Circular OPRAC 1-724 / LISOL 1-596: Credit Management, Borrower Classification, Consolidated Supervision, and Modifications — BCRA — AR

2014 - YEAR OF TRIBUTE TO ADMIRAL GUILLERMO BROWN, ON THE BICENTENNIAL OF THE NAVAL BATTLE OF MONTEVIDEO

COMMUNICATION “A” 5557 28/02/2014

TO FINANCIAL ENTITIES,
TO RECIPROCAL GUARANTEE COMPANIES,
TO NON-FINANCIAL ENTERPRISES ISSUING CREDIT CARDS, TO ADMINISTRATORS OF CREDIT PORTFOLIOS OF EX-FINANCIAL ENTITIES, TO TRUSTEES OF FINANCIAL TRUSTS INCLUDED IN THE FINANCIAL ENTITIES LAW, TO PUBLIC GUARANTEE FUNDS:

Ref.: Circular
OPRAC 1 - 724
LISOL 1 - 596
Credit Management. Borrower Classification. Consolidated Supervision. Modifications.

We address you to inform you that this Institution adopted the following resolution:

“1. Replace item ii) of subsection a) of point 1.1.3.3. of Section 1. of the norms on “Credit Management” with the following:

“ii) Individual limit.
The outstanding capital shall in no instance exceed $ 15,000 per client, under the French or German system modality.”

Replace items i) and ii) of subsection b) of point 1.1.3.3. of Section 1. of the norms on “Credit Management” with the following:

“i) Covered borrowers.

Individuals not affiliated with the financial entity.
Micro, small, and medium enterprises (MSMEs), in accordance with the definition provided in the norms on “Determination of the status of micro, small, or medium enterprise”.

ii) Individual limit.
The outstanding capital shall in no instance exceed the following limits, by class of credit and per client:

housing mortgage loans: $ 300,000;

-2-

pawn loans for motor vehicles: $ 150,000;
personal loans and other financings -such as those granted via credit cards and current account advances-, which in total shall not exceed $ 50,000;
financings to MSMEs, which in total shall not exceed $ 150,000.”

Incorporate as item iii) of subsection b) of point 1.1.3.3. of Section 1. of the norms on “Credit Management”, the following:

“iii) Global limit for financings to MSMEs.
10% of the entity’s computable equity responsibility from the month prior to the one in question.”

Replace point 1.4.2. of Section 1. of the norms on “Credit Management” with the following:

“1.4.2. Covered clients.
Non-financial private sector clients whose debt (for all concepts) plus the amount of the financing requested, at the time of granting, exceeds 2.5% of the entity’s computable equity responsibility from the last day of the month prior to the one in question, or the equivalent of $ 4,000,000, whichever is lower.”

Replace the tenth paragraph of point 3.4.2. of Section 3. of the norms on “Borrower Classification” with the following:

“In the case of non-financial private sector clients whose debt (for all concepts) plus the amount of the financing requested, at the time of granting, exceeds 2.5% of the entity’s computable equity responsibility from the last day of the month prior to the one in question, or the equivalent of $ 4,000,000, whichever is lower, a sworn declaration regarding whether they are or are not affiliated with the respective financial intermediary, or whether their relationship with it implies the existence of controlling influence, must be kept in the file, permanently available to the Superintendence of Financial and Exchange Entities.”

Replace the first paragraph of point 6.5.6.3. of Section 6. of the norms on “Borrower Classification” with the following:

“6.5.6.3. Non-financial private sector clients whose debt (for all concepts) plus the amount of the financing requested, at the time of granting, exceeds 2.5% of the entity’s computable equity responsibility from the last day of the month prior to the one in question, or the equivalent of $ 4,000,000, whichever is lower, and who have not submitted a sworn declaration regarding whether they are or are not affiliated with the respective financial intermediary, or whether their relationship with it implies the existence of controlling influence, or have not updated the previously submitted one, with the exception of debtors in bankruptcy or with an out-of-court preventive agreement requested or in judicial management, who, for a period of up to 540 days counted from the opening of the bankruptcy, request for preventive agreement, or start of judicial collection proceedings, as applicable, have not presented the documentation allowing it, provided that a lawyer’s report from the creditor financial entity on the reasonableness of the recovery of the included credits is available.”

-3-

Replace point 5.2.1.6. of Section 5. of the norms on “Consolidated Supervision”, with the following:

“5.2.1.6. Maximum global limits, in accordance with the norms on “Credit Management” for:
a) Reduced-amount loans. b) Loans for micro-entrepreneurs. c) Loans for micro, small, and medium enterprises (from item iii) of subsection b) of point 1.1.3.3.).”

Finally, we send you the sheets that, in replacement of those previously provided, must be incorporated into the referenced norms. Likewise, it is recalled that on this Institution’s website www.bcra.gob.ar, accessing “regulations” (“organized texts”), the modifications made with texts highlighted in special characters (strikethrough and bold) will be found.

We salute you attentively.

BANCO CENTRAL DE LA REPÚBLICA ARGENTINA
Matías A. Gutiérrez Girault Alfredo A. Besio
Manager of Emission
Manager of Norms
Deputy General Manager of Norms

ANNEX

The policy that each entity adopts to define the credit margins it assigns to each client must be approved by its Board of Directors or equivalent authority.

iii) In the case of correspondents, the file must contain the information and other elements of judgment that allow knowing their identification, qualification, credit margins, and any other data linked to that relationship, in accordance with what is established in the norms on “Correspondence Accounts”.

iv) In the case of loans to individuals with first-degree mortgage guarantee on a home or with first-degree pledge guarantee on automobiles or light utility vehicles 0 km for personal, commercial, or rental use, the credit folders, legal, and administrative folders must be attached to the debtor’s file when the guidelines provided in the respective origination and administration manuals are observed.

v) When the contracting of a life insurance on outstanding balance is provided for, the file must contain the record of the exercise of the option provided for in point 2.3.11. of the norms on “Protection of users of financial services” and the identification of the policy contracted for that effect, the respective original must be kept available to the user.

1.1.3.3. Special operations.
a) Reduced amount.
It will only be required that the file contains the data allowing the identification of the client, in accordance with the norms on “Valid identification documents”.

i) Borrowers.
Individuals not affiliated with the financial entity, insofar as they have not received financing under the terms provided for in point 1.1.3.4., subsection a).

ii) Individual limit.
The outstanding capital, in no instance, may exceed $15,000 per client, under the French or German system modality.

iii) Global portfolio limit.
10% of the entity’s computable equity responsibility from the month prior to the one in question. This limit will be computable for the purposes of calculating the global limit provided for in point 1.1.3.4., subsection a), item iii), in the case that the entity has also granted financings under that modality (loans for micro-entrepreneurs).

iv) Maximum payment frequency.
The frequency of payment installments shall not be for a period greater than monthly.

Version 11a. COMMUNICATION “A” 5557
Validity:
01/03/2014

CREDIT MANAGEMENT
B.C.R.A.
Section 1. Requirements for granting financings.

i) Covered borrowers.

Individuals not affiliated with the financial entity.
Micro, small, and medium enterprises (MSMEs), in accordance with the definition provided in the norms on “Determination of the status of micro, small, or medium enterprise”.

ii) Individual limit.
The outstanding capital shall in no instance exceed the following limits, by class of credit and per client:

housing mortgage loans: $ 300,000;
pawn loans for motor vehicles: $ 150,000;
personal loans and other financings -such as those granted via credit cards and current account advances-, which in total shall not exceed $ 50,000;
financings to MSMEs, which in total shall not exceed $ 150,000.

iii) Global limit for financings to MSMEs.
10% of the entity’s computable equity responsibility from the month prior to the one in question.

iv) Client classification and information to the Debtors Central of the Financial System.
It will be carried out based on objective guidelines as established in Section 7. of the norms on “Borrower Classification”.

v) The client’s file must record the evaluation carried out according to this procedure.
Likewise, it may contain other elements that the financial entity, at its discretion, deems necessary for credit evaluation, without this constituting a necessary condition for its application.

Entities must carry out a detailed description of the procedure adopted for client evaluation and the assignment of credit margins, discriminated, as applicable, according to the class of credit.

vi) This procedure must have the prior opinion of:

Highest-ranking official of the credit or commercial area responsible for deciding on credit matters.
General Manager or equivalent authority.
Credit Committee, unless it does not exist in the entity’s functional structure.

CREDIT MANAGEMENT
B.C.R.A.
Section 1. Requirements for granting financings.
Version:10a. COMMUNICATION “A” 5557
Validity:
01/03/2014

Likewise, it will be necessary to have the approval of the aforementioned procedure by the Board of Directors, Board of Administration, or equivalent authority of the financial entity.

vii) In cases where the evaluation of payment capacity is carried out directly based on supporting documentation of the borrower's income or where the provision of the fourth paragraph of point 1.1.3.1. applies, even if the methods indicated in this section are used complementarily, the provisions on file content established in point 1.1.3.1. must be observed.

1.1.3.4. Loans for micro-entrepreneurs and financings to Microcredit Institutions.
a) Loans for micro-entrepreneurs.
These are understood as loans destined for low-income individuals to attend needs linked to productive, commercial, and service activities, training for micro-entrepreneurs, and financings destined for the improvement of the only and family residence, in which specific methodologies are used for prior evaluation, granting, and follow-up of financial assistance in order to what is contemplated in item v) of this point.

Complementarily and to the extent that they have available financing margin within this class of credit, credits for the acquisition of goods or services for consumption may be granted to the micro-entrepreneur.

i) Borrowers.
Individuals or associative groups of individuals who carry out self-employed activities, not affiliated with the financial entity.

Borrowers who have received financial assistance under this modality shall not have access to the reduced-amount financings referred to in point 1.1.3.3., subsection a).

ii) Individual limit.
The outstanding capital shall in no instance exceed $ 60,000 per client. In the event that the client already has a credit granted as provided for in point 1.1.3.3., subsection a), the residual outstanding capital for both types of financings shall not exceed the aforementioned limit.

iii) Global limit for financings.
30% of the entity’s computable equity responsibility from the month prior to the one in question.
5% of the entity’s computable equity responsibility from the month prior to the one in question, with respect to the total of financings in which the periodicity of some/installments is greater than 90 days or has grace periods greater than that term.

CREDIT MANAGEMENT
B.C.R.A.
Section 1. Requirements for granting financings.
Version:10a. COMMUNICATION “A” 5557
Validity:
01/03/2014

The total of financings granted under the modalities established in points 1.1.3.3., subsection a), -without exceeding the specific limit of 10%- and 1.1.3.4., subsection a), shall not exceed the cited limit of 30%.

iv) Installment periodicity.
Based on the economic cycles corresponding to the activity developed by the client.

v) Origination of credits and evaluation and follow-up criteria.
The granting of financings may be carried out directly to the credit applicant or through the management of legal entities that meet the characteristics provided for in subsection b) of this point.

For the prior evaluation, granting, and follow-up of financial assistance under this modality, credit methodologies must be used that provide, among other techniques, the following:

observation of quantitative and qualitative aspects to determine the clients' repayment capacity,
credit evaluation, follow-up, and/or collection carried out “in-situ”,
granting of group credits,
granting of sequential credits (agreement of a first small-amount short-term credit, which once cancelled, may be granted in larger amounts and terms and/or lower interest rates, based on compliance with assumed obligations).

vi) Client classification and information to the Debtors Central of the Financial System.
The debtor's classification must be carried out in accordance with the periodicity and other conditions established for the consumption or housing portfolio, as established in Section 7. of the norms on “Borrower Classification”.

vii) In cases where the evaluation of payment capacity is carried out directly based on supporting documentation of the borrower's income, even if the methods indicated in this point are used complementarily, the provisions on file content established in point 1.1.3.1. must be observed.

b) Financings to Microcredit Institutions. i) Borrowers.
Legal entities, not affiliated with the financial entity (except those companies in which the financial entity maintains participation in their capital under the terms provided for in point 2.2.21. of the norms on “Complementary services of the financial activity and permitted activities”), whose corporate object and main activity is the carrying out of microcredit activities, in accordance with the definition of subsection a) of this point, destined for the individuals referred to in said subsection in item i).

CREDIT MANAGEMENT
B.C.R.A.
Section 1. Requirements for granting financings.
Version: 9a. COMMUNICATION “A” 5557
Validity:
01/03/2014

Its provision may additionally include the provision of technical assistance, follow-up, and training services to credit takers for the development of their business capacity, which must meet the following requirements:

Possess authorization to function from the competent authority according to their type and, as applicable, be registered in the relevant public registry.
Have accounting statements in accordance with applicable professional accounting standards.

ii) Regarding file content, what is provided for in point 1.1.3.1. must be observed.

1.1.4. Filing.
The debtor's file must be kept at the place of filing of the account.
It is admitted that the client's file may be in a place different from the filing of the account (for example: headquarters or branch that is the seat of regional management), when this has been determined for operational reasons -linked to the evaluation, granting, and follow-up of credits- and this circumstance is included in the “Classification and Provision Procedures Manual”.

Additionally, it will be necessary to keep a copy of the file of each of the clients whose indebtedness (included financings) is equivalent or superior to 1% of the computable equity responsibility at the entity's headquarters.

These provisions are also applicable to the annexes to the client's file.

1.1.5. Formal aspects.
The file and annexes may be kept on magnetic media.

1.2. Compliance with social security obligations.
1.2.1. Records.
The file must include demonstrative records of the degree of compliance with the client's social security obligations in accordance with the current legal provisions in the matter.

1.2.1.1. Law 14.499, article 12.

“...banking credit institutions..., will require employers, prior to granting credit..., a certificate that they do not owe any amount to the national pension funds in which they are registered, in the concept of contributions and/or contributions, or that having availed themselves of a moratorium, they are up to date in its compliance, unless the loan is requested to pay owed contributions and/or contributions.”

“The national pension funds will grant the necessary certificate, within 15 days of having been requested, except in the case that they have an impediment for it, in which case they will extend a record of the fact, with which the banking institution..., will process the management. This record will be valid for a term of 6 months.”

CREDIT MANAGEMENT
B.C.R.A.
Section 1. Requirements for granting financings.
Version: 8a. COMMUNICATION “A” 5557
Validity:
01/03/2014

1.2.5. Lifting of the inhibition.
If situations arise in which a taxpayer is affected by a credit restriction due to their status as a social security debtor, they must contact the dependency of the Federal Administration of Public Revenues in which they are registered, for the purpose that through it such status is resolved.

1.3. Registration in the National Industrial Registry.
In the case of clients carrying out any type of industrial activity, it must be recorded in the file the verification of compliance with the requirement established in article 6º of Law 19.971 in accordance with what is provided for in the norms on “Registration of clients in the National Industrial Registry to carry out certain operations”.

1.4. Sworn declaration on affiliation with the financial entity.
1.4.1. Requirement.
An updated sworn declaration regarding whether they are or are not affiliated with the respective financial intermediary, or whether their relationship with it implies the existence of controlling influence, must be kept in the files of the covered clients, permanently available to the Superintendence of Financial and Exchange Entities.

The sworn declaration must be formulated in the terms of the models contained in point 1.4.8., as applicable. This declaration will be integrated in duplicate, the one that will be delivered to the presenter with the receipt confirmation by the entity.

Financial entities are obligated to supply to the applicants the necessary information in a timely manner for the correct integration of the data contained in this declaration.

1.4.2. Covered clients.
Non-financial private sector clients, whose debt (for all concepts) plus the amount of the financing requested, at the time of granting, exceeds 2.5% of the entity’s computable equity responsibility from the last day of the month prior to the one in question, or the equivalent of $ 4,000,000, whichever is lower.

1.4.3. Scope.
For these purposes, the financings included with the scope established in the norms on “Credit risk fragmentation” will be considered.

Regarding affiliation, the definitions contained in the norms on “Credit risk fragmentation” are applicable.

CREDIT MANAGEMENT
B.C.R.A.
Section 1. Requirements for granting financings.
Version: 5a. COMMUNICATION “A” 5557
Validity:
01/03/2014

ORDERED TEXT ORIGIN OF THE NORM
Sec. Point Para. Com. Annex Ch. Sec. Point Para.
OBSERVATIONS
1.1.1. “A” 3051
1.1.2. “A” 2729 3. 3.4.1. S/Com. “A” 2950, 4972
(point 2.), 5093 and 5520.
1° “A” 49 I. 3.1. S/Com. “A” 5387.
2° “A” 5482
3° “A” 5387
4° “A” 2729 3. 3.4.2. 2° S/Com. “A” 2950.
5° “A” 2729 3. 3.4.2. 8° S/Com. “A” 2950 and 3051.
6° “A” 4972 2.
1.1.3.1.
7° “A” 3051 i) “A” 2729 3. 3.4.2. 3° S/Com. “A” 2950 and 3051. ii) “A” 2729 3. 3.4.2. 4° and 5° S/Com. “A” 2950 and 5093. iii) “A” 2729 3. 3.4.2. 7° S/Com. “A” 2950. iv) “A” 2729 3. 3.4.3. S/Com. “A” 2950. 1.1.3.2. v) “A” 5482 a) “A” 3142 1. S/Com. “A” 3182, 4325 (point 3.), 4556, 4559, 4891, 4972 and 5557. 1.1.3.3. b) “A” 4325 3. S/Com. “A” 4559, 4572, 4637, 4891, 4972 and 5557.
1.1.3.4. a) “A” 4891 2. S/Com. “A” 5226 and 5533.
b) “A” 4891 2
1.1.4. “A” 2729 3. 3.4.4. S/Com. “A” 2950.
1.1.5. “A” 2729 3. 3.4.5. S/Com. “A” 2950.
1.2.1. “A” 3051
1.2.1.1. “B” 5464
1.2.1.2. “B” 5464
1.2.2. “B” 5464 Last.
1.2.3. “B” 5664 S/Com. “A” 3051.
1.2.4. “C” 18820 S/Com. “B” 8833 and 9063.
1.2.5. “C” 18820 S/Com. “B” 9063.
1.3. “A” 2860 1. 1.1.1. S/Com. “A” 3051.
1° “A” 2573 1. 1° S/Com. “A” 3051.
2° “A” 2573 1. 5°
1.4.1.
3° “A” 2573 1. 6°
1.4.2. “A” 2573 1. 2° S/Com. “A” 3051, 4522 and
5557.
1.4.3. 1° “A” 2573 1. 3° S/Com. “A” 3051.
2° “A” 2573 1. 4°
1.4.4. “A” 2573 1. 7°
1° “A” 2573 1. 8°
2° “A” 3051
3° “A” 4972 2.
1.
1.4.5.
4° “A” 4972 2.

B.C.R.A.
ORIGIN OF THE PROVISIONS INCLUDED IN THE
ORDERED TEXT OF THE NORMS ON “CREDIT MANAGEMENT”

c) together with the receipt of payment of the fee, or

d) in the absence of the above, at the entity's option, by including this information in any general postal correspondence sent to the client or specific correspondence directed to that end.

Additionally and within the same timeframe, financial entities that provide information services to their clients via the internet ("home banking") must make known to each client -by the means indicated- the information referred to in this communication.

On the other hand, the updated balance of all financing granted -which will include facilities assigned by all subsidiaries and operational units of the entity- must be available, disaggregated by concept, according to the accounting information system used by the entity, at the place of filing of the client's file or the head office, if a copy is to be kept there, in accordance with the relevant regulations.

In the case of non-financial private sector clients whose debt (for all concepts) plus the amount of the financing requested, at the time of granting, exceeds 2.5% of the entity's last day of the previous month's computable net worth or the equivalent to $ 4,000,000, whichever is lower, a sworn declaration regarding whether they have or do not have the character of linked parties to the respective financial intermediary or if their relationship with it implies the existence of controlling influence must be kept in the file, permanently available to the Superintendency of Financial and Exchange Entities.

In the case of correspondents, the file must contain the information and other elements of judgment that allow knowing their identification, qualification, credit margins and any other data linked to that relationship, in accordance with what is established in the regulations on "Correspondence Accounts".

Furthermore, the analyses carried out as a result of the application of the regulations on credit graduation must be recorded in the files.

3.4.3. Annexes.

In the case of loans to individuals with first-degree mortgage guarantee on a home or with first-degree pledge guarantee on automobiles or light utility vehicles 0 km for personal, commercial or rental use, the credit, legal and administration folders will be attached to the debtor's file when the guidelines provided in the respective origination and administration manuals are observed.

3.4.4. Filing.

The debtor's file must be kept at the place of filing of the account.

It will be admitted that the client's file is located in a place different from the filing of the account (for example: headquarters or branch that is the seat of regional management), when this has been determined for operational reasons -linked to the evaluation, granting and monitoring of credits- and this circumstance is included in the "Manual of classification and provision procedures".

DEBTOR CLASSIFICATION

B.C.R.A.

Section 3. Classification Task.

Version: 6th. COMMUNICATION "A" 5557

Validity:

01/03/2014

Credit assistance granted through branches or subsidiaries abroad of local financial entities subject to the consolidated basis supervision regime, provided that it has been granted with resources that do not come from funds provided, directly or indirectly, by local financial entities.

The debtors previously excluded must be classified and their debts provided for in accordance with general provisions.

6.5.6.3. Non-financial private sector clients, whose debt (for all concepts) plus the amount of the financing requested, at the time of granting, exceeds 2.5% of the entity's last day of the previous month's computable net worth or the equivalent to $ 4,000,000, whichever is lower, and who have not presented a sworn declaration regarding whether they have or do not have the character of linked parties to the respective financial intermediary or if their relationship with it implies the existence of controlling influence, or have not updated the previously presented one, with the exception of debtors in bankruptcy or with a pre-judicial settlement agreement requested or under judicial management, for a period of up to 540 days counted from the opening of the bankruptcy, request for the pre-judicial settlement or start of the judicial collection proceedings, as appropriate, who have not presented the documentation that allows it, provided that there is a report from the entity's creditor financial institution lawyer on the reasonableness of the recovery of the credits included.

This, without prejudice to the fact that they are debts that meet all the conditions provided for in point 2.2.3.2. of the regulations on "Minimum provisions for uncollectible risk".

This treatment will apply from the date of granting of the assistance, when it is the first declaration, or from 1.12, in the case of subsequent updates, and until the month prior to the date on which the client makes the relevant presentation.

6.6. Mandatory Recategorization.

The debtor must be recategorized when there is a discrepancy of more than one level between the classification given by the financial entity and those given by at least two other entities or financial trusts in categories lower than that assigned by the latter, whose claims -together- represent 40% or more of the total reported by all creditors, according to the last information available in the "Central of debtors of the financial system".

The recategorization of the debtor will be carried out from the month following the making available of the relevant information of said central, at least in the immediate superior category to that in which it registers the highest level of indebtedness considering, for this purpose, that group of entities and financial trusts that represent 40% or more of the total reported by all creditors, according to the last information available in the "Central of debtors of the financial system".

DEBTOR CLASSIFICATION

B.C.R.A.

Section 6. Classification of debtors in the commercial portfolio.

Version: 6th. COMMUNICATION "A" 5557

Validity:

01/03/2014

DEBTOR CLASSIFICATION

ORDERED TEXT ORIGIN NORM

Sec. Point Para. Com. Annex Point Para.

OBSERVATIONS

3.3. last "A" 2216 I 2. 2°

1° "A" 2216 I 7. 1° According to Com. "A" 5093.

"A" 2287 3. last

2° "A" 2216 I 6. 2°

3° "A" 2216 I I.d. 3°

3.4.1.

4° "A" 4972 1. According to Com. "A" 5520.

3.4.2. "A" 467 3°

"A" 2216 I 7.

According to Com. "B" 5644, "A" 2287,

2573, 2932, 4545, 4738, 4781,

5093, 5311, 5470 and 5557. Includes

interpretative clarification.

3.4.3. "A" 2563 I II. According to Com. "A" 2677.

"A" 2586 unique II. According to Com. "A" 2677. It specifies

criterion.

1° "A" 2216 I 7. 1°

2° "A" 2216 7. last

3° "A" 2216 I 7. 2° According to Com. "A" 2223 (point 1.).

last "A" 2563 I II. According to Com. "A" 2677.

3.4.4.

"A" 2586 unique II. According to Com. "A" 2677.

3.4.5. Incorporates criterion not previously disclosed in general.

3.5. "A" 2216 I 3. 1°

3.5.1. "A" 2216 I 3. 1°

1° "A" 2216 I 3. 1°

2° "A" 2216 I 3. 2° According to Com. "A" 4972 (point 1.) and

5311.

3° "A" 2216 I 3. 3° According to Com. "A" 2223 (point 1.).

3.5.2.

last "A" 2216 I 3. last

3.5.3. Incorporates criterion not previously disclosed in general.

1° "A" 2373 8. and 3. Includes interpretative clarification.

2° "A" 2373 8.

3.6.

last "B" 5902 3. Includes interpretative clarification.

4.1. "A" 2216 I 1. 1°

4.2. "A" 2216 I 1. 2°

4.3.1. "A" 2216 I 1. 3° According to Com. "A" 2932 (point 3.).

4.3.2. "A" 2216 I 1. last

4.4. "A" 2932 4.

4.5. "A" 2932 4.

4.6. "A" 3314 8. According to Com. "A" 4529.

5.1. "A" 2216 I 6. 1°

5.1.1. 1° "A" 2216 I I. 1° According to Com. "A" 2410.

DEBTOR CLASSIFICATION

ORDERED TEXT ORIGIN NORM

Sec. Point Para. Com. Annex Point Para.

OBSERVATIONS

6.5.5. last "A" 2216 I I.d.5. According to Com. "A" 2826.

6.5.6.1. "A" 2216 I I.d.6. According to Com. "A" 2440.

6.5.6.1. i) "A" 2216 I I.d.6. i) According to Com. "A" 2440.

6.5.6.1. ii) "A" 2216 I I.d.6. ii) According to Com. "A" 2440.

6.5.6.1. iii) "A" 2216 I I.d.6. iii) According to Com. "A" 2440.

6.5.6.1. iv) "A" 2216 I I.d.6. iv) According to Com. "A" 2580.

6.5.6.1. last "A" 2440 2. last

6.5.6.2. "A" 2287 2. Modified by Com. "A" 2890 (point 3.) and 5183.

except b), 2nd

paragraph

"A" 2287 2.3. Modified by Com. "A" 2497 (point 1.) and 5183.

b),

last

paragraph

"A" 2287 2.5. Modified by Com. "A" 2497 (point 1.).

6.5.6.3. "A" 2573 1. According to Com. "A" 4545, 4972 (point

10) and 5557.

6.6.

last

"A" 2216

"A" 4060

I I.c.

10.

Modified by Com. "A" 2932 (point 6.) and 3339.

7.1. 1° "A" 2216 I II. 1º According to Com. "A" 3142, 4325 (point

1.), 4559 (point 7.), 4648, 4660,

4683, 4738 and 4972 (point 10).

7.2.1. "A" 2216 I II.1. According to Com. "A" 4648, 4660, 4683 and

4738.

7.2.2. "A" 2216 I II.2. According to Com. "A" 4648, 4660, 4683,

4738 and 4972 (point 10).

7.2.3. "A" 2216 I II.3. According to Com. "A" 4648, 4660, 4683,

4738 and 4972 (point 10).

7.2.4. "A" 2216 I II.4. Includes interpretative clarification.

According to Com. "A" 4310 (point 2),

4648, 4660, 4683, 4738, 4972 (point 10) and 4975.

7.2.5. "A" 2216 I II.5. Includes interpretative clarification.

According to Com. "A" 4310 (point 2),

4648, 4660, 4683, 4738, 4972 (point 10) and 4975.

7.2.6. "A" 2216 I II.6. According to Com. "A" 2440.

7.3. "A" 2216 I II. 1ºy 2º Modified by Com. "A" 2932 (point 6.) and 3339.

7.4. "A" 4891 7.

8.1. "A" 2216 I 5. Modified by Com. "A" 2562.

9.1. "A" 2227 unique 5.2.1. last According to Com. "A" 2649.

9.2. "A" 2227 unique 5.1.5. According to Com. "A" 2649.

"A" 2227 unique 5.2.2.

10.1. "A" 2389 2.

10.2.1. "A" 2703 3. According to Com. "A" 3145 (point 1.).

10.2.2. "A" 2703 4.

10.

10.3. "A" 3141 4. According to Com. "A" 5275.

11.1. "A" 4683 4.

11.2. "A" 4738

11.3. "A" 4975 7.

5.1. Individual base.

Unless otherwise provided, financial entities (including their subsidiaries in the country and

abroad) will individually observe the norms applicable to them.

In the case of minimum cash, the individual base will not include subsidiaries abroad.

5.2. Consolidated base.

Without prejudice to compliance individually, controlling financial entities subject to

consolidated supervision will observe on a consolidated basis the following norms:

5.2.1. Monthly consolidated base.

5.2.1.1. Minimum capital.

5.2.1.2. Debtor classification and minimum provisions for uncollectible risk.

5.2.1.3. Credit risk fragmentation.

5.2.1.4. Credit graduation.

i) Maximum limit for holding shares in companies that do not provide complementary services to the financial activity.

ii) Maximum limit of 2.5% of the entity's last day of the second month prior to the granting of the corresponding

financing, which reaches the complementary margin of 200% of the client's computable net worth.

5.2.1.5. Maximum limit that reaches financing, except those destined to other

financial entities, regarding whose granting the intervention

of credit area officials and the general manager and the approval of the directors of the lending entity is not required, fixed at 2.5% of the computable net worth of the second month prior to granting.

5.2.1.6. Global maximum limits, according to the regulations on "Credit Management" for:

a) Small amount loans.

b) Loans for micro-entrepreneurs.

c) Loans for micro, small and medium enterprises (from item iii) of paragraph b) of point 1.1.3.3.).

5.2.1.7. Position and minimum liquidity coefficients.

5.2.1.8. Ratio for immobilized assets and other concepts

CONSOLIDATED SUPERVISION

B.C.R.A.

Section 5. Compliance with norms.

Version: 5th. COMMUNICATION "A" 5557

Validity:

01/03/2014

CONSOLIDATED SUPERVISION

ORDERED TEXT ORIGIN NORM

Section Point Paragraph Com. Annex Point Paragraph

OBSERVATIONS

5.2.1.6. "A" 4891 8. According to Com. "A" 5557.

5.2.1.7. "A" 2690 unique 6.

5.2.1.8. "A" 2227 unique 5.1.8. According to Com. "A" 2736.

5.2.1.9. "A" 5180 8.

5.2.2. "A" 2227 unique 5.1. According to Com. "A" 2649. Complemented by Com. "A" 2461,

2736, 2839, 5180, 5272 and "B"

5902.

5.2.3. "A" 4835 4. According to Com. "A" 5223.

5.2.4. "A" 5093

5.3.1. "A" 2227 unique 5.2.1. According to Com. "A" 2649 and 5520.

5.3.2. "A" 2227 unique 5.2.2. According to Com. "A" 5520.

5.4.1. "B" 6115 3°

5.4.2. "B" 6566 1.

5.5. "A" 2227 unique 5.3. According to Com. "A" 2649.

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