country code followed by phone number
9.	Address	Char	5-75	√	The registered office address of the company No, street, neighborhood or zone, postal code (See Table 7)
10.	Commune	Code. Ref. Table 2		√	The code of the commune where the company is located according to the IHSI code. See Table 2
11.	Country	Code. Ref. Table 3		√	The code of the country where the company is located according to the international ISO code. See Table 3

Segment: PERSON AUTHORIZED TO BIND THE COMPANY This segment is not mandatory for credit cards. But if any field of this segment is filled in, the validation rules related to this segment must be respected.

12.	First Name	Char	2-45	√	The first name of the person authorized to bind the company.
13.	Last Name	Char	2-45	√	The last name of the person authorized to bind the company.
14.	Tax Identification Number (NIF)	Char	10		The tax ID number issued by the General Directorate of Taxes to a natural person exercising any activity on the territory of Haiti. Format: xxxxxxxxxx
15.	CIN	Char	14 or 17		The Number appearing on the National Identity Card. Format: xxxxxxxxxxxxxxxx
16.	Driver's License Number	Char	1-20		The file number of the driver's license Format: xxxxxxxx
17.	Passport Number	Char	7-25		The Passport Number
18.	Address	Char	5-75	√	The home address of the person authorized to bind the company: No, street, neighborhood or zone, postal code
19.	Commune	Code. Ref. Table 2		√	The code of the commune of the home of the person authorized according to the IHSI code See Table 2
20.	Country of the Authorized Person	Code. Ref. Table 3		√	The code of the country of the home of the person authorized according to the international ISO code See Table 3

Segment: SHAREHOLDER
This segment is not mandatory. But if any field of this segment is filled in, the validation rules related to this segment must be respected.

21.	First Name	Char	2-45		The first name(s) of a shareholder of the company
22.	Last Name	Char	2-45		The last name of a shareholder of the company
23.	Shareholder Tax Identification Number (NIF)	Char	10		The tax identification number of the shareholder Format: xxxxxxxxxx
24.	CIN	Char	10, 14 or 17		The number of the shareholder's tax identification card Format: xxxxxxxxxxxxxxxx
25.	Driver's License Number	Char	1-20		The file number of the shareholder's driver's license Format: xxxxxxxx
26.	Passport Number	Char	7-25		The number of the shareholder's passport
27.	Address	Char	5-75		The address where the shareholder resides: No, street, neighborhood or zone, postal code
28.	Commune	Code. Ref. Table 2			The code of the commune where the shareholder resides according to the IHSI code. See Table 2
29.	Country	Code. Ref. Table 3			The code of the country where the shareholder resides according to the international ISO code. See Table 3

Segment: CREDIT

30.	Loan Number	Char	5-45	√	The number assigned to the loan
31.	Loan Type	Code. Ref. List		√	The code of the loan type. List of loan types: PCN: Consumer Loan, PLT: Housing Loan, PCL: Commercial Loan, LC: Credit Line, PC-CC: Credit Card, PC-ED: Education Loan, PL-AG: Agricultural Loan, PL-CB: Leasing, PRI: Industrial Loan
32.	Classification / Loan Status	Code. Ref. List		√	The classification and status of the loan: List of classifications: CURRENT, TO BE REPORTED, LOW, DOUBTFUL, LOSS, FIRM. List of statuses: Code. Ref. Table 9. Format: Classification/Status Ex: FIRM/P-050
					Only the classification information is mandatory.
33.	Frequency	Number	2-3	√	The payment frequency in number of calendar days.
34.	Grant Date	Date	8	√	The grant date of the loan Format: yyyymmdd
35.	Closure Date or Maturity Date	Date	8	√	The closure date of the loan if the loan is closed. The maturity date of the loan in other cases. Format: yyyymmdd
36.	Authorized / Granted Amount	Number	14.2	√	The amount authorized for the loan Format: 99999999999999.99

37.	Currency	Code. Ref. List		√	The code of the currency used to grant the loan. List of currencies: HTG: Gourde, USD: US dollar
38.	Grace Period	Number	1-3		Time granted to the borrower before the first amortization (suspension) in number of calendar days.
39.	Reference Person	Char	1-75		The first name and last name of the reference person
40.	Responsibility towards Credit	Code. Ref. List		√	The code defining the relationship between the client and the credit. See Table 10

N.B.: At least one identification number must be specified for individuals (NIF, CIN, driver's license, or passport).

ANNEX 2

2. Individual/Employment/Credit

File Name 2: ind_emp_credit_yyyymmddcredittype.csv

Credit Type Abbreviation:

Term Loan	PT		Credit Card	CC
Credit Line	LC		Micro Credit Line	MCL
Micro Credit	MC

3 segments per record:

• Individual: mandatory segment
• Employment: optional segment
• Credit: mandatory segment

Ref.	Field	Data Type	Size	Mandatory	Description
Segment: INDIVIDUAL
1.	First Name	Char	2-45	√	The first name(s) of the individual
2.	Last Name	Char	2-45	√	The last name of the individual
3.	Full Name at Birth	Char	2-60		Maiden name for a woman or name of a natural person at birth in case of change of surname.
4.	Mother's Maiden Name	Char	2-60		The maiden name of the mother of the individual.
5.	Tax Identification Number (NIF)	Char	10		The tax ID number issued by the General Directorate of Taxes to a natural person exercising any activity on the territory of Haiti. Format: xxxxxxxxxx
6.	CIN	Char	10, 14 or 17		The number of the National Identity Card Format: xxxxxxxxxx

7.	Passport Number	Char	7-25		The passport number
8.	Driver's License Number	Char	1-20		File number of the driver's license Format: xxxxxxxx
9.	Date of Birth	Char	8	√	The date of birth according to the format: yyyymmdd
10.	Commune of Birth	Code. Ref. Table 2 or Table 3			The code of the commune (place) where the individual was born according to the IHSI code. For a foreigner, put the country code. See Table 2 or Table 3
11.	Civil Status	Code. Ref. List		√	The code of the marital status of the individual. List of codes: C=single, D=divorced, M=married, S=separated, U=concubinage, W=widow,
12.	Sex	Code. Ref. List		√	The sex of the individual List of codes: F=Female, M=Male
13.	Profession	Code. Ref. Table 8			The code of the profession exercised by the individual. See Table 8
14.	Phone 1	Char	8-11		The phone number Format: country code followed by phone number
15.	Phone 2	Char	8-11		The phone number Format: country code followed by phone number
16.	Phone 3	Char	8-11		The phone number Format: country code followed by phone number
17.	Address	Char	5-75	√	Home of the individual: Number, street, neighborhood, postal code

18.	Commune	Code. Ref. Table 2		√	The code of the commune according to the IHSI code See Table 2
19.	Country	Code. Ref. Table 3		√	The code of the country according to the international ISO code. See Table 3

Segment: EMPLOYMENT
This segment is not mandatory. But if any field of this segment is filled in, the validation rules related to this segment must be respected.

20.	Employer Name	Char	2-45	√	The name of the employer where the individual works. If the employer is a natural person, put the first name and last name of this person.
21.	Hire Date	Date	8	√	The date of recruitment of the person. format: yyyymmdd
22.	Employment Verification Date	Date	8		The date of verification of the individual's employment. Format: yyyymmdd
23.	Position Held	Char	5-45	√	The position assigned by the employer to the individual.
24.	Salary	Number	14.2	√	The salary of the individual Format: 99999999999999.99
25.	Currency	Code. Ref. List		√	The code of the currency in which the salary is paid. List of currencies: HTG: Gourde, USD: US Dollar
26.	Phone 1	Char	8-11		The phone number of the employer Format: country code followed by phone number
27.	Phone 2	Char	8-11		The phone number of the employer Format: country code followed by phone number
28.	Address	Char	5-75	√	The address of the Registered Office of the company: No, street, neighborhood or zone, postal code

29.	Commune	Code. Ref. Table 2		√	The code of the commune of the employer according to the IHSI code. See Table 2
30.	Country	Code. Ref. Table 3		√	The code of the country of the employer according to the international code See Table 3

Segment: CREDIT

31.	Loan Number	Char	5-45	√	The number assigned to the loan
32.	Loan Type	Code. Ref. List		√	The code of the loan type. List of loan types: PCN: Consumer Loan, PLT: Housing Loan, PCL: Commercial Loan, LC: Credit Line, PC-CC: Credit Card, PC-ED: Education Loan, PL-AG: Agricultural Loan, PL-CB: Leasing, PRI: Industrial Loan
33.	Classification / Loan Status	Code. Ref. List		√	The classification and status of the loan: List of classifications: CURRENT, TO BE REPORTED, LOW, DOUBTFUL, LOSS, FIRM. List of statuses: Code. Ref. Table 9. Format: Classification/Status Ex: FIRM/P-050
					Only the classification information is mandatory.
34.	Frequency	Number	2-3	√	The payment frequency in number of calendar days.
35.	Grant Date	Date	8	√	The grant date of the loan Format: yyyymmdd
36.	Closure Date or Maturity Date	Date	8	√	The closure date of the loan if the loan is closed. The maturity date of the loan in other cases. Format: yyyymmdd
37.	Authorized / Granted Amount	Number	14.2	√	The amount authorized for the loan Format: 99999999999999.99
38.	Currency	Code. Ref. List		√	The code of the currency used to grant the loan. List of currencies: HTG: Gourde, USD: US dollar
39.	Grace Period	Number	1-3		Time granted to the borrower before the first amortization (suspension) in number of calendar days.
40.	Reference Person	Char	1-75		The first name and last name of the reference person
41.	Responsibility towards Credit	Code. Ref. List		√	The code defining the relationship between the client and the credit. See Table 10

N.B.: At least one identification number must be specified for individuals (NIF, CIN, driver's license, or passport).