Circular LISOL 1-1047 OPRAC 1-1233 REMON 1-1110: Minimum Cash, MiPyME Productive Investment Financing Line, Minimum Provisions for Uncollectible Risk, Adjustments

"AÑO DE LA DEFENSA DE LA VIDA, LA LIBERTAD Y LA PROPIEDAD" COMUNICACIÓN “A” 7983 21/03/2024 TO FINANCIAL ENTITIES:
Ref.: Circular
LISOL 1-1047,
OPRAC 1-1233,
REMON 1-1110:
Minimum cash. Financing line for the productive investment of MiPyME. Minimum provisions for uncollectible risk. Adjustments.
___________________________________________________________________________ We address you to inform you that this Institution adopted the resolution that, in its pertinent part, establishes:

“1. Incorporate, effective from 1.4.24, as Section 6. in the regulations on “Minimum Cash” the following:

“Section 6. Minimum MiPyME Quota.

6.1. Covered Entities.
The financial entities included in the list of Annex II of Communication “A” 7859.

6.2. Minimum Quota.
The covered entities, from 1.4.24, for the purpose of complying with this quota, must maintain a quarterly average of daily balances (April-June; July-September; October-December and January-March of the following year) of included financings that is, at minimum, equivalent to 7.5% of the entity’s private non-financial peso deposits subject to fractional reserve requirements –excluding the deposits provided for in points 3.13. and 3.14. of the regulations on “Savings, salary account and special deposits”–, calculated based on the monthly average of daily balances of the penultimate month prior (February, May, August and November, respectively).

In the case of entities included in Groups B and C –in accordance with what is provided in Section 4. of the regulations on “Authorities of financial entities”, for which the indicator in point 4.1. of those regulations must be computed, for all financial entities, solely on an individual basis–, the minimum percentage to be applied will be 25% of that previously established.

For these purposes, the current residual balances of financings imputed to: i) the quotas 2020, 2021, 2021/2022, 2022, 2022/2023, 2023 and 2023/2024 of the regulations on “Financing line for the productive investment of MiPyME”; ii) in points 7.2.1., 7.2.2. and 7.2.4. that have been disbursed by 15.10.2020 and iii) to the previous quarters of this quota are computable.

Furthermore, to comply with the Minimum MiPyME Quota, at least 30% of it must be allocated to what is provided for in point 6.4.1.

Covered entities that comply with this Minimum MiPyME Quota may compute the reduction in the minimum cash requirement in pesos provided for in point 1.5.1. during the following quarter.

6.3. Destination.
The included financings must be granted to MiPyME clients in accordance with the definition in force in the regulations on “Determination of the condition of micro, small or medium enterprise”.

The following are excluded from the computation of the Minimum MiPyME Quota:

6.3.1. From the destinations of points 6.4.1. and 6.4.2.: MiPyMEs with agricultural activity registered in the Simplified Agricultural Information System (SISA) as “Producer” with collection of wheat and/or soybean production, except that they are categorized as microenterprises –according to the definition of the former Secretariat of Small and Medium Enterprises and Entrepreneurship– and the value of that collection does not exceed 5% of their annual harvest capacity, estimated based on yields published by the Secretariat of Agriculture, Livestock and Fisheries (SAGyP) (declared surface in SISA by the average yield published by SAGyP for each crop). The financial entity will be responsible for verifying that the applicant is not included in this exclusion; and

6.3.2. From the destinations of point 6.4.2. and the pertinent part to this point contained in points 6.4.3.2. and 6.4.3.3.: financings agreed to MiPyMEs with agricultural activity registered in SISA as “Producer” of cereals and/or oilseeds, except that they are categorized as microenterprises –according to the definition of the former Secretariat of Small and Medium Enterprises and Entrepreneurship–.

For these purposes, the simple average of the daily balances of the current financings during the period from April-June, July-September, October-December and January-March of each year will be considered.

6.4. Eligible Financings.

6.4.1. Investment project financing.
Financing of investment projects intended for the acquisition of capital goods and/or for the construction of facilities necessary for the production of goods and/or services and the commercialization of goods and/or services.

In the case of utility vehicles, automobiles and aircraft, only those of national origin –according to the corresponding manufacturing certificate– that are directly and exclusively assigned to the applicant’s activity may be financed, a situation that must be recorded in the client’s file.

Financings agreed under other special credit regimes cannot be classified as eligible applications to the extent that the funds for such assistance are provided to the entity for that specific purpose or entail the character of contingent liabilities.

6.4.2. Working capital and discounting of deferred payment checks and other documents.
It may be allocated to the financing of working capital, to the discounting of deferred payment checks and purchase of Electronic Credit Invoices MiPyME, in the latter case accepted by companies that comply with what is provided in point 2.2.1. of the regulations on “Credit evaluations”, of clients who meet the condition of MiPyME.

The values to be discounted must come from the collection of sales operations and/or the provision of services corresponding to the activity of the discounting MiPyME. This condition may be verified through the sworn declaration made by the client and/or by any other means the entity deems sufficient.

6.4.3. Special.

6.4.3.1. Non-MiPyME clients, to the extent that the funds are destined for the acquisition of machinery and equipment produced by local MiPyMEs.

6.4.3.2. Financings to financial entities not covered by this section and/or to companies that provide financial assistance through financial leasing operations (“leasing”) –point 2.2.8. of the regulations on “Complementary services of the financial activity and other permitted activities”–, provided that they allocate the funds to granting the financings provided for in points 6.4.1. and/or 6.4.2., under the conditions established in this section.

Entities must apply the funds to the destinations provided for in this point within a period not exceeding 10 business days between the date they receive the assistance from the financial entity and its credit application to MiPyME.

6.4.3.3. Incorporation through assignment or discounting of the financings provided for in points 6.4.1. and/or 6.4.2. granted by financial entities.

In all cases, the financings must comply with the conditions established in this section and may only be computed by the acquiring financial entity, if applicable.

6.5. Terms and conditions of the financings.

6.5.1. Interest rate.
The rate freely agreed upon by the parties.

6.5.2. Currency and terms.
The financings of point 6.4.1. must be denominated in pesos and have –at the time of disbursement– an average term equal to or greater than 24 months, weighting for this purpose the capital maturities.

The operations of point 6.4.2. must also be in pesos and will have no minimum term.”

2. Replace, effective from 1.4.24, point 1.5.3. and the last paragraph of point 1.5. of the regulations on “Minimum Cash” with the following:

“1.5.3. Financings granted by financial entities covered by the Minimum MiPyME Quota.
The requirement will be reduced by an amount equivalent to 40% of the financings provided for in point 6.4.1. that are agreed to an average term equal to or greater than 36 months, weighting for this purpose the capital maturities, measured in monthly average of daily balances of the previous month.”

“The financings computed for the deduction of points 1.5.1. and 1.5.4. may only be computed in one of the cited points, and the financings of point 1.5.3. may also be computed for the deduction of point 1.5.1.”

3. Establish, effective from 1.4.24, that the provisions of point 1.5.3. of the regulations on “Minimum Cash” in force until 31.3.24, will continue to be computed as a reduction of the minimum cash requirement in pesos by 40% of the balances of the included financings disbursed by that date.

4. Replace, effective from 22.3.24, point 1.5.2.2. of the regulations on “Minimum Cash” with the following:

“1.5.2.2. For those financial entities adhering to the “SIMPLE QUOTA” Program –established by Resolution No. 7/24 of the Ministry of Economy and its complementary regulations– the requirement will be reduced by an amount equivalent to:

• 30% of the sums of the peso financings that the entity grants until 21.3.24.
• 15% of the sums of the peso financings that the entity grants from 22.3.24.
  To this effect, the balance of the covered financings from the period prior to the computation of the requirement that meet the stated requirements will be considered.”

5. Incorporate, effective from 1.7.24, as the first paragraph of point 1.5.1. in the regulations on “Minimum Cash” the following:

“From 1.7.24, the financial entities covered by Section 6. must have complied with the Minimum MiPyME Quota of the previous quarter to compute this reduction during each quarter.”

Regarding this, we send you the sheets that, in replacement of those previously provided, correspond to be incorporated into the regulations of reference. In this sense, it is recalled that on this Institution’s website www.bcra.gob.ar, accessing “Financial System - LEGAL AND REGULATORY FRAMEWORK - Orders and summaries - Ordered texts of general regulations”, the modifications made with texts highlighted in special characters (strikethrough and bold) will be found.

We salute you attentively.
CENTRAL BANK OF THE ARGENTINE REPUBLIC
María N. Prieto Mazzucco Enrique C. Martin
Deputy Manager of Monetary Regulation and Active Operations Manager of Issuance of Norms

ANNEX

-Index
Section 1. Requirement.
1.1. Included obligations.
1.2. Application base.
1.3. Minimum cash.
1.4. Residual term.
1.5. Reduction of the requirement in average in pesos.
1.6. Point increases of requirement by concentration of liabilities.
1.7. Transfers.
1.8. Defect of application of resources in foreign currency.
1.9. Increase of the requirement for non-compliance with the regulations on “Financing line for the productive investment of MiPyME”.
Section 2. Integration.
2.1. Admitted concepts.
2.2. Computation.
2.3. Minimum daily integration.
2.4. Remuneration of the balances of the peso accounts opened in the Central Bank.
2.5. Remuneration of the balances of the foreign currency accounts opened in the Central Bank.
Section 3. Non-compliance.
3.1. Charge.
3.2. Framing programs.
3.3. Regularization and sanitation plans.
Section 4. Base for observance of the regulations.
4.1. Individual base.
Section 5. Responsible parties and sanctions.
5.1. Responsible for liquidity policy.
5.2. Responsibilities.
5.3. Sanctions.
Section 6. Minimum MiPyME Quota.
Section 7. Transitional provisions.
Correlation table.
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ii) Without early cancellation clauses.
The time remaining until maturity will be taken into account to the extent that early cancellation is explicitly excluded by any of the parties. Otherwise, they will have the treatment of demand obligations.

1.4.2.Fixed-term deposits.
In the case of fixed-term deposits in pesos, the established rates –according to the term structure fixed– will be applied to the daily balances of the aforementioned obligations determined based on point 1.2.

In the case of fixed-term deposits in foreign currency, the established rates –according to the term structure fixed– will be applied to the amounts resulting from multiplying the total daily balance of those obligations –which is registered in the month to which it corresponds– by the percentages resulting from the residual term structure of the previous month, considering the number of days remaining in that period until the maturity of each obligation, counted from each of the days of said period.

1.4.3.Remaining term operations.
In these cases –including term investments and obligations with banks and correspondent banks abroad computable–, the residual terms will be equivalent to the number of days remaining until the maturity of each obligation, counted from each of the days of the period prior to which the minimum cash integration corresponds, when it comes to deposits in pesos, or of the same period if it comes to operations in foreign currency or securities.

The requirement will arise from applying the established rates to the daily balances of the aforementioned obligations based on the different residual term tranches fixed.

In the particular case of payment obligations in installments of capital, the amounts of the amortization services that mature within the year, counted from each of the days of the period prior to which the minimum cash in pesos corresponds or of the same period if it comes to obligations in foreign currency, will be considered independently for the purpose of applying to them the rate that is appropriate based on the number of days remaining until their maturity.

1.5. Reduction of the requirement in average in pesos.

1.5.1.By compliance with the Minimum MiPyME Quota and based on certain financings.
From 1.7.24, the financial entities covered by Section 6. must have complied with the Minimum MiPyME Quota of the previous quarter to compute this reduction during each quarter.

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The requirement will be reduced according to the participation in the total of financings to the private non-financial sector in pesos in the entity of the financings to micro, small and medium enterprises (MiPyMEs) in the same currency –according to the definition contained in the regulations on “Determination of the condition of micro, small or medium enterprise”– considering that framing at the time of granting, according to the following table:

Participation of financings to
MiPyMEs with respect to the total of financings to the private non-financial sector, in the entity.
In %
Deduction
(on the total of the concepts included in pesos).
In %
Less than 4 0.00
Between 4 and less than 6 1.00
Between 6 and less than 8 1.25
Between 8 and less than 10 1.50
Between 10 and less than 12 1.75
Between 12 and less than 14 2.00
Between 14 and less than 16 2.25
Between 16 and less than 18 2.50
Between 18 and less than 20 2.75
Between 20 and less than 22 3.00
Between 22 and less than 24 3.25
Between 24 and less than 26 3.50
26 or more 3.75

Financings to MiPyMEs include those instrumented through the purchase of Electronic Credit Invoices MiPyME accepted by companies that comply with what is provided in point 2.2.1. of the regulations on “Credit evaluations” from the month of May 2023, to clients who meet the condition of MiPyME.

For the purpose of computing the financings to MiPyMEs, to determine the percentage of participation, it will be taken into account if they meet that condition at the time of granting the assistance, considering all current financings. If the borrower ceases to meet the condition of MiPyMEs, the financings granted up to that moment will be computed.

The moving average balance will be considered at the end of the last 12 months prior to the low report of the financings in pesos (Loans and Credits by Financial Leasing) granted to MiPyMEs with respect to the total of those financings to the private non-financial sector of the entity.

1.5.2. Based on the granting of financings within the framework of the “NOW 12” and “SIMPLE QUOTA” Programs.

1.5.2.1. For those financial entities that are adhering to the “NOW 12” program the requirement will be reduced by an amount equivalent to:

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• 50% of the sum of the peso financings granted from 1.10.2020 and until 31.1.22, and
• 40% of the sums of the peso financings that they grant from 1.2.22.

In all cases:
a) As provided by the “NOW 12” Program referred to in Joint Resolution No. 671/14 and 267/14 of the former Ministry of Economy and Public Finances and of the former Ministry of Industry, respectively, whose destination is the acquisition of goods and services included in said resolution and its complementary regulations. To this effect, the balance of the covered financings from the period prior to the computation of the requirement that meet the stated requirements will be considered. b) To non-financial companies issuing credit cards at an interest rate of up to 17% nominal annual, to the extent that those companies have adhered to the “NOW 12” Program. To this effect, the financings of the period prior to the computation of the requirement, measured in monthly average of daily balances, will be considered. The financial entity must require and have documentation that accredits that the borrowing company has allocated the funds to granting financings under the conditions of the cited program.

1.5.2.2. For those financial entities adhering to the “SIMPLE QUOTA” Program –established by Resolution No. 7/24 of the Ministry of Economy and its complementary regulations– the requirement will be reduced by an amount equivalent to:

• 30% of the sums of the peso financings that the entity grants until 21.3.24.
• 15% of the sums of the peso financings that the entity grants from 22.3.24.
  To this effect, the balance of the covered financings from the period prior to the computation of the requirement that meet the stated requirements will be considered.

The deductions contained in this point may not exceed 8% of the concepts in pesos subject to requirement, on average, of the month prior to the computation.

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1.5.3.Financings granted by financial entities covered by the Minimum MiPyME Quota.
The requirement will be reduced by an amount equivalent to 40% of the financings provided for in point 6.4.1. that are agreed to an average term equal to or greater than 36 months, weighting for this purpose the capital maturities, measured in monthly average of daily balances of the previous month.

1.5.4.Special for financial entities that have implemented the remote and in-person opening of the “Free universal account (CGU)” provided for in point 3.11. of the regulations on “Savings, salary account and special deposits”. The requirement will be reduced by an amount equivalent to 50% of the peso financings granted from 1.3.24 to natural persons and MiPyME –according to the definition contained in the regulations on “Determination of the condition of micro, small or medium enterprise”– that have not been reported by financial entities in the “Central of debtors of the financial system” (CENDEU) in December 2023, provided that they have been agreed to a nominal annual interest rate that does not exceed, at that time, the maximum rate established in the first paragraph of point 2.1.1. of the regulations on “Interest rates in credit operations” –when it comes to entities of Groups “A”, “B” and branches or subsidiaries of G-SIB not included in those groups, and regardless of the amount of the financing– or the one in force according to point 2.1.2. of those regulations for the rest of the financial entities. The monthly average balance of the covered financings from the period prior to the integration of the requirement will be considered. This deduction may not exceed 3% of the concepts in pesos subject to requirement, on average, of the month prior to the integration. From September and March of each year, entities must consider as the base month for these purposes the information contained in the “Central of debtors of the financial system” from the previous June and December, respectively. 100% of the residual balances of the peso financings granted until 29.2.24, will continue to be computed as a reduction of the minimum cash requirement in pesos until their maturity, proceeding in the same way –applying the proportion that corresponds to impute– in each change of base month.

1.5.5.Based on cash withdrawals made through the entity’s ATMs:
The requirement will be reduced by the amount resulting from the following expression without being able to exceed the amount of the previously determined requirement, considering what is provided in the preceding point:

where:

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Msi: monthly average of the total daily cash withdrawals from ATMs, corresponding to the previous month, located in the entity's operational branches, according to the jurisdiction in which they are domiciled, as established in the regulations on "Categorization of localities for financial entities".

Mni: monthly average of the total daily cash withdrawals from ATMs, corresponding to the previous month, outside its operational branches (neutral) and according to the jurisdiction in which they are domiciled, in accordance with the aforementioned categories.

Psi: weight applicable to the Msi amount.
Pni: weight applicable to the Mni amount.

Weights applicable depending on the categories in which the ATMs are located i Psi Pni 1 (category III) 4.25 7.05 2 (categories IV, V and VI) 7.50 14.80

For these purposes, those ATMs that –at a minimum– allow users to make cash withdrawals regardless of the entity they are customers of and the administrator network of those equipment, and that –on a monthly average, computing business and non-business days– have remained accessible to the public for at least ten hours a day, shall be counted.

The financings computed for the deduction of points 1.5.1. and 1.5.4. may only be counted in one of said points, and the financings of point 1.5.3. may also be counted for the deduction of point 1.5.1.

1.6. Point increases in requirement due to concentration of liabilities.
When an excessive concentration of liabilities (in titleholders and/or terms) is verified, which implies a significant risk regarding the individual liquidity of the financial entity and/or has an important negative effect on systemic liquidity, additional minimum cash requirements on the liabilities comprised by the financial entity and/or complementary measures deemed pertinent may be established.

It will be considered that this situation arises when, among others, any of the following factors occur:

• A high percentage of liabilities is concentrated in the same titleholder or titleholders.
• In term obligations, the term is short.
• The aforementioned liabilities represent a significant percentage with respect to the integration of the minimum cash and/or the total private sector deposits in the entity.

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1.7. Transfers.
1.7.1.Admitted margin.
The integration of the minimum cash of the position in average of the period cannot be less than 80% of the requirement resulting from the following expression:
EEMA (n) = EEF (n) + ENI (n-1) where
EEMA (n): adjusted minimum cash requirement corresponding to period “n”.
EEF (n): minimum cash requirement according to current regulations corresponding to period “n”.
ENI (n-1): requirement not integrated in period “n-1”.

1.7.2.Period of use.
The admitted transfer of the requirement not integrated in each period to the next position may be carried out up to a maximum of six periods, counted from the first –inclusive– in which it is opted to use it in accordance with the provisions above or from the first immediate position subsequent to that in which the transferred defects are compensated or charges are paid on them.

For its calculation, the transferred numerals of the period to which they correspond, divided by the number of days of the period to which the transfer is made, will be computed.

1.8. Defect in the application of resources in foreign currency.
The defect in the application of resources corresponding to deposits in foreign currency, net of cash balances in entities, in custody in other financial entities, in transit and in Value Transporters (TV), which is determined in a month, will be computed by an equivalent amount in the calculation of the minimum cash requirement of that same period of the respective currency.

Those originating from swap operations ordered by the National Executive Power are excluded, and consequently cannot be compensated with purchases of foreign currency.

Applying deposits in “Special Accounts to credit financing of exports” to cash in entities, in custody in other financial entities, in transit or in TV is not admitted.

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1.9. Increase in requirement for non-compliance with regulations on “Productive Investment Financing Line for SMEs”.
The defect in the application of quotas provided for in the regulations on “Productive Investment Financing Line for SMEs” will generate an increase in the minimum cash requirement in average in pesos, in accordance with what is established in point 11.1. of those regulations.

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6.1. Entities reached.
Financial entities included in the list of Annex II of Communication “A” 7859.

6.2. Minimum Quota.
The entities reached, from 1.4.24, for the purpose of complying with this quota must maintain a quarterly average of daily balances (April-June; July-September; October-December and January-March of the following year) of comprised financings that is, at a minimum, equivalent to 7.5% of the private non-financial sector deposits in pesos of the entity subject to fractional reserve –excluding the deposits provided for in points 3.13. and 3.14. of the regulations on “Savings deposits, salary accounts and special accounts”–, calculated based on the monthly average of daily balances of the penultimate previous month (February, May, August and November, respectively).

If they are entities included in groups B and C –in accordance with what is provided in Section 4. of the regulations on “Authorities of financial entities”, for which the indicator of point 4.1. of those regulations must be computed, for all financial entities, only individually–, the minimum percentage to apply will be 25% of that previously provided.

For these purposes, the residual balances of the applied financings valid are computable: i) to quotas 2020, 2021, 2021/2022, 2022, 2022/2023, 2023 and 2023/2024 of the regulations on “Productive Investment Financing Line for SMEs”; ii) in points 7.2.1., 7.2.2. and 7.2.4. that have been disbursed until 15.10.2020 and iii) to the previous quarters of this quota.

In addition, to comply with the Minimum SME Quota, at least 30% of it must be destined to what is provided for in point 6.4.1.

The entities reached that comply with this Minimum SME Quota may compute the decrease in the minimum cash requirement in pesos provided for in point 1.5.1. during the following quarter.

6.3. Destination.
The comprised financings must be granted to SME clients in accordance with the definition current in the regulations on “Determination of micro, small or medium enterprise status”.

The following are excluded from the computation of the Minimum SME Quota:

6.3.1. from the destinations of points 6.4.1. and 6.4.2.: SMEs with agricultural activity registered in the Simplified Agricultural Information System (SISA) as “Producer” with collection of wheat and/or soybean production, except that they are categorized as microenterprises –according to the definition of the former Secretariat of Small and Medium Enterprises and Entrepreneurs– and the value of that collection does not exceed 5% of their annual harvest capacity, estimated based on yields published by the Secretariat of Agriculture, Livestock and Fisheries (SAGyP) (area declared in SISA by the average yield published by SAGyP for each crop). The financial entity will be responsible for verifying that the applicant is not included in this exclusion; and

6.3.2. from the destinations of point 6.4.2. and the relevant part to this point contained in points 6.4.3.2. and 6.4.3.3.: financings agreed to SMEs with agricultural activity registered in SISA as “Producer” of cereals and/or oilseeds, except that they are categorized as microenterprises –according to the definition of the former Secretariat of Small and Medium Enterprises and Entrepreneurs–.

For these purposes, the simple average of the daily balances of the valid financings during the period between April-June, July-September, October-December and January-March of each year will be considered.

6.4. Eligible Financings.
6.4.1. Project investment financing.
Financing of investment projects intended for the acquisition of capital goods and/or for the construction of facilities necessary for the production of goods and/or services and the commercialization of goods and/or services.

If they are utility vehicles, road vehicles and aircraft, only those of national origin –according to the corresponding manufacturing certificate– that are directly and exclusively affected to the activity of the applicant, a situation of which must be recorded in the client file, may be financed.

Financings that are agreed upon under other special credit regimes cannot be qualified as eligible applications to the extent that the funds for such assistance are provided to the entity for that specific purpose or have the character of contingent liabilities.

6.4.2. Working capital and discounting of deferred payment checks and other documents.
It may be destined to working capital financing, discounting of deferred payment checks and purchase of Electronic Credit Invoices for SMEs, in the latter case accepted by companies that comply with what is provided for in point 2.2.1. of the regulations on “Credit evaluations”, from clients who meet the condition of SME.

The values to be discounted must come from the collection of sales and/or service provision operations corresponding to the activity of the discounting SME.

This condition may be verified through the sworn declaration made by the client and/or by any other means that the entity deems sufficient.

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6.4.3. Specials.
6.4.3.1. Non-SME clients, to the extent that the funds are destined for the acquisition of machinery and equipment produced by local SMEs.

6.4.3.2. Financings to financial entities not reached by this section and/or to companies that provide financial assistance through financial leasing operations (“leasing”) –point 2.2.8. of the regulations on “Complementary services of the financial activity and other permitted activities”–, provided that they destine the funds to granting the financings provided for in points 6.4.1. and/or 6.4.2., under the conditions established in this section.

Entities must apply the funds to the destinations provided for in this point within a period no greater than 10 business days between the date they receive the assistance from the financial entity and its credit application to SMEs.

6.4.3.3. Incorporation through assignment or discounting of the financings provided for in points 6.4.1. and/or 6.4.2. granted by financial entities.

In all cases, the financings must comply with the conditions established in this section and can only be computed by the acquiring financial entity, if applicable.

6.5. Terms and conditions of the financings.
6.5.1. Interest rate.
The rate freely agreed upon between the parties.

6.5.2. Currency and terms.
The financings of point 6.4.1. must be denominated in pesos and have –at the time of disbursement– an average term equal to or greater than 24 months, weighting for this purpose the capital maturities.

Operations of point 6.4.2. must also be in pesos and will have no minimum term.

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7.1. Minimum daily integration in foreign currency.
7.1.1. From 1.11.11, the defect in the application of resources in that species will be excluded from the calculation base of the minimum daily integration requirement in foreign currency.

7.1.1. From 1.6.12, the minimum daily integration requirement in foreign currency referred to in point 2.3. is suspended.

7.2. Decreases in the minimum cash requirement in pesos based on the balances of comprised financings disbursed until 30.9.22:

7.2.1. Special for entities included in Group “A”, in accordance with what is provided in Section 4. of the regulations on “Authorities of financial entities” and the branches or subsidiaries of banks from abroad classified as globally systemically important (GSIB) not included in that group.

The requirement will be reduced by an amount equivalent to 30% of the sum of the financings in pesos to SMEs –according to the definition contained in the regulations on “Determination of micro, small or medium enterprise status”– agreed at an interest rate maximum of:
– 40% fixed nominal annual until 16.2.2020 inclusive (which may continue to be computed until their cancellation).
− 35% fixed nominal annual from 17.2.2020.

Financings granted to financial entities not included in the first paragraph may be included in that sum, provided that: i) within 10 business days from the date they receive the assistance those entities destine the funds to granting financings to SMEs under the conditions of this point and ii) they have a special report from external auditor –registered in the “Register of Auditors” of the SEFyC– of the unreached financial entity on its compliance.

The special report: i) must record the dates, amounts and borrower data of each application, according to the model that will be communicated for this purpose and ii) must not contain limitations in the scope of the tasks, nor opinion with qualifications or abstention of opinion.

The intervention of the external auditor in all aspects required in this operation falls within the provisions established in the Minimum Standards on External Audits.

The entity may equally fulfill the preceding requirement with the presentation of a special report from its Internal Audit whose procedures, scope and conclusions adjust to the aforementioned conditions and model.

The monthly average balance of the reached financings of the period prior to the computation of the requirement that meet the indicated conditions will be considered.

This deduction may not exceed 2% of the concepts in pesos subject to requirement, on average, of the month prior to the computation.

B.C.R.A. MINIMUM CASH
Section 7. Transitional Provisions.
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7.2.2. Special within the framework of the health emergency ordered by Decree N° 260/2020.

The requirement will be reduced by an amount equivalent to 40% of the sum of the financings in pesos agreed at an interest rate nominal annual of up to 24% to the following destinations:

7.2.2.1. SMEs –according to the definition contained in the regulations on “Determination of micro, small or medium enterprise status”–, with at least 50% of the amount of those financings being destined to working capital lines, such as payments of salaries and coverage of deferred checks;

7.2.2.2. providers of human health services, authorized by the competent body of the corresponding jurisdiction, not previously included, to the extent that they provide hospitalization services within the framework of the Health Emergency ordered by Decree N° 260/2020 and it is destined for the purchase of medical supplies and equipment;

7.2.2.3. non-SME clients, to the extent that the funds are destined for the acquisition of machinery and equipment produced by local SMEs.

The monthly average balance of the reached financings of the period prior to the computation of the requirement that meet the indicated conditions will be considered.

Financings granted to other financial entities and non-financial credit providers –registered in the corresponding records enabled by the SEFyC– may be included in that sum, provided that: i) within 3 business days from the date they receive the assistance those entities destine the funds to granting financings to SMEs under the conditions of this point and ii) they have a special report from external auditor –registered in the “Register of Auditors” of the SEFyC–, which adjusts to what is provided for in point 7.2.1.

This deduction may not exceed 4% of the concepts in pesos subject to requirement on average, of the month prior to the computation, increasing to 6% if they are the following financings agreed upon from 1.7.2020:

• clients who received the assistance provided for in point 7.2.1., up to the total amount equivalent to the monthly payroll mass (without bonus) to be paid by the applicant; and
• clients who have not received this special assistance, in accordance with the admitted destinations in this point.

7.2.3. Special within the framework of Decree N° 332/2020 (and amendments).

The requirement will be reduced by an amount equivalent to:
i) 60% of the sum of the “Zero Rate Credits”, “Subsidized Rate Credits for Companies” and “Zero Rate Culture Credits” agreed upon within the framework of Decree N° 332/2020 (and amendments) and disbursed until 5.11.2020;

B.C.R.A. MINIMUM CASH
Section 7. Transitional Provisions.
Version: 4th COMMUNICATION “A” 7983 Validity:
01/04/2024 Page 2

ii) 24% of the “Subsidized Rate Credits for Companies” disbursed from 6.11.2020 at a nominal annual rate of 27%; and iii) 7% of the “Subsidized Rate Credits for Companies” disbursed from 6.11.2020 at a nominal annual rate of 33%.

Their monthly average balance in the period prior to the computation of the requirement will be considered.

7.2.4. Financings to SMEs not reported in the “Central Debtors of the Financial System”.

The requirement will be reduced by an amount equivalent to 40% of the financings in pesos to SMEs –according to the definition contained in the regulations on “Determination of micro, small or medium enterprise status”– that are agreed at an interest rate nominal annual of up to 24%, measured in monthly average of daily balances of the previous month, provided that said SMEs are not reported in the “Central Debtors of the Financial System” administered by the BCRA.

Financings granted to other financial entities and non-financial credit providers –registered in the corresponding records enabled by the SEFyC– may be included in that sum, provided that: i) within 3 business days from the date they receive the assistance those entities destine the funds to granting financings to SMEs under the conditions of this point and ii) they have a special report from external auditor –registered in the “Register of Auditors” of the SEFyC–, which adjusts to what is provided for in point 7.2.1.

7.2.5. Special within the framework of Decree N° 512/21.

The requirement will be reduced by an amount equivalent to 60% of the sum of the “Zero Rate Credits 2021” agreed upon within the framework of Decree N° 512/21.

Their monthly average balance in the period prior to the computation of the requirement will be considered.

The financings computed for the deduction of points 7.2.1. to 7.2.5. may only be counted in one of said points. The imputation of the financings of points 7.2.1., 7.2.2. and 7.2.4. will adjust as follows:

i. Financings granted until 15.10.2020 inclusive: its monthly average of daily balances in the previous period will continue to be computed, for the corresponding deduction.
In the case of financings disbursed from 9.10.2020 and until 15.10.2020, in both cases inclusive, they cannot impute for the deductions of points 7.2.1., 7.2.2. and 7.2.4. the financings to persons –natural or legal– that:
− belong to sectors of economic activity that have not been considered eligible for any of the benefits of the Emergency Assistance to Work and Production Program (ATP) created by Decree N° 332/2020; and/or − after 19.3.2020 have imported final consumption goods, except that they are products and/or medical supplies.

ii. Financings that were granted from 6.11.2020 inclusive: they cannot be imputed to the deductions of points 7.2.1., 7.2.2. and 7.2.4.

B.C.R.A. MINIMUM CASH
Section 7. Transitional Provisions.
Version: 3rd COMMUNICATION “A” 7983 Validity:
01/04/2024 Page 3

7.3. Decrease in the minimum cash requirement in pesos based on the balances of financings granted by the financial entities reached by the regulations on “Productive Investment Financing Line for SMEs” and disbursed until 31.3.24.

The requirement will be reduced by an amount equivalent to 40% of the financings provided for in point 4.1. of the “Productive Investment Financing Line for SMEs” that are agreed at an interest rate nominal annual that does not exceed that provided for in point 5.1.1. of those regulations, measured in monthly average of daily balances of the previous month.

B.C.R.A. MINIMUM CASH
Section 7. Transitional Provisions.
Version: 3rd COMMUNICATION “A” 7983 Validity:
01/04/2024 Page 4

MINIMUM CASH
ORDERED TEXT ORIGIN NORM OBSERVATIONS Sec. Point Para. Com. Annex Sec. Point Para.
1.
1.3.7. “A” 3549 According to Com. “A” 4179, 4388,
4549, 4851, 5356, 5534, 5555,
5569, 5873, 5893, 5980, 6195,
6526, 6532, 6616, 6706, 6728,
6740, 6817, 7016, 7290, 7295,
7383, 7432, 7511, 7536, 7545,
7614, 7637, 7717, 7767, 7775 and
7923.
1.3.8. “A” 4360 2. According to Com. “A” 5356 and 6616.
1.3.9. “A” 4754 6. According to Com. “A” 5356, 5980,
6195, 6526, 6532, 6616, 6728 and
7536.
1.3.10. “A” 5945 4. According to Com. “A” 6069, 6204 and
6616.
1.3.11. “A” 6341 According to Com. “A” 6616.
1.3.12. “A” 6069 4. According to Com. “A” 6616.
1.3.13. “A” 6992
1.3.14. “A” 7429
1.3.15. “A” 7556 4. According to Com. “A” 7570 and 7571.
1.3.16. “A” 6526 According to Com. “A” 6532, 6550,
6587, 6616, 6706, 7016, 7290,
7511, 7536, 7611, 7637 and 7767.
1.3.17. “A” 6550 According to Com. “A” 6556, 6559,
6575, 6587, 6616, 6706, 6738,
6740, 6817, 7018, 7029, 7047,
7092, 7290, 7295, 7383, 7432,
7511, 7536, 7545, 7573, 7614,
7717, 7775 and 7923.
1.3. Penultimate
“A” 7717 1.
Penultimate
“A” 6526 According to Com. “A” 6532, 6556,
6569, 6575, 6587, 6616, 6628,
6740, 7016, 7290, 7295, 7511,
7536, 7573, 7637 and 7767.
Last “A” 7742 Includes regulatory clarification.
1.4. “A” 3905 3. According to Com. “A” 4179, 4449,
4473, 5671, 5740, 6232, 6349,
6719, 6871 and 7046.
1.5. “A” 5356 2. According to Com. “A” 5471.
1.5.1. “A” 5356 2. According to Com. “A” 5471, 5623,
6531, 6703, 6705, 7432, 7758 and
7983.
1.5.2. “A” 5631 1. According to Com. “A” 5638, 6217,
6531, 6857, 6910, 6937, 7114,
7334, 7448, 7951 and 7983.
1.5.3. “A” 7161 5. According to Com. “A” 7432, 7459,
7474, 7491, 7536, 7561 and 7983.
1.5.4. “A” 7254 1. According to Com. “A” 7287, 7536 and
7970. Includes regulatory clarification.

MINIMUM CASH
ORDERED TEXT ORIGIN NORM OBSERVATIONS Sec. Point Para. Com. Annex Sec. Point Para.
1.
1.5.5. “A” 6740 1. According to Com. “A” 7254, 7536,
7661 and 7795.
1.5. Last “A” 6858 2. According to Com. “A” 6965, 6993,
7006, 7140, 7155, 7161, 7254,
7342, 7536 and 7983.
1.6. “A” 3274 II 1. 1. 1.5. According to Com. “A” 3498.
1.7. “A” 3274 II 1. 1.6
1.7.1. “A” 3274 II 1. 1.6.1. According to Com. “A” 4405, 4449,
6349, 6719 and 7046.
1.7.2. “A” 3274 II 1. 1.6.2. According to Com. “A” 3304, 4449,
6349 and 6719.
1.8. “A” 3498 unique 1. 1.8. According to Com. “A” 4147, 6537,
7003 and 7570.
1.9. “A” 7727
2.
2.1. “A” 3274 II 2. 2.1. According to Com. “A” 3498, 3597,
4716, 4815, 6288, 6763 and “B”
9186.
2.1.1. “A” 3274 II 2. 2.1.2. According to Com. “A” 3304, 3498,
4016 and 4147.
2.1.2. “A” 3498 unique 2. 2.1.3. According to Com. “A” 4147.
2.1.3. “A” 3274 II 2. 2.1.3. According to Com. “A” 3498, 4147,
4276 and 5194.
2.1.4. “A” 3274 II 2. 2.1.4.
2.1.5. “A” 4016 1.
2.1.6. “A” 4716 2. According to Com. “A” 6628 and “B”
9186.
2.2. “A” 3274 II 2. 2.2. According to Com. “A” 3498, 4449,
4716, 5299, 6349, 6719 and 6774.
2.3. “A” 3365 2. According to Com. “A” 3387, 3470,
3498, 3549, 3597, 3732, 3824,
4016, 4449, 4716, 5152, 5299,
5373, 6288, 6349, 6575, 6616,
6719, 7046 and “B” 9186.
2.4. “A” 4147 3. According to Com. “A” 4276, 4449,
4509, 5152, 5299, 6349, 6719 and
7046.
2.5. “A” 4147 3. According to Com. “A” 4393, 4509,
4716 and 5299.
3.
3.1. “A” 3274 II 3. 3.1.
3.1.1. “A” 3274 II 3. 3.1.1. According to Com. “A” 3326, 3365,
3498, 3549, 3905, 4276, 4449,
4473, 4707, 4716, 4862, 5356,
6349, 6638, 6719, 7939 and “B”
9186.
3.1.2. “A” 3274 II 3. 3.1.2.
3.1.3. “A” 3274 II 3. 3.1.3. According to Com. “A” 3326.
3.1.4. “A” 3274 II 3. 3.1.4.

MINIMUM CASH
ORDERED TEXT ORIGIN NORM OBSERVATIONS Sec. Point Para. Com. Annex Sec. Point Para.
3.
3.2. “A” 3274 II 3. 3.2. According to Com. “A” 6719 and 7046.
3.2.1. “A” 3274 II 3. 3.2.2.1. According to Com. “A” 4449, 6349 and
6719.
3.2.2. “A” 3274 II 3. 3.2.2.2. According to Com. “A” 4449 and 6719.
3.3. “A” 3274 II 3. 3.3. According to Com. “A” 3498.
3.3.1. “A” 3274 II 3. 3.3.1. According to Com. “A” 4771 and 6275.
3.3.2. “A” 3274 II 3. 3.3.2.
4. 4.1. “A” 3274 II 4. 4.1.
5.
5.1. “A” 3274 II 5. 5.1. According to Com. “A” 3498, 5693 and
6832.
5.2. “A” 3905 5. According to Com. “A” 5356 and 5693.
5.3. “A” 3905 5. According to Com. “A” 4449, 6167 and
7944.
6.
6.1. “A” 7983 1.
6.2. “A” 7983 1.
6.3. “A” 7983 1.
6.4. “A” 7983 1.
6.4.1. “A” 7983 1.
6.4.2. “A” 7983 1.
6.4.3. “A” 7983 1.
6.5. “A” 7983 1.
6.5.1. “A” 7983 1.
6.5.2. “A” 7983 1.
7.
7.1.1. “A” 5246 3.
7.1.2. “A” 5312 According to Com. “A” 5333.
7.2. “A” 7536 2.
7.2.1. “A” 6858 1. According to Com. “A” 6901, 6907 and
7536.
7.2.2. “A” 6937 2. According to Com. “A” 6943, 7054,
7140, 7155 and 7536.
7.2.3. “A” 6993 2. According to Com. “A” 7082, 7157 and
7536.
7.2.4. “A” 7006 2. According to Com. “A” 7536.
7.2.5. “A” 7342 2. According to Com. “A” 7536.
7.2. last “A” 6858 2. According to Com. “A” 6965, 6993,
7006, 7140, 7132, 7155, 7157,
7161, 7254, 7342 and 7536.
7.3. “A” 7983 3.

At least 30% of the quotas must be allocated to what is provided for in point 4.1.
3.2. Defects in compliance.
Financial entities may compute for the fulfillment of the quotas in Section 2. the following financings:
3.2.1. Those imputed in points 7.2.1., 7.2.2. and 7.2.4. of the norms on “Minimum cash” and which have been disbursed by 10/15/2020.
3.2.2. Those disbursed from 11/13/2020 as export pre-financing –except if they are for large exporting companies (Section 7. of the norms on “Credit policy”)–, export financings and/or financing of imports of inputs and/or capital goods –excluding services– that are financed with credit lines from banks abroad, new external loans and/or negotiable obligations placed abroad, or granted by financial entities abroad linked to the financial entity covered under Section 2. of the norms on “Large exposures to credit risk”. Financings granted with resources obtained from international organizations and/or international agencies or credit offices will be excluded.
The following conditions must be verified:
− The financings from abroad must have a contractual term of no less than 180 calendar days.
− They must be new financings from abroad received by the entity and used from 11/13/2020.
− The rate will be freely agreed upon.
− The financings from abroad must correspond to funds effectively disbursed by the foreign creditor.
− The amount to be imputed may not exceed the increase resulting from considering the average of the increases in daily balances registered between:
i) 11/13/2020 and 3/31/21, with respect to the balance registered on 11/12/2020 for the 2020 quota; ii) 4/1/21 and 9/30/21, with respect to the balance registered on 11/12/2020 for the 2021 quota; iii) 10/1/21 and 3/31/22, with respect to the balance registered on 11/12/2020 for the 2021/2022 quota; iv) 4/1/22 and 9/30/22, with respect to the balance registered on 11/12/2020 for the 2022 quota; B.C.R.A. FINANCING LINE FOR PRODUCTIVE INVESTMENT OF SMEs
Section 3. Applications.
Version: 12th COMMUNICATION “A” 7983 Validity:
04/01/2024 Page 2

ORDERED TEXT ORIGIN NORM OBSERVATIONS Sec. Point Para. Com. Annex Sec. Point Para.
1.
“A” 7140 unique 1. According to Com. “A” 7161, 7240, 7369, 7475, 7612, 7720 and 7848.
2.
2.1. “A” 7140 unique 2.
2.2. “A” 7240 1.
2.3. “A” 7369 1.
2.4. “A” 7475
2.5. “A” 7612 According to Com. “A” 7615.
2.6. “A” 7720 1.
2.7. “A” 7848
3.
3.1. “A” 7140 unique 3.1. According to Com. “A” 7161, 7240,
7369, 7475, 7561, 7612, 7720 and 7848.
3.2.1. “A” 7140 unique 3.2. According to Com. “A” 7616, 7795 and
7983.
3.2.2. “A” 7161 4. According to Com. “A” 7240, 7369,
7475, 7612, 7720 and 7848.
3.2.3. “A” 7197 According to Com. “A” 7227 and 7240.
3.2.4. “A” 7369 4. Includes interpretative clarification.
4.
4.1. “A” 7140 unique 4.1.
4.1.1. “A” 7140 unique 4.1. According to Com. “A” 7369.
4.1.2. “A” 7329
4.1.3. “A” 7373 1.
4.1. last “A” 7140 unique 4.1.
4.2. “A” 7140 unique 4.2. According to Com. “A” 7155, 7373 and
7758. Includes interpretative clarification.
4.3. “A” 7140 unique 4.3.
4.3.1. “A” 7140 unique 4.3.2.
4.3.2. “A” 7140 unique 4.3.3.
4.3.3. “A” 7161 3.
4.3. last “A” 7140 unique 4.3. According to Com. “A” 7161.
5.
5.1. “A” 7140 unique 5.1. According to Com. “A” 7173, 7174,
7432, 7474, 7491, 7512, 7527,
7561, 7577, 7605, 7745, 7751,
7767, 7822 and 7862.
5.2. “A” 7140 unique 5.2. According to Com. “A” 7369, 7475,
7612 and 7720.
6.
6.1. “A” 7140 unique 6.1.
6.2. “A” 7140 unique 6.2.
6.3. “A” 7140 unique 6.3.
6.4. “A” 7140 unique 6.4.
6.5. “A” 7140 unique 6.5.
7.
7.1. “A” 7140 unique 7.1.
7.2. “A” 7140 unique 7.2.
7.3. “A” 7240 2.
8. “A” 7140 unique 8.
9. “A” 7140 unique 9.
B.C.R.A.
ORIGIN OF THE PROVISIONS CONTAINED IN THE NORMS ON “FINANCING LINE FOR PRODUCTIVE INVESTMENT OF SMEs”

In the following months, the aforementioned procedure of calculating regulatory provisions on the contractual value –according to the category assigned to the client– and comparing the resulting amount with the net value (considering both concepts), determining additional provisions as appropriate or, if so, decreasing the difference of the determined amount with respect to that stated in the first paragraph will continue to be applied. In the case of eventual refinancings that include haircuts, these will be imputed first against the difference of the determined amount with respect to that stated in the first paragraph and then against the regulatory provisions determined.
2.2.7. Refinancing of debts with capital haircuts.
The minimum provision for uncollectability risk will be equivalent to the amount resulting from deducting from the provisions required on the debt –without considering the provision corresponding to accrued interest, as provided in point 2.2.2.2.– before its refinancing, the amount corresponding to the haircut effected. The resulting provisioning percentage on the refinanced amount will determine the classification level to be assigned to the debtor based on the ranges of the table contained in point 2.1.1.
2.2.8. Treatment of clients or guarantors residing abroad –“country risk”–.
In the case of clients or guarantors residing abroad, financial entities must evaluate the appropriateness of computing a specific provision for “country risk” based on what is provided in point 6.2. of the norms on “Debtor classification” and taking into account the criteria defined in Section 2. of the norms on “Guidelines for risk management in financial entities” related to that risk.
2.2.9. New financings in pesos that have:
2.2.9.1. Coverage of the price risk of the good that the debtor produces. It will be understood that the coverage reasonably protects that risk when it covers the entire financing balance and, in the judgment of the financial entity, the price of the asset involved in the coverage contract has a high positive correlation with the prices of the products that the debtor produces.
2.2.9.2. Coverage –through an insurance or other financial instrument– against climatic or meteorological risks that have an estimated probability of occurrence of at least once every 20 years and the amount of the coverage covers the entire financing balance.
2.2.10. SME financings –included in point 7.2.2. of the norms on
“Minimum cash”– that are destined for the payment of salaries, will be provisioned for regulatory calculation purposes –until the cancellation of the financing– based on the classification of the SME at the time of its granting. B.C.R.A. MINIMUM PROVISIONS FOR UNCOLLECTABILITY RISK
Section 2. Minimum guidelines.
Version: 15th COMMUNICATION “A” 7983 Validity:
04/01/2024 Page 7

ORDERED TEXT ORIGIN NORM OBSERVATIONS Section Point Para. Com. Annex Point Para.
1.
1.1. “A” 6851 a. According to Com. “A” 7443.
1.2. “A” 2216 2. 1st According to Com. “A” 6851 and 7443.
1.3.1. “A” 2216 2. 1st
1.3.2. “A” 2216 II 2nd Includes interpretative clarification.
1.3.3. “A” 2216 II 2nd
1.3.4. “A” 2216 II 3rd According to Com. “A” 3040 (point 3.) and
“B” 9074.
1.3.5. “A” 3040
1.3.6. “A” 3064
2.
2.1.1. 1st and
table
“A” 2216 II 1st According to Com. “A” 2440, 3339, 6851, 6938, 7024, 7443 and “B” 9074.
2.1.2.1. “B” 6331 6. According to Com. “A” 6303.
2.1.2.2. “A” 2826 2nd
2.1.2.3. “A” 2932 7th According to Com. “A” 6851 and 7443. In2.1.2.4. cludes interpretative clarification.
2.1.2.5. “A” 3314 According to Com. “A” 6558, 6851 and
7443.
2.2.1. “A” 2216 II 6th According to Com. “A” 2932 (point 15.),
6851 and 7443.
2.2.2. “A” 2216 II 9th and
last
According to Com. “A” 3040 (point 5.), includes interpretative clarification.
According to Com. “A” 3339, 3955, 6851,
7443 and “B” 9074.
2.2.3.1. “A” 2216 II 8th According to Com. “A” 2442, 3091, 6851,
7443 and “B” 9074.
2.2.3.2. “A” 3091 According to Com. “A” 6851 and 7443.
2.2.3.3. “A” 3091
2.2.3.4. “A” 2216 II 8th According to Com. “A” 2442 and 3091.
2.2.4. “A” 6851 d. According to Com. “A” 7443.
2.2.5. “A” 3157 2. According to Com. “A” 3918 and 4055.
2.2.6. “A” 4060 6. According to Com. “A” 6851 and 7443.
2.2.7. “A” 4467 According to Com. “A” 6851 and 7443.
2.2.8. “A” 5398 According to Com. “A” 6851 and 7443.
2.2.9. “A” 6032 2. According to Com. “A” 6489.
2.2.10. “A” 6946 2. According to Com. A 7443, 7616,7795 and
7983.
2.2. last “A” 2216 II According to Com. “A” 6851, 6938 and
7443.
2.3. “A” 2216 II 4th According to Com. “A” 4738, 6851 and
7443.
2.4. 1st “A” 2357 1. According to Com. “A” 6327, 6851 and
7443.
2.5. “A” 2287 4. According to Com. “A” 2893 (point 2.),
6851 and 7443.
2.5.1. “A” 2287 4. According to Com. “A” 2893 (point 2.),
6851 and 7443.
B.C.R.A. ORIGIN OF THE PROVISIONS CONTAINED IN THE NORMS ON “MINIMUM PROVISIONS FOR UNCOLLECTABILITY RISK”