CENTRAL BANK OF THE ARGENTINE REPUBLIC

COMMUNICATION "A" 2687
17/04/98

TO FINANCIAL INSTITUTIONS:

Ref. : Circular RUNOR l - 273 Chapter XXI. Security Measures in Financial Institutions.

We address you in order to inform you that by Resolution No. 194/98, the Board of Directors of this Institution approved the new regulatory text of the Security Measures in Financial Institutions.

Consequently, we send you in annex the text of Chapter XXI of Circular RUNOR - 1, which replaces the one previously provided.

As from the divulgation of this communication, all Communications referring to security of financial institutions issued previously, which are not contained in this regulatory text, are repealed.

We greet you very attentively.

CENTRAL BANK OF THE ARGENTINE REPUBLIC

Juan Carlos Maidana
Submanager of
General Security
Alejandro G. Henke
General Submanager
Technical Coordination Area

ANNEX

INDEX

l. Introduction

2. Minimum security devices for banks and savings banks (head offices, parent companies and branches).

2.1. Armored booth.

2.1.1. Booths to be installed.

2.1.2. Booths in use.

2.1.3. Permanence.

2.1.4. Booth with closed-circuit television as a complement.

2.1.5. Replacement of the armored booth by a security enclosure and closed-circuit television.

2.2. Remote alarm.

2.3. Armored vault.

2.3.1. Mobile vault-cash box.

2.3.2. Modular vault.

2.4. Protection at access points and glazed surfaces.

2.5. Additional police service.

2.6. Night watchmen and lighting services.

2.7. Enclosure for important operations.

2.8. Elements for temporary storage in public service teller windows.

3. Minimum security devices for finance companies, credit banks and savings and loan societies for housing or other real estate.

3.1. When the cash stored does not exceed $ 22,000.00.

3.2. When the cash stored exceeds $ 22,000.00.

4. Money transport.

5. Particular provisions.

5.1. Minimum security measures in the installation of automatic teller machines.

B.C.R.A.	RUNOR 1- 273 - Minimum Security Measures in Financial Institutions Validity: 22.04.98	ANNEX Com. "A" 2687 Page 2 of 36.

5.2. Minimum security measures in offices that provide certain services and in those installed in client companies.

5.3. Deposit boxes for round-the-clock deposits.

6. Complementary provisions:

6.1. Declaration of the minimum security measures adopted, when communicating the authorization or transfer of a financial institution office.

6.2. Self-grouping, in the sections provided in article 1 of Decree No. 1.284/73, of finance companies, credit banks and savings and loan societies for housing or other real estate.

6.3. Reporting of criminal acts and incidents caused to the detriment of financial institutions.

6.4. Abstention from sending plans or sketches to the Central Bank.

6.5. Directives issued by RENAR (National Weapons Registry).

6.6. Possession of certificates of suitability and/or replacement.

6.7. Expert appraisals of the suitability of security elements.

6.8. Personnel responsible for the Security of the Financial Institution.

1. Introduction.

1.1. The minimum security measures contained in this document are mandatory for financial institutions covered by the regime of Law 21.526, and the adoption of other measures they deem necessary based on the Security Studies they conduct, in order to protect valuables and people, remains at their exclusive discretion and responsibility, without authorization from the Central Bank.

1.2. When offices, branches or dependencies that do not carry out money movements or store money are installed, financial institutions may request the Central Bank (General Security Submanagement) for exemption from implementing some or all of the minimum security measures required in the current legal regulations. In the pertinent request, the activities to be carried out must be indicated in detail. If it is granted, it will be valid only for the requested premises and for as long as the situation persists. In the event of a transfer, a new authorization must be requested.

1.3. For those aspects not contemplated and/or that generate the need to make inquiries, the entities must address the General Security Sub-Management of the Central Bank, which will evaluate and resolve accordingly.

2. Minimum security devices for banks and savings banks (head offices, parent companies and subsidiaries).

The minimum security measures that banks and savings banks must adopt, at each of their premises located in the country, will be the following:

2.1. Elevated armored turret, booth or cabin, allowing panoramic surveillance. When the characteristics of the premises make installation at height impossible, its construction outside the premises - also at height - near the main entrance door or inside the premises at ground level will be allowed, in that order.

2.1.1. The characteristics of the turrets to be installed will be the following:

2.1.1.1. Dimensions.

2.1.1.1.1. Interior base: not less than 1 m by 1 m per side.

2.1.1.1.2. Minimum interior height: 2 m.

2.1.1.2. General characteristics.

2.1.1.2.1. Wide visibility: it must allow the occupant the maximum visual field through its transparent armor, must have 0.30 m per side as a minimum and be placed at heights greater than 1 m from the floor of the turret. In all cases, direct observation of the customer service counters, entry to the treasury and access to the entity must be ensured. When surveillance of any of these sectors is not possible, cameras of a closed-circuit television system or the necessary personnel that ensure permanent observation of these areas will be installed, an option that will be at the discretion of the entity.

2.1.1.2.2. Height: the turrets must be installed at a height not less than 0.60 m from the floor of the premises under surveillance, when the characteristics of the premises allow it. In all cases, its base must be clad so that there is no direct access to the lower face of the turret floor from the outside.

2.1.1.2.3. Roof: it must have a slope such that it does not allow the retention of elements thrown against its upper part, unless it coincides with that of the premises to be guarded. This requirement can be achieved by means of a cladding or false ceiling firmly attached to the structure of the turret.

2.1.1.2.4. Door: it must allow normal access to the enclosure. Its closing system must lack interior bolts or latches that cannot be removed from the outside. Its lock must be able to be operated

indistinctly from the inside or from the outside, even if the key is placed on the opposite side.

2.1.1.2.5. Identification: Both the body of the turret and its door must have an indelible numbering that identifies them, which must appear in the respective certificates.

2.1.1.3. Armor

2.1.1.3.1. Protection: both opaque and transparent must provide protection against impacts of 7.62 mm caliber ammunition. NATO standard, and must fully comply with Test Standard No. 1 (anti-FAL armor) issued by the National Registry of Weapons (RE-NAR) or its international equivalent.

2.1.1.3.2. Cladding: the entire opaque sector of the armor must be bulletproof against the projectiles defined in 2.1.1.3.1 or have a coating that gives it that property on its exterior surface.

2.1.1.4. Habitability.

2.1.1.4.1. Ventilation: it must be achieved through its incorporation into the general air conditioning system or by means of the turret's own means (extractor, fan, etc.).

2.1.1.4.2. Ventilation controls: they must exist and be available to the personnel occupying them, for their regulation or blocking, as deemed necessary.

2.1.1.4.3. Entry and exit of ventilation pipes or fans: they must be difficult to access. If they have openings to or from the outside, they must be protected so as to prevent the passage of solid objects with a diameter greater than 30mm.

2.1.1.4.4. Self-contained breathing apparatus: its availability is mandatory. It must ensure an air reserve of not less than 30 minutes and have a mask that protects the main mucous membranes of the face against the irritating effect of chemical agents.

2.1.1.5. Remote alarm: inside the turret there must be a remote alarm push button within immediate reach of its occupant. It must offer minimal possibilities of accidental operation.

2.1.1.6. Link with other dependencies: It must have an intercom (telephone) connected to the internal network of the house. At the discretion of the entity, with prior coordination and authorization of the Security or Police Agency of the jurisdiction, a radio transceiver may be installed for linking with its radioelectric system.

2.1.2. The turrets in use must comply with the following:

2.1.2.1. General characteristics: they must conform to the armor and cladding specifications indicated in point 2.1.1.3..

2.1.2.2. Embrasures: They must be disabled to prevent their use.

2.1.3. Permanence: the presence of the uniformed agent inside the turret must be with the door closed and permanently, from the entry of personnel until the closing of the treasury at the end of the daily activity. The financial entity must immediately report its non-compliance to the respective providing agency, for its immediate intervention.

The primary function of the security personnel located inside the turret is to activate the remote alarm, connected to the respective Security or Police Agency.

2.1.4. When it is necessary to complement the turret with a closed-circuit television system to visualize the areas determined in 2.1.1.2.1., a monitor and the necessary cameras must be installed, which meet the conditions stipulated in 2.1.5.6.1., paragraphs a., b. and c., and 2.1.5.6.2..

2.1.5.Replacement of the armored booth with a security enclosure and closed-circuit television.

Entities may request the replacement of the armored booth with a security enclosure and closed-circuit television that meet the minimum requirements established in this standard.

Applications must be submitted no less than 30 days prior to the date of installation of the device, informing by note addressed to the General Security Sub-Management of the Central Bank: the address of the premises where it will be installed and, in summary, the characteristics of the system with the general location of the security enclosure (point 2.1.5.1), elements inside it (point 2.1.5.4.), standards met by the closed-circuit television equipment and the visual field of the cameras (point 2.1.5.6.). Following evaluation of the system, the General Security Sub-Management will decide accordingly.

Unless otherwise indicated by the Central Bank, they must refrain from sending plans or sketches as stipulated in point 6.4..

The substitute system (security enclosure and closed-circuit television) must remain installed and in proper working condition at the premises in question and must comply, at a minimum, with the security standards indicated below:

2.1.5.1.The control of the system must be located in an armored enclosure or booth whose dimensions must be adequate. Where possible, this enclosure should be located away from the entity's access points.

2.1.5.2.The enclosure must be made of reinforced concrete with a resistance of no less than H-17 (170 Kg. per cm2), in accordance with IRAM Standard 1.666, with a minimum thickness of 15 cm., or of solid masonry with a thickness of no less than 30 cm.. The entire structure must be in accordance with the building code of the installation location. Its construction with another material that complies with RENAR Test Standard No. 1 (resistance to impacts of 7.62 mm caliber ammunition) will also be accepted. NATO Standard). Walls exposed to possible attacks must be lined with anti-theft material on their exterior face. Masonry walls are exempt from this requirement. It must have a certification supporting the construction characteristics of the enclosure, signed by a licensed professional or, if another material is chosen, by RENAR or its international equivalent. If transparent surfaces are used, they must have the same ballistic resistance as indicated, with the corresponding documentation supporting it, as indicated above.

2.1.5.3. Access door.

2.1.5.3.1.It must be armored, in accordance with RENAR Test Standard No. 1 (resistance to impacts of 7.62 mm caliber ammunition. NATO Standard) or its international equivalent, with its respective records. Its exterior face must be lined with anti-theft material.

2.1.5.3.2.It must have a window of transparent armored material, with equal ballistic resistance, of at least 30 cm. per side.

2.1.5.3.3.It must have a special security lock that allows opening from either side, even with the key inserted.

2.1.5.3.4.Identification: it must have numbering as determined in 2.1.1.2.5..

2.1.5.4. Interior.

2.1.5.4.1.It must have a remote alarm button, located near the monitor viewing area, with minimal probability of accidental operation.

2.1.5.4.2.Ventilation will be achieved by incorporating the booth into the air conditioning system, if it exists, or by electric "forced" alternative extraction and/or injection air fans, with the controls stipulated in 2.1.1.4.2..

2.1.5.4.3.It must have a self-contained breathing apparatus that ensures an air reserve of at least 30 minutes, with a mask that protects the main mucous membranes of the face against the irritating effects of chemical agents.

2.1.5.4.4.It must have an intercom or telephone connected to the internal network of the premises. At the entity's discretion, with prior coordination and authorization from the Security or Police Agency of the jurisdiction, a radio transceiver may be installed for linking with its radioelectric system.

2.1.5.4.5.The temperature will be maintained, where possible, at an average of 22* degrees C, in order to keep the system equipment at an adequate level of reliability.

2.1.5.5. Security Agent.

The enclosure must be occupied, with the door closed, by a member of Security or Police Forces or of a private security company. If deemed necessary, the entity may add an operator and/or supervisor of the system

They will be properly instructed for the operation of the entire system and will perform exclusively permanent surveillance tasks from the entry of personnel until the closing of the treasury at the end of the daily activity.

2.1.5.6. Closed-circuit television equipment:

2.1.5.6.1. It must meet the necessary suitability and reliability requirements, complying at a minimum with any of the following standards: VDS, CE, DIN, EIA 1956, IRE 25, ISO or those applicable to it. Likewise, the systems must comply with what is established for the CCIR or RETMA standards.

The minimum technical characteristics are those established below:

a. Black and white cameras.

(1) Horizontal resolution: 380 lines.

(2) Light sensitivity: 0.2 lux.

(3) Back Light: with backlight luminosity conditions.

(4) Auto iris lens: with variable luminosity conditions.

(5) Phase adjustment: +- 90*.

b. Color cameras.

(1) Horizontal resolution: 330 lines.

(2) Light sensitivity: 0.8 lux.

(3) Back Light: with backlight luminosity conditions.

(4) Auto iris lens: with variable luminosity conditions.

(5) Phase adjustment: +-90*. c. Monitors.

c. Monitors

(1) Black and white. - Horizontal resolution: at least 800 lines at the center of the screen.

(2) Color. - Horizontal resolution: 400 lines at the center of the screen.

(3) Screen dimension. - With 1 image: 9 inches minimum. - With 2 and up to 4 images: not less than 12 inches. - With more than 4 images: greater than 14 inches.

d. Video recorder (time-lapse).

(1) Permanent recording of date and time.

(2) Self-cleaning video head.

(3) VHS cassette system.

e. Multiplexer or Quad.

(1) Minimum horizontal resolution: 768 x 480 pixels.

(2) On-screen indication of camera number and date-time (in 24-hour format).

f. Video recording.

Whatever the recording method used, the maximum time interval between the image from the first camera and the last must not exceed two seconds.

2.1.5.6.2. It must have UPS power supply (uninterruptible power source) or battery bank with automatic charger, according to the system's current type, that allows operation in the event of a power outage automatically, or with an automatically started generator set, whose location is adequately protected from intruder access.

2.1.5.6.3. It must have, at minimum, fixed-location cameras that adequately observe:

a. Entry and exit of public and personnel to the financial institution.

b. Customer service teller windows.

c. Door of the main vault and/or mobile teller vault.

2.1.5.6.4. It will have no fewer than one monitor with image splitting (QUAD or multiplexer) or other programmable device for permanent system control.

2.1.5.6.5. Image recording:

a. It must have a video recorder device (time-lapse type) or digital recording equipment that permanently records, at minimum, the images of the areas mentioned in point 2.1.5.6.3., with constant indication of date and time, from the entry of personnel until the closing of the vault, also allowing the recording of any other sector that the operator might momentarily intend to record. This equipment must be protected from access by unauthorized persons.

b. The image file media (video cassettes or back-up tapes or hard or floppy disk or CD) will be kept with the recorded material for a minimum of 60 days of operations. In the event of a possible recording of a loss, the medium with that information must be removed from continuous recording and safeguarded separately.

2.1.5.7. Permanent lighting of the lenses must be ensured in the event of a power supply cut.

2.1.5.8. At the time of the mandatory verification, it will be checked that the installed system complies with what this standard determines.

2.2. Remote alarm, with controls suitable for activating it safely and with minimal possibilities of accidental operation.

2.2.1. Remote alarms must conform to what was published by Communication "C" 2200 of 7 August 1985 (General Directive No. DRNC 05-93 of the National Communications Secretariat).

2.2.2. The systems must comply with the provisions of the National Communications Commission.

2.2.3. The doors of armored vaults must have opening sensors connected to the remote alarm system.

2.2.4. Improper activation of the alarm system.

In order to avoid the inconveniences caused to Security and Police Agencies, the deployment of elements and general readiness for intervention, financial entities must prevent, through negligence, the alarm system from being activated without criminal acts occurring.

To this end, they must adopt all necessary measures so that remote alarms (Article 1, subsection b) of Decree 2.525/71 and Article 1, section "B", subsection b) of Decree 1.284/73) and external alarms (Article 1, section "A", subsection c) of Decree 1.284/73) are equipped with sensors and controls suitable for activating them safely and with minimal possibilities of accidental operation.

2.2.5. Cases deserving special consideration will be evaluated by the Central Bank, which will decide on the matter.

2.3. Armored vault (cement and steel) in the basement or at ground level, separated from party walls, fireproof and resistant to violation by mechanical elements or oxyhydrogen torch. It will have, at minimum, a main door equipped with the locks described in 2.3.1.3. Entities may request the Central Bank to replace it with:

2.3.1. A mobile vault-box, in accordance with the following:

Applications must be submitted no less than 30 days prior to the date of opening of the branch.

The substitute element (mobile vault-box) must comply, at minimum, with the safety standards indicated below:

2.3.1.1. Outer shell in steel plate no less than 1/4" (6.35 mm.) thick and inner shell in steel plate no less than 2 mm. thick; the interior of this chamber will contain a block of steel alloy casting with a uniform hardness no less than 450 Brinell, highly resistant to oxyhydrogen torch, mechanical perforations and high-power impacts, covering the entire surface of the shell with a single piece, or one piece per face, with tongue-and-groove or interlocking joints, in a thickness of 40 millimeters. Its total solid thickness must be at least 125 millimeters, including the cast armor, steel plates and refractory material.

2.3.1.2. Door consisting of an outer steel plate with a thickness no less than 5/8" (15.9 mm.) and a cover of solid thickness in steel plate no less than 3/16" (4.75 mm.) and, inside that chamber, a block of steel alloy casting with a uniform hardness no less than 450 Brinell, highly resistant to oxyhydrogen torch, mechanical perforations and high-power impacts, in a single piece, with a minimum thickness of 60 mm., covering the entire surface of the door. The total solid thickness required is a minimum of 160 millimeters, including the cast armor, steel plates and insulating refractory material.

2.3.1.3. It must have a hermetic seal through effective and uniform contact of the door on its frame along its entire perimeter and shall be achieved by means of a machined profile, preferably of stainless steel or with anti-corrosive treatment, formed by no fewer than two steps of perfect fit on its contact surface. The closing system shall consist of movable bolts designed in such a way that it remains closed and secured even in the event of cutting of the hinge axes. These shall ensure the correct closing of the door and its contact with the double step to prevent heat produced by a fire from filtering inside, destroying or charring its contents.

In no case may deficiencies in mechanical fit be concealed with puttying and/or painting of the mating profiles, nor with the fitting of closing stops, screws, straps or shims of any kind.

It must have 2 combination locks (for the individual stop of two movement guides of the bolts) of the indirect-axis model, of four discs with 100,000,000 combinations, with key change from its interior platform, which does not allow its rear cover to be removed without first setting the code in use, guaranteeing the secrecy of the code in use: provided with anti-spy dial and protection device or protruding collars that prevent forcing their axes; or electronic locks that provide similar performance and comply with UL 768 standards or those applicable to them.

Likewise, it must be provided with a triple time lock, of 120 hours minimum action.

2.3.1.4. It must have at least one interior safe for the safekeeping of the main stocks, equipped at least with a combination lock of 1,000,000 codes, possibility of changing codes, with adjustable delay of 5 or more minutes.

2.3.1.5. The doors of mobile safe-deposit boxes located in basements must have a hermetic compression system.

2.3.1.6. An opening sensor connected to the remote alarm system must be installed on its door.

2.3.1.7. Entities that have been authorized by the Central Bank to operate with mobile safe-deposit boxes, whose characteristics do not conform to the specifications contained in the preceding points, may continue to use them, when they meet the following minimum requirements:

2.3.1.7.1. Solid thickness of the body not less than 100 mm. but with the armor determined above.

2.3.1.7.2. Door plate with a total solid thickness not less than 130mm. but with the armor specified in point 2.3.1.2.

2.3.1.7.3. The locks: as specified in this standard.

2.3.2 A modular safe, whose characteristics comply with what is established for concrete and steel vaults. To that end, the General Security Sub-Management shall determine the suitability of the alternative product, with the technical advice it deems pertinent.

2.4. Special locks, latches, bolts, chains, iron or steel shutters, bars and bulletproof peepholes, as applicable, in all access points to the buildings (doors, windows, skylights, internal courtyards, etc.).

Financial entities may request authorization to replace iron or steel bars and shutters on glazed surfaces bordering the exterior, with an adequate installation of electronic sensors connected to the alarm system, which provide an alert upon intrusions and meet the minimum requirements established in this standard.

Entities that have a 24-hour surveillance service are exempt from complying with the legal requirements mentioned above.

Applications must be filed no less than 30 days prior to the date of installation of the device, informing by note to the General Security Sub-Management of the Central Bank: the address of the premises where it will be installed, the characteristics of the sensors and the alarm device to which they will be connected. After evaluation of the system, the General Security Sub-Management shall resolve accordingly.

Unless otherwise indicated by the Central Bank, they must refrain from sending plans or sketches as stipulated in point 6.4.

The substitute system (sensors connected to the alarm system) must remain installed and in proper working condition at the premises in question and comply at least with the safety standards indicated below:

2.4.1. The sensors must meet the necessary suitability and reliability requirements, complying at least with one of the following standards: VDS, CE, DIN, ISO or those applicable to them.

2.4.2. They must be connected to the alarm system linked to the Security or Police Agency of the jurisdiction or, if a proprietary alarm center is available, with permanent attention and communication with said agency, it may be linked to this, obviating the former.

2.4.3. Their distribution and location must be carried out in such a way that the areas of action overlap in order to detect any entry of intruders.

2.4.4. Their operation must be ensured in the event of a possible cut of the electrical supply from the public network.

2.4.5. At the time of the mandatory verification, it shall be checked that the installed system complies with what this standard determines.

With respect to entities that at the time this provision is issued already have similar systems installed, when the semi-annual verification provided for in article 2* of Law 19.130 is carried out, it shall be checked that they conform to the characteristics set forth herein.

In cases where situations not contemplated in this regulation arise, the entities shall make a detailed presentation addressed to the General Security Sub-Management of the Central Bank, which shall evaluate and resolve accordingly, with the advice it deems pertinent.

2.5. Additional police service.

2.5.1. This service consists of stationing an officer when the entity has a teller's cage, from the entry of personnel until the closing of the vault at the end of the daily activity, who must monitor, by direct observation or through a closed-circuit television system: the accesses to the premises, the public service teller windows and the entrance to the vault. When it is not possible to monitor all these sectors, closed-circuit television cameras or the necessary officers shall be added to ensure permanent observation of these areas, an option that shall be at the discretion of the entity.

2.5.2. It shall be considered effectively adopted when it is covered with active personnel, provided by the competent Security or Police Agency of the jurisdiction.

2.5.3. In the event that the Security or Police Agency has difficulties in providing the service, it shall be replaced by legally qualified surveillance personnel, either its own or from a private security company.

2.5.4. When the Security or Police Agency is in a position to resume providing the service, it shall notify the entity and coordinate the date for the replacement to take effect.

2.5.5. Notwithstanding the provisions of point 2.5.2., after an assessment of their own surveillance and custody needs, entities may reinforce the additional police service with third parties and/or personnel from their organizational structure, always within the framework of the legal provisions in force for these purposes, and the determination of the proportions of the final composition of the service shall be at their discretion.

2.6. Night watchman services and internal and external nighttime lighting, when necessary.

The premises of financial entities must have the necessary lighting that facilitates observation of their interior from the outside, as permitted by their building characteristics.

2.7. Place or enclosure for important operations, away from public view when the characteristics of the premises allow it.

2.8. Elements for temporary safekeeping in public service teller windows.

All entity premises must have auxiliary treasury cash boxes that meet the minimum specifications detailed below or other alternative elements, with a lock and delay mechanism, that perform a similar function, located in the line of public service teller windows, for the purpose of temporarily safekeeping the surpluses they hold in these. The number of auxiliary treasury cash boxes or alternative elements as well as the determination of the surpluses shall be established by the entity, according to its operational needs.

With respect to premises that are in operation and do not have this element at the disclosure of this regulation, this Central Bank shall determine in due course the deadline for its adoption, noting that no new authorizations will be granted if they do not comply with this regulation.

The minimum specifications of the auxiliary treasury cash box or receiving mailbox (teller deposit mailbox) are as follows: 2.8.1.

Be solidly fixed to the floor or to a resistant structure at its location, by means of two steel bolts no smaller than 1/2" (12.7 mm.) in diameter, removable only from the inside.

2.8.2. Steel plate shell, with a minimum thickness of 1/8" (3.2 mm.).

2.8.3. Steel plate door with a total thickness of no less than 5/16" (7.9 mm.) with its perimeter edges machined, for a perfect fit in its frame, and a maximum tolerable gap of 1 mm. (if there is another compartment, the door shall have the same characteristics). Hinges arranged inside the box with axes of a diameter no less than 16 mm., mounted in such a way that they are not accessible from the outside.

2.8.4. The locking mechanism shall control solid cylindrical bolts (no less than 22 mm. in diameter) or flat bolts on their front that allow a minimum entry of 10 mm. into the door frame, controlled by two three-disc numerical combination locks, 1,000,000 combinations, with automatic relocking device, with an adjustable delay mechanism of at least 5 minutes and, in the case of having only one combination lock, another lock operated by double-bit and double-turn keys, with no fewer than 6 laminated combinations.

The installation of an electronic locking system that complies with UL 768 or those applicable to it and that has the following minimum characteristics shall be permitted:

• System with a keypad of 1,000,000 combinations, possibility of two accesses, adjustable delay of at least 5 minutes and automatic relocking system.

• The bolts shall enter no less than 10 mm. into the door frame.

• The lock shall contain an internal memory that does not allow its operation unless the corresponding code is correctly entered and always with the minimum delay of 5 minutes.

2.8.5. "Anti-fishing Mailbox" system that does not allow the exit of cash through its opening.

3. Minimum security devices for finance companies, credit banks and savings and loan associations for housing or other real estate.

The minimum security measures that finance companies, savings and loan associations for housing or other real estate and credit banks must adopt, in each of their premises, shall be the following:

3.1. When the safekept cash does not exceed $ 22,000.00:

3.1.1. Mobile treasury cash box that meets the specifications detailed in point 2.3.1., except for the triple time lock and the remote alarm.

3.1.2. Teller deposit mailbox in the public service teller windows, in accordance with the specifications detailed in point 2.8..

3.1.3. External alarm, with adequate controls to activate it safely and with minimal possibilities of accidental operation. It must have connections to the openings of the premises and to the vault.

3.1.4. Special locks, latches, bolts, chains, iron or steel shutters, bars and bulletproof peepholes, as applicable, at all access points to the buildings (doors, windows, skylights, interior courtyards, etc.)

Entities may request authorization to replace the iron or steel bars and shutters on glass surfaces bordering the exterior with an adequate installation of electronic sensors connected to the alarm system, which provide an alert upon intrusions and meet the minimum requirements established in this standard.

Entities that have a 24-hour surveillance service are exempt from complying with the legal requirements mentioned above.

Applications must be submitted no less than 30 days prior to the installation date of the device, informing by note addressed to the General Security Sub-Management of the Central Bank: the address of the premises where it will be installed, the characteristics of the sensors and the alarm device to which they will be connected. After evaluating the system, the General Security Sub-Management will decide accordingly.

Unless otherwise indicated by the Central Bank, they must refrain from sending plans or sketches as stipulated in point 6.4.

The substitute system (sensors connected to the alarm system) must remain installed and in proper working condition at the premises in question and must comply at a minimum with the security standards indicated below:

3.1.4.1. The sensors must meet the necessary suitability and reliability requirements, complying at a minimum with any of the following standards: VDS, CE, DIN, ISO or those applicable.

3.1.4.2. They must be connected to the alarm system.

3.1.4.3. Their distribution and location must be carried out in such a way that the areas of action overlap in order to detect any intrusion.

3.1.4.4. Their operation must be ensured in the event of a power cut from the public grid.

3.1.4.5. When the required verification is carried out, it will be checked that the installed system complies with what this standard determines.

With respect to entities that already have similar systems installed when this provision is issued, when the semi-annual verification provided for in article 2 of Law 19.130 is carried out, it will be checked that they conform to the characteristics set forth herein. In cases where situations not contemplated in this regulation arise, the entities will make a detailed presentation addressed to the General Security Sub-Management of the Central Bank, which will evaluate and decide accordingly, with the advice it deems pertinent.

3.2. When the cash held exceeds the sum of $ 22,000, the following minimum measures must additionally be implemented:

3.2.1. Elevated armored turret, booth or cabin, allowing panoramic surveillance. When the characteristics of the premises make elevated installation impossible, its construction outside the premises - also elevated - near the main entrance door or inside the premises at ground level will be allowed, in that order.

3.2.1.1. The characteristics of the turrets to be installed will be those specified in point 2.1.1.

3.2.1.2. The turrets in use must comply with the provisions of point 2.1.2.

3.2.1.3. The permanence of the agent inside the turret will conform to what is determined in point 2.1.3.

3.2.1.4. When it is necessary to complement the turret with a closed-circuit television to visualize the areas determined in point 2.1.1.2.1., a monitor and the necessary cameras must be installed, meeting the conditions stipulated in point 2.1.5.6.1., subsections a., b. and c. 3.2.1.4. The entity may request the replacement of the armored turret with a security enclosure and closed-circuit television as provided in point 2.1.5.

3.2.2. Remote alarm, with controls suitable for activating it safely and with minimal possibilities of accidental operation; in accordance with the provisions of point 2.2.

3.2.3. Additional police service or surveillance personnel authorized by the competent authority.

This service consists of stationing an officer in the turret or security enclosure, from the entry of personnel until the closing of the vault at the end of the daily activity, who must monitor, through direct observation or via closed-circuit television: the accesses to the premises, the customer service counters and the entrance to the vault. When it is not possible to monitor all these sectors, the closed-circuit television cameras or the necessary officers will be added to ensure permanent observation of these areas, an option that will remain at the discretion of the entity.

3.2.4. The mobile vault-cash box must conform to what is specified in point 2.3.1.

3.2.5. Night watchman services and internal and external night lighting, when necessary, in accordance with the provisions of point 2.6.

4. Money transport.

In due course, the Central Bank will inform the update of the maximum amounts to be transported for each mode of transfer.

5. Particular provisions.

5.1. Minimum security measures in the installation of automated teller machines.

Financial entities that install automated teller machines must conform to the specifications and minimum security measures determined in each case.

These provisions are of a minimum nature, and the adoption of other precautions deemed necessary, as arising from the Security Studies they carry out, remains at the exclusive discretion and responsibility of the financial entities, in order to ensure the protection of the valuables held in each automated teller machine and of the respective users. 5.1.1. Applicable on a general basis.

5.1.1.1. Automated teller machines must meet the constructive security requirements specified by ANSI-UL 291 standards, and must have the manufacturer's certification accrediting such requirement. The door of the valuables container must have a combination and delay lock.

5.1.1.2. The automated teller machine must be solidly fixed to the floor.

5.1.1.3. The glass used in the construction of the modules must allow observation of the interior of the enclosure ("lobby") from the outside, in order to detect possible criminal acts, whether against the machine or with respect to the user.

5.1.1.4. The lighting of the automated teller machine shall provide sufficient clarity to allow observation at all times of the movements occurring internally and externally.

5.1.1.5. All wiring necessary for the operation of the automated teller machine must reach it through conduits with adequate protection and with the necessary electrical safeguard to prevent possible accidents.

5.1.1.6. Automated teller machines must be connected to the remote alarm system with the corresponding security or police agency, whether this is for exclusive use, owned by the entity or the site where they are installed. In those sites that have a security center communicated with the security or police agency, it will be accepted that the ATM is connected to said center. If there is permanent surveillance, only a local alarm will be required.

The alarm systems referred to in the previous paragraph shall be implemented through vibration (seismic), temperature and door opening sensors of the valuables container, activated through keys, for which purpose the pertinent keypad must be available.

In rear-load ATMs, which have passive infrared sensors in the enclosures destined for the loading and unloading of valuables, the installation of temperature detectors may be omitted.

Automated teller machines located within the financial entity, operational during public service hours, are exempt from complying with this section.

5.1.1.7. In cases where situations not contemplated in this regulation arise, financial entities shall make a detailed presentation addressed to the General Security Submanagement of the Central Bank, which will evaluate and resolve accordingly, with the advisements it deems pertinent.

5.1.2. Applicable according to the services they provide.

5.1.2.1. Automated teller machines (ATM) with comprehensive services (includes bill dispenser and deposit reception): require security in the valuables container and in the perimeter of their location.

5.1.2.2. Automated teller machines with bill dispenser ("cash dispenser" - do not receive deposits): require security in the valuables container and in the perimeter of their location.

5.1.2.3. Self-service terminals: the adoption of security measures will be at the discretion of the entity.

5.1.3. Applicable according to the location of the automated teller machines.

5.1.3.1. Within the premises of the financial entity, with operation subject to public service hours:

• The valuables container of these automated teller machines does not require armored protection; its security will be provided by the booth or, if a closed-circuit television (CCTV) is available, through the installation of a camera that allows its observation.

• No valuables should be stored outside of business hours.

5.1.3.2. At the premises of the financial entity, with street access and 24-hour operation:

• Preferably, according to space availability, they shall have an operational enclosure ("lobby"), with an access door equipped with an electromechanical lock activated by magnetic card.

• The transparent elements bordering the entity must comply with the provisions of point 2.4.. If the entity has services of

surveillance outside of business hours, this requirement may be omitted.

• Automated teller machines with front loading installed in enclosures ("lobby") must have an access door from the entity, for the loading and unloading of valuables. The public access door must be able to be locked during this operation. For those that do not have an operational enclosure ("lobby"), the loading and unloading of valuables shall be carried out in accordance with the provisions of Decree "R" 2625 and its amendments.

5.1.3.3. Away from the entity with 24-hour operation:

5.1.3.3.1. Sites with perimeter and/or internal security (shopping centers, mini markets at service stations, companies, factories, subway stations, etc.):

• If the place has CCTV, a camera shall observe the ATM and the user.

• They must be installed in such a way that the ergonomics of the ATM provide certain privacy to the client, not allowing the observation of the monitor and keyboard by third parties.

• If installed outdoors, it must be provided with an enclosure that provides protection to the valuables container.

5.1.3.3.2. Semi-open sites (service station forecourts, etc.):

They must have an enclosure ("lobby") to carry out operations, similar to what is described in point 5.1.3.2. first paragraph.

5.1.3.3.3. Open sites (public squares, operations from mobile units, etc.):

They require a solid construction for their fixation, in such a way that prevents their removal.

5.1.3.3.4. The loading and unloading of valuables shall be carried out with the custody provided by the legislation and regulations for the transport of money in accordance with the provisions of Decree "R" 2625/73 and its amendments.

5.2. Minimum security measures in premises destined for the provision of certain services by financial entities and in companies of their clients.

Entities that install premises destined for the provision of the services detailed below must comply with the specifications and minimum security measures determined in each case.

Such provisions are of a minimum nature, and the adoption of other precautions deemed necessary remains at the exclusive discretion and responsibility of the financial institutions, in order to ensure the protection of the securities handled and of the respective users.

5.2.1. The branches intended to carry out the activities of:

• Collection of public services, taxes and fees,

• Collection of taxes at facilities operating within offices of the Dirección General Impositiva,

• Sale of fiscal securities and receipt of judicial deposits

must operate in constructions specially adapted to their operations that have, at a minimum, the following characteristics:

5.2.1.1. Not be located in an open place and be positioned in such a way that its rear part rests on a solid wall.

5.2.1.2. Have a receiving mailbox (teller deposit mailbox) or an auxiliary treasury box, which comply with the minimum specifications contained in point 2.8..

5.2.1.3. The maximum sum that may be kept outside the receiving mailbox or auxiliary treasury box, for the conduct of the branch's operations, is $3.000,00 (three thousand pesos) per teller. This amount will be updated, when applicable, by Comunicación "B".

5.2.1.4. The removal of securities must be done with the participation of the armored transport guard involved in the transfer, who must be the holder of the numerical combination code and/or key that allows their extraction from inside the unit.

5.2.1.5. During inactive hours, no sum whatsoever may remain stored in the receiving mailbox or in the auxiliary treasury box.

5.2.1.6. For the transfer of securities, the provisions of the regime of Decreto "R" 2625/73 and its amendments must be strictly observed.

5.2.1.7. When the branch also performs "paying" functions, it must be provided with the minimum security measures set forth in point 2.

5.2.2. Entities that install branches intended to carry out the activities of:

• Payments of pension benefits, and

• Payment of salaries of the Public Administration must observe the minimum security measures detailed below:

5.2.2.1. The premises must be an enclosed area with a single direct access point to the place where payment is made; if other accesses exist, they must remain closed for entry while this activity lasts.

5.2.2.2. If the entity does not have the possibility of installing a mobile treasury box that complies with the rules detailed in point 2.3.1., or another product with equal features but with ANSI - UL 291 certification or equivalent, it must provide for the use of an auxiliary treasury box, for temporary storage, which must meet the minimum characteristics set forth in 2.8., and may not have the "anti-fishing mailbox".

5.2.2.3. Have an additional police officer, with a handheld radio transmitter linked to the police station of the jurisdiction, inside the premises and another one(s), who may be a skilled third party(ies), located according to needs.

5.2.2.4. If the premises where the branch operates has a remote alarm system, the radio transmitter provided for in point 5.2.2.3 will not be necessary.

5.2.2.5. While the operations for which this branch is installed are being carried out, no other activity unrelated to it may be carried out simultaneously.

5.2.2.6. Outside operating hours, no sum whatsoever may be stored, unless the branch has all the minimum security measures determined by Decreto 2525/71 and the rules issued by this Central Bank

5.2.2.7. The transport of cash shall conform to the provisions of Decreto "R"2625/73 and its amendments.

5.2.3. Branches that entities install at client companies to carry out the activities provided for in Section 8, Chapter II of Circular CREFI-2 (Comunicación "A" 2241), must operate in constructions specially adapted to their operations, located in enclosed places and having the following minimum security measures:

5.2.3.1. Remote alarm.

5.2.3.2. If the company has closed-circuit television, it must incorporate at least one camera that monitors the operating area.

5.2.3.3. For the storage of securities, during operating hours an auxiliary treasury box must be installed that meets the minimum characteristics mentioned in point 2.8..

5.2.3.4. Outside operating hours, no sum whatsoever may be stored; if operational reasons require keeping stored funds or securities outside hours, in place of the Auxiliary Treasury Box a mobile treasury box must be installed that complies with the provisions of point 2.3.1., and the installation of any of the aforementioned elements shall be at the free choice of the entities, whatever the operating conditions.

5.2.3.5. Have an additional police officer or skilled third party.

5.2.3.6. The transport of cash shall conform to the provisions of Decreto "R" 2625/73 and its amendments.

5.3. Round-the-clock deposit mailboxes.

5.3.1. The round-the-clock deposit receiving box must be located in the internal part of the building occupied by the entity and be firmly fixed to a solid floor.

5.3.2. The component parts of the box must have on all their faces armor plating, hermetic sealing and insulation resistant to fire and to perforation and fracture, whether by oxyhydrogen torch and/or mechanical means.

5.3.3. The box must be equipped internally with devices that prevent the extraction of securities deposited through the collector mailbox. This must be of the smallest dimensions permitted by the operation.

5.3.4. The door of the receiving box that allows access to its interior must be built with characteristics of greater resistance than the rest of the device, as must its corresponding lock housing and bolts.

5.3.5. The door referred to in the previous point must have two locks; one of which must be a numerical combination lock, with four dials with automatic key change to key, and a device that makes it impossible to violate, with protruding necks on its axes that prevent forcing its displacement inward or outward, and the other of laminated combinations with a key of at least two toothed profiles of different conformation.

The access door to the collecting mailbox must have, in its corresponding lock box, a mechanism that prevents the extraction of the key if said door is not properly closed. The key must be difficult to reproduce and without any type of identification.

Electronic locks that provide similar performance and comply with UL 768 standards or those applicable to them will be accepted.

5.3.6. Entities must adopt the necessary measures to enable the exhibition, to the acting verifying official, of a certificate issued by the manufacturer stating that the box meets the requirements established in this regulation. Said certificate must also state the technical specifications of the materials used and construction details of the referred device.

5.3.7. The collecting mailbox must have adequate nighttime lighting, and the devices providing it must be properly protected.

6. Complementary provisions.

6.1. Declaration of the minimum security measures adopted, when communicating the authorization or relocation of a financial institution's premises.

6.1.1. When submitting Form 2522 "Initiation of activities or relocation (head office, parent company or subsidiary)", entities must declare thirty days before the informed authorization date that all minimum security measures established in the applicable legal and regulatory context in force will be adopted.

6.1.2. The Central Bank will promote the request for verification to the competent Security or Police Agency.

6.1.3. Once the indicated formal communications are made, the entity may coordinate with the intervening Agency the precise date of the verification to be executed, ensuring the intermediate periods that contemplate the administrative time required for processing the Verification Act, in accordance with the planned authorization date and related communications, thus avoiding any circumstance that would prevent it.

6.1.4. If at the time of verification, the premises are under construction or any of the prescribed minimum security measures are not fully adopted, evidence must be shown that allows reliably determining that they will be implemented (execution contracts, purchase orders, factory certificates or others considered appropriate), an aspect that the official will record in the respective act. In these cases, the General Security Sub-Management will evaluate and resolve accordingly.

6.1.5. With Form 2522, a note must be submitted, according to the attached model, which will have the character of a sworn statement, signed by the security area manager and a legal representative of the entity, detailing the minimum security measures to be adopted.

6.1.6. When the Security or Police Agency of the jurisdiction, having received the communications within the established deadlines, cannot carry out the verification before the authorization date, the General Security Sub-Management of the Central Bank will evaluate whether the information in the sworn statement complies with current legal regulations and, if no opposing non-compliances are found, the entity may initiate activities under its responsibility.

6.1.7. At the time of carrying out the mandatory verification, it will be confirmed that the declared measures have been effectively adopted; otherwise, it will give rise to the Central Bank initiating the corresponding actions for non-compliance with what was stated in the corresponding declaration.

6.1.8. In cases of relocation, the provisions established above must be complied with.

6.2. Self-grouping, in the sections provided in Article 1 of Decree 1.284/73, of finance companies, credit unions and savings and loan societies for housing or other real estate.

The entities mentioned in the heading must inform in which of the sections contained in Article 1 of Decree 1.284/73 each of their premises is included, taking into account that such Self-grouping does not necessarily have to be homogeneous, but must be assigned individually according to the operations of each premises. Thus, the case of a Head Office located in section "A" and its subsidiaries in "B", or vice versa, is admitted.

Likewise, they must immediately notify any modification that alters the declared grouping.

6.3. Reporting of criminal acts and incidents produced to the detriment of financial entities.

The Central Bank needs, for the fulfillment of the task assigned to it in the matter, to have information related to all criminal acts and incidents suffered by financial entities in which the minimum prevention measures established by Law 19.130 and its Decrees and regulatory norms have been affected.

For this reason, in the event of any such act occurring in the buildings they occupy or during the transfer of money, they must send to the General Security Sub-Management, within five (5) days of occurrence, a detailed report of the event, with special indication about the behavior, on the occasion, of the security devices adopted, information that, given its confidential nature, must be provided with the necessary reservations.

6.4. Abstention from sending plans or sketches to the Central Bank Unless otherwise indicated, financial institutions must refrain from sending any type of plans, sketches or other graphics that refer to the layout and/or distribution, general or particular, of the premises where they carry out or plan to carry out their activities, especially those related to the areas comprising prevention and/or protection devices.

6.5. Directives issued by the National Weapons Registry (RENAR).

The National Weapons Registry (RENAR) requires that financial institutions seek due advice from that Agency before proceeding with the acquisition, modification or deregistration of any of the elements covered by National Weapons and Explosives Law No. 20.429 and Law No. 24.492, Decrees Nos. 395/75, 252/94, 64/95 and 821/96, whose texts are provided for a fee by said entity.

6.6. Holding of suitability and/or replacement certificates.

Financial institutions must adopt the measures that enable the presentation of certificates proving that the specifications of the minimum security devices established by virtue of Law 19.130 and its Decrees and regulatory norms satisfy the stipulated requirements. Likewise, when the replacement or exemption of some of such measures has been authorized, they must have the pertinent conformity issued by the General Security Sub-Management of the Central Bank.

Such elements must be shown to the verifying official each time they are required and, in this regard, the following must be taken into account:

6.6.1. Financial institutions must adopt the necessary measures to keep at each of their premises a copy of the certificates demonstrating the suitability of the minimum security measures implemented, as required by current legislation and regulations.

6.6.2. Since financial institutions are considered responsible for their presentation, if they do not have the aforementioned certificates at the time of verification, they must send them to the intervening agency within fifteen (15) days thereafter.

6.6.3. Security or police agencies must send to this Institution the reports corresponding to the verifications they carry out, when the financial institutions have shown them the corresponding suitability certificates, or once the period set in the preceding point has elapsed. In all cases, they must record on the aforementioned form whether, from the elements presented, it emerges that the security measures do not satisfy the requirements considered minimum by current legislation and regulations or, as the case may be, any eventual non-compliance incurred.

6.7. Suitability inspections of security elements.

In the absence of certificates proving the constructive or manufacturing suitability of the different security devices that financial institutions have implemented or plan to use, the suitability inspections that may be necessary may be carried out by agencies or companies specialized in the matter, endorsed by a licensed professional, after prior notification to the Central Bank.

For this purpose, it is necessary that the pertinent reports or inquiries be addressed to the General Security Sub-Management, indicating the element to be inspected, the agency or company that will carry it out, the professional involved, the place where it will be carried out and the method to be applied.

6.8. Personnel responsible for the Security of the financial institution.

Given the relations that financial institutions must maintain with the Central Bank, in aspects related to minimum security measures, governed by National Law 19.130, its regulatory Decrees and current norms, all procedures, steps or inquiries inherent to the matter must be carried out through the direct intervention of a senior official appointed by each institution for that purpose.

This appointment must fall to a person who possesses sufficient suitability and experience in security matters, enabling them to properly apply the requirements of current regulations.

In order to cover the leaves or momentary absences of that official, the institution must determine and inform who will replace them during those periods.

Consequently, they shall provide to the General Security Sub-Management, within 15 calendar days from the date of this Communication, the name of the designated persons, ranks, physical workplace and telephone numbers where they can be located.

When circumstances require the replacement of the designated officials, the change must be communicated in due time to the indicated department.

P.A.D.
RT.

MODEL SWORN STATEMENT (Point 6.1. Chapter XXI Circular RUNOR)

Buenos Aires (the date), the undersigned with power and representation for the (name of the financial institution concerned), declare under oath that on the day (date of authorization of the premises, as recorded in Form 2522), the opening of (number and name of the branch, office (Sec. 7 or 8), address) will proceed, with all the minimum security measures established in current legal regulations as detailed below: MEASURES YES NO 1. Castillete

MEASURES	YES	NO
1. Castillete
1.1. Castillete with CCTV as complement
1.2. Security enclosure and CCTV
2. Remote alarm
3. Cement and Steel Vault
3.1. Mobile Safe-Deposit Box
3.2. Modular Safe
4. Accesses with minimum protection measures (grilles,
4.1. Glazed surfaces with sensors
5. Additional Police Service
5.1. Private Security
6. Internal and external lighting
7. Temporary safekeeping element
8. 24-hour deposit box

9. Automated Teller Machine

OBSERVATIONS: In an annex, a detailed breakdown of each measure adopted will be made. Replacement applications must be accompanied by copies of the certificates of aptitude and the necessary brochures for their evaluation and approval.

It is expressly recorded that we are fully aware of the legal actions arising and that, by force of Laws Nos. 19.130, 21.526 and 24.144, they must be applied in the event of non-compliance with any of the minimum security measures set forth herein.

Signature of the Legal Representative of the Financial Institution Signature of the Security Officer of the Financial Institution