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2022-01-10

Added 2026-07-31 · Updated 2026-08-03

Instruction No. 2/2022

The Bank of Portugal amends Annex XIV, Section 4 of Instruction No. 3/2015 to update the reporting model for external auditors certifying credit rights procedures and systems. The revised requirements mandate that initial ex-ante certification occur before the first mobilization of credit rights, with subsequent certifications required at least every five years. External auditors must validate internal system reliability, data accuracy, eligibility criteria, timely updates, unique identification, and historical archiving for a minimum of ten years using credit right samples. This instruction enters into force the day following its publication.

Portugal

Banco de Portugal

Instruction No. 2/2022 BO No. 12/2021 3rd Supplement • 2022/01/10 .................................................................................................................................................................................................. Topics Markets :: Money Markets Mod. 99999940/T – 01/14 Index Text of the Instruction Text of the Instruction Subject: Amending Instruction No. 3/2015 Taking into account the acquired practice with the verification model of the procedures and systems used for the presentation of credit rights by counterparties of the Bank of Portugal, some changes considered necessary have been introduced. Thus, in the exercise of the competence attributed to it by Articles 12, 15, 16, and 24 of its Organic Law, approved by Law No. 5/98 of January 31, in its current version, the Bank of Portugal determines: Instruction No. 3/2015 (BO No. 5, of 15-05-2015) is amended as follows:

Annex XIV, No. 4 is amended, taking the following wording:
Reporting model for the verification of procedures and systems used for the presentation of credit rights – Initial Certification and Regular Certification Within the scope of audit actions, external auditors must certify the procedures and systems used by the counterparty to submit information on credit rights. The initial ex-ante certification must be carried out before the first mobilization of credit rights by the counterparty. Subsequent certifications of the procedures and systems must take place at least every five years. For this purpose, external auditors must resort, whenever appropriate, to a sample of credit rights, carrying out management simulations and future submission of credit rights information to the Bank and performing the verifications deemed adequate to certify the required requirements. The verifications by external auditors must focus on the submission of information by counterparties directly to the banking loan information systems, and on information communicated to the Credit Registry (CRC) and used by those systems within the scope of mobilizing credit rights as collateral assets. Based on these verifications, external auditors must pronounce themselves on the reliability/quality of the counterparty's procedures and systems, according to the reporting model to the Bank presented below.

Certification reference date Reference date: / / Comment: ________________ Sample constitution: ____ For the certification of some requirements, it is necessary to analyze a sample of credit rights, according to what is defined in the previous subsection '3.2. Constitution of samples for verification'. In the case of ex-ante certification, the sample must be constituted based on an estimate of the total number of loans that the counterparty will mobilize. The composition of the sample used in the verifications (credit rights identifiers) must be provided in an annex to this report.
Certifications 2.1. Quality of information recorded in the internal systems of credit rights 2.1.1. The information systems used by the counterparty in the internal registration of credit rights reveal reliability/quality, confirming in particular the registration in the internal systems of the variables required by the Bank within the scope of mobilization of credit rights. Description of existing information systems: Description of verifications performed: The validation of this requirement must involve the verification of a sample of credit rights. Report on the verifications of the procedures and systems used for the presentation of credit rights

Instruction No. 2/2022 BO No. 12/2021 3rd Supplement • 2022/01/10 Topics Markets :: Money Markets .................................................................................................................................................................................................. Mod. 99999940/T – 01/14 Result: The verifications performed allow certifying compliance with the requirement: Yes ☐ No ☐ Comments or other relevant observations: 2.1.2. The information included in the counterparty's internal systems corresponds to the information of the loan contracts concluded. Description of procedures: Brief description of the procedures implemented by the counterparty that ensure that the information included in the internal systems corresponds to the information of the concluded contracts and any changes that occur over time. Description of verifications performed: The validation of this requirement must involve the verification of a sample of credit rights. Result: The verifications performed allow certifying compliance with the requirement: Yes ☐ No ☐ Comments or other relevant observations: 2.2. Quality of information communicated to the Bank of Portugal 2.2.1. Submission to the Bank of Portugal of eligible credit rights The procedures in force ensure that the credit rights submitted to the Bank meet the eligibility criteria. Description of procedures: Brief description of the procedures implemented by the counterparty for the exclusive selection and submission of eligible credit rights.

Instruction No. 2/2022 BO No. 12/2021 3rd Supplement • 2022/01/10 Topics Markets :: Money Markets .................................................................................................................................................................................................. Mod. 99999940/T – 01/14 Description of verifications performed: The validation of this requirement must involve the verification of a sample of credit rights. Result: The verifications performed allow certifying compliance with the requirement: Yes ☐ No ☐ Comments or other relevant observations: 2.2.2. Communication to the Bank of Portugal of all relevant changes The procedures in force ensure that, for the credit rights delivered as collateral, the changes occurring in their characteristics and of their respective debtors/guarantors are communicated to the Bank in a timely manner. Description of procedures: Brief description of the procedures that ensure the timely communication of changes in the credit rights delivered as collateral. Description of verifications performed: The validation of this requirement must involve a simulation of changes for a sample of credit rights. Result: The verifications performed allow certifying compliance with the requirement: Yes ☐ No ☐ Comments or other relevant observations: 2.2.3. Non-duplication of credit rights The procedures in force ensure that a credit right cannot be submitted to the Bank more than once. A unique identification code is assigned to each credit right according to the Bank's instructions.

Instruction No. 2/2022 BO No. 12/2021 3rd Supplement • 2022/01/10 Topics Markets :: Money Markets .................................................................................................................................................................................................. Mod. 99999940/T – 01/14 Description of procedures: Brief description of the procedures that ensure that the counterparty assigns a unique identification code to each credit right, with no duplication of codes, even after the maturity of the credit rights. Description of verifications performed: The validation of this requirement must involve the verification of a sample of credit rights. Result: The verifications performed allow certifying compliance with the requirement: Yes ☐ No ☐ Comments or other relevant observations: 2.2.4. Credit rights submission procedures Correct application of credit rights reporting rules to the Bank. Description of procedures: Brief description of the procedures implemented by the counterparty for the adequate compliance with the rules of information reporting. Description of verifications performed: The validation of this requirement must involve the verification of a sample of credit rights. Result: The verifications performed allow certifying compliance with the requirement: Yes ☐ No ☐ Comments or other relevant observations:

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