Superintendent Resolution No. 108-2025-SMV/02 — SMV — PE

PERÚ Ministry of Economy and Finance

SMV
Securities Market
Superintendency
Electronically signed document in the framework of Law No. 27269, Law of Digital Signatures and Certificates, its regulations and amendments. The integrity of the document and authorship Superintendent Resolution No. 108-2025-SMV/02 Lima, September 10, 2025 The Superintendent of the Securities Market SEEN:
The file No. 2025016751 which contains, among others, the appeal filed by Mrs. Claudia María Amelia Teresa Cooper Fort against the Superintendent Adjunct Resolution SMV No. 040-2025-SMV/10, Report No. 1258-2025-SMV/06, issued by the Legal Advisory Office, and after hearing the oral report from the appellant; CONSIDERING:

That, by Superintendent Adjunct Resolution SMV No. 040-2025-SMV/10 of July 10, 2025 (hereinafter, SANCTION RESOLUTION), the Superintendent Adjunct of Prudential Supervision (SASP) resolved to sanction Mrs. Claudia María Amelia Cooper Fort (hereinafter, MRS. COOPER) with a reprimand for having committed one (01) very serious infringement typified in Annex I, numeral 1, subsection 1.1, of the Sanctions Regulation, approved by SMV Resolution No. 035-2018-SMV/01 and its amendments (hereinafter, SANCTIONS REGULATION), for having infringed what is established in Article 12, letter d), and Article 156 of the Unified Text of the Law of the Securities Market, approved by Supreme Decree No. 020-2023-EF (hereinafter, LMV), by carrying out sales operations of securities or financial instruments, registered in the Public Registry of the Securities Market – RPMV, without prior authorization from the Securities Market Superintendency – SMV and, consequently, having carried out unauthorized operations or activities;

1 «ANNEX I
Of General Infractions
Common infractions to Participants and liquidators, as applicable:
1.- Very Serious
1.1 To carry out functions, operations, activities, acts or contracts, not authorized or that do not meet the requirements established in the regulations».
«Article 12.- Market Transparency.- Any act, omission, practice or conduct that attacks the integrity or transparency of the market is prohibited, such as:
(...) d) That directors, officials and workers of stock exchanges and other entities responsible for the management of centralized mechanisms, clearing and settlement institutions, including the floor director, acquire or transfer securities or financial instruments registered in the Registry, unless they obtain prior authorization from the SMV. (...)» «Article 156.- Prohibition.- Members of the Board of Directors or Directorate, as applicable, may not acquire or dispose of securities registered or traded on the respective Stock Exchange for valuable consideration, unless they have previously obtained the written authorization of the SMV. This prohibition does not apply to operations referring to securities that come from the condition of user of a public service»

PERÚ Ministry of Economy and Finance

SMV
Securities Market
Superintendency
Electronically signed document in the framework of Law No. 27269, Law of Digital Signatures and Certificates, its regulations and amendments. The integrity of the document and authorship
2. That, on August 4, 2025, MRS. COOPER filed an appeal against the SANCTION RESOLUTION, in order for it to be fully revoked and for it to be declared that she did not commit a sanctionable infringement, or for the nullity of said resolution to be declared, based on the arguments exposed in said administrative appeal. Likewise, pursuant to what is provided in Article 18 of the SANCTIONS REGULATION, she requested that she be granted the right to speak, in order to expose the grounds of her appeal, which was granted by Letter No. 4447-2025-SMV/14;
3. That, by writing dated August 27, 2025, MRS. COOPER requested the postponement of the hearing to August 28, 2025, which was granted by Letter No. 4562-2025-SMV/14. Thus, on that latter date, the use of the word by MRS. COOPER before the Superintendent of the Securities Market(e) took place, as recorded in the minutes contained in the file referenced;
I. ARGUMENTS OF MRS. CLAUDIA COOPER
4. That, within the framework of the appeal, MRS. COOPER has requested the revocation or total nullity of the SANCTION RESOLUTION, based on the following arguments:
(i) She alleges that the prohibition established in Article 12, letter d), of the LMV, in concordance with Article 156 of said Law, has as its objective to prevent market abuse practices, avoiding that those people who by their function may have access to information that has not been revealed to the market use it for their own benefit or that of third parties. Nevertheless, she questions that the SMV intends to apply said provision under an absolute presumption, since, she considers that not every member of the board of a stock exchange has access to privileged information on securities and/or issuers. Thus, she affirms that in her case, the operations were carried out without her having privileged information that could have been used for her own benefit; (ii) She states that the operations subject to sanction were carried out on April 23, 2021, when she was in the United States undergoing treatment to obtain the vaccine against the pandemic by COVID-19, as evidenced by her migratory report which she attaches to her appeal; and, after a communication from Credicorp Capital Brokerage Company S.A. (hereinafter, CREDICORP CAPITAL SAB), within a span of three minutes, she decided to sell the securities, accepting an unfavorable price as is recognized in consideration 74 of the SANCTION RESOLUTION. She explains that her only purpose was to protect her assets in a context of capital flight and fall in market indicators; and, therefore, she denies the existence of any risk of market abuse; (iii) She invokes the principle of presumption of innocence, arguing that no operation of acquiring or transferring securities can be considered an infringement of Article 12, letter d), of the LMV, unless there is misuse of privileged information and undue benefit, which has not occurred in the present case. Likewise, she emphasizes that the SMV has not proven the existence of any undue advantage, for herself or for third parties, derived from the use of non-public information; (iv) She maintains that in the SANCTION RESOLUTION it is recognized that there was no intent, but in its considerations 52 and 54 she is attributed with objective liability, for having committed an infringement by fault, that is, by the production of an unlawful result, duly typified, completely foreseeable and avoidable; (v) Regarding this, she indicates that Article 230 of Law No. 27444, General Administrative Procedure Law (hereinafter, LPAG) establishes subjective liability as the rule, and that objective liability only proceeds when it is expressly provided for by law or legislative decree. Consequently, she considers that, by establishing this requirement, objective liability becomes an exceptional figure, being the rule in sanctioning matters subjective liability; She adds that Article 230 of said legal body contemplates the principle of typicity, which prohibits analogy or extensive interpretation. Therefore, she considers that it is not accepted to apply objective liability by
analogy or by extensive interpretation as the SMV intends to apply in the present case; (vi) In support of what was stated in the preceding numeral, she cites the ruling of the Plenary 201/2022 of the Constitutional Court that proscribes objective liability without legal authorization, administrative doctrine, as well as laws and legislative decrets applicable from other public entities where the objective liability of the administered is expressly established. In that scenario, she states that Article 12 of the LMV does not expressly establish objective liability, so having analyzed the element of fault in the operations carried out in the SANCTION RESOLUTION, she considers that it has been demonstrated that she has not committed a sanctionable infringement, so it corresponds that said resolution be revoked; (vii) She alleges that in consideration 57 of the SANCTION RESOLUTION, the transcription of what was stated in her writing dated April 28, 2021, was incorrectly made, since, in said consideration it transcribes «(...) although, voluntarily I omitted to request prior authorization from the SMV to carry out the Transaction»; however, it should say «(...) although, involuntarily I omitted to request prior authorization from the SMV to carry out the Transaction». In her judgment, she considers that by totally modifying the meaning of her communication, an improper motivation has been committed that vitiates the SANCTION RESOLUTION with nullity; (viii) She alleges that in the SANCTION RESOLUTION it is maintained that voluntary remediation implies that the immediate restoration of the state prior to the act subject to sanction is generated, that is, in the present case, it would suppose that the sale of the securities remains without effect and return to the assets of the appellant; (ix) Regarding this matter, she considers that voluntary remediation does not have the effect of retroverting to the stage prior to the commission of a supposed infringement but rather to eliminate the element that constitutes the infringement. In this sense, she indicates that Article 236-A, letter f), of the LPAG establishes the characteristics of voluntary remediation, which must be applicable transversally to all special procedures; (x) She states that, in the present case, the remediation was of a voluntary nature, before the formulation of charges and had as its object to reverse the non-compliance of

3 In the appeal, reference is made to the Unified Text of Law No. 27444, General Administrative Procedure Law, approved by Supreme Decree No. 004-2019-JUS.

PERÚ Ministry of Economy and Finance

SMV
Securities Market
Superintendency
Electronically signed document in the framework of Law No. 27269, Law of Digital Signatures and Certificates, its regulations and amendments. The integrity of the document and authorship requesting from the SMV the respective authorization; furthermore, she indicates that there has been no damage to the integrity or transparency of the market, as has been explained in the SANCTION RESOLUTION, therefore, she estimates that it was perfectly possible to remedy the omission; (xi) She mentions that the SANCTIONS REGULATION violates the hierarchy of laws and denies any possibility of voluntary remediation, attacking the principle of legality by contravening and denaturing what is regulated by the LPAG with respect to the application of the exemption of liability for voluntary remediation of the infringement, since, it is establishing less favorable conditions for the administered than those recognized by said Law. Consequently, she considers that that part of the SANCTIONS REGULATION is legally inapplicable, for attempting to modify the LPAG, via regulatory norm. Additionally, she considers that additional requirements are being established for the application of said exemption, such as determining which infringements are not susceptible to remediation; and, (xii) In addition to this, she points out that in the SANCTION RESOLUTION (consideration 58), the nature of the remediation is being confused with the reversal to the previous state of non-compliance and, as the resolution itself recognizes, a fact that is materially impossible is required as a condition;
5. That, in the use of the word carried out on August 28, 2025, MRS. COOPER has reiterated the arguments sustained in the appeal; and, formulated as a new argument that the situation provided for in letter d) of Article 28 of the SANCTIONS REGULATION does not fit the type of infringement imposed, since, in the present case, it is not about «unauthorized activities» but of operations that she carried out without the prior authorization of the SMV;
II. EVALUATION OF THE APPEAL
2.1. Formal requirements of the appeal
6. That, pursuant to what is provided in numeral 109.1 of Article 109 of the LPAG, against an «act that implies that it violates, affects, disregards or harms a right or a legitimate interest, its contradiction in the administrative route proceeds in the form provided for in this Law, so that it is revoked, modified, annulled or its effects are suspended»;
7. That, regarding this, Article 207 of the LPAG provides that administrative appeals are of reconsideration and appeal; and that their filing must be made within a peremptory period of fifteen (15) days. Complementarily, subsection 134.1 of Article 134 of the LPAG 4 provides that when the period is indicated by days, it will be understood as consecutive business days, excluding from the calculation those non-working days of the service, and the non-working holidays of national

4 «Article 134.- Passage of the period
134.1 When the period is indicated by days, it will be understood as consecutive business days, excluding from the calculation those non-working days of the service, and the non-working holidays of national or regional order.
(...)»

PERÚ Ministry of Economy and Finance

SMV
Securities Market
Superintendency
Electronically signed document in the framework of Law No. 27269, Law of Digital Signatures and Certificates, its regulations and amendments. The integrity of the document and authorship or regional order. Additionally, Articles 113 5, 209 6 and 211 7 of the LPAG provide the requirements that the appeal must meet;
8. That, now well, from the evaluation carried out based on said legal framework, it has been verified that the appeal filed by MRS. COOPER meets the requirements established in Articles 113, 207, 209 and 211 of the LPAG, since it was filed within the period of fifteen (15) business days of being notified of the SANCTION RESOLUTION, it is founded on issues of pure law and meets the other requirements established by the regulations, so it corresponds to issue an opinion on the grounds thereof;
2.2. Evaluation of the arguments of MRS. COOPER
9. That, first of all, MRS. COOPER states that Article 12, letter d), of the LMV, in concordance with Article 156 of said Law, has as its objective to prevent market abuse practices, in that sense, she questions that said articles are being applied fully, without differentiating if the Director has carried out operations with or without misuse of sensitive information, or if he has done so for his own benefit or not. Likewise, she affirms not having had privileged information nor having used it for her own benefit;
10. That, regarding said argument, it corresponds to cite the mentioned articles:
«Article 12.- Market Transparency.- Any act, omission, practice or conduct that attacks the integrity or transparency of the market is prohibited, such as:
(...) d) That directors, officials and workers of stock exchanges and other entities responsible for the management of centralized mechanisms, clearing and settlement institutions, including

5 «Article 113.- Requirements of the writings
Every writing that is presented before any entity must contain the following:

Full names, address and National Identity Document number or foreigner's ID card of the administered, and if applicable, the quality of representative and of the person whom he represents.
The concrete expression of what is requested, the grounds of fact that support it and, when possible, the grounds of law.
Place, date, signature or fingerprint, in case of not knowing how to sign or being impeded.
The indication of the organ, the entity or the authority to which it is addressed, understanding by such, as far as possible, the authority of the grade closest to the user, according to the hierarchy, with competence to know and resolve it.
The address of the place where notifications of the procedure are desired to be received, when it is different from the real address exposed by virtue of numeral 1. This address designation produces its effects from its indication and is presumed subsistent, unless its change is expressly communicated. Likewise, the email or, if applicable, the electronic mailbox, pursuant to Article 20 of this law.
The relationship of the documents and attachments that accompany it, indicated in the TUPA.
The identification of the file of the matter, in the case of already initiated procedures.»
6 «Article 209.- Appeal
The appeal shall be filed when the challenge is based on a different interpretation of the evidence produced or when it concerns issues of pure law, and must be addressed to the same authority that issued the act being challenged so that it elevates the proceedings to the hierarchical superior». 7 «Article 211.- Requirements of the appeal The appeal writing must indicate the act from which the appeal is made and must meet the other requirements provided in Article 113 of this Law».

PERÚ Ministry of Economy and Finance

SMV
Securities Market
Superintendency
Electronically signed document in the framework of Law No. 27269, Law of Digital Signatures and Certificates, its regulations and amendments. The integrity of the document and authorship the floor director, acquire or transfer securities or financial instruments registered in the Registry, unless they obtain prior authorization from the SMV. This restriction does not reach the following cases:
1. Released shares;
2. Shares that are subscribed in exercise of the preferential subscription right established in the Companies Law;
3. Securities that come from the condition of user of a public service or have been acquired for tax exemption purposes;
4. Mutual fund participation certificates; and,
5. Others that the SMV determines through a norm of a general character.
(...)» (Underline added).
«Article 156.- Prohibition.- Members of the Board of Directors or Directorate, as applicable, may not acquire or dispose of securities registered or traded on the respective Stock Exchange for valuable consideration, unless they have previously obtained the written authorization of the SMV. This prohibition does not apply to operations referring to securities that come from the condition of user of a public service» (Underline added).
11. That, as it is observed, the aforementioned letter d) of Article 12 of the LMV establishes that directors, officials and workers of stock exchanges and of other entities responsible for the management of centralized mechanisms, clearing and settlement institutions, including the floor director, are prohibited from acquiring or transferring securities or financial instruments registered in the Public Registry of the Securities Market – RPMV, unless they obtain prior authorization from the SMV;
12. That, in concordance with the above, Article 156 of the LMV establishes that members of the Board of Directors or Directorate, as applicable, may not acquire or dispose of securities registered or traded on the respective stock exchange for valuable consideration, unless they have previously obtained the written authorization of the SMV;
13. That, these prohibitions, as MRS. COOPER correctly points out, have as their objective to prevent market abuse practices, avoiding that those people who by their function may have access to information that has not been revealed to the market, use it for their own benefit or that of third parties;
14. That, nevertheless, it is important to indicate that the infringement of said norms is configured when the obligated party acquires or transfers securities or financial instruments registered in the RPMV and/or registered or traded on the respective stock exchange, without prior authorization from the SMV, regardless of whether he used or not information that has not been revealed to the market, or if he did so for his own benefit or that of third parties; since, if this situation had occurred, the obligated party would not only have incurred in non-observance of Articles 12, letter d), and 156 of the LMV, but also of other regulatory provisions such as that provided in Article 45 of said Law 8, or those contemplated in the Regulation against Market Abuse – Norms on

8 «Article 45.- Prohibitions.- Persons who possess privileged information are prohibited from:
a) Revealing or confiding the information to other persons until it is disseminated to the market; b) Recommending the carrying out of operations with securities regarding which privileged information is held; and,

PERÚ Ministry of Economy and Finance

SMV
Superintendencia del Mercado de Valores
Document electronically signed digitally under Law No. 27269, Law of Digital Signatures and Certificates, its regulations and amendments. The integrity of the document and the authorship

Misuse of Insider Information and Market Manipulation, approved by SMV Resolution No. 005-2012-SMV/01 and its amendments;

That, thus, in consideration 50 of the SANCTION RESOLUTION, the SASP states the following, a criterion with which we agree:

«50. In that sense, the conduct carried out by DIRECTORABVL, referred to as carrying out the sale operations of securities of her ownership, in her capacity as president of the BVL, without having prior authorization from the SMV, constitutes behavior contrary to the aforementioned regulation, since only certain people are prohibited, such as the members of the Board of Directors of the BVL, that operations with securities or instruments financial instruments registered in the RPMV and/or registered or traded in the respective exchange are carried out without prior authorization from the SMV. Consequently, article 12, letter d), of the LMV does not establish that the infringing conduct requires that the person carry out misuse of insider information or market manipulation for its configuration, but it is sufficient that they carry out operations with securities or financial instruments registered in the RPMV and/or registered or traded in the respective exchange without having prior authorization from the SMV;»

That, it should be clarified that what is indicated in the
preceding consideration does not imply that the existence of a objective responsibility regarding the non-observance of articles 12, letter d), and 156 of the LMV, since the circumstances in which the infraction was committed will be evaluated within the framework of the principles of administrative sanctioning law, including the principle of culpability, as we will develop further;
That, therefore, the fact that MS. COOPER
has carried out the operations without having used information that has not been revealed to the market, or without obtaining personal benefit or for third parties, does not disprove the commission of the infraction determined in the SANCTION RESOLUTION. In that sense, it corresponds to dismiss the arguments of MS. COOPER on this point;
That, secondly, MS. COOPER indicates
that the operations subject to sanction were carried out on April 23, 2021, a date on which she was in the United States with the objective of obtaining the vaccine against the pandemic caused by COVID-19. Likewise, she indicates that upon communication from CREDICORP CAPITAL SAB she decided to sell her securities at an unfavorable price —as is recognized in consideration 74 of the SANCTION RESOLUTION—, with the purpose of protecting her assets in the face of a context of capital flight and falling indicators of the market. Therefore, she denies the existence of any risk of market abuse;

c) To misuse and avail oneself, directly or indirectly, for one's own benefit or that of third parties, of the privileged information.
These people are obliged to ensure that their subordinates comply with the prohibitions established in this article.
The persons who fail to comply with the prohibitions established in this article must deliver to the issuer or fund, when it comes to information related to the operations of mutual funds, of investment funds, pension funds or other funds administered by institutional investors, of the benefits they have obtained.»

PERÚ Ministry of Economy and Finance

That, regarding this matter, it must be indicated that the SMV
has, even prior to the date of the operations in question, various virtual channels enabled for the exchange of information with its regulated entities, such as MVNet and SMV Virtual. Likewise, at that date, the email tramite_documentario@smv.gob.pe was enabled, through which it was possible to initiate administrative procedures virtually, without the need to appear at the SMV facilities, information that was disseminated, at the time, through the SMV website;
That, therefore, the fact that MS. COOPER
was outside the country did not imply that she was prevented from requesting the corresponding authorization from the SMV, as she could access virtual channels such as SMV Virtual and the documentary processing email. Consequently, said argument does not exempt her from the duty to comply with articles 12, letter d), and 156 of the LMV;
That, regarding the argument that the
decision to sell the securities was adopted in a span of only three minutes after receiving the communication from CREDICORP CAPITAL SAB, it should be noted that this also does not exempt her from administrative responsibility. On the contrary, it reveals that the decision was adopted without adequate diligence, given that in her capacity as Director of the Lima Stock Exchange S.A. (BVL), MS. COOPER was subject to diverse regulatory provisions of strict compliance in the securities market;
That, on the other hand, regarding the allegation
that the transactions were carried out at an unfavorable price, it must be indicated that in the considerations 72, 73, 74 and 75 of the SANCTION RESOLUTION it has been indicated that, in fact, MS. COOPER obtained a loss of USD 29,368.57. Nevertheless, this economic loss, by itself, does not constitute an exemption from responsibility; but it must be valued within the circumstances of the commission of the infraction, as well as in the illicit benefit resulting from the commission of the infraction;
That, in that sense, it corresponds to dismiss the
arguments of MS. COOPER on this point of her writing;
That, thirdly, MS. COOPER invokes the
principle of presumption of innocence, stating that no infraction can be considered of article 12, letter d), of the LMV, for any operation of acquiring or transferring securities, unless there is misuse of insider information and undue benefit, which has not occurred in the present case. She emphasizes, moreover, that the SMV has not evidenced the existence of an undue advantage for herself or for third parties;
That, regarding this, it must be indicated that the presumption
of innocence is a constitutional principle recognized in article 2, paragraph 24, letter e, of the Political Constitution of Peru, which provides that «every person is considered innocent until their responsibility has been declared judicially». The scope of this guarantee has been extended to administrative law under the principle of presumption of lawfulness, contemplated in article 230, numeral 9, of the LPAG, which provides as follows:

«Article 230. Principles of administrative sanctioning power The sanctioning power of all entities is additionally governed by the following special principles:
(…)

PERÚ Ministry of Economy and Finance

9. Presumption of lawfulness.- Entities must presume that the
regulated parties have acted in accordance with their duties unless they have evidence to the contrary».

26. That, from the aforementioned article it is evident that on the
regulated party falls a presumption iuris tantum regarding the legal compliance of their duties, corresponding to the administrative authority the obligation to gather the means of proof that allow it to rebut this presumption. It should be clarified that this guarantee applies from the moment charges are brought against the regulated party, within the framework of an administrative sanctioning procedure, until the corresponding resolution is issued;

27. That, regarding this principle, the author Morón
Urbina 9 has stated the following:

«(…) This presumption covers the accused during the procedure sanctioning (…). The presumption will only yield if the entity can gather sufficient evidence on the facts and their authorship, have certainty that all the elements constituting the type provided for have occurred, and a sufficient logical reasoning that articulates all these elements forming conviction.» (Underlining added).

That, for its part, the Constitutional Tribunal 10 has
exposed that:

«(…) every sanction, whether criminal or administrative, must be based on a minimum activity of probative evidence against, that is, the burden of proof corresponds to the accuser; this must prove the fact for which he accuses a determined person, proscribing sanctions that are based on presumptions of guilt. Thus the presumption of innocence (...) constitutes a limit to the exercise of the sanctioning power of the State, in its various manifestations» (Underlining added).

That, from what has been stated above, it is crucial that
the administrative authority carries out a minimum probative activity in order to collect element(s) of proof sufficient(s) to demonstrate that the regulated party has committed the alleged infraction imputed to him, with the purpose of applying the sanction corresponding. In the absence of probative activity, it must be presumed that the conduct of the regulated party has been in accordance with the law, based on the principle of presumption of lawfulness;
That, in that framework, it has been observed that, in the
case under analysis, MS. COOPER was charged with having carried out, on April 23, 2021, the sale of her bonds registered in the RPMV — subordinated bonds INTER2BS3A and corporate bonds ENGIE1BC6A— without the prior authorization of the SMV, thus disobeying what is provided for by articles 12, letter d), and 156 of the LMV;
That, in that context, in the administrative
sanctioning procedure, the following have been taken as means of proof, among others: (i) the Letter GC-010.21 of April 26, 2021, by means of which the BVL informed the SMV of the operations carried out by MS. COOPER without the prior authorization of said

9 MORÓN URBINA, Juan Carlos (2020). Comments on the General Administrative Procedure Law.
15th ed. Lima: Gaceta Jurídica. Pg. 440 – 441.
10 File 02971-2016-PA/TC.

PERÚ Ministry of Economy and Finance

Superintendence; (ii) the writing of April 28, 2021, in which MS. COOPER informs the SMV about the aforementioned operations; and, (iii) the Memorandum No. 1402- 2021-SMV/11 of May 05, 2021, through which the Adjunct Superintendence of Supervision of Market Conducts (SASCM) informed that there were no active reserved facts related to the issuing companies of the securities subject to operation;

That, from the aforementioned means of proof —
including the writing of MS. COOPER— it can be evidenced that, after the due valuation of these, it was determined that there are sufficient probative elements that accredit the non-compliance incurred by the appellant. Regarding what is indicated in her appeal resource regarding the fact that the SMV has not accredited that MS. COOPER has obtained an undue advantage for herself or for third parties, it must reiterate what is indicated in this resolution, regarding the fact that the non-compliance of articles 12, letter d), and 156 of the LMV occurs when the obligated party acquires or transfers securities or financial instruments registered in the RPMV and/or registered or traded in the respective exchange, without the prior authorization of the SMV, regardless of whether he used or not information that has not been revealed to the market, or if he did so for his own benefit or for third parties;
That, consequently, the
principle of presumption of lawfulness has not been violated and, therefore, it corresponds to dismiss the arguments of MS. COOPER on this point of her writing;
That, fourthly, MS. COOPER maintains
that in the SANCTION RESOLUTION objective responsibility is attributed to her, despite the fact that, in considerations 52 and 54 of the same, it is recognized that there was no intent. She adds that article 230 of the LPAG establishes that objective responsibility only proceeds when it is provided for by law or legislative decree, and that article 248 of said Law contemplates the principle of typicity that proscribes analogy or extensive interpretation, a supposition that apparently the SMV intends to apply in this case;
That, in support of what was expressed in the paragraph
preceding, she cites the sentence of the Plenary 201/2022 of the Constitutional Tribunal 11, administrative doctrine, as well as laws and legislative decrees applicable from other public entities where the objective responsibility of the regulated parties is expressly established;
That, in that scenario, she expresses that in the
article 12 of the LMV does not expressly establish objective responsibility, so having been analyzed in the SANCTION RESOLUTION the element of fault in the
operations carried out, she considers that it has been demonstrated that she has not incurred in punishable infraction, so it corresponds that said resolution be revoked;
That, regarding what was indicated by MS.
COOPER, it is necessary to cite the principle of culpability, collected in article 230, numeral 10, of the LPAG, which provides as follows:

«Article 230.- Principles of administrative sanctioning power

11 «53. Regarding this, it is necessary to underline, first of all, that when it has been established that only by means of law or legislative decree (that is, only by means of norms with legal rank) can a regime of objective administrative responsibility be fixed, it seeks to avoid an implicit regulation of the same or that it be by means of infra-legal provisions, which constitutes a guarantee for the regulated parties.»

PERÚ Ministry of Economy and Finance

The sanctioning power of all entities is additionally governed by the following special principles:
(…)
10. Culpability.- Administrative responsibility is subjective, except for
the cases in which by law or legislative decree the responsibility objective administrative responsibility is established».

That, regarding this, the Constitutional Tribunal 12 has
indicated the following:

«50. As is known, the principle of culpability operates as a limit to the sanctioning power of the State, whether of a criminal or administrative type. From there that the sanction, criminal or administrative, can only be sustained on the proof of subjective responsibility of the agent infringer of a legal good (cfr. Sentence 01287-2010-AA/TC, foundation 9).
51. According to what is established in the LPAG and its current TUO, for purposes
of subjective responsibility being configured, it is necessary, in addition to the commission of the infraction and the production of the objective result, that the action can be attributed to the infringer by title of intent or fault. (…)
54. On the other hand, to determine the responsibility of administrative type
objective to which the questioned article 248.10 of the TUO of the LPAG refers, it will not be necessary the intentional or imprudent behavior of the subject infringer. For purposes of imposing the administrative sanction, it is sufficient that the infringing conduct has occurred. The will or imprudent behavior of the subject are set aside and it will be sufficient to verify the commission of the infraction.»

That, for its part, national and international doctrine has
developed extensively on the principle of culpability. Thus Morón Urbina 13 has exposed the following:

«(…)
According to the dominant conception, the principle of culpability guarantees that the sanction is applied only if it is accredited in the procedure sanctioning that the subject has acted in a deliberate or negligent manner in the commission of the infringing fact and not only by the conduct or the effect damaging has been produced. In this sense, by virtue of this principle, which encompasses other categories within it, it is not enough with the material result produced by the action, but it requires taking into account the circumstances subjective of the author».

That, likewise, the author Ángeles De Palma 14 has
stated that:

«The principle of intent or fault, referred to the subjective elements of the infraction, is the essential core of the principle of culpability. (…)

12 Plenary Sentence 201/2022. File No. 00002-2021-PI/TC.
13 MORÓN URBINA, Juan Carlos (2020). Comments on the General Administrative Procedure Law.
15th ed. Lima: Gaceta Jurídica.
14 DE PALMA DEL TESO, Ángeles (2001). Culpability. Administrative Justice: Journal of Administrative Law, extraordinary number, Valladolid: Lex Nova.

PERÚ Ministry of Economy and Finance

The different protagonism of intent and fault in Criminal Law and in the Administrative Sanctioning Law is explained in good measure by the differences between criminal types and administrative ones. In the criminal field the majority of crimes are of injury, the type requires the effective injury of a legal good. In contrast, most administrative infractions are of danger, the type provides for the simple putting in danger –concrete or abstract– of a legal good, without requiring its effective injury. Therefore, the illicit administrative contemplates in general the commission of imprudence. The Administrative Sanctioning Law seeks to prevent not only the injury of the legal goods that in this area are protected, but their simple putting in danger. In Administrative Sanctioning Law, intent constitutes, in general, an aggravating factor of responsibility. (…) Thus, it can be said that a person acts culpably or imprudently who, by disregarding a legal duty of care, does not behave with the diligence that is expected of him and carries out (in a non-deliberate or intentional manner) the conduct typed as an infraction, being such fact foreseeable and avoidable. Therefore, the fault or imprudence implies the non-observance of the expected diligence. The infraction of a care norm through a negligent, careless, imprudent action, which leads the person to carry out the conduct constitutive of infraction. Consequently, we are facing an imprudent administrative infraction when the typical conduct has been due to the lack of the expected diligence or to the violation of the care norm.

That, this means that, for the correct application
of the principle of culpability in the administrative sanctioning procedure it is required to consider personal responsibility for one's own acts, by title of intent or fault. In this way, it is ensured that the sanction imposed reflects, among others, the circumstances subjective of the infringer in the commission of the infraction;
That, from what has been stated above and by virtue of the
principle of culpability, the administrative responsibility applicable for the non-compliance of what is provided for by articles 12, letter d), and 156 of the LMV is the subjective, not the objective. In that sense, from the review of the SANCTION RESOLUTION it is not evident that objective responsibility invoked by MS. COOPER has been recognized or applied. Thus, in considerations 54 and 55 of the mentioned resolution it has been indicated as follows:

«54. Regarding this, we must indicate that in the present case no evidence has been found that determines that DIRECTORABVL acted with will to break the prohibition established in article 12 of the LMV; however, her conduct involves the commission of an infraction by fault; that is, by the production of an unlawful result, duly typed, completely foreseeable and avoidable, since she disregarded a duty of care, in her conduct, that was expected by the regulations of the securities market, as well as by her quality as president of the board of directors of an institution that serves as a centralized mechanism for the negotiation of securities;
55. In that sense, it was demonstrated that DIRECTORABVL carried out
operations to sell securities, without authorization, in contravention of the prohibition of article 12, letter d), of the TUO LMV, a norm that was in force on the date of the commission of the infraction;»

That, as is evident from the cited paragraphs, in the
SANCTION RESOLUTION it has been evaluated that the infringing conduct was committed by

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negligence, not intent. In this regard, this assessment is shared, since, in the present case, MRS. COOPER has not demonstrated that her conduct was diligent nor that she took the necessary precautions to avoid the infringement;

That, although the appellant maintains that the operations were carried out due to "the country's situation, capital flight, and the fall of market indicators" and that the decision was adopted in a "rapid" manner, "based solely on protecting [her] assets" within a period of "3 minutes", this does not justify that MRS. COOPER disregards her obligations before the SMV nor exempts her from compliance. In her capacity as Director of the BVL, MRS. COOPER is obligated not only to possess technical competence regarding the securities market but also to strictly observe the applicable regulations, which takes on special relevance when dealing with operations subject to prior administrative authorization by the SMV, whose purpose is to safeguard market integrity. Therefore, the alleged circumstances do not justify the conduct of MRS. COOPER, which evidences negligent behavior and a breach of the duty of care corresponding to her as Director of the BVL;
That, consequently, the principle of culpability has not been violated, and therefore, it corresponds to dismiss the arguments of MRS. COOPER on this point of her writing;
That, in the fifth place, MRS. COOPER indicates that in consideration 57 of the SANCTION RESOLUTION, an erroneous transcription of what was stated in her writing dated April 28, 2021, was made, changing "involuntary" to "voluntary". In this sense, she considers that by completely modifying the meaning of her communication, an improper motivation was incurred that vitiates the nullity of the SANCTION RESOLUTION;
That, regarding this, it must be noted that, indeed, there was a typographical error in said consideration. However, this error does not affect the validity of the administrative act, as it does not alter the essential content or the meaning of the decision. As explained in this resolution, the SANCTION RESOLUTION has adopted the position that MRS. COOPER acted with negligence, not intent. In this sense, if said transcription with the typographical error had been considered literally, the SASP would have interpreted that her conduct was intentional, which would have modified the valuation of the imposed sanction considering this aggravating factor. Consequently, the transcription error is not transcendent nor does it invalidate the resolution; therefore, it corresponds to dismiss the arguments of MRS. COOPER on this point of her writing;
That, in the sixth place, MRS. COOPER states that in the SANCTION RESOLUTION it is held that in voluntary remediation, the state must be reverted to the moment prior to the infringement, which in her case would imply that the sale of the securities remains without effect. However, pursuant to what is provided by the LPAG, remediation does not retroactively change the situation, but eliminates the element that constitutes the infringement, as provided in article 236-A, letter f), of the LPAG. In this case, MRS. COOPER states that the remediation was voluntary, before the formulation of charges, and consisted of correcting the omission of not requesting authorization from the SMV, without causing harm to the market;
That, furthermore, she mentions that the SANCTIONS REGULATION violates the hierarchy of laws and denies any possibility of voluntary remediation, attacking the principle of legality by contravening and

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distorting what is regulated by the LPAG, for which she considers that part of the SANCTIONS REGULATION is legally inapplicable, for attempting to modify the LPAG via regulatory norm. Additionally, she considers that additional requirements are being established for the application of said exemption, such as having those infringements that are not susceptible to remediation;

That, regarding this, it must be indicated that article 236-A of the LPAG regulates the following regarding voluntary remediation:

"Article 236-A.- Exemptions and mitigating factors for liability for infringements 1.- The following constitute conditions exempting liability for infringements:
(...) f) Voluntary remediation by the possible sanctioned party of the act or omission attributed as constitutive of an administrative infringement, prior to the notification of the imputation of charges referred to in paragraph 3) of article 235."

That, as observed, the LPAG establishes three elements for the exemption of liability to operate: i) the voluntary nature, ii) the remediation, and iii) the timing of the remediation 15;
That, regarding the voluntary nature, it must be noted that this implies that the remediation is the result of the free and spontaneous initiative of the obligated subject. In such sense, it cannot be considered as an exempting factor if the remediation is carried out in response to a prior request from the SMV or after a communication has been issued requesting compliance with the obligation, as in such cases the voluntariness is distorted. This criterion has been collected by the SMV in articles 27, letter f), and 28 of the SANCTIONS REGULATION, in concordance with what is established in the aforementioned article 236-A, letter f), of the LPAG;
That, with respect to the timing of the remediation, the LPAG establishes that it must be carried out prior to the notification of the imputation of charges, which has also been collected in the SANCTIONS REGULATION;
That, as for the remediation itself, it refers, in general terms, to the fact that the infringement has ceased (in case of commission by action) or the omitted conduct has been carried out (in case of omission), as well as, when applicable, the effects or consequences derived from said infringement have been reversed. However, it must be specified that this figure is not applicable to all types of infringements, as in certain cases remediation is materially impossible, as will be developed further;
That, in this framework, in article 28 of the SANCTIONS REGULATION, the SMV has delimited — based on the nature of the infringing conduct and in protection of the legal goods protected — those situations in which it is not possible to remediate and, consequently, apply said exemption of liability. Its objective is to generate predictability for the regulated party regarding the infringements to which said exemption could be applied, since as the SANCTIONS REGULATION has provided for the administrative infringements susceptible to

15 Superintendent Resolution No. 086-2022-SMV/02 of September 30, 2022.

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sanction, the SMV has considered it pertinent to specify which are the infringing conduct that are not susceptible to being remedied. Consequently, it should not be interpreted, as indicated by MRS. COOPER, as a distortion of the exemption of liability for voluntary remediation provided in letter f) of paragraph 1 of article 236-A of the LPAG, nor as the imposition of less favorable conditions to the regulated parties nor a transgression to the hierarchy of laws. On the contrary, the SANCTIONS REGULATION has been drafted with full observance of the principles and guarantees applicable to the sanctioning procedure. Additionally, it is worth indicating that said Regulation has been issued within the framework of the competencies of the SMV, provided in its Unified Concordant Text of the Organic Law of the SMV, approved by Legislative Decree No. 26126 and its amendments (hereinafter, ORGANIC LAW), particularly in letters a) and b) of article 1 and letters b) and d) of article 5, which empower it to issue norms in the field of the securities market, typify infringements and supervise their compliance;

That, therefore, it corresponds to dismiss what was alleged by MRS. COOPER regarding that the SANCTIONS REGULATION establishes additional requirements for the application of the exemption of liability for voluntary remediation and, therefore, violates the normative hierarchy and the principle of legality;
That, now well, in the present case, it is also observed that MRS. COOPER questions the position of the SASP regarding that the infringement committed is not considered "remedied", pursuant to what is provided in letter d) of article 28 of the SANCTIONS REGULATION. That is, she is not questioning the voluntary nature nor the timing of the remediation, but only whether the infringing conduct is remediable or not;
That, regarding this, it is observed that in considerations 58 and 59 of the SANCTION RESOLUTION, the SASP has stated, regarding voluntary remediation, the following:

"58. Despite what was mentioned by the DIRECTOR BVL, it must be specified that the voluntary remediation of an infringement implies the performance of an action conducive to repairing the situation altered by the infringement to its previous state. In other words, not any action can be considered as a voluntary remediation, as this must lead to the restoration of the situation to its state prior to the commission of the infringement. In this sense, the communication of April 28, 2021, does not retroact the sale operations of the securities of her property, nor generates the immediate restoration of the situation to its state prior to the purchase. Likewise, in the present case, it is materially impossible to remediate the infringement, as even if the DIRECTOR BVL had acquired the securities again, it cannot alter the fact that the sale of them was carried out without prior authorization from the SMV;

59. In this sense, the communication of April 28, 2021, cannot be considered as a writing or an action tending to remediate the violation of article 12, letter d), of the LMV; therefore, it cannot be considered as an exemption of liability under the parameters established in article 257, paragraph 1, letter f) of the TUO LPAG, nor of article 27 of the SANCTIONS REGULATION;"

59. That, from the aforementioned text, it is important to clarify that, regarding the remediation of the infringement, this not only implies the cessation of the infringing conduct or the performance of the omitted conduct, as applicable, but also

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reverse the consequences or harmful effects on the protected legal good caused by said conduct. Thus, in the Practical Guide on the administrative sanctioning procedure, prepared by the General Directorate of Development and Legal Ordering of the Ministry of Justice and Human Rights (MINJUS) — Guide for legal advisors of the State that promotes uniform criteria regarding the exercise of the sanctioning power of the State, as well as on the application of legal figures linked to the administrative sanctioning procedure — the following has been indicated:

"2.4. Exemptions and mitigating factors of administrative liability (...)
The case provided for in letter f) has a distinct nature from the previous ones, as it provides for a typical and unlawful conduct, with intent or negligence, in which the regulated party decides to remediate its infringement before the administrative authority decides to exercise its sanctioning power. (....) It is worth indicating that this case does not consist only in the cessation of the infringing conduct but that, when applicable, the remediation implies the repair of the consequences or harmful effects to the protected legal good derived from the infringing conduct. This with the purpose of not generating impunity and avoiding that the accused appropriates the benefit illicitly obtained by the infringement 75."

That, however, it is necessary to reiterate that not all infringements are susceptible to remediation, due to their nature. Thus, we have as an example, that infringements for crossing the traffic light in red light or driving with excessive speed are materially impossible to remediate;
That, this analysis has been addressed in national doctrine. Regarding this, the author Natalia Zuñiga Arbildo 16 has indicated the following:

"Thus, there may be cases where the impossibility of reversing the effects of an infringement is impossible. Basically, this would happen with those infringements of instant effects, in which 'the injury or endangerment of the protected legal good occurs at a specific moment, in which the infringement is consummated, without producing a lasting unlawful situation.'"

That, in the same line, Hebert Tassano Velaochaga 17 holds the following:

"Under this optics, not only the concurrence of the described requirements (before the start of the PAS) will be evaluated, but also the remediable character of the detected non-compliance, from the nature of the infringing conduct and from the effects that it deploys, taking into account that there are infringements that, due to their own nature or by express legal provision, are not susceptible to being remedied."

That, in view of what has been stated, it is concluded that the infringement in question — carrying out unauthorized operations — is not legally susceptible to being remedied, as it is an administrative infringement of

16 BACA ONETO, Víctor Sebastián. The prescription of infringements and its classification in the General Administrative Procedure Law. Revista Derecho & Sociedad No. 37, Lima, 2012, p. 268.
17 TASSANO VELAOCHAGA, Hebert. The Voluntary Remediation of Infringements as an Exemption of Liability in the Case of the Sanctions Tribunal of SUSALUD. Mercantile Dimension, Lima, June 04, 2022.

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instant nature, that is, the infringement was consummated immediately at the moment when MRS. COOPER carried out the unauthorized transaction on April 23, 2021, without the authorization of the SMV. Therefore, it is not possible to affirm that through the writing presented on April 28, 2021, MRS. COOPER remedied the infringement committed. This criterion is collected in letter d) of article 28 of the SANCTIONS REGULATION;

That, it is worth specifying that, in other entities of the public administration, the position has also been incorporated in their respective regulations that not all infringing conduct is susceptible to being remedied 18;
That, consequently, we share the position of the SASP regarding that the exemption of liability for voluntary remediation is not applicable to MRS. COOPER, as has been recognized in letter d)

18 In the case of the Superintendence of Banks, Insurance and Private Pension Fund Administrators (SBS), article 16, letter f, of the Regulation of Infringements and Sanctions of the Superintendence of Banks, Insurance and Private Pension Fund Administrators, approved by SBS Resolution No. 2755-2018 and its amendments, contemplates the following:

"Article 16. Exemptions of liability
The following situations are considered exemptions of liability:
(...) f. Voluntary remediation of the infringement.- This exemption is configured when the infringing conduct or omission is expressly recognized in writing and fully remedied voluntarily, prior to the notification of the imputation of charges. Voluntary remediation is not considered when the conduct is remedied as a consequence of an order or mandate of the Superintendence issued in the exercise of its supervisory and/or oversight power. This exemption only applies to minor and immaterial infringements that do not cause concrete and significant harm to users or the market. The immateriality of the committed infringement must be understood as that situation in which the facts have little significance. Voluntary remediation is not applicable as an exemption in the case of recurrent infringements."

In the case of the Private Investment in Telecommunications Supervisory Body (OSIPTEL), article 5, paragraph iv, of the Regulation of Oversight, Infringements and Sanctions, approved by Council Resolution No. 087-2013-CD-OSIPTEL and its amendments, establishes the following:

"Article 5.- Exemptions of liability
The following are considered conditions exempting administrative liability:
(...) iv) Voluntary remediation by the possible sanctioned party of the act or omission attributed as constitutive of an administrative infringement, prior to the notification of the start of the administrative sanctioning procedure, to which article 22 refers. For such purposes, it must be verified that the infringement has ceased and that the effects derived from it have been reversed. Likewise, the remediation must have occurred without there having been, by the OSIPTEL, a request for remediation or compliance with the obligation, expressly recorded in a letter or resolution."

In the case of the Supervisory Body of Investment in Energy and Mining (OSINERGMIN), article 16, letter e, of the Regulation of Oversight and Sanction of energy and mining activities in charge of Osinergmin, approved by Council Resolution of OSINERGMIN No. 208-2020-OS-CD, contemplates the following:

"Article 16.- Exemptions of administrative liability The following constitute conditions exempting administrative liability:
(...) e) Voluntary remediation by the Audited Agent of the act or omission attributed as constitutive of an administrative infringement, prior to the notification of the start of the administrative sanctioning procedure. For this exemption of liability to be configured, three conditions must concur: i) that the infringing conduct is susceptible to being remedied, ii) the voluntariness of the remediation and iii) the timing of the remediation."

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of article 28 of the SANCTIONS REGULATION and, therefore, it corresponds to dismiss the arguments on this point of her appeal;

That, in the use of the word, MRS. COOPER has raised as a new argument that letter d) of article 28 of the SANCTIONS REGULATION does not fit the type of infringement imposed, given that, in the present case, it is not about "unauthorized activities" but about operations that she carried out without prior authorization from the SMV;
That, on this particular, it corresponds to cite the aforementioned paragraph, which disposes the following:

"Article 28.- SITUATIONS IN WHICH REMEDIATION DOES NOT APPLY AS AN EXEMPTION OF LIABILITY Remediation prior to the notification of the imputation of charges is not considered as an exemption of liability, when a communication demanding compliance with the obligation has been issued. Those not susceptible to remediation for the purposes of what is provided in letter f) of article 27:
(...) d) The carrying out of activities not permitted or providing services or performing activities not authorized by the SMV, in cases where the regulation requires having the respective authorization."

That, from the reading of the cited provision, it is observed that, among the situations not susceptible to remediation, is the carrying out of activities not permitted when the regulation requires having the respective authorization. In this sense, the sale of securities without the corresponding authorization constitutes precisely an activity not permitted, since it was executed outside the prior authorization required by law to safeguard market integrity. Accepting the interpretation of MRS. COOPER, in the sense that her conduct does not fit this situation given that it qualifies as an "operation without prior authorization", would empty the purpose of article 28 of the SANCTIONS REGULATION of content. Indeed, the spirit of the norm is to prevent regulated parties from executing operations first and then attempting to remediate them to evade responsibility, thereby weakening the preventive and corrective role of the SMV;
That, consequently, the conduct attributed to the appellant fits the situation described in letter d) of article 28 of the aforementioned Regulation, since she executed an operation without having the prior authorization required by the applicable regulation. Therefore, it corresponds to conclude that in the present case, voluntary remediation does not proceed as an exemption of liability;
That, finally, it must be indicated that, in the second paragraph of the First Additional Statement of the appeal, MRS. COOPER considers "a disproportionate consequence and against the principle of reasonableness, that a disqualification or impediment to exercise a position in companies that operate and/or are supervised in the sector may derive";
That, regarding this, it corresponds to specify that, although the infringement incurred by MRS. COOPER is qualified in the SANCTIONS REGULATION as a very serious infringement, as has been developed in considerations 60 and following of the SANCTION RESOLUTION, under what is provided

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in the last paragraph of Article 25 of the SANCTIONS REGULATION 19—which allows that when, from the evaluation of sanctioning criteria, it is observed that there is no proportionality between the sanction to be imposed and the imputed facts, by exception and through a reasoned resolution, a sanction corresponding to a classification lower than that provided for can be imposed—a sanction of reprimand was imposed, which—according to Article 35 of the SANCTIONS REGULATION 20—corresponds to an infraction of a minor nature;

That, in this context, it is pertinent to mention that Annex B, literal j), of the Common Norms for entities that require authorization for organization and operation of the Superintendency of the Securities Market – SMV, approved by SMV Resolution No. 039-2016-SMV/01 and its amendments, establishes the following:

“ANNEX B
GENERAL IMPEDIMENTS
The following persons cannot be organizers:
(…) j) Natural persons who have received a sanction from the SMV or SBS, which is final in the administrative arena, or from equivalent institutions abroad, corresponding to: i) serious infractions in the last ten (10) years, counted from when the sanction became final; or ii) very serious infractions; (…)” (Underlining added)

That, as observed, the impediment provided for in the aforementioned literal is conditioned on the imposed sanction corresponding to a serious or very serious infraction;
That, in such sense, since no sanction corresponding to a very serious infraction was imposed, MS. COOPER is not subject to the impediment regulated in literal j) of Annex B of the aforementioned norms, so the consequences of the imposed sanction are not those mentioned in her appeal;
That, according to what has been developed and analyzed, there are no grounds to revoke or declare null and void the SANCTION RESOLUTION, so it corresponds to dismiss the appeal filed by MS. COOPER and, therefore, confirm the SANCTION RESOLUTION; and,
Being subject to what is provided in numeral 26 of Article 12 of the Organization and Functions Regulation of the Superintendency of the Securities Market, approved by Supreme Decree No. 216-2011-EF and its amendments.

19 “Article 35.- SANCTIONS FOR MINOR INFRACTIONS For the commission of minor infractions, the offender is imposed one of the following sanctions:
a) Reprimand; and, b) Fine not less than one (1) UIT and up to twenty-five (25) UIT”.

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RESOLVES:
Article 1°.- Declare unfounded the appeal filed by Mrs. Claudia María Amelia Teresa Cooper Fort against Superintendent Adjunct Resolution SMV No. 040-2025-SMV/10, for the reasons set forth in the consideration part of this resolution.
Article 2°.- Declare the administrative route exhausted.
Article 3°.- Notify this resolution to Mrs. Claudia María Amelia Teresa Cooper Fort.
Article 4°.- Order the dissemination of this resolution on the Institutional Page of the Superintendency of the Securities Market – SMV on the Peruvian State Digital Unified Platform (www.gob.pe/smv).
Register, communicate and disseminate.
Daniel Alonso García López
Superintendent of the Securities Market (e)

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