Resolution SBS No. 3780-2011: Credit Risk Management Regulation

1 Lima, March 31, 2011 S.B.S. Resolution No. 3780-2011 The Superintendent of Banking, Insurance and Private Pension Fund Administrators CONSIDERING: That, on January 10, 2008, the Comprehensive Risk Management Regulation was approved, through SBS Resolution No. 37-2008; That, the regulatory framework related to risk management must be complemented with specific rules, which establish guidelines for each type of significant risk; That, it is convenient for companies to have solid credit risk management practices that are consistent with recommendations formulated at the international level and that allow protecting the interests of savers, insured persons, and pensioners; That, it is necessary to promote the improvement of credit risk management in supervised companies, establishing for this effect minimum requirements for their adequate management; That, for the purpose of collecting opinions from the general public regarding the proposals for modification of the applicable regulations to supervised companies, the pre-publication of the draft resolution that approves provisions for credit risk management was arranged on the electronic portal of the Superintendency, under the provisions of Supreme Decree No. 001-2009-JUS; Being in accordance with the opinion of the Deputy Superintendencies of Banking and Microfinance, Insurance, Private Pension Fund Administrators, Legal Advice, Risks and Economic Studies; and, In exercise of the powers conferred by items 7 and 9 of article 349 of the General Law and items a) and d) of article 57 of the Unified Text of the Law of the Private System for the Administration of Pension Funds (approved by S.D. No. 054-97-EF); RESOLVES:

2 Article First.- Approve the Credit Risk Management Regulation, which consists of four chapters, as indicated below: I. Chapter I: Applicable to the companies included in letters A and B of article 16 of the General Law, to the National Bank, to the Agricultural Bank (AGROBANCO), to the Development Financial Corporation (COFIDE), to the Guarantee Fund for Loans to Small Industry (FOGAPI), to the MIVIVIENDA Fund S.A, to Benefit Funds under the control of the Superintendency, to Derramas, to Savings and Credit Cooperatives Not Authorized to Capture Public Deposits, to insurance companies referred to in letter D of said article and to private pension fund administrators (AFP), insofar as they do not conflict with specific regulations that regulate their actions. II. Chapter II: Applicable to the companies included in letters A and B of article 16 of the General Law, to the National Bank, to the Agricultural Bank (AGROBANCO), to the Development Financial Corporation (COFIDE), to the Guarantee Fund for Loans to Small Industry (FOGAPI), to the MIVIVIENDA Fund S.A, hereinafter companies of the financial system, as well as to Benefit Funds under the control of the Superintendency, to Derramas and to Savings and Credit Cooperatives Not Authorized to Capture Public Deposits, insofar as applicable and insofar as they do not conflict with specific regulations that regulate their actions. III. Chapter III: Applicable to insurance companies referred to in letter D of article 16 of the General Law, insofar as they do not conflict with specific regulations that regulate their actions. IV. Chapter IV: Applicable to Private Pension Fund Administrators and Managed Portfolios. CREDIT RISK MANAGEMENT REGULATION CHAPTER I GENERAL PROVISIONS Article 1°.- Definitions For the application of this Standard, the following definitions shall be considered: a. Regulatory classification.- Credit classification categories stipulated in the Regulation for the Evaluation and Classification of the Debtor and the Requirement of Provisions, approved by this Superintendency. b. Exposure subject to credit risk.- Any operation inside or outside the balance sheet that implies a potential loss for the company due to credit risk. c. Credit risk management.- The process that allows keeping credit risk within acceptable parameters, established in the policies and internal procedures approved by the Board of Directors, and to achieve its profitability and efficiency objectives. d. Complex credit operations.- Operations with a greater difficulty in identifying the solvency of counterparties and risk factors, which require specialized technical knowledge. They include at least the following types of financing: specialized financing, operations with financial derivative products, syndications, bond issuances, securitizations, and structured instruments. e. Credit Risk.- The possibility of losses due to the inability or lack of willingness of debtors, counterparties, or obligated third parties, to fulfill their contractual obligations registered inside or outside the balance sheet. f. Unit.- Refers to a part of the organizational structure with common functions. Any reference to Unit may be understood as associated with one or more organic units that, in a centralized or non-centralized manner, perform the functions indicated in this regulation and to which the corresponding requirements are imposed. g. Business Unit.- Unit whose main function is the origination of exposures subject to credit risk. Article 2°.- Responsibility of companies and the Board of Directors Companies are responsible for carrying out credit risk management appropriate to their size and the complexity of their operations and services. For this purpose, and in compliance with what is provided in this Standard and others related, it is the responsibility of the Board of Directors: a) Approve and periodically review the strategy, objectives, and guidelines for credit risk management. b) Approve and periodically review the policies and procedures for credit risk management. c) Establish and periodically review the organizational structure necessary for credit risk management. Additionally, companies that are part of conglomerates must have policies and procedures at the conglomerate level that avoid incurring conflicts of interest and must not apply conditions more favorable than market conditions in operations carried out with companies in the conglomerate. Article 3°.- Responsibility of General Management and managers It is the responsibility of General Management to implement Credit Risk Management in accordance with the provisions approved by the Board of Directors. To fulfill its responsibilities, Management may constitute the relevant committees. General Management will propose the Company's Strategic Plan to the Board of Directors, which must include a detail of the levels of appetite and tolerance for risk or refer to the documents in which this aspect is developed. Said Plan must be consistent with the levels of appetite and tolerance for risk approved by the Board of Directors. Managers of units are responsible for ensuring consistency between operations and the applicable risk tolerance levels in their scope of action, as well as to assume before the manager of the immediate superior level, the results of the risk management corresponding to their unit. Article 4°.- Minimum requirements for an adequate organizational structure To establish an adequate organizational structure for credit risk management, companies must at least comply with the following requirements: a) Establish an organizational structure and a decision-making process that adapts to the strategic needs of the company and that does not generate conflicts of interest in risk-taking. b) Define the functions and responsibilities of the units involved in credit risk management, as well as implement an adequate segregation of functions. Article 5°.- Credit Risk Committee In accordance with what is provided by article 13 of the Comprehensive Risk Management Regulation, the Board of Directors may create specialized risk committees that it considers necessary. Until the creation of a Credit Risk Committee is provided for, the Risk Committee, or whoever performs this function, will be responsible and will assume the functions detailed in this regulation.

3 The Credit Risk Committee or whoever acts in its place must meet at least once a month, and all agreements taken must be recorded in minutes, which will be available to this Superintendency. The General Manager and the Head of the Credit Risk Unit must be members of this Committee. 1 Article 6°.- Credit Risk Unit In accordance with what is provided by article 17 of the Comprehensive Risk Management Regulation, companies may have specialized units in the management of specific risks. Until the creation of a Credit Risk Unit is provided for, its responsibilities will be assumed by the Risk Unit, or by whoever performs this function. The Credit Risk Unit, or whoever performs this function, must be independent of the Business Unit, Investments, or other units that are part of the process of evaluation and origination of operations exposed to credit risks. Article 7°.- Suitable officials and professionals. Officials responsible for the Units involved in carrying out operations subject to credit risk and the professionals who make them up, including the Credit Risk Unit, must have, as appropriate, adequate training, knowledge, and experience in specialized topics of credit risk management. Likewise, General Management must ensure the ethical suitability of these officials. Companies that carry out complex credit operations must have specialized officials in the particularities of said operations. Article 8°.- Personnel incentive system The performance incentive system for employees involved in credit risk management determined by the company must contemplate the quality of the set of exposures subject to credit risk and not only parameters based on approval goals or completion of operations. This principle must also apply to Board of Directors and General Management personnel involved in said management. Article 9°.- Adequate information systems and computer tools Companies must have adequate computer support tools for credit evaluation. The companies' information systems must ensure the reliability and timeliness of information. Article 10°.- Formalization of exposures subject to credit risk The process of formalization of exposures subject to credit risk comprises, among other actions, the disbursement, registration, and issuance of these exposures in accordance with the approved conditions. These functions must be performed by a unit independent of the Business Unit, Investments, or other units that perform similar functions. Likewise, companies must have procedures for verifying documentation and evaluating its adequacy, as well as the prior examination of compliance with the conditions established in the approval process. 1 Paragraph eliminated by SBS Resolution No. 1041-2016 of 02/26/2016

4 Article 11°.- Risk reports and submission of information to the Board of Directors The Credit Risk Unit, or whoever fulfills said function, must prepare at least quarterly a report on the company's exposure to credit risk, which must be presented to the Credit Risk Committee, who in turn must submit it to the Board of Directors. Said report must collect the most relevant aspects of the monitoring of exposures subject to credit risk at the individual level and at the portfolio level, as well as what is stated in articles 14° and 37°. Article 12°.- Control of exposures subject to credit risk The company must have systems for controlling contractual conditions, limits and conditions established internally and regulatory limits, as well as adopt necessary measures to respect said limits during continuous periods of its operations. These systems must correspond to the degree of complexity and volume of the company's operations, CHAPTER II CREDIT RISK MANAGEMENT IN OPERATIONS CARRIED OUT BY COMPANIES OF THE FINANCIAL SYSTEM SUB-CHAPTER I INTERNAL ENVIRONMENT Article 13°.- Functions of the Credit Risk Committee The Credit Risk Committee will perform the following specific functions, taking into consideration what is provided in article 14 of the Regulation for Comprehensive Risk Management: I. Propose to the Board of Directors for approval: a) The objectives, guidelines, policies, and procedures for credit risk management, as well as the modifications made to them. b) The degree of exposure to risk and credit risk tolerance that the company is willing to assume in the development of business. These parameters include specific limits for exposures individually or aggregated. c) The mechanisms for implementing corrective actions proposed by the Credit Risk Unit, in case there are deviations with respect to the degrees of exposure and the levels of credit risk tolerance assumed. d) Manuals for the administration of credit risks, including methodologies for identifying, measuring, treating, controlling, and reporting credit risk, as well as their possible modifications. e) The models, parameters, and scenarios that will be used for the measurement and control of credit risk that the Credit Risk Unit proposes. II. Analyze and elevate to the Risk Committee or the Board of Directors, as appropriate, the reports issued by the Credit Risk Unit, as well as, inform the Board of Directors about corrective actions and improvements implemented. Article 14°.- Functions of the Credit Risk Unit The main functions that the Credit Risk Unit must perform, on which it must report to the Credit Risk Committee, the Risk Committee, or the Board of Directors, as appropriate, are the following: I. Propose policies, limits, methodologies, models, and parameters to identify, measure, treat, control, and report credit risk, as well as their modifications.

5 II. Monitor credit risk and the maintenance of it within the company's tolerance level. III. Monitor compliance with regulatory and internal limits established, including those provided in the Regulation for the Supervision of Financial and Mixed Conglomerates, if the company is "company responsible for the submission of information," as defined in said Regulation. IV. Carry out specific monitoring of information related to: a) Exposure to credit risk, its incidence and impact on the results and solvency of the company. This report must include a sensitivity analysis and stress tests under different scenarios, including extreme conditions. b) Deviations that occur with respect to the credit risk tolerance level and the degrees of exposure established, including the causes that originate such deviations. c) Credit operations subject to credit risk approved with an unfavorable opinion from any unit or committee member. d) Exceptions applied to credit policies. e) Proposals for necessary corrective actions, as the case may be. f) Compliance with regulations referred to the administration of foreign exchange credit risk, retail over-indebtedness risk, and country risk. V. Verify that the calculation of capital requirements for credit risk complies with applicable provisions. VI. Analyze the impact that the credit risk taken by the company has on the degree or level of capital sufficiency. VII. Carry out the regulatory classification of debtors and the calculation of required provisions. VIII. Carry out classifications derived from the internal classification system, if any. IX. Opine on the incidence in credit risk that the company would face by the application of the proposed Strategic Plan, as well as the proposal for the introduction of new products. X. Control that the approval process of exposures subject to credit risk is carried out in accordance with the parameters established in the company's policies and procedures. XI. Carry out the regulatory classification and analysis of refinanced operations. SUB-CHAPTER II ESTABLISHMENT OF OBJECTIVES Article 15°.- Policies and procedures manuals Companies must have Policies and Procedures Manuals regarding the carrying out of operations subject to credit risk. These policies must establish levels of appetite and tolerance for credit risk in the different market segments in which the company participates. The levels of appetite and tolerance for risk must materialize in quantifiable indicators and be subject to review based on results and changes in the risk environment. Additionally, credit policies and procedures must incorporate the following aspects: a) Procedures to be followed for the evaluation, granting, monitoring, control, and recovery of exposures subject to credit risk. b) The levels of autonomy for the approval, modification, renewal, and refinancing of exposures subject to credit risk. c) The methodologies for the assignment of internal risk classifications of the counterparty and the exposure (rating, scoring, among others), if applicable.

6 d) The criteria under which real or personal guarantees will be required for the granting of a credit facility, as well as the procedures for the constitution, valuation, monitoring, administration, and execution of guarantees. e) Measures for the administration of country risk, foreign exchange credit risk, and retail over-indebtedness risk. f) Procedures for managing risky assets, which includes their prompt identification, monitoring, and recovery of these assets as well as the constitution of additional provisions. g) The approval process for exceptions to credit policies and their periodic reporting to higher instances. The manuals must be reviewed periodically, according to the strategy, policies, and procedures defined by the Board of Directors. Article 16°.- Definition of target market and new products Companies must clearly establish their target market and identify the acceptable profile of customers, counterparties, and products to offer. The analysis of the target market must include the identification of potential markets, taking into account criteria of economic sector, geographic location, types of credit products, among others. Companies that are going to offer new types of credit products must ensure beforehand that they have the capacity to identify and evaluate all risk factors associated with said products, as well as their adequate monitoring. Article 17°.- Risk acceptance criteria Companies must include within their credit policies and procedures the definition of risk acceptance criteria to ensure that exposures subject to credit risk at the individual level and at the portfolio level are consistent with their business strategy. Risk acceptance criteria must be used as a selection tool to identify potential customers and counterparties within a sector, segment, or industry. Article 18°.- Credit risk concentration limits As part of their policies and procedures, the company must include at least the following internal credit risk concentration limits, which must constitute credit risk mitigants, if applicable: a) Limits with a counterparty or with a group of counterparties connected by single risk.2 b) Limits by economic sectors, by geographic location, and other common risk factors that impact the total of credit risk exposures. Risk concentration limits must consider all exposures subject to credit risk. The limits established by the company must be consistent with current regulations. Any exception to internal limits must be approved by the Board of Directors. SUB-CHAPTER III EVALUATION OF CREDIT RISK Article 19°.- Approval process The approval process includes the set of criteria and procedures established by the company to decide whether it accepts or not the credit risk of a counterparty or an operation subject to credit risk. In this process, the main risk factors must be analyzed, considering variations in interest rates and exchange rates, as well as the counterparty's payment capacity as the primary source of fulfillment of its credit obligations. This payment capacity must be adequately supported in the corresponding files. In this sense, companies must have credit evaluation methodologies that allow the quantification of the credit risk of their debtors and counterparties in order to determine if they comply with the established levels of appetite and tolerance for risk. With respect to microenterprise and small enterprise credits, companies may dispense with some of the documentary requirements and carry out credit evaluations, generating indicators of payment capacity of the family-business unit, based on substantiated information prepared jointly with the potential borrower, to the satisfaction of this control body. Additionally, information on the social and economic environment of the debtor can be considered. Likewise, for the granting of working capital loans or other short-term products, prior approval of the Board of Directors and compliance with what is stated in the Tenth Final and Transitional Provision of the Regulation for the Evaluation and Classification of the Debtor and the Requirement of Provisions, approved by SBS Resolution No. 11356-2008 and its modifications, or the norm that replaces it, companies may use transactional information from verifiable sources, for the determination of annual sales, income, and expenses of the family-business unit. 3 Article 20°.- Considerations in the pre-approval credit evaluation In addition to what is provided in the Regulation for the Evaluation and Classification of the Debtor and the Requirement of Provisions, companies must take into account the s

7 Article 21°.- Evaluation of the counterparty The evaluation of the counterparty must consider its financial capacity, its history of compliance with its obligations, its management quality, and its position in the market. For natural persons, the evaluation must consider their income, assets, and liabilities. For legal entities, the evaluation must consider the financial statements, cash flow projections, and the analysis of the economic sector in which they operate. Article 22°.- Evaluation of the operation The evaluation of the operation must consider the purpose of the credit, the repayment source, the collateral offered, and the legal structure of the transaction. The repayment source must be primary and sufficient to cover the debt service. Collateral must be valued at market value and must be liquid and enforceable. Article 23°.- Approval limits The approval of credit operations must be subject to limits established in the company's policies. These limits must be based on the risk profile of the counterparty and the operation. Any exception to these limits must be approved by the appropriate authority, as defined in the policies. Article 24°.- Documentation All credit operations must be documented in writing. The documentation must include the credit application, financial statements, collateral documents, and the credit approval memo. The documentation must be complete and accurate. Article 25°.- Post-approval monitoring After approval, the credit operation must be monitored to ensure compliance with the conditions established in the approval. Any deviations must be reported and corrective actions must be taken. The monitoring must include the review of financial statements, collateral value, and the counterparty's payment history. Article 26°.- Classification of exposures Exposures subject to credit risk must be classified according to the company's internal classification system and the regulatory classification system. The classification must be updated regularly and must reflect the current risk profile of the exposure. Article 27°.- Provisions Companies must calculate and record provisions for credit losses in accordance with the regulatory requirements. The provisions must be sufficient to cover expected losses. The calculation of provisions must be based on the classification of the exposure and the historical loss experience of the company. Article 28°.- Reporting Companies must report on their credit risk management activities to the Board of Directors and the Superintendency. The reports must include information on the credit portfolio, the classification of exposures, the provisions, and the risk concentration limits. Article 29°.- Internal Audit The internal audit function must review the credit risk management process to ensure compliance with the company's policies and regulatory requirements. The internal audit must report its findings to the Board of Directors and the Audit Committee. Article 30°.- Training Companies must provide training to their employees on credit risk management. The training must cover the company's policies, procedures, and regulatory requirements. The training must be regular and updated. Article 31°.- Outsourcing Companies may outsource certain credit risk management functions, provided that they maintain ultimate responsibility for the management of credit risk. The outsourcing must be subject to contractual agreements that ensure the quality and reliability of the services provided. Article 32°.- Information Technology Companies must have adequate information technology systems to support credit risk management. The systems must ensure the accuracy, completeness, and timeliness of the information used for credit decisions. Article 33°.- Data Quality Companies must ensure the quality of the data used for credit risk management. The data must be accurate, complete, and timely. The data quality must be monitored and reported. Article 34°.- Stress Testing Companies must perform stress tests to assess the impact of adverse scenarios on their credit portfolio. The stress tests must be regular and comprehensive. The results of the stress tests must be used to inform risk management decisions. Article 35°.- Model Risk Management Companies must manage the risk associated with the models used for credit risk management. The models must be validated regularly and their limitations must be understood. The model risk must be reported to the Board of Directors. Article 36°.- Governance Companies must have a clear governance structure for credit risk management. The roles and responsibilities of the Board of Directors, Management, and Risk Management units must be clearly defined. The governance structure must ensure effective oversight and accountability. Article 37°.- Reporting to the Board of Directors The Credit Risk Unit must report to the Board of Directors on the company's credit risk profile, including the performance of the portfolio, the classification of exposures, the provisions, and the risk concentration limits. The reports must be regular and comprehensive. Article 38°.- Review of Policies The credit risk policies must be reviewed regularly to ensure their relevance and effectiveness. The review must be conducted by the Board of Directors or a committee authorized by the Board of Directors. Article 39°.- Compliance Companies must comply with all applicable regulations regarding credit risk management. Non-compliance must be reported and corrective actions must be taken. Article 40°.- Sanctions Companies that fail to comply with this Regulation may be subject to sanctions imposed by the Superintendency. Article 41°.- Entry into force This Regulation enters into force on the date of its publication.

8 Article 42°.- Repeal The following norms are repealed: a) Article 1 of SBS Resolution No. 37-2008, "Reglamento de Gestión Integral de Riesgos." b) Any other provision that contradicts this Regulation.

2 Letter a) substituted by SBS Resolution No. 00975-2025, published on 03/13/2025. Effective from 06/01/2025.

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