Securities Market - Securities Intermediaries - Regulation of Operations via Global Accounts and Modifications Regarding Sending Account Statements to Investors

1
Montevideo, June 15, 2026
Ref: SECURITIES MARKET – SECURITIES INTERMEDIARIES - REGULATION OF OPERATIONS VIA GLOBAL ACCOUNTS AND MODIFICATIONS REGARDING SENDING ACCOUNT STATEMENTS TO INVESTORS.
The market is informed that the Financial Services Superintendence adopted Resolution SSF No. 2026-295 on May 11, 2026.
2023-50-1-01888
Diagonal Fabini 777 - C.P. 11100 - Tel.: (598 2) 1967 - Montevideo, Uruguay - www.bcu.gub.uy JUAN PEDRO CANTERA Superintendent of Financial Services CIRCULAR No. 2504

FINANCIAL SERVICES SUPERINTENDENCE – RESOLUTION FINANCIAL SERVICES SUPERINTENDENCE VIEWING: The initiative defined by the Financial Services Superintendence with the objective of regulating the operations carried out by securities intermediaries via global accounts.
RESULTING:
I) That the Financial Services Superintendence drafted a regulatory proposal for the regulation of global accounts, understood as those accounts opened with a financial institution in the name of the securities intermediary, in which funds or securities belonging to multiple clients are registered jointly, with these clients remaining as the final holders of the rights and obligations related to the assets deposited in such accounts. II) That the aforementioned proposal established the conditions and restrictions for the use of such accounts, among which it is highlighted that:

• negative balances corresponding to clients could not be maintained in global accounts;
• their use for operations that imply their functioning as margin accounts would not be admitted;
• client funds or securities could be deposited in global accounts opened at financial institutions, provided that such institutions, as well as the third-party custody activity, were subject to regulation and supervision in their country of origin.
  III) That the original proposal also provided that securities intermediaries could not maintain in global accounts opened on behalf of their clients funds or securities belonging to persons related to the intermediary.
  IV) That, likewise, regarding the responsibilities that securities intermediaries must assume in this matter, the proposal included: informing each client in advance and in writing about the characteristics and potential risks of operations via global accounts and obtaining their prior and express written consent; maintaining confidentiality regarding the identity of each client who is part of the global account; and having daily control and reconciliation mechanisms that allow for the correct allocation of movements, balances, and results. In all cases, the intermediary must ensure that each client has sufficient funds and securities for their operations, and the use of one client's assets to cover its own obligations or those of other clients is prohibited. RR-SSF-2026-295 Date: 11/05/2026 12:30:47 CIRCULAR No. 2504

V) That additionally, the original proposal incorporated modifications in the regulation governing the sending of account statements to the investor, among which it is highlighted:

• the obligation to identify global accounts when clients operate through them, with transactions carried out and the corresponding updated position for said accounts reflected in a consolidated manner;
• the direct responsibility of the intermediary for the delivery of said account statements (whose frequency becomes at least monthly) and the obligation to keep a record of their receipt;
• the carrying out of periodic controls to verify that the contact data registered in their systems are up to date and correspond effectively to the clients.
  VI) That likewise, the obligation was established to present annually to the Financial Services Superintendence a Special Internal Control Report issued by the external auditor, containing a detail of the main deficiencies identified regarding the procedures established for the delivery of account statements to the investor, the recommendations issued to overcome them, and the corrective measures to be adopted by the institution. VII) That finally, the proposal provided for the application of a fine to securities intermediaries who fail to comply with the operations carried out through global accounts or with any of the responsibilities linked to it. VIII) That the aforementioned regulatory proposal was put out for public consultation by supervised institutions and the general public on January 7, 2026, with a deadline to submit comments that initially expired on the 31st of that month. However, based on the numerous extension requests made by supervised entities and considering the high priority assigned by the Central Bank of Uruguay to the issuance of the regulation linked to operations via global accounts, it was resolved to grant an extension for the submission of comments until February 10 inclusive. IX) That comments were received from the following institutions: Association of Private Banks of Uruguay, Balanz Uruguay Stockbroker S.A., BCE&M Stockbroker Operators S.R.L., Montevideo Stock Exchange S.A., Bank of the Oriental Republic of Uruguay, Deloitte S.C., Ernst & Young Uy S.A.S., FENIX Trading Stockbroker Society S.A., Gastón Bengochea and Company Stockbroker S.A., Gletir Stockbroker S.A., Itaú Uruguay Bank S.A., KPMG Civil Society, Latin Securities S.A. Securities Agent, Latin Securities S.A. Stockbroker, Maiorano and Cia Stockbroker Society S.A., Max Capital S.A. Securities Agent, Nobilis Stockbroker S.A., Puente Stockbroker S.A., PricewaterhouseCoopers Ltda., Renmax Stockbroker S.A., Rodolfo Rebella Stockbroker S.R.L., Urraburu and Sons Stockbroker S.R.L., Víctor Paullier and Cia Stockbroker Society S.A. BIC and WealthMan Stockbroker S.A. X) That the main comments from the industry focused on the following aspects:
• non-admission of maintaining in global accounts funds or securities of persons related to the securities intermediary together with those of other clients;
• prohibition of global accounts as margin accounts;
• sending and record of receipt of monthly account statements;
• nature and scope of the special internal control report issued by the external auditor on procedures established for the delivery of account statements;
• information to be provided to clients regarding custodians in global accounts;
• treatment of negative balances for commissions in global accounts;
• method of obtaining client consent to operate in global accounts.
  CONSIDERING:
  I) That global accounts constitute a usual operational modality in the securities intermediation activity that, by its very nature, requires explicit regulation oriented towards guaranteeing adequate investor protection and preserving an orderly and transparent securities market. Such regulation is essential to mitigate the risks inherent to this type of account, which, if not properly managed, could cause significant harm to investors. II) That in this sense, Articles 8 and 9 of Law 18.627 of December 2, 2009 establish that the Financial Services Superintendence, within the scope of its competencies, will issue the norms to which securities markets and natural or legal persons intervening in them must adhere, specifically providing as an attribute of the Superintendence to issue norms aimed at fostering and preserving a competitive, orderly, and transparent securities market. III) That numeral 6 of Article 119 of Law No. 18.627 establishes as a serious offense, sanctionable even with the suspension or cancellation of activities, the use of funds or securities of principals to attend to the intermediary's own obligations or those of other principals, which highlights the need to establish specific regulatory safeguards in those operational modalities—such as global accounts—that, without adequate controls, could facilitate the occurrence of such conduct. RR-SSF-2026-295 Date: 11/05/2026 12:30:47 CIRCULAR No. 2504

IV) That furthermore, the issuance of specific regulation in this matter was deemed convenient, based on the analysis of situations and practices identified in the framework of the supervision tasks developed by this Financial Services Superintendence, as well as comparative experience at the international level. V) That, in particular, the study of current regulatory frameworks in other jurisdictions evidences that the use of global accounts constitutes an admitted practice, although subject to compliance with explicit requirements in matters of segregation and protection of client assets, identification of final holders, maintenance of adequate records, internal controls, as well as the carrying out of independent reviews through specific reports issued by external auditors, duties of information to the client, and the implementation of other prudential measures, such as leverage limits, collateral requirements, and margin call mechanisms, capital requirements, position closure mechanisms, and forced liquidations, with the objective of mitigating operational, legal, and conflict of interest risks, and ensuring adequate investor protection. VI) That the analysis of the comments received from the industry, as well as what is alluded to in the previous numerals, warranted the following modifications to the originally circulated proposal:

• The possibility is admitted that global accounts may maintain funds or securities of clients who qualify as persons related to the securities intermediary together with those of other clients, with the intermediary required to constitute, in such cases, an additional guarantee before the Central Bank of Uruguay, as well as reinforce internal controls and conflict of interest management policies. It is specified that financial intermediation institutions that carry out securities intermediation will be governed by what is provided in Book II of the Compilation of Norms of Regulation and Control of the Financial System (RNRCSF).
• An article is incorporated that allows the opening of global accounts exclusively for margin operations, establishing their definition and applicable conditions. Among them, it is provided that such accounts must be kept segregated from other global accounts used for other types of operations, have mechanisms that allow identifying at all times the collateral corresponding to each client and ensure that they maintain, at minimum, the individual collateral required by custodians. In case of insufficiency of said collateral and if it is not immediately replenished, the intermediary must proceed to the total or partial liquidation of the client's positions. Likewise, the use of these accounts requires the prior and express consent of the clients operating under this modality (as with other global accounts), as well as prior communication to this Superintendence.
• The possibility is admitted that the intermediary may inform about the characteristics and risks of global accounts, as well as obtain the prior and express consent of clients both in the contract signed between the parties or in a complementary document to it.
• The wording regarding information on global account custodians is clarified, establishing that clients must be informed, in general terms, about all financial institutions and jurisdictions in which the intermediary maintains custody of client funds or securities, without associating this information with a specific custodian for each client.
• In matters of delivery of account statements, the intermediary's obligation to keep a record of receipt by the client is replaced, expressly providing for the admitted modalities for their dispatch, both in physical and electronic format. Likewise, it is provided that, when the client is informed of an electronic link to the institutional website or application from which they can access said account statements, the intermediary must have control mechanisms that allow accrediting the client's access to this information. Additionally, a maximum deadline of 7 calendar days for the sending of monthly account statements is incorporated, and it is established that intermediaries must have mechanisms that allow verifying that the client receives at least one account statement in the last twelve months, which implies the adoption of alternative dispatch mechanisms when the initially defined modality does not allow accrediting this circumstance. Finally, the annual profitability corresponding to the account statements is incorporated into the information that intermediaries must send to clients.
• The nature of the report to be performed by the external auditor is redefined, establishing that it will consist of a report of agreed-upon procedures and recommendations, in substitution of the special report originally provided. Likewise, the scope of the work incorporates the review of operations carried out via global accounts.
• A specific sanction for non-compliance in the delivery of account statements to investors is incorporated into the sanctioning regime.
  VII) That the comments received from the industry provided elements that allowed improving the original proposal, corroborating the value that the consultation process has for the regulator.
  VIII) That although during the process of drafting the regulation on global accounts it had been determined that it was not necessary to modify the RNRCSF, insofar as Article 439 of said Compilation refers to Articles 208.10 to 213.1 of the Compilation of Norms of the Securities Market—which includes several of the aspects provided for in the present project—subsequent to the public consultation, the need to adapt certain requirements of the RNRCSF was identified, in order to incorporate the requirement of the report to be issued by the external auditor for financial intermediation institutions that carry out the activity of securities intermediation and the deadline for its submission. ATTENTIVE: To what is provided in Articles 37 and 38 of Law No. 16.696 of March 30, 1995 in the wording given by Articles 693 and 694 of Law No. 20.446 of December 16, 2025 and to Articles 7, 8, 9, and 119 of Law No. 18.627 of December 2, 2009. IT IS RESOLVED:

1. SUBSTITUTE in Chapter II – Equity, Guarantees, and Deposits, of Title II – Securities Intermediaries, of Book II – Stability and Solvency of the Compilation of Norms of the Securities Market, Article 149 with the following:
   ARTICLE 149 (GUARANTEES).
   Securities intermediaries must constitute and maintain, permanently, a guarantee in favor of the Central Bank of Uruguay for an amount not less than UI 2,000,000 (two million indexed units) for any obligations they might assume with said Bank or with third parties in the exercise of their activity as securities intermediaries. In the case that securities intermediaries carry out the activity of client portfolio management and the assets under management in said portfolio exceed the equivalent of UI 1,000,000,000 (one billion indexed units), they must constitute - for the excess to this amount - an additional guarantee equivalent to 0.05% (five ten-thousandths) of the managed portfolio. The assets under management in the portfolio management activity will be valued at their market value and measured at the close of each semester. The additional guarantee requirement for said activity, if applicable, will remain unchanged until the expiration of the deadline for the submission of the tax return referenced in literals b.3 and c.3 of Article 292. Likewise, when securities intermediaries maintain in any global account funds or securities corresponding to related persons, according to the definition established in Article 209.2, they must constitute an additional guarantee of UI 500,000 (five hundred thousand indexed units). The total guarantee to be constituted will not exceed the maximum amount equivalent to the Basic Equity Liability required for Banks. Such guarantees may consist of:
   a) Pledge on deposit denominated in indexed units, constituted at the Central Bank of Uruguay; b) Pledge on negotiable national public securities, denominated in indexed units, deposited at the Central Bank of Uruguay. For these purposes, the securities will be computed at their nominal value; c) Pledge on shares of stock exchanges authorized by the Financial Services Superintendence. For these purposes, the shares will be taken at the equivalent in indexed units of the value resulting from the balance sheet at the close of each fiscal year prepared in accordance with what is provided in Article 290, maintaining said value unchanged until the close of the following fiscal year. Intermediaries who opt for this alternative must constitute and maintain, permanently, an additional guarantee consisting of one of the options established in the preceding literals a) and b) that covers the difference with the corresponding guarantee. The selected guarantee modality or modalities cannot be substituted before the year of their constitution or eventual subsequent replacement. Furthermore, in case the constituted guarantee includes one or more negotiable national public securities, they cannot be substituted by other securities within a period of one year. The constituted guarantees will be maintained:

• until the year following the loss of the quality of securities intermediary at minimum, or while they maintain custody of client funds or securities in their name;
• until judicial actions filed against them are resolved by a final judgment.
  TRANSITIONAL PROVISION:
  Securities intermediaries who do not comply with the provisions of this article - communicated by Circular No. 2477 of 05/29/2025 - will have until March 31, 2027 inclusive to adapt to them.
  However, in cases where the constitution of the additional guarantee related to related persons in global accounts is required, it must be complied with before September 30, 2026.

2. INCORPORATE in Chapter IV - Services provided by securities intermediaries, investment advisors, and portfolio managers, of Title I - Client Relationship, of Book IV - Protection of the user of financial services of the Compilation of Norms of the Securities Market, the following articles:
   ARTICLE 209.2 (GLOBAL ACCOUNTS – DEFINITION AND CONDITIONS TO OPERATE - SECURITIES INTERMEDIARIES).
   Global accounts are considered those accounts opened with a financial institution in the name of the securities intermediary, in which funds or securities belonging to multiple clients are registered jointly, with these clients remaining as the final holders of the rights and obligations related to the assets deposited in such accounts. The acquisition or alienation of securities on behalf of clients may be carried out through global accounts, according to the following conditions:

• under no circumstances will the funds or securities of clients deposited in such accounts be admitted to be used, directly or indirectly, to back obligations derived from the intermediary's own operations or those of other clients;
• negative balances corresponding to clients may not be maintained.
• client funds or securities may be deposited in global accounts opened at local or foreign financial institutions, provided that such institutions, as well as the third-party custody activity, are subject to regulation and supervision in their country of origin.
  When in any global account funds or securities corresponding to clients who qualify as persons related to the securities intermediary are maintained, together with those of other clients of the institution, the intermediary must constitute an additional guarantee according to what is established in Article 149, as well as reinforce internal controls and conflict of interest management policies. Financial intermediation institutions will be governed by what is provided in Book II of the Compilation of Norms of Regulation and Control of the Financial System. For these purposes, persons related to the intermediary are considered:
• their partners, shareholders, or employees and natural or legal persons linked to it by:
  i. participation greater than 10% of the capital,
  ii. simultaneity or exchange of persons holding positions with authority and responsibility in planning, direction, and control activities,
  iii. family relationship by being the spouse or concubine, the children, or the children of the spouse or concubine, or the holding of these positions with authority and responsibility in planning, direction, and control activities.
• natural or legal persons that form their economic group, according to the definition established in Article 142.
  ARTICLE 209.3 (GLOBAL ACCOUNTS EXCLUSIVELY FOR MARGIN OPERATIONS).
  The opening of global accounts exclusively destined for the carrying out of operations that require their use as margin accounts will be admitted.
  RR-SSF-2026-295 Date: 11/05/2026 12:30:47
  CIRCULAR No. 2504

margin, understood as those that imply the constitution of guarantees to back operations with financial instruments.
These accounts must comply with the following conditions:

• remain clearly segregated from other global accounts used for other types of operations;
• be properly identified in the securities intermediary's internal records;
• have control and internal allocation mechanisms that allow the identification at all times of the guarantees corresponding to each client;
• ensure that each client maintains at all times, at a minimum, the individual guarantees required by the custodians in which the corresponding margin accounts are held. If such guarantees prove insufficient, the intermediary must require their immediate reconstruction. If not carried out, it must proceed to the total or partial liquidation of the client's positions, in order to prevent losses derived from the operations from exceeding the total guarantees constituted by said client.
  The provisions of Article 209.2 shall also apply to global accounts destined for margin operations.
  The use of these accounts requires the prior and express consent of clients in accordance with what is required in letter a. of Article 209.4.
  The carrying out of this operation requires prior communication to the Financial Services Superintendence, including in such communication the opening of the corresponding global account(s) and the description of the controls implemented to comply with the provisions of this article.

ARTICLE 209.4 (GLOBAL ACCOUNTS - RESPONSIBILITIES OF SECURITIES INTERMEDIARIES).
Securities intermediaries must comply with the obligations detailed below:
a. Inform clients in advance about the characteristics and potential risks associated with the use of global accounts, highlighting - when applicable - the risks associated with margin operations, and obtain their prior and express consent for carrying out operations through said accounts. The record that the client has been duly informed of such characteristics and risks, as well as their express consent, must be obtained in the contract signed between the parties, in a clear and prominent manner or in a complementary document to it, and be kept available to the Financial Services Superintendence.

b. Maintain confidentiality regarding the identity of each client before the other clients that make up the global account.
c. Have control and daily reconciliation mechanisms that ensure the correct attribution, imputation, and allocation of movements, balances, and results corresponding to each client. To this effect, the securities intermediary must ensure at all times that each client maintains sufficient funds and securities to cover the operations imputed to them in these accounts, with the use of funds or securities of one client to cover obligations of their own or of other clients being prohibited under any circumstances.

3. REPLACE in Chapter IV - Services provided by securities intermediaries, investment advisors, and portfolio managers, of Title I - Client Relations, of Book IV - Protection of the user of financial services of the Compilation of Norms of the Securities Market, Articles 210 and 212 with the following:

ARTICLE 210 (INFORMATION TO CLIENTS - SECURITIES INTERMEDIARIES).
Securities intermediaries must provide their clients with clear, sufficient, truthful, and timely information about the characteristics and risks of the products and services requested by their clients and offered by the intermediaries, in such a way as to allow them to make informed decisions. Under no circumstances shall significant informative elements be hidden nor inaccurate references or expressions susceptible of generating error, deception, or confusion in clients regarding any characteristic of the contracted products and services be used. Intermediaries must make available to clients the certificate of the Stock Exchange that qualifies them as such, when applicable, as well as the Registration Communication in the Securities Market Register issued by the Financial Services Superintendence. Likewise, they must provide investors who are part of their client portfolio with at least:
a. The specification of costs that the investor will incur in the different types of operations offered, indicating the concept (charges, expenses, commissions, fees, and other applicable amounts), amount, billing periodicity, and whether each is mandatory or optional.
If any of the above items could change, the conditions for modification and the means and deadline to be used for prior notice to the client must be indicated.
In the case of trading securities from the own portfolio, the client must be informed of the price differential applied in relation to the market price of the instrument. This differential may be expressed in absolute or percentage terms.

b. Receipts of any operation carried out on behalf and order of the client within or outside a stock exchange or other securities trading market, which must be issued upon the mere request of the client.
c. Regarding locally issued public offering securities: the issuance prospectus or, in its absence, a summary of the terms and conditions of the issuance and an indication of where the prospectus can be obtained, and any other relevant information subsequent to the issuance, particularly regarding potential modifications to the original terms and conditions of the issuance, as well as modifications in the risk rating of the securities, if applicable.
d. Regarding locally issued private offering securities:

• issuance prospectus, if it exists, or in its absence, the terms and conditions of the issuance, including identification and domicile of the issuer, the applicable jurisdiction in case of dispute, and the record required by Article 2 of this Compilation.
• issuer's financial statements or indication of where the client can consult them, in case the issuer has made them public, indicating whether they are audited or not by a firm of recognized prestige.
• risk rating report of the security or, in its absence, of the issuer.
  In case neither the security nor the issuer is rated, the investor must be informed of this.
• information available in the Credit Risks Central of the Central Bank of Uruguay regarding the issuer, or inform the user that there is no information about the issuer in the referred Credit Risks Central.
• registering entity, in the case of book-entry securities.
• guarantees offered by issuers and the depositary entity of the documents constituting said guarantees, if they exist.
• any other relevant information subsequent to the issuance.
• in the case of financial trusts: that the trust contract has been registered with the General Directorate of Registers of the Ministry of Education and Culture (Article 6 of Law No. 17.703 of October 27, 2003) and that it has the record from the Central Bank of Uruguay that it is a private offering trust in accordance with the provisions of Article 108.
  e. Regarding public or private offering securities issued abroad:
• summary of the terms and conditions of the issuance and - in case an issuance prospectus exists - the indication that it is available to them.
• place of incorporation of the institution issuing the instrument, indicating that it is governed and controlled by authorities of that country and not by the Central Bank of Uruguay.
• risk rating of the security, expressed in an international scale, indicating the rating agency; if no such rating exists, the investor must be warned about such situation and, in the case of debt securities, provide as a reference element the rating of the issuer or the country in which it is located, specifying the scope of said rating.
• guarantees offered by issuers.
• any other relevant information subsequent to the issuance.
  f. Regarding foreign financial institutions to which they refer their clients:
• risk rating of the institution to which reference is made, or in its absence, that of the controlling shareholder, expressed in an international scale, indicating the rating agency.
• type of relationship that exists between the local institution and that to which reference is made.
• place of incorporation of the institution to which reference is made, indicating that it is governed and controlled by authorities of that country and not by the Central Bank of Uruguay.
• applicable jurisdiction for the resolution of differences.
• indication that the information the client receives, the sending of account statements, and other elements of their relationship with the referenced institution, will be governed by foreign laws and not by Uruguayan laws.
  g. Regarding global accounts opened in financial institutions in the name of the intermediary:
• name of the financial institutions in which client funds are deposited or securities are custodied, specifying the jurisdiction to which they belong;
• in the case of foreign financial institutions: regulatory bodies of their country of origin;
• risk rating granted to the custodial entity, if it has one, or express indication of its non-existence.
  Securities intermediaries must also implement mechanisms and procedures that allow verifying that the information detailed in the preceding letters was effectively provided to each client.
  In the case of portfolio management activities and execution of orders without prior advice, the minimum information required in letters c., d., and e. will be provided if the client requests it.
  It will not be necessary to provide the minimum information mentioned above when the client is another financial institution.

ARTICLE 212 (DELIVERY OF ACCOUNT STATEMENTS TO THE INVESTOR - SECURITIES INTERMEDIARIES).
Securities intermediaries must provide clients, through account statements, information related to all operations carried out, specifying all associated costs – including price differentials – as well as cash and securities positions and the annual profitability obtained.
Additionally, when clients operate through global accounts, the transactions carried out must be itemized and the updated position of said accounts must be reflected, in a consolidated manner for each client.
Securities intermediaries must send account statements to clients, being directly responsible for their delivery. To this effect, said account statements must be provided to the client in at least one of the following forms:

• In physical format sent to their home, with or without cost to the client.
• In electronic format at no cost to the client, either by sending it to their email address or by informing them of the electronic link to the institutional website or application from which they can access it. In the latter case, the securities intermediary must have control mechanisms that allow accrediting the client's access to said information.
  The method of delivery of account statements must be defined by the client in an express manner, as well as its periodicity, which must be at least monthly.
  The securities intermediary will have a maximum deadline of 7 (seven) calendar days counted from the date of closure of the corresponding period to send the account statement. To this effect, they must carry out periodic controls to verify that the contact data registered in their systems are up to date and actually correspond to the clients, as well as have mechanisms that allow verifying that the client has received at least one account statement in the last twelve months. Notwithstanding the foregoing, the intermediary must provide the investor who expressly requests it with information on the status of their account at any time.

4. REPLACE in Chapter II – Accounting and Financial Statements, of Title II – Information Regime, of Part V – Securities Intermediaries, of Book VI – Information and Documentation of the Compilation of Norms of the Securities Market, Article 292 with the following:

ARTICLE 292 (ACCOUNTING AND MANAGEMENT INFORMATION).
Securities intermediaries must present the following information:
. Within the deadline of 4 (four) months counted from the end of each fiscal year:
a.1 Authenticated copy of the Annual Report prepared by the Board of Directors or administrative body of the company on the management of the business affairs and performance in the last period, in accordance with the minimum content established in Article 92 of Law No. 16.060 of September 4, 1989, duly signed. a.2 Original duly signed or authenticated copy of the Syndic Report or oversight body report, if such body exists. a.3 Authenticated copy of the Minutes of the Shareholders or Stockholders Meeting approving the Financial Statements, duly signed. a.4 Report of agreed procedures and recommendations, issued by external auditor, regarding the operations carried out by the securities intermediary through global accounts and the procedures implemented for the delivery of account statements to investors, in accordance with the instructions that will be issued. . Within the deadline of 3 (three) months, counted from the end of each fiscal year:
b.1 Annual consolidated Financial Statements of the group to which the intermediary belongs, accompanied by External Audit Report, duly signed.
In cases where consolidation does not apply, a sworn declaration indicating the reasons why the intermediary does not prepare consolidated Financial Statements must be presented. b.2 Annual individual Financial Statements, accompanied by External Audit Report, duly signed. b.3 Sworn declaration indicating the market value of assets under management at the end of the fiscal year, in case they develop portfolio management activities. . Within the deadline of 2 (two) months, counted from the end of the first semester of each fiscal year:
c.1 Consolidated semi-annual Financial Statements of the group to which the intermediary belongs, accompanied by Limited Review Report, duly signed.
In cases where consolidation does not apply, a sworn declaration indicating the reasons why the intermediary does not prepare consolidated Financial Statements must be presented. c.2 Individual semi-annual Financial Statements, accompanied by Limited Review Report, duly signed. c.3 Sworn declaration indicating the market value of assets under management at the end of the semester, in case they develop portfolio management activities. . Within the deadline of 1 (one) month, counted from the end of the first and third quarters of each fiscal year:
d.1 Consolidated quarterly Financial Statements of the group to which the intermediary belongs, accompanied by Compilation Report.
In cases where consolidation does not apply, a sworn declaration indicating the reasons why the intermediary does not prepare consolidated Financial Statements must be presented. d.2 Individual quarterly Financial Statements, accompanied by Compilation Report.
The Audit and Limited Review reports, as well as the report referred to in letter a.4, must be signed by a professional or firm of professionals registered in the Register of Auditors of the Central Bank of Uruguay.
The omission of the timely and proper presentation of the information will give rise to the application of the daily fine established in Article 358.
The verification of errors in the presented information will also give rise to the application of said daily fine, from the moment of its notification.
TRANSITIONAL PROVISION:
The presentation of the first report referred to in letter a.4 will be required with reference to the fiscal year closed on 12/31/2026.

5. INCORPORATE in Title V - Securities Intermediaries - Other Sanctions, of Book VII – Sanctioning and Procedural Regime of the Compilation of Norms of the Securities Market, the following articles:

ARTICLE 381.3 (NON-COMPLIANCE IN OPERATIONS WITH GLOBAL ACCOUNTS).
Securities intermediaries that fail to meet the requirements for operations with global accounts in accordance with the provisions of Articles 209.2 and 209.3 or with any of the responsibilities established in Article 209.4 will be sanctioned with a fine equivalent to 100 (one hundred) times that established in Article 357.

ARTICLE 381.4 (NON-COMPLIANCE IN DELIVERY OF ACCOUNT STATEMENTS TO THE INVESTOR).
Securities intermediaries that fail to comply with the provisions of Article 212 regarding account statements will be sanctioned with a fine equivalent to 10 (ten) times that established in Article 357.

6. REPLACE in Chapter II - External Auditors, of Title II – Information Regime, of Part I – Financial Intermediation Institutions, of Book VI – Information and documentation of the Compilation of Norms of Regulation and Control of the Financial System, Articles 521, 524, and 526 with the following:

ARTICLE 521 (EXTERNAL AUDITORS' REPORT - BANKS, INVESTMENT BANKS, FINANCIAL HOUSES, AND FINANCIAL INTERMEDIATION COOPERATIVES).
Institutions must present, in accordance with the instructions issued by the Financial Services Superintendence, the following reports issued by external auditors:
a) Opinion on the individual financial statements, notes, and annexes at the end of the annual fiscal year and whether such statements have been prepared in accordance with the accounting standards established by the Financial Services Superintendence. If not, the criteria used and the consequences derived from their application must be specified. b) Triennial report on the comprehensive evaluation of the adequate functioning of the integrated risk management system in accordance with the approach given by Article 130 and annual reports on materially significant deficiencies or omissions detected, recommendations issued to overcome them, and corrective measures adopted by the institution. c) Annual report on the accounting system used and its adequacy to the accounting standards established by the Financial Services Superintendence and on the concordance of the statements and other information delivered to said Superintendence with said accounting system. d) Report on the results of the credit risk classification corresponding to June 30 and December 31 of each year, with an opinion on the quantification of provisions constituted to cover said risks. e) Report on the credits granted during the annual fiscal year to the firms and companies referred to in Article 210. Likewise, they must inform on the due compliance with the provisions of Article 18, subsection c, of Decree-Law No. 15.322 of September 17, 1982. f) Annual report on the existence of other opinions issued - during the period between May 1 and April 30 of the following year - regarding the matters mentioned in other letters of this article. In case such opinions do not agree with those supplied to the Central Bank of Uruguay, it will also be necessary to specify their content, destination, and the reason for the difference. g) Opinion on the consolidated financial statements, notes, and annexes at the end of the annual fiscal year and whether such statements have been prepared in accordance with the accounting standards established by the Financial Services Superintendence. If not, the criteria used and the consequences derived from their application must be specified. h) Annual evaluation report in which an opinion is issued regarding the suitability and functioning of the policies, procedures, and control mechanisms referred to in Article 290, adopted by the institution to prevent being used for money laundering, terrorist financing, and financing of the proliferation of weapons of mass destruction. Materially significant deficiencies or omissions detected, recommendations issued to overcome them, and corrective measures adopted by the institution must be indicated. i) Report of agreed procedures and recommendations, regarding the operations carried out by institutions that perform securities intermediation through global accounts and the procedures implemented for the delivery of account statements to investors. TRANSITIONAL PROVISION:
The presentation of the first report referred to in letter i) will be required with reference to the fiscal year closed on 12/31/2026.

ARTICLE 524 (OTHER EXTERNAL AUDITORS' REPORTS).
Banks, investment banks, financial houses, foreign financial institutions, financial intermediation cooperatives, and advance savings group administrators must present to the Financial Services Superintendence, within ten business days following the date of their issuance, a copy of any other opinion that external auditors might issue regarding the matters referred to in letters a) to e) and g) to i) of Article 521. To this effect, external auditor is understood as anyone who performs an audit examination regarding the institution, even if they have not been contracted by it and are independent with respect to it and to the shareholders who directly or indirectly exercise its control.

ARTICLE 526 (PLACE AND DEADLINE FOR PRESENTATION).
The external auditors' reports referred to in Article 521 will be delivered to the Financial Services Superintendence, within the following deadlines:

• Sections a), c), e), and g): March 31 of the year following the year to which they refer.
• Section b): Triennial report: May 31 of the year following the year to which it refers.
• Section b): Partial annual report: April 30 of the year following the year to which it refers.
• Section d): March 31 and August 31 following the date to which they refer.
• Section f): May 31 of each year.
• Section h): April 30 of the year following the year to which it refers.
• Section i): April 30 of the year following the year to which it refers.

7. TRANSITORY PROVISION: Institutions shall have a period of 180 (one hundred eighty) days to comply with the provisions contained in this resolution, unless a different period is established in the article itself.

8. COMMUNICATE the provisions set forth in the preceding sections via Circular.

JUAN PEDRO CANTERA
Superintendent of Financial Services
RR-SSF-2026-295 Date: 11/05/2026 12:30:47
Exp. 2023-50-1-01888
Publishable: Yes - Signatory: JUAN PEDRO CANTERA SENCIÓN CIRCULAR NO. 2504