Circular REMON 1-1124: Minimum Cash. Adjustments.

"AÑO DE LA DEFENSA DE LA VIDA, LA LIBERTAD Y LA PROPIEDAD" COMUNICACIÓN “A” 8159 19/12/2024 TO FINANCIAL ENTITIES:
Ref.: Circular
REMON 1-1124:
Minimum Cash. Adjustments.
___________________________________________________________________________ We address you to inform you that this Institution adopted the resolution that, in its pertinent part, establishes:

“1. To dispose, with effect from 01/04/25, the reduction by half of the deduction percentages (on the total of the concepts included in pesos) for the reduction of the minimum cash requirement in pesos provided for in point 1.5.1. (MSME Credit/Private Credit) of the ordered text on Minimum Cash.

2. To leave without effect, with effect for financings agreed from 01/01/25, the deduction of the minimum cash requirement provided for in points 1.5.2. (Investment Projects) and 1.5.3. (Clients not reported in the Debtors Central Registry of the Financial System) of the ordered text on Minimum Cash.

Financial entities may continue to compute that reduction in the requirement for the residual balances of the financings included in the aforementioned points, agreed until 31/12/24.”

In this regard, we send you the sheets that, in replacement of those previously provided, must be incorporated into the ordered text of the reference with effect from 01/01/25. In this sense, it is recalled that on this Institution's website www.bcra.gob.ar, by accessing “Financial System - LEGAL AND REGULATORY FRAMEWORK - Regulations and summaries - Ordered texts of general regulations”, the modifications made with texts highlighted in special characters (strikethrough and bold) will be found.

We salute you attentively.
BANCO CENTRAL DE LA REPUBLICA ARGENTINA
Enrique C. Martin Darío C. Stefanelli
Manager of Emission of Norms
Main Manager of Emission and Regulatory Applications

ANEXO

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

MSME financings include those instrumented through the purchase of MSME Electronic Credit Invoices accepted by companies, as well as the holding of fund shares subject to the “Special Regime for the Establishment of Common Investment Funds for SMEs”.

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

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

1.5.2. Based on cash withdrawals made through the entity's ATMs:
The requirement will be reduced by the amount resulting from the following expression without exceeding the amount of the previously determined requirement, considering what is provided in the preceding point:

B.C.R.A. MINIMUM CASH
Section 1. Requirement.
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where:
Msi: monthly average of the total daily cash withdrawals from ATMs, corresponding to the previous month, located in the entity's operational houses, according to the jurisdiction in which they are located, as established in the TO on Categorization of Localities for Financial Entities. Mni: monthly average of the total daily cash withdrawals from ATMs, corresponding to the previous month, outside its operational houses (neutral) and according to the jurisdiction in which they are located, in accordance with the aforementioned categories. Psi: weight applicable to the amount Msi. Pni: weight applicable to the amount Mni.

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

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

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

It will be considered that this situation is configured when, among others, any of the following factors are present:

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

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Section 1. Requirement.
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1.7. Transfers.
1.7.1. Admitted margin.
The integration of the minimum cash of the position in average of the period cannot be less than 80% of the requirement resulting from the following expression:

EEMA (n) = EEF (n) + ENI (n-1)

where
EEMA (n): adjusted minimum cash requirement corresponding to period “n”.
EEF (n): minimum cash requirement according to current regulations corresponding to period “n”.
ENI (n-1): requirement not integrated in period “n-1”.

1.7.2. Period of use.
The admitted transfer of the requirement not integrated in each period to the following position may be carried out up to a maximum of six periods, counted from the first – inclusive – in which the option to use it is chosen according to what is provided above or from the first position immediately subsequent to that in which the defects transferred are compensated or a charge is paid on them.

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

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

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

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

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Section 1. Requirement.
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To this effect, the financings of the period prior to the computation of the requirement will be considered, measured in monthly average of daily balances.

The financial entity must require and have documentation that accredits that the borrowing company has allocated the funds to grant financings under the conditions of the aforementioned program.

7.4.2. For those financial entities adhering to the “SIMPLE QUOTA” Program – established by Resolution 7/24 of the Ministry of Economy and its complementary regulations – the requirement will be reduced by an amount equivalent to:

• 30% of the sums of the financings in pesos that the entity grants until 21/03/24.
• 15% of the sums of the financings in pesos that the entity grants until 23/05/24.

To this effect, the balance of the financings covered by the period prior to the computation of the requirement that meet the indicated requirements will be considered.

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

7.5. Deposits in the “Special Account for Asset Regularization” – point 3.16. of the TO on Savings Deposits, Salary Account and Special Accounts – will be considered as demand deposits for the purpose of the minimum cash requirement – point 1.3.2.–.

For cases of deposits in currencies other than the US dollar, the requirement must be imputed to the US dollar.

7.6. Financings granted by financial entities covered by the Minimum MSME Quota.
The requirement will be reduced by an amount equivalent to 40% of the financings provided for in point 6.4.1. that are agreed at an average term equal to or greater than 36 months, weighting for this purpose the capital maturities, measured in monthly average of daily balances of the previous month based on the residual balances of the financings agreed until 31/12/24.

The balances of the financings computed for this deduction can be computed for the deduction of point 1.5.1.

7.7. Reduction of the minimum cash requirement in pesos for financial entities that have implemented the remote and in-person opening of the Free Universal Account (CGU) provided for in point 3.11. of the TO on Savings Deposits, Salary Account and Special Accounts based on the residual balances of the financings agreed until 31/12/24.

The requirement will be reduced by an amount equivalent to 50% of the financings in pesos granted from 01/03/24 and agreed until 31/12/24 to natural persons and MSMEs – according to the definition contained in the TO on Determination of the Condition of Micro, Small or Medium Enterprise – that have not been reported by financial entities in the

B.C.R.A. MINIMUM CASH
Section 7. Transitional Provisions.
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Debtors Central Registry of the Financial System (CENDEU) in June 2024, provided that they have been agreed at a nominal annual interest rate that does not exceed, at that time, the rate established in point 2.1.1. of the TO on Interest Rates in Credit Operations.

The monthly average balance of the financings covered by the period prior to the integration of the requirement will be considered.

This deduction cannot exceed 3% of the concepts in pesos subject to requirement, on average, of the month prior to the integration.

100% of the residual balances of the financings in pesos granted until 29/02/24 will continue to be computed as a reduction of the minimum cash requirement in pesos until their maturity.

The financings computed for this deduction cannot be computed for the deductions of other points.

B.C.R.A. MINIMUM CASH
Section 7. Transitional Provisions.
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MINIMUM CASH
ORDERED TEXT ORIGIN NORM OBSERVATIONS Sec. Point Para. Com. Annex Sec. Point Para.
1.
1.3.7. “A” 3549 According to Comm. “A” 4179, 4388,
4549, 4851, 5356, 5534, 5555,
5569, 5873, 5893, 5980, 6195,
6526, 6532, 6616, 6706, 6728,
6740, 6817, 7016, 7290, 7295,
7383, 7432, 7511, 7536, 7545,
7614, 7637, 7717, 7767, 7775,
7923, 8061 and 8124.
1.3.8. “A” 4754 6. According to Comm. “A” 5356, 5980,
6195, 6526, 6532, 6616, 6728 and
7536.
1.3.9. “A” 5945 4. According to Comm. “A” 6069, 6204 and
6616.
1.3.10. “A” 6341 According to Comm. “A” 6616.
1.3.11. “A” 6069 4. According to Comm. “A” 6616.
1.3.12. “A” 6992 According to Comm. “A” 7988, 8000 and
8119.
1.3.13. “A” 8000 1. According to Comm. “A” 8119.
1.3.14. “A” 7429
1.3.15. “A” 7556 4. According to Comm. “A” 7570 and 7571.
1.3.16. “A” 6526 According to Comm. “A” 6532, 6550,
6587, 6616, 6706, 7016, 7290,
7511, 7536, 7611, 7637, 7767 and
8134.
1.3.17. “A” 6550 According to Comm. “A” 6556, 6559,
6575, 6587, 6616, 6706, 6738,
6740, 6817, 7018, 7029, 7047,
7092, 7290, 7295, 7383, 7432,
7511, 7536, 7545, 7573, 7614,
7717, 7775, 7923, 8061, 8124 and
8134.
1.3. Antepenultimate
“A” 7717 1. According to Comm. “A” 8061.
Penultimate
“A” 6526 According to Comm. “A” 6532, 6556,
6569, 6575, 6587, 6616, 6628,
6740, 7016, 7290, 7295, 7511,
7536, 7573, 7637, 7767 and 8061.
Last “A” 7742 Includes regulatory clarification.
1.4. “A” 3905 3. According to Comm. “A” 4179, 4449,
4473, 5671, 5740, 6232, 6349,
6719, 6871 and 7046.
1.5. “A” 5356 2. According to Comm. “A” 5471.
1.5.1. “A” 5356 2. According to Comm. “A” 5471, 5623,
6531, 6703, 6705, 7430, 7432,
7758 and 7983, 8021, 8124.
1.5.2. “A” 6740 1. According to Comm. “A” 7254, 7536,
7661 and 7795.

MINIMUM CASH
ORDERED TEXT ORIGIN NORM OBSERVATIONS Sec. Point Para. Com. Annex Sec. Point Para.
1.
1.6. “A” 3274 II 1. 1.5. According to Comm. “A” 3498.
1.7. “A” 3274 II 1. 1.6
1.7.1. “A” 3274 II 1. 1.6.1. According to Comm. “A” 4405, 4449,
6349, 6719 and 7046.
1.7.2. “A” 3274 II 1. 1.6.2. According to Comm. “A” 3304, 4449,
6349 and 6719.
1.8. “A” 3498 unique 1. 1.8. According to Comm. “A” 4147, 6537,
7003 and 7570.
2.
2.1. “A” 3274 II 2. 2.1. According to Comm. “A” 3498, 3597,
4716, 4815, 6288, 6763 and “B”
9186.
2.1.1. “A” 3274 II 2. 2.1.2. According to Comm. “A” 3304, 3498,
4016 and 4147.
2.1.2. “A” 3498 unique 2. 2.1.3. According to Comm. “A” 4147.
2.1.3. “A” 3274 II 2. 2.1.3. According to Comm. “A” 3498, 4147,
4276 and 5194.
2.1.4. “A” 3274 II 2. 2.1.4.
2.1.5. “A” 4016 1.
2.1.6. “A” 4716 2. According to Comm. “A” 6628 and “B”
9186.
2.2. “A” 3274 II 2. 2.2. According to Comm. “A” 3498, 4449,
4716, 5299, 6349, 6719 and 6774.
2.3. “A” 3365 2. According to Comm. “A” 3387, 3470,
3498, 3549, 3597, 3732, 3824,
4016, 4449, 4716, 5152, 5299,
5373, 6288, 6349, 6575, 6616,
6719, 7046 and “B” 9186.
2.4. “A” 4147 3. According to Comm. “A” 4276, 4449,
4509, 5152, 5299, 6349, 6719 and
7046.
2.5. “A” 4147 3. According to Comm. “A” 4393, 4509,
4716, 5299 and 8124.
3.
3.1. “A” 3274 II 3. 3.1.
3.1.1. “A” 3274 II 3. 3.1.1. According to Comm. “A” 3326, 3365,
3498, 3549, 3905, 4276, 4449,
4473, 4707, 4716, 4862, 5356,
6349, 6638, 6719, 7939 and “B”
9186.
3.1.2. “A” 3274 II 3. 3.1.2.
3.1.3. “A” 3274 II 3. 3.1.3. According to Comm. “A” 3326.
3.1.4. “A” 3274 II 3. 3.1.4.
3.2. “A” 3274 II 3. 3.2. According to Comm. “A” 6719 and 7046.
3.2.1. “A” 3274 II 3. 3.2.2.
1.
According to Comm. “A” 4449, 6349 and
6719.
3.2.2. “A” 3274 II 3. 3.2.2.
2.
According to Comm. “A” 4449 and 6719.
3.3. “A” 3274 II 3. 3.3. According to Comm. “A” 3498.
3.3.1. “A” 3274 II 3. 3.3.1. According to Comm. “A” 4771 and 6275.
3.3.2. “A” 3274 II 3. 3.3.2.

MINIMUM CASH
ORDERED TEXT ORIGIN NORM OBSERVATIONS Sec. Point Para. Com. Annex Sec. Point Para.
4. 4.1. “A” 3274 II 4. 4.1.
5.
5.1. “A” 3274 II 5. 5.1. According to Comm. “A” 3498, 5693 and
6832.
5.2. “A” 3905 5. According to Comm. “A” 5356 and 5693.
5.3. “A” 3905 5. According to Comm. “A” 4449, 6167 and
7944.
6.
6.1. “A” 7983 1.
6.2. “A” 7983 1. According to Comm. “A” 8018.
6.3. “A” 7983 1.
6.4. “A” 7983 1.
6.4.1. “A” 7983 1.
6.4.2. “A” 7983 1. According to Comm. “A” 8021.
6.4.3. “A” 7983 1.
6.5. “A” 7983 1.
6.5.1. “A” 7983 1.
6.5.2. “A” 7983 1.
7.
7.1.1. “A” 5246 3.
7.1.2. “A” 5312 According to Comm. “A” 5333.
7.2. “A” 7536 2.
7.2.1. “A” 6858 1. According to Comm. “A” 6901, 6907 and
7536.
7.2.2. “A” 6937 2. According to Comm. “A” 6943, 7054,
7140, 7155 and 7536.
7.2.3. “A” 6993 2. According to Comm. “A” 7082, 7157 and
7536.
7.2.4. “A” 7006 2. According to Comm. “A” 7536.
7.2.5. “A” 7342 2. According to Comm. “A” 7536.
7.2. last “A” 6858 2. According to Comm. “A” 6965, 6993,
7006, 7140, 7132, 7155, 7157,
7161, 7254, 7342 and 7536.
7.3. “A” 7983 3.
7.4. “A” 5631 1. According to Comm. “A” 5638, 6217,
6531, 6857, 6910, 6937, 7114,
7334, 7448, 7951, 7983 and 8026.
7.5. “A” 8062 2. According to Comm. “A” 8124.
7.6. “A” 7161 5. According to Comm. “A” 7432, 7459,
7474, 7491, 7536, 7561, 7983 and
8159.
7.7. “A” 7254 1. According to Comm. “A” 7287, 7536,
7970, 8057 and 8159. Includes regulatory clarification.