Deputy Superintendence Resolution SMV No. 013-2026-SMV/10 Sanctioning BLUM SAF for Late Information Submission — SMV — PE

PERÚ Ministry of Economy and Finance

In accordance with Article 1 of Law N° 29782, Law for the Strengthening of Securities Market Supervision, the name of the National Supervisory Commission of Companies and Securities (CONASEV) is replaced by that of the Superintendency of Securities Market (SMV), so that all references to CONASEV in legal norms shall be understood as made to the SMV;
I. FACTS
Within the supervisory functions assigned to the SMV, an evaluation was carried out regarding the timely submission of occasional information by BLUM Sociedad Administradora de Fondos S.A. (hereinafter, BLUM SAF);

PERÚ Ministry of Economy and Finance

SMV
Electronic document digitally signed under Law N° 27269, Law of Digital Signatures and Certificates, its Regulations and amendments. The integrity of the document and the authorship of the signature(s) can be verified at https://apps.firmaperu.gob.pe/web/validador.xhtml
3. As a result of said evaluation and under the provisions of the Consolidated Text of Law N° 27444 – General Administrative Procedure Law, approved by Supreme Decree N° 004-2019-JUS (hereinafter, TUO LPAG), by Official Letter N° 5917-2025-SMV/10.3, notified on October 20, 2025 (hereinafter, CHARGE LETTER), an administrative sanctioning procedure was initiated against BLUM SAF for infractions of the Regulations for Mutual Funds of Investment in Securities and their Administering Companies approved by CONASEV Resolution N° 068-2010-EF/94.01.1 and its amendments (hereinafter, FM REGULATIONS), the Regulations for Investment Funds and their Administering Companies approved by SMV Resolution N° 029-2014-SMV-01(hereinafter, IF REGULATIONS) and the Regulations for Material Events and Reserved Information, approved by SMV Resolution N°005-2014-SMV/01 and its amendments (hereinafter, RHI), in force at the time of the commission of the facts, for not having timely submitted the following information:
a. The material event related to the agreement for the cessation of a promoter, which occurred on March 11, 2022. Said material event should have been communicated to the RPMV on the day of its occurrence; however, it was reported on March 14, 2022^1. b. The material event related to the agreement for the designation of the members of the surveillance committee of the investment fund called “Blum Renta Alternativa Fondo de Inversión” (hereinafter, BLUM RENTA ALTERNATIVA), which occurred on January 25, 2022. Said material event should have been communicated to the RPMV on the day of its occurrence^2; however, it was reported on February 17, 2022^3.
c. The material event related to the communication of the result of the placement by public offering directed to institutional investors of the participation units of the BLUM RENTA ALTERNATIVA investment fund, which occurred on January 24, 2022. Said material event should have been communicated to the RPMV on the day of its occurrence; however, it was reported on January 25, 2022^4.
d. The material event related to the excess participation in relation to the participant “Founding Participant 1” of the mutual fund “Blum Capital Global Fondo Mutuo” (hereinafter, BLUM CAPITAL GLOBAL), which occurred on September 14, 2022. Said material event should have been communicated to the RPMV on September 15, 2022^5; however, it was reported on October 24, 2022^6. e. The material event related to the excess investment in relation to the entity “Non-Linked Fund” of the BLUM CAPITAL GLOBAL mutual fund, which occurred on September 27, 2022. Said material event should have been communicated on September 28, 2022^7; however, it was reported on March 31, 2023^8.

^1 File N° 2022010409
^2 On 01.25.2022, the administrator reported by file N°2022002863 that at the participants' assembly on 01.25.2022, the designation of the members of the surveillance committee, among others, was discussed, without detailing their names, a detail that was reported on 02.10.2022 by file N°2022002863, but without complying with the technical specifications of the registration and supervision information system approved by Superintendence Resolution N°003-2022-SMV/02, so such information is considered as not submitted in application of numeral 7.3 of article 7 of the RHI. Subsequently, by file N° 2022006809 dated 02.17.2022, the administrator submitted the structured format of the composition of the surveillance committee, in accordance with the aforementioned technical specifications. ^3 File N° 2022002863/ File N° 2022006809. ^4 File N° 2022002862 ^5 In accordance with the provisions of numerals 2, literal b), 3.1 and 5.2 of the Technical Specifications for information to be submitted by Administering Companies of Mutual Funds of Investment in Securities, approved by General Management Resolution N°058-2010-EF/94.01.2, the participants' file of a fund is reported daily and the frequency of information submission is no later than 8:00 p.m. on the next business day. ^6 File N° 2022042415

PERÚ Ministry of Economy and Finance

^7 In accordance with the provisions of numerals 2, literal b), 3.1 and 5.5 of the Technical Specifications for information to be submitted by Administering Companies of Mutual Funds of Investment in Securities, approved by General Management Resolution N°058-2010-EF/94.01.2, the valuation file with the detail of portfolio investment instruments of a fund is reported daily and the frequency of information submission is no later than 8:00 p.m. on the next business day. ^8 File N° 2023014827. ^9 Ibid. 7 ^10 File N° 2023014827. ^11 Ibid. 7 ^12 File N° 2023014827. ^13 File N° 2023005700. ^14 Ibid. 5 ^15 File N° 2023036368. ^16 Ibid. 5 ^17 File N° 2023051859. ^18 Ibid. 5 ^19 File N° 2023051872. ^20 Ibid 5 ^21 File N° 2024049883.

PERÚ Ministry of Economy and Finance

SMV
Electronic document digitally signed under Law N° 27269, Law of Digital Signatures and Certificates, its Regulations and amendments. The integrity of the document and the authorship of the signature(s) can be verified at https://apps.firmaperu.gob.pe/web/validador.xhtml m. The material event related to the excess participation in relation to “Participant 1” of the BLUM CAPITAL GLOBAL mutual fund, which occurred on September 23, 2024. Said material event should have been communicated on September 24, 2024^22; however, it was reported on December 10, 2024^23. n. The material event related to the change of the member of the surveillance committee of the investment fund “BLUM Renta Alternativa Fondo de Inversión”, which occurred on April 26, 2024. Said material event should have been communicated to the RPMV on the day of its occurrence; however, it was reported on July 02, 2024^24;
4. The indicated non-compliances are typified as minor infractions, in accordance with the provisions of Annex I, numeral 3, subsection 3.1 of the Sanctions Regulations, approved by Resolution N° 035-2018-SMV/01 (hereinafter, SANCTIONS REGULATIONS), according to which it constitutes an infraction: “Submitting, outside the established period, or doing so incompletely, or, without observing the technical specifications approved by the SMV or without communicating the approval by the corresponding corporate body, to the SMV, to the Stock Exchange, to the entity in charge of the centralized negotiation mechanism or to any other entity or subject of the securities market, the audited individual or consolidated financial information, the interim individual or consolidated financial statements, management report, special audit report, material events and annual reports”;
5. By means of a document submitted on October 31, 2025, BLUM SAF presented the defenses requested by the CHARGE LETTER;
6. The charges formulated, as well as the defenses presented by BLUM SAF, have been evaluated by the General Superintendency of Prudential Compliance in Report N° 1769-2025-SMV/10.3, which has been submitted to the knowledge of this Deputy Superintendency;
7. In observance of the Principle of Due Process contemplated both in Article IV, subsection 1, numeral 1.2 of the Preliminary Title, as well as in Article 248, numeral 2, of the TUO LPAG, by Official Letter N° 7049-2025-SMV/10, the administrative file to which this resolution refers was made available to BLUM SAF for its review;
8. On December 15, 2025, the administrator submitted additional written arguments;
9. On December 22, 2025, Blum SAF presented its oral report to the Deputy Superintendency of Prudential Supervision;
10. On December 23, 2025, the administrator submitted additional written arguments by which it states that it withdraws the arguments of nullity of the administrative sanctioning procedure developed in its arguments of December 15, 2025, and those complementary ones exposed in the use of the floor that are in the file;

^22 Ibid 5
^23 File N° 2024050642
^24 File N° 2024028715

PERÚ Ministry of Economy and Finance

SMV
Electronic document digitally signed under Law N° 27269, Law of Digital Signatures and Certificates, its Regulations and amendments. The integrity of the document and the authorship of the signature(s) can be verified at https://apps.firmaperu.gob.pe/web/validador.xhtml
II. ISSUES TO BE DETERMINED
11. In the present administrative procedure, in the opinion of this Deputy Superintendency, it is necessary to determine the following:
a. Whether or not BLUM SAF incurred an infraction by not having communicated the material event related to the agreement for the cessation of a promoter, which occurred on March 11, 2022, subject to charges, within the period established in Article 9, numeral 9.1 of the RHI. b. Whether or not BLUM SAF incurred an infraction by not having communicated the material event related to the agreement for the designation of the members of the surveillance committee of the investment fund called “Blum Renta Alternativa Fondo de Inversión” (hereinafter, BLUM RENTA ALTERNATIVA), which occurred on January 25, 2022, subject to charges, within the period established in Article 9, numeral 9.1 of the RHI.
c. Whether or not BLUM SAF incurred an infraction by not having communicated the material event related to the communication of the result of the placement by public offering directed to institutional investors of the participation units of the BLUM RENTA ALTERNATIVA investment fund, which occurred on January 24, 2022, subject to charges, within the period established in Article 9, numeral 9.1 of the RHI.
d. Whether or not BLUM SAF incurred an infraction by not having communicated the material event related to the excess participation in relation to the participant “Founding Participant 1” of the mutual fund “Blum Capital Global Fondo Mutuo” (hereinafter, BLUM CAPITAL GLOBAL), which occurred on September 14, 2022, subject to charges, within the period established in Article 9, numeral 9.1 of the RHI. e. Whether or not BLUM SAF incurred an infraction by not having communicated the material event related to the excess investment in relation to the entity “Non-Linked Fund” of the BLUM CAPITAL GLOBAL mutual fund, which occurred on September 27, 2022, subject to charges, within the period established in Article 9, numeral 9.1 of the RHI. f. Whether or not BLUM SAF incurred an infraction by not having communicated the material event related to the excess investment in relation to the entity “Non-Linked Fund” of the BLUM CAPITAL GLOBAL mutual fund, which occurred on October 04, 2022, subject to charges, within the period established in Article 9, numeral 9.1 of the RHI. g. Whether or not BLUM SAF incurred an infraction by not having communicated the material event related to the excess investment in relation to the entity “Non-Linked Fund” of the BLUM CAPITAL GLOBAL mutual fund, which occurred on February 03, 2023, subject to charges, within the period established in Article 9, numeral 9.1 of the RHI. h. Whether or not BLUM SAF incurred an infraction by not having communicated the material event related to the agreement of the General Shareholders' Meeting regarding the increase of the administrator's share capital, which occurred on February 06, 2023, subject to charges, within the period established in Article 9, numeral 9.1 of the RHI.
i. Whether or not BLUM SAF incurred an infraction by not having communicated the material event related to the excess participation in relation to the participant “Linked Group 1” of the BLUM Cash Mutual Fund (hereinafter, BLUM CASH),

PERÚ Ministry of Economy and Finance

SMV
Electronic document digitally signed under Law N° 27269, Law of Digital Signatures and Certificates, its Regulations and amendments. The integrity of the document and the authorship of the signature(s) can be verified at https://apps.firmaperu.gob.pe/web/validador.xhtml which occurred on August 16, 2023, subject to charges, within the period established in Article 9, numeral 9.1 of the RHI. j. Whether or not BLUM SAF incurred an infraction by not having communicated the material event related to the excess participation in relation to the participant “Linked Group 1” of the BLUM CASH fund, which occurred on December 13, 2023, subject to charges, within the period established in Article 9, numeral 9.1 of the RHI. k. Whether or not BLUM SAF incurred an infraction by not having communicated the material event related to the excess participation in relation to “Participant 1” of the BLUM CASH fund, which occurred on December 13, 2023, subject to charges, within the period established in Article 9, numeral 9.1 of the RHI.
l. Whether or not BLUM SAF incurred an infraction by not having communicated the material event related to the excess participation in relation to “Participant 1” of the BLUM RENTA GLOBAL mutual fund, which occurred on October 02, 2024, subject to charges, within the period established in Article 9, numeral 9.1 of the RHI.
m. Whether or not BLUM SAF incurred an infraction by not having communicated the material event related to the excess participation in relation to “Participant 1” of the BLUM CAPITAL GLOBAL mutual fund, which occurred on September 23, 2024, subject to charges, within the period established in Article 9, numeral 9.1 of the RHI. n. Whether or not BLUM SAF incurred an infraction by not having communicated the material event related to the change of the member of the surveillance committee of the investment fund “BLUM Renta Alternativa Fondo de Inversión”, which occurred on April 26, 2024, subject to charges, within the period established in Article 9, numeral 9.1 of the RHI. o. Whether or not to impose a sanction on BLUM SAF;
III. ANALYSIS
A. Of the applicable regulations
12. Regarding the communication of material events, literal h) of Article 131 of the FM REGULATIONS establishes the following:
“Article 131°.- MATERIAL EVENTS
The administering company is obliged to submit all information regarding the mutual fund under its administration that qualifies as a material event for investors, in accordance with the provisions of the relevant regulations, as well as the provisions issued by the SMV. (…) The following also qualify as Material Events, in addition to what has been indicated above:
(…) h) Excesses of investments and participation.
(…)”;
13. Likewise, regarding material events, Article 141° of the IF REGULATIONS must be considered, which states the following:
“Article 141°.-Material Events and Disclosure

PERÚ Ministry of Economy and Finance

SMV
Electronic document digitally signed under Law N° 27269, Law of Digital Signatures and Certificates, its Regulations and amendments. The integrity of the document and the authorship of the signature(s) can be verified at https://apps.firmaperu.gob.pe/web/validador.xhtml Without prejudice to what is indicated in the preceding article, the following qualify as material events referred to in Article 28 of the LMV:
(…) d) Variations in the members of the surveillance committee. (…)”;
14. Also, it should be noted that Article 5° of the RHI qualifies as material events those listed in Annex 1 of said regulations, which include:
“Annex 1
Calls and Agreements
(…)
2.3. In the cases of agreements on capital increase or reduction, grouping or splitting of shares or redemption of shares, or modifications of the nominal value of shares.
(…)
Offer of value
(…)
21. Information on the issuance of securities by public or private offering within or outside the country, including participation in American Depositary Receipt programs, detailing, among others, the offering notice and/or the conditions of the issuance and/or sale, as well as the result of the placement, specifying the number and total amount of securities placed or sold.”;
15. Regarding the communication of material events, Article 7, numerals 7.2 and 7.3 and Article 9°, numeral 9.1 of the RHI provide the following:
“Article 7.- Obligation to inform
(…)
7.2. Material events must be submitted complying with the technical specifications approved by the SMV. The issuer must ensure that in the submission of information there is consistency between its content and the existing classification or typology in the MvNet.
7.3. The obligation to report a material event shall only be understood as fulfilled if the Issuer has observed the requirements established in these Regulations and in the corresponding technical specifications established by the SMV.
(…)
Article 9°.- Timeliness for reporting material events
9.1. The Issuer must report its material event as soon as such event occurs or the Issuer becomes aware of it, and in no case later than the day on which it occurred or became known. This information must be communicated to the SMV before any other person, entity or means of dissemination, and simultaneously, when applicable, to the Stock Exchange or to the administering entity of the respective centralized negotiation mechanism. This, regardless of whether the information was generated in the Issuer itself or not.
(…)”;
B. Of the charges formulated

[RegAlert note: the English text above is a translation of the first 24,000 characters of a 90,708-character original (26% of the document). The remainder was not translated. The complete original-language text is stored with this document.]