SOCIALIST REPUBLIC OF VIETNAM

Independence - Freedom - Happiness

CIRCULAR¹

Regulating financial safety indicators and handling measures for securities business organizations that do not meet financial safety indicators

Circular No. 91/2020/TT-BTC dated November 13, 2020 of the Minister of the Ministry of Finance regulating financial safety indicators and handling measures for securities business organizations that do not meet financial safety indicators, effective from January 01, 2021, is amended and supplemented by:

Circular No. 102/2025/TT-BTC dated October 29, 2025 of the Minister of the Ministry of Finance amending and supplementing some articles of Circular No. 91/2020/TT-BTC regulating financial safety indicators and handling measures for securities business organizations that do not meet financial safety indicators, effective from December 15, 2025.

• Based on the Securities Law dated November 26, 2019;
• Based on the Enterprise Law dated June 17, 2020;
• Based on Decree No. 87/2017/ND-CP dated July 26, 2017 of the Government regulating the functions, tasks, powers, and organizational structure of the Ministry of Finance;
• According to the proposal of the Chairman of the State Securities Commission;
• The Minister of the Ministry of Finance issues the Circular regulating financial safety indicators and handling measures for securities business organizations that do not meet financial safety indicators.²

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¹ This document is consolidated from the following 02 Circulars:

• Circular No. 91/2020/TT-BTC dated November 13, 2020 of the Minister of the Ministry of Finance regulating financial safety indicators and handling measures for securities business organizations that do not meet financial safety indicators.
• Circular No. 102/2025/TT-BTC dated October 29, 2025 of the Minister of the Ministry of Finance amending and supplementing some articles of Circular No. 91/2020/TT-BTC regulating financial safety indicators and handling measures for securities business organizations that do not meet financial safety indicators.

This consolidated document does not replace the 02 Circulars mentioned above.

² Circular No. 102/2025/TT-BTC dated October 29, 2025 of the Minister of the Ministry of Finance amending and supplementing some articles of Circular No. 91/2020/TT-BTC regulating financial safety indicators and handling measures for securities business organizations that do not meet financial safety indicators has the following basis for issuance:

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2

## Chapter I
### GENERAL PROVISIONS

### Article 1. Scope of regulation and subjects of application

#### 1. Scope of regulation

This Circular guides the determination of financial safety indicators, the reporting regime on financial safety ratios of securities business organizations, handling measures, and responsibilities of related parties for securities business organizations that do not meet financial safety indicators. This Circular does not apply to the determination of tax obligations of securities business organizations to the State budget.

#### 2. Subjects of application

a) Securities companies, branches of foreign securities companies in Vietnam (hereinafter collectively referred to as securities companies), securities investment fund management companies, branches of foreign fund management companies in Vietnam (hereinafter collectively referred to as fund management companies);
b) Related agencies, organizations, and individuals.

### Article 2. Interpretation of terms

In this Circular, the following terms are understood as follows:

1. **Securities business organization** is a securities company, a branch of a foreign securities company in Vietnam, a securities investment fund management company, or a branch of a foreign fund management company in Vietnam.

2. **Market risk value** is the value corresponding to the level of loss that may occur when the market price of assets currently owned and expected to be owned under underwriting commitments fluctuates in an unfavorable direction.

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“Based on the Securities Law No. 54/2019/QH14 amended and supplemented by Law No. 56/2024/QH15;
Based on the Enterprise Law No. 59/2020/QH14 amended and supplemented by Law No. 03/2022/QH15 and Law No. 76/2025/QH15;
Based on Decree No. 29/2025/ND-CP of the Government regulating the functions, tasks, powers, and organizational structure of the Ministry of Finance amended and supplemented by Decree No. 166/2025/ND-CP;
According to the proposal of the Chairman of the State Securities Commission;
The Minister of the Ministry of Finance issues the Circular amending and supplementing some articles of Circular No. 91/2020/TT-BTC regulating financial safety indicators and handling measures for securities business organizations that do not meet financial safety indicators.”

3. Payment risk value is the value corresponding to the level of loss that may occur when a counterparty fails to make payments or transfer assets on time according to commitments.

4. Operational risk value is the value corresponding to the level of loss that may occur due to technical errors, system errors, and business process errors, human errors in the operation process, lack of business capital arising from expenses, losses from investment activities, or other objective causes.

5. Total risk value is the sum of market risk value, payment risk value, and operational risk value.

6. Available capital is equity capital that can be converted into cash within ninety (90) days.

7. Available capital ratio is the percentage between the value of available capital and the total risk value.

8. Payment guarantee is the commitment to assume financial obligations to ensure the payment of a third party.

9. Underwriting guarantee period is the period from the date the underwriting guarantee obligation arises in the form of a firm commitment to the date of payment to the issuing organization according to the commitment.

10. Net position for a security at a point in time (hereinafter referred to as net position for a security) is the number of securities held by the securities business organization, after reducing the number of securities lent, the number of securities hedged by put warrants, futures contracts, and increasing the number of securities borrowed in accordance with the provisions of the law.

11. Net payment position for a counterparty at a point in time (hereinafter referred to as net payment position for a counterparty) is the value of loans and receivables after adjusting for debts and payables to that counterparty.

12. Group of organizations and individuals related to an organization or an individual (hereinafter referred to as group of related organizations and individuals) is organizations and individuals as prescribed at Clause 46, Article 4 of the Securities Law.

13. Margin value is the sum of the following values:

a) Monetary value and securities contributed by the securities business organization to the clearing fund of the Vietnam Securities Depository and Clearing Corporation;

b) Monetary value and securities pledged by the securities business organization for investment, proprietary trading, and market-making transactions for derivative securities;

c) Monetary margins and payment guarantee values of the custodian bank in the case where the securities company issues covered warrants.

14. Open interest of a derivative security at a point in time (hereinafter referred to as open interest) is the volume of derivative securities still outstanding at that time, not yet settled or closed out.

15. Approved auditing organization is an independent auditing organization on the list of auditing organizations approved by the State Securities Commission to audit according to the provisions of the Securities Law and independent auditing law.

16. In-the-money warrant is a call warrant with an exercise price (exercise index) lower than the price (index) of the underlying security or a put warrant with an exercise price (exercise index) higher than the price (index) of the underlying security.

17. Exercise price is the price at which the warrant holder has the right to buy (for call warrants) or sell (for put warrants) the underlying security (stock or ETF fund certificate) to the issuer, or is used by the issuer to determine the payment to the warrant holder.

18. Conversion ratio indicates the number of warrants needed to convert into one unit of underlying security.

Article 3. Principles of application

1. Securities business organizations are responsible for calculating financial safety indicators and are responsible for the accuracy of the calculation results.

2. Asset and capital items used to calculate available capital value and risk values must be updated to the point of calculation.

3. Securities business organizations are not required to calculate risk values for asset items already deducted from available capital as prescribed at Article 5 and Article 6 of this Circular.

4. For securities business organizations with subsidiaries, the securities business organization calculates financial safety indicators based on the separate financial items of the securities business organization.

5. The financial safety ratio report as of June 30 must be reviewed by an approved auditing organization according to Vietnamese auditing standards for review engagement services. The financial safety ratio report as of December 31 and the financial safety ratio report used to prove that the securities business organization meets the conditions to be removed from warning, control, and special control status must be audited by an approved auditing organization according to Vietnamese auditing standards for audit of financial reports prepared for special purposes and other relevant auditing standards.

6. Securities business organizations must establish an information and internal control system to record, monitor, and update fully financial information and detailed information for the preparation and review, audit of financial safety ratio reports. The Board of Directors (executive management board) of the securities business organization is responsible for the preparation and presentation of the financial safety ratio report according to the provisions of this Circular.

Chapter II

FINANCIAL SAFETY INDICATORS

Section 1

AVAILABLE CAPITAL

Article 4. Available capital

1. Available capital of securities companies is determined according to the provisions at Appendix VI issued together with this Circular, specifically as follows: a) Capital contribution of owners, excluding redeemable preferred shares (if any); b) Share premium excluding redeemable preferred shares (if any); c) Convertible bond conversion option - Equity component (for securities companies issuing convertible bonds); d) Other owner's capital; đ) Fair value adjustment of assets; e) Exchange rate differences; g) Reserve fund for supplementing charter capital; h) Financial and business risk reserve fund; i) Other funds belonging to owner's equity established in accordance with legal provisions; k) Undistributed after-tax profit excluding the value of items prescribed at Clause 3 Article 5 and Clause 1 Article 7 of this Circular; l) Balance of asset impairment provision; m) Fifty percent (50%) of the increased value of fixed assets revalued according to legal provisions (in case of revaluation increase), or deduct the entire decreased value (in case of revaluation decrease);

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³ This point is amended and supplemented according to Clause 1 Article 1 Circular No. 102/2025/TT-BTC dated October 29, 2025 of the Minister of the Ministry of Finance amending and supplementing some articles of Circular No. 91/2020/TT-BTC regulating financial safety indicators and handling measures for securities business organizations that do not meet financial safety indicators, effective from December 15, 2025.

n)⁴ Deductions according to the provisions at Article 5 of this Circular and treasury stock deduction (if any); o) Additions according to the provisions at Article 7 of this Circular; p) Other capital (if any).

2. Available capital of fund management companies is determined according to the provisions at Appendix V issued together with this Circular, specifically as follows: a) Owner's investment capital, excluding redeemable preferred shares (if any); b) Share premium excluding redeemable preferred shares (if any); c) Reserve fund for supplementing charter capital; d) Development investment fund (if any); đ) Financial and business risk reserve fund; e) Other funds belonging to owner's equity established in accordance with legal provisions; g) Undistributed after-tax profit; h) Balance of asset impairment provision; i) Fifty percent (50%) of the increased value of fixed assets revalued according to legal provisions (in case of revaluation increase), or deduct the entire decreased value (in case of revaluation decrease); k) Exchange rate differences; l)⁵ Deductions according to the provisions at Article 6 of this Circular and treasury stock deduction (if any); m) Additions according to the provisions at Article 7 of this Circular; n) Other capital (if any).

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⁴ This point is amended and supplemented according to Clause 1 Article 1 Circular No. 102/2025/TT-BTC dated October 29, 2025 of the Minister of the Ministry of Finance amending and supplementing some articles of Circular No. 91/2020/TT-BTC regulating financial safety indicators and handling measures for securities business organizations that do not meet financial safety indicators, effective from December 15, 2025.

⁵ This point is amended and supplemented according to Clause 2 Article 1 Circular No. 102/2025/TT-BTC dated October 29, 2025 of the Minister of the Ministry of Finance amending and supplementing some articles of Circular No. 91/2020/TT-BTC regulating financial safety indicators and handling measures for securities business organizations that do not meet financial safety indicators, effective from December 15, 2025.

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3.⁶ (Abolished)

Article 5. Deductions from available capital of securities companies

1. Margin value. In the case where the securities company has collateral assets for the bank to issue a payment guarantee when issuing covered warrants, the deduction value is the smallest of the following values: the bank's payment guarantee value; the collateral asset value determined according to Clause 6 Article 10 of this Circular.

2.⁷ Value of assets used to secure obligations of the securities business organization and other organizations and individuals with a remaining term of more than 90 days. In case the collateral asset is used for multiple obligations of the securities business organization, the deduction is calculated proportionally for each obligation of the securities business organization (Remaining value of obligation/Collateral asset). The asset value is determined according to Clause 6 Article 10 of this Circular.

3. The entire decreased value of financial assets recorded at book value, excluding securities prescribed at Clause 7 of this Article, based on the difference between book value and market value determined according to Appendix II issued together with this Circular.

4. Other deductions determined according to the provisions at Appendix VI issued together with this Circular as follows: a) Items in long-term assets, except cases prescribed at Clause 6 of this Article; b) Items in short-term assets as follows:

• Securities prescribed at Clause 7 of this Article under the short-term financial assets item;
• Prepayments;
• Receivables with a remaining collection or payment term of more than ninety (90) days;
• Advances with a remaining repayment term of more than ninety (90) days;

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⁶ This clause is abolished according to Clause 1 Article 8 Circular No. 102/2025/TT-BTC dated October 29, 2025 of the Minister of the Ministry of Finance amending and supplementing some articles of Circular No. 91/2020/TT-BTC regulating financial safety indicators and handling measures for securities business organizations that do not meet financial safety indicators, effective from December 15, 2025.

⁷ This clause is amended and supplemented according to Clause 1 Article 2 Circular No. 102/2025/TT-BTC dated October 29, 2025 of the Minister of the Ministry of Finance amending and supplementing some articles of Circular No. 91/2020/TT-BTC regulating financial safety indicators and handling measures for securities business organizations that do not meet financial safety indicators, effective from December 15, 2025.

• Other short-term assets, except cases prescribed at Clause 5 of this Article.

c) Exceptions, adverse opinions, or disclaimers (if any) on the audited or reviewed financial report that have not been deducted from available capital according to points a, b of this clause. In case the auditing organization confirms that the exception has ended, the securities business organization is not required to deduct this item.

5. The deduction from available capital according to points a, b of Clause 4 of this Article does not include the following items:

a) Assets that must determine market risk according to Clause 2 Article 9 of this Circular, except securities prescribed at Clause 7 of this Article;

b) Provision for impairment of financial assets recorded at book value;

c) Provision for impairment of other assets;

d) Provision for doubtful receivables;

đ) Contracts and transactions mentioned at point k Clause 1 Article 10 of this Circular.

6. When determining asset items deducted from available capital prescribed at Clause 1, Clause 2, point a, b of Clause 4 of this Article, the securities business organization may adjust to reduce the deduction value as follows:

a) For assets used to secure obligations of the securities business organization itself, when calculating the deduction, the smallest of the following values is deducted: the market value of the asset determined according to Appendix II issued together with this Circular (if any), the book value, the remaining value of the obligation;

b) For assets secured by customer assets, when calculating the deduction, the smallest of the following values is deducted: the collateral asset value determined according to Clause 6 Article 10 of this Circular, the book value.

7. The following securities in the short-term financial assets and long-term financial assets items must be deducted from available capital:

a) Securities issued by related organizations to the securities business organization in the following cases:

• Parent company, subsidiary of the securities business organization;

• Subsidiary of the parent company of the securities business organization.

b) Securities with a remaining restricted transfer period of more than ninety (90) days from the calculation date.

8.⁸ Deduction according to the provisions at Clause 9 Article 10 of this Circular.

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⁸ This clause is supplemented according to Clause 2 Article 2 Circular No. 102/2025/TT-BTC dated October 29, 2025 of the Minister of the Ministry of Finance amending and supplementing some articles of

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Article 6. Deductions from available capital of fund management companies

1. The entire decreased value of investments, excluding securities prescribed at Clause 5 of this Article, based on the difference between book value and market value determined according to Appendix II issued together with this Circular.

2. Other deductions determined according to the provisions at Appendix V issued together with this Circular as follows:

a) Items in long-term assets, except cases prescribed at Clause 3 of this Article;

b) Items in short-term assets as follows:

• Securities prescribed at Clause 5 of this Article under the short-term financial investment item;

• Prepayments;

• Receivables with a remaining collection or payment term of more than ninety (90) days;

• Advances with a remaining repayment term of more than ninety (90) days;

• Other short-term assets, except cases prescribed at Clause 3 of this Article.

c) Exceptions, adverse opinions, or disclaimers (if any) on the audited or reviewed financial report that have not been deducted from available capital according to points a, b of this clause. In case the auditing organization confirms that the exception has ended, the securities business organization is not required to deduct this item.

3. The deduction from available capital according to points a, b of Clause 2 of this Article does not include the following items:

a) Assets that must determine market risk according to Clause 2 Article 9 of this Circular, except securities prescribed at Clause 5 of this Article;

b) Investment depreciation provision;

c) Provision for doubtful receivables;

d) Contracts and transactions mentioned at point k Clause 1 Article 10 of this Circular.

4. When determining asset items deducted from available capital prescribed at points a, b of Clause 2 of this Article, the securities business organization may adjust to reduce the deduction value as follows:

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Circular No. 91/2020/TT-BTC regulating financial safety indicators and handling measures for securities business organizations that do not meet financial safety indicators, effective from December 15, 2025.

a) For assets used to secure obligations of the securities business organization itself or for third parties, when calculating the deduction, the smallest of the following values is deducted: the market value of the asset determined according to Appendix II issued together with this Circular (if any), the book value, the remaining value of the obligation;

b) For assets secured by customer assets, when calculating the deduction, the smallest of the following values is deducted: the collateral asset value determined according to Clause 6 Article 10 of this Circular, the book value.

5. The following securities in the short-term financial investment and long-term financial investment items must be deducted from available capital:

a) Securities issued by related organizations to the securities business organization in the following cases:

• Parent company, subsidiary of the securities business organization;

• Subsidiary of the parent company of the securities business organization.

b) Securities with a remaining restricted transfer period of more than ninety (90) days from the calculation date.

6.⁹ Deduction according to the provisions at Clause 9 Article 10 of this Circular.

Article 7. Additions

1. The entire increased value of investments, financial assets recorded at book value excluding securities prescribed at Clause 7 Article 5, Clause 5 Article 6 of this Circular, based on the difference between book value and market value determined according to Appendix II issued together with this Circular.

2. Convertible debts include:

a)¹⁰ Convertible bonds except cases already counted as available capital at point c Clause 1 Article 4 of this Circular, redeemable preferred shares issued by the securities business organization satisfying all the following conditions:

• Initial term of at least 05 years;

• Not secured by assets of the securities business organization

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⁹ This clause is supplemented according to Article 3 Circular No. 102/2025/TT-BTC dated October 29, 2025 of the Minister of the Ministry of Finance amending and supplementing some articles of Circular No. 91/2020/TT-BTC regulating financial safety indicators and handling measures for securities business organizations that do not meet financial safety indicators, effective from December 15, 2025.

¹⁰ This point is amended and supplemented according to Article 4 Circular No. 102/2025/TT-BTC dated October 29, 2025 of the Minister of the Ministry of Finance amending and supplementing some articles of Circular No. 91/2020/TT-BTC regulating financial safety indicators and handling measures for securities business organizations that do not meet financial safety indicators, effective from December 15, 2025.

itself;

• Convertible bonds cannot be called early or can only be called early if the bond terms stipulate that the issuing organization may call the bonds early upon the request of the bondholder or buy back on the secondary market, and the buyback of these convertible bonds is implemented when meeting the provisions at Clause 5 of this Article after the securities business organization reports to the State Securities Commission according to the provisions at Clause 6 of this Article;

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• A securities business organization may suspend interest payments and carry accumulated interest to the next year if paying interest leads to a loss in the year's business results;

• In the event of the dissolution of a securities business organization, holders may only be paid after the securities business organization has paid all secured and other unsecured creditors;

• Interest rate adjustments, including adjustments to the reference rate plus an additional rate, may only be implemented after 05 years from the issuance date and may be adjusted only once throughout the term before conversion into common stock;

• Additional available capital has been registered in accordance with Clause 4 of this Article.

b) Other debt instruments satisfying all of the following conditions:

• It is a debt under which, in all cases, the creditor may only be paid after the securities business organization has paid all secured and other unsecured creditors;

• It has an initial maturity of at least ten (10) years;

• It is not secured by the assets of the securities business organization itself;

• A securities business organization may suspend interest payments and carry accumulated interest to the next year if paying interest leads to a loss in the year's business results;

• The creditor may only be paid early by the securities business organization after notifying the State Securities Commission in accordance with Clauses 5 and 6 of this Article;

• Interest rate adjustments must ensure the following: For fixed rates, the adjustment to increase the rate plus the reference rate may only be implemented after five (05) years from the issuance and contract signing date, and may be adjusted only one (01) time throughout the term of the subordinated debt; For rates calculated by formula, the formula must not be changed, and only the variables in the formula (if any) may be changed one (01) time after five (05) years from the issuance and contract signing date;

• Additional available capital has been registered in accordance with Clause 4 of this Article.

3. Limits when calculating additional amounts for available capital:

a) The values of the items specified at points a and b of Clause 2 of this Article must be calculated with gradual reduction according to the following principles:

• During the last five (05) years before the maturity date, conversion into common stock, after each year approaching the conversion or payment maturity, the values of the items specified at points a and b of Clause 2 of this Article must be depreciated by 20% of the initial value;

• During the last four (04) quarters before the maturity date, conversion into common stock, an additional 25% of the remaining value after depreciation according to the above regulations must be deducted each quarter.

b) The total value of the items specified in Clause 2 of this Article used to supplement available capital is maximum 50% of the equity capital.

4. Securities business organizations must report supplementary debts specified in Clauses 2 and 3 of this Article to the available capital to the State Securities Commission. Reports sent directly to the State Securities Commission include:

a) Reports according to the model in Appendix VII issued with this Circular regarding the use of convertible bonds, preferred shares, and debts to supplement available capital;

b) Meeting minutes, Resolutions of the Board of Directors, Board of Members, Decisions of the owner regarding the use of debts that can be converted into equity capital to supplement available capital;

c) Valid copies of loan contracts or equivalent documents, loan contracts or equivalent documents must have commitments from both parties with full contents consistent with the regulations in Clauses 2 and 3 of this Article. This regulation does not apply to the case of issuing bonds to the public that has been issued a Certificate of Offering by the State Securities Commission.

5. Securities business organizations may buy back convertible bonds, preferred shares, or pay off debts early that have supplemented available capital in the following cases:

a) The available capital ratio after buying back convertible bonds, preferred shares, or paying off debts early that have been registered for use to supplement available capital, does not fall below the level of 180%;

b) In the case where the securities business organization does not meet the regulation in point a of this clause, the securities business organization must have new capital sources to supplement to ensure maintaining the minimum available capital ratio not lower than 180%.

6. Securities business organizations must report to the State Securities Commission at least fifteen (15) days before buying back convertible bonds, preferred shares, or paying off debts early that have supplemented available capital. Reports sent directly to the State Securities Commission include:

a) Reports according to the regulation in point a of Clause 4 of this Article;

b) Documents according to the regulation in points b and c of Clause 4 of this Article regarding new convertible bonds, preferred shares, and debts used to supplement available capital, replacing the convertible bonds, preferred shares to be bought back, and debts to be paid (if any).

Section 2

RISK VALUES

Article 8. Operational Risk Value

1. The operational risk of a securities business organization is determined as the maximum value of the following values: 25% of the cost to calculate operational risk¹¹ of the securities business organization over the consecutive twelve (12) months up to the calculation time, 20% of the minimum charter capital for the business activities of the securities business organization according to the regulations of law.

2. The cost to calculate operational risk¹² of a securities company is determined by the total costs incurred in the period, minus:

a) Depreciation costs;

b) Costs or provisions for impairment of short-term financial assets and collateral assets;

c) Costs or provisions for impairment of long-term financial assets;

d) Costs or provisions for impairment of receivables;

d) Costs or provisions for impairment of other short-term assets;

e) Costs of decrease in revaluation of financial assets recognized through profit/loss;

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¹¹ The phrase "operating maintenance costs" is replaced by the phrase "cost to calculate operational risk" according to Clause 2 of Article 8 of Circular No. 102/2025/TT-BTC dated October 29, 2025 of the Minister of the Ministry of Finance amending and supplementing some articles of Circular No. 91/2020/TT-BTC regulating financial safety indicators and handling measures for securities business organizations not meeting financial safety indicators, effective from December 15, 2025.

¹² The phrase "operating maintenance costs" is replaced by the phrase "cost to calculate operational risk" according to Clause 2 of Article 8 of Circular No. 102/2025/TT-BTC dated October 29, 2025 of the Minister of the Ministry of Finance amending and supplementing some articles of Circular No. 91/2020/TT-BTC regulating financial safety indicators and handling measures for securities business organizations not meeting financial safety indicators, effective from December 15, 2025.

g) Interest expense costs.

h)¹³ Costs of differences due to revaluation of outstanding warrants to be paid;

i)¹⁴ Costs or income of unrealized exchange rate differences;

k)¹⁵ Financial costs and other non-monetary costs in the business activities of the securities company.

3. The cost to calculate operational risk¹⁶ of a fund management company is determined by the total costs incurred in the period, minus:

a) Depreciation costs;

b) Costs or provisions for impairment of short-term investments;

c) Costs or provisions for impairment of long-term investments;

d) Costs or provisions for impairment of difficult-to-collect receivables.

d)¹⁷ Costs or income of unrealized exchange rate differences;

e)¹⁸ Other non-monetary costs in the business activities of the fund management company.

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¹³ This point is supplemented according to Clause 1 of Article 5 of Circular No. 102/2025/TT-BTC dated October 29, 2025 of the Minister of the Ministry of Finance amending and supplementing some articles of Circular No. 91/2020/TT-BTC regulating financial safety indicators and handling measures for securities business organizations not meeting financial safety indicators, effective from December 15, 2025.

¹⁴ This point is supplemented according to Clause 1 of Article 5 of Circular No. 102/2025/TT-BTC dated October 29, 2025 of the Minister of the Ministry of Finance amending and supplementing some articles of Circular No. 91/2020/TT-BTC regulating financial safety indicators and handling measures for securities business organizations not meeting financial safety indicators, effective from December 15, 2025.

¹⁵ This point is supplemented according to Clause 1 of Article 5 of Circular No. 102/2025/TT-BTC dated October 29, 2025 of the Minister of the Ministry of Finance amending and supplementing some articles of Circular No. 91/2020/TT-BTC regulating financial safety indicators and handling measures for securities business organizations not meeting financial safety indicators, effective from December 15, 2025.

¹⁶ The phrase "operating maintenance costs" is replaced by the phrase "cost to calculate operational risk" according to Clause 2 of Article 8 of Circular No. 102/2025/TT-BTC dated October 29, 2025 of the Minister of the Ministry of Finance amending and supplementing some articles of Circular No. 91/2020/TT-BTC regulating financial safety indicators and handling measures for securities business organizations not meeting financial safety indicators, effective from December 15, 2025.

¹⁷ This point is supplemented according to Clause 2 of Article 5 of Circular No. 102/2025/TT-BTC dated October 29, 2025 of the Minister of the Ministry of Finance amending and supplementing some articles of Circular No. 91/2020/TT-BTC regulating financial safety indicators and handling measures for securities business organizations not meeting financial safety indicators, effective from December 15, 2025.

¹⁸ This point is supplemented according to Clause 2 of Article 5 of Circular No. 102/2025/TT-BTC dated October 29, 2025 of the Minister of the Ministry of Finance amending and supplementing some articles of

4. In the case where a securities business organization operates for less than one (01) year, operational risk is determined as the maximum value of the following values: three (03) times the average monthly cost to calculate operational risk¹⁹ from the time the securities business organization starts operations; twenty percent (20%) of the minimum charter capital for the business activities of the securities business organization according to the regulations of law.

Article 9. Market Risk Value

1. At the end of the trading day, the securities business organization must determine the market risk value for the assets of the securities business organization specified in Clause 2 of this Article.

2. Market risk must be determined for the following assets:

a) Securities in the proprietary trading account not including the quantity of covered warrants not fully issued (for securities companies), securities trading accounts (for fund management companies, securities companies without proprietary trading business), entrusted securities, other investment securities. The above securities include both securities in the process of receiving transfer from the seller;

b) Securities received as support from other individuals and organizations according to the regulations of law, including securities borrowed for the securities business organization itself, securities borrowed on behalf of other individuals and organizations;

c) Customer securities that the securities business organization receives as collateral, which are then used by the securities business organization or lent to a third party in accordance with the regulations of law;

d) Cash, cash equivalents, transferable instruments, and other securities owned by the securities business organization;

d) Securities that the securities business organization underwrites in the form of a firm commitment that have not been distributed and not fully paid during the underwriting period.

3. Securities and assets specified in Clause 2 of this Article do not include the

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Circular No. 91/2020/TT-BTC regulating financial safety indicators and handling measures for securities business organizations not meeting financial safety indicators, effective from December 15, 2025.

¹⁹ The phrase "operating maintenance costs" is replaced by the phrase "cost to calculate operational risk" according to Clause 2 of Article 8 of Circular No. 102/2025/TT-BTC dated October 29, 2025 of the Minister of the Ministry of Finance amending and supplementing some articles of Circular No. 91/2020/TT-BTC regulating financial safety indicators and handling measures for securities business organizations not meeting financial safety indicators, effective from December 15, 2025.

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following types:
a) Treasury shares;
b) Securities specified in Clause 7 of Article 5 and Clause 5 of Article 6 of this Circular;
c) Bonds, debt instruments, and money market securities that have matured.
d) Securities that have been hedged against risk by put warrants or futures contracts; Put warrants and put options are used to hedge risk for underlying securities.

4. The formula to determine the market risk value for assets specified in points a, b, c, d of Clause 2 of this Article is as follows:

Market Risk Value = Net Position × Asset Price × Market Risk Coefficient

a) Market risk coefficients are determined according to Appendix I issued with this Circular;

b) Asset prices are determined according to Appendix II issued with this Circular.

5.²⁰ The market risk value of each asset determined according to the regulation in Clause 4 of this Article must be adjusted upwards in the case where the securities business organization invests too much in that asset, except for securities during the underwriting period in the form of a firm commitment, government bonds, and bonds guaranteed by the government. The risk value is adjusted upwards according to the following principles:

a) Increase by 10% in the case where the total value of the investment in securities, the equity contribution of an organization, accounts for from over 10% to 15% of the equity capital of the securities business organization;

b) Increase by 20% in the case where the total value of the investment in securities, the equity contribution of an organization, accounts for from over 15% to 25% of the equity capital of the securities business organization;

c) Increase by 30% in the case where the total value of the investment in securities, the equity contribution of an organization, accounts for from over 25% or more of the equity capital of the securities business organization.

6. Securities business organizations must adjust upwards additional dividends, bond coupons, preferred share values if incurred (for securities), or interest

²⁰ This clause is amended and supplemented according to the regulation in Article 6 of Circular No. 102/2025/TT-BTC dated October 29, 2025 of the Minister of the Ministry of Finance amending and supplementing some articles of Circular No. 91/2020/TT-BTC regulating financial safety indicators and handling measures for securities business organizations not meeting financial safety indicators, effective from December 15, 2025.

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rates are less than thirty (30) days: the issuance risk coefficient is 60%;
- During the period from the end of the distribution period to the payment date to the issuer: the issuance risk coefficient is 80%.

d) After the last payment date to the issuer, the securities business organization must determine the market risk value for the quantity of securities that could not be fully distributed according to the regulation in Clause 4 of this Article.

d) The value of customer collateral assets is determined according to the regulation in Clause 6 of Article 10 of this Circular.

8. Securities companies must calculate the market risk value for outstanding covered warrants issued by the securities company. This risk value is determined by the following formula:

Market Risk Value = Max {((P₀ × Q₀ /k - P₁ × Q₁) × r -MD), 0}

Where:
P₀: is the average closing price of the underlying security in the 05 consecutive trading days before the calculation date.
Q₀: is the number of outstanding warrants of the securities company.
k: is the conversion ratio
P₁: is the price of the underlying security determined according to the regulation in Appendix II issued with this Circular
Q₁: is the number of underlying securities that the securities company uses to secure the payment obligation of the covered warrants issued by itself
r: is the market risk coefficient of the warrant determined according to the regulation in Appendix I issued with this Circular
MD: is the margin value when the securities company issues covered warrants

a) Underlying securities to calculate market risk according to the formula above must fully meet the following conditions:
- Already included in the issuance plan or registered with the State Securities Commission regarding the use of this security in the proprietary trading account to hedge risk when issuing covered warrants;
- Is the underlying security of the covered warrant.

b) In the case where warrants issued by the securities company do not have profit as specified in Clause 16 of Article 2 of this Circular, the securities company does not need to calculate market risk for the issued warrants but must calculate market risk for the underlying securities formed from the risk hedging activities for the issued warrants.

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c) Securities companies must calculate market risk for the positive difference between the value of underlying securities used by the securities company to hedge risk for covered warrants issued by itself and the value of underlying securities necessary to hedge risk for covered warrants. The necessary value to hedge risk for covered warrants must correspond to the hedging value.

9. Market risk value for futures contracts is determined by the following formula:

Market Risk Value
= Max {(End of day settlement value
- Value of securities purchased)
× Market risk coefficient of the futures contract
- Margin value), 0}

End of day settlement value
= End of day settlement price × Open interest

Where:
- Value of securities purchased is the value of underlying securities that the securities business organization purchases to secure the payment obligation of the futures contract;
- Margin value is the portion of asset value that the securities business organization deposits for investment, proprietary trading, and market making transactions.

**Article 10. Settlement Risk Value**

1. At the end of the trading day, the securities business organization must determine the settlement risk value for the following contracts and transactions:
a) ²¹ Time deposits at credit institutions, deposit certificates issued by credit institutions, money in securities trading accounts of fund management companies opening trading accounts at securities companies;
b) Securities lending and borrowing contracts in accordance with the regulations of law;
c) Securities sale contracts with a commitment to repurchase in accordance with the regulations of law;
d) Securities purchase contracts with a commitment to resell in accordance with

²¹ This point is amended and supplemented according to the regulation in Clause 1 of Article 7 of Circular No. 102/2025/TT-BTC dated October 29, 2025 of the Minister of the Ministry of Finance amending and supplementing some articles of Circular No. 91/2020/TT-BTC regulating financial safety indicators and handling measures for securities business organizations not meeting financial safety indicators, effective from December 15, 2025.

of law;

d) Margin lending contracts for purchasing listed securities in accordance with the regulations of law;

e) Underwriting contracts signed with other organizations in the underwriting consortium in the form of a firm commitment where the securities business organization is the main underwriting organization;

g)²² Receivables in securities business activities in accordance with the regulations of law, receivables when selling listed securities in the financial investment activities of fund management companies;

h) Receivables from matured bonds, securities, and debt instruments that have matured but have not been paid;

i) Assets past the transfer deadline, including securities in the business activities of the securities business organization, customer securities in securities brokerage activities.

k)²³ Contracts, transactions, and capital uses outside the transactions and contracts recorded in points a, b, c, d, d, e, g of this clause; contracts committing to repurchase or resell securities or contracts of a similar nature except for contracts specified in point c, d of this clause; receivables from debt purchases and sales with trading partners that are not the Vietnamese Asset Management Company (VAMC), Vietnamese Debt Management Company (DATC).

2. For contracts specified in points a, b, c, d, d, g of Clause 1 of this Article, the settlement risk value before the time of receiving transfer of securities, money, and contract termination is determined as follows:

Settlement Risk Value = Value of assets with potential settlement risk × Counterparty settlement risk coefficient

a) Counterparty settlement risk coefficients are determined depending on the creditworthiness of the trading partner according to the principles specified in Appendix III issued with this Circular;

b) Value of assets with potential settlement risk is determined according to the principles

²² This point is amended and supplemented according to the regulation in Clause 1 of Article 7 of Circular No. 102/2025/TT-BTC dated October 29, 2025 of the Minister of the Ministry of Finance amending and supplementing some articles of Circular No. 91/2020/TT-BTC regulating financial safety indicators and handling measures for securities business organizations not meeting financial safety indicators, effective from December 15, 2025.

²³ This point is amended and supplemented according to the regulation in Clause 1 of Article 7 of Circular No. 102/2025/TT-BTC dated October 29, 2025 of the Minister of the Ministry of Finance amending and supplementing some articles of Circular No. 91/2020/TT-BTC regulating financial safety indicators and handling measures for securities business organizations not meeting financial safety indicators, effective from December 15, 2025.