Technical Standards for the Authorization and Operation of Subordinated Private Alternative Investment Funds

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NDMC-39
SUBORDINATED PRIVATE INVESTMENT FUNDS
Approval: 12/17/2025
Validity: 01/02/2026

THE COMMITTEE OF STANDARDS OF THE CENTRAL BANK OF RESERVE OF EL SALVADOR,

CONSIDERING:

I. That Article 5, second paragraph, of the Law on Private Alternative Investment Funds, establishes that it corresponds to the Central Bank of El Salvador, through its Committee of Standards, within its area of competence, to issue the necessary technical standards that allow the operation of PAIFs and Administrative Companies.

II. That Article 12, first paragraph, of the Law on Private Alternative Investment Funds, establishes that prior to the authorization of a fund and until one year after the liquidation of the Administrative Company, the latter must constitute and maintain at all times a guarantee based on the assets of the Alternative Investment Funds it manages, for the benefit of its investors, to guarantee the fulfillment of all its obligations.

III. That Article 29 of the Law on Private Alternative Investment Funds, establishes that the Superintendence will authorize or not the operation of a subordinated PAIF, according to the procedure established in the Technical Standards issued for such effect by the Central Bank of Reserve of El Salvador, through its Committee of Standards.

IV. That Article 30, fifth paragraph, of the Law on Private Alternative Investment Funds, establishes that, upon presentation of the authorization request with the information required by said Law, the Council of the Superintendence of the Financial System will have a period of up to thirty calendar days to review the content of the presented documents and authorize in the same act the constitution and the start of operations of the PAIF.

V. That Article 63, second paragraph, of the Law on Private Alternative Investment Funds, establishes that the Administrative Company and the respective Alternative Funds will be subject to legal provisions on the prevention of money laundering and asset laundering, financing of terrorism and proliferation of weapons of mass destruction, as well as others related to the compliance of their tax obligations or investigation of criminal activities.

THEREFORE,

by virtue of the regulatory powers conferred by Article 99 of the Law on Supervision and Regulation of the Financial System,

NDMC-39
SUBORDINATED PRIVATE INVESTMENT FUNDS
Approval: 12/17/2025
Validity: 01/02/2026

AGREES to issue the following:

TECHNICAL STANDARDS FOR THE AUTHORIZATION AND OPERATION OF SUBORDINATED PRIVATE ALTERNATIVE INVESTMENT FUNDS

CHAPTER I
OBJECT, SUBJECTS AND TERMS

Object
Art. 1.- These Standards aim to establish the requirements and procedures that interested parties must comply with to obtain authorization for the constitution of a Subordinated Private Alternative Investment Fund, as well as for their operation, including provisions for the presentation of requests for authorization of internal regulations and information prospectuses.

Subjects
Art. 2.- The subjects obliged to comply with the provisions established in these Standards are the Administrative Companies of Private Alternative Investment Funds, interested in receiving authorization for the constitution and operation of a Subordinated Private Alternative Investment Fund.

Terms
Art. 3.- For the purposes of these Standards, the terms indicated below have the following meaning:
a) Central Bank: Central Bank of Reserve of El Salvador; b) Quotas: Participation quotas, which express the contributions of participants in a Subordinated Private Alternative Investment Fund, in accordance with Article 27 of the Law on Private Alternative Investment Funds; c) Identity Document: Refers to the Unique Identity Document, Minor's Card, Passport or Resident Card, as applicable; d) PAIF: Private Alternative Investment Funds (PAIF, from its English acronym); e) Sophisticated Investor: In accordance with Article 4 of the Investment Banks Law, these are natural or legal persons, national or foreign, to whom the Administrative Company of Private Alternative Investment Funds or Fixed Capital Investment Company are authorized to offer their services, which must meet the criteria established in said article; f) Board of Directors: Collegiate body or equivalent body, in charge of the administration of the Administrative Company of Private Alternative Investment Funds, with functions of supervision, direction and control; g) Law: Law on Private Alternative Investment Funds; h) Participant: Investor in a subordinated PAIF; i) Subordinated PAIFs: In accordance with Article 3 of the Law on Private Alternative Investment Funds, these are those PAIFs that are formed through the contributions or assets of investors who are delivered to an Administrative Company with the purpose that this manages them exclusively for the benefit of these same investors; j) Information Prospectus: Information prospectus of a subordinated PAIF that contains at least what is established in Article 32 of the Law on Private Alternative Investment Funds; k) Internal Regulation: Document that contains all the specific characteristics and rules that govern the operation of a certain PAIF, in accordance with Article 31 of the Law; l) Administrative Company: Administrative Company of Subordinated Private Alternative Investment Funds; and m) Superintendence: Superintendence of the Financial System.

CHAPTER II
GENERAL PROVISIONS ON SUBORDINATED FUNDS

Constitution of a PAIF
Art. 4.- A subordinated PAIF will be formed by the set of contributions from various investors who will be called participants, which will be administered by an Administrative Company, at the account and risk of the same. The value of the participants' contributions, as well as any type of return they receive, will be directly related to the financial result of the PAIF's assets.

The subordinated PAIF is the exclusive property of the participants, being an independent patrimony different from that of the Administrative Company, which is characterized by a certain level of diversification of its investments according to the investment policies established in the internal regulation.

PAIF Quotas
Art. 5.- Each subordinated PAIF will be expressed in quotas, in order to determine the share corresponding to each of the participants, within its patrimony. When one or more quotas belong in common to several people, the co-owners will be obliged to designate one of them to act on their behalf before the Administrative Company, in the quota contribution contract.

Subordinated PAIF quotas may be fractionated to facilitate their contribution or redemption, being the minimum number of quotas that a participant can have at all times, that established in the internal regulation and in the information prospectus, if so defined.

The value of the quota and the value of the assets of the subordinated PAIF may be calculated using procedures and methodologies established by the Administrative Company, based on international best practices, which they must make known to the Superintendence.

Accreditation of the Sophisticated Investor
Art. 6.- The Administrative Company must have a process that accredits the category of Sophisticated Investors of its interested participants, for which it must consider and document through the means established in Article 33 of the Law.

Due diligence and procedures on prevention and control of money laundering Art. 7.- The Administrative Company must adopt policies, mechanisms and control measures to comply with the obligations established in laws, instructions and current regulations related to the prevention, detection and control of money laundering, terrorism financing and the financing of the proliferation of weapons of mass destruction.

The Administrative Company must have policies and procedures to carry out due diligence for the identification and knowledge of its sophisticated investors, as well as the origin of the funds and their economic activity, in accordance with what is established in laws, instructions and current regulations related to the prevention, detection and control of money laundering, terrorism financing and the financing of the proliferation of weapons of mass destruction.

Identification of participants
Art. 8.- The Administrative Company, for the purposes of marketing its quotas, will be responsible for the identity and legal capacity of the participants, for which it may prepare forms, which may be placed in electronic media defined by the entity, in which the corresponding information for each of the participants will be included, which will contain at least the following information:
a) Place and Date; b) Assigned code; c) Name, nationality, denomination or trade name; d) Tax Identification Number (TIN), which will be in accordance with what is established by the Tax Administration, when applicable; e) Type and number of identity document; f) Address and telephone of residence and office; g) Occupation and place of work; h) Nature or business of the entity, legal representative with their identification documents and respective signature, when applicable; i) Name of the PAIF in which they wish to subscribe to quotas; j) Amount of the contribution; k) Persons authorized to order operations in their name, specifying their general information; l) Method to settle operations in favor of the participant: credit to account, electronic transfer (specify Bank Account No.), issuance of checks; m) Medium (physical or electronic), for sending or consulting the following information: Movements related to the contribution quota or account statements, information related to modifications of the internal regulation, the information prospectus and quota contribution contract, among others; n) Name of the designated beneficiaries, in order that, upon their death, they be delivered to them; o) Other data deemed convenient; and p) Signature of the participant or another means that guarantees their consent.

The Administrative Company must obtain copies of the participant's identity document and Tax Identification Number (TIN), when applicable, and of the persons authorized to order operations in their name, document that accredits the legal representative or attorney-in-fact, the deed of constitution of the legal person and all that information that in the judgment of the Administrative Company must be part of the participant's file, in addition it must have a signature registration form for each of its participants, including for the persons authorized to order operations on behalf of the participant.

Quota contribution contract
Art. 9.- For the purposes of establishing the conditions that will govern the relationship between the participant and the Administrative Company, a quota contribution contract must be prepared for each PAIF it administers, for every participant who acquires quotas of a PAIF for the first time.

The aforementioned contract must be signed by the Administrative Company and the participant, once the identification of said participant has been carried out and their status as a Sophisticated Investor has been accredited. Said contract must contain at least the following information: identification of the Administrative Company and participant; denomination of the PAIF to which the contributions are made; amount of contribution and value of the quota; responsibility and obligations of the Administrative Company with the participant; rights and obligations of the participant; rules that regulate the operation of the PAIF; designated beneficiaries; the indication of the participant who will be responsible in case of co-ownership, when applicable; Commissions and expenses to be charged; Indication on the procedure to resolve controversies; among other aspects that the Administrative Company considers relevant.

In the contract, a clause must be included indicating that the internal regulation and the information prospectus contain the conditions that will govern the Administrative Company in the administration of the PAIF.

Quality of participant
Art. 10.- The quality of participant is acquired when:
a) The participant's contribution is credited to the PAIF's account; b) The accounting transfers of the quotas that are represented in the Administrative Company's records are made; c) The quotas are registered in the name of the beneficiaries in the participant register, in the event of the death of the holder; applying what is established in Articles 7 and 8 of these Standards; or d) Judicial adjudication is carried out.

When the contribution is made by check, it will be considered that the client acquires the quality of participant when the contribution is definitively applied to the PAIF's bank accounts, that is, when the contribution is confirmed.

The quality of participant in a PAIF is lost when they carry out the total redemption of their participation.

Extract of the internal regulation
Art. 11.- The Administrative Company must prepare an extract of the internal regulation, which will be part of the internal regulation. The regulation extract must contain at least the following information:
a) Denomination of the Administrative Company and relevant aspects thereof; b) Denomination of the PAIF; c) Definition of the different categories of participants within the PAIF, if any, and the objective criteria for their classification; d) Investment policy of resources, diversification of investments, liquidity of its assets and indebtedness; e) Commissions that the Administrative Company will charge the PAIF and the participant, expressed as percentages or amounts; f) Expenses that will be charged to the PAIF, detailing their concepts; g) Rules for the subscription and redemption of participation quotas, deadlines for redemption payment, specifying the reasons that give rise to the right to redemption, when applicable; h) Form and periodicity of conversion of contributions and redemption of participation quotas; i) Obligations and rights of participants in the PAIF; j) Information that will be delivered to participants; and k) Other information that the Administrative Company considers important.

Register of participants
Art. 12.- In accordance with Article 34, second paragraph, of the Law, the Administrative company will keep a register of the contributions of participants in subordinated PAIFs, which may be kept through electronic systems, which allow to leave a record of the operations that have an effect on its content and maintain permanent historical information regarding the operations that are registered in said register.

Internal Control in the administration of the PAIF Art. 13.- The Administrative Company, with respect to the administration of PAIFs, must define internal control policies and procedures that contemplate at least the following aspects:
a) Administer separately the PAIFs offered to participants. In each PAIF, the bank accounts used and the cash movements thereof must be specified. The balances of the bank accounts must reflect at the end of the day the balance corresponding to each of the PAIFs, and their bank movements will correspond exclusively to the operations of the PAIF and its participants; b) Reconcile daily in each of the administered PAIFs the balances of values and the associated money, considering for such purposes their internal records and external sources; c) Administer the PAIFs in accordance with what is established in the internal regulation and information prospectus; d) Establish within its procedures the controls that document the receipt of movements related to the contribution quota or account statements that must be sent monthly to each participant physically or electronically according to the request made by the participant, in the case of subordinated PAIFs; e) Establish controls for the identification of contributions and of the participants who make deposits in each Fund; f) Register the operations of the PAIF, in accordance with the accounting policies defined by the Administrative Company; g) Comply with the internal control procedures approved by its Board of Directors regarding the administration of the PAIF, especially with regard to risk management, investments, cash, marketing, calculation of the quota value, conversion of contributions and redemption; h) Have a file for each participant, which contains: identification form with investor information, copy of investor information documentation, quota contribution contract, investor profile, signature registration form with the names and signatures of the persons authorized to issue instructions on behalf of the participant; i) Disclose any essential fact or information regarding the Funds it administers in accordance with what is established in the Law; j) Adopt policies, mechanisms and control measures to comply with the obligations established in laws, instructions and current regulations related to the prevention, detection and control of money laundering and asset laundering, terrorism financing and the financing of the proliferation of weapons of mass destruction; and k) Deliver to participants the documents that prove the contributions or redemptions made, when applicable.

Commissions and expenses
Art. 14.- Administration commissions and other necessary expenses will be charged to each PAIF, and commissions may be established to be charged to participants. Commissions will be expressed as percentages or amounts, and in the case of expenses, their concepts will be clearly detailed, in accordance with Article 18 of the Law.

The Administrative Company cannot charge commissions higher than those established in the internal regulation and in the information prospectus of a PAIF, so the initial commission percentage and any modification thereof must be known to the participant prior to its entry into force.

CHAPTER III
AUTHORIZATION OF PAIFs

Authorization request for the Subordinated PAIF Art. 15.- For the authorization of a Subordinated PAIF, the legal representative or attorney-in-fact of the Administrative Company must present to the Superintendence a request accompanied by the following documentation:
a) Certification of the agreement of the Board of Directors of the Administrative Company, in which the constitution of the PAIF was agreed, as well as the approval of the internal regulation and the information prospectus; b) The Internal Regulation, which must include the minimum content established in Article 31 of the Law; c) Information prospectus of participation quotas, which must include the minimum content established in Article 32 of the Law; d) Project of the documents related to the constitution of the PAIF guarantee according to its nature; e) Certification of the agreement of the Board of Directors of the Administrative Company in which the entity that will be the representative of the beneficiaries of the guarantee is designated; f) Acceptance of the entity as representative of the beneficiaries of the guarantee; g) List of investors or participants who hold a participation equal to or greater than twenty-five percent of the social capital, attaching their general information.

If it is a natural person, they must present the following:
i. Full name;
ii. Nationality and domicile;
iii. Copy of the Unique Identity Document, in the case of Salvadoran persons;
iv. Copy of the Tax Identification Number, which will be in accordance with what is established by the Tax Administration, when applicable;

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NDMC-39
SUBORDINATED PRIVATE INVESTMENT FUNDS
Approval: 12/17/2025
Effective Date: 01/02/2026

v. Certified copy of passport, in the case of foreigners;
vi. Current certificate issued by the General Directorate of Penal Centers stating no criminal record. In the case of foreign shareholders, they must present the document accrediting that they have no criminal record or equivalent, issued by the competent authority in their country of origin;
vii. Information evidencing the source of funds for the acquisition of the shares.

If it is a legal entity, they must present the following information:
i. Name or corporate name;
ii. Nationality and domicile;
iii. Copy of the Tax Identification Number, which shall be in accordance with what is established by the Tax Administration, when applicable;
iv. Annual financial statements of the last three years with their corresponding audit opinions and notes, when applicable. If the company is of recent constitution, it must present at least the Financial Statements of the last fiscal year;
v. Deed of incorporation and bylaws, or creation law, as applicable, in both cases with their reforms and legal representation;
vi. Power of attorney granted to be represented as a shareholder;
vii. Certification of the minute point of the Board of Directors, where the acquisition of shares is authorized;
viii. Information evidencing the source of funds for the acquisition of the shares;
ix. Updated credentials of the Board of Directors of the requesting legal entity.

h) Method of valuation of investments; i) Manual of controls, procedures, and policies for the management of operations carried out in the administration of the PAIFs, personnel, and responsible units that will intervene in said procedures; j) Name of the person(s) designated as investment administrator(s); k) Projections of income and expense flows for the first year of the PAIF; l) Place, email address, and telephone contact to receive any kind of notifications, and the designation of the persons commissioned for such effect; and m) Other documentation and information that, due to the nature of the PAIF, is necessary to present.

The application and documentation may be submitted through the means made available by the Superintendency, which may be electronic. In any case, the period referred to in the first paragraph of Article 16 of these Standards shall begin to run from the next business day after the application has been submitted.

Authorization Procedure

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NDMC-39
SUBORDINATED PRIVATE INVESTMENT FUNDS
Approval: 12/17/2025
Effective Date: 01/02/2026

Art. 16.- Upon receiving the corresponding authorization application with the complete information detailed in Article 15 of these Standards, as applicable, the Superintendency shall proceed to verify compliance with the requirements defined by the Law and these Standards, having a period of up to thirty calendar days to authorize the PAIF.

If the application is not accompanied by the complete and properly submitted information detailed in Article 15 of these Standards, the Superintendency, due to the lack of necessary requirements, may require the applicant to present the missing documents within a period of ten business days counted from the day following the notification, a period that may be extended at the request of the interested entity when there are reasons justifying such extension.

The Superintendency in the same notice shall indicate to the applicant that if the information is not completed within the aforementioned period, the Superintendency shall proceed, without further procedure, to archive the application, leaving their right to submit a new application intact.

If after the analysis of the documentation presented in accordance with Article 15 of these Standards, the Superintendency has observations or when the documentation or information presented is not sufficient to establish the facts or information intended to be accredited as requested, the Superintendency shall notify the respective requesting entity to rectify the deficiencies communicated or present additional documentation or information as required.

The applicant shall have a maximum period of ten business days counted from the day following the notification, to resolve the observations or present the additional information required by the Superintendency.

The Superintendency may, through a reasoned resolution, extend by up to another ten business days, the period indicated in the previous paragraph, when the nature of the observations or notified deficiencies so requires.

Extension Period

Art. 17.- Interested parties may submit to the Superintendency, before the expiration of the period, an application for extension of the period indicated in the fifth paragraph of Article 16 of these Standards, stating the grounds on which it is based and proposing, if applicable, the relevant evidence.

The extension period shall not exceed ten business days and shall begin from the next business day following the expiration date of the original period.

Suspension of the Period

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NDMC-39
SUBORDINATED PRIVATE INVESTMENT FUNDS
Approval: 12/17/2025
Effective Date: 01/02/2026

Art. 18.- The thirty-day period indicated in Article 16 of these Standards shall be suspended for the days that elapse between the notification of the request for information or documentation referred to in the second and fifth paragraphs of Article 16 of these Standards, until the interested parties rectify the observations indicated by the Superintendency.

Once the documents are presented in due form, the Superintendency shall proceed to respond to the authorization request for the PAIF.

Resolution

Art. 19.- Once the complete documentation is presented in due form, the Superintendency shall respond to the authorization request through a resolution. The Superintendency shall notify the interested parties of the corresponding resolution within a maximum period of three business days from the date of issuance, in which it authorizes or denies the authorization, operation, and start of operations of the Subordinated PAIF.

Modification of the Constitutive Documents of the PAIF

Art. 20.- When the Administrative Company intends to modify the internal regulations or the information prospectus, it must submit to the Superintendency an application for authorization of modification to said documents, attaching for such purposes the following documentation:
a) Certification of the agreement authorizing the modification, issued by the corresponding authority; b) Detail of the proposed modifications, including the justification for them, as well as supporting documentation when applicable; and c) Drafts of the documents that require authorization by the Superintendency in which the requested modification proposals will be incorporated.

To evaluate the submitted application, the Superintendency must observe the authorization procedure established in Articles 16, 17, 18, and 19 of these Standards.

CHAPTER IV
OPERATION, ACCOUNTING, AND AUDITING ASPECTS FOR SUBORDINATED PAIFs

Equity of the PAIF

Art. 21.- PAIFs must have, from the moment of their formation, at least the equity and number of participants referred to in the second paragraph of Article 30 of the Law.

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NDMC-39
SUBORDINATED PRIVATE INVESTMENT FUNDS
Approval: 12/17/2025
Effective Date: 01/02/2026

In the event that PAIFs, after their formation, fail to meet the minimum capital requirements established in the second paragraph of Article 30 of the Law at any time, the Administrative Company must communicate this to the Superintendency on the next business day, which may grant a period for compliance, not exceeding one hundred and eighty days.

When the Administrative Company does not resolve the non-compliance indicated in the previous paragraph, it must communicate this to the Superintendency within two business days following the expiration of the granted period, proceeding to liquidation. For the liquidation process of a PAIF, what is established in the Technical Standards issued for such effect by the Standards Committee of the Central Bank must be observed.

Contributions

Art. 22.- Participants in a PAIF may make their contributions in money, national or foreign securities, movable or immovable property, stablecoins, digital assets in general, and any other asset, provided that the Administrative Company establishes or employs a valuation mechanism that allows knowing its value at all times in accordance with internal policies, in accordance with Article 34 of the Law, which shall be expressed through PAIF quotas.

The Administrative Company must define by internal policy the place or means in which the contributions of the respective PAIF will be stored or deposited.

Art. 23.- The Administrative Company must define internal policies and procedures for: redemption of quotas, quota valuation mechanisms, contribution and redemption requests, and computer system for the registration of contributions and redemption payments.

Accounting Records

Art. 24.- It is the responsibility of the Administrative Companies to record the operations of the subordinated PAIF, from the preparation of vouchers, documents, accounting records, and transaction files, to the formulation of Financial Statements and their notes, as well as other reports for their corresponding analysis and interpretation.

Administrative Companies must keep separate accounting for each subordinated PAIF they administer, which is independent of their own accounting.

Timing of Accounting Records

Art. 25.- It is the responsibility of the Administrative Companies to daily account for the transactions carried out by the subordinated PAIFs, which shall be recorded in chronological order and in the accounts whose title corresponds to their nature.

Responsibilities

Art. 26.- The directors, managers, and employees responsible for the preparation,

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NDMC-39
SUBORDINATED PRIVATE INVESTMENT FUNDS
Approval: 12/17/2025
Effective Date: 01/02/2026

review, and authorization of the information, will respond in their personal capacity for the errors, omissions, and irregularities it contains.

Appointment of Auditor

Art. 27.- The Administrative Companies, through the General Meeting or its equivalent directing body, must appoint for each of the subordinated PAIFs they administer, external auditors from internationally recognized audit firms, domiciled or not in the country, considering for this their experience or specialty with the business model and information obligations.

Communication of the appointment of external auditor to the Superintendency

Art. 28.- The Administrative Companies must communicate to the Superintendency, no later than ten business days after the date of appointment, the name of the external auditor selected for each of the subordinated PAIFs they administer, attaching the certification of the minute point of the General Meeting or its equivalent body where it was approved.

Separation or resignation of the external auditor

Art. 29.- The Administrative Companies must inform about the separation or resignation of the external auditor of the subordinated PAIFs they administer, explaining to the Superintendency the reasons for resignation from their position, the intention to do so, or the termination of their contract with the entity that hired them, notification which must be made no later than three business days after the event occurred. In the case of the termination of the contract with the external auditor, indicate the name of the substitute and the date from which the latter will begin their functions. In these cases, notifications must be made no later than three business days after their appointment.

External Audit

Art. 30.- The external auditors appointed for the subordinated PAIFs must carry out the audits considering as a minimum the following aspects:
a) Verification during the accounting period that accounting accounts and economic and operational facts are correctly recorded in their accounting records; b) Carry out the planning, execution, and quality control of the audit; c) Issue a report containing the opinion on the financial statements and their notes, with a detail of the audit results; and d) Issue an independent opinion on whether the financial statements have been prepared, in all material aspects, in accordance with the applicable legal, regulatory, and financial framework for each audited entity, which provides reasonable assurance to users thereof, that they do not contain material errors or omissions.

Attestations

Art. 31.- At the request of the Administrative Company and after a resolution has been issued

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NDMC-39
SUBORDINATED PRIVATE INVESTMENT FUNDS
Approval: 12/17/2025
Effective Date: 01/02/2026

by its General Meeting or its equivalent directing body, external auditors may be designated to carry out their activities in accordance with the criteria established in International Standards on Assurance Engagements 3000, ISAE 3000 Revised, issued by the International Auditing and Assurance Standards Board (IAASB), and report on their conclusions in the context of a certification, known internationally as "Attestations".

Submission of Financial Information and Audit Report

Art. 32.- The Administrative Companies must submit to the Superintendency the financial information of each of the subordinated PAIFs they administer, on June 30 and December 31 of each year, which must be accompanied by the report of the external audit firm or attestations, in accordance with what is established in Article 41 of the Law, which must be submitted within a maximum period of ninety calendar days after the end of each period.

Once the information is presented in due form by the Administrative Companies, the Superintendency must issue a receipt certificate, in accordance with what is established in the third paragraph of Article 41 of the Law.

Publication of Financial Statements of Administrative Companies

Art. 33.- The Administrative Companies must make available to investors through electronic means, and at their request, the financial statements corresponding to June 30 and December 31 of each year, in accordance with the Internal Regulations and other internal documentation of the subordinated PAIFs.

CHAPTER V
GRANTING OF GUARANTEES

Regarding the guarantee

Art. 34.- The Administrative Company must comply, prior to the authorization of a PAIF, with the constitution of a guarantee in accordance with what is established in Article 12 of the Law, which must be updated over time and in accordance with the parameters established in the aforementioned article. The guarantee must be constituted with own resources of the Administrative Company, which may be in cash, bonds, or pledge over securities.

The Administrative Company must establish the events or causes that will be covered by the guarantee and include them in the documents related to the constitution of the PAIF guarantee, according to its nature.

Cash

Art. 35.- When it concerns cash, the Administrative Company must deliver it for custody to the representative of the beneficiaries of the guarantee, and this person may keep it in deposit in an internationally recognized bank, bank, or a cooperative bank, the latter, regulated by the Law of Cooperative Banks and Savings and Credit Societies, provided that it is not part of the financial conglomerate to which the Administrative Company belongs.

The representative has the obligation to keep the received money clearly identified in their accounting, and reveal that it corresponds to the amount received as guarantee for the PAIF in question and that it is exclusively for use to guarantee the compliance of the obligations of the Administrative Company and the events or causes covered by the guarantee. In any case, the bank account used must be a restricted account that identifies the name of the PAIF to which the guarantee corresponds, with authorized signature only by the representative of the beneficiaries.

Bonds or Pledge over Securities

Art. 36.- The securities pledged for the constitution of the guarantee must be deposited with the depository in the name of the representative of the beneficiaries of the guarantee and meet criteria of high liquidity and low risk, which will be defined by internal policies.

Securities that are not represented by book entries must be endorsed in favor of the representative of the beneficiaries of the guarantee and registered in the respective book of the issuer in favor of the representative of the guarantee, when applicable.

For the amount of the guarantee, the market value of the securities constituting it will be considered in accordance with the investment valuation policy of the Administrative Company.

In the event that the amount of the guarantee decreases due to market price fluctuations below what is required by the Law or does not meet the characteristics of high liquidity and low risk that have been required, the Company shall proceed to make a complement or substitution thereof on the next business day after identifying it.

Execution of Guarantees

Art. 37.- When the guarantee of a PAIF is executed, the amount obtained shall be distributed pro rata among the affected participants, considering the percentage represented by the number of quotas of each participant in relation to the equity held on the date on which the event or cause that originated the request for the execution of the guarantee was presented.

Additionally, the Administrative Company must have a procedure for the distribution of the guarantee, which must include among other aspects, such as the following: identification and notification of participants, method of calculation for its distribution, method of making the payment, controls on the delivery of payment to the

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NDMC-39
SUBORDINATED PRIVATE INVESTMENT FUNDS
Approval: 12/17/2025
Effective Date: 01/02/2026

participants.

Representatives of Beneficiaries of the Guarantee

Art. 38.- The designation of the representative of beneficiaries of the guarantee shall be the responsibility of the Administrative Company in accordance with Article 12 of the Law and additionally to the functions established in the aforementioned article, the representative of the beneficiaries will control the expiration date of the guarantees that are under their custody, for such purposes they must inform the Administrative Company about the upcoming expirations of the guarantees thirty business days prior to the expiration date thereof.

Submission of Information to the Superintendency

Art. 39.- The Administrative Company must inform the Superintendency on the next business day after having made any modification to the guarantee, whether in its amount or in its form of constitution, attaching the corresponding documents.

CHAPTER VI
RISK MANAGEMENT FRAMEWORK

Risk management policies and manuals

Art. 40.- The Administrative Company must approve and develop policies to define the management framework for each of the types of risks to which they are exposed, allowing them to reduce their vulnerability and losses from such risks and promote at the entire organization level the culture of prevention and risk management.

For risk management, the Administrative Company must have a continuous and documented process to identify, measure, control, and mitigate, monitor, and communicate the risks to which they are exposed, considering as a minimum what is established in Article 13 letter i), 14, and 19 of the Law.

For the development of the risk management manual, the Administrative Company must consider the implementation of prudential measures and best practices referred to risk management.

CHAPTER VII
OTHER PROVISIONS AND EFFECTIVE DATE

Information retention period

Art. 41.- The information and operations related to the participants of the Subordinated PAIF must be preserved in accordance with the period established in the Special Law for the Prevention, Control, and Sanction of Money Laundering, Financing of Terrorism, and Proliferation of Weapons of Mass Destruction.

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NDMC-39
SUBORDINATED PRIVATE INVESTMENT FUNDS
Approval: 12/17/2025
Effective Date: 01/02/2026

Submission of Information

Art. 42.- The copies presented to the Superintendency, in compliance with what is established in these Standards, must be legible and certified by a Salvadoran Notary. In cases where the copies correspond to the Unique Identity Document (DUI) and the Tax Identification Number (NIT), notarization certification shall not be required.

Likewise, signatures that match any type of documentation issued in El Salvador must be legalized by a Salvadoran Notary.

Notwithstanding the foregoing, if the documentation presented comes from abroad, both the copies and the signatures appearing therein must be authenticated or certified by a foreign notary or official, as applicable, and follow the apostille procedure in the case of countries signatory to the "Hague Convention Abolishing the Requirement of Legalization for Foreign Public Documents", in other cases they must be legalized by the Head of the Diplomatic Mission, Consul, Vice-Consul, or Officer in Charge of Consular Affairs of El Salvador, or in their absence, by officials of the Ministry of Foreign Relations from which such documents originate.

Sanctions

Art. 43.- Non-compliance with the provisions contained in these Standards shall be sanctioned in accordance with what is established in the Law on Supervision and Regulation of the Financial System.

Unforeseen Aspects

Art. 44.- Unforeseen aspects in regulatory matters in these Standards shall be resolved by the Standards Committee of the Central Bank.

Effective Date

Art. 45.- These Standards shall enter into effect from January 2, 2026.