Resolution No. CD-SIBOIF-478-1-MAY9-2007: Norm on Concentration Limits

RESOLUTION NO. CD-SIBOIF-478-1-MAY9-2007
Dated May 9, 2007
NORM ON CONCENTRATION LIMITS

The Board of Directors of the Superintendence of Banks and Other Financial Institutions,

CONSIDERING
I
That Law No. 561, General Law of Banks, Non-Banking Financial Institutions and Financial Groups, hereinafter "General Law of Banks," in Article 55 establishes limits on active operations between financial institutions and their related parties. Likewise, Article 56 of the same law establishes limits on active operations with non-related parties. II That based on the powers conferred by Article 3, numeral 13, and Article 10, numerals 6 and 8, and the final part thereof, of Law No. 316, Law of the Superintendence of Banks and Other Financial Institutions, reformed by Law No. 552, Law of Reforms to Law No. 316, Law of the Superintendence of Banks and Other Financial Institutions; In exercise of its powers, HAS ISSUED The following:

NORM ON CONCENTRATION LIMITS
RESOLUTION NO. CD-SIBOIF-478-1-MAY9-2007

Chapter I
CONCEPTS, OBJECT AND SCOPE

Art. 1. Concepts.- For the purposes of this norm, the following shall be understood:
a) Calculation Base: The concept established as the capital calculation base shall be that set forth in the General Law of Banks and in the norm regulating the matter of capital adequacy for banks and financial companies. b) Substantial Credits: In the application of Article 55, numeral 1, literal b, of the General Law of Banks, when said paragraph refers to the concept of substantial credits, it shall be understood as any active operation referred to in Article 4 of this norm, as well as any sale operation of adjudicated goods, for amounts according to the authorization levels, individual or collective, assigned to the official. For these purposes, the following authorization levels are established:

1. For the individual authorization level, active operations for amounts equal to or greater than the equivalent in national currency of twenty-five thousand dollars (US$25,000.00) of the United States of America;
2. For the collective authorization level, active operations for amounts equal to or greater than the equivalent in national currency of fifty thousand dollars (US$50,000.00) of the United States of America.
   c) Officials: The concept of officials shall be understood as those persons in financial institutions who hold the positions of chief executive (Executive President, General Director, Executive Director, General Manager or their equivalents) and officials with the power, individually or collectively, to authorize substantial credits, in accordance with numeral 1, literal b. and e. of Article 55 and Article 170 of the General Law of Banks. d) Superintendence Law: Law 316, Law of the Superintendence of Banks and Other Financial Institutions and its reforms. e) General Law of Banks: Law 561, General Law of Banks, Non-Banking Financial Institutions and Financial Groups, published in Gaceta, Official Diary, number 232, of November 30, 2005. f) Superintendence: Superintendence of Banks and Other Financial Institutions. g) Superintendent: Superintendent of Banks and Other Financial Institutions.

Art. 2. Object.- This norm aims to establish guidelines for the application of what is established in Articles 55 and 56 of the General Law of Banks regarding the limits of active operations between financial institutions and their related parties and units of interest of these, as well as with non-related parties including their units of interest. Likewise, to develop concepts regarding: substantial credits, dominant influence, presumption of significant linkages, indirect manifestations, among others.

Art. 3. Scope.- The provisions of this norm are applicable to banks and non-banking financial institutions subject to the authorization, supervision and surveillance of the Superintendence.

Art. 4. Active operations with related parties.- For the purposes of calculating the concentration limit, the computation of the total of active operations granted to a natural or legal person who individually or together with their related parties form a unit of interest, will be the sum of the following items:
a) The credits granted (commercial, financial leasing, consumer or personal, mortgage for housing, micro credit) including contingent operations (Bonds, guarantees, guarantees granted, letters of credit and unused balances of confirmed lines of credit and automatic utilization); accounts receivable (in the case of insurance, premium receivable accounts will not be included); and any other obligation, direct and indirect, effective and contingent, assumed by the same. b) Deposits and investments of any nature that the institution maintains, including repo operations carried out in accordance with the regulation governing the limits of deposits and investments; c) Asset purchase operations, previously sold by the buying entity, either to the selling entity or to any other natural or legal person. The additional aspects of this type of operation must comply with what is established in the regulation governing the matter; d) Sale of assets on credit or financed. The additional aspects of this type of operation must comply with what is established in the regulation governing the matter;

Art. 5. Credit and investments with non-related parties.- For the purposes of calculating the concentration limit, the computation of the total of credits and investments with a natural or legal person who individually or together with their related parties form a unit of interest not related to the institution, will be the sum of the following items:
a) The credits granted (commercial, financial leasing, consumer or personal, mortgage for housing, micro credit) including contingent operations (Bonds, guarantees, guarantees granted, letters of credit and unused balances of confirmed lines of credit and automatic utilization); accounts receivable (in the case of insurance, premium receivable accounts will not be included); and any other obligation, direct and indirect, effective and contingent, assumed by the same. b) Deposits and investments of any nature that the institution maintains, including repo operations carried out in accordance with the regulation governing the limits of deposits and investments.

Art. 6. Operations not included.-

1. The following operations will not be computable for the purposes of the concentration limit:

1 Art. 6, reformed on October 20, 2010 - Resolution CD-SIBOIF-650-1-OCT20-2010

a) Current account deposits, MMDA/MMSA accounts, savings and time deposits up to seven (7) days with foreign financial institutions with first-rate international rating, as established in the regulation governing the matter on limits of deposits and investments; b) Assets covered with liquid guarantees as provided in the regulation governing the matter on credit risk management.

Art. 7. Dominant Influence.- In accordance with Art. 55, numeral 2, paragraph d, of the General Law of Banks, the Superintendent may determine that a natural or legal person exercises dominant influence over another legal person when any of the following circumstances occur:
a) The first natural or legal person controls or represents, directly or indirectly, in the second legal person, a voting right greater than twenty percent (20%) of the capital and superior to that controlled or represented, directly or indirectly, in this second legal person by any other natural or legal person; b) The first natural or legal person controls or represents, directly or indirectly, a voting right of at least twenty percent (20%) of the capital of the second legal person and, furthermore, is among the three largest shareholders of this same legal person and is part of its Board of Directors or is its main executive or attorney-in-fact. c) Any other type of evidence is presented that the first natural or legal person exercises, directly or indirectly, in the second legal person, an influence equivalent to controlling, directly or indirectly, a voting right equivalent to or greater than the control of 33% of the capital of this second legal person. In this case, rebuttal proof is admitted.

Art. 8. Presumption of Significant Linkages.- The Superintendent may presume that a natural or legal person or several of them maintain, directly or indirectly, significant linkages among themselves or with another natural or legal person, when there is evidence of any of the following indications of affinity of interests:
a) A natural or legal person, whether constituted in the country or abroad, is a debtor of another natural or legal person, without the assets and/or income of the first being sufficient in relation to the amount of credits granted to it by the second, or if there are no antecedents regarding the activities it develops. b) A debtor has received credits under notably favorable conditions compared to other debtors of the same creditor, without any objective situation justifying it from a financial point of view; or such a debtor has obtained notably favorable treatments in deposits and/or in other services provided by the creditor. c) A client has received services (stock market operations, purchase of insurance, warehousing of merchandise, among others), under notably favorable conditions compared to other clients of the same institution or of the financial group to which it belongs, without any objective situation justifying it. d) The financial institution has contracted (consultancies, advisory services, hiring of professional services, software development, purchase of goods, leasing, among others) under notably favorable conditions compared to other suppliers, without any objective situation justifying it. e) The provision of services to a client without this obtaining a considerable economic benefit compared to the provision of the same service, under equal conditions, by other providers. f) The legal representative of a legal person debtor of a financial institution is, at the same time, legal representative of a legal person significantly linked to the creditor financial institution and there are no antecedents regarding the owners of the debtor legal person, their asset situation or their actual business activity. g) There is centralized accounting between a debtor and a legal person significantly linked to the creditor financial institution; or two natural or legal persons whatsoever have centralized accounting. h) A debtor maintains common administration with a natural or legal person significantly linked to the creditor financial institution; or two natural or legal persons whatsoever maintain between themselves the same administration. i) There is evidence leading to presume that credits granted to a natural or legal person will be used for the benefit of another, other than by virtue of a normal commercial credit relationship. j) There is evidence leading to presume that resources for the development of the activities of a legal person come, directly or indirectly, from another, other than by virtue of a normal commercial credit relationship. k) A debtor maintains accounts receivable representing twenty percent or more of its assets with other natural or legal persons, and there is no business activity justifying the existence of such accounts. l) A debtor maintains common business relationships and carries out its operations in the same premises with a natural or legal person significantly linked to the creditor financial
institution; or two natural or legal persons whatsoever maintain between themselves common business relationships and carry out their operations in the same premises. Premises means any property subject to title of ownership, condominium contract, or lease contract. m) A debtor provides services under the same corporate image with a natural or legal person significantly linked to the creditor financial institution; or two natural or legal persons whatsoever provide services under the same corporate image. n) There is frequent or permanent assumption of shared risks that are not by virtue of a normal commercial credit relationship between the debtor and a natural or legal person significantly linked to the creditor financial institution; or the same circumstance occurs between two natural or legal persons whatsoever. o) The same non-fiduciary guarantee backs obligations of the debtor and a natural or legal person significantly linked to the creditor financial institution, or there is a contract of assignment of guarantees between them; or two natural or legal persons whatsoever present as backing the same guarantee, or there is a contract of assignment of guarantees between them. p) The common presence of two or more persons occupying positions as members of boards of directors, chief executives, general managers of administration or internal auditors in a debtor legal person, and who occupy any of the mentioned positions in another legal person significantly linked to the creditor financial institution; or the same circumstances occur between two natural or legal persons whatsoever. q) A natural or legal person effectively exercises a veto right over the business of another legal person. r) Two legal persons have common policies or coordination bodies. s) A supervised financial institution does not provide detailed information on the capital ownership structure of another company that in turn is a partner of a debtor legal person. t) The existence of any other indication of affinity of interests, whose effects are equivalent to any of the determinants of significant linkage established in Article 55, numeral 2, paragraphs a), b), c) and d) of the General Law of Banks, at the judgment of the Superintendent. Presumptions based on the aforementioned indications admit rebuttal proof. Such proof must demonstrate that the respective circumstance does not entail an affinity of interest whose effects are at least equivalent to any of the determinants of significant linkage established in Art. 55, numeral 2, paragraphs a), b), c) and d) of the General Law of Banks.

Art. 9. Indirect Manifestations.- In accordance with Article 55, numeral 3, of the General Law of Banks, in cases where said article, and therefore this norm, refers to significant linkages, participations, means and any other manifestation of an indirect character, it must be understood that such manifestations refer to situations where evidence is shown of the celebration of acts or contracts, the existence of facts or the intervention of third parties that, in the judgment of the Superintendent, produce effects equivalent to those that would be produced directly. Without prejudice to other possible bases for establishing or presuming the existence of indirect manifestations, in cases where the Superintendent has determined that a legal person exercises dominant influence over another legal person, it may consider that the partners of the first legal person have an indirect participation in the second legal person. In such cases, the indirect participation of said partners in the second legal person will be calculated as the product of the percentage of their direct participation in the capital of the first legal person by the percentage of participation of said first legal person in the capital of the second. Evidence of indirect manifestations admits rebuttal proof.

Art. 10. Process to Rebut Presumptions.- Financial institutions will have a period of thirty (30) calendar days to present the proofs they deem pertinent to rebut the presumption, counted from the date of notification of the presumption. The Superintendent will rule within a period of fifteen (15) calendar days.

Art. 11. Non-compliance with concentration limits.- Without prejudice to monetary sanctions corresponding for presenting excesses over the established concentration limits, the financial institution must, additionally, comply with the following:
a) Immediately provision one hundred percent (100%) of the concentration excess. In the case of credit portfolio, the excess of the net portfolio of already constituted provisions will be provisioned; b) Not distribute profits while limits are exceeded; c) Correct the excess in a period not greater than 180 days. Non-compliance with concentration limits will not be considered when these are exceeded in demand deposit accounts maintained in related banks originated by deposits made by persons or entities external to the institution, provided that such excess is regularized in a period not greater than three (3) business days and duly justified in communication sent to the Superintendent.

Chapter II
GENERAL PROVISIONS

Art. 12. Duties of the Board of Directors.- The Board of Directors of the Institution must:
a) Have full knowledge of the content of this norm and will be responsible for ensuring its due compliance; b) Approve policies and guidelines for the administration of concentration limits of active operations with its related parties and units of interest; c) Expressly approve every active operation for amounts equal to or greater than five thousand dollars of the United States of America or its equivalent in national currency, granted to any of the related parties and any member of its unit of interest of the financial institution; d) Approve the signing of service provision contracts with related parties considered material in accordance with the regulation governing the contracting of service providers. Likewise, it must ensure that such contracts are signed under market conditions and are duly documented; e) Require quarterly from the general manager of the respective institution or his/her substitute, information on the totals of active operations granted to any natural or legal person who individually or together with their related parties form a unit of interest, whether related or not, that represents more than ten percent of the capital calculation base. Likewise, make it known to the General Assembly of Shareholders through the annual report of the President of the Board of Directors.

Art. 13. Supply of Information.- The financial institution must supply the Superintendent with the following information:
a) Monthly Information: The institution must inform the Superintendent in accordance with the reporting calendar sent to institutions, the following:
1) The totals of active operations granted to any natural or legal person who individually or together with their related parties form a unit of interest, which in turn is a related party with the institution. The information must be reported according to the detail of information required in Annex 1 attached.
2) The totals of active operations granted to any natural or legal person who individually or together with their related parties form a unit of interest, whether related or not to the institution, that represents more than ten percent of the capital calculation base. The information must be reported according to the detail of information required in Annex 2 attached.
b) Semiannual Information: The financial institution must inform the Superintendent at the close of each calendar semester, about the natural or legal persons related to the institution, who individually or together with their related parties form a unit of interest detailing the information required in Annex 3-A and 3-B attached, which forms part of this norm. The cut-off dates for the delivery of this information will be June 30 and December 31 of each year. Legal persons that are members of the financial group to which the institution belongs, referred to in numeral 1, literal e), of Article 55 of the General Law of Banks, are not included, since the detail of the same will be governed by the norm regulating the matter of consolidated supervision of financial groups. The aforementioned annexes and their instructions form an integral part of this norm, and the Superintendent is authorized to modify them when necessary.

Chapter III
TRANSITIONAL AND FINAL PROVISIONS

Art. 14. Transitional.- The following transitional provisions are established:
a) Non-compliance with concentration limits will not be considered when these are exceeded due to changes in the concepts of "Officials" and "Substantial Credits" referred to in literals b) and c) of Article 1 of this norm, during the first six (6) months counted from the entry into force of the same, provided that, it concerns active operations carried out before the entry into force of this norm. b) Financial institutions must comply with the first sending of the information referred to in literal b) of Article 13 above, with a cut-off date of December 31, 2007.

Art. 15. Repeal.- The Norm on Concentration Limits, contained in Resolution CD-SIBOIF-447-1-OCT17-2006 dated October 17, 2006, published in La Gaceta, Official Diary No. 221 of November 14, 2006, is repealed.

Art. 16. Validity.- This norm will enter into force upon its notification without prejudice to publication in La Gaceta, Official Diary.

INSTITUTION: Annex 1
DATE:
Capital Adequacy Base Calculation: C$ -
A. RELATED DEBTORS (K)
Thousands of Cordobas

---

0.0% - - 0.00% 0% - -

---

0.0% - - 0.00% N/A
Sub Total XXXXX - - - - - - -

• • 0.00%

---

0.0% - - 0.00% 0% - -

---

0.0% - - 0.00% 0%
Sub Total XXXXX - - - - - - -

• • 0.00%

---

0.0% - - 0.00% 0% - -

---

0.0% - - 0.00% N/A - -
Sub Total XXXXX - - - - - - -

• • 0.00%

---

0.0% - - 0.00% 0% - -

---

0.0% - - 0.00% N/A - -
Sub Total XXXXX - - - - - - -

• • 0.00%
• • • • • • • • • 0.00%
• • • • • • 0.0% - - 0.00% 0% - -
• • • • • • • 0.0% - - 0.00% 0% - -
              Sub Total XXXXX - - - - - - - - - 0.00%
• • • • • • 0.0% - - 0.00% N/A - -
• • • • • • 0.0% - - 0.00% N/A - -
            Sub Total XXXXX - - - - - - - - - 0.00%
• • • • • • 0.0% - - 0.00% 0% - -
            Sub Total XXXXXX - - - - - - - - - 0.00%
• • • • • • 0.0% - - 0.00% N/A -
• • • • • • 0.0% - - 0.00% 0% - -
            Sub Total XXXX - - - - - - - - - 0.00%
• • • • • • • • • 0.00%
• • • • • • 0.0% - - 0.00% 0% - -
• • • • • • 0.0% - - 0.00% N/A
            Sub Total XXXXX - - - - - - - - - 0.00%
• • • • • 0.0% - - 0.00% N/A - -
          Sub Total XXXXX - - - - - - - - - 0.00%
• • • • • • • • • 0.00%
• • • • • • • • • 0.00%
                  B. DEPOSITS AND INVESTMENTS HELD IN RELATED FINANCIAL INSTITUTIONS
• • • • • 0% - - 0.00%
• • • • • 0% - - 0.00%
• • • • • 0% - - 0.00%
• • • • • 0% - - 0.00%
• • • • • • • 0.00%
              C. OTHER OPERATIONS WITH OTHER RELATED PARTIES
• 0% - - 0.00%
• 0% - - 0.00%
• 0% - - 0.00%
• • • 0.00%
• • • • • 0.00%
          Notes: 1. The Obligations of each debtor must be summed in the Sub Total and each of the Sub Totals must sum to the Total of the Interest Unit.

2. Credit Card Balances must be reflected in their different currencies.
3. ( * ) Concentration percentage with respect to the Capital Adequacy Base Calculation of the corresponding month.
   Description id_asset Description
   TOTAL DEPOSITS AND INVESTMENTS WITH RELATED FIN. INST.
   Name of Depositor / Issuer
   Total Interest Unit XXXXX
   Total Interest Unit XXXX
   Total Interest Unit XXXX
   TOTAL OBLIGATIONS INTEREST UNITS
   Total id_asset Description
   TOTAL RELATED
   Type of Relationship with the Bank Relationship with the Depositor Observations TOTAL OTHER OPERATIONS WITH RELATED Name of Depositor Related Party Qualification of the Entity Depositor / Issuer % Weighting Exposure Balance Weighted Type of Investment Exposure Balance the Largest Exposure Balance without Weighting (R) % Concentration () S =(R/K) Observations Exposure Balance without Weighting in Deposits and Investment P =( L+M+N+O) % Concentration () Q = (P/K) Related Party Type of Relationship with the Bank % Weighting Relationship with the Depositor Qualification of the Entity Depositor / Issuer Exposure Balance Weighted Exposure Balance the Largest Amount Investment (O) View (L) Savings Deposit (M) Time Deposits (N) Days in Default Amount Liquid Guarantee (E) Exposure Balance without Weighting F = (D-E) % Concentration () J = (I / K) Related Party Type of Relationship with the Bank Relationship with the Debtor % Weighting (G) Exposure Balance Weighted H = (FG) Exposure Balance the Largest I=(F>H;F;H) SUPERINTENDENCY OF BANKS AND OTHER FINANCIAL INSTITUTIONS DETAIL OF RELATED DEBTORS, DEPOSITS AND OTHER OPERATIONS WITH RELATED FINANCIAL ENTITIES No. Operation No. Identification Number Name of Debtor id_asset Debtor Obligations Total Debtor Obligation D =(A+B+C) Complementary Information Amount Authorized Unused (A) Principal + Interest + Others in ESF (B) Contingent (C) % FX Generator Days in Default Amount Liquid Guarantee (E) Exposure Balance without Weighting F = (D-E) % Concentration () J = (I / K) Related Party Type of Relationship with the Bank Relationship with the Debtor % Weighting (G) Exposure Balance Weighted H = (FG) Exposure Balance the Largest I=(F>H;F;H) SUPERINTENDENCY OF BANKS AND OTHER FINANCIAL INSTITUTIONS TOTAL OF RELATED DEBTORS, DEPOSITS AND OTHER OPERATIONS WITH RELATED FINANCIAL ENTITIES Those who sign this report confirm, under penalty of law, that the information presented fully complies with what is required in Arts. 55 and 56 of Law No. 561, reformed by Law No. 1237, Law of Reforms and Additions to Law No. 561, General Law of Banks, Non-Bank Financial Institutions and Financial Groups and the Norm on Concentration Limits Resolution No. CD-SIBOIF-478-1-MAY9-2007 and its Reforms.

INSTITUTION: Annex 2
DATE:
Capital Adequacy Base Calculation: C$ -
A. RELATED AND NON-RELATED DEBTORS (K)
Thousands of Cordobas

---

0.0% - - 0.00% 0%

---

0.0% - - 0.00% N/A
Sub Total XXXXX - - - - - - -

• • 0.00%

---

0.0% - - 0.00% N/A

---

0.0% - - 0.00% N/A
Sub Total XXXXX - - - - - - -

• • 0.00%

---

0.0% - - 0.00% 0%

---

0.0% - - 0.00% 0%
Sub Total XXXXX - - - - - - -

• • 0.00%

---

0.0% - - 0.00% N/A

---

0.0% - - 0.00% 0%
Sub Total XXXXX - - - - - - -

• • 0.00%
• • • • • • • • • 0.00%
• • • • • • 0.0% - - 0.00% N/A
• • • • • • • 0.0% - - 0.00% 0%
              Sub Total XXXXX - - - - - - - - - 0.00%
• • • • • • 0.0% - - 0.00% 0%
• • • • • • 0.0% - - 0.00% N/A
            Sub Total XXXXX - - - - - - - - - 0.00%
• • • • • • 0.0% - - 0.00% 0%
            Sub Total XXXXXX - - - - - - - - - 0.00%
• • • • • • 0.0% - - 0.00% N/A
• • • • • • 0.0% - - 0.00% N/A
            Sub Total XXXX - - - - - - - - - 0.00%
• • • • • • • • • 0.00%
• • • • • • 0.0% - - 0.00% N/A
• • • • • • 0.0% - - 0.00% 0%
            Sub Total XXXXX - - - - - - - - - 0.00%
• • • • • 0.0% - - 0.00% 0%
          Sub Total XXXXX - - - - - - - - - - 0.00%
• • • • • • • • • 0.00%
• • • • • • • • • 0.00%
                  Notes: 1. The Obligations of each debtor must be summed in the Sub Total and each of the Sub Totals must sum to the Total of the Interest Unit.

2. Credit Card Balances must be reflected in their different currencies.
3. ( * ) Concentration percentage with respect to the Capital Adequacy Base Calculation of the corresponding month.
   Description
   Total Interest Unit XXXXX
   Total Interest Unit XXXX
   Total Interest Unit XXXX
   TOTAL INTEREST UNITS
   % Concentration ()
   J = (I / K)
   Name of Person
   Linking
   Type of Relationship between
   Debtors
   % Weighting
   (G) Exposure Balance Weighted
   H = (FG)
   Exposure Balance the Largest
   I=(F>H;F;H)
   SUPERINTENDENCY OF BANKS AND OTHER FINANCIAL INSTITUTIONS DETAIL OF RELATED AND NON-RELATED INTEREST UNITS WITH CONCENTRATIONS GREATER THAN 10% OF THE BASE CALCULATION No. Operation No. Identification Number Name of Debtor id_asset Debtor Obligations Total Debtor Obligation D =(A+B+C) Amount Authorized Unused (A) Principal + Interest + Others in ESF (B) Contingent (C) % FX Generator Amount Liquid Guarantee (E) Exposure Balance without Weighted F = (D-E)

INSTITUTION: ______________________________
DATE: ______________________________ Annex 2.1 Figures in Thousands of Cordobas Description Balance Total Exposure Balance the Largest (A) Capital Adequacy Base Calculation (B) % Concentration (A/B) Responsible for preparation: _____________________________ Authorized by: _______________________________ Note: These data must match the total of Annex 2: Detail of Related and Non-Related Interest Units with Concentrations Greater than 10% of the Base Calculation. SUPERINTENDENCY OF BANKS AND OTHER FINANCIAL INSTITUTIONS TOTAL OF RELATED AND NON-RELATED INTEREST UNITS WITH CONCENTRATIONS GREATER THAN 10% OF THE BASE CALCULATION Those who sign this report confirm, under penalty of law, that the information presented fully complies with what is required in Arts. 55 and 56 of Law No. 561, reformed by Law No. 1237, Law of Reforms and Additions to Law No. 561, General Law of Banks, Non-Bank Financial Institutions and Financial Groups and the Norm on Concentration Limits Resolution No. CD-SIBOIF-478-1-MAY9-2007 and its Reforms.

11
ANNEX No. 3-A
Financial Institution:__________________________ Date of this report:_____________ Related Party: ___________________________ Position _________________________________ Date of Birth :___________________ ID No. 3/ _________________ Natural Persons Degree and Nature of the link First Name Second Name First Surname Second Surname Date of Birth Identity Card Country of Residence Indicate link with Legal Persons 1/ 1/ 1/ 1/ 2/ 3/ 4/ 5/ Grandparents Parents Siblings Spouse Children Grandchildren Spouse's Grandparents In-laws Brothers-in-law Son-in-law/Daughter-in-law Spouse of Grandchild _____________________________ Name and Signature of the Linked Part Information that must be provided by related natural persons:
5/ Indicate if they have or do not have a link with a legal person. If positive, fill out annex 3-B.
4/ The country where the related person is located must be indicated.
In all cases, as established in article 55 of the Banking Law, they must inform relatives up to the second degree of consanguinity and second degree of affinity, as detailed in this annex. When any of the mentioned links do not exist, it must be clearly indicated: "Does not have". Cases of deceased persons, minors or others must be clearly indicated. RELATED PARTIES 1/ Do not abbreviate or omit names or surnames. Married surnames should not be included unless according to a legal requirement the substitution of the maiden name by the married name is mandatory, in which cases it must be explicitly clarified. In cases where the person does not have a second name or second surname, it must be clearly indicated "Does not have". 2/ The dates of birth must be indicated in all cases, even of minors in a uniform format (Example: day-month-year ) 3/ In the case of Nicaraguan citizens, indicate the number of the identity card issued by the Supreme Electoral Council, for foreigners residing in Nicaragua, they must indicate the number of the residence card registration issued by the General Directorate of Migration and Foreigners and in cases where the reported persons reside outside Nicaragua, the number of the passport and the country of residence must be indicated. Observations

12
ANNEX No. 3-B
Financial Institution:__________________________ Related Party 1/: ___________________________ Position _________________________________ Date of Birth :___________________ ID No. 2/ _________________ Legal Persons _____________________________ Name and Signature of the Linked Part Information that must be provided by related legal persons:
No. of
Identification
Position held in the entity: Corresponds to the name of the position held by the related party, within the entity to be detailed. In the case that they do not hold any position, they must specify in quotes: "N/A" (NOT APPLICABLE). Type of Link: The type of link that the natural person has with the legal person must be specified, according to the criteria established in
article 55 of the General Law of Banks and in the Norm on Concentration Limits. In case the link is shareholding, the percentage of participation must be specified in the following column.
Country of Residence: The country in which the entity is located will be specified.
Name of the Entity: Indicates the trade name of the legal person, national or foreign.
No. of Identification: Corresponds to indicating the number of the Single Taxpayer Registry (RUC) or similar.
Type of Identification: Corresponds to specifying the type of document to which the identification number used by the legal person, national or foreign, corresponds. % of Shareholding Participation: Indicates the number expressed as a percentage, of participation that the related party detailed in annex 3-A, has in the entity to be detailed. 1/ This annex must be presented for each of the related parties to the institution; as well as, for the natural persons that make up their unit of interest, described in annex 3-A. 2/ In the case of Nicaraguan citizens, indicate the number of the identity card issued by the Supreme Electoral Council, for foreigners residing in Nicaragua, they must indicate the number of the residence card registration issued by the General Directorate of Migration and Foreigners and in cases where the reported persons reside outside Nicaragua, the number of the passport and the country of residence must be indicated. Type of Link PARTIES RELATED Country of Residence Position Held in the Entity Observations Name of the Entity Type of Identification % of Shareholding Participation (f) Roberto Solórzano Ch. (f) V. Urcuyo V. (f) A. Cuadra G. (f) Gabriel Pasos Lacayo (f) U. Cerna B. URIEL CERNA BARQUERO SECRETARY BOARD OF DIRECTORS SIBOIF