Circular No. 2375 — Amends Circular No. 2062 Regarding Pension Recalculation Treatment in Life Annuity Insurance Policies under Decree Law No. 3,500 of 1980

1 REF: Modifies Circular No. 2062, which instructs regarding the treatment of pension recalculation, in life annuity insurance policies of D.L. No. 3,500, of 1980.

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CIRCULAR No. 2375 August 20, 2026 To all insurance and reinsurance entities of the second group This Commission, in exercise of the powers conferred by Articles 5 No. 1, Article 20 No. 3 and 21 No. 1 of Decree Law No. 3,538; in Articles 5, 5 bis, 62, 64, 66, 67 and 70 of D.L. No. 3,500 of 1980; and, as agreed by the Council of the Commission in Ordinary Session No. 509, of August 13, 2026, executed through Exempt Resolution No. 8,817 of August 20, 2026, has resolved to modify Circular No. 2062 as follows:

I. The word “Superintendence” is replaced throughout the Circular by “Commission”, except when reference is being made to the Pension Superintendence.

II. In the “Seen” sections, the articles “62, 64 and 70” are replaced by “5, 5 bis, 62, 64, 66, 67 and 70”; and the expression “article 4 letter a)” by “article 5 No. 1”.

III. Chapter I. Cases in which pension recalculation is applicable, is modified, as follows:

1. The following final paragraph is added to title 2. Loss or change of beneficiary status: “If the company becomes aware that a legal pension beneficiary is in the situation indicated in Article 5 bis of D.L. No. 3,500, the following shall apply: a) If the affiliated pensioner dies, the beneficiaries must communicate the death to the Insurance Company that is paying the respective pension, so that it pays the survivor pensions that correspond. Upon knowledge, the company must proceed to recalculate the currently active reference pension, excluding the convicted beneficiary. In the event that there are no survivor beneficiaries, the reserve corresponding to the convicted beneficiary, calculated on the last day of the month in which the Pension Superintendence (SP) informed the Insurance Company, will be added to the deceased's estate mass. b) If the pensioner has not died, the currently active reference pension must be recalculated, excluding the convicted beneficiary.”.

2. The following number 4 is added: “4. Advance of the additional clause for deferred and lifelong pension increase. While the payment of the increased monthly life annuity has not begun, if the pensioner or their beneficiaries jointly decide to advance the date from which the insurance company will start its payment, the company must proceed to recalculate the currently active increased monthly pension. Once the company informs the insured or beneficiaries, as appropriate, of the amount of the new pension and the date on which it will begin to be paid, and formal conformity with the amount of the new increased monthly life annuity is obtained, it may effect the policy endorsement for the advance of the deferred and lifelong pension increase clause. The endorsement must indicate the monthly life annuity amount, which does not vary; the new amount of the increased monthly pension; the date on which the increased annuity payment will begin; and the resulting increase percentage due to the recalculation.”

3. The first paragraph of Chapter II. Pension Recalculation Procedure, is modified, as follows:

3.1 Letter b) Calculation is modified as follows:

a) The formula P_caus_t is replaced by the following: P_caus_t = [Sum from i=T_{t-1} to t-1 of (f_i^{t-1}(x, y1, ..., yn) / (1+r)^{i-1} * C_i^a) / (w-x)] * P_caus_{t-1} + ([Sum from i=1 to t-1 of (f_i^{t-1}(x, y1, ..., yn) / (1+r)^{i-1}) - Sum from i=1 to T_{t-1}-1 of (f_i^t(x, y1, ..., ym) / (1+r)^{i-1})] / [Sum from i=T_t to t of (f_i^t(x, y1, ..., ym) / (1+r)^{i-1} * C_i^a) / (w-x)]) * p_caus_base + Sum from k=0 to v_t of f_{Ck}^t(y_{n+1},...,y_m)

b) In the definition P_caus_{t-1}, after the period, the following is added: “If it concerns the advance of the additional clause for deferred and lifelong pension increase, it corresponds to the currently active increased monthly life annuity of the deceased affiliate. In other cases, it will correspond to the currently active monthly life annuity or the currently active increased monthly life annuity, depending on the stage in which the application of the said additional clause is.”

c) The definition P_caus_t is replaced by the following: “Recalculated reference pension of the deceased affiliate, whether the number of beneficiaries entitled to pension changes or if the deferred life annuity is advanced. In the case of old age or disability, it will correspond to the affiliate's pension; in the case of survivorship, it will correspond to the reference pension. If it concerns the advance of a deferred life annuity, it corresponds to the pension resulting from the elimination of the deferred period. If it concerns the advance of the additional clause for deferred and lifelong pension increase, it corresponds to the recalculated increased monthly life annuity. In other cases, it will correspond to the recalculated monthly life annuity or the recalculated increased monthly life annuity, depending on the stage in which the application of the said additional clause is.”

d) The following definitions are added after the definition P_caus_t: P_caus_base: In the case of the additional clause for deferred and lifelong pension increase, it corresponds to the monthly life annuity. Thus, in endorsements other than the advance of this clause, P_caus_base = 0 is fixed. T_{t-1}: In the case of the additional clause for deferred and lifelong pension increase, it corresponds to the month, counted from the recalculation date, in which the payment of the increased monthly life annuity begins, according to the conditions in effect before the endorsement. In endorsements other than the advance of this clause, T_{t-1} = 1 is fixed. T_t: In the case of the additional clause for deferred and lifelong pension increase, it corresponds to the new month, counted from the recalculation date, in which the payment of the increased monthly life annuity begins. In endorsements other than the advance of this clause, T_t = 1 is fixed.

e) The definition f_{t-1}(x, y1, ..., yn) is replaced by the following: “f_i^{t-1}(x, y1, ..., yn): Unitary flow of the currently active family group of the policy in month i, without considering flows for the burial allowance. In the case of advance of a deferred life annuity, it corresponds to the unitary flows of the contracted deferred pension. In case there is an additional clause for deferred and lifelong pension increase, and as long as there is no advance endorsement, the unitary flows must consider that, from the corresponding month, the pension increases based on the increase percentage associated with said clause.”.

f) The definition f_t(x, y1, ..., ym) is replaced by the following: “f_i^t(x, y1, ..., ym): Unitary flow of the new family group of the policy in month i, without considering flows for the burial allowance. In the case of advance of a deferred life annuity, it corresponds to the unitary flows considering the immediate payment of the life annuity (without remaining deferred period). In case there is an additional clause for deferred and lifelong pension increase, and as long as there is no advance endorsement, the unitary flows must consider that, from the corresponding month, the pension increases based on the increase percentage associated with said clause.”

g) The definition f_1^t(y_{n+1}, ..., y_m) is replaced by the following: “f_{Ck}^t(y_{n+1}, ..., y_m): Certain unitary flow (probability to apply at each instant k is 1) corresponding to the new members of the family group, for the months accrued where pension was not paid to them, applying the corresponding pension percentages, which must consider adjustments for the activation of the deferred and lifelong pension increase clause if applicable. In case the change in the beneficiary's legal position regarding the deceased signifies an increase in the legal pension percentage, in the certain flows of the recalculation formula, the difference between the new legal pension percentage and the currently paying percentage will be considered. In case it signifies a decrease in the legal pension percentage, a certain payment should not be considered in the recalculation.”

h) The last five paragraphs, following the definition yk, are replaced by the following: “That is, the pension recalculation must be carried out considering the equivalence of reserves between the situation in effect before the endorsement and the adjusted situation after the endorsement, excluding in all cases the burial allowance. For this, the general expression established in the preceding formula will be used, which allows capturing in the numerator the unitary flows of the family group in effect before the endorsement, and in the denominator the unitary flows of the family group resulting from the endorsement, incorporating, as appropriate: • The certain accrued flows of the new survivor pension beneficiaries or the percentage differentials in case of increase in pension right percentages, corresponding to the period between the date they claimed the benefit before the AFP and the date the company became aware. • In the case of advance of a deferred life annuity, the ratio between the unitary reserve of the flows of the deferred pension (original) and the unitary reserve of the flows considering the immediate payment of the life annuity (without remaining deferred period) must be calculated. • In the case of endorsements involving the additional clause for deferred and lifelong pension increase, the difference between the originally agreed months and the months modified by the endorsement for the activation of the increased life annuity must be taken into consideration. When an endorsement simultaneously involves the incorporation of beneficiaries and an advance of the increased life annuity, the recalculation must be carried out successively, applying the formulas established for each type of endorsement.”

i) The following final paragraph is added to number 2 of Chapter III. General Aspects: “The Pension Superintendence will remit the information referred to in Article 5 bis of DL No. 3500 for the purposes established in said norm.”.

4. The Annex Development of Pension Recalculation Formula, is modified, as follows:

4.1 The formula “ ” is replaced by the following “F_i = F_i(P_caus) + G_i(CM)”.

4.2 Wherever the unitary flows “f(x, y1, ..., yn), f_{t-1}(x, y1, ..., yn), f_t(x, y1, ..., ym), f_1^t(x, y1, ..., ym), g(x), g_t(x) and g_{t-1}(x)” appear, they are replaced by the following “f_i(x, y1, ..., yn), f_i^{t-1}(x, y1, ..., yn), f_i^t(x, y1, ..., ym), f_{Ck}^t(x, y1, ..., ym), g_i(x), g_i^t(x) and g_i^{t-1}(x)” respectively.

4.3 In the paragraph beginning with “In the case of advance of a deferred annuity”, the equations: “ ” are replaced by the following: “ Sum from i=1 to w-x of f_i^{t-1}(x, y1, ..., yn) = (0 + ... + 0 + a_{z+1} + ... + a_{w-x}) Sum from i=1 to w-x of f_i^t(x, y1, ..., ym) = (a_1 + ... + a_z + a_{z+1} + ... + a_{w-x}) ”

4.4 The following is added after the last paragraph: “In the case of advance of the additional clause for deferred and lifelong pension increase, the reserve at t must be established considering that the pension payment is decomposed into two periods, one in which the monthly life pension (P_caus_base) is paid and another in which the increased life pension (P_caus_t) is paid: R_t = Sum from i=1 to T_{t-1} of (f_i^t(x, y1, ..., ym) / (1+r)^{i-1}) * P_caus_base + Sum from i=T_t to w-x of (f_i^t(x, y1, ..., ym) / (1+r)^{i-1}) * P_caus_t + Sum from i=1 to w-x of (g_i^t(x) * CM / (1+r)^{i-1}) R_{t-1} = Sum from i=1 to T_{t-1}-1 of (f_i^{t-1}(x, y1, ..., yn) / (1+r)^{i-1}) * P_caus_base + Sum from i=T_{t-1} to w-x of (f_i^{t-1}(x, y1, ..., yn) / (1+r)^{i-1}) * P_caus_{t-1} + Sum from i=1 to w-x of (g_i^{t-1}(x) * CM / (1+r)^{i-1}) Considering that R_t = R_{t-1} and that the conditions of the deceased do not change, i.e., g_t(x) = g_{t-1}(x), and solving for the increased pension of the deceased, we have: Sum from i=1 to T_{t-1} of (f_i^t(x, y1, ..., ym) / (1+r)^{i-1}) * P_caus_base + Sum from i=T_t to w-x of (f_i^t(x, y1, ..., ym) / (1+r)^{i-1}) * P_caus_t = Sum from i=1 to T_{t-1}-1 of (f_i^{t-1}(x, y1, ..., yn) / (1+r)^{i-1}) * P_caus_base + Sum from i=T_{t-1} to w-x of (f_i^{t-1}(x, y1, ..., yn) / (1+r)^{i-1}) * P_caus_{t-1} Solving for P_caus_t leads to: P_caus_t = [Sum from i=T_{t-1} to w-x of (f_i^{t-1}(x, y1, ..., yn) / (1+r)^{i-1}) * P_caus_{t-1} + (Sum from i=1 to T_{t-1}-1 of (f_i^{t-1}(x, y1, ..., yn) / (1+r)^{i-1}) - Sum from i=1 to T_{t-1} of (f_i^t(x, y1, ..., ym) / (1+r)^{i-1})) * P_caus_base] / [Sum from i=T_t to w-x of (f_i^t(x, y1, ..., ym) / (1+r)^{i-1})] ”

Validity This Circular will enter into force as of September 1, 2026. CATHERINE TORNEL LEÓN PRESIDENT COMMISSION FOR THE FINANCIAL MARKET