Circular CONAU 1-1730: Information Regime. Special Report on Compliance with Regulations on Non-Financial Credit Providers

"2026 - YEAR OF ARGENTINE GREATNESS"COMMUNICATION “A” 8456 07/17/2026TO FINANCIAL ENTITIES,TO NON-FINANCIAL COMPANIES ISSUING CREDIT CARDS,TO NON-FINANCIAL COMPANIES ISSUING PURCHASE CARDS,TO OTHER NON-FINANCIAL CREDIT PROVIDERS:Ref.: Circular CONAU 1-1730: Information Regime. Special report on compliance with regulations on "Non-financial credit providers"._____________________________________________________________________We are writing to you to provide the updated pages for the referenced Report for those other non-financial credit providers who use the transfer collection service, the implementation of which was disseminated through Communication A 8406.In this regard, it should be noted that, in cases of requesting access to the transfer collection service, the first submission must be made through the "Register of Non-Financial Credit Providers" application.Likewise, the annual submission - corresponding to the year in which the request is made in the register - will be sent even if the period subject to review is less than 12 months.Finally, it is noted that for its submission, the specifications established in Section 74. of the consolidated text of "Submission of information to the Central Bank" will be taken into account.Sincerely,CENTRAL BANK OF THE ARGENTINE REPUBLICMariana A. Díaz Manager of Information RegimeRodrigo J. Danessa Deputy General Manager of Information Regime and Financial Services User Protection i/cANNEX1. Covered entities.This requirement must be met by non-financial companies issuing credit and/or purchase cards and other non-financial credit providers, except mutual associations and cooperatives, registered in the registers enabled by the Central Bank of the Argentine Republic (BCRA).Those other non-financial credit providers who are authorized to access the transfer collection service (Communication A 8406) and are mutual associations and cooperatives must also comply with this requirement.2. Content.The aforementioned entities must submit the Special Report on compliance with the regulations on "Non-financial credit providers", in accordance with the model included in the Annex, in observance of the regulations issued by the BCRA that are applicable according to the type of non-financial provider in question.The report must be prepared by registered professionals or professional associations, with the pertinent certification by the Professional Council of Economic Sciences where they are registered, it not being a requirement that they be registered in the auditors' register referred to in the "Minimum Standards for External Audits for Financial Entities".However, in the case of other non-financial credit providers who request access to the transfer collection service (Communication A 8406) or are authorized, this report must be prepared by registered professionals or professional associations who are registered in the "Auditors' Register" enabled by the Superintendency of Financial and Exchange Entities and include the procedure established in point E) "Minimum requirements for the management of technology and information security risks associated with digital financial services" of the model included in the Annex.3. Frequency and due date.The requirement will be annual, covering the period between 1/1 and 12/31 of each year.The report corresponding to the year of registration will be submitted even if the period subject to review is less than 12 months.In cases of requesting access to the transfer collection service, the first submission must be made through the "Register of Non-Financial Credit Providers" application.The annual submission - corresponding to the year in which the request is made in the register - will be sent even if the period subject to review is less than 12 months.The deadline for submission will be February 20 (or the next business day if it is a non-business day). For its submission, the specifications established in Section 74. of the consolidated text of "Submission of information to the Central Bank" will be taken into account.B.C.R.A. INFORMATION REGIMESPECIAL REPORT ON COMPLIANCE WITH REGULATIONS ON “NON-FINANCIAL CREDIT PROVIDERS”Version: 2nd. COMMUNICATION “A” 8456 Effective: 07/18/2026 Page 1-1-SPECIAL REPORT OF INDEPENDENT PUBLIC ACCOUNTANTS REQUIRED IN POINT 2.2.2. OF THE REGULATIONS ON “NON-FINANCIAL CREDIT PROVIDERS”To the members of the Board of Directors [or equivalent authorities] ofXXX [Company Name].CUIT N° [complete]Legal address: [complete]------------------------------------------1. Purpose of the engagementWe have been engaged by XXX (hereinafter “the Company”), to issue a special report on compliance with the regulations on “Non-financial credit providers” –point 2.2.2.–, of the Central Bank of the Argentine Republic (hereinafter “BCRA”), during the period between .. of ….. of ….. and .. of ….. of …..2. Responsibility of the Company's ManagementThe Company's Management is responsible for complying with the provisions established in the regulations on “Non-financial credit providers” and other BCRA regulations applicable to non-financial credit providers, for the financing they grant under these regulations.Likewise, the Company's Management is responsible for establishing and maintaining an adequate internal control system that includes compliance with BCRA regulations regarding Non-financial credit providers. Due to the inherent limitations of any internal control system, errors or irregularities may occur and may not be detected. Furthermore, the projection of any system evaluation to future periods is subject to the risk that procedures become inadequate due to changes in conditions, or that the degree of compliance with procedures deteriorates, so due attention must be paid to maintaining updated procedures appropriate to the circumstances.3. Professional's responsibilityOur responsibility consists of issuing this special report, based on our professional work, detailed in the following chapter, to comply with the BCRA requirements mentioned in chapter 1.4. Professional workOur professional work was developed in accordance with the standards on special reports established by Technical Resolution N° 37 of the Argentine Federation of Professional Councils of Economic Sciences (hereinafter “RT 37”) and consisted of applying certain procedures necessary to verify the Company's compliance with BCRA requirements in relation to the regulations on “Non-financial credit providers”. RT 37 requires us to comply with ethical requirements, as well as to plan and execute our work in such a way that allows us to issue this special report.In an engagement to issue a special report, the accountant applies a series of procedures to verify the Company's compliance with certain requirements of the supervisory body, and is limited to providing a statement of findings based on the results obtained from those procedures. This service improves the reliability of the information subject to the work, by being accompanied by an independent professional statement. Consequently, our workB.C.R.A.SPECIAL REPORT ON COMPLIANCE WITH REGULATIONS ON “NON-FINANCIAL CREDIT PROVIDERS”-ANNEX--2-does not constitute an audit, a review of financial statements, or other assurance engagement.[In case this report is issued by the auditor, the following paragraph may be added:In our capacity as external auditors of the Company, we have audited its financial statements as of __ of _____ of 20, prepared in accordance with [indicate the financial reporting framework], regarding which we issued on __ of ______ of 20 our independent auditor's report without reservations [or with reservations, adapt as appropriate], to which we refer. We have not performed any audit of any financial statement of the Company, as of any date and for any period subsequent to __ of ______ of 20.]The procedures detailed below, within our competence and in certain cases performed on a selective basis, have been applied to the records and documentation provided to us by the Company. Additionally, for the execution of these procedures, we have taken into account our understanding of the Company's internal control environment regarding the aspects reviewed and other aspects.[adapt and/or eliminate the procedures listed below as applicable to the operations of each non-financial credit provider]A. Interest rates on credit operationsi. Verify for the affected financings what is established in points 1.3. “Settlement bases”, 1.4. “Application modalities”, 1.5. “Fixed divisor” and 1.6. “Punitive interest” of the regulations on “Interest rates on credit operations”, by means of reviewing the formula used for calculating interest and/or reprocessing the interest of a representative sample of cases determined from the universe of operations in force during the period between __ and __ [must cover the year covered by the review].ii. Regarding financings linked to credit cards, by means of reviewing a representative sample of cases determined from the universe of operations in force during the period between __ and __ [must cover the year covered by the review] verify regarding Compensatory Interest what is established in points 2.1.2. “Other issuing companies” and 2.1.3. “Calculation method” and regarding Punitive Interest what is established in point 2.2. of the regulations on “Interest rates on credit operations”. Also verify compliance with the cited regulatory points in case of balance refinancings, in accordance with the provisions of point 2.3. “Financings granted to refinance outstanding credit card balances” of the aforementioned regulations.iii. Verify by means of reviewing a representative sample of contracts, credit card statements and/or cases determined from the universe of operations in force during the period between __ and __ [must cover the year covered by the review], that the commissions and charges collected from users comply with what is established in points 1.7. “Commissions and charges additional to interest” of the regulations on “Interest rates on credit operations” and 2.3.2. “Commissions and charges” of the regulations on “Protection of financial service users”.iv. Regarding advertising offers, through any mass or individual medium, of specific credits, evaluate the existence of policies and procedures established by the Company to guarantee compliance with what is established in Section 4. “Advertising” of the regulations on “Interest rates on credit operations”. [In case of absence of policies and procedures, verify by obtaining a-3-representative sample of advertisements in graphic, radio, television, telephone and other media, during the period between __ and __ [must cover the year covered by the review], compliance with the provisions of Section 4. “Advertising” of the regulations on “Interest rates on credit operations”.]B. Protection of financial service usersi. Regarding the contract models and other instruments used by the Company during the period between __ and __ [must cover the year covered by the review] in relation to credit operations entered into with its clients:a. Verify compliance with the provisions of point 2.3.1. “Minimum precautions for the consumer relationship - At the time of contracting the product or service”, of the regulations on “Protection of financial service users”, also verifying the delivery to the user of copies of the subscribed instruments in accordance with what is established in point 2.4. “Information advertising” of the aforementioned regulations, by obtaining a representative sample of cases determined from the universe of operations in force during the period between __ and __ [must cover the year covered by the review].b. Verify that the contract model does not provide for the modification of the interest rate in certain circumstances for fixed-rate contracts and determines the parameters to be used in determining the interest rate for variable-rate instruments in accordance with what is indicated in point 1.2. of Section 1. “General aspects” of the regulations on “Interest rate on credit operations”.c. Verify the absence of clauses that restrict users' rights or distort the obligations of obligated entities, indicated in point 2.3.9. “Abusive clauses” of the regulations on “Protection of financial service users”.ii. In relation to the disclosure of the interest rate and the Total Financial Cost (CFT) verify, based on a representative sample of contracts and/or cases determined from the universe of operations in force during the period between __ and __ [must cover the year covered by the review], the following aspects:a. That in compliance with what is indicated in Section 3. “Rate Expression” in its point 3.2. “Disclosure in documents” of the regulations on “Interest rate on credit operations” it is stated (i) the annual interest or discount rate contractually agreed as a percentage with at least one decimal, (ii) the effective annual interest rate equivalent to the calculation of interest in arrears as a percentage with at least one decimal, (iii) the fixed or variable nature of the interest rate, with an indication in the latter case of the parameters to be used for its determination and the frequency of change, and (iv) CFT.b. That for the purpose of disclosing the effective annual interest rate, the formulas provided in point 3.3. “Calculation of the effective annual interest rate” of the regulations on “Interest rate on credit operations” are used.c. That for the purpose of disclosing the CFT, the formulas provided in point 3.4. “Total financial cost” of the regulations on “Interest rate on credit operations” are used.-4-d. That account statements include the legends provided in point 2.3.14. “Information to the user” of the regulations on “Protection of financial service users”iii. Regarding changes in agreed conditions, verify:a. That in contracts, the conditions that can be modified are exhaustively specified.b. In case of modifications in the agreed conditions, verify for a sample of cases compliance with the provisions of point 2.3.4. “Changes in agreed conditions” of the regulations on “Protection of financial service users” regarding notification to the user.c. Verify the information to the BCRA of commissions and charges collected, and of new and increased commissions that they wish to implement through the information regime provided for this purpose, as well as their notification to users in accordance with what is indicated in point 2.5. “Information to the Central Bank of the Argentine Republic” of the regulations on “Protection of financial service users”.iv. Verify what is established in point 2.3.12. “Insurance as an accessory contract to a financial service” of the regulations on “Protection of financial service users” regarding not charging users life insurance on outstanding balances and, for other accessory insurance, offering at least three insurance companies, and what is established in point 2.3.13. “Insurance as a non-accessory contract to the financial service” of the regulations on “Protection of financial service users” regarding that, if this type of insurance is offered, the provider does not receive any remuneration from the user, by means of reviewing a sample of contracts and/or cases determined from the universe of operations in force during the period between __ and __ [must cover the year covered by the review].v. In case of detecting interest, commissions and/or charges collected in excess, verify that the provisions of point 2.3.5. “Reimbursement of amounts” of the regulations on “Protection of financial service users” have been complied with.vi. In relation to the user service, verify the following:a. That the Company's Board of Directors has appointed an official as responsible for financial service user attention as titular and at least one other as substitute as prescribed in point 3.1.1. “Responsible for financial service user attention (titular or substitute in charge)” of the regulations on “Protection of financial service users”.b. That (i) the Centralized Register of Queries and Complaints (RCCR) referred to in point 3.1.3. “Centralized Register of Queries and Complaints (RCCR)”; (ii) the Register of Amount Reimbursements (RRI) provided for in point 3.1.4. “Register of Amount Reimbursements (RRI)”; and (iii) the Register of Complaints before Judicial and/or Administrative Consumer Defense Instances (RDJA) established in point 3.1.5. “Register of Complaints before Judicial and/or Administrative Consumer Defense Instances (RDJA)” of the regulations on “Protection of financial service users” have been enabled and are kept updated.c. That a report is prepared and submitted to the Board of Directors or the Executive Responsible for the Protection of Financial Service Users or the Committee for the Protection of Financial Service Users –as appropriate–, with a minimum quarterly frequency, regarding: (i) queries and complaints received; (ii) interventions required by complaints processed before the competent judicial and/or administrative consumer defense instances and (iii) amount reimbursements made, in compliance with what is established in point 3.1.1.8. of the regulations on “Protection of financial service users”.-5-d. That the Board of Directors has approved, after acknowledging the Audit Committee [in case the Company has an Audit Committee], the steps and precautions to be observed for handling user queries and complaints as established in point 3.1.2 “Procedure Manual” of the regulations on “Protection of financial service users”.e. That the rules and procedures established by the Company provide for the different alternatives for submitting queries and complaints from financial service users as provided in point 3.1.6. “Reception of submissions and response time” of the regulations on “Protection of financial service users”, andf. That the Company's Internal Audit completes at least annually a comprehensive evaluation of the processes implemented to comply with the regulations on “Protection of financial service users”. [only applicable if the Company has an Internal Audit area]vii. In relation to communication by electronic means for environmental care, verify the following:a. Verify that the entity publishes on its institutional website the information provided in points 5.2. “Models and location of information” and 5.3. “Mandatory disclosure information” of the regulations on “Communication by electronic means for environmental care”.b. Verify that the information detailed in points 4.4.1.2., 4.4.1.7 and 4.5.1. of the regulations on “Communication by electronic means for environmental care” is disseminated in public service areas, in the modalities provided therein.C. Information Regimei. Regarding the information regimes for Credit Card Financing, Debtors of the Financial System, Transparency and Complaints corresponding to the period between .. of ….. of ….. and .. of ….. of …..[must cover the year covered by the review]:a. Verify that the Company has submitted these information regimes in compliance with the deadlines and presentation designs established by the BCRA.b. Verify for a sample of cases that the information incorporated in these regimes arises from the supports or analytical inventories provided by the Company or with the respective supporting documentation.c. Verify the integrity of the information regimes for Debtors of the Financial System and Credit Card Financing for the monthly period corresponding-6-to the last month of the review period by comparing their totals with the corresponding accounting records.d. Regarding the Complaints information regime, verify that the Company (a) has designed procedures and controls to ensure that the information incorporated into the regime arises from the centralized register of queries and complaints; and (b) has incorporated the URL corresponding to the section “Information to the financial user”, point 5.2. of the regulations on “Communication by electronic means for environmental care”.D. Non-financial credit providersVerify that the update of the registration information required in point 1.3.3. of the regulations on “Non-financial credit providers” has been complied with.E. Minimum requirements for the management of technology and information security risks associated with digital financial servicesVerify that the Company complies with point 3.3 “Digital identification of clients” of the consolidated text of “Minimum requirements for the management of technology and information security risks associated with digital financial services”, regarding the processes and controls applicable to client identification/onboarding within the framework of the Transfer Collection operation.For this purpose, the following procedures were carried out:a) Corroborate that the Company applies mechanisms for validating the client's real presence through liveness tests.b) Verify that the Company implements controls to validate the contact points declared by the client, as well as the associated mobile device.c) Verify that the Company implements m