Revocation of Authorization for Caja Solidaria Huejuquilla, S.C. de A.P. de R.L. de C.V. — SHCP — MX

DOF: 23/04/2018

OFFICE through which the authorization granted to Caja Solidaria Huejuquilla, S.C. de A.P. de R.L. de C.V., to operate as a savings and loan cooperative society is revoked.

At the margin, a seal with the National Coat of Arms, which says: United Mexican States.- Ministry of Finance and Public Credit.- National Banking and Securities Commission.- Office No.: P092/2018.- Exp.: CNBV.212.421.12(5705) " 2017/Mar/10,2017/Mar/10 " /01/.

SUBJECT:

Your authorization to operate as a Savings and Loan Cooperative Society is revoked.

CAJA SOLIDARIA HUEJUQUILLA, S.C.
DE A.P. DE R.L. DE C.V.

Mariano Matamoros No. 7-B, Col. Centro,
C.P. 46000, Huejuquilla El Alto, Jalisco.

Attention:

C.P. CLAUDIA MADERA VALDÉZ
General Manager.

This National Banking and Securities Commission, based on the provisions of articles 84 of the Law to Regulate the Activities of Savings and Loan Cooperative Societies (hereinafter LRASCAP) and 16, fractions VI and XVII, of the Law of the National Banking and Securities Commission (hereinafter LCNBV); with the objective of complying with said legal norms, issues this resolution revoking the authorization to operate as a savings and loan cooperative society, which was previously granted to the society known as Caja Solidaria Huejuquilla, S.C. de A.P. de R.L. de C.V. (hereinafter Huejuquilla, Entity or Society, interchangeably), in accordance with the following:

BACKGROUND

Through office 311-30933/2008 and 134-21673/2008 of May 16, 2008, authorization was granted to operate as a savings and loan cooperative society to Huejuquilla, whose last registered address at this Decentralized Body is located at Mariano Matamoros No. 7-B, Col. Centro, C.P. 46000, Huejuquilla El Alto, Jalisco.

II.

Through office 134-2889/2015 of November 13, 2015 (hereinafter observation office), this Commission communicated to Huejuquilla the observations resulting from the ordinary inspection visit carried out on that Entity, in compliance with office 134-2752/2015 of August 21, 2015, granting the right to be heard so that said Society could make statements regarding its rights and submit the documentation and information it deemed appropriate to disprove said observations.

III.

By writing dated January 8, 2016, presented at the Common Registry Office of this Commission on that same date, Huejuquilla exercised the right to be heard granted to it through the observation office, making various statements and accompanying the documentation it considered relevant.

IV.

After conducting a detailed analysis of the documents and statements submitted by said Entity via writing dated January 8, 2016, this Institution determined that Huejuquilla did not disprove the observations made to it through office 134-2889/2015, which is why, through office 134-102478/2016 of February 22, 2016 (hereinafter corrective actions and measures office), it issued the corresponding corrective actions and measures.

Through two writings dated March 31, 2016, the first presented at the Common Registry Office of this Commission on April 11, 2016, and the second on May 17 of the same year, said Society made various statements and presented documentation requested in the corrective actions and measures office. Likewise, through writing dated April 30, 2016, presented at the Common Registry Office of this Commission on May 9, 2016, said Entity sent various documentation " regarding points 24 and 26 " of the corrective actions and measures office. Finally, by writing dated May 24, 2016, presented at the Common Registry Office of this Commission on May 30 of the following year, Huejuquilla attached various documentation related to corrective actions and measures corresponding to the observations indicated in numbers 1, 6 and 26.

VI.

From the analysis of the financial information sent by Huejuquilla to this Commission, through Regulatory Reports " Series R21 Capitalization. A-2112 Disaggregated capital requirements by risk " , in compliance with what is established in article 307 of the General Provisions applicable to the activities of savings and loan cooperative societies, published in the Official Journal of the Federation on June 4, 2012, modified by resolution published in the cited Journal on January 9, 2015 and January 7, 2016 (hereinafter Provisions), relative to the credit and market risks incurred in its operation, with respect to the period comprising December 2015 to January 2017, it emerges that its capital is lower than required, in accordance with what is provided in articles 50 and 51 of the Provisions, as observed in the table shown below:

MONTH / YEAR

CAPITAL REQUIREMENTS
BY RISKS

NET CAPITAL

CAPITAL
SHORTAGE

NICAP

31/12/2015
$2,434,372
-$193,412
$2,627,784
-7.945%
31/01/2016
$3,197,242
$185,279
$3,011,963
5.7949%
29/02/2016
$3,441,258
$275,228
$3,166,030
7.9978%
31/03/2016
$3,551,932
$263,880
$3,288,052
7.4291%
30/04/2016
$3,725,859
-$129,423
$3,855,282
-3.4736%
31/05/2016
$3,487,577
$691,507
$2,796,070
19.8277%
30/06/2016
$3,228,508
$487,029
$2,741,479
15.0852%
31/07/2016
$3,128,697
$346,358
$2,782,339
11.0703%
31/08/2016
$2,799,447
-$437,822
$3,237,269
-15.6395%
30/09/2016
$2,878,402
-$361,320
$3,239,722
-12.5527%
31/10/2016
$2,872,956
$547,464
$2,325,492
19.0557%
30/11/2016
$2,805,935
$1,350,203
$1,455,732
48.1195%
31/12/2016
$2,599,763
$1,287,222
$1,312,541
49.5130%
31/01/2017
$2,579,669
$1,127,534
$1,452,135
43.7084%

VII.

Through office 212/61888/2017, of June 13, 2017, notified by certified mail on August 7, 2017, this Commission summoned Huejuquilla to revoke its authorization to operate as a credit union, noting that it determined that said Society might have fallen under the causes provided for in article 84, fractions III, VI, VII and VIII, of the LRASCAP. Likewise, in terms of the aforementioned office, this Commission granted Huejuquilla a term of ten business days counted from the next business day after which the notification thereof took effect, so that, in exercise of its guarantee of hearing, it could state what it deemed appropriate to its rights, offer evidence and formulate arguments, in relation to the grounds for revocation for which it was summoned.

VIII.

Through office 212/61909/2017, of July 31, 2017, notified by certified mail on August 15, 2017, this Commission requested the Auxiliary Supervision Committee of the Auxiliary Supervision Fund of Savings and Loan Cooperative Societies and Protection of their Savers, opinion regarding the probable updating of the grounds for revocation provided for in the fractions III, VI, VII and VIII of article 84 of the LRASCAP, in which Huejuquilla might have incurred; in the terms exposed in office 212/61888/2017, of June 13, 2017. In light of this, in terms of the aforementioned office, this Commission granted said Fund a term of ten business days counted from the next business day after which the notification thereof took effect, so that it could issue an opinion regarding the possible updating of the referred grounds for revocation.

IX.

By writing dated August 10, 2017, presented at the Common Registry Office of this Commission on the 18th of the same month and year, Huejuquilla, in exercise of its right to be heard, made various statements in relation to the content of the summons office 212/61888/2017, of June 13 2017.

By writing dated August 24, 2017, presented at the Common Registry Office of this Commission on the 25th of the same month and year, the President of the Auxiliary Supervision Committee of the Trust of the Auxiliary Supervision Fund of Savings and Loan Cooperatives and Protection of their Savers, issued a favorable opinion, in relation to the grounds for revocation for which Huejuquilla was summoned.

XI.

Through memorandum DGSCAP A.- 144/2017, of November 10, 2017, the General Directorate of Supervision of Savings and Loan Cooperatives A of this Commission stated that " taking into account the background and financial situation ... has no objection to continuing with the revocation process of HUEJUQUILLA " .

XII.

By writing dated October 30, 2017, Huejuquilla submitted deed 24,772, of August 25, 2017, corresponding to the celebration of the extraordinary assembly of August 5, 2017, which was registered in the Public Commerce Register on September 4, 2017, with electronic commercial folio 176.

XIII.

On March 15, 2018, the revocation of the authorization of Caja Solidaria Huejuquilla, S.C. of A.P. de R.L. de C.V. was submitted to the consideration of the Board of Directors of the National Banking and Securities Commission, based on the facts indicated in the previous numbers and adopted, with respect to said Society, Agreement Twenty-Fourth, of which certification is attached to the present resolution and, for quick reference, is transcribed below:

" TWENTY-FOURTH.- The members of the Board of Directors, based on articles 12, fraction V of the Law of the National Banking and Securities Commission, in relation to article 84, fractions III, VI, VII and VIII of the Law to Regulate the Activities of Savings and Loan Cooperative Societies, taking into consideration the favorable opinion of the Sanctions Committee of the National Banking and Securities Commission in its session held on February 28, 2018, agreed unanimously to revoke the authorization granted, through office number 311-30933/2008 and 134-21673/2008 of May 16, 2008, to operate as a savings and loan cooperative society, to the society named Caja Solidaria Huejuquilla, S.C. de A.P. de R.L. de C.V., in the terms contained in the resolution attached to the respective note and which forms part of this agreement. "

As a result of the above, the reasons and legal provisions that support and motivate the revocation of the authorization to operate as a savings and loan cooperative society, which was previously granted to Huejuquilla are set forth below, in accordance with the following:

CONSIDERING

FIRST. Based on the provisions of articles 10 and 84 of the LRASCAP, in relation to what is established in articles 4, fractions XI and XXXVIII, as well as 12, fractions V and XV, of the LCNBV, this Decentralized Body is empowered to authorize the constitution and operation of savings and loan cooperative societies and, if applicable, to agree on the revocation of such authorizations.

SECOND. That in terms of what is provided in article 84 of the LRASCAP, this Commission, prior to hearing the corresponding savings and loan cooperative society, may declare the revocation of the authorization granted in the cases referred to therein, among which are those established in the fractions III, VI, VII and VIII, which for quick reference are transcribed below:

" Article 84.- The Commission may declare the revocation of the authorizations granted in terms of Article 10 of this Law, to Savings and Loan Cooperative Societies with Operation Levels I to IV, after having heard the opinion of the Auxiliary Supervision Committee and prior to hearing of the Society interested, in the following cases:
...
III.
If it does not comply with the capitalization requirements established pursuant to what is provided by Article 31, fraction VI, and the provisions to which said precept refers. ... VI. If it carries out operations in contravention of what is provided by this Law, the General Law of Cooperative Societies or by the provisions emanating from it, or if it abandons or suspends its activities. VII. If repeatedly, despite the Commission's observations, the Savings and Loan Cooperative Society executes operations other than those permitted, does not comply with general provisions applicable or puts at risk with its administration the interests of its Members, or of its social object, in accordance with what is provided by this Law and the General Law of Cooperative Societies. VIII. When due to causes attributable to the Savings and Loan Cooperative Society, the operations carried out do not appear duly and timely registered in its accounting. ... "

THIRD. That this National Banking and Securities Commission through office 212/61888/2017, of June 13, 2017, cited in numeral VII of the background section of this resolution, gave full compliance to what is provided in article 84, first paragraph, of the LRASCAP, in relation to what is established in fraction I of article 99 of the same legal order, as well as in article 62 of the Regulations of Supervision of the National Banking and Securities Commission, by having granted said Society a term of ten business days counted from the next business day after its notification, so that in exercise of its right to be heard, it could state what it deemed appropriate to its rights, offer evidence and formulate arguments, in relation to the grounds for revocation of its authorization to operate as a savings and loan cooperative society in which it was allegedly found, which are provided for in the fractions III, VI, VII and VIII of said article 84. Furthermore, in strict compliance and observance of what is provided in the first paragraph of article 84 of the LRASCAP, this Decentralized Body through office 212/61909/2017, cited in numeral VIII of the background section of this resolution, requested the Auxiliary Supervision Committee of the Auxiliary Fund of Savings and Loan Cooperative Societies and Protection of their Savers, opinion regarding the ground for revocation of the authorization to operate as a savings and loan cooperative society which was previously granted to Huejuquilla, who by writing dated August 24, 2017 (referred to in numeral X of the background section of this resolution), issued an opinion in the sense of stating that " due to the evident deterioration in its financial situation described above, Caja Solidaria Huejuquilla, S.C. de A.P. de R.L. de C.V., lacks viability to continue operating, therefore in accordance with the LRASCAP in its Article 84 fractions III, VI, VII and VIII, the declaration of the revocation of the authorization to Caja Solidaria Huejuquilla, S.C. de A.P. de R.L. de C.V., to operate as Savings and Loan Cooperative Society " is appropriate. Therefore, it must be concluded that this Commission gave full compliance to what is provided in the first paragraph of article 84 of the LRASCAP, fulfilling the requirements provided therein for the proceeding of the present resolution.

FOURTH. That from the integral and exhaustive analysis of the content of all and each of the documents referred to in the background section of this resolution, especially the summons office 212/61888/2017, of June 13, 2017, as well as the writing of August 10, 2017, by which said Entity exercised its right to be heard, this Decentralized Body determines that the arguments exposed by Huejuquilla are ineffective and, therefore, the grounds for revocation for which it was summoned are confirmed. Indeed, from the analysis of the content of office 212/61888/2017, referred to in numeral VII of the background section of this resolution, it emerges that this Commission summoned said Entity, estimating that it possibly could fall under the grounds for revocation of its authorization to operate as savings and loan cooperative society, which are referred to below:

" a)
NON-COMPLIANCE WITH THE CAPITALIZATION LEVEL FOR CREDIT AND MARKET RISK.
From the analysis of the financial information relating to said Entity, regarding the credit and market risks incurred in its operation (referred to in numeral 6 of the BACKGROUND section of this office), which was reported to this National Banking and Securities Commission through the Regulatory Reports " Series R21 Capitalization. A-2112 Disaggregated capital requirements by risk " , it emerges that its Capitalization Level by credit and market risk is lower than required, in terms of what is provided in articles 49, 50 and 51 of the Provisions, in relation to what is established in article 31, fraction VI, of the LRASCAP. For the above, it is affirmed that, during the period comprising December 2015 and January 2017, Huejuquilla did not comply with the Capitalization Level by credit and market risk, by maintaining a net capital lower than the capital requirements by risks, provided for in articles 49, 50 and 51 of the Provisions, which places it in non-compliance with what is provided in article 31, fraction VI, of the LRASCAP, which is transcribed in part below:
...
Under these conditions, since from the analysis of the content of the reports referred to it emerges that said Society, during the period comprising December 2015 to January 2017, did not comply with the Capitalization Level by credit and market risk, provided for in articles 50 and 51 of the Provisions, this Commission concludes that said Entity could fall under the ground for revocation provided for in fraction III of article 84 of the LRASCAP, which for quick reference is transcribed below:
... b)
CARRYING OUT OPERATIONS IN CONTRAVENTION OF WHAT IS PROVIDED IN THE LRASCAP AND THE PROVISIONS EMANATING FROM IT.
I. From the content of office 134-2889/2015 of November 13, 2015, referred to in the
numeral 2 of the BACKGROUND section of this office, it emerges that as a result of the ordinary inspection visit carried out on said Society in compliance with what is established in office 134-2752/2015 of August 21, 2015, this Decentralized Body communicated to Huejuquilla various observations, among which was the one marked with numeral 6, named " Receipt in firm of immediate collection documents " , in the following terms:

" Observation 6 Receipt in firm of immediate collection documents.
Derived from the cash count performed on September 22, 2015 on the cash balances in the boxes and vault of the main branch, the 40 checks were identified for a total of $329,378.21, which are detailed below received by said Society in firm, for which it delivered cash for the same amount and which formed part of the cash balance of $2,396,133.45, contravening its own " General Cash Policies and Management of Liquidity " which establish that checks received for deposit or payments, must be registered as safe good collection, being prohibited for the cashier, to register them in firm, according to numeral " 2. OF THE COUNTER AREA (CASHIERS) [sic] ", subnumeral 4.5. It is important to emphasize that said Society does not have authorization from this Commission for the celebration or receipt of checks in firm, accrediting previously before the Vice Presidency in charge of its supervision, that it has the technical and operational capacity for the administration of associated risks and the prudent realization of said operation, as it does not correspond to those of which said Society can perform, provided for in articles 19 of the LRASCAP and 10 of the Provisions. Ref. Date No. Bank Drawn by Beneficiary Amount 1 15/07/2015 57383 Banco Mercantil del Norte, S.A. Secretariat of Planning Administration and Finance Government of the State of Jalisco Domínguez Jara Vanesa Guadalupe $5,585.77 2 11/09/2015 19193797 BBVA Bancomer, S.A. SEP FONE Jalisco Payroll Falcón Ávila $794.35 3 11/09/2015 1479 BBVA Bancomer, S.A. Caja Huejuquilla, S.C. de A.P. of R.L. de C.V. Casas Tabuyo Gabriel $21,500.00 4 22/09/2015 993859 BBVA Bancomer, S.A. Caja Solidaria Huejuquilla, S.C. of A.P. de R.L. de C.V. María Idalit Álvarez Dávila $39,000.00 5 11/09/2015 193800 BBVA Bancomer, S.A. SEP FONE Jalisco Payroll Marcelo Falcón Ávila $545.87 6 11/09/2015 193798 BBVA Bancomer, S.A. SEP FONE Jalisco Payroll Marcelo Falcón Ávila $281.45 7 11/09/2015 193799 BBVA Bancomer, S.A. SEP FONE Jalisco Payroll Marcelo Falcón Ávila $545.87 8 11/09/2015 193789 BBVA Bancomer, S.A. SEP FONE Jalisco Payroll Marcelo Falcón Ávila $545.87 9 11/09/2015 193788 BBVA Bancomer, S.A. SEP FONE Jalisco Payroll Marcelo Falcón Ávila $545.87 10 11/09/2015 193790 BBVA Bancomer, S.A. SEP FONE Jalisco Payroll Marcelo Falcón Ávila $564.11 11 11/09/2015 193791 BBVA Bancomer, S.A. SEP FONE Jalisco Payroll Marcelo Falcón Ávila $564.11 12 11/09/2015 193792 BBVA Bancomer, S.A. SEP FONE Jalisco Payroll Marcelo Falcón Ávila $564.11 13 11/09/2015 193793 BBVA Bancomer, S.A. SEP FONE Jalisco Payroll Marcelo Falcón Ávila $564.11 14 11/09/2015 193794 BBVA Bancomer, S.A. SEP FONE Jalisco Payroll Marcelo Falcón Ávila $564.11 15 11/09/2015 193795 BBVA Bancomer, S.A. SEP FONE Jalisco Payroll Marcelo Falcón Ávila $564.11 16 11/09/2015 193796 BBVA Bancomer, S.A. SEP FONE Jalisco Payroll Marcelo Falcón Ávila $844.35 17 21/09/2015 993856 BBVA Bancomer, S.A. Caja Solidaria Huejuquilla, S.C. of A.P. de R.L. de C.V. Amando Méndez Márquez
$21,000.00 18 18/09/2015 156 BBVA Bancomer, S.A. Claudia Madera Valdéz Claudia Madera Valdéz $15,000.00 19 18/09/2015 155 BBVA Bancomer, S.A. Claudia Madera Valdéz Claudia Madera Valdéz $4,264.60 20 21/09/2015 8367 BBVA Bancomer, S.A. Municipality of Huejuquilla el Alto Partic Wenseslao Simental Galaviz $3,828.00 21 18/09/2015 511 BBVA Bancomer, S.A. SISTPARAELDESARR Integraldelafamilia DEELM María Isabel Valdéz Madera $3,600.00 22 18/09/2015 154 BBVA Bancomer, S.A. Claudia Madera Valdéz Carlos Iván Madera Valdez $10,000.00 23 18/09/2015 8343 BBVA Bancomer, S.A. Municipality of Huejuquilla el Alto Partic Rosa María Miranda Vela $6,067.72 24 11/09/2015 193505 BBVA Bancomer, S.A. SEP FONE Jalisco Payroll Martha Elena Ku Ramos $9,492.43 25 11/09/2015 193787 BBVA Bancomer, S.A. SEP FONE Jalisco Payroll Marcelo Falcón Ávila $545.87 26 15/09/2015 10573 BBVA Bancomer, S.A. Municipality of Mezquitic Jalisco Elvia Guillermina Macías Garay $39,692.80 27 04/09/2015 576419 BBVA Bancomer, S.A. Secretariat of Planning Administration and Finance Government of the State of Jalisco Falcón Ávila Rosalba $3,517.54 28 18/09/2015 8351 BBVA Bancomer, S.A. Municipality of Huejuquilla el Alto Partic Pablo Herrera Oroni $4,798.75 29 15/09/2015 507 BBVA Bancomer, S.A. SISTPARAELDESARR Integraldelafamilia DEELM

María de la Luz Caldera

Falcón

$7,269.00

13/09/2015

8347

BBVA Bancomer, S.A.

Municipio de Huejuquilla el Alto

Partic

Regina Yaneth Victorio

Torres

$1,000.00

17/09/2015

8337

BBVA Bancomer, S.A.

Municipio de Huejuquilla el Alto

Partic

Regina Yaneth Victorio

Torres

$1,000.00

15/09/2015

8350

BBVA Bancomer, S.A.

Municipio de Huejuquilla el Alto

Partic

Francisca Falcón Ramírez

$2,100.00

18/09/2015

8340

BBVA Bancomer, S.A.

Municipio de Huejuquilla el Alto

Partic

Ricardo Rosales Rodarte

$2,200.00

30/08/2015

67748

BBVA Bancomer, S.A.

SEP FONE Zacatecas Nómina

García

$8,793.23

21/09/2015

993857

BBVA Bancomer, S.A.

Caja Solidaria Huejuquilla, S.C. de A.P. de R.L. de C.V.

Anacleta Domínguez

González

$41,113.21

21/09/2015

993855

BBVA Bancomer, S.A.

Caja Solidaria Huejuquilla, S.C. de A.P. de R.L. de C.V.

Juana González Mata

$18,021.00

22/09/2015

993854

BBVA Bancomer, S.A.

Caja Solidaria Huejuquilla, S.C. de A.P. de R.L. de C.V.

Rentería Madera Edith

Esmeralda

$34,600.00

21/09/2015

993851

BBVA Bancomer, S.A.

Caja Solidaria Huejuquilla, S.C. de A.P. de R.L. de C.V.

Caldera García Yessica

$13,900.00

SIN FECHA

157

BBVA Bancomer, S.A.

Claudia Madera Valdez

$1,500.00

18/09/2015

8357

BBVA Bancomer, S.A.

Municipio de Huejuquilla el Alto

Partic.

María de Jesús Vargas

Ceniceros

$2,500.00

Total

$329,378.21

The practice described, in addition to distorting financial information by improperly recording an increase in the balance of its bank account for resources that did not actually enter, creates the risk that upon receiving firm checks and applying the corresponding resources to the payment of credits or crediting them to the members' deposit accounts, without prior verification that they will not be returned by the credit institutions, once deposited, the resources may fail to be received and losses may be generated. "

To this effect, in exercise of the right to be heard conferred upon said Society through the observations letter 134-2889/2015 of November 13, 2015, Huejuquilla presented before this Commission the writing of January 8, 2016, referred to in the antecedent marked with numeral 3 of the ANTECEDENTS section of this present letter, by virtue of which it issued various considerations, attaching the documentation it deemed appropriate; in particular, regarding the observation marked with numeral 6, it referred to the following:

" In relation to this observation, a meeting was held with the branch staff to reiterate their obligation to fully comply with the Policies established by the Society, mainly regarding the obligation to register checks received for deposit or payment subject to good collection, reminding them that in case of non-compliance with the aforementioned policies, they will be subject to the sanctions determined by the Board of Directors. Regarding this, documentation is sent that accredits that the checks were not returned as well as deposit receipts at the bank.

On the other hand, and in view of the fact that in the region where Caja Solidaria Huejuquilla, S.C. de A.P. de R.L. de C.V. operates, there are no banking institutions that offer financial services to the inhabitants of the place, it is of great importance that this Society can offer the services of receiving checks for deposit or payment, a situation for which a writing is being prepared in which authorization is requested from this National Banking and Securities Commission to continue carrying out said operation, previously accrediting that it has the technical and operational capacity for the administration of associated risks and the prudent execution of such operation. "

Having seen the above, after carrying out a detailed analysis of the statements made by Huejuquilla, this Commission determined that it did not disprove the observation in question, which is why it issued letter 134-102478/2016 of February 22, 2016, through which it communicated to said Entity the corrective actions and measures that were deemed appropriate, among which was the one related to observation 6, which was issued in the following terms:

" Not disproven (in process) with corrective action

The response is noted and this Commission informs you that the observation is not disproven, in virtue of the fact that said Society omitted to send proof that would disprove what was observed, so the infringement prevailed at the time of the review.

Therefore, and considering your arguments, this Commission instructs you to carry out the following actions:

Send complete bank statement of account 0449531599 that they maintain at BBVA Bancomer S.A., corresponding to the month of September 2015, in which the deposits corresponding to the crediting of the checks received subject to good collection are highlighted, in electronic file of Pdf format.

Send copy of the printed accounting vouchers made for the firm taking of the documents detailed in this observation, as well as their crediting in the bank balance, signed by its General Manager and by the president of the Board of Directors, as well as by the General Accountant.

Taking into account the corrective actions instituted in observation 4, we consider that they will serve to remedy the observation of the present numeral, so they must proceed as indicated in the aforementioned observation.

The foregoing without prejudice to the fact that this Commission may verify, if applicable, the correct implementation of the measures instructed to the Society and independently of the sanctions that may be appropriate. "

In light of the above, Huejuquilla through a writing of March 31, 2016, presented at this Institution on May 17 of the same year, made various statements regarding the actions and corrective measures that were ordered to it through letter 34-102478/ 2016 of February 22, 2016, being that, in the specific case, regarding the one identified with numeral 6, said Society referred to the following:

" Observation 6. Receipt in firm of immediate collection documents.

Subsection a) attached on CD in PDF file the statements where the deposit of the checks indicated in the list of this point is reflected.

Subsection b) Attached are the printed accounting vouchers of the accounting record of the deposit of said checks indicated in this observation. "

Subsequently, through a writing of March 31, 2016, presented at this Commission on May 30, 2016, said Society sent various documentation related to the observation and subsequent corrective measure identified with numeral 6., consisting " in cd statement and auxiliaries " .

Having seen the foregoing, it is reasonable to conclude that Huejuquilla contravened what is established in articles 19 of the LRASCAP, as well as 10 and 17 of the Provisions, since those do not correspond to those that can be carried out by the Entity in question.

II.

From the content of letter 134-2889/2015 of November 13, 2015, referred to in numeral 2 of the ANTECEDENTS section of this present letter, it is clear that as a result of the ordinary inspection visit carried out on said Society in compliance with what is established in letter 134-2752/2015 of August 21, 2015, this Decentralized Body communicated to Huejuquilla various observations, among which was the one marked with numeral 17, named " Operation not permitted for Savings and Loan Cooperatives " , in the following terms:

" Observation 17

Operation not permitted for Savings and Loan Cooperatives.

In the cash inventory witnessed by the inspectors of this Commission who carried out the inspection visit, carried out by the C. Lauramelia González Ramírez, Head of Deposits, on the cash holdings of the main office corresponding to the start of operations on October 1, 2015, it was observed that they maintained an expense voucher dated September 29, 2015 for $50,000, which indicates in the concept " pen to recover from José Cruz Ruíz de la Torre " and regarding which, the staff in charge of the cashier verbally stated that it corresponds to a loan made to the exchange house (sic) named " el centavito " , notwithstanding that none of the persons mentioned are members of HUEJUQUILLA. "

" Response: With respect to this observation, we allow ourselves to explain that due to staff error, said operation was carried out; however, the Society commits to avoiding it in the future. In addition, payment receipt and deposit slip are sent, corresponding to the payment of said operation, in which it is observed that it was covered the day after the operation.

It is important to mention that, this situation resulted from internal control failures within the Society, on which work is already being done to avoid them in the future. "

Under such conditions, after carrying out a detailed analysis of the statements made by Huejuquilla, this Commission determined that it did not disprove the observation in question, which is why it issued letter 134-102478/2016 of February 22, 2016, through which it communicated to said Entity the corrective actions and measures that were deemed appropriate, among which was the one related to Observation 17, which was issued in the following terms:

" Not disproven (in process) with corrective action

The response is noted and this Commission informs you that the observation is not disproven, in virtue of the fact that said Society provided evidence of its correction after the deadline and manner in which it should have complied, so the infringement prevailed at the time of the review.

Notwithstanding the above, from the analysis carried out on the information provided by in relation to the argument exposed, it was concluded that it does not adhere to the facts presented by the documents, submitted, since the payment date that the format named " Deposit Slip " with folio number 9979 of Series Aes of February 21, 2015. On the other hand, an inconsistency was observed in the chronological use of the formats named " Deposit Slip ", since folio 9978 of series A that they sent as proof of the previous observation 5 documents a deposit made on December 12, 2015, so it is inconsistent that the next folio, 9979 of the same series, documents a deposit made on February 21, from which it is clear that said Society does not keep chronological control and documentation of the formats used, generating uncertainty regarding the veracity of the operations carried out.

Therefore, this Commission instructs you to send an accounting voucher in which the restitution of those cash resources is appreciated, signed by the presidents of the Board of Directors and Supervisory Board, as well as evidence that supports documentally that they have communicated to their staff to avoid carrying out that type of operations, which they will prove by sending it in electronic file of Pdf format.

" At this point. I allow myself to inform that attached in printed form is the accounting voucher where the payment of 50,000.00 corresponding to the settlement of the operation referred to in this observation was registered, which had been settled in October, but in the receipt an incorrect date was registered by error.

Likewise (sic) attached in printed form is the writing addressed to the general cashier responsible and signed by the Manager, where it is made known to her that the operations indicated in this observation are strictly prohibited. "

Exposing the above, it is reasonable to conclude that Huejuquilla carried out operations with persons who are not its members, which contravenes what is provided in articles 19, fraction I, subsection f), of the LRASCAP and 10, fraction I, subsection f), of the Provisions.

Thus, in light of the content of the observations identified with numerals 6 and 17 of letter 134-2889/2015 of November 13, 2015, which were made to said Society as a result of the 2015 ordinary inspection visit; to the statements and documentation that in exercise of its right to be heard it presented before this Commission through a writing of January 8, 2016; as well as to the actions and corrective measures that were dictated to said Entity through letter 134-102478/2016 of February 22, 2016; and to the statements and documentation that said Society made available to this Institution through the various writings of March 31, 2016, this Decentralized Body concludes that Huejuquilla carried out operations in contravention of what is provided in articles 19 of the LRASCAP, as well as 10 and 17, of the Provisions.

Therefore, since from the content of the aforementioned observations and of the appropriate corrective measures, it is clear that said Society carried out operations in contravention of what is provided in the LRASCAP and in the Provisions emanating from it, it is concluded that Huejuquilla could be located in the cause for revocation provided for in fraction VI of article 84 of the LRASCAP, which for prompt reference is reproduced below:

...

IN SPITE OF THE OBSERVATIONS ISSUED BY THIS COMMISSION,

HUEJUQUILLA REPEATEDLY EXECUTED OPERATIONS DIFFERENT FROM THE

PERMITTED ONES.

As a result of the ordinary inspection visit carried out on Huejuquilla in compliance with what is provided in letter 134-2752/2015 of August 21, 2015, this Commission issued various observations to said Society, which were communicated to it through letter 134-2889/2015 of November 13, 2015, referred to in numeral 2 of the ANTECEDENTS section of this present document, among which was the one identified with numeral 6 (transcribed above), which constituted a " Repeated Offense " on the part of said Entity in the following terms:

" Repeated Offense

This situation had already been observed in numeral 2.5 of Letter

No. 134-4389/2012 of May 15, 2012, product of the

ordinary inspection visit carried out in the year 2012, without

actions necessary for its

correction having been taken to date. "

Having seen the above, it is affirmed that said Society, despite the observations made to it by this Commission, through letter 134-4389/2012 of May 15, 2012, continued to carry out operations different from those that it is expressly permitted to carry out, in terms of the applicable regulations, which constitutes a repeated conduct that contravenes what is provided in articles 19 of the LRASCAP, as well as 10 and 17

of the

Provisions.

For this reason, since, despite the observations made by this Commission,

Huejuquilla repeatedly carried out operations different from the permitted ones, it is determined

that said Society could be located in the cause for revocation provided for in fraction VII of

article 84 of the LRASCAP, which is transcribed below:

...

FOR CAUSES ATTRIBUTABLE TO HUEJUQUILLA, THE OPERATIONS

CARRIED OUT WERE NOT PROPERLY AND TIMELY REGISTERED IN ITS ACCOUNTING.

I. From the content of letter 134-2889/2015 of November 13, 2015, referred to in

numeral 2 of the ANTECEDENTS section of this present letter, it is clear that as a

result of the ordinary inspection visit carried out on said Society, in compliance with

what is established in letter 134-2752/2015 of August 21, 2015, this Decentralized

Body communicated to Huejuquilla various observations, among which was

the one marked with numeral 1, named " Alteration of records and simulation of

cash operations that affected the composition of assets and results " , in the terms

following:

" Observation 1

Alteration of records and simulation of cash operations

that affected the composition of assets and results.

In the inventory witnessed by the inspectors of this Commission who carried out the inspection

visit, carried out by the C. Lauramelia González Ramírez, Head of Deposits, on the

cash holdings of the branches and vault of the HUEJUQUILLA main branch, at the

close of operations on September 22, 2015, 27 vouchers were found that the

staff of said Society identifies as " Renewals " vouchers for a total of

$2,679,309.52 in which it is recorded that various payments or partial credits were made

to the amount of the voucher, such that subtracting the credited amounts, a

net amount of $2,484,745.43 is obtained, and that despite the fact that said documents do not correspond

to bills, coins or deposits in financial entities made in the country,

represented in cash, the amount of the same was part of the cash balance by

$2,396,133.45 on that date.

On the other hand, in the accounting registration vouchers and the slips issued by its

computer system, signed by the members and endorsed with the seal of the Society, it was proven

that the aforementioned vouchers were used to simulate and register in its computer system the

collection of the 27 credits detailed below, without said Society having

received the corresponding resources, as stated in the partial act that was

drawn up during the ordinary inspection visit on September 22, 2015:

Ref.

Credit No.

Disposal Date

Maturity Date

Original Amount

of Credit

Member No.

Member

Voucher Date

Net Amount of

Voucher

3083

13-jul-11

12-jul-12

$500,000.00

821

Fausto Vela Miranda

09-aug-12

$657,914.75

3085

13-jul-11

12-jul-12

$169,000.00

5000

22-oct-13

22-oct-14

$475,000.00

2374

Francisco Valdez Álvarez

31-dec-14

$607,240.00

5865

7-nov-14

6-may-15

$171,000.00

4543

José Alvaro Corona Ochoa

11-jun-15

$196,149.33

5806

4-dec-14

6-feb-15

$20,000.00

29-apr-14

$23,456.55

1816

11-jan-10

11-jan-11

$90,000.00

2525

Ma Guadalupe Delgado Valdivia

23-jul-12

$178,574.70

1831

18-jan-10

18-jan-11

$88,000.00

2630

Rosalina Montes Rodriguez

23-jul-12

$173,772.72

1969

19-mar-10

21-mar-11

$40,000.00

23-jul-12

$25,519.74

1236

18-may-09

18-may-10

$97,800.00

938

Catalina Carrillo Ramírez

28-oct-11

$85,506.48

2337

24-sep-10

25-jul-11

$72,000.00

1270

Javier Madera Leyva

15-jun-12

$67,292.08

3383

30-nov-11

1-dec-14

$70,500.00

3508

Lizeth América Madera

01-dec-14

$65,614.46

414

7-may-08

7-may-09

$16,240.00

322

Rafael Cruz Gonzalez

30-jun-14

$54,823.53

4890

30-aug-13

7-sep-15

$40,000.00

3284

Natzume Oyumiri Campos

Castañeda

01-sep-15

$46,400.45

30-aug-13

$655.00

1212

30-apr-12

30-jun-09

$17,000.00

626

Rogelio Vera Faullon

16-jan-13

$45,600.00

3962

24-aug-12

24-feb-14

$200,000.00

1798

Yesenia Armas Moreno

15-dec-14

$43,260.00

2512

24-nov-10

26-sep-11

$45,000.00

1706

Ismael Madera Leyva

15-jun-12

$39,473.58

434

15-may-08

15-mar-09

$8,550.00

1258

Juan Macías Ramírez

30-jun-14

$29,131.28

4354

27-feb-13

30-dec-13

$50,000.00

4066

Israel Rivera Ledezma

06-jan-14

$25,022.43

903

24-nov-08

24-sep-09

$12,800.00

1345

Felipe Ramírez Garcia

24-aug-12

$23,505.54

2767

11-mar-11

9-jan-12

$9,337.92

2123

Margarito Carrillo Alaniz

30-jun-14

$22,395.88

3556

7-feb-12

7-dec-12

$60,000.00

377

Fredy Medina Sánchez

11-dec-12

$22,380.14

1930

1-mar-10

1-mar-11

$13,000.00

701

Martha Carrillo Mejia

24-oct-11

$19,921.72

1941

5-mar-10

3-jan-11

$20,000.00

819

Ma. Rosario Barrios Vargas

15-jun-12

$18,009.66

245

25-jan-08

25-nov-08

$1,550.00

1712

Indalecio Pinedo Valdez

30-jun-14

$5,480.80

5539

1-jul-14

4-may-15

$10,000.00

4358

Javier Núñez Reyes

17-apr-15

$3,258.77

3123

27-jul-11

23-apr-12

$8,000.00

3087

Elsa Gómez Alcantar

16-oct-13

$2,385.84

2000

18-oct-05

18-jan-06

$1,000.00

1217

Herminia Ramírez Chávez

28-aug-12

$2,000.00

TOTAL

$2,305,

777.92

$2,484,745.43

Data of accounting vouchers and slips issued by the computer system

Ref.

Voucher Date

Member No.

Credit No.

Member

Date of slip and accounting voucher where the simulation of credit payment is recorded

Cash slip No. in which payment is simulated

Accounting voucher No. of income in which it was registered

09-aug-12

821

3083

Fausto Vela Miranda

09-aug-12

37,906

3085

09-aug-12

37,905

31-dec-14

2374

5000

Francisco Valdez Álvarez

31-dec-14

70,205

215

11-jun-15

4543

5865

José Alvaro Corona Ochoa

11-jun-15

76,673

557

29-apr-14

4543

5806

José Alvaro Corona Ochoa

29-apr-15

75,010

419

23-jul-12

2525

1816

Ma Guadalupe Delgado Valdivia

23-jul-12

37,320

23-jul-12

2630

1831

Rosalina Montes Rodriguez

23-jul-12

37,318

23-jul-12

2630

1969

Rosalina Montes Rodriguez

23-jul-12

37,319

28-oct-11

938

1236

Catalina Carrillo Ramírez

30-jun-10

14,186

15-jun-12

1270

2337

Javier Madera Leyva

15-jun-12

36124 y 36125

01-dec-14

3508

3383

Lizeth América Madera

01-dec-14

69,151

147

30-jun-14

322

414

Rafael Cruz Gonzalez

30-jun-14

63,892

01-sep-15

3284

4890

Natzume Oyumiri Campos

Castañeda

01-sep-15

80,158

30-aug-13

16-jan-13

626

1212

Rogelio Vera Faullon

16-jan-13

44,005

15-dec-14

1798

3962

Yesenia Armas Moreno

15-dec-14

69,610

174

15-jun-12

1706

2512

Ismael Madera Leyva

15-jun-12

36127

30-jun-14

1258

434

Juan Macías Ramírez

30-jun-14

63891

06-jan-14

4066

4354

Israel Rivera Ledezma

06-jan-14

57718

24-aug-12

1345

903

Felipe Ramírez Garcia

24-aug-14

38740

30-jun-14

2123

2767

Margarito Carrillo Alaniz

30-jun-14

63894

11-dec-12

377

3556

Fredy Medina Sánchez

11-dec-12

42616

24-oct-11

701

1930

Martha Carrillo Mejia

24-oct-11

28407

15-jun-12

819

1941

Ma. Rosario Barrios Vargas

15-jun-12

36123

30-jun-14

1712

245

Indalecio Pinedo Valdez

30-jun-14

63890

17-apr-15

4358

5539

Javier Núñez Reyes

17-abr-15

74589

393

16-oct-13

3087

3123

Elsa Gómez Alcantar

28-feb-12

N.D.

28-ago-12

1217

2000

Herminia Ramírez Chávez

28-dic-12

N.D.

It is worth highlighting that in addition to improperly registering an increase in the cash balance for resources that were not received, with the described accounting alteration, by considering the involved credits as paid, that Society omitted to recognize the days of default that would have been registered from the date they were due to be settled, and consequently, even though its amortizations were not fully settled in the agreed terms, that Society omitted to register in its accounting as non-performing loans the balances of those that presented the natural days of overdue as provided for in the Accounting Criterion B-4 Credit Portfolio, paragraph 61, in addition to establishing the preventive estimates for credit risks corresponding thereto. "

To this effect, in exercise of the right to be heard conferred upon it through the observation notice 134-2889/2015 of November 13, 2015, Huejuquilla presented before this Commission the writing of January 8, 2016, referred to in the antecedent marked with numeral 3 of the section of ANTECEDENTS of this notice, by virtue of which it issued various considerations, attaching the documentation it deemed appropriate; in particular, regarding the observation marked with numeral 1, it referred to the following:

" Response: Regarding this point, it should be mentioned that of the 27 credits mentioned, as of today, 9 credits have been settled and from one a payment was received, which represents a total amount of $845,836.95, for which a payment receipt and bank deposit slip are attached. Of the remaining 17, certified copies of the promissory notes held by the Society for their recovery and the court document are attached, for those credits that are in judicial process.

It should be clarified that, although it is true, this situation resulted from internal control failures within the Society, at no time was there intent, bad faith, or a particular interest on the part of its employees and executives to conceal the true nature of the operations carried out, appearing to present a financial situation of the Society different from the real one, failures on which work is already being done to avoid them in the future. "

Under such conditions, after carrying out a detailed analysis of the statements made by Huejuquilla, this Commission determined that it did not refute the observation in question, which is why it issued notice 134-102478/2016 of February 22, 2016, through which it communicated to that Entity the corrective actions and measures that were deemed appropriate, among which was the one related to Observation 1, which was issued in the following terms:

" Not refuted (in process) with corrective action

The response is noted and this Commission informs you that the observation is not refuted, in virtue of the fact that that Society provided evidence of the actions taken for the recovery of the credits indicated for correction after the deadline and manner in which it should have complied; however, it omitted to provide information and documentation that accredits that it registered the cash shortage we are concerned with, so the infringement prevails.

On the other hand, that Society omitted to send the bank statements in which the deposit into its accounts of the resources corresponding to the credits it stated had been recovered can be seen.

For the above, this Commission instructs you to carry out the following actions:

Send the complete bank statement(s) signed by the Presidents of the Board of Directors and Supervisory Board of HUEJUQUILLA, in which the 10 deposits for a total of $845,836.95, to which your response refers, are visible, in electronic file format Pdf.

Register in its accounting at the end of December 2015, the shortage of bills and coins detected in the cash count of cash holdings practiced at the close of day September 22, 2015, as well as all credits that that Society improperly cancelled with the "Renewals" vouchers, through a charge in the item of "Credit Portfolio", classifying them as overdue according to the days of default that the credits backing them present and a credit to the account "110100000000 Cash", which will be proven by sending the printed accounting vouchers of said registration, signed by its General Manager and the President of the Board of Directors, as well as by the General Accountant.

Create and recognize in accounting the preventive estimates for credit risks for a total amount of $2,484,745.43 corresponding to the reclassification carried out in the previous subsection, which will be proven by sending the printed accounting vouchers in which said records are observed, signed by its General Manager and by the President of the Board of Directors, as well as by the General Accountant.

Adapt its computer system, so that any movement affecting cash resources operating in all its counters, for deposit and credit operations, is registered in detail and controlled within it, allowing obtaining true, integral, complete and verifiable reports of final cash holdings at a specific date or period, which will be proven by sending the printout of the screens of its computer system in which it is appreciated that the respective adaptations were carried out, in electronic files of format Pdf.

Implement the policy of practicing daily cash counts by cash personnel and surprise counts by the Internal Audit area, on the cash holdings of all the branches that HUEJUQUILLA maintains, in which it is contemplated to compare the amount of cash holdings at the close of the day of the count, against the holdings that the records of its computer system present, and that the amount of the latter, is compared against the balance of the accounting account corresponding to cash.

Include in its policies for the handling and control of cash the activities of registration, control, investigation and assignment of responsibility, in case shortages or differences in cash holdings are detected, which, together with the one described in the preceding subsection, must be approved by its Board of Directors, which will be proven by sending the document containing the aforementioned policies, accompanied by the copy of the minutes in which its approval is recorded, certified by the Secretary of said Body, in electronic file format Pdf.

Send within the following 10 natural days, at the close of the months of March and April 2016, printed reports, signed by the Presidents of the Boards of Directors and Supervisory, of the result of the counts practiced during said months, indicating date, amount of holdings and accounting balance; as well as the actions taken in case of differences, between the physical holdings and the accounting records, attaching in case, those counts that present differences, in electronic file format

Pdf.

In light of the above, Huejuquilla through a writing of March 31, 2016, presented at this Institution on May 17 of the same year, made various statements regarding the actions and corrective measures that were ordered to it through notice 134-102478/2016 of February 22, 2016, being that, in the specific case, regarding the one identified with numeral 1, said Society referred to the following:

" Observation 1. Alteration of records and simulation of operations in cash that affected the composition of assets and results.

Regarding this point, the following is attached:

Subsection a). The statements of account required in this point are attached in printed form.

Subsection b). The accounting vouchers indicated in said subsection are attached, which proves that the indicated accounting adjustments corresponding to this subsection were made.

Subsection c). The printed accounting vouchers indicated in said subsection are attached, which prove that the indicated accounting adjustments were made, corresponding to this subsection.

Subsection d). Attached on cd, in PDF file, screen printout of the computer system where it is proven that the system was adapted as requested in this subsection.

Subsection f). Attached in PDF file the indicated policies, it should be clarified that both the policies and the board of directors minutes are also attached with PDF files with their respective names.

Subsection g). The reports of counts required in this observation are attached in printed and digital form. "

Subsequently, through a writing of May 24, 2016, presented at this Commission on the 30th of the same month and year, that Society, regarding the observation in matter, sent in printed and digital format various information consisting of "printed statement of account and auxiliaries".

In light of all the foregoing, it can be affirmed that Huejuquilla simulated and registered in its computer system the collection of the various credits, without that Society having received the corresponding resources, which contravenes what is established in articles 31, fraction VII and 32, of the LRASCAP, as well as 41 of the Provisions.

II. From the content of notice 134-2889/2015 of November 13, 2015, referred to in numeral 2 of the section of ANTECEDENTS of this notice, it is derived that as a result of the ordinary inspection visit carried out on that Society in compliance with what is established in notice 134-2752/2015 of August 21, 2015, this Decentralized Body communicated to Huejuquilla various observations, among which was the one marked with numeral 2, named "Expense vouchers and vouchers to be checked that were part of the cash balance", in the following terms:

" Observation 2

Expense vouchers and vouchers to be checked that

were part of the cash balance.

In the same count described in the preceding observation 1, other

44 expense vouchers to be checked and 61 expense vouchers for a total

of $111,635.50 and $40,496.06, respectively, were found, and which were part of the cash balance

of $2,396,133.45, despite the fact that said documents do not represent bills,

coins or deposits in financial entities made in the country, represented in cash, a situation from which it is derived that that Society omitted to recognize in

its accounting the items in question as an expense, despite having been made

during an accounting period, with the intention of generating income and with an impact

unfavorable on the net change in accounting equity, characteristics for

considering them as expenses, established in NIF A-5 Basic elements of

financial statements, paragraphs 51, 52 and 53, concealing the true nature of

said operations. "

Regarding this matter, in exercise of the right to be heard conferred upon it through the

observation notice 134-2889/2015 of November 13, 2015, Huejuquilla presented

before this Commission the writing of January 8, 2016, referred to in the antecedent marked

with numeral 3 of the section of ANTECEDENTS of this notice, by virtue of which

it issued various considerations, attaching the documentation it deemed

appropriate; in particular, regarding the observation marked with numeral 2, it referred to

the following:

" Response: in relation to this observation, receipts and/or invoices for the

44 expense vouchers to be checked and of 61 expense vouchers are sent, for a total of

$111,635.50 and $40,496.06, as well as the accounting voucher corresponding to the accounting

registration of said vouchers.

It should be clarified that, although it is true, this situation resulted from internal control

failures within the Society, at no time was there intent, bad faith, or a

particular interest on the part of its employees and executives to conceal the true nature of the operations carried out

appearing to present a financial situation of the Society different from the real one, failures on which work is already being done

to avoid them in the future. "

Having seen the above, after carrying out a detailed analysis of the statements made by

Huejuquilla, this Commission determined that it did not refute the observation in

question, which is why it issued notice 134-102478/2016 of February 22, 2016,

through which it communicated to that Entity the corrective actions and measures that were deemed

appropriate, among which was the one related to Observation 2, which was

issued in the following terms:

" Not refuted (in process) with corrective action

The response is noted and this Commission informs you that the observation is not

refuted, in virtue of the fact that that Society provided evidence of its correction after the deadline and manner in which it should have complied, so that the

infringement prevailed at the time of the review.

Notwithstanding the above, derived from the analysis of the 14 accounting vouchers for expenses

that it sent, detailed in the following table, it was determined that the accounting charges to

different expense accounts of the income statement amount to $186,421.96 that were

credited against the sub-account of banks "10-01-02-01-01-01-01-00-00 Bancomer

matrix 1599" of the account "10-01-02-00-00-00-00-00-00 Banks" for $199,091.54, which

results in an incongruence, since the total of expenses registered exceeds

by $34,290.40 the sum of the 44 expense vouchers to be checked and of 61

expense vouchers for a total of $111,635.50 and $40,496.06, respectively.

On the other hand, we clarify to you that the aforementioned amounts of $111,635.50 and $40,496.06

were part of the cash balance and not of banks, so the accounting effect

carried out is incorrect.

No.

Date of registration

Voucher Number

Amount charged to results

Credit to bank account

30/09/2015

$12,000.00

$11,440.80

30/09/2015

$6,877.72

$7,121.02

30/09/2015

$4,176.97

$4,599.90

30/09/2015

$11,882.00

16/10/2015

$20,000.00

$23,200.00

19/10/2015

$21,432.94

$22,252.46

29/10/2015

$3,330.92

$3,671.00

29/10/2015

$33,066.51

$36,122.84

29/10/2015

$12,501.07

$13,804.60

26/11/2015

138

$7,019.43

$7,689.11

26/11/2015

139

$12,471.58

$14,463.50

30/11/2015

148

$7,189.19

$7,807.81

30/11/2015

154

$8,676.40

$9,105.00

04/12/2015

169

$25,797.23

$25,931.50

Total

$186,421.96

$199,091.54

For the above, this Commission instructs you to carry out the following actions:

Send the complete bank statement(s) signed by the

Presidents of the Board of Directors and Supervisory Board in which

the 14 withdrawals detailed in the column "Credit to bank account"

of the preceding table are visible.

Recognize and register in its accounting with figures as of December 31, 2015,

a decrease in the balance of the account "110100000000 Cash" for an amount of

$152,131.56, corresponding to the sum of the 44 expense vouchers to be

checked and of 61 expense vouchers for a total of $111,635.50 and

$40,496.06, respectively, with a charge for the same amount to the sub-account

"10-01-02-01-01-01-01-00-00 Bancomer matrix 1599" of the account "10-01-02-00- 00-00-00-00-00 Banks", which will be proven by sending the printed accounting voucher

in which said entry is observed, signed by its General Manager and the

President of the Board of Directors, as well as by the General Accountant.

Provide documentary evidence that clarifies the difference between the charge to

expenses for $186,421.96, according to the 14 accounting vouchers for expenses that

it sent, and the sum of the 44 expense vouchers to be checked and of 61

expense vouchers for a total of $111,635.50 and $40,496.06 detected

in the count.

In order to strengthen the deficient process in the handling of cash in counters to

settle expenses, as well as null internal controls, they must design, implement

and incorporate into the "General Cash and Liquidity Management Policies" the

policies that contain as a minimum the following aspects, which will be proven by

sending us said policies, highlighting the modified and/or included texts,

accompanied by the certified copy by the Secretary of the Board of

Directors of the minutes of the session in which said Body approved them, in

electronic file format Pdf:

The cash that is required for the settlement of its operating expenses,

as well as the cash that is delivered to its employees and executives that

subsequently will be checked, must not be handled together with the holdings

of cash from its counters, instead they must be operated through a

revolving cash fund.

ii.

Deadlines for the verification of expenses.

iii.

Characteristics of the supporting documentation.

iv.

Procedures to control the verifications and, if applicable, assign

responsibilities, and

Accounting records that they will make, which must not be mixed with the

records of savings and credit operations, using the item of other

accounts receivable.

The foregoing without prejudice to the fact that this Commission may verify, if applicable, the correct

implementation of the measures instructed to the Society and independently of the

sanctions that may be applicable. "

Regarding this matter, Huejuquilla through a writing of March 31, 2016, presented at

this Institution on May 17 of the same year, made various statements regarding

the actions and corrective measures that were ordered to it through

notice 34-102478/2016 of February 22, 2016, being that, in the specific case, regarding the one identified with

numeral 2, said Society referred to the following:

" Observation 2. Expense vouchers and vouchers to be checked that were part of

the cash balance.

Subsection a). The requested statements of account are attached in print, including

from October to December 2016, where the indicated movements are observed.

Subsection b). The accounting voucher is attached in printed form as requested.

Subsection c). Clarifying documentation required is sent in printed form.

Subsection d). Attached on cd in PDF format the General Cash and Liquidity Management

policies, as indicated in this subsection. "

For the above, it is affirmed that Huejuquilla omitted to recognize in its accounting the items in

matter as an expense, despite having been made during an accounting period, with the

intention of generating income and with an unfavorable impact on the net change in the

accounting equity, which contravenes what is established in article 32 of the LRASCAP.

III. From the content of notice 134-2889/2015 of November 13, 2015, referred to in

numeral 2 of the section of ANTECEDENTS of this notice, it is derived that as

a result of the ordinary inspection visit carried out on that Society in compliance with

what is established in notice 134-2752/2015 of August 21, 2015, this Body

Decentralized communicated to Huejuquilla various observations, among which

was the one marked with numeral 3, named "Omission in the accounting registration of cash outflows from the Society's bank accounts", in the following terms:

" Observation 3

Omission in the accounting registration of cash outflows from the

Society's bank accounts.

From the analysis carried out on the bank reconciliations with figures as of July 31,

2015, it was observed that within the total of the 364 items that they presented in 7

bank accounts, that Society presented in the reconciliation corresponding to the

account 0449531599 that it maintained in BBVA Bancomer, S.A., the 17 items that

detail below for a total amount of $2,201,800.00 that correspond to

outflows of resources from its bank accounts and that that Society omitted to register in

its accounting:

Ref.

Date

Concept

Amount

01/07/15

Cash replenishment 2027907

$600,000.00

05/06/13

Transit check 991228

$50,000.00

07/10/13

Paid check 991525

$50,000.00

25/05/15

Payment to third party account 226010 25/05/15

$90,000.00

02/07/15

Payment to third party account 9133010 02/07/15

$50,000.00

09/07/15

Payment to third party account 53579010 09/07/15

$95,000.00

10/07/15

Payment to third party account 57016010 10/07/15

$50,000.00

17/07/15

Payment to third party account 49532010 17/07/15

$60,000.00

Subtotal, cash received and transferred to third parties

$1,045,000.00

09/12/13

Paid check in transit 991892

$200,000.00

14/11/14

Paid check 992687

$225,000.00

05/02/13

Paid check 990939

$300,000.00

10/05/13

Paid check in transit 991185

$136,800.00

27/10/12

Transit check 990255

$80,000.00

19/03/15

Paid check 1098

$50,000.00

19/03/15

Paid check 1099

$100,000.00

19/07/12

Transit check 669

$20,000.00

05/08/13

Transit check 151 (Banamex)

$45,000.00

Subtotal cash replenishments

$1,156,800.00

Total

$2,201,800.00

It is worth highlighting that with the accounting recognition of these items in the item of

Cash, the balance of the accounting account "101-01-00-00-00-00 Cash" that it maintained at

close of September 22 of the current year, date of the count practiced,

would increase to an amount of $1,631,678.25, which when compared to the cash holdings

on that date of $334,362.20, still presents a shortage of $1,297,316.05,

as shown below: "

Concept

Amount

Account balance of account "10-01-01-01-01-01-00-00-00 GENERAL

CASH" at close of September 22, 2015.

$2,396,133.45

(-) Renewal vouchers (observation 1)

$2,484,745.43

(-) Expenses to be checked (observation 2)

$111,635.50

(-) Expense vouchers (observation 2)

$40,496.06

(-) Checks exchanged for cash (observation 6)

$329,378.21

(=) Theoretical accounting balance of account "10-01-01-01-01-01-00-00-00

GENERAL CASH" at close of September 22, 2015.

-$570,121.75

(+) Cash replenishments to cash charged to banks not

accounted for.

$2,201,800.00

(=) Theoretical cash existence in CASH.

$1,631,678.25

(-) Cash counted in count of September 22, 2015.

$334,362.20

(=) Shortage in cash registers to be registered as loss.

$1,297,316.05

... "

To this effect, in exercise of the right to be heard conferred upon it through the observation notice 134-2889/2015 of November 13, 2015, Huejuquilla presented before this

Commission the writing of January 8, 2016, referred to in the antecedent marked with

numeral 3 of the section of ANTECEDENTS of this notice, by virtue of which it issued

various considerations, attaching the documentation it deemed appropriate;

in particular, regarding the observation marked with numeral 3, it referred to the following:

" In relation to this observation, documentation relative to the verification of the movements indicated in the first table, as well as the corresponding accounting voucher and corrected bank reconciliation, is sent attached to the present writing.

With respect to what is indicated in the second table, I hereby request an extension until April 30, 2016, to respond to this part of observation 3, due to the fact that an exhaustive review of the General Cash area has been underway, which includes the review of documentation from previous years, requiring a longer period to adequately conclude this review.

It should be clarified that, although it is true that this situation resulted from internal control failures within the Society, at no time was there intent, bad faith, or a particular interest on the part of its employees and executives to conceal the true nature of the operations carried out, pretending a financial situation of the Society different from the real one, failures for which work is already being done to avoid them in the future. "

In view of the foregoing, after carrying out a detailed analysis of the statements made by Huejuquilla, this Commission determined that it did not refute the observation in question, which is why it issued letter 134-102478/2016 of February 22, 2016, through which it communicated to that Entity the corrective actions and measures that proved appropriate, among which was the one related to Observation 3, which was issued in the following terms:

" Not refuted (in process) with corrective action

The response is noted and this Commission informs you that the observation is not refuted, in that that Society provided evidence of actions taken for its correction after the deadline and in the manner in which it should have complied, so the infringement prevailed at the time of the review.

Likewise, it is important to mention that within the records of the nine vouchers mentioned above, the 11 movements detailed below were identified, charged to the sub-account " '10-01-01-01-01-01-00-00 GENERAL CASH " of the account " 10-01-01-00-00-00-00-00-00 CASH " for $309,000.00 and credited to the sub-account " 10-01-02-01-01-01-01-00-00 BANCOMER MATIRZ 1599 " of the account " 10-01-02-00-00-00-00-00-00 BANKS " for the same amount, and that taking into account the dates contained in the vouchers and their concept, " cash replenishment ", it was determined that these are cases identical to those observed that that Society detected and corrected subsequently. "

Ref.

Date

Concept

Amount

Voucher Date

No. of

voucher

No date

Ref.992664 - Cash replenishment 06-1

$40,000.00

31/10/2015

263

09/11/2012

Cash replenishment ge

$5,000.00

01/11/2015

305

26/02/2013

Cash replenishment ge

$35,000.00

01/11/2015

305

26/02/2012

Cash replenishment ge

$25,000.00

01/11/2015

305

26/02/2012

Cash replenishment ge

$19,000.00

01/11/2015

305

26/04/2013

Cash replenishment ge

$30,000.00

01/11/2015

305

25/07/2013

Cash replenishment ge

$30,000.00

01/11/2015

305

18/07/2013

Cash replenishment ge

$30,000.00

01/11/2015

305

17/09/2013

Cash replenishment ge

$30,000.00

01/11/2015

305

16/10/2013

Cash replenishment ge

$30,000.00

01/11/2015

305

No date

Ref.991917 - Cash replenishment

$35,000.00

01/11/2015

307

Total

$309,000.00

For the above, this Commission instructs you as follows:

a) Until you inform the results of the exhaustive review that is being carried out in the general cash area of that Society, you must recognize and register in your accounting a cash shortage for an amount of $1,297,316.05 as of December 31, 2015, through an accounting entry charged to the sub-account " 505026010000 For Shortage in Branches " of the account " 505026000000 Losses " in the income statement and credited to the account " 110100000000 Cash " in the balance sheet, corresponding to the shortage calculated in the second table of this observation, which you will prove by sending the printed accounting voucher in which said accounting entry is observed, signed by its General Manager and by the President of the Board of Directors, as well as by the Comptroller General.

Send a report of the results obtained from the review that that Society will carry out of its general cash area, attaching to it the documentation that supports its conclusions, such as: accounting vouchers, bank statements, among others, as well as, in case of determining responsibilities, provide complaints filed with the competent authority, all of the above signed by the President of the Board of Directors, within the 10 business days following the close of the month of April 2016.

Send the integration of the adjustments made to clean up the 364 items that were maintained in the seven reconciliations of its bank accounts as of July 2015, detailing the reason that originated the item in reconciliation, accounts that are charged and credited for the cleanup, as well as the corresponding amounts, accompanied by the accounting vouchers and supporting documentation, as well as the bank reconciliations, bank statements and accounting auxiliaries, of all the accounts that it holds as of April and May 2016, within the 10 business days following the close of the months indicated above, signed by the Presidents of the Board of Directors and Supervisory Board, as well as by the Internal Auditor.

Include in its " manual of general cash policies and handling of liquidity " the obligation to prepare daily reconciliations of all bank accounts and investments that that Society maintains in operation, which must be carried out by persons unrelated to the handling and custody of its liquidity, in order to verify that the administration and recording of operations is carried out correctly, as well as to timely detect items that for some reason have not been recognized by the credit institutions, or by the Society itself, describing the process for their investigation, clarification and authorization, which you will prove by sending us the aforementioned manual that includes the policies in question, highlighting the modified and/or included texts, accompanied by the certified copy by the Secretary of the Board of Directors of the minutes of the session in which said Body approved it, in electronic file format Pdf.

In view of the foregoing, by writing of March 31, 2016, presented at this Institution on May 17 of the same year, Huejuquilla made various statements regarding the actions and corrective measures that were ordered to it by letter 34-102478/2016 of February 22, 2016, being that, in the specific case, regarding the one identified with numeral 3, that Society referred to the following:

" Observation 3. Omission in the accounting registration of cash exits from the Society's bank accounts.

Subsection a). Attached is a printed accounting voucher, in which the realization of the indicated adjustment is proven.

Subsections b) and c). They are in the process of being concluded, as more time than considered has been required, for which an extension is requested for this purpose.

Subsection e). Attached on CD in PDF file, the General Cash and Handling of Liquidity policies, with the indicated modifications.

Subsection g). Attached on CD electronic file with the report of audits performed. "

Having seen the above, it is indisputable that Huejuquilla omitted to register in its accounting various items for a total amount of $2,201,800.00, which correspond to exits of resources from its bank accounts, which contravenes what is provided in article 32 of the

LRASCAP.

IV . From the content of letter 134-2889/2015 of November 13, 2015, referred to in numeral 2 of the section of ANTECEDENTS of this letter, it emerges that as a result of the ordinary inspection visit carried out on that Society in compliance with what is established in letter 134-2752/2015 of August 21, 2015, this Decentralized Body communicated to Huejuquilla various observations, among which was the one marked with numeral 4, named " Registration of credit payments with resources from checks received in firm that were returned ", in the following terms:

" Observation 4.

Registration of credit payments with resources from checks

received in firm that were returned.

In the same analysis of the bank reconciliations, it was identified that HUEJUQUILLA had 5 items corresponding to the checks detailed below, received in firm on November 14, 2013, whose resources were credited on that date to the savings checking account of member 1050,

Ms.

Margarita Reyes Arroyo, who simultaneously withdrew from her checking account to pay credits 4928, 4119 and 4123, for amounts of $15,763.18, $38,104.20 and

$38,104.20, respectively, corresponding to the first two credits to member 2222, Mr. Saulo Zuriel Madrigal Reyes, son of the aforementioned member, and the other to the aforementioned member, despite that that Society deposited the referred checks in account 449531599 that it maintains with BBVA Bancomer, S.A. until the 19th of that same month and year, on which date they were subject to return by said credit institution, without that Society modifying the balances of the accounts of the members involved, the balance of its bank account, nor carrying out the actions to recover the resources.

Date

Check Number

Bank

Drawn by

Beneficiary

Amount

14/11/2013

3663

BBVA Bancomer, S.A.

Margarita Reyes Arroyo

Caja Solidaria Huejuquilla,

S.C. de A.P. de R.L. de

C.V.

$19,053.00

3664

$19,052.00

3665

$19,052.00

3666

$19,053.00

3662

$15,763.18

Total

$91,973.18

For the above, in addition to improperly registering an increase in the balance of its bank account for resources that did not enter the account, that Society omitted to recognize the days of default that would have been registered since the date on which they should have been settled and, consequently, despite the fact that its amortizations were not fully settled in the terms agreed, that Society omitted to register in its accounting as past due portfolio the balances of those that presented the natural days of overdue provided for in the B-4 Credit Portfolio accounting criterion, paragraph 61, in addition to constituting the preventive estimates for credit risks corresponding. "

Regarding this, in exercise of the right to be heard that was conferred upon it by the observation letter 134-2889/2015 of November 13, 2015, that Society presented before this Commission the writing of January 8, 2016, referred to in the antecedent marked with numeral 3 of the section of ANTECEDENTS of this letter, by virtue of which it issued various considerations, attaching the documentation that it deemed appropriate to that effect; in particular, regarding the observation marked with numeral 4, it referred to the following:

" Response: Regarding this observation, communication was had with Ms. Margarita Reyes Arroyo, committing herself to settle the total amount of $91,973.18 during the month of January 2016, a situation that is awaiting the corresponding payment, once it is made, the payment receipt and accounting voucher

will be sent to this National Banking and Securities Commission.

It should be clarified that although it is true that this situation resulted from internal control failures within the Society, at no time was there intent, bad faith, or a particular interest on the part of its employees and executives to conceal the true nature of the operations carried out, pretending a financial situation of the Society different from the real one, failures for which work is already being done to avoid them in the future. "

Under such conditions, after carrying out a detailed analysis of the statements made by Huejuquilla, this Commission determined that it did not refute the observation in question, which is why it issued letter 134-102478/2016 of February 22, 2016, through which it communicated to that Entity the corrective actions and measures that proved appropriate, among which was the one related to Observation 4, which was issued in the following terms:

" Not refuted (in process) with corrective action

The response is noted and this Commission informs you that the observation is not refuted, in that that Society stated that it had carried out actions to recover the amount in question; however, it omitted to send proof that corroborates its statement, so the infringement prevails.

For the above, this Commission instructs you to proceed as indicated below:

Accountably register as of December 31, 2015, the shortage in banks for an amount of $91,973.18, through a charge to the sub-account

" 505026010000 For Shortage in Branches " of the account " 505026000000

Losses " in the income statement and a credit to the account " 110200000000

Banks " in the balance sheet, corresponding to the return made by

BBVA Bancomer, S.A. when depositing the checks detailed in the table above,

with which the described credits were settled, which you will prove

by sending the printed accounting voucher in which said entry is observed,

signed by its General Manager and by the President of the Board of

Directors, as well as by the Comptroller General.

Modify its automated system so that the accounting treatment of the checks in question is carried out in accordance with the B- 1 Liquidity accounting criterion, paragraph 8, which you will prove by sending a copy of the system screens that show the described functionality, in electronic file format Pdf.

Provide a list of the checks received in the months of March and April

2016, indicating at least the following data, within the first ten

natural days following the close of the month in question in electronic file format Excel:

Date of receipt.

Name of the drawer.

Banking institution of the drawn account.

Drawn account number.

Check number.

Name of the beneficiary.

Indicate if the check was received for savings deposit or credit payment.

Date of deposit in the Society's bank accounts.

Date of crediting in the Society's bank accounts.

Banking institution of the Society in which the check was deposited.

Account number of the Society's banking institution in which the check was deposited.

Name of the member.

Amount of the check.

Send a copy of the statements issued by the banking institutions in electronic files

of Pdf format, in which it is appreciated that that Society sent to deposit the

checks that it received during the months of March and April 2016, identifying in said documents, each deposit made, which you will prove by sending them within

the first ten natural days following the close of the month in question.

Of the checks related in the preceding subsection d), send accounting auxiliaries of the

off-balance sheet accounts in which you identify the receipt of checks subject to good collection, of their cancellation and their registration in balance accounts when the resources were credited to the Society's accounts, in electronic files of Pdf format.

Likewise, from the situations described in observations 1 to 4, you must send a copy of the minutes of the Board of Directors session in which the records instructed by that Commission are approved, for the deficiencies determined, certified by the Secretary of said Body.

Under the aforementioned conditions, by writing of March 31, 2016, presented at

this Institution on May 17 of the same year, Huejuquilla made various statements

regarding the actions and corrective measures that were ordered to it by letter

34-102478/2016 of February 22, 2016, being that, in the specific case, regarding the

one identified with numeral 4, that Society referred to the following:

" Observation 4. Registration of credit payments with resources from checks received in

firm that were returned.

Subsection a), Attached in printed form is the accounting voucher requested, of the adjustment

indicated in the letter.

Subsection b). Attached on CD in electronic file in PDF format showing

the modification to the system indicated in this point.

Subsection c). Attached on CD file in Excel format containing the list of

checks requested.

Subsection d). in

... "

For the above, it is concluded that Huejuquilla registered in its accounting an improper

increase in the balance of its bank account for resources that did not enter the account,

which contravenes what is provided in articles 31, fraction VII and 32 of the LRASCAP, as

well as 41 of the Provisions.

V. From the content of letter 134-2889/2015 of November 13, 2015, referred to in

numeral 2 of the section of ANTECEDENTS of this letter, it emerges that as a

result of the ordinary inspection visit carried out on that Society in compliance with

what is established in letter 134-2752/2015 of August 21, 2015, this Decentralized Body

communicated to Huejuquilla various observations, among which was

the one marked with numeral 5, named " Registration in liquidity of remittances and

government programs paid ", in the following terms:

" Observation 5

Registration in liquidity of remittances and

government programs paid.

From the review of the trial balance issued by its system and integrations

provided by that Society, with figures as of July 31, August 31 and September 23

of 2015, it was observed that the balance of the item of Restricted Liquidity or

given as guarantee, included the nine items detailed below, corresponding to deliveries of resources that that Society made for the concept of payment of remittances and of the government program " Oportunidades ", without it being bills and coins, deposits in financial entities made in the country represented in cash.

Payment Date

Name of Beneficiary

Amount

Days of Age

as of 23-Sep-15

Concept

13-Jan-12

Sabino Madera Ramírez

$6,395.00

1,349

Remittance

16-Nov-12

Esmeralda Dorado R

$2,000.00

1,041

Remittance

01-Jul-13

Manuel Madera Ramírez

$6,455.00

814

Remittance

04-Apr-14

Sigifredo Galaviz

$5,904.00

537

Remittance

04-Apr-14

Margarito Ibarra

$3,974.20

537

Remittance

04-Nov-14

Elena Castañeda Rodarte

$912.69

323

Remittance

24-Feb-15

Reyes Muñiz Pedro Pablo

$1,000.00

211

Remittance

10-Apr-15

Mena Vela Martha Patricia

$3,087.00

166

Remittance

14-Apr-15

Rodriguez Casas Alfonso

$570.00

162

Remittance

19-Jun-15

Esperanza Landa Madera

$2,900.00

Oportunidades

Total to estimate

$33,197.89

Additionally, that Society has not obtained the reimbursement of the resources corresponding, so the items should have been registered as expense or within

the concept of accounts receivable, if there is any enforceable right to have the amounts delivered reimbursed, in which case, that Society omitted to constitute

the estimate for uncollectibility or difficult collection for the total of $33,197.89, not

withstanding that they are items that present an age superior to 90 natural days

since their initial recognition and that correspond to identified debtors. "

Regarding this matter, in exercise of the right to be heard that was conferred upon it by the

observation letter 134-2889/2015 of November 13, 2015, that Society

presented before this Commission the writing of January 8, 2016, referred to in the antecedent

marked with numeral 3 of the section of ANTECEDENTS of this letter, by virtue

of which it issued various considerations, attaching the documentation that it deemed

appropriate to that effect; in particular, regarding the observation marked with numeral 5, it referred to

the following:

" Response: Regarding the 10 items corresponding to remittances and payment of the

program " Oportunidades ", in that the National Savings Bank and Financial Services, S.N.C. did not recognize the payment of said items, communication was maintained with the persons to whom the resource was delivered to request their return. Attached is the payment receipt of said items and the corresponding bank deposit slip "

Having seen the above, after carrying out a detailed analysis of the statements

made by Huejuquilla, this Commission determined that it did not refute the observation

in question, which is why it issued letter 134-102478/2016 of February 22, 2016,

through which it communicated to that Entity the corrective actions and measures that proved

appropriate, among which was the one related to Observation 5, which was

issued in the following terms:

" Not refuted (in process) with corrective action

The response is noted and this Commission informs you that the observation is

not refuted, in that that Society provided evidence of

actions taken for its correction after the deadline and in the manner in which

it should have complied, so the infringement prevailed at the time of the review.

Notwithstanding the above, from the review carried out, it was detected that the $2,900.00

paid to Ms. Esperanza Landa Madera were not recovered as they

stated in their response and were recognized in the account " 52-13-03-14-00-00

Other expenses " in the income statement, according to voucher 393 of disbursements of November 30

2015; it was also observed that there were two formats named " Deposit Slip " with folio 9977 of series " A ", notwithstanding that in one of them the recovery of the remittance for $3,974.20 of Mr. Margarito Ibarra was documented and in the other format a remittance for $912.69 of Ms. Elena Castañeda Rodarte, which is incongruent and denotes a lack of control in the formats that document the deposit operations of that Society.

For the above, this Commission instructs you to incorporate into your " General Cash Operation Policies " the following policies:

The accounting registration of operations for remittance services, as well

as payment of government support, must be carried out in the item of Other

accounts receivable and not as part of Liquidity.

Prior to the payment of the remittance or government support, the Society must

verify that said person is the beneficiary and have them identified.

In the event that reimbursement for a remittance or government support has not been received, and more than 90 natural days have elapsed following its initial recognition, the corresponding Estimate for uncollectibility or difficult collection must be established for the total amount of the debt.

d)
Specific measures or actions that the Society will carry out in case there is no reimbursement by the transmitter of the remittance or government support.

The foregoing will be verified by sending to this Commission the aforementioned "General Cash Operation Policies", highlighting the modified and/or included texts, accompanied by a certified copy by the Secretary of the Board of Directors of the minutes of the session in which said Body approved the referred document, in electronic file format Pdf.

To this effect, through a writing dated March 31, 2016, presented at this Institution on May 17 of the same year, Huejuquilla made various statements regarding the corrective actions and measures ordered to it through notice 34-102478/2016 of February 22, 2016, being that, in the specific case, regarding the one identified with numeral 5, said Society referred to the following:

" Observation 5. Registration of availability of remittances and government programs paid. A cd is attached in PDF file the Cash and Availability Management Policies where the modifications made to said policies according to what is indicated in this point are reflected. "

Attentive to all the foregoing, this Institution concludes that Huejuquilla omitted to constitute the estimate for uncollectibility or difficult collection for the total of $33,197.89, which contravenes what is provided in article 32 of the LRASCAP.

VI. From the content of notice 134-2889/2015 of November 13, 2015, referred to in numeral 2 of the BACKGROUND section of this notice, it is derived that as a result of the ordinary inspection visit carried out on said Society in compliance with what is established in notice 134-2752/2015 of August 21, 2015, this Decentralized Body communicated to Huejuquilla various observations, among which was the one marked with numeral 7, named "Incorrect classification of investments in securities as availability", in the following terms:

" Observation 7
Incorrect classification of investments in securities as availability.
Derived from the analysis carried out on the integration of the bank account, belonging to the Availability item, at the close of July 2015, it was observed that the balance of $3,299,669.90 shown in the trial balance, included the amounts of $7,240.91 and $53,207.14, corresponding to the promissory notes with yield payable at maturity numbers PRLV3803007 and PRLV3803005, issued by the National Savings Bank and Financial Services (BANSEFI) that said Society maintained in accounts 615803 and 615802, respectively, which it has with the same credit institution, as evidenced in the respective bank statement, instead of being registered in the item of investments in securities. "

To this effect, in exercise of the right to be heard granted to it through the observation notice 134-2889/2015 of November 13, 2015, said Society presented before this Commission the writing of January 8, 2016, referred to in the antecedent marked with numeral 3 of the BACKGROUND section of this notice, by virtue of which it issued various considerations, attaching the documentation it deemed appropriate; in particular, regarding the observation marked with numeral 7, it referred to the following:

" Response: In relation to this observation, an accounting voucher is attached in which the reclassification of the balances of $7,240.91 and $53,207.14 corresponding to the promissory notes with yield payable at maturity issued by the National Savings Bank and Financial Services, S.N.C. is observed. "

Seeing the foregoing, after carrying out a detailed analysis of the statements made by Huejuquilla, this Commission determined that it did not disprove the observation in question, which is why it issued notice 134-102478/2016 of February 22, 2016, through which it communicated to said Entity the corrective actions and measures that were appropriate, among which was the one related to Observation 7, which was issued in the following terms:

" Not disproven (in process) with corrective action The response is noted and this Commission informs you that the observation is not disproven, in that said Society provided evidence of its correction after the deadline and manner in which it should have complied, so the infringement prevailed at the time of the review. For the above, this Commission instructs you to adhere to what is established in Accounting Criterion B-2 Investments in securities, and incorporate in your "Accounting Manual" the corresponding accounting records that you must carry out, taking as a basis the intention at the time of acquiring a certain instrument, which you will verify by sending said Manual with the modified and/or included texts, accompanied by a certified copy by the Secretary of the Board of Directors of the minutes of the session in which said Body approved the referred document, in electronic file format Pdf.

" Observation 7. Incorrect classification of investments in securities as availability. A cd file in PDF format is attached with the accounting manual with the modifications requested (sic) in this observation. "

Under these conditions, it is indisputable that Huejuquilla made an incorrect classification of investments in securities as availability, in contravention of what is provided in article 32 of the LRASCAP.

Thus, derived from the content of observations 1 to 5 and 7, which were made to said Society through the observation notice 134-2752/2015 of August 21, 2015; from the statements and documentation that in exercise of its right to be heard Huejuquilla presented before this Commission on January 8, 2016; from the corrective actions and measures dictated to said Entity through notice 134-102478/2016 of February 22, 2016; and from the statements and documentation that said Society sent to this Institution through writings dated March 31, 2016, this Decentralized Body concludes that due to causes attributable to said Society, the operations it carried out were not duly and timely registered in its accounting, thereby contravening what is provided in articles 31, fraction VII and 32 of the LRASCAP, as well as 41 of the Provisions, in addition to possibly placing it in the cause for revocation provided for in fraction VIII of article 84 of the LRASCAP, which is transcribed below:

... "

Regarding this matter, through a writing dated August 10, 2017, presented at the Common Registry Office of this Institution on the 18th of the same month and year, said Society, in exercise of the right to be heard granted to it through the summons notice 212/61888/2017, of June 13, 2017, stated the following:

" Based on the application of the corrective actions determined for the Cash by the last ordinary inspection visit carried out, the capitalization index had a very significant decrease, which put and puts Caja Solidaria Huejuquilla in a delicate financial situation, and despite the efforts and work carried out by the Board of Directors and the staff that works there, it was not possible to improve the capitalization index to desired levels, as a result of which, an audit and a consolidation study were carried out, and as a result of this, an orderly exit was seen as the best option, for which some cooperatives were contacted to try to agree on a transmission of assets and liabilities. After analyzing the proposals presented, the Board of Directors determined that the best option was the cooperative Caja SMG S.C. de A.P. de R.L. de C.V., which was informed to FOCOOP, and the Technical Committee gave its approval. With the above, on August 5, 2017, the extraordinary assembly was held, where the assembly approved that Caja Solidaria Huejuquilla will carry out the process of transmission of assets and liabilities and the minutes of said assembly are being reviewed and the agreement that will be signed between the cooperatives is being prepared. "

Seeing the foregoing, this Commission determines that the statements made by Huejuquilla in the writing of August 10, 2017, are ineffective in that they are not oriented to discredit the causes for revocation for which said Society was summoned; namely: i) failing to meet the Capitalization Level for credit and market risk is lower than required, in terms of what is provided in articles 49, 50 and 51 of the Provisions, in relation to what is established in article 31, fraction VI, of the LRASCAP; ii) carrying out operations in contravention of what is provided in articles 19 of the LRASCAP, as well as 10 and 17, of the Provisions, despite the observations issued by this Commission; iii) repeatedly executing operations other than those permitted in the applicable regulations; and iii) that due to causes attributable to said Entity, the operations it carried out do not appear duly and timely registered in its accounting.

In effect, said Society far from emitting any consideration tending to disprove the updating of the causes for revocation in which it was allegedly located, limited itself to stating that " it carried out an audit and a consolidation study, and as a result of this, an orderly exit was seen as the best option, for which some cooperatives were contacted to try to agree on a transmission of assets and liabilities. After analyzing the proposals presented, the Board of Directors determined that the best option was the cooperative Caja SMG S.C. de A.P. de R.L. de C.V., which was informed to FOCOOP, and the Technical Committee gave its approval " , a situation that, far from discrediting said causes, confirms that Huejuquilla incurred in them.

This is confirmed by the fact that said Entity in the writing of August 10, 2017, expressly states that its " capitalization index had a very significant decrease, which put and puts Caja Solidaria Huejuquilla in a delicate financial situation, and despite the efforts and work carried out by the Board of Directors and the staff that works there, it was not possible to improve the capitalization index to desired levels " ; that is, Huejuquilla recognizes that its capitalization index decreased significantly, that it could not improve it, as well as that its financial situation is delicate, which is taken as an express confession on its part that confirms the fact that said Entity did not comply with the capitalization requirements established in accordance with what is provided in articles 31, fraction VI, of the LRASCA and 49, 50 and 51 of the Provisions and, consequently, that the cause for revocation established in fraction III of article 84 of the LRASCAP is updated.

Furthermore, it is noted that Huejuquilla did not accompany its writing of August 10, 2017, with any element of conviction by virtue of which it accredited that the causes for revocation for which said society was summoned were not updated, nor by virtue of which it demonstrated the truth of its assertions.

Finally, it is worth noting that said Society does not emit any consideration by virtue of which it refers to having carried out any action tending to regularize its financial situation, but on the contrary, states that " despite the efforts and work carried out by the Board of Directors and the staff that works there, it was not possible to improve the capitalization index to desired levels " , which concatenated with the fact that it affirms that " an orderly exit was seen as the best option " , leads to the conclusion that said Society will not be in a position to comply with the established capitalization levels in accordance with what is provided in articles 31, fraction VI, of the LRASCA and 49, 50 and 51 of the Provisions.

On the other hand, it should be clarified that in compliance with what is provided in the first paragraph of article 84 of the LRASCAP, this Commission, through notice 212/61909/2017, indicated in numeral VIII of the chapter of antecedents of this resolution, requested from the Auxiliary Supervision Committee, an opinion regarding the possible updating of the causes for revocation of the authorization to operate as a savings and loan cooperative society, which was granted to Huejuquilla, to which, by writing of August 24, 2017, referred to in numeral X of the section of antecedents of this resolution, the President of the Auxiliary Supervision Committee of the Trust of the Auxiliary Supervision Fund of Savings and Loan Cooperative Societies and Protection of their Savers, through an opinion report, stated that " ... in the Opinion of the Auxiliary Supervision Committee of the Protection Fund, due to the evident deterioration in its financial situation described above, Caja Solidaria Huejuquilla, S.C. de A.P. de R.L. de C.V., lacks viability to continue operating, so in accordance with the LRASCAP in its Article 84 fractions III, VI, VII and VIII, it is appropriate to declare the revocation of the authorization to Caja Solidaria Huejuquilla, S.C. de A.P. de R.L. de C.V., to operate as a Savings and Loan Cooperative Society " , which constitutes another element that allows concluding the updating of the causes for revocation for which said Society was summoned.

Finally, it is not unnoticed by this Commission that Huejiquilla through a writing of October 30, 2017 (referred to in numeral XII of the section of Antecedents of this resolution), sent a copy of deed 24,772, of August 25, 2017, corresponding to the celebration of the extraordinary assembly of the 5th of the same month and year, from whose reading it is evident that it was inscribed in the Public Registry of Commerce on September 4, 2017 and registered with electronic commercial folio 176, and from which it is derived that said Entity agreed on the transmission of assets and liabilities of said Society to Caja SMG S.C. de A.P. de R.L. de C.V. (as it told it in its writing of August 10, 2017), however, this situation in no way disproves the causes for revocation for which it was summoned, so, if applicable, said transmission will be the subject of the dissolution and liquidation process that said Society will be subject to.

Attentive to what is exposed in the legal consideration, this Commission determines that, based on the information and documentation on file at this Commission, obtained in the exercise of its inspection and surveillance functions, the causes for revocation for which said Society was summoned are updated, which is confirmed by the fact that said Entity in exercise of the right to be heard granted to it through summons notice 121/61888/2017 of July 13, 2017, not only did not emit any consideration tending to disprove said causes and much less provided an element of conviction by virtue of which to discredit them, but also expressly stated that " despite the efforts and work carried out by the Board of Directors and the staff that works there, it was not possible to improve the capitalization index to desired levels " , added to the fact that the Auxiliary Supervision Committee of the Auxiliary Supervision Fund of Savings and Loan Cooperative Societies and Protection of their Savers, through a writing of August 24, 2017, issued an opinion stating that " due to the evident deterioration in its financial situation described above, Caja Solidaria Huejuquilla, S.C. de A.P. de R.L. de C.V., lacks viability to continue operating, so in accordance with the LRASCAP in its Article 84 fractions III, VI, VII and VIII, it is appropriate to declare the revocation of the authorization to Caja Solidaria Huejuquilla, S.C. de A.P. de R.L. de C.V., to operate as a Savings and Loan Cooperative Society " .

Under the aforementioned conditions, it is concluded that Huejuquilla is located in the causes for revocation provided for in fractions III, VI, VII and VIII of article 84 of the LRASCAP, which for quick reference are referred to below:

...

III .
If it does not comply with the capitalization requirements established in accordance with what is provided by Article 31, fraction VI, and the provisions to which said precept refers.

...

VI .
If it carries out operations in contravention of what is provided by this Law, the General Law of Cooperative Societies or by the provisions emanating from it, or if it abandons or suspends its activities.

VII .
If repeatedly, despite the observations of the Commission, the Savings and Loan Cooperative Society executes operations other than those permitted, does not adjust to the general character provisions applicable or puts in danger with its administration the interests of its Members, or of its social object, in accordance with what is provided by this Law and the General Law of Cooperative Societies.

VIII .
When due to causes attributable to the Savings and Loan Cooperative Society, the operations it has carried out do not appear duly and timely registered in its accounting.

... "

Based on the foregoing, the National Banking and Securities Commission, prior agreement of its Government Board, taken in its ordinary session, held on March 15, 2018, and with the object of preserving the stability of the financial system as a whole, safeguarding the interests of the public:

RESOLVES

FIRST. This Decentralized Body, based on what is provided in articles 84, first paragraph, fractions III, VI, VII and VIII, of the LRASCAP and 12, fraction V, of the LCNBV; as well as in accordance with the Twenty-Fourth Agreement, adopted by the Government Board of said Commission in its ordinary session, held on March 15, 2018, and to the considerations that were exposed in this Resolution, revokes the authorization to operate as a savings and loan cooperative society, granted to Caja Solidaria Huejuquilla, S.C. de A.P. de R.L. de C.V., through notice 311-30933/2008 and 134- 21673/2008.

SECOND. From the date of notification of this resolution, Caja Solidaria Huejuquilla, S.C. de A.P. de R.L. de C.V., is unable to carry out operations and will be placed in a state of dissolution and liquidation, in accordance with what is provided in article 84, penultimate paragraph, of the LRASCAP.

THIRD. Based on what is provided in articles 84, last paragraph, of the LRASCAP and 19 of the LCNBV, Caja Solidaria Huejuquilla, S.C. de A.P. de R.L. de C.V. must accredit before this Commission, within the term of 60 business days following the publication of this resolution in the Official Journal of the Federation, the designation of the corresponding liquidator.

FOURTH. Based on what is provided in article 84, second paragraph, of the LRASCAP, inscribe this notice in the corresponding Public Registry of Commerce, as well as publish it in the Official Journal of the Federation and in 2 newspapers of wide circulation in the geographic area where said Society operated.

FIFTH. Based on what is established in the antepenultimate paragraph of article 16 of the LCNBV, in articles 4, fractions I, section B and II, section B, subsection 26), 9 and 12 of the Internal Regulations of the National Banking and Securities Commission, published in the Official Journal of the Federation on November 12, 2014; as well as 51 of the Agreement by which the President of the National Banking and Securities Commission delegates Powers to the Vice Presidents, General Directors and Assistant General Directors of said Commission, published in the Official Journal of the Federation of November 30, 2015, updated with the reforms published in said Journal on December 14, 2016, and in terms of what is ordered in the Twenty-Seventh Agreement, adopted by the Government Board of said Commission in its ordinary session, held on March 15, 2018, it is delegated indistinctly to the public servants of this Commission, Karla Patricia Montoya Gutiérrez, María Isabel Almaráz Guzmán, Josué Martínez Rocha, Mariana Vázquez Bracho García, Ivonne Marcela López Franco, Melissa Fernanda Portillo Valdepeña, José Luis García González, Ángel Jonathan García Romo, Manuel Erwin Vásquez Rafael, Alberto Erick Méndez Medina, Juan Carlos Macías Luna, Luis Antonio Rodríguez Rodríguez, José Alberto Jiménez Rosales, Rogelio García Martínez, Rosa Cristina Avalos Gutiérrez, David Rodrigo Mejía Ríos, Lourdes Andrea Chavero Gaitan, Cesar Javier Jiménez Ramírez, José Luis Moreno Martínez, Tania Patricia Morales Reyes, Mariana Cecilia Luna Rivera and Francisco Godínez Ayala, the charge of notifying, jointly or separately, this notice through which compliance with the agreement adopted by the Government Board of said Commission is given.

The foregoing is made known to you based on what is provided in articles 16, fraction VI, and penultimate paragraph, of the Law of the National Banking and Securities Commission and 12 of the Internal Regulations of the National Banking and Securities Commission, as well as in terms of the Twenty-Sixth Agreement, adopted by the Government Board of said Commission in its ordinary session held on March 15, 2018.

Thus, the President of the National Banking and Securities Commission provided for this and signed in substitution for the absence of the same, the Legal Vice President of the National Banking and Securities Commission, based on what is provided in articles 4, fraction I, section A, fraction II, section A, subsection 7), 12 and 54

of the Internal Regulations of the National Banking and Securities Commission.

Sincerely,

Mexico City, March 20, 2018. - The Vice President of Legal Affairs, Edgar Manuel Bonilla del Ángel.-

Signature.

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