Communication A 7181: Extension of Financial Services, Debtor Classification, Result Distribution, ATM Fees, and Other Measures Under the COVID-19 Emergency

“2020 - YEAR OF GENERAL MANUEL BELGRANO”
COMMUNICATION “A” 7181 17/12/2020
TO FINANCIAL ENTITIES,
TO COOPERATIVE CREDIT BOXES (LAW 26.173),
TO TRUSTEES OF FINANCIAL TRUSTS INCLUDED IN THE FINANCIAL ENTITIES LAW, TO CREDIT PORTFOLIO ADMINISTRATORS OF EX-FINANCIAL ENTITIES, TO EXCHANGE OPERATORS, TO SOCIETIES OF RECIPROCAL GUARANTEE, TO PUBLIC-CHARACTER GUARANTEE FUNDS, TO NON-FINANCIAL COMPANIES ISSUING CREDIT CARDS, TO NON-FINANCIAL COMPANIES ISSUING PURCHASE CARDS, TO OTHER NON-FINANCIAL CREDIT PROVIDERS:
Ref.: Circular
OPRAC 1 - 1080
SERVI 1 - 81
RUNOR 1 - 1632
SINAP 1 - 122
CONAU 1 - 1447
LISOL 1 - 925
OPASI 2 - 630
Communication “A” 6938. Financial services within the framework of the health emergency established by Decree No. 260/2020 Coronavirus (COVID-19). Debtor classification. Distribution of results. Savings deposits, salary accounts, and special accounts. Regulation of the bank current account. Checking accounts opened in cooperative credit boxes. Adjustments. ____________________________________________________________ We address you to inform you that this Institution has adopted the resolution that, in its pertinent part, provides:
“1. Extend until 31.3.21 the following provisions:
i) First and last paragraphs of point 2.1.1.2. of the rules on “Financial services within the framework of the health emergency established by Decree No. 260/2020 Coronavirus (COVID-19)”, so that unpaid installments corresponding to maturities of credit assistance not covered by the Credit Cards Law that have been granted by financial entities and operate from 1.4.2020 onwards may only accrue compensatory interest at the rate contractually provided; entities must incorporate these installments starting from the month following inclusive to the end of the credit’s life –considering the accrual of the compensatory interest rate–.

-2- ii) Points 11.1. and 11.2. of the rules on “Debtor classification”, which increase by 60 days the admitted delinquency periods for levels 1, 2, and 3 –both for the commercial portfolio as well as for the consumer or housing portfolio– and suspend the mandatory reclassification provided in points 6.6. and 7.3. of the aforementioned rules, respectively. iii) Points 5.4. and 13.2. of the rules on “Savings deposits, salary accounts, and special accounts” and “Regulation of the bank current account”, respectively, and Section 11. of the rules on “Checking accounts opened in cooperative credit boxes”, insofar as financial entities cannot charge fees or commissions for operations carried out through all automated teller machines (ATMs) enabled and operated in the country by them, without any distinction between customers and non-customers, regardless of the type of checking account on which the corresponding operation is made, and of the financial entity and/or the ATM network to which it belongs.
2. Provide that financial entities must arrange the means so that, in all automated teller machines enabled and operated in the country by them, natural and legal persons can withdraw, per day and in a single withdrawal, at least up to $ 15,000, without any distinction between customers and non-customers, regardless of the type of checking account on which the corresponding operation is made and of the financial entity and/or the ATM network to which it belongs.
3. Postpone until 1.1.22, for financial entities of groups B and C, the application of point 5.5 of IFRS 9 –established through Communication “A” 6430– and, consequently, the proration methodology that generates the application of the cited point –provided in Communication “A” 6847–.
4. Extend until 30.6.21 the suspension of the distribution of results of financial entities established in point 7.3. of the rules on “Distribution of results.””
On the other hand, we send you the sheets that, in replacement of those previously provided, correspond to incorporate into the referenced rules. In this sense, it is recalled that on this Institution’s website www.bcra.gob.ar, accessing “Financial System - LEGAL AND REGULATORY FRAMEWORK - Orders and summaries - Ordered texts of general regulations”, the modifications made with text highlighted in special characters (strikethrough and bold) will be found. We salute you attentively. CENTRAL BANK OF THE ARGENTINE REPUBLIC Darío C. Stefanelli María D. Bossio Main Manager of Emission and Normative Applications General Deputy Manager of Financial Regulation

-3-
WITH COPIES TO THE ELECTRONIC COMPENSATION EXCHANGES, TO COMPANIES ADMINISTERING ATM NETWORKS, TO EXTRA-BANK COLLECTION COMPANIES, TO FINANCIAL MARKET INFRASTRUCTURES, TO VALUE TRANSPORTERS.
ANNEX

2.1. Financial entity credit assistance.
2.1.1. Refinancings.
2.1.1.1. Unpaid balances of credit cards.
i) Balances that are unpaid between 13.4.2020 and 30.4.2020 must be automatically refinanced for a minimum term of one year with a 3-month grace period in 9 monthly, equal, and consecutive installments, able to accrue only compensatory interest, and no other surcharge, which cannot exceed that established in point 2.1.1. of the rules on “Interest rates in credit operations”. ii) Balances that are unpaid between 1.9.2020 and 30.9.2020 must be automatically refinanced for a minimum term of one year with a 3-month grace period in 9 monthly, equal, and consecutive installments, able to accrue only compensatory interest, and no other surcharge, which cannot exceed 40% nominal annual. Refinanced balances may be prepaid, totally or partially, at any time and without cost –except for the compensatory interest accrued until prepayment– when the customer requests it, an option that the financial entity must inform them of along with the modalities to effect it. Unpaid balances corresponding to maturities that operate from 1.4.2020 to 30.9.2020 may only accrue the compensatory interest at the contractually provided rate.
2.1.1.2. Of the rest of the financings.
Entities must incorporate the unpaid installments corresponding to maturities that operate between 1.4.2020 and 31.3.21 starting from the month following inclusive to the end of the credit’s life, considering the accrual of the compensatory interest rate. For the case of mortgage credits on unique homes and pledged credits updated by UVA, the customer may opt for this scheme or for that established in Decrees No. 319/2020 and 767/2020. Credit assistance granted to the financial sector is excluded from this point. Unpaid balances corresponding to maturities that operate from 1.4.2020 to 31.3.21 may only accrue the compensatory interest at the contractually provided rate. FINANCIAL SERVICES WITHIN THE FRAMEWORK OF THE HEALTH EMERGENCY ESTABLISHED BY DECREE NO. 260/2020 CORONAVIRUS (COVID-19)
Section 2. Other provisions.
Version: 9a. COMMUNICATION “A” 7181
Validity:
18/12/2020

Section Point Paragraph Com. Cap. Point Paragraph
OBSERVATIONS
1.1. 1st “A” 6942 2. According to Com. “A” 6949, 6951
6953, 6954, 6956, 6958 and “C” 86999.
1.1.1.1. “A” 6933 According to Com. “A” 6949, 6958,
6982 and 7025.
1.1.1.2. “A” 7067 According to Com. “A” 7084 and 7088.
1.1.1.3. “A” 6958 1. According to Com. “A” 6982, 7017 and
7028.
1.1.2. “A” 6944 3. According to Com. “A” 6958, 6982 and
7025. Decree No. 605/2020,
article 6°.
1.1.3.1. “A” 6944 1. According to Com. “A” 6949, 6982 and
7025.
1.1.3.2. “A” 6942 2.1. According to Com. “A” 6944 and 7025.
1.1.3.3. “A” 6942 2.2. According to Com. “A” 7025.
1.1.3.4. “A” 6948 7. According to Com. “A” 7084.
1.1.3.5. “A” 6949 6.
1.2. “A” 6958 2. According to Com. “A” 6982.
1.3. “A” 6942 1. According to Com. “A” 6949, 6958 and
7177.
1.
1.4. “A” 6977 According to Com. “A” 7025. Decree
No. 605/2020, article 6°. i) “A” 6942 3. According to Com. “A” 6949, 6964, and
7025. Includes interpretative clarification.
ii) “A” 7095 According to Com. “A” 7102.
2.1.1.1. last “A” 6949 4 1st According to Com. “A” 7025, 7044,
7056 and 7111.
2.1.1.2. “A” 6942 3. According to Com. “A” 6949, 7025,
7044, 7056, 7107, 7130 and
7181.
2.1.2. “A” 6993 1. According to Com. “A” 7082 and 7092.
2.1.3. “A” 7082 1. According to Com. “A” 7092, 7102,
7130, 7157 and 7173. Includes interpretative clarification.
2.2. “A” 6942 6. According to Com. “A” 6949 and 7025.
2.3. “A” 6942 7. According to Com. “A” 6949 and 7025.
Decree No. 297/2020, article
6º.
2.
2.4. “A” 6942 8. According to Com. “A” 6949 and 7025.
Decree No. 297/2020, article
6º.
3. “B” 11992
B.C.R.A.
ORIGIN OF THE PROVISIONS CONTAINED IN THE RULES ON “FINANCIAL SERVICES WITHIN THE FRAMEWORK OF THE HEALTH EMERGENCY ESTABLISHED BY DECREE NO. 260/2020 CORONAVIRUS (COVID-19)”

11.1. With validity until 31.3.21, for the purposes of the debtor classification provided in
these provisions, financial entities and other obligated parties by these rules must increase by 60 days the admitted delinquency periods for categories 1, 2, and 3, both for the commercial portfolio as well as for the consumer or housing portfolio. In this order, until 31.3.21 the days of delay corresponding to the classification levels are:
Portfolio Category Days of delay
1 ≤ 91 a) 92 to 150 b) 92 to 150
2 c)
Special treatment
(point 6.5.2.3.)
3 151 to 240
4 241 to 1 year
Commercial
5 > 1 year
1 ≤ 91 a) 92 to 150
2 b)
Special treatment
(point 7.2.2.2.)
3 151 to 240
4 241 to 1 year
Consumer or housing
5 > 1 year
Timely the BCRA will announce a schedule so that they gradually classify their debtors according to the pre-existing delinquency criteria before 19.3.2020.
11.2. Until 31.3.21 the application of points 6.6. and 7.3. is suspended.
DEBTOR CLASSIFICATION
B.C.R.A.
Section 11. Transitional provisions.
Version: 11a. COMMUNICATION “A” 7181
Validity:
18/12/2020

DEBTOR CLASSIFICATION
Sec. Point Para. Com. Annex Point Para.
OBSERVATIONS
8. 8.1. “A” 2216 I 5. According to Com. “A” 2562.
9.1. “A” 2227 unique 5.2.1. Last According to Com. “A” 2649.
9.
9.2. “A” 2227 unique 5.1.5.
and
5.2.2.
According to Com. “A” 2649.
10.1. “A” 2389 According to Com. “A” 5593 and 7146.
10.2.1. “A” 2703 3. According to Com. “A” 3145.
10.2.2. “A” 2703 4.
10.
10.3. “A” 3141 4. According to Com. “A” 5275.
11.1. “A” 6938 1. According to Com. “A” 7024, 7107 and 7181.
11.
11.2. “A” 6938 8. According to Com. “A” 7107 and 7181.

7.1. The countercyclical capital buffer that financial entities must apply to their exposures in Argentina, according to what is established in point 4.2., is established, from
1.4.16, at 0 %.
7.2. For the purposes of determining the distributable result, it must be deducted from the computations
provided in Sections 2. and 3. the increase in the computable equity responsibility (RPC) that results from the application of point 11.4. of the rules on “Minimum capitals of financial entities” and the lower provisions and higher RPC that result from the treatments established in point 2. of Communication “A” 6946 (and modifications) –for financings to MiPyME destined for the payment of salaries– and in point 3. of Communication “A” 7181 –which postponed until 1.1.22, for financial entities of groups B and C, the application of point 5.5 of IFRS 9–.
7.3. The distribution of results of financial entities is suspended until 30.6.21.
DISTRIBUTION OF RESULTS
B.C.R.A.
Section 7. Transitional provisions.
Version: 8a. COMMUNICATION “A” 7181
Validity:
18/12/2020

ORDERED TEXT SOURCE OF THE PROVISIONS OBSERVATIONS Sec. Point Para. Com. Annex Cap. Sec. Point Para. 1. “A” 4589 1. According to Com. “A” 5827 and 6464. 1st and 2nd “A” 4589 2. According to Com. “A” 4591 (point 6.), 5273, 5827, 6327 and 6464.
2.1. “A” 6327 12.
2.2. “A” 6396 4.
2.3. “A” 6327 12.
2.4. “A” 4589 2.3.
2.5. “A” 4589 2.4.
2. last “A” 6327 26.
1st “A” 4589 3. According to Com. “A” 4591 (point 8.), 5072, 5273, 5827, 5985, 6464 and “B” 9104.
3.1. “A” 4589 3.1. According to Com. “A” 4591 (point
8.) and 6428.
3.2. “A” 4589 3.3. iv) According to Com. “A” 4591 (point
8.) and “B” 9104.
3.3. “A” 4589 3.3. According to Com. “A” 4591 (point
8.), 6428 and 6464.
3.4. “A” 5737 4.
3. last “A” 4589 1.1. a
1.4.
According to “A” 4591, 5072 and
6464.
4. “A” 5827
“A” 4591 1. According to Com. “A” 5282 and
5827.
5.1. “A” 4591 1. Incorporates the interpretative criterion of Com. “C” 46841.
5. According to Com. “A” 5393.
5.2. “A” 4591 1. According to Com. “A” 4686, 4702,
5072, 5180, 5282, 5369,
5580, 5827, 6013, 6464 and
“B” 9104.
6. “A” 6768
7.1. “A” 5938
7.2. “A” 6946 3. According to Com. “A” 7007, 7108,
7. 7. 7143 and 7181.
7.3. “A” 6939 According to Com. “A” 7007, 7035
and 7181.
B.C.R.A.
ORIGIN OF THE PROVISIONS CONTAINED IN THE RULES ON “DISTRIBUTION OF RESULTS”

5.4. Until 31.3.21 inclusive, financial entities cannot charge fees or commissions for
operations (deposits, withdrawals, inquiries, etc.) carried out through all automated teller machines (ATMs) enabled and operated in the country by them, without amount limits –except those expressly agreed for security reasons and/or resulting from operational restrictions of the equipment– nor quantity of withdrawals, nor any distinction between customers and non-customers, regardless of the type of checking account on which the corresponding operation is made, and of the financial entity and/or the ATM network to which it belongs.
5.5. Checking accounts for judicial use.
During the validity period of restrictions on free social circulation and limitations in public service –according to the legal and regulatory framework established by virtue of the pandemic derived from the coronavirus COVID-19 (Decree No. 260/2020 and modifications)–, financial entities must accept transfer orders that courts order and send via electronic office in paper format through the accounts belonging to “authorized users” of the remote access information systems provided in point 3.6.7. Additionally, financial entities must establish a system that allows courts to electronically send the offices and/or any other document signed by a competent judicial authority in which the opening of these accounts is requested, ensuring the proper identification of the “authorized user”. When the opening of a savings account and the issuance of a debit card to beneficiaries of judicial payments who do not have a checking account –as provided in the second-to-last paragraph of point 3.6.4.– is appropriate, financial entities must send the corresponding debit card to the beneficiary’s home address by postal mail –in accordance with what is established in point 7. of Communication “A” 6948– or to their operational house closest to the beneficiary’s home address. This latter, when the postal mail system used by the financial entity does not access the beneficiary’s home address in person.
5.6. For the case of foreign currency savings accounts existing as of 15.9.2020, prior to the crediting of new amounts –except that they come from transfers– financial entities must make the inquiry on the ANSES website provided in point 1.4.2., whose result they must consider in the terms of that point, and request supporting documentation of the client’s income and/or assets and/or any other documentation that allows them to evaluate the reasonableness of the client making savings in foreign currency.
For the purpose of complying with that requirement, only when the certification is denied because the person is in an employment relationship or is a beneficiary of pension benefits, self-employed worker, monotributista, or domestic worker, financial entities may consider that the information they already have or that the client possesses open in that entity a “Salary/Social Security Account” is sufficient. SAVINGS DEPOSITS, SALARY ACCOUNTS, AND SPECIAL ACCOUNTS B.C.R.A.
Section 5. Transitional provisions.
Version: 7a. COMMUNICATION “A” 7181
Validity:
18/12/2020

The documentation detailed above may be presented both in person and by electronic means and must be updated annually or more frequently if the financial entity deems it necessary. When the crediting is carried out by the holder through cash deposits, it is not required that entities make the aforementioned inquiry.
5.7. Financial entities must arrange the means so that, in all automated teller machines (ATMs) enabled and operated in the country by them, natural and legal persons can withdraw, per day and in a single withdrawal, at least up to $ 15,000, without any distinction between customers and non-customers, regardless of the type of checking account on which the corresponding operation is made and of the financial entity and/or the ATM network to which it belongs.
SAVINGS DEPOSITS, SALARY ACCOUNTS, AND SPECIAL ACCOUNTS B.C.R.A.
Section 5. Transitional provisions.
Version: 3a. COMMUNICATION “A” 7181
Validity:
18/12/2020

SAVINGS DEPOSITS, SALARY ACCOUNTS, AND SPECIAL ACCOUNTS Sec. Point Para. Com. Annex Cap. Sec. Point Para. OBSERVATIONS
4.4.2. “A” 1199 I 5.3.2.
4.4.3. “A” 1199 I 5.3.3.
4.4.4. “A” 3042
4.4.5. “A” 1199 I 5.3.4.
4.4.6. “A” 1199 I
5.3.4.1. and
5.3.4.3.
4.4.7. “A” 627 1. S/Com. “A” 6419.
4.5. “A” 1199 I 5.1.
4.5.1. “A” 1199 I 5.1.1.
4.5.3. “A” 1199 I 5.1.3. S/Com. “A” 5990.
4.6.1. “A” 1199 I 5.2.1. S/Com. “A” 3042.
4.6.2. “A” 1199 I 5.2.2.
S/Com. “A” 3042, 4809,
5482, 6042 and 6448.
4.7. “B” 6572 S/Com. “A” 5388.
4.8. “A” 4809 6. S/Com. “A” 5986 and 6249.
4.9. “A” 4809 7.
S/Com. “A” 5164, 5520,
5612 and 6639.
4.10. 1st “A” 5212
4.10.1. “A” 5127 3.
S/Com. “B” 9961, “A”
5164, 5212, 5473, 5718,
5778 and 5927.
4.10.2. “A” 5212 S/Com. “A” 5718.
4.10.3. “A” 5137 S/Com. “A” 5164 and 5990.
4.11. “A” 5482 S/Com. “A” 5928 and 6681.
4.12. “A” 5482
4.13. “A” 5588
4.13.1. “A” 5588
4.13.2. “A” 5588
4.14.
“A” 5928
10.
S/Com. “A” 6236, 6483,
6639, 6709 and 6762.
4.15. “B” 11269
4.16. “A” 6059 S/Com. “A” 6273.
4.17. “A” 6448 2.
4.18. “A” 6714
4.19.
“A” 6893 S/Com. “B” 11952 and “A”
6941.
4.
4.20. “A” 7115 S/Com. “A” 7117.
5.1. “A” 1199 I 4.2.6.
S/Com. “B” 9516 and 10025,
“A” 5410 and 5565.
5.2. “B” 10567
5.3. “A” 6341
5.4. “A” 6945
S/Com. “A” 6957, 7009,
7044, 7107, 7181 and “C”
87078.
5.5. “A” 6976
5.6. “A” 7105 2. S/Com. “A” 7112 and 7125.
5.
5.7. “A” 7181 2.

13.1. Until 31.12.2020 inclusive, the obligation to proceed with the closure of
bank current accounts and to dispose of the disqualification established in article 1° of Law 25730 is suspended, as well as the application of the fines provided in said law. Likewise, while the aforementioned suspension remains in effect, the following will apply:
13.1.1. The deadline for presenting common or deferred payment checks whose original legal validity period ends during the validity of this measure, whether issued in Argentina or abroad, will be extended by 30 days.
13.1.2. Admit a second presentation for checks rejected due to the cause “Insufficient funds available in account” –according to the rules on “National Payment System - Checks and Other Compensable Instruments”–, except that they be checks generated by electronic means (ECHEQ).
13.1.3. Financial entities cannot charge commissions to their customers related to the rejection of checks.
13.2. Until 31.3.21 inclusive, financial entities cannot charge fees or commissions for
operations (deposits, withdrawals, inquiries, etc.) carried out through all automated teller machines (ATMs) enabled and operated in the country by them, without amount limits –except those expressly agreed for security reasons and/or resulting from operational restrictions of the equipment– nor quantity of withdrawals, nor any distinction between customers and non-customers, regardless of the type of checking account on which the corresponding operation is made, and of the financial entity and/or the ATM network to which it belongs.
13.3. Financial entities must arrange the means so that, in all automated teller machines (ATMs) enabled and operated in the country by them, natural and legal persons can withdraw, per day and in a single withdrawal, at least up to $ 15,000, without any distinction between customers and non-customers, regardless of the type of checking account on which the corresponding operation is made and of the financial entity and/or the ATM network to which it belongs.
REGULATION OF THE BANK CURRENT ACCOUNT
B.C.R.A.
Section 13. Transitional provisions.
Version: 6a. COMMUNICATION “A” 7181
Validity:
18/12/2020

REGULATION OF THE BANK CURRENT ACCOUNT
Sec. Point Para. Com. Annex Cap. Sec. Point Para.
OBSERVATIONS
12.6.1. “A” 5127 3. S/Com. “B” 9961 and “A” 5164,
5212, 5473, 5718 and 5927.
12.6.2. “A” 5212 S/Com. “A” 5718.
12.7. “A” 5588
12.7.1. “A” 5588
12.7.2. “A” 5588
12.8. “A” 5928 10. S/Com. “A” 6236, 6483,
6639, 6709 and 6762.
12.9. “B” 11269
12.10. “A” 6273
12.
12.11. “A” 6714
13.1. “A” 6950 Decrees No. 312/2020, No.
425/2020 and No. 544/2020.
13.2. “A” 6945 S/Com. “A” 6957, 7009,
7044, 7107, 7181 and “C”
87078.
13.
13.3. “A” 7181 2.

11.1. Until 31.3.21 inclusive, cooperative credit boxes cannot charge fees or commissions for
operations (deposits, withdrawals, inquiries, etc.) carried out through all automated teller machines (ATMs) enabled and operated in the country by them, without amount limits –except those expressly agreed for security reasons and/or resulting from operational restrictions of the equipment– nor quantity of withdrawals, nor any distinction between customers and non-customers, regardless of the type of checking account on which the corresponding operation is made, and of the financial entity and/or the ATM network to which it belongs.
11.2. Financial entities must arrange the means so that, in all automated teller machines (ATMs) enabled and operated in the country by them, natural and legal persons can withdraw, per day and in a single withdrawal, at least up to $ 15,000, without any distinction between customers and non-customers, regardless of the type of checking account on which the corresponding operation is made and of the financial entity and/or the ATM network to which it belongs.
CHECKING ACCOUNTS OPENED IN COOPERATIVE CREDIT BOXES B.C.R.A.
Section 11. Transitional provisions.
Version: 5a. COMMUNICATION “A” 7181
Validity:
18/12/2020

DEMAND ACCOUNTS OPENED IN COOPERATIVE CREDIT UNIONS Sec. Point Para. Com. Annex Sec. Point Para. OBSERVATIONS
7. 7.8. “A” 4713 Single 7. 7.8.
7.9. “A” 4713 Single 7. 7.9.
8.1. “A” 4713 Single 8. 8.1.
8.2. “A” 4713 Single 8. 8.2.
8.2.1. “A” 4713 Single 8. 8.2. C/Com. “A” 6042 and 6448.
8.2.2. “A” 4713 Single 8. 8.2.
8.3. “A” 4713 Single 8. 8.3.
8.
8.4. “A” 4713 Single 8. 8.4.
9. 9.1. “A” 4713 Single 9. 9.1.
9.2. “A” 4713 Single 9. 9.2.
10.1. “A” 4713 Single 10. 10.1. C/Com. “A” 6419.
10.2. “A” 4713 Single 10. 10.3.
10.3. “A” 4713 Single 10. 10.4.
10.4. “A” 4713 Single 10. 10.5. C/Com. “A” 5388.
10.5. “A” 4713 Single 10. 10.6.
10.6. 1° “A” 5212
10.6.1. “A” 5127 3. C/Com. “B” 9961 and “A” 5164, 5212,
5473, 5718 and 5927 (pt. 3.).
10.6.2. “A” 5212 C/Com. “A” 5718.
10.7. “A” 5588
10.7.1. “A” 5588
10.7.2. “A” 5588
10.8. “A” 5928 10. C/Com. “A” 6236, 6483, 6639, 6709 and
6762.
10.
10.9. “A” 6273
11.1. “A” 6945 C/Com. “A” 6957, 7009, 7044, 7107,
7181 and “C” 87078.
11.
11.2. “A” 7181 2.