Bank of the Republic of Haiti

CIRCULAR

No. 115-6

TO FINANCIAL INSTITUTIONS

In application of the provisions of Articles 83 and 161 of the law of May 14, 2012, concerning banks and other financial institutions, banks, development finance companies, leasing companies, and credit card companies, hereinafter referred to as "credit financial institutions," are required to comply with the following provisions regarding loans granted to their clients.

1. Moratorium on Loans

Credit financial institutions are authorized, during a period of twelve (12) months starting from October 1, 2024, to consider credit moratoria in favor of eligible clients as mentioned below. Financial institutions, based on their analysis of the financial capacity of the clients in question, determine the duration and necessity of granting moratoria.

Eligible clients are those:

a. who benefited from a moratorium under Circular 115-5 and who have made their interest payments regularly until September 30, 2024 (current or non-current loan).

b. who did not opt for the moratorium under Circular 115-5 and who have made their payments (principal and interest) regularly until September 30, 2024 (current or non-current loan), but whose financial situation has greatly deteriorated in recent months, strongly calling into question their ability to continue meeting their obligations (principal and interest) from October 2024 onwards.

However, within the aforementioned twelve-month period, no moratorium may be renewed or granted for a duration extending beyond September 30, 2025.

During the moratorium period, only the payment of interest on receivables is required, and the credit classification of beneficiary clients remains that recorded on September 30, 2024.

The moratorium implies a temporal shift in the client's credit status between September 30, 2024, and September 30, 2025. Upon expiration of said moratorium, the client must resume normal monthly debt service (payment of principal and interest) while retaining the same credit classification as of late September 2024. In other words, the moratorium under this circular automatically results in an extension of the loan term equivalent to the duration of the moratorium.

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2. Restructuring and Provisioning of Loans

Following an analysis of the client's financial capacity and by mutual agreement with the client, a credit financial institution may, in accordance with Circular No. 87 on loan classification and the establishment of provisions for doubtful debts, proceed to redefine the terms of a loan that:

i. Did not benefit from a moratorium under Circular 115-5 and had payment delays as of September 30, 2024, or was likely to become non-performing by March 31, 2025; or

ii. Benefited from a moratorium under Circular 115-5 and whose interest payments were regular until September 30, 2024; or

iii. Benefited from a moratorium under this circular and whose quality has deteriorated (3 consecutive months of interest payment arrears) before or upon expiration of said moratorium due to the socio-political troubles currently affecting the country.

For restructurings under section 2.ii, the financial institution is authorized, for a period of one (1) year, to apply a minimum provisioning rate of 5%. Credit financial institutions covered by this circular have until March 31, 2025, to carry out such restructurings.

For restructurings under sections 2.i and 2.iii, the financial institution is authorized, for a period of one (1) year, to apply a minimum provisioning rate of 20%. Credit financial institutions covered by this circular have until September 30, 2025, to carry out such restructurings.

Loans restructured by credit financial institutions under this circular will be reported to the BRH in accordance with the provisions of Circular 87 or its amended version, if applicable, with the notation "restructured loan Circ.115-6" or "restructured loan Circ.115-6/after moratorium," as applicable.

1. Other Measures

During the moratorium period, beneficiaries are exempt from late fees.

In order to ensure the maintenance of the capital adequacy of financial institutions in this context of socio-economic instability, financial institutions covered by this circular are required to request a non-objection from the BRH for any project regarding the distribution of dividends or interest on permanent shares for the 2024-2025 fiscal year.

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2. Reports

All financial institutions covered by this circular are required to electronically transmit to the BRH, on December 31, 2024, March 31, 2025, June 30, 2025, and September 30, 2025, a report on loans that benefited from a moratorium, no later than 21 days after the end of each of these quarters.

The format of the reports to be transmitted is attached to this circular.

3. Repeal and Entry into Force

This circular replaces Circular 115-5 of March 28, 2024, and enters into force on October 1, 2024.

Port-au-Prince, September 30, 2024.

Ronald Gabriel Governor

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ANNEX

Quarterly Report on Clients Benefiting from Moratorium/Circular 115-6

Name of the financial institution _________________________ Period from ____________ to ____________

Client Identification (Name of individual or company)	Date of renewed moratorium (dd/mm/yyyy)	Loan balance at the date of granting the renewed moratorium (in gourdes)	Interest Payment: Current (C) or Non-current (NC)
Client 1
Client 2
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