Circular G-176-2014: Provisions on the User Service Department for Supervised Companies

Lima, 5 September 2014

CIRCULAR No. G – 176 – 2014 -------------------------------------------------------- Ref.: Circular for the User Service Department --------------------------------------------------------

Sir
General Manager:

Please be advised that, in exercise of the power conferred by numeral 9 of article 349 of the General Law of the Financial System and the Insurance System and Organic Law of the Superintendency of Banking and Insurance, Law No. 26702 and its amending norms, hereinafter the General Law, and for the purpose of promoting adequate service to the users of the companies under its control, the Superintendency approves the Circular for the User Service Department; and having complied with the pre-publication of norms provided in Supreme Decree No. 001-2009-JUS, the Superintendency orders the publication of the circular:

1. Scope

The provisions of the circular are applicable to the companies indicated in articles 16 and 17 of the General Law, to the Banco de la Nación, to the Fundación Fondo de Garantía para Préstamos a la Pequeña Industria (FOGAPI), to the Derramas and Cajas de Beneficios, the Asociaciones de Fondos Regionales o Provinciales contra Accidentes de Tránsito (AFOCAT), as well as to the Administradoras Privadas de Fondos de Pensiones (AFP), hereinafter the companies.

The companies are governed by the provisions of the circular, in accordance with the special and/or complementary provisions or norms issued by the Superintendency, where applicable, and the applicable aspects of the Consumer Protection and Defense Code, Law No. 29571 and its amending norms, and the Regulation of the Complaints Book approved by Supreme Decree No. 011-2011-PCM and its amending norms.

2. Definitions

For the purposes of the provisions of the circular, consider the following definitions:

a) Inquiry: communication submitted by a user so that certain information is provided to them in a situation of uncertainty, lack of knowledge or doubt related to the operation, product or service offered or contracted with the company. Aspects related to the handling of claims submitted by users cannot be considered as an inquiry.

b) Complaint: notice or bringing to the knowledge of the Superintendency, by a user or a third party, of a fact that constitutes an alleged infringement of the norms that regulate the complained company.

c) Days: calendar days.

d) INDECOPI: National Institute for the Defense of Competition and the Protection of Intellectual Property.

e) PAU: User Service Platform of the Superintendence.

Los Laureles No. 214 - Lima 27 - Perú Tel.: (511) 6309000 Fax: (511) 6309239

f) Claim: communication submitted by a user through the different service channels available in the company, expressing their dissatisfaction with the operation, product or service received or for the breach of the obligations contemplated in the contracts or current regulatory framework, or manifesting the alleged impairment of their legitimate interest. Additionally, any reiteration that originates as a consequence of the user's disagreement regarding the response issued by the company, or due to the delay or lack of handling of a request, inquiry, claim or request for information, must be considered a claim.

g) Transparency Regulation: the Regulation of Transparency of Information and Contracting with Users of the Financial System, approved by SBS Resolution No. 8181-2012 and its amending norms and/or the Regulation of Transparency of Information and Contracting of Insurance, approved by SBS Resolution No. 3199-2013.

h) Superintendency: Superintendencia de Banca, Seguros y Administradoras Privadas de Fondos de Pensiones.

i) User: natural or legal person who uses or may use the products and services offered by the companies.

3. General aspects

To comply with the provisions of the circular, the communications sent by users whose content is included in the definitions of "inquiry" or "claim", as well as in the case of requests for information, may only be recorded by the companies in said categories.

4. Handling of inquiries

4.1. The companies must have inquiry handling manuals, where they establish the internal procedures and deadlines for handling, the reception channels and the areas responsible for answering inquiries. Likewise, a record of inquiries must be kept that allows adequate monitoring of the service provided. Said manuals must be available to the Superintendency, when it requires them.

4.2. For the handling of inquiries, the companies must have personnel trained and specialized in user service. Said personnel must identify themselves with their names and surnames.

4.3. The companies must respond to the inquiries made, to the domiciliary address or email registered by the user at the time of contracting or during the contractual relationship - if the user so requires -, within a period no greater than thirty (30) days of having been submitted through the channels enabled for such purpose by the companies. Said period may be extended, exceptionally, provided that the complexity of the inquiry justifies it. The companies must have the supporting documents for the extensions of deadlines, which may be required by the Superintendency. This extension must be communicated to the user within the aforementioned period, specifying the estimated response time.

4.4. The private pension fund administrators (AFP) must apply the provisions of Title IV of the Superintendency Regulations of the Private Pension Fund Administration System (SPP), to handle user inquiries.

Los Laureles No. 214 - Lima 27 - Perú Tel.: (511) 6309000 Fax: (511) 6309239

5. Request for information

5.1. Companies must have manuals for handling users' information requests regarding aspects related to the operation, product or service contracted with the company, but that are not referred to situations included in the definition of inquiry. Additionally, companies must establish the channels and procedures for handling, and maintain a record of said requests, which allows the generation of detailed reports on the handling of all their aspects.

The aforementioned manuals and the record must be available to the Superintendency, when it requires them.

5.2. Companies must respond to information requests within a period no greater than thirty (30) days from their submission. Said periods may be extended, exceptionally, provided that the nature of the request justifies it. Companies must have the supporting documentation for the extensions of periods, which may be required by the Superintendency. This extension must be communicated to the applicant within the aforementioned period, specifying the estimated response period.

5.3. The AFP must apply the provisions of Title IV of the Superintendency's Regulatory Norms of the SPP, to handle users' information requests.

6. Claims Handling System

As part of the claims handling system, companies must:

6.1. Have a claims handling system that guarantees compliance with the provisions of the applicable regulations, establishing procedure manuals for their registration, follow-up and handling, which include the presentation requirements, the various reception channels, the internal handling periods, the interaction with other areas, the conservation of the documentation contained in the claim files, the identification of claims that by their characteristics will always be resolved in favor of the user without requiring analysis of the particular case, additional aspects indicated in the circular, and others at the discretion of the companies. Said manuals must be available to the Superintendency.

6.2. Have a backup system for the claims handling system that can be physical or virtual for when the system originally established by the company for claims handling cannot be used.

6.3. Make available to users, at least, the following claims reception channels: a) network of customer service offices; b) telephone via the number designated for claims reception; c) electronic via the email established by the company and/or its website. Companies may request from the Superintendency, exceptions for the implementation of the channels indicated in literals b) and/or c), supporting said request on their size and/or the volume of claims they register.

Los Laureles No. 214 - Lima 27 - Peru Tel.: (511) 6309000 Fax: (511) 6309239

6.4. Provide handling of the claims presented, through specialized personnel and in accordance with the provisions established by the current regulatory framework.

6.5. Register all claims made by users in a computer support that allows adequate follow-up of the handling provided, regardless of the channel or means used for their presentation. Said record must allow the generation of detailed reports, identifying all aspects related to the claim.

6.6. Record, in the computer support of the claims handling system, the date on which each claim was handled.

6.7. In the case of companies of the financial system, the claims reception and handling channels are autonomous from those implemented by the company to report the loss or theft of cards, or their information, as well as improper charges and unrecognized operations, related to said events.

7. Claims Handling Area

7.1 Companies must have an area in charge of handling the claims presented by users.

Companies must guarantee that the claims handling areas have the adequate human, material and technical resources for the fulfillment of their functions. In particular, they must adopt the necessary actions so that the personnel have the knowledge and management of the policies, procedures and internal periods of user service established by the company, in accordance with the provisions established by the Superintendency.

7.2 Companies must designate a responsible person in charge of the supervision and/or coordination of the areas in charge of claims handling. Their designation must be informed to the Superintendency within fifteen (15) days after the beginning of the exercise of their functions, attaching updated information regarding the organization, infrastructure and policies established for the operation of the area in charge of claims handling, identifying the functions and responsibilities of each of its members.

Likewise, an alternate responsible person must be appointed who will be in charge of complying with the obligations detailed in the circular, only in the absence of the titular. Their designation will be brought to the attention of the Superintendency, considering -for such purpose- the period indicated in the preceding paragraph.

7.3 Any substantive modification, regarding the information indicated in point 7.2, must be communicated to the Superintendency within fifteen (15) days of having been made.

7.4 Companies, in order to comply with the provisions of numerals 7.2 and 7.3, must send the requested information to the Superintendency, both in writing and by electronic means to the address transparencia@sbs.gob.pe.

7.5 The Superintendency may allow, exceptionally, those companies that due to their volume of claims and size do not require having a claims handling area,

Los Laureles No. 214 - Lima 27 - Peru Tel.: (511) 6309000 Fax: (511) 6309239

entrust the tasks of said specialized area to another area or officer of the company that can fulfill the purpose of the claims handling system, in accordance with the current regulatory framework. Companies may request the Superintendency to apply said exceptional treatment, by submitting the information that the Superintendency requires from them for such purpose. This provision is not applicable in the case of private pension fund administrators.

AFOCATs, due to their size and volume of operations, may entrust the tasks of the claims handling area to another area or officer they designate, without requiring prior authorization from the Superintendency. Without prejudice to the foregoing, they must submit the information referred to in numerals 7.2 and 7.3, as applicable.

8 Officer Responsible for the Claims Handling Area

8.1 The officer responsible for the claims handling area ensures the implementation and compliance of the company's policies and procedures related to claims handling, as well as compliance with the circular.

8.2 The responsible officer must handle the requests made by the Superintendency, in order to respond to complaints filed by users of the companies or to requests made by third parties before the Superintendency.

8.3 In the case of companies included within the scope of application of the Transparency Regulation applicable to companies of the financial system or the insurance system, the aforementioned responsible officer must coordinate permanently with the user service officer on the aspects regulated in the circular.

9. Management reports

9.1 The officer responsible for the claims handling area prepares quarterly reports on the evolution of claims handling, indicating, at a minimum, the following aspects: a) the operations, products or services, as applicable, b) the reasons for the highest number of claims, c) the average handling time, d) the corrective measures adopted, e) the improvement opportunities detected, and f) others indicated by the Superintendency through multiple official letter.

Quarterly reports must also be prepared, considering the minimum aspects detailed in the preceding paragraph, when applicable, on the inquiries and information requests referred to in numerals 4 and 5 of the circular.

The results of said reports must be coordinated with the areas involved and brought to the attention of general management. In the case of companies under the scope of application of the Transparency Regulation applicable to companies of the financial system or the insurance system, as applicable, said results must also be coordinated with the user service officer.

9.2 The management reports must be available to the Superintendency with the corresponding support. The Superintendency must be allowed access to the information recording system for the corresponding verifications, as well as to the improvement projects

implemented, which must be detailed at the request of this oversight and control body.

10. Procedure for the submission, processing and resolution of claims

Submission and admission

10.1 Users have the right to submit claims through the channels referred to in numeral 6.3 of the circular. The network of customer service offices of the companies must receive and channel the supporting information provided by users, as a consequence of the submission of a claim, regardless of the channel used for its submission.

10.2 At the time of submission of claims, companies must:

a) Record the user's personal data and the domiciliary or electronic address to which the response to the claim must be given, as indicated by the user. The parties may agree on a specific response mechanism for claims resolved in favor of users, provided that said agreement can be reliably proven. In the event that the claim is submitted by a third party on behalf of the user, and no reference is made to the applicable address for providing the response, the company responds to the claim at the domiciliary address or email registered by the user, at the time of contracting or during the contractual relationship. Companies must adopt the corresponding measures to corroborate that the claim is submitted on behalf of the user.

b) Prepare a report that considers, at a minimum, the information detailed in Annex No. 1 – A, B C, D or E of the circular, as applicable to: i) the financial system or companies providing complementary or related services, ii) the insurance system, iii) AFOCAT, iv) contributions and benefit funds or v) SPP, respectively. This report will be delivered to the user as proof of the submission of the claim, if it is made at a customer service office.

When the claim is submitted through channels other than those indicated in the preceding paragraph, the following must be done:

b.1) Provide at the time of submission of the claim, a proof or registration code, which must include the claim identification number and the date and time of its submission.

b.2) Agree with the user on the manner in which the proof will be delivered, through a customer service office of the company, email, among other mechanisms implemented by the companies. In any case, the report must be available to the user on the day the claim is submitted, provided that it is made within the operating hours of the network of customer service offices of the companies; otherwise, on the next business day.

When the claim is submitted by a third party on behalf of the user, the acknowledgment of receipt of the submitted claim is considered as compliance with the issuance of the report, provided that said document refers to the channel the user can access, to obtain the detailed information in Annex No. 1 – A, B, C, D or E of the

Los Laureles No. 214 - Lima 27 - Peru Tel.: (511) 6309000 Fax: (511) 6309239

circular, as applicable, regarding the submitted claim, considering the provisions of the preceding paragraph. Companies must adopt the corresponding measures to corroborate that the claim is submitted on behalf of the user.

10.3 Companies may require the user to provide documentation or complementary information on aspects related to the claim, provided that they do not have it or cannot obtain it, granting a period of no less than two (2) business days for its submission, and specifying the consequences derived from non-compliance with said requirement. If possible, companies must guide users to obtain said documentation.

Processing and completion

10.4 Companies must substantiate the handling of all their claims, and said substantiation must be kept available to the Superintendency. In those claims declared in favor of the client as a consequence of the application of internal policies, the manuals that collect these policies may be considered as substantiation.

10.5 In the case of claims resolved in favor of the companies, they must base their decisions in the response communication to the user, attaching, if applicable, a copy of the corresponding substantiating document. Likewise, in said communication, the various instances to which the claimant may resort must be expressly mentioned, if they are not in agreement with the result of the decision, such as INDECOPI; the Superintendency, in the case of claims related to aspects of the SPP; and the National Health Superintendency, in the case of claims related to aspects of health risk coverage; as applicable.

10.6 For the application of the circular, a claim is understood to have been resolved in favor of the user when in all its aspects it has been attended in favor of the user, without any controversy remaining over the facts set forth in the claim.

11. Computation of terms and notification

11.1 Claims must be resolved within a period no greater than thirty (30) days from their submission, with the exception of:

a) Claims submitted against the AFP which, for said purpose, have a period no greater than fifteen (15) business days.

b) Claims related to the microinsurance product, which have a period no greater than fifteen (15) days, in accordance with the Microinsurance Regulation, approved by SBS Resolution No. 14283-2009 and its amending norms.

11.2 The claims handling area must ensure that claims are handled diligently and that the response is communicated to users within the periods established in numeral 11.1 above. Said periods may be extended, exceptionally, provided that the nature of the claim justifies it. In these cases, the substantiation for the extension of the period must be available to the Superintendency. Said extension must be communicated to the user within the aforementioned period, explaining the reasons for the delay, in addition to specifying the estimated response period. The extension

Los Laureles No. 214 - Lima 27 - Peru Tel.: (511) 6309000 Fax: (511) 6309239

exceptional extension of the period is not applicable in cases of claims referring to aspects derived from the administration of pension funds by the AFP.

11.3 The computation of the period for handling claims begins from the date of submission of the claim before the companies, until the date of receipt of the final response communication by the user, through the corresponding channel, in accordance with the provisions of numeral 10.2 a), and must be counted, in each case, with due substantiation.

11.4 In accordance with the provisions of numeral 10.2, the notification of the response to the claim must be communicated in writing to the domiciliary or electronic address indicated by the user. For the notification, the following must be complied with:

a) In the case of notifications to the domiciliary address, these must be substantiated by the company, which must keep in its files the respective acknowledgments of receipt of the communications sent. These acknowledgments must prove the names and surnames of the person receiving the communication, the type and number of their identity document and/or their relationship or kinship with the user, their signature, in addition to the date on which the notification is made. If the person receiving the communication refuses to sign the acknowledgment of receipt of the notification, or if – having made a first attempt, duly evidenced – there is no person at the domicile who can receive said document, the notification must be left under the door, leaving a record of this in the respective acknowledgment, and the date, time and main characteristics of the facade of the property must be recorded.

b) In the case of notification by electronic mail, it will be considered validly made with the proof of sending the response to the claim addressed to the electronic mail address provided by the user.

11.5 In the event that the parties have agreed, the notification of the response to claims resolved in favor of users may be made through a response mechanism other than those indicated in numeral 11.4, provided that it allows proof of the notification to be left. In the claims resolved in favor of the user that involve the return or delivery of a sum of money, the calculation of the service period is understood to be completed on the date on which the user is in a position to know the measure adopted in their favor, through the agreed means in accordance with numeral 10.2 a), and the company must keep the supporting evidence thereof in order to provide it to the Superintendency upon request.

12. Archiving of documentation

12.1 Companies implement mechanisms that allow the proper archiving of claim, inquiry and information request files, which must contain all the documentation that supports the service and follow-up provided in each particular case, with the exception of claims that have been declared in favor of the client as a consequence of the application of internal policies. The conservation and access to the aforementioned documentation is the responsibility of the claims service area, and must be available to the Superintendency when required.

Los Laureles No. 214 - Lima 27 - Peru Tel.: (511) 6309000 Fax: (511) 6309239

12.2 In those cases in which the registration of inquiries is mandatory, in accordance with the current regulatory framework, companies must observe, as applicable, the provisions of numeral 12.1.

12.3 Companies may use technological tools for the archiving of documents and information, which must have the authorization of the Superintendency and contain the characteristics set forth in Legislative Decree No. 681, SBS Resolution No. 5860-2009 and related regulations, on substitution of documents.

13. Information to the user

13.1 Companies must keep available to users, in all their establishments open to the public, in a visible and easily accessible place, posters and/or brochures with information on the procedures for handling inquiries and claims, clearly establishing the requirements for their procedures, the maximum service periods and the channels made available to users for their corresponding reception; likewise, this information must be available on their website.

13.2 Companies must keep available to the public informative material related to the work of the Superintendency, which has been provided to them by it, in order to inform about its competencies in handling inquiries, claims or complaints related to the services provided by the companies.

14. Management indicators

Companies must establish management indicators, which constitute control mechanisms for the proper management of the user service system, for handling inquiries, claims and information requests. These indicators must be brought to the attention of the Superintendency, within the period granted for the circular to enter into force, specifying the concept of the indicator and the parameters for its registration and comparison. Any modification of the aforementioned indicators must be reported to the Superintendency within fifteen (15) days of having been made.

The Superintendency may designate those minimum indicators and parameters related to the aspects contemplated in the circular, which companies must consider based on the services and/or products they offer in the market, aspects that will be brought to their attention for their respective implementation and reporting by means of a multiple official letter.

15. Dissemination of claims information through the website

Each company must disseminate, through its website, in the portal or specific area in which information associated with products and services offered to the user is disseminated, in a prominent and easily accessible manner, the statistical information related to the claims submitted by users.

The information disseminated must show the total claims handled by the company, classified by the ten (10) operations, products or services that are most frequently the subject of claims, for the last quarter reported to the Superintendency, indicating the three (3) most frequent reasons for claims. Likewise, the number of claims that were resolved in favor of the user and in favor of the company must be distinguished, as well as the average time of their handling and the total number of operations of the company in the last quarter, considering

Los Laureles No. 214 - Lima 27 - Peru Tel.: (511) 6309000 Fax: (511) 6309239

as applicable, what is indicated in claim reports No. RR1, RR2 and RR3, which are presented as Annex No. 2 of the circular. Such information must be kept on its website for a period of no less than one year.

Companies may additionally show, in a disaggregated form, information related to claims that have been declared admissible, as a consequence of the application of the internal policies indicated in numeral 10.4 of the circular, as applicable.

16. Communication of Statistics

16.1 Companies must report quarterly to the Superintendency, within fifteen (15) days after the close of each calendar quarter, the statistics of the claims submitted by their corresponding users. Such statistics must consider information referring to the number of claims received, number of claims handled (in favor of the user and in favor of the company), average handling time, the products and reasons for claims, the number of claims in process and the total number of operations of the company in the last quarter.

16.2 The aforementioned statistics must be sent to the Superintendency via the External Capture and Validation Submodule (SUCAVE), using, as applicable, claim reports No. RR1, RR2 and RR3 presented as Annex No. 2 of the circular, as applicable. For this purpose, the code tables included as annexes to the circular must be taken into account, which may be updated by the Superintendency by means of a multiple official letter.

16.3 In the case of companies that are not required to submit through SUCAVE, the aforementioned reports must be sent in an Excel file, via email, to the address transparencia@sbs.gob.pe.

17. Training

The companies must prepare an annual training plan for the personnel in charge of handling claims and/or inquiries, which includes aspects related to the regulatory framework applicable to such companies, to the rules on transparency of information and consumer protection, as well as regarding their functions. The aforementioned plan is submitted for prior consideration by the board of directors and approved by it before 31 December of each year.

Without prejudice to the foregoing, in the event of modifications to the current regulatory framework on transparency of information and consumer protection, or other relevant regulatory aspects, the personnel in charge of handling claims and/or inquiries must be informed of such modifications.

The documentation supporting compliance with the provisions of this numeral must be available to the Superintendency.

18. Resolution of inquiries in a group or guild form

Companies may organize themselves in a group or guild manner to resolve and handle user inquiries, a situation that must be brought to the attention of the Superintendency within a period no greater than fifteen (15) days from having decided the implementation of such system. The companies must inform within said period about the established service procedures, as well as their organization and functions manuals.

Los Laureles Nº 214 - Lima 27 - Perú Tel.: (511) 6309000 Fax: (511) 6309239

19. Annexes The annexes that form part of the circular are published on the institutional portal (www.sbs.gob.pe), in accordance with the provisions of Supreme Decree No. 001-2009-JUS and its amending rules.

20. Multiple Official Letter The Superintendency, by multiple official letter, may establish interpretations on aspects related to compliance with the circular.

21. Validity1 The circular enters into force on 1 October 2015, with the exception of numerals 6, 10, 11 and 13 of the circular, which enter into force on 1 January 2015.

On 1 October 2015, the Circular of Service of Attention to Users, Circular No. G-146-2009 and its amending rules, is repealed. The Superintendency determines the manner in which the information included in reports 24, 24-A and 24-B of the Circular of Service of Attention to Users, Circular No. G-146-2009 and its amending rules, is submitted, by means of a multiple official letter.

The foregoing does not eliminate compliance with the applicable provisions included in the Consumer Protection and Defense Code, Law No. 29571 and its amending rules, and in the Regulation of the Complaints Book approved by Supreme Decree No. 011-2011-PCM and its amending rules.

Atentamente,

DANIEL SCHYDLOWSKY ROSENBERG
Superintendent of Banking, Insurance and
Private Administrators of Pension Funds

[1] Numeral modified by Circular G-178-2014 of 30/12/2014.

Los Laureles Nº 214 - Lima 27 - Perú Tel.: (511) 6309000 Fax: (511) 6309239

SUPERINTENDENCY OF BANKING, INSURANCE AND AFP Republic of Peru

Los Laureles Nº 214 - Lima 27 - Peru Tel.: (511) 6309000 Fax: (511) 6309239

Los Laureles Nº 214 - Lima 27 - Peru Tel.: (511) 6309000 Fax: (511) 6309239

Los Laureles Nº 214 - Lima 27 - Perú Tel. : (511) 6309000 Fax: (511) 6309239

Los Laureles Nº 214 - Lima 27 - Perú Tel. : (511) 6309000 Fax: (511) 6309239

Los Laureles Nº 214 - Lima 27 - Perú Tel. : (511) 6309000 Fax: (511) 6309239

Los Laureles Nº 214 - Lima 27 - Perú Tel. : (511) 6309000 Fax: (511) 6309239

Los Laureles Nº 214 - Lima 27 - Perú Tel. : (511) 6309000 Fax: (511) 6309239

Claim Report No. RR3

DETAIL OF OTHER CHANNELS, OTHER OPERATIONS - SERVICES - PRODUCTS AND OTHER REASONS FOR CLAIM (1)

From:
/
/ to:
/
/
Company:
Code:

	OTHER OPERATIONS – SERVICES – PRODUCTS (2)		REASONS FOR CLAIM (3)		QUANTITY (4)
	Channel	Typified	Others	Channel	Typified	Others
TOTAL

.....................................
...............................................................
General Manager
Responsible Officer

1) In this report, all codes 999 recorded in claim reports No. RR1 or RR2, as the case may be, must be recorded, in accordance with the following: Claims received for operations, services or products not detailed in the Table of Codes of Operations, Services or Products (Annex No. II – claim reports No. RR1 or RR2), related to claim reasons coded specifically or not, in Annex No. III of the claim report). Claims received that are not recorded in the Table of Reasons for Claim (Annex No. III - claim reports No. RR1 or RR2) related to operation, service or product codes coded specifically or not in Annex No. II of claim reports No. RR1 or RR2.

2) In the “Typified” column, the code corresponding to the operations, services or products that have a specific code in Annex No. II of claim reports No. RR1 or RR2 must be recorded. In the “Others” column, other operations, services or products for which the claims originated and that are not typified must be detailed. Likewise, in the “Channel” column, the code of the channel in which the claim was recorded must be indicated.

3) In the "Typified" column, the code corresponding to the reasons that have a code in accordance with Annex No. III of the claim report must be recorded. In the "Others" column, other non-typified claim reasons must be detailed. Likewise, in the "Channel" column, the code of the channel through which the claim was registered must be indicated.

Los Laureles No. 214 - Lima 27 - Peru Tel.: (511) 6309000 Fax: (511) 6309239

4) The number of claims that have been submitted for the same type of operation, service or product and the same type of claim reason must be recorded.

ANNEXES TO CLAIM REPORTS No. RR1 - RR2 - RR3

Annex No. I

CHANNEL CODES2

CODE	CHANNELS
01	Office
02	ATM
03	Internet
04	Mobile Banking3
05	Telephone
06	Correspondent ATMs
07	Service executive - promoters (applicable to the SPP)
08	Information and service center for disaffiliation (CIAD)
09	Bancassurance
10	Points of sale (applicable to the Insurance System)
11	Insurance brokers
99	There is no associated channel

[2] The channel shall be considered to be the medium used to carry out the operation and/or service that is the reason for the claim.

[3] Mobile Banking is understood as the channel (application) that allows operations or inquiries to be carried out through the cell phone.

Los Laureles No. 214 - Lima 27 - Peru Tel.: (511) 6309000 Fax: (511) 6309239

Annex No. II

CODES OF OPERATIONS, SERVICES OR PRODUCTS (1) (2)

FINANCIAL SYSTEM, COMPLEMENTARY AND RELATED

CODE	OPERATIONS – SERVICES – PRODUCTS
01	Savings account (does not include code 102)
02	Checking account
03	Time deposit account
04	CTS account
05	Credit card
06	Debit card
07	Mortgage loan for housing
08	Corporate, large enterprise and medium enterprise loan
09	Consumer loan
11	Fund transfers (interbank or intrabank, between different locations of the same supervised entity)
12	Fund transfers abroad
13	Remittances
14	Factoring and/or discounting
15	Letter of guarantee / guarantees
16	Other guarantees (real and personal)
17	Securities (checks, promissory notes, among others)
18	Trust
19	Custody of securities
20	Safe deposit boxes
21	Storage
24	Financial leasing (leasing)
25	Arbitrage (buying and selling of financial securities)
26	Investments (mutual funds, among others)
27	Collection service
28	Payment of services
29	Miscellaneous services (exchange, collections, judicial payments, payroll payments, among other similar ones) other than those indicated in codes 27 and 28.
97	Credits to small enterprises and microenterprises
101	Drafts
102	Savings account intended for the deposit of remuneration
103	Bancassurance (insurance sold through the channels of the financial system)
104	Electronic money

Los Laureles No. 214 - Lima 27 - Peru Tel.: (511) 6309000 Fax: (511) 6309239

INSURANCE SYSTEM

CODE	OPERATIONS – SERVICES – PRODUCTS
31	Fire
32	Allied fire lines
33	Earthquake
34	Glass
35	Loss of profit
36	Loss of profit machinery breakdown
37	Transport
38	Marine hull
39	Aviation
40	Vehicles
41	Allied lines of vehicles
42	All risks for contractors
43	All risks contractors' equipment
44	Machinery breakdown
45	Erection all risks
46	All risks electronic equipment
47	Boilers
48	Robbery and assault
49	Dishonesty against the company
50	Comprehensive against dishonesty (3D)
51	Bankers insurance (BBB)
52	Animals
53	Household
54	Civil liability
55	Surety bonds
57	Export credit
58	Multirisk
59	Agricultural
60	Miscellaneous
61	Personal accidents
62	School
63	Medical assistance
64	SOAT
65	Individual life
66	Group life private
67	Life Law workers
68	Credit life insurance
69	Funeral expenses
70	Individual annuity (lifetime)
71	Retirees' annuity
72	Supplementary insurance for hazardous work
73	Pensions from the supplementary insurance for hazardous work
74	Pension insurance – Disability
75	Pension insurance – Survivorship
76	Pension insurance – funeral expenses
99	Microinsurance

Los Laureles No. 214 - Lima 27 - Peru Tel.: (511) 6309000 Fax: (511) 6309239

200	Card protection insurance (credit or debit)

AFOCAT

CODE	OPERATIONS – SERVICES – PRODUCTS
100	CAT

ASSESSMENTS AND BENEFIT FUNDS

CODE	OPERATIONS – SERVICES – PRODUCTS
201	Assessments and pensions
202	Funeral and disability
203	Loans

PRIVATE PENSION SYSTEM

77	Affiliation to the private pension system
78	Disaffiliation from the private pension system
79	Transfers between pension fund administrators
80	Member contributions to the private pension fund
81	Recognition bond
82	Retirement regimes with State Guarantee – Complementary Bond for minimum pension
83	Retirement regimes with State Guarantee – Complementary Bond for early retirement due to work hazardous to life or health
85	Transfer of pension funds for SPP members residing abroad
86	Legal retirement
87	Early retirement
88	Early Retirement for Workers Performing Work Hazardous to Life or Health
89	Special early retirement regimes for unemployed persons (REJA) 27617
90	State-Guaranteed retirement regimes - Early retirement – D.L. No. 19990
92	Investment of the pension fund
95	Provide information to the public (non-client) about the private pension system
300	State-Guaranteed retirement regimes – Retirement of complementary minimum pension (PCPM)
301	State-Guaranteed retirement regimes – Retirement of complementary pension for Hazardous Work (PCLR)
302	Disability and pre-existing condition evaluation procedures in the SPP
303	Disability Pension
304	Survivor's Pension
305	Special early retirement regimes for unemployed persons (REJA) 28991
306	Special early retirement regimes for unemployed persons (REJA) 29426
307	Collection of Contributions
308	Inheritance
309	Refund of Contributions (DAO 29426)
310	Complementary Work Risk Insurance
311	Funeral Expenses

Los Laureles No. 214 - Lima 27 - Peru Tel.: (511) 6309000 Fax: (511) 6309239

312	Refund of Contributions (Circular 040-2004, Circular 125-2012, Circular 078-2006).

APPLICABLE TO SUPERVISED COMPANIES

96	Customer service (not related to the operations or products offered by the company)
999	Other operations, services and/or products (detail in Claim Report No. RR3)

(1) Each supervised company shall enter, as applicable, the codes of the claims related to the operations they are authorized to carry out.

(2) The code must be assigned based on the scope where the event giving rise to the claim occurs. In the event of concurrence of two or more applicable codes, companies must choose the most specific claim scope, preferring the service over the operation, and the latter over the product.

Annex No. III

CLAIM REASON CODES (1)

FINANCIAL SYSTEM, COMPLEMENTARY AND RELATED

CODE	OPERATIONS – SERVICES – PRODUCTS
06	Unprocessed / improperly executed transactions
08	Contract termination
09	Problems with checks (improperly issued, rejected, duplicated, forged).
10	Erroneous settlements
11	Improper closure of checking accounts for issuing checks without funds
13	Problems related to guarantees (among others: valuation, appraisal and enforcement)
14	Inadequate execution of guarantees granted by the entity (letters of guarantee and others)
15	Problems presented with the credit or debit card (retained, not issued, not delivered on time, deactivated, blocked, cancelled, suspended, canceled)
17	Breach of banking secrecy
18	Unrecognized transactions (consumptions, withdrawals, cash withdrawals, charges, credits and overdrafts, as applicable)
19	Delays or breaches in sending correspondence (account statements, others)
22	Improper report in the credit bureau
23	Delay in rectifying the information reported in the credit bureau
24	Errors in the purchase-sale of foreign currency and application of exchange rate
25	Problems related to enrollment in PREDA and other state programs
27	Delay or breach in the return of valued documents / securities
28	Problems related to ATMs owned or operated by the company (did not dispense cash or voucher, card retention)
29	Delivery of counterfeit bills
31	Deficiencies in the transport and/or custody of cash
32	Disagreement with the settlement of debts sold to related companies or collection companies
33	Dissemination of information without the user's authorization
35	Problems related to loyalty programs
38	Problems related to ATMs of other companies (did not dispense cash or voucher, card retention)
103	Technical deficiencies in ATMs
104	Problems related to correspondent ATMs
105	Problems related to the company's website
106	Problems related to early payment of the credit

INSURANCE SYSTEM

CODE	OPERATIONS – SERVICES – PRODUCTS
12	Contracting or improper charge of insurance.
36	Inadequate or insufficient information about the contracted insurance
40	Not in accordance with the conditions of the insurance policy (among others: premium amount, deductible, franchise or endorsements)
41	Not in accordance with the amount of compensation, damage assessment, repair or

Los Laureles Nº 214 - Lima 27 - Peru Tel.: (511) 6309000 Fax: (511) 6309239

	accessories
43	Not in accordance with the medical diagnosis (internal auditor of the insurance company)
44	Delay in payment of compensation
45	Delay in the reimbursement of expenses
46	Did not receive the policy, insurance certificate, endorsement or provisional coverage
47	Improper renewal of insurance policy
48	Improper cancellation of the insurance policy
49	Errors in the collection of premiums
51	Breach in the resolution of the insurance policy
62	Rejection in the handling of the claim
65	Breach of the deadline for handling the coverage request
200	Problems and/or delays in the granting and payment of pension by the insurer.

AFOCAT

CODE	REASON
201	Not in agreement with the amount of the indemnity
202	Delay in the payment of the indemnity
203	Delay in the reimbursement of medical or funeral expenses
204	Errors in the collection of contributions
205	Rejection in the handling of the claim

SPILLAGES AND PROFIT BOXES

CODE	REASON
206	Not in agreement with the amount of the indemnity
207	Delay in the payment of the benefit
208	Rejection of the benefit request
209	Rejection of the request for return of contributions
210	Delay in the payment of the indemnity
211	Not in agreement with the interest charged
212	Delay in the delivery of the loan
213	Rejection of the loan request

PRIVATE PENSION SYSTEM (SPP)

67	Delay in handling the request for annulment of affiliation
68	Delay in handling the request for disaffiliation
69	Delay in handling the transfer request
70	Problems related to the payment and crediting of contributions of dependent worker in the Individual Capitalization Account
71	Problems related to the payment and crediting of contributions of independent worker in the Individual Capitalization Account
72	Problems related to the management of contribution collection
73	Problems related to the transfer of funds from the SPP abroad
74	Problems related to delays in the procedure related to the recognition bond
75	Lack of information regarding the recognition bond
76	Other problems related to the recognition bond

Los Laureles No. 214 - Lima 27 - Peru Tel.: (511) 6309000 Fax: (511) 6309239

77	Disagreement with the ONP's ruling related to the recognition bond and Regimes with State Guarantee
78	Delay by the AFP in the processing of appeals filed in relation to the recognition bond and access to Regimes with State Guarantee.
79	Problems related to multiple affiliation
80	Problems and/or delay related to the calculation and amount of pension or Additional Contribution
81	Problems and/or delay in the granting and payment of pension or Additional Contribution
82	Problems and/or delay related to the granting and reimbursement of funeral expenses
83	Problems related to the actions of the COMAFP or the COMEC
84	Delay in notifying the member of the COMAFP or COMEC ruling
85	Problems related to the pension surplus
86	Problems with the AFP in cases of complaints against sales agents
87	Disagreement with the profitability of the pension funds
89	Problems related to accreditation
90	Problems related to payment by default or excess
91	Problems related to the process of joining the SPP and/or execution of the affiliation contract other than those indicated in other numerals
92	Problems related to transfers – SPP, other than those indicated in numeral 69
93	Problems related to arrears and cross-credits
94	Problems related to the information included in the member's account statement
95	Delay or failure to send the member's account statements
96	Problems related to voluntary contributions with a pension purpose and without a pension purpose
97	Problems related to the processing and payment of claims when there is a probable SCTR.
98	Problems related to the refund of member contributions
99	Disagreement with the suspension of pension due to exhaustion of the CIC, non-redemption of the recognition bond, lack of disability ruling, end of the preliminary pension period.
100	Problems affecting pension beneficiaries
101	Disagreement with the pension received and/or with the conditions already defined in the retirement process
102	Disagreement with the rejection of the retirement application for not meeting the established requirements
300	Inclusion or Exclusion of beneficiaries
301	Delay in payment of Inheritance
302	Disagreement with the pension modality
303	Failure to issue proof of service
304	Withdrawal from the initiated pension procedure
305	Disagreement with the pension received and/or with the conditions already defined in the disability process
306	Disagreement with the pension received and/or with the conditions already defined in the survivorship process
307	Problems with the annual pension recalculation due to programmed withdrawal or Temporary Income
308	Exhaustion of the CIC in the Temporary Income stage
309	Problems with the notification about the possibility of requesting a pension Repacto and its execution.
310	Delay or non-compliance in sending other correspondence
311	Problems related to the payment of the pension under the collection modality, previously requested by the member (check, over-the-counter payment, bank account deposit,

Los Laureles No. 214 - Lima 27 - Peru Tel.: (511) 6309000 Fax: (511) 6309239

	others)
312	Disagreement with the suspension of pension due to lack of proof of survival
313	Rejection of pension coverage due to presumed SCTR coverage
314	Failure to address the communication submitted by the claimant by the AFP
315	Problems related to the pension Surplus

APPLICABLE TO SUPERVISED COMPANIES

01	Breach of clauses of contracts, policies, conditions, agreements
02	Inadequate or insufficient information about operations, products and services
03	Improper charges of interest, commissions, expenses and taxes (such as insurance, ITF, among other charges, as applicable)
04	Improper modification of interest rates, commissions, or other agreed conditions
07	Improper withholdings (includes judicial or coercive collection withholdings)
20	Disagreement with notifications addressed to third parties
21	Misleading advertising or information that induces error
30	Computer system failures that hinder operations and services.
34	Error in the user data registered in the company
39	Inadequate user service - Problems in service quality
999	Other reasons (detail in Claim Report No. RR3)

[1] Each supervised company shall record, as applicable, the codes of the claim reasons related to the operations they are authorized to perform.