Circular LISOL 1-1149: Update of Consolidated Texts

"2026 - YEAR OF ARGENTINE GREATNESS" COMMUNICATION "A" 8463 07/31/2026 TO FINANCIAL ENTITIES: Ref.: Circular LISOL 1-1149: Communication A 8394. Update of consolidated texts.

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We address you to deliver attached the sheets that, in replacement of those previously provided, must be incorporated into the consolidated texts on Minimum Capital of Financial Entities (point 1.3. and Section 6.), Guidelines for Risk Management in Financial Entities (points 1.2.5. and 1.2.6.) and Large Credit Risk Exposures (point 2.5.2.1.), in accordance with the provisions set forth in the resolution disseminated by Communication A 8394.

Likewise, we inform you that formal adjustments were made and, on the other hand, points 6.7. –criteria for integration and daily deficiency of the market risk requirement– and 6.10. –provisions on prudent valuation, applicable both to the investment portfolio and the trading portfolio– were transferred from the consolidated text on Minimum Capital of Financial Entities to points 1.5. and 1.4., respectively.

Furthermore, point 6.1.2.2. of the consolidated text on Minimum Capital of Financial Entities was updated based on what was previously established by Communication A 8066 regarding sizing (aforos).

Finally, we remind you that on this Institution's website www.bcra.gob.ar, by accessing “Sections - Financial System - LEGAL AND REGULATORY FRAMEWORK - Consolidations and summaries - Consolidated texts of general regulations”, the modifications made will be found with texts highlighted in special characters (strikethrough and bold).

We salute you attentively. CENTRAL BANK OF THE ARGENTINE REPUBLIC Pablo D. Montero Darío C. Stefanelli Manager of Emission of Norms Principal Manager of Emission and Regulatory Applications

ANNEX

-Index- Section 1. Minimum Capital. 1.1. Requirement. 1.2. Basic requirement. 1.3. Delimitation between the investment portfolio and the trading portfolio. 1.4. Prudent valuation guidelines. 1.5. Integration. 1.6. Non-compliance. Section 2. Minimum capital for credit risk. 2.1. Requirement. 2.2. Exclusions. 2.3. Calculation of included concepts. 2.4. Due diligence requirements. 2.5. Criteria for determining risk-weighted assets. 2.6. Exposures to financial entities. 2.7. Exposures to companies. 2.8. Retail exposures. 2.9. Exposures with mortgage guarantee. 2.10. Exposures in default. 2.11. Exposures to instruments. 2.12. Risk weighting table. 2.13. Off-balance sheet items. Credit conversion factors (CCF). Section 3. Minimum capital for credit risk. Securitizations and fund investments. 3.1. Treatment of securitizations. 3.2. Treatment of fund positions. Section 4. Minimum capital for counterparty credit risk. 4.1. Capital requirement for counterparty credit risk for failed and non-DvP operations. 4.2. Capital requirement for counterparty credit risk in operations with derivatives –OTC or traded on regulated markets– and with deferred settlement. 4.3. Capital requirement for counterparty credit risk in operations with central counterparty entities. Section 5. Credit risk coverage. 5.1. Credit risk coverage techniques. 5.2. Requirements for the application of credit risk coverage techniques. 5.3. Operations covered with assets admitted as collateral. 5.4. Operations covered with personal guarantees (and counter-guarantees) and credit derivatives.

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-Index- Section 6. Minimum capital for market risk. 6.1. Requirement. 6.2. Capital requirement for interest rate risk. 6.3. Capital requirement for equity position risk. 6.4. Capital requirement for exchange rate risk. 6.5. Capital requirement for commodity positions risk. 6.6. Capital requirement for options positions risk. 6.7. Responsibilities. 6.8. Internal audit. Section 7. Minimum capital for operational risk. 7.1. Capital requirement for operational risk for group 1 entities. 7.2. Capital requirement for operational risk for group 2 entities. 7.3. Limit for group 2 entities. 7.4. New entities. Section 8. Computable net worth. 8.1. Determination. 8.2. Computable concepts. 8.3. Criteria related to computable concepts. 8.4. Deductible concepts. 8.5. Limits. 8.6. Capital contributions. 8.7. Procedure. Section 9. Bases for compliance with regulations. 9.1. Individual basis. 9.2. Consolidated basis. Section 10. External Credit Rating Agencies (ECAI). Section 11. Other provisions. Section 12. Transitional provisions. Correlation table.

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1.1. Requirement. The minimum capital requirement that financial entities must have integrated shall be equivalent to the highest value resulting from the comparison between: i) the basic requirement, and ii) the sum of those determined by credit risks (including counterparty credit risk), market risk –requirement for daily positions of included assets– and operational risk.

For these purposes, positions in instruments must be assigned to the investment portfolio (subject to capital requirement for credit risk, counterparty credit risk and operational risk –Sections 2., 3., 4., 5. and 7., respectively–) and to the trading portfolio (subject to capital requirement for counterparty credit risk, market risk and operational risk –Sections 4., 6. and 7., respectively–) in accordance with the criteria of point 1.3.

1.2. Basic requirement. Depending on the type of entity, the following basic requirements shall apply: Banks Other entities (except Cooperative Credit Unions)

• In millions of pesos - 5,000 2,500

Financial companies that carry out foreign trade operations directly shall observe the requirements established for banks.

1.3. Delimitation between the investment portfolio and the trading portfolio. 1.3.1. Criteria for assigning positions to the trading portfolio. 1.3.1.1. The trading portfolio comprises all positions in financial instruments held by a financial entity, whether for trading purposes or as a hedge for positions held for trading purposes. These positions must be valued at market, in accordance with the prudent valuation requirements established in point 1.4.

Understood as: i) financial instrument: the contract that gives rise to both a financial asset for one party and a financial liability or equity instrument for the other party, including financial derivatives, among others; ii) financial asset: any asset that is cash, a right to receive cash or another financial asset or equity instrument; and

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iii) financial liability: a contractual obligation to deliver cash or a financial asset.

1.3.1.2. Positions assigned to the trading portfolio must be free of legal or other restrictions on their trading or for being subject to hedging.

1.3.1.3. Any instrument that is incorporated for at least one of the following purposes: short-term sale, obtaining benefits from short-term price movements or arbitrage, or instruments that hedge the aforementioned positions.

To this effect, it is presumed that the following positions in instruments must be assigned to the trading portfolio, unless the entity justifies the contrary with credible documentation in accordance with its internal policies for these purposes: i) Instruments classified accounting-wise at fair value through profit or loss. ii) Instruments resulting from market maker activities. iii) Fund investments, in which the entity meets at least one of the following conditions: a) examine the fund in order to gain knowledge of its individual components, as well as obtain sufficient and frequent information, verified by an independent third party, on the composition of the fund; b) obtain daily quotes of the fund and access the information contained in the management regulations or applicable regulations. iv) Shares that trade on recognized stock exchanges or securities markets. v) Exposures to securitizations whose underlying assets are identifiable and have a liquid secondary market. vi) Options –explicit or implicit– on instruments issued by the entity assigned to the investment portfolio that are linked to credit risk (including exposures to shares). vii) Instruments resulting from commitments to subscribe to shares, bonds or other types of instruments, which the subscribing entity is obligated to acquire. viii) Instruments that would give rise to a net short position in credit risk assigned to the investment portfolio. ix) Repo operations not assigned to the investment portfolio.

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1.3.2. Criteria for assigning financial instruments to the investment portfolio. 1.3.2.1. Any position in a financial instrument that does not meet any of the criteria for its assignment to the trading portfolio (point 1.3.1.) must be assigned to the investment portfolio. Real estate exposures are also included.

1.3.2.2. The following financial instruments must be assigned to the investment portfolio: i) Shares that do not trade on recognized stock exchanges or securities markets. ii) Retail and SME exposures. iii) Exposures held temporarily with the intention of securitizing them (securitisation warehousing). iv) Fund investments (including hedge funds) not assigned to the trading portfolio –item iii) of point 1.3.1.3.–. v) Financial derivatives and fund investments whose underlying consists of any of the instruments provided for in items i) to iv). vi) Instruments held for hedging purposes of the positions mentioned in items i) to v). vii) Repo operations carried out to manage liquidity or measured at amortized cost.

1.3.3. Requirement of the Superintendence of Financial and Exchange Entities (SEFYC) for the assignment of financial instruments. The SEFYC may require the entity to provide evidence that the positions in financial instruments assigned to the trading portfolio are held for at least one of the purposes established in the first paragraph of point 1.3.1.3. or, if applicable, that the positions in instruments assigned to the investment portfolio are not held for those purposes. If the SEFYC considers that the entity has not provided sufficient evidence, it may order the reassignment of the positions in instruments to the corresponding portfolio, except if they are instruments included in items vii) and viii) of point 1.3.1.3. and in point 1.3.2.2.

1.3.4. Requirements for the reassignment of positions between the investment and trading portfolios. Financial entities must: 1.3.4.1. Reassign positions between portfolios –irrevocably– only in response to exceptional circumstances. 1.3.4.2. Have prior approval from Senior Management and the SEFYC, except when it concerns the reassignment of positions from the investment portfolio to the trading portfolio due to the accounting reclassification of financial instruments to fair value through profit or loss, without prejudice to the application of point 1.3.4.3. 1.3.4.3. Compute as a capital requirement any reduction in that requirement as a result of the reassignment of positions in instruments between portfolios, which must be disclosed –in accordance with the requirements established for this purpose– and maintained until the position originating that capital requirement computation is derecognized in the entity's financial statements.

1.3.5. Policies, procedures and practices for the assignment and reassignment of positions to the trading and investment portfolios. Financial entities must: 1.3.5.1. Establish policies, procedures and practices for the initial assignment of positions to each of the portfolios –in accordance with the criteria contemplated in points 1.3.1. and 1.3.2.–, taking into account their risk management capacity and practices. 1.3.5.2. Establish policies and procedures for the reassignment of positions between portfolios, which must include: i) the requirements for reassignment (point 1.3.4.); ii) the method of identifying extraordinary reassignment events and the circumstances or criteria under which they can be implemented; and iii) the approval process by Senior Management and the SEFYC.

1.3.6. Internal control and audit. Financial entities must have: 1.3.6.1. Internal control functions for: i) the continuous evaluation of the correct initial assignment and reassignment of positions in instruments to each of the portfolios, in the context of their trading activities, which must be duly documented. ii) the review of the policies and procedures for the assignment and reassignment of positions to the portfolios (point 1.3.5.), at least with annual periodicity, contemplating the analysis of all extraordinary reassignment events identified previously. 1.3.6.2. Periodic review by internal audit, at least with annual periodicity.

1.3.7. Internal risk transfer. An internal risk transfer will be considered to exist when a risk offset is verified between a position assigned to the investment portfolio and another assigned to the trading portfolio, or assigned to different positions within each of the portfolios.

Entities may have trading desks to manage the risks of their portfolios. A trading desk is defined as a group of operators established by an entity to jointly manage a series of positions assigned to the trading portfolio according to a coherent and well-defined commercial strategy and which operates within the same risk management structure.

1.3.7.1. Internal risk transfer from the trading portfolio to the investment portfolio. The capital requirement for market risk cannot be reduced as a consequence of an internal risk transfer from the trading portfolio to the investment portfolio.

1.3.7.2. Internal risk transfer from the investment portfolio to the trading portfolio. i) The internal risk transfer that covers credit risk in the investment portfolio (including exposures to shares) must meet the following requirements: a) the trading portfolio must have an external coverage from an admissible credit protection provider that matches exactly the internal risk transfer; and b) the external coverage meets the requirements of Section 5. with respect to the exposure of the investment portfolio, except when it concerns exposures to shares.

External coverages may be composed of several transactions with multiple counterparties as long as the aggregated external coverage matches exactly the internal risk transfer, and the internal risk transfer matches exactly the aggregated external coverage.

Without prejudice to meeting the aforementioned requirements, both the tranche of the internal risk transfer from the trading portfolio and the external coverage must be included in the market risk capital requirements.

ii) The internal risk transfer that covers interest rate risk in the investment portfolio must meet the following requirements: a) be carried out by an ad hoc trading desk that, for the purposes of computing the capital requirement for market risk, must: – have SEFYC approval; – be treated in a totally independent manner with respect to other trading desks (i.e., the transfer will be subject to the capital requirement for market risk applicable to the trading portfolio, separately from any other risk generated by activities in the trading portfolio); and – apply only the quantitative requirements of the P&L attribution test, as well as the backtesting test (it is not required to have operators or trading accounts assigned). b) have exact coverage, if it is an external market coverage through an intermediary agent.

If the aforementioned requirements are met, the tranche of the internal risk transfer in the investment portfolio must be included in the calculation of the interest rate risk exposure in the investment portfolio for the purposes of computing the capital requirement.

Positions originated as a result of internal risk transfers registered in the trading portfolio must observe the same prudential conditions applicable to operations carried out with external counterparties.

1.3.7.3. Internal risk transfer between positions of the trading portfolio. Internal risk transfers between positions of the trading portfolio (including exchange rate and commodity risk in the investment portfolio) will be recognized for the determination of the capital requirement for market risk, in accordance with Section 6.

Internal risk transfers managed between a trading desk and the ad hoc internal risk transfer desk of point 1.3.7.2. must meet the requirements applicable to the latter.

1.3.7.4. Internal risk transfer between operations subject to counterparty credit risk with credit valuation adjustment of the trading and investment portfolios (CVA portfolio, point 4.2.2.) and the trading portfolio. Internal risk transfers composed of tranches that cover both the counterparty credit risk of the CVA portfolio and the market risk will be excluded from the capital requirement for market risk only for the tranche linked to the counterparty credit risk. For these purposes, the requirements of item i) of point 1.3.7.2. must be met.

Internal risk transfers must be duly documented, identifying the source of the risk and its magnitude.

1.4. Prudent valuation guidelines. Guidelines are established for the prudent valuation of positions accounted for at fair value, whether assigned to the trading portfolio or the investment portfolio. These guidelines are especially important for positions for which there are no market prices or observable data to use for valuation, as well as for less liquid positions that require entities to exercise greater caution.

The following provisions do not modify the valuation criteria and procedures of accounting standards, but the SEFYC will evaluate their compliance for the purposes of calculating the capital requirement and risk management and to determine if it is appropriate to make adjustments in the valuation of less liquid positions to reflect more realistic market conditions when available information is insufficient or price transparency is inadequate.

A prudent valuation framework must include, at minimum, the following: 1.4.1. Systems and controls. Systems and controls must guarantee to the directors and/or managers of the entity and to the SEFYC that estimated values are prudent and reliable. These systems, which must be integrated with the organization's other risk management systems, must include: 1.4.1.1. Documented policies and procedures for the valuation process. This includes clear definition of the responsibilities of the areas participating in the valuation, sources to consult to obtain market information and opinion on its validity, guidelines for the use of data that, being unobservable, result from the entity's assumptions about the considerations of market participants for the determination of prices, frequency of independent valuations, timeliness of closing prices, procedures for valuation adjustments and verification procedures, both ad hoc and end-of-month; and 1.4.1.2. Clear and independent reporting lines for the responsible persons of the valuation process and the entity's board of directors, independent of those who decide and generate operations (front office).

1.4.2. Valuation methodologies. 1.4.2.1. Market valuation. Market valuation consists of valuing positions, at least daily, at prices that would allow the entity to liquidate its holdings in an orderly manner and that come from independent and easily available sources, such as prices obtained from markets, and screens and quotes provided by several independent and reputable brokers.

Market valuation must be used whenever possible. The most prudent value of the bid/ask price interval must be used, unless the entity is a significant market maker in a certain type of position and can liquidate it at an intermediate price.

For the estimation of fair value through valuation techniques, entities must maximize the use of observable data when they are relevant. However, observable data or transactions may not be relevant if they come, for example, from forced liquidations, sales in critical situations or inactive markets. In such cases, observable data may be considered, but will not be determinative.

1.4.2.2. Model valuation. When it is not possibl