Technical Standards for Granting Financing to the Deposit Guarantee Institute (IGD)

TECHNICAL STANDARDS FOR GRANTING FINANCING TO THE DEPOSIT GUARANTEE INSTITUTE (IGD) SYSTEM STABILITY DEPARTMENT FINANCIAL STABILITY AND PUBLIC POLICIES MANAGEMENT JUNE 2022

INDEX
1 GENERALITIES ......................................................................................................... 1
1.1 BACKGROUND ................................................................................................... 1
1.2 LEGAL BASIS ........................................................................................................... 1
1.3 SCOPE OF APPLICATION ................................................................................... 1
2 OBJECTIVE .....................................................................................................................2
3 DEFINITIONS..............................................................................................................2
4 GENERAL STANDARDS.................................................................................................3
5 SPECIFIC STANDARDS ...............................................................................................5
5.1 FINANCING APPLICATION....................................................................5
5.2 FINANCING CONDITIONS ..........................................................6
5.3 APPROVAL OF FINANCING APPLICATION ................................7
5.4 FINANCING GUARANTEES.................................................................8
5.5 DISBURSEMENT AND REPAYMENT OF FINANCING ...........................8
6 SPECIAL PROVISIONS....................................................................................9
7 VALIDITY, DISTRIBUTION AND DISCLOSURE.......................................................10
8 MODIFICATION CONTROL TABLE.................................................. 11
ANNEXES...............................................................................................................................12

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Manager of Financial Stability and Public Policies APPROVED BY:
CD-14/2022 of June 30, 2022

1 GENERALITIES
1.1 BACKGROUND
According to its organic law, the Central Bank’s fundamental objective is to safeguard the stability of the currency, and its essential purpose is to promote and maintain the most favorable monetary, exchange rate, credit, and financial conditions for the stability of the national economy.

In November 2000, reforms to Article 51 of the Organic Law of the Central Bank of Reserve of El Salvador were approved, which authorized the Central Bank to grant financing to the Deposit Guarantee Institute, for the purposes established in Article 179 of the Banks Law. Although there have been other reforms, this provision remains in force.

For its part, the Deposit Guarantee Institute’s objective is to guarantee public deposits, under the modalities established by law, either by paying the deposit guarantee or by supporting the restructuring process of a member entity.

1.2 LEGAL BASIS
These Technical Standards are issued based on what is stipulated in Articles 3, letters d) and e); 23, letters g) and j) and 51 all of the Organic Law of the Central Bank of Reserve of El Salvador, to Articles 179 of the Banks Law and 106 and 160 of the Law of Cooperative Banks and Savings and Credit Societies.

1.3 SCOPE OF APPLICATION
These Technical Standards will be applied by the Presidency, the Financial Stability and Public Policies Management, the Financial Operations Management, the International Management, the Compliance Office, and the Legal Department in their relations with the Deposit Guarantee Institute, arising from the granting of financing to the Deposit Guarantee Institute.

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Manager of Financial Stability and Public Policies APPROVED BY:
CD-14/2022 of June 30, 2022

2 OBJECTIVE
To regulate the operations that the Central Bank of Reserve of El Salvador carries out with the Deposit Guarantee Institute for System Financial Stability, and to address the situations foreseen in Article 179 of the Banks Law, with the objective of providing financing to ensure the expedient reimbursement to depositors or alternatively to participate in a restructuring process.

3 DEFINITIONS
3.1 CBR: Central Bank of Reserve of El Salvador.
3.2 IGD Account: Deposit account that the IGD maintains at the CBR.
3.3 Member Entity: In accordance with Article 156 of the Banks Law and Articles 106 and 160 of the Law of Cooperative Banks and Savings and Credit Societies.
3.4 Financing: Credit that the CBR will grant to the IGD as provided in Article 179 of the Banks Law.
3.5 GOF: Financial Operations Management.
3.6 GEFPP: Financial Stability and Public Policies Management.
3.7 IGD: Deposit Guarantee Institute.
3.8 LDA/FT/FPDAM: Money Laundering and Asset Laundering, Terrorism Financing, and Financing of the Proliferation of Weapons of Mass Destruction.
3.9 LBTR: Real-Time Gross Settlement System. National Payments System of Systemic Importance, owned by the CBR, through which Participants process firm and irrevocable fund transfers among themselves. The system also provides settlement services to other Payment and Securities Settlement Systems.

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Manager of Financial Stability and Public Policies APPROVED BY:
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4 GENERAL STANDARDS
4.1 The IGD may request financing from the CBR to complete the resources it requires, either to pay the deposit guarantee or to support the restructuring process of a member entity.
4.2 Financing will be granted in accordance with the availability of CBR resources.
4.3 The GEFPP, based on what is regulated in these Technical Standards, will coordinate the participation of the involved internal units to attend to the received request and will require the IGD to provide all additional information and documentation it deems necessary.
4.4 The Legal Department will be responsible for reviewing the documentation presented by the IGD, according to Annex 1.
Additionally, it will verify that the documentation presented regarding the guarantee complies with legal formalities and is sufficient to demand payment in case of default by the IGD.
4.5 Immediately upon receiving the financing request, the GOF and the International Management will be responsible for verifying the availability of resources that the CBR has for financing the IGD. This situation will be reported to the GEFPP when the information is available.
4.6 The GOF and the International Management will confirm the availability of funds for financing. In the event that it is determined that the financing will be covered with funds from credit lines authorized for financing the IGD, the International Management will confirm with the fund provider the financial conditions and terms of the disbursement (term, interest rate, commissions, conditions for early payment, and other applicable conditions), which it will report to the Presidency, the GEFPP, and the GOF.
4.7 The IGD must have previously signed a Master Agreement with the CBR, in which the conditions applicable to the Financing, the IGD’s willingness to provide the required guarantees, as well as the commitment to assume all financial costs charged by the CBR to carry out the operation and all necessary information for the signing and monitoring of the financing contract, will be established.
4.8 The guarantee that the IGD may offer must meet the conditions described in these standards. According to Article 179 of the Banks Law, the IGD will pay the financing with the increase in premiums referred to in Article 169 of said Law, with the proceeds in favor of the IGD resulting from the alienation of acquired shares and assets, as well as with the returns from its equity, if applicable.
4.9 Since this financing will be used to support the stability and confidence of the Financial System, it will be granted under conditions determined by the Board of Directors of the CBR.
4.10 The IGD may withdraw in writing, at any time, the request made. The date and time of the presentation of the withdrawal will automatically suspend the evaluation process and will lead to the determination of applicable penalties; in such case, the GOF will make the corresponding debit to the account that the IGD maintains at the CBR, for the value of costs, commissions, penalties, and all those incurred or to be incurred by the CBR as a consequence of the suspension.
4.11 On each agreed date for the payment of financing, the CBR through the Payments and Values Department will debit the quota value from the account that the IGD maintains at the CBR. Upon completion of the financing term, the CBR will be authorized to debit any outstanding capital, interest, commissions, and costs.
4.12 In the event that the IGD cancels the financing before the maturity date, the GOF will perform the corresponding calculation and debit in the deposit account that the IGD maintains at the CBR for the amount equivalent to the financial costs it had to assume with the financing source due to the prepayment.

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Manager of Financial Stability and Public Policies APPROVED BY:
CD-14/2022 of June 30, 2022
The notification of early cancellation must be addressed to the Presidency of the CBR with a copy to the GEFPP.

5 SPECIFIC STANDARDS
5.1 FINANCING APPLICATION
5.1.1 In the event that the IGD wishes to use this financing, it must request it in writing from the CBR.
5.1.2 The IGD must direct its request, according to Annex No. 1, to the Presidency of the CBR, with a copy to the GEFPP, indicating the required amount and term, as well as the offer of guarantees for the fulfillment of its obligations.
5.1.3 The request must be accompanied by the following documents:
5.1.3.1 Certification of the Meeting Point in which the agreement of the respective governing body of the IGD is recorded, manifesting its decision to request financing, detailing the amount necessary to cover the purpose of Article 179 of the Banks Law, as well as the signing of the necessary documents, and the guarantees that may be required, in order to pay the deposit guarantee or support the restructuring of an entity.
5.1.3.2 Compliance Plan specifying how it will use the resources and how it will generate the necessary income to pay the financing.
5.1.3.3 Photocopy of the IGD’s Tax Identification Number.
5.1.3.4 Photocopy of the Unique Identity Document of the legal representative or attorney-in-fact of the IGD.

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5.1.3.5 Certification issued by the legal representative of the IGD regarding both the destination of the financing funds and the source of funds for payment.
5.1.3.6 Certification of the application of preventive controls executed by its compliance unit. This must be signed by the IGD’s Compliance Officer.
5.1.4 The CBR’s Compliance Office will perform due diligence on the IGD and any related counterparties in this financing. If it is identified that any of these represents a level of exposure to LDA/FT/FPDAM risk that cannot be mitigated or managed, or is on lists issued by the Office of Foreign Assets Control (OFAC), lists issued by the United Nations Security Council of sanctioned parties, or public lists issued by international bodies binding for El Salvador related to terrorism or affiliated groups, or have a conviction or sentence against them for crimes related to LDA/FT/FPDAM; the procedures established in the Manual for the Prevention of Money Laundering and Asset Laundering and Terrorism Financing to the Financing of the Proliferation of Weapons of Mass Destruction must be carried out.
5.1.5 The IGD may request financing on any calendar day through a written request. The GEFPP will immediately inform the GOF, the Legal Department, the Compliance Office, and the International Management of such request.

5.2 FINANCING CONDITIONS
5.2.1 The CBR will transfer to the IGD the financial conditions and costs incurred to obtain these resources (including interest rates, commitment commissions, disbursement commissions, other commissions, and surcharges) plus one hundred basis points.
5.2.2 The approved financing amount must be backed at all times by a guarantee equivalent to 100% of its value.

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5.2.3 The financing term will depend on the resource sources.

5.3 APPROVAL OF FINANCING APPLICATION
5.3.1 Prior to the approval of the financing operation, the GEFPP within the request analysis report will verify compliance with the general and specific standards listed above, which are not the responsibility of the GOF, Compliance Office, and International Management, and additionally the following requirement:
5.3.1.1 Obtain the opinion of the Legal Department stating whether the operation complies with the relevant legal aspects, which must be reported to the GEFPP as soon as possible, given the relevance of attending to the request in a timely manner.
5.3.1.2 Obtain confirmation from the fund source regarding the financing conditions (Costs and disbursement term).
5.3.2 The GEFPP will propose to the Board of Directors the approval or disapproval of the financing, including the amount that may be granted to the IGD, interest rate, guarantees, commissions, and other conditions, as deemed appropriate, based on compliance or non-compliance with all requirements contained in these technical standards.
Likewise, and based on the resource availability report issued by the GOF and the International Management, it will propose the approval of the use of resources or disbursement of funds from external credit lines, as well as the financial conditions of such disbursements.
5.3.3 The Board of Directors of the CBR will decide whether to approve or not the financing, and the general conditions of the operation, taking into consideration the proposal of the GEFPP which will include the opinions of the Legal Department, the GOF, the International Management, and the Compliance Office. Likewise, the Board of Directors will approve the use and disbursement of resources from the Central Bank’s accounts or external credit lines to cover the Financing. Its decision will be communicated to the

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GEFPP, the International Management, the Legal Department, the Compliance Office, and the GOF.
5.3.4 The Secretary of the Board of Directors of the CBR will communicate the agreement to approve or deny the requested financing to the IGD.

5.4 FINANCING GUARANTEES
5.4.1 Once the request is approved by the Board of Directors of the CBR, the Legal Department will proceed to formalize the constitution of the corresponding guarantee according to Annex 3.
5.4.2 The Treasury Department will be responsible for custodianing the documents mentioned in paragraph 5.1.3.

5.5 DISBURSEMENT AND REPAYMENT OF FINANCING
5.5.1 Once the financing request is approved by the Board of Directors of the CBR, the Legal Department will proceed to draft the financing contract and other relevant documents of the guarantee. After this, the contract will be signed by the President of the CBR or an authorized representative with powers to do so, and the legal representative or attorney-in-fact of the IGD, proceeding to send a copy of the signed contract to the GEFPP and the GOF, for the execution of the operation. Likewise, the GOF and the International Management will proceed to secure the funds for financing; which includes the request for disbursement of funds from the external provider, under the terms authorized by the Board of Directors.
5.5.2 The disbursement of resources will be carried out by the GOF by crediting the deposit account that the IGD maintains at the CBR. To proceed with the disbursement, the GOF must have in its possession:
Resolution of the Board of Directors agreement approving the financing to the IGD, Copy of the signed financing contract, with its respective guarantee constitution, and confirmation of the receipt of the disbursement from the fund provider by the International Management.

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Manager of Financial Stability and Public Policies APPROVED BY:
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5.5.3 On the agreed date for each payment, the CBR will automatically debit, through the LBTR System, the IGD’s account for the agreed amount, which will include capital, interest, and commissions. The IGD will give its consent to this procedure through the Financing Contract.
5.5.4 Upon final payment, the GOF will inform the Legal Department, so that it proceeds to take the necessary actions to release the guarantees that have been constituted in support of the operation.
5.5.5 If the IGD does not have sufficient funds in the deposit account at the CBR to effect payment of the operation, it will be considered in default, in which case the GOF will inform the Legal Department so that it carries out the necessary procedures to collect the guarantee when appropriate.

6 SPECIAL PROVISIONS
6.1 Operational and contingency difficulties that arise in the execution of these technical standards will be resolved by the Presidency of the CBR upon proposal of the GOF, International Management, GEFPP, and Legal Department, in their respective areas of competence. All of the above will be reported to the Board of Directors of the CBR at its next session.
6.2 Cases or situations not contemplated in these technical standards will be resolved by the Board of Directors of the CBR.
6.3 When circumstances so warrant, upon request of the IGD and at the exclusive judgment of the Board of Directors of the CBR, it may, for each requirement or generally, modify the terms, prior justification of the same.

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Manager of Financial Stability and Public Policies APPROVED BY:
CD-14/2022 of June 30, 2022

7 VALIDITY, DISTRIBUTION AND DISCLOSURE
7.1 These technical standards will enter into force on July 1, 2022.
7.2 The Board of Directors of the CBR will keep a copy of these technical standards and deliver the original to the Risk and Strategic Management Department. Likewise, it will deliver an electronic copy to the System Stability Department and authorize the delivery of electronic copies of these technical standards to the following units:
7.2.1 Presidency.
7.2.2 Vice Presidency.
7.2.3 GEFPP.
7.2.4 GOF.
7.2.5 International Management.
7.2.6 Legal Department.
7.2.7 Payments and Values Department.
7.2.8 Financial Department.
7.2.9 International Reserves Management Department.
7.2.10 Compliance Office.
7.3 The Board of Directors of the CBR will send a copy of these technical standards to the IGD, via notification, following the distribution and sending control mechanisms already established.
7.4 The DRYGE is authorized to publish these technical standards in the Administrative Instruments System, for general consultation.
7.5 These technical standards will be disclosed to the different areas involved in the process, under the responsibility of the GEFPP, through the System Stability Department.

8 MODIFICATION CONTROL TABLE
No.
Review
Previous Version
(Identification of
section and content)
Approved Version
(Identification of
section and content)
Approver and
Date

ANNEXES
Annex No. 1
FORMAT TO REQUEST FINANCING FROM THE CENTRAL BANK OF RESERVE San Salvador, XX of XXX of 20XX Doctor, Lawyer, Engineer

---

President
Central Bank of Reserve of El Salvador
Present.
Dear Doctor, Lawyer, Engineer ----------------:
Based on the provisions contained in Article 51 of the Organic Law of the Central Bank of Reserve of El Salvador, Article 179 of the Banks Law, and the Technical Standards for Financing to the IGD for Financial Stability approved by the Board of Directors of the Central Bank of Reserve of El Salvador in Session No. CD-14, dated June 30, two thousand twenty-two, and as President of the IGD (or attorney) , in compliance with the agreement of the Board of Directors/Administration Committee No XXX, taken in session XXXX, of the XXXXXX of the month of XXXXX of 20xx, and considering that the accumulated funds by the IGD to date amount to US$xx, which are not sufficient to fulfill the purpose of Articles 173 and 174 of the Banks Law, I request an amount of US$, (amount in letters)___________________________________________________________ __, for a term of ____ calendar days, for which I present in attachment the documents detailed below:

1. Certification of the Meeting Point in which the agreement of the respective governing body of the IGD is recorded, manifesting its decision to request financing, detailing the amount necessary to cover the purpose of Article 179 of the Banks Law, as well as the signing of the necessary documents, and the guarantees that may be required, in order to pay the deposit guarantee or participate in the restructuring of an entity.
2. Compliance Plan specifying how it will use the resources and how it will generate the necessary income to fulfill the financing payments.
3. Photocopy of the IGD’s Tax Identification Number.
4. Photocopy of the Unique Identity Document of the legal representative or attorney.
5. Certification issued by the legal representative confirming the destination of the funds and the source of funds for payment.
6. Certification of the application of preventive controls for LDA/FT/FPDAM signed by the Compliance Officer.
   Sincerely,

---

Legal Representative or Attorney

ANNEX 2
We: ________________, aged _______________, ___________, residing in San Salvador, with Unique Identity Document number ________________, acting on behalf and in representation, in my capacity as President of the Deposit Guarantee Institute, residing in San Salvador, with tax identification number ______________, which in this instance may be referred to as [Name], or ; and _____________ aged ____________ years, residing in ____________, with unique identity document number ______________________________, acting on behalf and in representation, in my capacity as ______________________ of the CENTRAL RESERVE BANK OF EL SALVADOR, an autonomous public institution of a technical nature, residing in San Salvador, with Tax Identification Number zero six one four zero one zero seven seven four zero zero six two, which in this instrument may be referred to as [Name]; by means of this instrument WE GRANT:
IGD FINANCING CONTRACT
I. OBJECT
The object of this contract is to regulate the financing that the Central Bank grants to the IGD, according to the situations provided for in Art. 179 of the Banks Law, with the objective of ensuring prompt reimbursement to depositors or alternatively participating in a banking restructuring process.
II. AMOUNT AND INTEREST RATE
The Central Bank has approved financing for the IGD of US$, which will generate an interest rate of ____(this rate will be defined at the time of financing authorization).
III. TERM
The term of this financing contract is ________ calendar days. Its maturity will always be on a banking business day.
IV. GUARANTEE
The Financing is guaranteed by a promissory note, issued on this date by ________, in his/her capacity as ______________ which will be backed by a document signed by the President or Chief Executive Officer and certified by the Internal Auditor and External Auditor of the IGD, which forms an integral part of this contract.
V. DISBURSEMENT AND CANCELLATION OF OPERATIONS
The disbursement of resources will be carried out by the Financial Operations Management that the IGD maintains at the Central Bank, and will be effective provided that the Central Bank has received the Promissory Note duly signed according to the format in Annex A. On the maturity date of the financing, the Central Bank will debit via the Real-Time Gross Settlement System (LBTR) the IGD's deposit account and credit the agreed balance, which will include principal, interest, and commissions, to the account indicated for such effect at the Central Bank.
VI. AUTHORIZATION
The Debtor authorizes the Central Bank to, through the Real-Time Gross Settlement System, debit from its deposit account the agreed amount of each payment that will include principal, interest, and commissions; in case of failure to make the payment, proceedings will follow according to this contract.
VII. DEFAULT
In the event that payment is not made by the IGD, or if it does not have sufficient funds in its deposit account at the Central Bank to effect the payment of the operation, it will be considered in default. In that case, proceedings will be initiated to collect the corresponding guarantee when appropriate.
VIII. JURISDICTION AND APPLICABLE LEGISLATION
For the jurisdictional purposes of this contract, the parties submit to the current legislation of the Republic of El Salvador, whose application will be carried out in accordance with the Organic Law of the Central Reserve Bank of El Salvador and the Technical Standards for Financing to the IGD. They also designate as their special domicile this city, submitting to the competence of its courts.
IX. NOTIFICATIONS
All notifications regarding the execution of this contract will be valid only when made in writing to the addresses of the contracting parties, for which purposes the parties designate as the place to receive notifications the following:
a) Deposit Guarantee Institute ______________________ b) Central Reserve Bank of El Salvador, in Juan Pablo II Building, Juan Pablo II Avenue, between 15th and 17th North Avenue, San Salvador.
IN WITNESS WHEREOF WE SIGN, in triplicate, this instrument, in the city of San Salvador, on the _________ day of the month of __________ of the year two thousand XXX ____________________________ ________________________________ Deposit Guarantee Institute Central Reserve Bank of El Salvador

In the city of San Salvador, at __________ hours on the day __________ of _________ of two thousand ____.- Before me, ___________________, notary, residing here, appear, on the one hand, Mr. _______________, aged _______________, _______________, residing in ____________, whom I know, with unique identity document number __________, acting on behalf and in representation, in his capacity as ¬¬¬¬¬ of the DEPOSIT GUARANTEE INSTITUTE, a public institution, of credit, of an autonomous nature, residing in San Salvador, with tax identification number ________________________, and on the other hand ____ ________________________, aged ____________ years, (profession), residing in _________, whom I know, with unique identity document number __________________, acting on behalf and in representation, in his capacity as ___________, of the CENTRAL RESERVE BANK OF EL SALVADOR, an autonomous public institution of a technical nature, residing in San Salvador, with tax identification card number zero six one four zero one zero seven seven four zero zero six two, and THEY SAY: That the signatures placed below the preceding FINANCING CONTRACT are AUTHENTIC, having been placed in my presence by the appearing parties, who in the capacity in which they act recognize them as their own, as well as all obligations, conditions, stipulations contained in the instrument preceding, granted in this city, on today's date, drafted on _________ sheets of bond paper, which I have signed and sealed, in which the appearing parties literally DECLARE _______________ years old, ___________, residing in San Salvador, with unique identity document number ______________, acting on behalf and in representation, in my capacity as ___________________ of the IGD ___________, , public institution, of credit, of an autonomous nature, residing in San Salvador, with tax identification number _, which in this present - aged ____________ years old, residing in ____________, with unique identity document number __________________________, acting on behalf and in representation, in my capacity as ______________________ of the CENTRAL RESERVE BANK OF EL SALVADOR, an autonomous public institution of a technical nature, residing in San Salvador, with tax identification number zero six one four zero one zero seven seven four zero zero six two (or it can be the Vice President or a Special Attorney), which in this instrument may be [Name]; by means of this instrument WE GRANT:
_____________________________________________________________________ .- I BEAR WITNESS: A) To the fact that the signatures accompanying the document preceding are AUTHENTIC, having been placed in my presence by the appearing parties, who furthermore recognized as their own the obligations contained in the same. B) To the fact that the authority with which the _____________ acts, in the character indicated INSTITUTION OF GUARANTEE OF DEPOSITS, is legitimate and sufficient having had to view: 1) ; C) Of being legitimate and sufficient the legal authority with which ________________ appears, (authority representative of the BANCO CENTRAL DE RESERVA DE EL SALVADOR,) Thus the appearing parties expressed themselves, to whom I explained the legal effects of this notarial act, which consists of ____________ sheets and read by me the written content entirely and in a single act without interruption, ratify its content and we sign.- I BEAR WITNESS.- _______________________ _____________________________ Deposit Guarantee Institute Central Reserve Bank of El Salvador

ANNEX 3: PROMISSORY NOTE FORMAT
PROMISSORY NOTE FOR _____________
US$00.00
I, ____________, with Unique Identity Document _____; in my capacity as Legal Representative of the DEPOSIT GUARANTEE INSTITUTE, with tax identification number 0614-010774-006-2, declare that in accordance with what is established in the Financing Contract celebrated with the CENTRAL RESERVE BANK OF EL SALVADOR, my represented entity must and will pay unconditionally to the CENTRAL RESERVE BANK OF EL SALVADOR, the amount of {} (US$), amount equivalent to disbursement No , in the city of San Salvador. The payment will be made in dollars, currency of the United States of America, without any deduction for taxes or for any other cause. It will be charged to my represented entity any expense occasioned by the extrajudicial collection of this promissory note. During the term expiring on the _______ of ____________ of 20, the DEPOSIT GUARANTEE INSTITUTE will pay the CENTRAL RESERVE BANK OF EL SALVADOR annual interests_____________on the sum owed at the rate ________________. The principal will be amortized by means of (monthly/quarterly/semiannual installments). In case of delay, it will pay the CENTRAL RESERVE BANK OF EL SALVADOR a default interest rate consisting of increasing the ordinary interest by _______ percentage points on the portion of capital in default, from the maturity date of the obligation until the date on which payment is made. Any diligence of presentation, protest for lack of acceptance or notice of lack of payment or rejection of this promissory note, are hereby voluntarily and expressly waived. For any action or legal procedure related to this Promissory Note, my represented entity submits to the jurisdiction of the Courts of the Republic of El Salvador, whose competence they accept. San Salvador, on the ______ day of the month of _________ of two thousand ___ FOR THE DEPOSIT GUARANTEE INSTITUTE Name:
Position: