2025-09-18 | A 8329

Circular LISOL 1-1119 Minimum Capital of Financial Entities. Minimum Capital for Operational Risk. Adjustments.

The Central Bank of the Argentine Republic (BCRA) issued Communication “A” 8329 to establish updated minimum capital requirements for operational risk across financial entities. The regulation caps the operational risk capital requirement at 20% for Group A, 17% for Group B, and 14% for Group C entities, with further reductions to 11%, 8%, 7%, or 5% based on SEFYC inspection ratings, while mandating a 100% calculation for branches or subsidiaries of systemically important foreign banks. Additionally, the circular introduces a transitional methodology for new entities over their first 36 months and incorporates revised regulatory sheets into the ordered text available on the BCRA website.

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"Year of the Reconstruction of the Argentine Nation" COMMUNICATION “A” 8329 18/09/2025 TO FINANCIAL ENTITIES:

Ref.: Circular LISOL 1-1119: Minimum Capital of Financial Entities. Minimum capital for operational risk. Adjustments.

We address you to inform you that this Institution has adopted the resolution which, in its relevant part, provides: “- Establish that the minimum capital requirement for operational risk determined through the application of the expression described in point 7.2 of the ordered text on Minimum Capital of Financial Entities shall not exceed 20% (twenty percent) in the case of Group 2A entities, based on the average of the last 36 (thirty-six) months –prior to the month corresponding to the determination of the requirement– of the minimum capital requirement for credit risk calculated as provided in Section 2., expressed in homogeneous currency of the month prior to when the calculation is made.”

In this regard, we forward the sheets which, replacing those previously provided, should be incorporated into the referenced regulations. In this sense, it is recalled that on this Institution’s website www.bcra.gob.ar, accessing “Financial System - LEGAL AND REGULATORY FRAMEWORK - Regulations 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. BANCO CENTRAL DE LA REPÚBLICA ARGENTINA (CENTRAL BANK OF THE ARGENTINE REPUBLIC) Dario C. Stefanelli Marina Ongaro Principal Manager of Emission and Regulatory Applications Deputy General Manager of Financial Regulation

ANEXO (Annex)

-Index- 6.5. Capital requirement for risk of positions in basic products –commodities–. 6.6. Capital requirement for risk of positions in options. 6.7. Computation. 6.8. Policies and procedures for the management of the trading portfolio. 6.9. Additional requirements to include positions in the trading portfolio. 6.10. Treatment for less liquid positions. 6.11. Responsibilities. 6.12. Internal audit. Section 7. Minimum capital for operational risk. 7.1. Capital requirement for operational risk for Group 1 entities. 7.2. Capital requirement for operational risk for Group 2 entities. 7.3. Limit for Group 2 entities. 7.4. New entities. Section 8. Computable net worth. 8.1. Determination. 8.2. Computable concepts. 8.3. Criteria related to computable concepts. 8.4. Deductible concepts. 8.5. Limits. 8.6. Capital contributions. 8.7. Procedure. Section 9. Bases for compliance with regulations. 9.1. Individual basis. 9.2. Consolidated basis. Section 10. External Credit Rating Agencies (ECRA). Section 11. Other provisions. Section 12. Transitional provisions. Correlation table.

B.C.R.A. ORDERED TEXT ON MINIMUM CAPITAL OF FINANCIAL ENTITIES Version: 26th. COMMUNICATION “A” 8329 Validity: 18/09/2025 Page 2

7.3. Limit for Group 2 entities. The requirement determined through the application of the expression described in point 7.2 shall not exceed: 7.3.1. 20% in the case of Group A entities, based on the average of the last 36 months –prior to the month corresponding to the determination of the requirement– of the minimum capital requirement for credit risk calculated as provided in Section 2., expressed in homogeneous currency of the month prior to when the calculation is made. 7.3.2. 17% in the case of Group B entities and 14% in the case of Group C entities, based on the average of the last 36 months –prior to the month corresponding to the determination of the requirement– of the minimum capital requirement for credit risk calculated as provided in Section 2., expressed in homogeneous currency of the month prior to when the calculation is made. The maximum limits established above shall be reduced to 11% and 8%, respectively, when the financial entity holds a rating of 1, 2, or 3 according to the assessment provided by SEFYC, during the last inspection conducted, regarding all of the following aspects: the entity as a whole, its information systems, and the work of those responsible for evaluating their internal control systems. In cases where the financial entity holds a rating of 1 or 2 in all cited aspects, the maximum limit shall decrease to 7% or 5%, depending on whether it belongs to Group B or C, respectively. For this purpose, the last rating reported for calculating the requirement that should be integrated into the third month following the notification shall be considered. The applicable limit will always apply provided that the financial entity is not a branch or subsidiary of an external bank rated as systemically important (G-SIB); otherwise, the operational risk capital requirement shall be calculated at 100% as provided in point 7.1.

7.4. New entities. The monthly minimum capital requirement for operational risk of Group 1 and 2 financial entities corresponding to the first month shall be equivalent to 10% of the sum of the requirements determined by credit and market risks –in this case, for positions on the last day– of that month. From the second to the thirty-sixth month, the monthly requirement shall be equivalent to 10% of the average of the requirements determined for the months elapsed up to the calculation period –inclusive–, resulting from considering the risks mentioned in the preceding paragraph, according to the following expression:

where for each month “t”: CRCt: capital requirement for credit risk, expressed in homogeneous currency of the month prior to when the calculation is made. RMp,t: capital requirement for market risk for positions on the last day of month “t”, expressed in homogeneous currency of the month prior to when the calculation is made. n: number of months elapsed up to the calculation month –inclusive– (2 ≤ n ≤ 36). From the thirty-seventh month onward, the monthly requirement shall be calculated according to the methodology established for Group 1 or Group 2, as applicable.

B.C.R.A. MINIMUM CAPITAL OF FINANCIAL ENTITIES Section 7. Minimum capital for operational risk. Version: 2nd. COMMUNICATION “A” 8329 Validity: 18/09/2025 Page 8

B.C.R.A. MINIMUM CAPITAL OF FINANCIAL ENTITIES Section 7. Minimum capital for operational risk. Version: 2nd. COMMUNICATION “A” 8329 Validity: 18/09/2025 Page 9

MINIMUM CAPITAL OF FINANCIAL ENTITIES ORDERED TEXT | SOURCE COMMUNICATION | OBSERVATIONS Section | Point | Paragraph | Communication Cap./Annex | Point | Paragraph 6. | [blank] | “A” 2461 | single | III | According to Com. “A” 3161, 4172, 5272, 5867 and 6690. 6.8. a | [blank] | “A” 5867 | 1. | According to Com. “A” 6690. 6.11. | [blank] | “A” 2461 | single | VI | According to Com. “A” 4172, 6690 and 6832. 6.12. | [blank] | “A” 5867 | 1. | According to Com. “A” 6690. 7. | [blank] | [blank] | 1st | “A” 8068 | single 7.1. | [blank] | “A” 8068 | single 7.2. | [blank] | “A” 5272 | 2. | According to Com. “A” 6327 and 8068. 7.3. | [blank] | “A” 5737 | 2. | According to Com. “A” 5746, 6260, 6475 (point 4.), 6633, 7108, 7143, 8068 and 8329. 7.4. | [blank] | “A” 5272 | 2. | According to Com. “A” 5369, 5580, 5737, 5867 and 8068. 8. | [blank] | [blank] | [blank] | [blank] 8.1. | [blank] | “A” 414 LISOL-1 | VI 3.1. 1st | According to Com. “A” 2279, 2453, 2793, 2914, 3039, 4172 and 5369 (Annex I). 8.2.1. | [blank] | “A” 414 LISOL-1 | VI 3.1.1. | According to Com. “A” 2223, 2227, 4296 (point 2.), 4576 (point 1.), 4665, 5369 (Annex I), 6327, 6396 and 6428. 8.2.2. | [blank] | “A” 5369 | I 8.2.3. | [blank] | “A” 414 LISOL-1 | VI 3.1.2. | According to Com. “A” 2223, 2768, 2948, 4172, 4576 (point 3.), 4665, 4702, 5369 (Annex I) and “B” 9074. 8.3. | [blank] | “A” 5369 | I 8.3.1. | [blank] | “A” 5369 | I 8.3.2. | [blank] | “A” 4576 | 2. | According to Com. “A” 4591 (points 2. to 5.), 4665, 4782 and 5369 (Annex I). ant-último | [blank] | “A” 5369 | I | According to Com. “A” 5831. último | [blank] | “A” 5831 8.3.2.2. | [blank] | “A” 4576 | 2. | According to Com. “A” 4665, 5369 (Annex I) and 5831. 8.3.2.7. | [blank] | “A” 4576 | 2. | According to Com. “A” 4591 (point 2.), 4665, 5369 (Annex I) and 5831. 8.3.3. | [blank] | “A” 414 LISOL-1 | VI 3.1.2.2. | According to Com. “A” 2264, 4172, 4576 (points 4., 5., 6. and 8.), 4665, 4782 and 5369 (Annex I). 8.3.4. | [blank] | “A” 5369 | I 8.3.4.1. | [blank] | “A” 5369 | I | According to Com. “A” 5831. 8.3.4.4. | [blank] | “A” 5369 | I | According to Com. “A” 5831.