Circular G-184-2015: User Service Circular

Lima, 30 September 2015
CIRCULAR No. G – 184 – 2015

-------------------------------------------------------- Ref.: User Service Circular --------------------------------------------------------

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 provisions, hereinafter the General Law, and by subsection d) of article 57 of the Single Ordered Text of the Law of the Private Pension Fund Management System approved by Supreme Decree No. 054-97-EF and its amending provisions, the Superintendency issues the User Service Circular; and, having complied with the pre-publication of regulations provided in Supreme Decree No. 001-2009-JUS, orders the publication of the circular:

1. Scope1

The provisions of the circular are applicable to the companies indicated in literals A, B and D of article 16, and in article 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 Private Pension Fund Management Companies (AFP), hereinafter the companies.

2. Definitions

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

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

b) Days: calendar days.

c) PAU: User Service Platform of the Superintendency.

d) 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 provisions and/or the Regulation of Transparency of Information and Contracting of Insurance, approved by SBS Resolution No. 3199-2013.

e) Superintendency: Superintendency of Banking, Insurance and Private Pension Fund Management Companies.

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

3. System of Attention to Requests

3.1 Requests are the communications made by users or by third parties on behalf of users, by which an action by the company is sought. For purposes of the provisions of the circular, requests comprise the attention of:

[1] Numeral amended by SBS Resolution No. 3966-2018 of 11/10/2018

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a) Inquiries; understood as those communications by which the company is sought to provide certain information in the face of a situation of uncertainty, lack of knowledge or doubt related to the operation, product or service offered or contracted with the company.

b) Requests for delivery or making available of information that the company possesses about the relationship that users maintain with the company.

c) Other requests different from those indicated in literal b), provided that they are not within the cases indicated in numeral 3.2.

3.2 The following cannot be considered or registered as requests:

a) Aspects related to the attention of claims.

b) Aspects inherent to the execution of contracts (such as account operations, claim coverage, pension payments, among others), to the modification of contracts and to the exercise of the right to terminate contracts.

c) The contracting of new products and/or services.

3.3 Companies must have manuals for the attention of requests that establish, at least, the following:

a) The channels made available to users or third parties on their behalf, for their submission.

b) The procedure, attention periods and channels established to respond to requests considering the provisions of numeral 4.2.

c) The types of request that can be attended at the moment they are made.

d) The procedure for filing documentation and those responsible for its conservation.

4. Procedure for the submission, registration and response to requests

4.1 At the moment of submission of the request, companies must require users to indicate the channel for receiving the response, considering the channels indicated in numeral 4.2 and must keep a record that allows accrediting the choice made. For this purpose, previously, they must inform users of the channels established to respond to their requests so that they may choose the applicable channel.

4.2 Companies must consider at least the address or email registered by the user, for those cases in which the client requests the response in writing; without prejudice to the fact that they may establish other channels provided that they allow leaving a record of the making available or delivery of the response to the user.

In those cases in which the user requests a response in writing, but does not refer to the channel to which the response must be given, the company may send the response to the domiciliary address or to the email registered by the user, indistinctly.

4.3 In the event that the request is submitted by a third party on behalf of the user, companies must adopt the corresponding measures to corroborate that the request is submitted on behalf of the user.

4.4 A record of requests must be kept, assigning an internal tracking code and considering the information indicated in numeral 10 of the circular. Those requests that are attended at the moment they are made do not require the aforementioned registration, unless at

present the request, the user requests a written response in the form established in numeral 4.2.

4.5 For the handling of requests, companies must have personnel trained and specialized in user service, in accordance with the provisions established by the current regulatory framework. Such personnel must identify themselves to users with their names and surnames.

4.6 For the handling of requests, the AFPs must apply the provisions of the Compendium of Superintendency Regulations of the SPP and other regulations issued by the Superintendency applicable to the SPP, regarding their service.

5. Claims Service System

5.1 Claims are communications submitted by users or by third parties on behalf of users, expressing their dissatisfaction with the operation, product or service received or for the breach of obligations contemplated in the contracts or current regulatory framework, or manifesting the alleged impairment of their legitimate interest. Additionally, any reiteration arising as a consequence of the user's disagreement with the response issued by the company, or due to the delay or lack of handling of a claim or a request, is considered a claim.

5.2 Companies must have manuals for the handling of claims that establish, at least, the following:

a) The channels made available to users or third parties on their behalf, for their submission, considering the provisions of numeral 5.3.

b) The procedure for their registration, follow-up and handling, including the submission requirements, internal handling deadlines and interaction with other areas.

c) The procedure for filing documentation and those responsible for its preservation.

d) The identification of claims that, due to their characteristics, will always be resolved in favor of the user without requiring analysis of the particular case, additional aspects indicated in the circular.

e) Others at the discretion of the companies.

5.3 Companies must make available to users, at least, the following claim reception channels: a) network of public service offices; b) by telephone at the number designated for the reception of claims; c) electronically at the email address 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.

5.4 Companies must have a backup system for the claim handling system, which may be physical or virtual, for those cases in which the system originally established by the company for the handling of claims cannot be used.

5.5 All claims submitted by users must be recorded in a computer support that allows adequate follow-up of the service provided, regardless of the channel or means used for their submission. Such record must allow the generation of detailed reports, identifying all aspects related to the claim. Additionally, the date on which each claim was handled must be recorded in the computer support of the claim handling system.

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

5.6 For the handling of claims, companies must have personnel trained and specialized in user service, in accordance with the provisions established by the current regulatory framework. Such personnel must identify themselves with their names and surnames.

5.7 In the case of companies in the financial system, the claim 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 transactions related to such events.

6. Claims Service Area

6.1 Companies must have an area responsible for the handling of claims, which must have adequate human, material and technical resources for the fulfillment of its functions. Companies must adopt the necessary actions so that personnel have knowledge and command of the applicable regulations, policies, procedures and internal user service deadlines established by the company.

6.2 For this purpose, companies must designate a person responsible for the claims service area. Its designation must be reported to the Superintendency within fifteen (15) days following the start of the exercise of its functions, attaching updated information regarding the organization, infrastructure and policies established for the operation of the area responsible for the handling of claims, 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 holder. Its designation will be brought to the attention of the Superintendency, considering -for such purpose- the deadline indicated in the preceding paragraph.

6.3 Any substantive modification regarding the information indicated in point 6.2 must be communicated to the Superintendency within fifteen (15) days of having been made.

6.4 Companies, in order to comply with the provisions of numerals 6.2 and 6.3, must send the information to the Superintendency, both in writing and by electronic means to the address transparencia@sbs.gob.pe.

6.5 The Superintendency may exceptionally permit those companies that, due to their volume of claims and size, do not require a claims service area, to entrust the duties of said specialized area to another area or officer of the company that can fulfill the purpose of the claims service system, in accordance with the current regulatory framework. Companies may request authorization from the Superintendency for the application of 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 the AFP.

The AFOCAT, due to their size and volume of operations, may entrust the duties of the claims service area to another area or officer that they designate, without requiring prior authorization from the Superintendency. Without prejudice to the foregoing, they must submit the information referred to in numerals 6.2 and 6.3, as applicable.

7. Officer Responsible for the Claims Service Area

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

7.1 The officer responsible for the claims service area is in charge of:

a) Ensuring the implementation and compliance of the company's policies and procedures related to claims service.

b) Preparing the management reports referred to in numeral 13, as well as ensuring compliance with the circular.

c) Handling the requests made by the Superintendency, in order to respond to the complaints filed by the users of the companies or to the requests made by third parties before the Superintendency.

d) Coordinating permanently with the user service officer on the aspects regulated in the circular, in the case of companies included in the scope of application of the Transparency Regulation applicable to companies of the financial system or the insurance system.

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

8.1 Users have the right to submit claims through the channels referred to in numeral 5.3 of the circular. The network of public 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.

8.2 In those cases in which the claim is submitted by a third party, the companies must adopt the corresponding measures to corroborate that the claim is submitted on behalf of the user.

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

a) Register the user's personal data and, in accordance with what is indicated by the user, register the home or electronic address to which the response to the claim must be given. Additionally, the company and the user may agree that the response be delivered at a public service office of the company, provided that the company considers said response mechanism. The parties may agree on a specific response mechanism for claims resolved in favor of users, provided that said agreement can be reliably proven.

If no reference is made to the applicable means for giving the response to the claim, the company shall send the response to the home address or email address registered by the user.

b) Prepare a report on the submission of the claim that includes, 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) derramas and cajas de beneficios or v) SPP, respectively. This report shall be delivered to the user as proof of the submission of the claim, if it is made at a public service office.

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

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

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

b.2) Agree with the user on the manner in which the proof will be delivered, through a public 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 public service offices of the companies; otherwise, on the following 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 through which the user can access the information detailed in Annex No. 1 – A, B, C, D or E of the 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.

8.4 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.

8.5 Companies must substantiate the handling of all their claims, and said substantiation must be kept available to the Superintendency. If it is established, as part of the application of the companies' internal policies, that certain types of claims will be declared in favor of the customer, the manuals that set out these policies may be considered as support.

8.6 In the case of claims resolved in favor of the companies, they must base their decisions on the response communication to the user, attaching, where applicable, a copy of the corresponding supporting document. Likewise, in said communication, the various instances to which the claimant may resort must be expressly mentioned, if they do not agree with the result of the decision, such as the National Institute for the Defense of Competition and the Protection of Intellectual Property; the Superintendency, in the case of claims regarding aspects related to the SPP; and the National Health Superintendency, in the case of claims regarding aspects related to health risk coverage; as applicable.

8.7 For the application of the circular, a claim is understood to have been resolved in favor of the user when all of its aspects have been addressed in favor of the user, with no controversy remaining regarding the facts set out in the claim.

9. Calculation of time limits and notification

Aspects related to the calculation of time limits

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

9.1 Requests - with the exception of those cases in which general rules establish maximum time limits for their handling - must be resolved within a period no greater than thirty (30) days from their submission.

Claims must be resolved within a period no greater than thirty (30) days from their submission, with the exception of claims submitted against the AFP and the microinsurance product, which are governed by the rules on the matter.

9.2 The companies must comply with communicating the response to claims and requests within the time limits established in numeral 9.1 above. Such time limits may be extended, exceptionally, provided that the nature of the claim or request justifies it. In these cases, the support for the extension of the time limit must be available to the Superintendency. Said extension must be communicated to the user within the aforementioned time limit, explaining the reasons for the delay, in addition to specifying the estimated response time limit.

The exceptional extension of the time limit is not applicable in those cases in which maximum time limits for their handling are established by regulation.

9.3 The calculation of the time limit for the handling of claims and requests begins from the date of their submission to the companies, until the date of notification or making available of the response by the company, through the established channel. The company must have the corresponding support for the notification or making available.

Notification or making available of the response to claims

9.4 The notification of the response to the claim must be communicated in writing, to the home or electronic address, as indicated by the user. The user may request that the response to the claim be available at a customer service office of the company, for which record must be left of the choice of this response mechanism. For the notification, the following must be complied with:

a) In the case of notifications to the home address, these must be supported 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 address who can receive said document, the notification must be left under the door, leaving 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 email, it will be considered validly made with the proof of sending of the response to the claim addressed to the email address provided by the user.

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

9.5 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 9.4, provided that it allows record of the notification to be left. In claims resolved in favor of the user that involve the return or delivery of a sum of money, the calculation of the time limit is understood to end on the date on which the user is in a position to know the measure adopted in their favor, through the means agreed in accordance with numeral 8.3 a), and the company must keep the corresponding support. Said information must be available to the Superintendency, when so required.

10. Archiving of documentation

10.1 The companies must implement mechanisms that allow the proper archiving of claim and request files, which must contain the documentation that supports the handling and follow-up provided in each particular case, with the exception of claims that have been declared in favor of the customer as a consequence of the application of internal policies; and of requests handled at the time they are made. The aforementioned documentation must be available to the Superintendency, when so required.

10.2 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 the conservation and substitution of archives.

11. Information to the user

11.1 Companies must keep available to users, on their website and in all their establishments open to the public, in a visible and easily accessible place, posters and/or brochures with information on:

a) The procedures for handling requests and claims: the requirements for their processing, the maximum handling periods and the channels made available to users for their corresponding submission.

b) The mechanisms available to users for receiving/providing the response to the claim or request submitted.

11.2 Companies must keep available to the public informative material provided by the Superintendency regarding the work it carries out, for the purpose of informing about its powers in handling requests, claims or complaints related to the products and/or services that the companies provide.

12. Management indicators

Companies must establish management indicators that constitute control mechanisms for the proper management of the user service system, for the handling of requests and claims. These indicators must be available to the Superintendency when it so requires.

The Superintendency may specify those minimum indicators and parameters related to the aspects set forth 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.

13. Management reports

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

13.1 The person 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, f) the management indicators established in numeral 12, and g) others specified by the Superintendency through a multiple official letter.

In the case of requests, quarterly reports must be prepared considering the minimum aspects detailed in the preceding paragraph, as applicable, in accordance with what is established by the Superintendency through a multiple official letter.

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.

13.2 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 supervisory and control body.

14. Dissemination of claims information through the website

Each company must disseminate, through its website, in the portal or specific area where 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, most frequently, are 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 handling time and the total number of operations of the company in the last quarter, considering 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 8.5 of the circular, if applicable.

15. Communication of Statistics

15.1 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. Said 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.

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

15.2 The aforementioned statistics must be submitted 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; these may be updated by the Superintendency by means of a multiple official letter.

15.3 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.pe2 .

16. Training

The companies must prepare an annual training plan for the personnel in charge of handling claims and/or requests, which includes aspects related to the regulatory framework applicable to said 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.

For those companies included within the scope of the Transparency Regulation, it shall be understood that the obligation to prepare the annual training plan for personnel has been complied with when said plan has been included in the Annual Work Program of the User Service Officer.

Without prejudice to the foregoing, in the event that modifications occur 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 requests must be informed about said modifications.

The documentation supporting compliance with the provisions of this paragraph must be available to the Superintendency3 .

17. Resolution of queries in a group or guild form4

Companies may organize themselves in a group or guild manner to resolve and handle user queries, provided that there is no doubt regarding the identity and responsibility corresponding to the company receiving the query. In this case, the Superintendency must be informed within a period no greater than fifteen (15) days from having decided the implementation of said system. The companies must inform within said period about the established service procedures, as well as their organization and functions manuals.

The foregoing does not eliminate compliance with the applicable provisions on outsourcing set forth in the Regulation of Integral Risk Management.

18. Annexes

[2] Errata in El Peruano dated 7/10/2015.

[3] Errata in El Peruano dated 7/10/2015.

[4] Errata in El Peruano dated 7/10/2015.

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

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.

19. Multiple Official Letter

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

20. Final provisions

Communications made by users that do not conform to the categories of requests and claims in accordance with the provisions of this circular must be classified according to the qualification established internally for such purpose by the companies, which must be available to the Superintendency.

21. Effective date

The circular enters into force on 1 January 2016, with the exception of paragraphs 5 and 8, which enter into force on the day following the publication of the circular.

On the day following the publication of the circular, Circular No. G-176-2014 and its amending rules are rendered ineffective.

The Superintendency, by multiple official letter, determines the manner in which the information generated in the last two quarters of 2015 is submitted, which corresponds to reports 24, 24-A and 24-B of the User Service Circular, Circular No. G-146-2009 and its amending rules5 .

The provisions set forth do 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.

Sincerely.

SERGIO ESPINOSA CHIROQUE
Superintendent of Banking, Insurance and
Private Pension Fund Administrators (a.i.)

[5] Errata in El Peruano dated 7/10/2015.

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

SUPERINTENDENCY
OF BANKING, INSURANCE AND AFP
Republic of Peru

Annex No. 1 - D

Claim service form
Derramas and Benefit Funds

Claim number
Claim date

Personal Data:

Paternal surname Maternal surname Names

Corporate name / business name Name of father or mother or guardian (minor)

Identity document DNI foreigner's card Passport RUC No.

Address: Street/ Ave. /Jr. No./MZ Lot Int/Apt Urb. District Province Department

Landline telephone Mobile Email

Claim channel: In person Telephone Email Letter Other:

Operations/services/products:

Derramas and pensions Others
Funeral and disability
Loans

Reasons:

Not in agreement with the amount of the indemnity Others Delay in payment of the benefit Rejection of the benefit request Rejection of the request for return of contributions Delay in payment of the indemnity Not in agreement with the interest charged Delay in the delivery of the loan

Amount claimed:

Documents attached: 1
2
3
4
5

Claim details:

Estimated time to resolve:

Client's signature Signature of the claim recipient Name

The response to the claim will be communicated as established by the User Service Circular

Los Laureles N° 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 - Peru Tel. : (511) 6309000 Fax: (511) 6309239

[1] This report shall include all claims received during the quarter subject to reporting, through the reception channels made available by the company directly or in association with the guild, with the exception of those applicable to the private pension system, as well as the current status of claims reported as "in process" in the quarter prior to the reporting quarter. If the attention and resolution of a claim is carried out within a fraction of one (1) day, it shall be counted as a one (1) day attention period.6

[2] Enter the company code assigned by the SBS

[3] Enter the code according to the attached Table of Channels (Annex No. I)

[4] Indicate the corresponding code according to the attached Table of Codes of Operations, Services or Products (Annex No. II). Claims must be presented in ascending order as they appear in the aforementioned table.

[5] Enter according to the attached Table of Claim Reasons (Annex No. IIII). Claim reasons must be grouped according to the operation, service or product code entered in the previous column and in ascending order according to Annex No. II.

[6] Indicate the corresponding code according to the Geographic Location Code provided by INEI according to where the claim was presented. Geographic areas must be grouped in ascending order according to the operation, service or product code and the claim reason. The level of precision is department and province. For example, if you wish to indicate the department and province of Lima, you must indicate code 1501. For claims presented from abroad, register code 9999. If the claim is presented through channels with code 03, 04, 05 of Annex No. I, and as long as it is not possible to identify the geographic location, no code is entered. 7

[7] Indicate "1" to report the statistics of claims presented for the first time and "2" to report the statistics corresponding to reconsiderations, maintaining the respective code and reason.

[6] Numeral modified by SBS Resolution No. 3966-2018 of 11/10/2018, applicable as of the submission of statistics corresponding to the fourth quarter of 2018

[7] Numeral modified by SBS Resolution No. 652-2016, published on 9.2.2016 and in force from the day following its publication.

8) Indicate the number of claims in process, specifying the time elapsed since their presentation. For this purpose, the periods shall be counted from the receipt of the claim by the company until the last day of the quarter subject
to the report.
9) A claim is considered resolved when the company has sent the user its final position. Indicate the number of resolved claims according to the periods taken for their conclusion, disaggregating between those
resolved in favor of the company or in favor of the user. The calculation of the period must be made from the receipt of the claim by the company (FI) until the receipt by the user of the final response (FF). For the calculation of the duration, consider FF-FI and when FI=FF consider one (1) day, since zero (0) days is not admitted.
10) The average time for resolving claims is obtained by dividing the sum of days taken to resolve a given set of claims corresponding to the same operation, service or product code and
the same claim reason, by the number of claims that originate said sum.
11) It is equal to the sum of claims in process plus those resolved minus the claims in process from the previous quarter.
12) It corresponds to the sum of the resolution time of each claim resolved in the period divided by the total number of claims resolved during the same period.
13) It corresponds to the monetary operations of the quarter for the financial system and for the insurance system; they are the sum of all policies contracted in the quarter and the coverage requests presented in
said quarter (accepted or rejected).

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

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

6) Indicate the corresponding code according to the Geographic Location Code provided by INEI according to where the claim was presented. Geographic areas must be grouped in ascending order according to the operation, service or product code and the claim reason. The level of precision is department and province. For example, if you wish to indicate the department and province of Lima, you must indicate code 1501. For claims presented from abroad, register code 9999. If the claim is presented through channels with code 03, 04, 05 of Annex No. I, and as long as it is not possible to identify the geographic location, no code is entered.

[8] 8 Numeral modified by SBS Resolution No. 652-2016, published on 9.2.2016 and in force from the day following its publication.

SUPERINTENDENCY OF BANKING, INSURANCE AND AFP Republic of Peru

Claim Report No. RR3

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

From:
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Company:
Code:

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

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General Manager
Responsible Officer

1) In this report, all codes 999 recorded in claim reports No. RR1 or RR2, as applicable, 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 Claim Reasons (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 “Coded” 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 coded 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 “Coded” 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 uncoded claim reasons must be detailed. Likewise, in the “Channel” column, the code of the channel in which the claim was recorded must be indicated.

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.

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

ANNEXES TO CLAIM REPORTS No. RR1 - RR2 - RR3

Annex No. I

CHANNEL CODES9

CODE	CHANNELS
01	Office
02	ATM
03	Internet
04	Mobile banking10
05	Telephone
06	Correspondent tellers
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

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

[10] 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

OPERATION, SERVICE OR PRODUCT CODES (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 (currency exchange, collections, judicial payments, payroll payments, among other similar ones) other than those indicated in codes 27 and 28.
97	Credits to small businesses and microenterprises
101	Drafts
102	Savings account for the deposit of remuneration
103	Banking – Insurance (insurance sold through the channels of the financial system)
104	Electronic money

INSURANCE SYSTEM

CODE	OPERATIONS – SERVICES – PRODUCTS
31	Fire
32	Allied fire lines
33	Earthquake
34	Glass

Republic of Peru

SUPERINTENDENCY OF BANKING, INSURANCE AND AFP

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

35	Loss of profit
36	Loss of profit machinery breakdown
37	Transport
38	Marine hull
39	Aviation
40	Vehicles
41	Allied vehicle lines
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	Domiciliary
54	Civil liability
55	Guarantees (bonds)
57	Export credit
58	Multi-insurance
59	Agricultural
60	Miscellaneous
61	Personal accidents
62	School
63	Medical assistance
64	SOAT
65	Individual life
66	Group life particular
67	Life Law workers
68	Mortgage redemption
69	Funeral
70	Particular annuity (life)
71	Retirees' annuity
72	Complementary risk work insurance
73	Pensions of the complementary risk work insurance
74	Pension insurance – Disability
75	Pension insurance – survival
76	Pension insurance – funeral expenses
99	Microinsurance
200	Card protection insurance (credit or debit)

AFOCAT

CODE	OPERATIONS – SERVICES – PRODUCTS
100	CAT

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

ASSESSMENTS AND BENEFIT FUNDS

CODE	OPERATIONS – SERVICES – PRODUCTS
201	Assessments and pensions
202	Burial and invalidity
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	Contributions of the affiliate to the private pension fund
81	Recognition bond
82	Retirement regimes with State Guarantee – Complementary Minimum Pension Bond
83	Retirement regimes with State Guarantee – Complementary Early Retirement Bond for work that poses a risk to life or health
85	Transfer of pension funds for SPP affiliates residing abroad
86	Legal retirement
87	Early retirement
88	Early Retirement for Workers Performing Work that Poses a Risk to Life or Health
89	Special early retirement regimes for unemployed persons (REJA) 27617
90	Retirement regimes with State Guarantee - 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	Retirement regimes with State Guarantee – Retirement of Complementary Minimum Pension (PCPM)
301	Retirement regimes with State Guarantee – Retirement of Complementary Pension for Risk 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	Burial Expenses
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)

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

999	Other operations, services and/or products (detail in Claim Report No. RR3)

(1) Each supervised company shall record, as applicable, the codes of claims related to the operations it is authorized to carry out.

(2) The code shall be assigned based on the area 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 area, preferring the service over the operation, and the operation 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 enforcement of guarantees granted by the entity (letters of guarantee and others)
15	Problems presented with credit or debit card (retained, not issued, not delivered on time, deactivated, blocked, cancelled, suspended, canceled)
17	Breach of banking secrecy
18	Unrecognized operations (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 user 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 repayment of the loan

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 agreement with the conditions of the insurance policy (among others: premium amount, deductible, excess or endorsements)

Republic of Peru

SUPERINTENDENCY OF BANKING, INSURANCE AND AFP

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

41	Not in agreement with the amount of the indemnity, damage assessment, repair or accessories
43	Not in agreement with the medical diagnosis (internal auditor of the insurance company)
44	Delay in the payment of the indemnity
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	Non-compliance in the resolution of the insurance policy
62	Rejection in the handling of the claim
65	Non-compliance with 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

DISTRIBUTIONS AND BENEFIT FUNDS

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

PRIVATE PENSION SYSTEM (SPP)

67	Delay in handling the application for annulment of affiliation
68	Delay in handling the application for disaffiliation
69	Delay in handling the transfer application
70	Problems related to the payment and crediting of contributions of a dependent worker in the Individual Capitalization Account
71	Problems related to the payment and crediting of contributions of a self-employed worker in the Individual Capitalization Account
72	Problems related to the management of contribution collection
73	Problems related to the transfer of SPP funds abroad
74	Problems related to the delay in the procedure related to the recognition bond
75	Lack of information regarding the recognition bond

SUPERINTENDENCE OF BANKING, INSURANCE AND AFP Republic of Peru

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

76	Other problems related to the recognition bond
77	Disagreement with the ONP's ruling related to the recognition bond and Regimes with State Guarantee
78	Delay of 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 pension funds
89	Problems related to accreditation
90	Problems related to default or excess payment
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 delays 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 pension purpose and without 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 pension procedure initiated
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 survival process
307	Problems with the annual pension recalculation for 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 failure to send other correspondence

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

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, 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 complainant by the AFP
315	Problems related to the pension surplus

APPLICABLE TO SUPERVISED COMPANIES

01	Breach of contract clauses, policies, conditions, agreements
02	Inadequate or insufficient information about transactions, 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 transactions and services.
34	Error in the user data registered with the company
39	Inadequate user service - Problems with service quality
999	Other reasons (specify in Claim Report No. RR3)

[1] Each supervised company shall record, as applicable, the codes of the claim reasons related to the transactions it is authorized to carry out.