Rule · BCRA · 17 Nov 2017 · A 6374
Financial entities must maintain preferred guarantee documentation with security safeguards for Superintendence verification. Discount portfolios require 85% normal debtors, max 15% category 2, and max 20% per obligor, capped at 15% of prior month’s equity. Daily limits restrict single-obligor exposure to 2.5% of equity and 5% of average balances, with a global 100% cap. Unpaid amounts cannot exceed 100% of the appraisal margin. Real estate trust guarantees require fiduciary ownership, priority collection clauses, and specific construction permits and land ownership certificates.
"2017 - YEAR OF RENEWABLE ENERGIES
COMMUNICATION “A” 6374 17/11/2017
TO FINANCIAL ENTITIES:
Ref.: Circular
LISOL 1 - 766
Guarantees. Adjustments.
We address ourselves to you to inform you that this Institution adopted the following resolution:
“1. Replace the first paragraph of point 1.1., points 1.1.6. and 1.1.11., the first paragraph of point 1.2., point 2.2. and the second paragraph of point 3.1. of the norms on “Guarantees” with the following:
1.1. Preferred “A”.
“They are constituted by the assignment or pledge of rights regarding titles or documents of any nature that, reliably instrumented, ensure that the entity can dispose of funds in concept of cancellation of the obligation contracted by the client, without needing to previously require payment from the debtor since the effectiveness depends on solvent third parties or on the existence of markets in which the mentioned titles or documents, or the effects they represent, can be liquidated directly, whether their maturity coincides or is subsequent to the maturity of the loan or the periodic payments committed or that the proceeds be applied to the cancellation of the debt or transferred directly to the entity for that purpose.” “1.1.6. Guarantees and letters of credit issued by banks abroad or multilateral development banks that comply with what is provided in point 3.1. of the norms on “Credit Evaluations” –requiring for that effect international risk rating “A” or higher–, that are not the parent company or controlling company and its subsidiaries and branches, or controlled entities or branches of the local entity, or that maintain other forms of linkage, regardless of the term of the operation, insofar as they are unrestricted and that the crediting of funds is effected immediately upon simple request of the beneficiary entity.” “1.1.11. Direct guarantees issued by central governments, agencies or departments of central governments of countries members of the Organisation for Economic Co-operation and Development (O.E.C.D.) that have an international risk rating “A” or higher.”
1.2. Preferred “B”.
“They are constituted by real rights over assets or commitments of third parties that, reliably instrumented, ensure that the entity can dispose of funds in concept of cancellation of the obligation contracted by the client, having previously complied with the procedures established for the execution of the guarantees.”
-2-
“2.2. Supporting documentation.
The supporting documentation of preferred guarantees must be kept in a predetermined place of the entity or of an external service provider for archiving.
It may also be kept on magnetic, electronic media or other similar technology, in accordance with what is provided in point 1.1.5. of the norms on “Credit Management”.
In all cases, adequate security safeguards must be available, and at all times the documentation must be at the disposal of the Superintendence of Financial and Exchange Entities for its eventual verification.”
3.1. Coverage margins.
“Preferred guarantees shall be calculated according to the percentages established in this section. If they are Preferred “A” guarantees on financings that exceed one year of validity, 10 percentage points shall be deducted from the coverage margin, except those corresponding to points 1.1.1. and 1.1.3. –in both cases, when the guarantee is constituted in the currency of the credit operation–, 1.1.4., 1.1.6., 1.1.10., 1.1.11.,
1.1.15. and 1.1.16.”
2. Repeal the second paragraph of points 1.1.1., 1.1.3., 1.1.12. and point 1.2.7. of the norms on “Guarantees”.
3. Establish that these provisions shall be applicable to operations that are contracted from the day following the date of publication of this communication.”
On the other hand, we send you attached the sheets that, in replacement of those previously provided, correspond to incorporate into the reference norms. Likewise, it is recalled that on the website of this Institution www.bcra.gob.ar, accessing “Financial System - LEGAL AND REGULATORY FRAMEWORK - Ordering and Summaries - Ordered texts of general regulation”, the modifications made with text highlighted in special characters (strikethrough and bold) will be found. We salute you attentively. CENTRAL BANK OF THE ARGENTINE REPUBLIC Darío C. Stefanelli Agustín Torcassi Principal Manager of Issuance and Normative Applications General Manager of Norms
ANNEX
1.1. Preferred “A”.
They are constituted by the assignment or pledge of rights regarding titles or documents of any nature that, reliably instrumented, ensure that the entity can dispose of funds in concept of cancellation of the obligation contracted by the client, without needing to previously require payment from the debtor since the effectiveness depends on solvent third parties or on the existence of markets in which the mentioned titles or documents, or the effects they represent, can be liquidated directly, whether their maturity coincides or is subsequent to the maturity of the loan or the periodic payments committed or that the proceeds be applied to the cancellation of the debt or transferred directly to the entity for that purpose. Included in this category, with the character of exhaustive enumeration, are the following:
1.1.1. Guarantees constituted in cash, in pesos, or in the following foreign currencies: US dollars, Swiss francs, British pounds, yen and euros, taking into account permanently their quotation value.
1.1.2. Guarantees constituted in gold, taking into account permanently its quotation value.
1.1.3. Pledges of certificates of fixed-term deposits issued by the financial entity itself, constituted in the currencies referred to in point 1.1.1.
1.1.4. Automatic reimbursements of export operations, charged to the Central Bank of the Argentine Republic (BCRA), in accordance with the respective bilateral or multilateral agreement regimes, regardless of the term of the operation.
1.1.5. Guarantees or pledges of national public securities or monetary regulation instruments of the BCRA, contemplated in the volatility list published monthly by this Institution.
1.1.6. Guarantees and letters of credit issued by banks abroad or multilateral development banks that comply with what is provided in point 3.1. of the norms on “Credit Evaluations” –requiring for that effect international risk rating “A” or higher–, that are not the parent company or controlling company and its subsidiaries and branches, or controlled entities or branches of the local entity, or that maintain other forms of linkage, regardless of the term of the operation, insofar as they are unrestricted and that the crediting of funds is effected immediately upon simple request of the beneficiary entity.
Version: 9th COMMUNICATION “A” 6374
Validity:
18/11/2017
GUARANTEES
B.C.R.A.
Section 1. Classes.
1.1.7. “Warrants” on fungible goods that have normal and habitual quotation in local or international markets, of wide dissemination and easy access to public knowledge.
1.1.8. Guarantees constituted by the assignment of collection rights on invoices to consumers for services already rendered, issued by service provider companies (companies that supply electricity, gas, telephone, water, etc.), provided that it is a set of invoices representing a quantity no lower than 1,000 clients.
1.1.9. Guarantees constituted by the assignment of collection rights regarding credit card coupons.
1.1.10. Credit instruments (deferred payment checks, promissory notes, bills of exchange and credit invoices) discounted with responsibility for the assignor, insofar as the following conditions are observed:
1.1.10.1. In the set of operations carried out with each assignor, it must be verified with respect to some of the subjects legally obliged to pay different from the assignor:
a) That at least 85%, measured in relation to the nominal value of the documents, are classified in “normal situation” (category 1) according to the latest information available in the “Central Debtors of the Financial System”. b) That, as a maximum, 15%, measured in relation to the nominal value of the documents, are classified in category 2 or are persons not informed in said central. c) That, as a maximum, 20% of the nominal value of the documents corresponds to the same subject obliged to pay. This limitation will not be applicable when it comes to documents up to the equivalent of 1% of the reference amount established in point 1.4. These requirements must be observed considering the nominal value of the documents still pending maturity and the new documents to be discounted, when carrying out each discount operation.
1.1.10.2. With respect to the assigned documents, it must be verified:
a) That, in addition to the pertinent endorsement, there is record of the transfer formulated by the assignor. b) That they are appraised according to the category assigned to the subject obliged to pay in the “Central Debtors of the Financial System” –regardless of the classification of the assignor–, considering the following percentages with respect to their nominal value:
GUARANTEES
B.C.R.A.
Section 1. Classes.
Version: 10th COMMUNICATION “A” 6374
Validity:
18/11/2017
− Classified in Category 1: 100%
− Classified in Category 2 and unclassified: 90% c) That they come from sales operations or service provision corresponding to the activity of the assignor. This condition may be verified through a sworn statement made by the client or by any other means that the entity deems convenient. When the assignor client of the financial entity is a credit cooperative, mutual aid society providing economic assistance or another legal person not included in article 2° of the Law of Financial Entities, whose activity is the discounting of third-party documents, the financial entity must require said legal person to declare under oath that it has verified that the discounted instruments come from sales and/or service provision operations corresponding to the activity of each third-party client assignor of said legal person, which must be indicated in an annex to the aforementioned sworn statement. Without prejudice to what is established above, the treatment as preferred guarantee “A” will not be applicable when the third-party assignor is any of the legal persons indicated in the previous paragraph. d) That they are not replaced at maturity, and must be presented for collection. Nevertheless, their replacement –before maturity– will be admitted when with respect to the subjects obliged to pay any of the following circumstances is verified:
i) That they have requested preventive bankruptcy or their bankruptcy has been requested. ii) That they are incorporated into the “Central of rejected checks” or complaints of loss or theft have been filed before the competent authority, in accordance with what is provided in the current regulation in the jurisdiction in question, in relation to other deferred payment checks of the same holders. iii) That they register the non-payment of other credit instruments –other than the deferred payment check–, confirmed by protest, that form part of this portfolio.
1.1.10.3. The set of operations carried out with different clients must constitute a portfolio whose nominal value is up to 15% of the computable equity responsibility of the entity of the month prior to the one in question. It may exceed that limit with adjustment to the following guidelines:
GUARANTEES
B.C.R.A.
Section 1. Classes.
Version: 6th COMMUNICATION “A” 6374
Validity:
18/11/2017
a) Maximum limit of the total nominal value of documents corresponding to the same subject obliged to pay: 2.5% with respect to the computable equity responsibility of the entity of the month prior to the one in question. b) Maximum limit of the nominal value of documents corresponding to the same subject obliged to pay: 5% of this portfolio measured in average monthly daily balances of the month prior to the one in question. c) Global limit of the portfolio in nominal value: 100% of the computable equity responsibility of the entity of the month prior to the one in question. When the subjects obliged to pay are clients of the financial entity, the amount of assistance granted in accordance with this modality will be imputed to their credit margins, not being computed for the purposes of the limits established above. Within each period, the limits must be observed on a daily basis.
1.1.10.4. In the portfolio discounted by a certain client, the unpaid amount by the client of the unpaid documents and of the checks whose registration has been rejected, cannot exceed the equivalent to 100% of the remaining appraisal margin. In case of exceeding that value, the assignor cannot access new operations of discounting credit instruments within this modality, except in the measure necessary to replenish the amount of those unpaid documents. Once the entire portfolio of the client is cancelled, the entity may grant them financements adjusted to this regime.
In all cases where this point mentions “subject/s obliged to pay”, it refers to any of the signatory persons of the documents who hold that condition in their capacity as drawer, endorser, acceptor or guarantor.
1.1.11. Direct guarantees issued by central governments, agencies or departments of central governments of countries members of the Organisation for Economic Co-operation and Development (O.E.C.D.) that have an international risk rating “A” or higher.
1.1.12. Guarantees constituted by the assignment of rights over the collection of tariffs and taxes in public works concessions, provided that it does not exceed 50% of the projected income.
1.1.13. Guarantees or pledges of securities (shares or bonds) privately issued by national or foreign companies, taking into account permanently their market value, which must respond to a normal and habitual quotation in local or international markets, of wide dissemination and easy access to public knowledge.
Local issuing companies must comply with what is provided in point 2.2.1. of the norms on “Credit Evaluations”.
Foreign titles must correspond to companies that comply with what is provided in point 3.2. of the norms on “Credit Evaluations”, requiring for that effect that their debt papers have an international risk rating “A” or higher.
GUARANTEES B.C.R.A.
Section 1. Classes.
Version: 8th COMMUNICATION “A” 6374
Validity:
18/11/2017
1.1.14. Credit instruments (deferred payment checks, promissory notes, bills of exchange and credit invoices), discounted with responsibility for the assignor, in which any of the subjects legally obliged to pay, holding that condition in their capacity as drawer, endorser, acceptor or guarantor, meets at least one of the following conditions:
1.1.14.1. Register a level of indebtedness with the system equal to or greater than the equivalent to 170% of the reference amount established in point 1.4., according to the latest information available in the “Central Debtors of the Financial System” and being informed by at least two financial entities in which the indebtedness –in each of them– is at least 85% of said reference amount.
It must be classified, in said central, “in normal situation” by all financial entities and, in the case of maintaining outstanding debentures or other debt titles, verify what is provided in point 1.1.14.2.
The total financing granted to different assignors and assigned by the entity in this modality to the same legally obliged subject, cannot exceed 10% of the latter’s debts with the financial system, reported in the “Central Debtors of the Financial System”, nor 5% of the computable equity responsibility of the entity of the month prior to the one in question, whichever is lower. This last limit will not be observed in case that the entity has a credit file of said obliged subject, so that the operations will be computed within the assistance margins provided by the regulations applicable in the matter.
1.1.14.2. Maintain outstanding debentures or other debt titles in the local market for a sum no less than the equivalent to 90% of the reference amount established in point 1.4. and comply with what is provided in point 2.2.1. of the norms on “Credit Evaluations”.
The total financing granted to different assignors and assigned by the entity in this modality to the same legally obliged subject, cannot exceed 5% of the computable equity responsibility of the entity of the month prior to the one in question. This limit will not be observed in case that the entity has a credit file of said obliged subject, so that the operations will be computed within the assistance margins provided by the regulations applicable in the matter.
1.1.15. Guarantees granted by reciprocal guarantee societies or by public guarantee funds registered in the Registries authorized at the BCRA, regardless of the term of the operation, provided that they make effective the unpaid credits within 30 calendar days of their maturity.
1.1.16. Export credit insurance –operations without responsibility for the assignor– that cover commercial risk and, if applicable, extraordinary risks (charged to the National State, Law 20.299), including credit risk insurance “with scope of public buyer”, regardless of the term of the operation. The policy covering commercial risk must contemplate the effectiveness of credits within 180 calendar days of their maturity and be issued by:
GUARANTEES
Section 1. Classes.
Version: 10th COMMUNICATION “A” 6374
Validity:
18/11/2017
a) Local insurance companies with respect to which compliance with what is provided in point 2.2.2. of the norms on “Credit Evaluations” is met and which have reinsurance in insurance companies:
i) local with respect to which compliance with the aforementioned point 2.2.2. of the norms on “Credit Evaluations” is also verified; or ii) abroad that comply with what is provided in point 3.2. of the norms on “Credit Evaluations”, requiring for that effect international risk rating “A” or higher. The amount of reinsurance must be adjusted to the regulation issued by the Superintendence of Insurance of the Nation. b) Local branches of foreign insurance companies with respect to which compliance with what is provided in point 2.2.2. of the norms on “Credit Evaluations” is verified and their parent company complies with point 3.2. of said norms –requiring for that effect international risk rating “A” or higher–. c) Local subsidiaries of foreign insurance companies with respect to which compliance with what is provided in point 2.2.2. of the norms on “Credit Evaluations” is verified and their controlling company complies with point 3.2. of said norms –requiring for that effect international risk rating “A” or higher– and has explicitly guaranteed the obligations of the subsidiary.
1.2. Preferred “B”.
They are constituted by real rights over assets or commitments of third parties that, reliably instrumented, ensure that the entity can dispose of funds in concept of cancellation of the obligation contracted by the client, having previously complied with the procedures established for the execution of the guarantees. Included in this category, with the character of exhaustive enumeration, are the following:
1.2.1. First-degree mortgage on real estate or surface rights, and regardless of its degree of prelation provided that the entity is the creditor in all degrees. Also included are real estate and/or surface rights over which a fiduciary ownership has been constituted, insofar as the lending financial entity has been assigned –in the trust contract– the best collection priority with respect to the rest of the creditors, regardless of the modality by which that collection preference is granted.
1.2.2. Fixed pledge with first-degree registration or with displacement towards the entity on motor vehicles and agricultural, road and industrial machinery (insofar as they are registered in the pertinent national motor vehicle property registry and have a market that allows obtaining a reference value), or fixed pledge with registration on bovine livestock.
1.2.3. Floating pledge registered on:
1.2.3.1. Motor vehicles and agricultural, road, and industrial machinery (to the extent that it is instrumented over assets that have manufacturing certificates or other documents limiting the disposal of the asset, which must be retained by the entity until the cancellation of the assistance granted), or
1.2.3.2. Cattle.
1.2.4. Guarantees granted by reciprocal guarantee companies or by public guarantee funds registered in the Records authorized at the BCRA, regardless of the term of the operation, to the extent that the requirement mentioned in point 1.1.15 is not met.
1.2.5. Credits from financial leases (“leasing”) that had been agreed upon in accordance with the provisions of the Civil and Commercial Code of the Nation regarding real estate and motor vehicles and agricultural, road, and industrial machinery (to the extent that they are registered in the pertinent national register of automobile property and have a market that allows obtaining a reference value).
1.2.6. Export credit insurance, to the extent that the timeframes for the effective realization of losses due to commercial risk exceed 180 days without exceeding 270 days counted continuously from the maturity of the credits, regardless of the term of the operation, and the other precautions provided for in point 1.1.16 are observed.
1.2.7. Guarantee trusts constituted in accordance with the provisions of the Civil and Commercial Code of the Nation (article 1666 and following) with the object of backing the payment of financing granted for the construction of real estate, provided that, at a minimum, the following requirements are verified:
1.2.7.1. The holder of the title cedes to the guarantee trust the real estate on which the construction of the project will take place and the rights and other assets resulting from the execution and completion of the works and their marketing in fiduciary ownership, with the scope agreed upon in the trust contract.
1.2.7.2. The proceeds from said marketing shall be destined to the partial or total cancellation of the obligations incurred by the borrower in connection with the financing agreed upon under the terms established in the trust contract.
1.2.7.3. The trustee has broad powers to effectively control the tasks provided for in point 1.2.7.1., as well as to remove from their functions the natural or legal persons who have been designated to carry them out and appoint their replacements, in case of non-compliance or poor performance of their functions.
1.2.7.4. The ceded assets are free of encumbrances.
GUARANTEES
B.C.R.A.
Section 1. Classes.
Version: 10th COMMUNICATION “A” 6374
Validity:
18/11/2017
1.2.7.5. In cases where there are other beneficiaries in addition to the lending financial entity, the respective contracts contemplate a clause establishing that in the event of default, by the borrower, of the payment –partial or total– of the financing granted, the lending/beneficiary financial entity shall have priority in collection against the remaining beneficiaries of the product of the trust.
1.2.7.6. The deed of fiduciary transfer of the trustor’s real estate properties and the trust contracts contain a clause by which the settlor grants in advance the required consent such that in the event that the objective conditions of default contained in the trust contract are verified, the trustee is enabled to dispose of the asset and transfer its full ownership, with the corresponding registry effect.
1.2.7.7. In the preliminary sales contract for the assets resulting from the project, whose model will be included in an annex forming part of the guarantee trust contract, it must be indicated through a specific clause that there is fiduciary ownership over the real estate on which the construction develops, in which the identification data of the trustee of the guarantee trust will be recorded.
1.2.8. Pledge or assignment in guarantee –including fiduciary– of the preliminary sales contract of plots, lots or parcels –whether urban or rural–, or of warehouses, premises, offices, garages and already built housing with respect to which a mortgage cannot be constituted because the real estate is not registered in the real estate registry of the corresponding jurisdiction. This, to the extent that the total price of the real estate is paid, possession is delivered to the purchaser and there is an irrevocable power to execute the deed –with signature certified by a public notary– in favor of the latter.
1.2.9. Pledge or assignment in guarantee of rights over real estate developments implemented through trusts –under the terms of article 1666 and following of the Civil and Commercial Code of the Nation– or construction companies, provided that the existence of the following elements is verified:
1.2.9.1. Notarized copy by a notary of the corresponding contract instrumented by public deed, from which arises the obligation of the trustee or the company –as applicable– to carry out the work to which the guarantee is attributed for financing.
1.2.9.2. Certificate of ownership of the land issued by the corresponding Real Property Registry, from which arises ownership in favor of the trustee or the construction company. In its absence, a preliminary sales contract instrumented by public deed with an age no greater than 6 months, through which the trustee or the construction company had canceled, at minimum, 60% of the purchase value of the land.
1.2.9.3. Permit or authorization for construction, granted by the corresponding jurisdictional authority for the start of construction.
GUARANTEES
B.C.R.A.
Section 1. Classes.
Version: 14th COMMUNICATION “A” 6374
Validity:
18/11/2017
1.2.9.4. The contract, whose rights are the subject of the pledge or assignment, must contemplate clauses whereby the borrowers authorize or grant mandate to the lending financial entity so that the funds granted as a loan are contributed or entrusted, as the case may be, with the aim of carrying out the work.
The contracts that instrument the financing must clearly establish that the failure to contract an insurance in favor of the purchasers of the projected functional units, in accordance with what is provided by article 2071 of the Civil and Commercial Code of the Nation, will not deprive the financial entity of any right emerging from the financing granted. When it concerns the pledge or assignment in guarantee of rights over functional units for financings granted directly to the purchasers, in addition to the previously mentioned requirements, it will be required: i) the presentation of a notarized copy by a notary of the instruments by which those rights were constituted in favor of the respective purchasers and ii) a copy of the approved building plan by the competent authority in which it is observed that the totality of the projected functional units that will be subdivided appears.
1.3. Remaining guarantees.
The guarantees not explicitly included in the preceding points, such as the mortgage in a rank other than first and the pledge or caution of shares or commercial documents and the encumbrances constituted abroad with adjustment to legislations different from the local one –except for the cases expressly provided–, will be considered non-preferred.
1.4. Reference amount.
The amount to be considered will be the maximum level of value of total annual sales for the “Micro” category corresponding to the “Commerce” sector, according to point 1.1. of the rules on “Determination of the condition of micro, small or medium enterprise”. GUARANTEES B.C.R.A.
Section 1. Classes.
Version: 7th COMMUNICATION “A” 6374
Validity:
18/11/2017
2.1. Consideration of preferred guarantees.
Preferred guarantees are considered such only as long as circumstances do not occur that, by affecting the quality, the possibilities of realization, the legal situation or other aspects related to the encumbered assets, decrease or nullify their realization value, negatively impacting the integrity and/or effectiveness of the guarantee. Special and permanent attention shall be paid to ensure that the credit rating of third parties legally obligated in the situations provided for in point 1.1. corresponds to the established levels, immediately de-allocating operations when, due to subsequent modifications, the ratings result in lower than the minimums fixed.
2.2. Supporting documentation.
The supporting documentation of preferred guarantees must be kept in a predetermined place of the entity or of an external service provider for archiving. It may also be kept on magnetic, electronic or similar technology media, in accordance with what is provided for in point 1.1.5. of the rules on “Credit management”. In all cases, adequate security safeguards must be available, and at all times, the documentation must be available to the Superintendency of Financial and Currency Entities for its eventual verification. GUARANTEES B.C.R.A.
Section 2. Conditions.
Version: 3rd COMMUNICATION “A” 6374
Validity:
18/11/2017
3.1. Coverage margins.
For their determination in operations covered with preferred guarantees “A” contracted under figures other than discount, the amount of capital and interest will be taken into account.
Preferred guarantees will be computed by the percentages established in this section. If they are preferred guarantees “A” on financings that exceed one year of validity, 10 percentage points will be deducted from the coverage margin, except those corresponding to points 1.1.1. and 1.1.3. –in both cases, when the guarantee is constituted in the currency of the credit operation–, 1.1.4., 1.1.6., 1.1.10., 1.1.11., 1.1.15. and 1.1.16.
3.1.1. Cash (point 1.1.1.).
3.1.1.1. In pesos:
i) For coverage of an operation in pesos: 100 %. ii) For coverage of an operation in foreign currency: 80 % of the quotation value.
3.1.1.2. In foreign currency:
i) For coverage of an operation in pesos: 80 % of the quotation value. ii) For coverage of an operation in the same foreign currency: 100 %. iii) For coverage of an operation in a different foreign currency: 80 % of the quotation value.
3.1.2. Gold (point 1.1.2.): 90 % of the realization value.
3.1.3. Certificates of time deposits (point 1.1.3.).
3.1.3.1. In pesos:
i) For coverage of an operation in pesos: 100 %. ii) For coverage of an operation in foreign currency: 80 % of the quotation value, calculated on the imposed capital.
3.1.3.2. In foreign currency:
i) For coverage of an operation in pesos: 80 % of the quotation value, calculated on the imposed capital. ii) For coverage of an operation in the same foreign currency: 100 %.
GUARANTEES
B.C.R.A.
Section 3. Computation.
Version: 4th COMMUNICATION “A” 6374
Validity:
18/11/2017
ORDERED TEXT ORIGIN NORM
Section Point Paragraph Com. Annex Point Paragraph
OBSERVATIONS
1.1. “A” 2932 unique 1.1. According to Com. “A” 4242 and 6374.
1.1.1. “A” 2216 I 1. 3°, a) According to Com. “A” 2443, 2932,
3918, 4242 and 6374.
1.1.2. “A” 2216 I
1.
3°, a) According to Com. “A” 2443, 2932 and
3918.
1.1.3. “A” 2216 I 1. 3°, b) According to Com. “A” 2932, 3918,
4242 and 6374.
1.1.4. “A” 2216 I 1. 3°, c) According to Com. “A” 2932 and 4242.
1.1.5. “A” 2216 I 1. 3°, d) According to Com. “A” 2932, 4741 and
6091.
1.1.6. “A” 2216 I 1. 3°, e) According to Com. “A” 2932, 3918,
4242, 5671, 5740, 6328 and
6374.
1.1.7. “A” 2216 I 1. 3°, g) According to Com. “A” 2932.
1.1.8. “A” 2216 I 1. 3°, h) According to Com. “A” 2932.
1.1.9. “A” 2216 I 1. 3°, i) According to Com. “A” 2932.
1.1.10. “A” 2932 unique 1.1.11. According to Com. “A” 3104, 4242,
4522, 4957 and 5998.
1.1.11. “A” 2932 unique 1.1.12. According to Com. “A” 4141, 5671,
5740 and 6374.
1.1.12. “A” 2932 unique 1.1.13. According to Com. “A” 4242 and 6374.
1.1.13. “A” 2932 unique 1.1.14. According to Com. “A” 3918, 5671 and
5740. Includes interpretative clarification.
1.1.14. “A” 3114 1.
1.1.14.1. 1° “A” 3114 According to Com. “A” 3918, 4055,
5671, 5740 and 5998. Includes interpretative clarification.
1.1.14.2. “A” 3114 1. According to Com. “A” 3918, 4055,
5671, 5740 and 5998.
1.1.15. “A” 3141 According to Com. “A” 3307, 3918,
4465 and 5275.
1.1.16. “A” 3314 According to Com. “A” 4529, 5671 and
5740.
1.2. “A” 2932 unique 1.2. According to Com. “A” 3104 and 6374.
1.2.1. “A” 2419 1. 1° According to Com. “A” 2563 (points
GUARANTEES
ORDERED TEXT ORIGIN NORM
Section Point Paragraph Com. Annex Point Paragraph
OBSERVATIONS
1.2.7. “A” 4491 1. According to Com. “A” 4501, 5998 and
6250.
1.2.8. “A” 6250 According to Com. “A” 6297.
1.2.9. “A” 6250 According to Com. “A” 6297.
1.3. “A” 7 Specifications of the items of “other guarantees received”, modified by Com. “A”
2932.
1.
1.4. “A” 5998 1.
1° “A” 2448 Statement of position of debtors (point 6.1.2.2.2.).
2.1.
2° “A” 2932 unique 2.1. 2°
2.
2.2. “A” 2216 I 1. 4° According to Com. “A” 6374.
3.1. “A” 2932 unique 3.1. According to Com. “A” 6374.
3.1.1. “A” 2932 unique 3.1.1. According to Com. “A” 3918.
3.1.2. “A” 2932 unique 3.1.2.
3.1.3. “A” 2932 unique 3.1.3. According to Com. “A” 3918.
3.1.4. “A” 2932 unique 3.1.4.
3.1.5. “A” 2932 unique 3.1.5. According to Com. “A” 3918, 4242 and
4741.
3.1.6. “A” 2932 unique 3.1.6. According to Com. “A” 3918 and 6328.
3.1.7. “A” 2216 I 1. 3°, g) According to Com. “A” 2932.
3.1.8. “A” 2216 I 1. 3°, h) According to Com. “A” 2932.
3.1.9. “A” 2216 I 1. 3°, i) According to Com. “A” 2932.
3.1.10. “A” 2932 unique 3.1.11. According to Com. “A” 3104 and 4522.
3.1.11. “A” 2932 unique 3.1.12. According to Com. “A” 3918.
3.1.12. “A” 2932 unique 3.1.13.
3.1.13. “A” 2932 unique 3.1.14.
3.1.14. “A” 2419 1. 1º, ii) According to Com. “A” 2932, 3314,
3918, 4551 (point 2.), 4559
(point 3), 5998 and 6297.
3.1.15. “A” 2932 unique 3.1.18. According to Com. “A” 3918 and 6162.
3.1.16. “A” 6162 4.
3.1.17. “A” 2932 unique 3.1.19. According to Com. “A” 3141, 3918,
4242, 4465 and 5275.
3.1.18. “A” 3114 2. According to Com. “A” 4242.
3.1.19. “A” 3259 2. According to Com. “A” 5067.
3.1.19.1. “A” 4559 5. According to Com. “A” 5998.
3.1.19.2. “A” 4559 5. According to Com. “A” 5998.
3.1.19.3. “A” 3259 2. According to Com. “A” 3314, 3918 and
4559 (point 5.).
3.1.19.4. “A” 3259 2. According to Com. “A” 3918 (point
4.).
3.1.19.5. “A” 3259 2. According to Com. “A” 3314 (point
3.).
3.1.19.6. “A” 3314 6.
3.1.20. “A” 3314
3.1.21. “A” 4491 1. According to Com. “A” 4501.
3.1.22. “A” 6250
3.
3.1.23. “A” 6250 According to Com. “A” 6297.
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