SBS Resolution No. 4081-2025: Amendment to Title VI of the Compendium of Regulatory Supervision Norms for the Private Pension Fund Administration System, Regarding Investments

Page 1 of 4 Los Laureles No. 214 - Lima 27 - Peru Tel.: (511)630-9000 Lima, November 13, 2025

SBS RESOLUTION No. 4081-2025

The Superintendent of Banking, Insurance and Private Pension Fund Administrators

CONSIDERING Whereas Supreme Decree No. 054-97-EF approved the Consolidated Text of the Law of the Private Pension Fund Administration System, hereinafter the SPP Law; Whereas Supreme Decree No. 004-98-EF approved the Regulations of said SPP Law; Whereas Law No. 32445 exceptionally and optionally authorized all members of the Private Pension Fund Administration System (SPP), without exception, to withdraw up to four Taxable Income Units (4 UIT) from the accumulated funds in their respective individual capitalization accounts; Whereas the early withdrawal of pension funds affects the investment strategy established by Private Pension Fund Administrators (AFP), as liquidity demand to cover members' early withdrawals generates the need for immediate and/or progressive asset sales, affecting the composition and performance of managed portfolios and, consequently, the expected replacement rate provided by the SPP; Whereas, in this context, it is a priority to approve the following extraordinary investment measures to provide AFPs with necessary instruments to mitigate impacts on expected replacement rates and future member pensions resulting from the extraordinary withdrawal authorized by Law No. 32445: allow the extraordinary transfer of local equity instruments from type 3 funds to type 1 and/or type 2 funds, under specific technical conditions; temporarily authorize bilateral repo operations with financial system companies without the need for an intermediary agent; allow inter-fund lending of Peruvian government bonds, with guarantees and market-rate returns; temporarily relax trading limits applicable to foreign currency purchase and sale operations; establish internal issuer limits for investments in foreign sovereign debt rated above BBB-, considering each fund's risk profile; and temporarily authorize the acquisition of derivative instruments, such as futures on sovereign debt and equity securities, within existing regulatory limits, allowing their maintenance until maturity and considering any resulting excesses as non-imputable; Whereas the execution of these measures must be carried out in strict compliance with Article 21-B of the SPP Law, which regulates the fiduciary responsibility of AFPs, establishing their obligation to administer pension funds always attending to members' interests; Whereas, additionally, in accordance with Article 59 of the SPP Law Regulations, AFPs must manage funds with diligence, competence, impartiality, prudence, and honesty, maintaining an adequate balance between profitability and risk, diversifying investments, and respecting current regulations; With the approval of the Adjunct Superintendencies for Pensions, and Regulation and Legal Affairs, as well as the Risk Management and Economic Studies Departments; and, In exercise of the powers conferred by paragraph 7 of Article 349 of the General Law of the Financial and Insurance System and Organic Law of the Banking and Securities Superintendency, Law No. 26702 and its amendments, in Article 57 of the SPP Law, and based on what is provided in the Thirty-Second Final and Complementary Provision of the General Law;

RESOLVES: Article One. – Incorporate the forty-first transitional provision of Title VI of the Compendium of Regulatory Supervision Norms for the Private Pension Fund Administration System, approved via SBS Resolution No. 052-98-EF/SAFP, regarding Investments, according to the following text: “Forty-first. Extraordinary measures due to extraordinary and optional withdrawals - Law 32445. The AFP is granted the authority to implement the following provisions: a) Extraordinary transfer of local equity instruments. The AFP may carry out the transfer of the category of local equity instruments (shares) from type 3 fund (source fund) to type 1 fund, type 2 fund, or both (destination funds), complying with the following:

1. Maximum amount. The maximum amount to be transferred from the source fund must not exceed the accumulated net outflows executed by inter-fund transfer operations from the source fund to the destination fund between May 2024 and October 2025, multiplied by the portfolio percentage in the category of local equity instruments of the source fund, calculated using the price vector from the last Daily Investment Report (DIR) that has received approval. In case local equity instruments have been transferred due to inter-fund transfer operations during the aforementioned period and from the source fund, these amounts must be deducted from the balance calculated for the extraordinary transfer of local equity instruments to each destination fund.
2. Local equity instruments to be transferred. The units of investment instruments to be transferred from the source fund must consider the following: a. Apply the cross-sectional criterion to maintain, as much as possible, the same percentage composition of investment instruments comprising the instrument category in the source fund. b. Once the amount corresponding to each investment instrument is determined, calculate the units to be transferred, rounding down. c. It may decide not to transfer to the destination fund local equity instruments whose total stock valuation in the source fund at the time of transfer is equal to or less than three hundred fifty thousand Soles (S/. 350,000). d. It may transfer investment instruments up to the maximum investment percentages defined in the respective investment policies of the destination funds, provided it is consistent with the strategy defined by the AFP's investment committee for said funds.
3. Method of compensating the transfer. The destination fund must compensate the source fund with cash transfers for the same value of the units effectively transferred, calculated using the price vector from the last Daily Investment Report (DIR) that has received approval.
4. Transfer date. The transfer must be carried out in December 2025 within the timeframe established in Title V of the Compendium of Regulatory Supervision Norms for the SPP, regarding resource transfers generated from inter-fund transfer requests.
5. Information to the Superintendency. The AFP must notify the Superintendency, by December 3, 2025 at the latest, with information from the last DIR that has obtained its respective approval, of its intention to carry out the extraordinary transfer, attaching the annexes made available to the AFP through the Supervised Entity Portal. b) Temporary authorization to carry out repo operations. The AFP may carry out, until July 2026, repo operations directly with financial system companies, without the need for an intermediary agent, allowing the delivery of equity securities in case these act as the reporting party. c) Temporary authorization to carry out lending of Peruvian government bonds. The AFP may carry out, until July 2026, lending operations of Peruvian government bonds belonging to type 1 or 2 funds to type 3 fund. In these operations, the AFP may offer debt and equity securities as collateral. The remuneration between funds is established according to market rates, duly substantiated. d) Trading limits applicable to foreign currency purchase and sale operations. Until July 2026, excesses beyond the limits established in Article 77-K, regarding maximum limits applicable to foreign currency purchase and sale operations, are considered non-imputable. The AFP must apply reasonable and prudent criteria in managing these excesses, ensuring that their occurrence and magnitude remain within levels consistent with adequate investment and risk management. e) Issuer limits for foreign sovereign debt. Until July 2026, the sum of investments made in debt instruments issued by the same State, which holds an international rating greater than or equal to BBB- for its long-term debt securities, is subject to the internal limit defined by the AFP's risk committee, considering the risk associated with the instruments and the profile of each fund type. In case investment excesses occur during this period, they will be considered non-imputable. f) Temporary execution of derivative operations. The AFP may temporarily acquire until July 2026, the following derivative instruments: i) futures on debt securities issued by States with international ratings; and ii) equity futures. Such operations must not exceed the limits defined in Article 75-F. Derivative operations carried out may be maintained until maturity and are considered non-imputable if they generate excesses. Prior to investing in the aforementioned derivative instruments, the AFP must ensure it has trained and experienced personnel relevant to investing in said instruments, complying with what is established in SBS Resolution No. 114-2005 and its amendments. Likewise, it must have systems and models that allow tracking the performance of these types of instruments and managing associated risks.

Article Two. - This resolution takes effect from the day following its publication in the Official Gazette El Peruano.

Registered, communicated, and published SERGIO JAVIER ESPINOSA CHIROQUE Superintendent of Banking, Insurance and AFP