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Item 11 — Quantitative and Qualitative Disclosures About Market Risk
Grupo Supervielle S.a. · 20-F · FY 2025 · Period ended Dec 31, 2025
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Market Risk
Market risk is the risk of loss arising from fluctuations in financial markets variables, such as interest rates, foreign exchange rates and other rates or prices. This risk is a consequence of lending, trading and investments businesses and mainly consists of interest rate risk and foreign exchange risk.
Our market risk arises mainly from our capacity as a financial intermediary.
The Risk Management Committee is responsible for approving and amending our market risk policies.
The Risk Management Committee uses a risk map to explain, in detail, the trades that the trading desk at Banco Supervielle S.A. is authorized to close. The risk map also describes the maximum amounts for the position in certain products, the maximum amount of losses accepted (“stop loss”) and the maximum expected loss (given a confidence interval) over a specific time period if the portfolio were held unchanged over that period (VaR limit). Alongside with the risk of Banco Supervielle S.A., there is a set of additional metrics that establish the market risk of Grupo Supervielle on a consolidated basis with its subsidiaries. Complementarily, the credit committee establishes the credit risk limits with all financial counterparties. Our Financial Risk Department conducts a daily control over compliance with the limits established in the risk map. In the event that an exception is needed, the trading desk must apply for authorization from the CEO while maintaining the Asset and Liability Committee and the Risk Management Committee informed of all developments. In addition, the Risk Management Committee authorizes risk levels in terms of interest rate, foreign exchange rate, inflation and term imbalance risks. The Assets and Liabilities Committee is responsible for monitoring compliance with our market risk policies every two weeks.
In the course of its monthly meetings, our Board of Directors is advised of the full range of resolutions adopted by the Assets and Liabilities Committee, including: liquidity risk, market risk, foreign currency risk and interest rate risk management.
We evaluate, upgrade and improve market risk measurements and controls on a daily basis. In order to measure significant market risks on the trading portfolio, we use the value at risk methodology, or “VaR,” in our internal models. This methodology is based on statistical methods that take into account many variables that may cause a change in the value of its portfolios, including interest rates, foreign exchange rates, securities prices, volatility and any correlation among them. VaR is an estimation of potential losses that could arise from reasonably likely adverse changes in market conditions. It expresses the maximum amount of loss expected (given a confidence interval) over a specified time period, or “time horizon,” if that portfolio were held unchanged over that time period.
All VaR models, while forward looking, are based on past events and are dependent upon the quality of available market data. The quality of our VaR models is therefore continuously monitored. As calculated, for the trading book VaR is an estimate of the expected maximum loss in the market value of a given portfolio over a ten-day time horizon at a one tailed 99% confidence interval. We assume a ten-day holding period and adverse market movements of 2.32 standard deviations as the standard for risk measurement and comparison. Additional information on our risk management is set forth in Note 26 to our audited consolidated financial statements.
The following table shows the Basel Standardized Approach for market risk capital requirement for our combined trading portfolios in 2025, 2024 and 2023 (in thousands of Pesos):
2025 2024 2023
Minimum 15,857,707 9,619,411 2,040,195
Maximum 22,652,742 25,097,082 8,002,553
Average 17,900,107 14,526,102 5,167,841
As of December 31, 16,852,852 25,097,082 7,616,661
Due to regulatory changes, 2024 and 2025 corresponds to the consolidation level of Grupo Supervielle, whose presentation became effective starting in April 2025.
In order to take advantage of good trading opportunities, we have sometimes increased risk; however, during periods of uncertainty, we have also reduced it.
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Interest Rate Risk
Central Bank Communication “A” 6534 amended the way in which the Central Bank evaluates capital needs related to interest rate risk exposure, by the way adapting its methodology to international best practices. Even though Interest Rate Risk is not part of Tier I capital requirements in a direct way, this could be the case whenever the bank reaches the status of “outlier bank.” The “outlier bank” test compares the bank’s ρEVE with 15% of its Tier 1 capital, under a set of prescribed interest rate shock scenarios. Tier I capital requirements will increase by the excess of the bank’s ρEVE over 15% of its Tier 1 capital. Therefore, the Superintendency of Financial Institutions continues to review such risk and determines if there is a need for additional regulatory capital in case a predetermined threshold is surpassed or it finds clear evidence of an inappropriate management of this type of risk. Additionally, the Central Bank establishes the need to measure interest rate risk considering two dimensions: a) the impact of interest rate fluctuations over the underlying value of a bank’s assets, liabilities and off-balance sheet items and hence its economic value and b) the impact over the net interest income. In order to tackle the first dimension, the Central Bank established a Standardized Framework considering the impact of six different shock scenarios over the bank’s ρEVE. To assess the impact over the net interest income, the bank has to make use of its internal measurement systems. See “Item 4.B. Business Overview—Liquidity and Solvency Requirements.”
We define interest rate risk as the risk relating to changes in the entity’s financial income and economic value as a result of fluctuations in the market’s interest rates. The following are known factors that contribute to this risk:
● differences in maturity and adjustment dates of assets, liabilities and off-balance sheet holdings;
● foreseeability, evolution and volatility with respect to local interest rates, foreign interest rates and CET;
● the base risk arising out of an imperfect correlation when adjusting asset and liability rates for instruments with similar revaluation characteristics; and
● implicit options for particular assets, liabilities and off-balance sheet commitments held by the entity.
The Bank employs a prudent interest rate risk strategy allowing to uphold its commitments and maintain desired levels of revenue and capital, both in normal and adverse market conditions.
Interest Rate Risk Management Model – Standardized Framework
The Bank includes interest rate gaps in their interest rate risk management model. This approach analyzes mismatches between asset and liability interest rates between reevaluation periods with respect to the financial statements and off-financial statements line-items. The result is a basic representation of the financial statements structure that allows for the detection of interest rate risk concentrations within the different periods. This is also used to estimate the potential impact of interest rates falling outside of the financial margin (NIM-EaR method) and the entity’s economic value (MVE-VaR method).
Every financial statements and off-financial statements line-item is classified according to its maturity. For asset/liability management accounts without maturity, an internal method of analysis is used to determine possible maturity and sensitivity.
The Asset and Liability Management Committee monitors interest rate risk management and each financial management team is in charge of executing it. The Risk Management team and Financial Planning team are in charge of monitoring compliance, enforcing risk management strategies and issuing periodic reports.
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Interest Rate Risk Capital Requirement
The Bank evaluates its minimum capital requirements relating to interest rate risk through the use of a MVE-VaR internal model, using a holding period of three months and a 99% confidence interval. This quantitative model factors in the economic capital required for our securitization risk. The results are then compared with those obtained from the application of the Standardized Framework, being the resulting capital need the higher of those figures. The following chart shows the Bank’s interest rate risk figures under the Standardized Framework described above for 2025, 2024 and 2023 (in thousands of Pesos):
2025 2024 2023
Minimum 44,350,202 9,815,117 6,854,663
Maximum 84,754,133 51,600,752 27,883,059
Average 66,914,008 32,388,983 13,967,154
As of December 31, 79,443,869 44,796,819 27,883,059
The Bank’s consolidated gap position refers to the mismatch of interest-earning assets and interest-bearing liabilities. The following tables show the Bank’s consolidated exposure to a positive interest rate gap, in Pesos:
Remaining Maturity at December 31, 2025
Over 5
0-1 Year 1-5 Years Years Total
(in thousands of Pesos, except percentages)
Interest-earning assets
Investment Portfolio(1) 1,230,064,189 11,449,498 — 1,241,513,687
Loans to the non-financial public sector(2) 8,394,201 — — 8,394,201
Loans to the private and financial sector(2) 2,426,104,027 428,505,405 32,676,689 2,887,286,121
Receivables from financial leases 46,694,330 45,228,091 5,204,727 97,127,148
Other assets 329,268,341 — 1,041,475,677 1,370,744,018
Total interest-earning assets 4,040,525,088 485,182,994 1,079,357,093 5,605,065,175
Interest-bearing liabilities
Savings 1,324,885,153 — 988,459,281 2,313,344,434
Time deposits 1,071,963,418 — — 1,071,963,418
Non subordinated notes — — — —
Liabilities with financial institutions 413,060,149 3,197,103 213,860,955 630,118,207
Other liabilities 563,526,471 — 166,436,594 729,963,065
Total interest-bearing liabilities 3,373,435,191 3,197,103 1,368,756,830 4,745,389,124
Asset/liability gap 667,089,897 481,985,891 (289,399,737) 859,676,051
Cumulative asset/liability gap 667,089,897 1,149,075,788 859,676,051
Cumulative sensitivity gap as a percentage of total interest-earning assets 16.5 % 236.8 % 79.6 %
(1) Includes government securities and instruments issued by the Central Bank.
(2) Loan amounts are stated before deducting allowances for loan losses.
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The table below shows the Bank’s consolidated exposure to an interest rate gap in foreign currency:
Remaining Maturity at December 31, 2025
Over 5
0-1 Year 1-5 Years Years Total
(in thousands of Pesos, except percentages)
Interest-earning assets in foreign currency
Investment Portfolio(1) 136 49 — 185
Loans to the non-financial public sector(2) — — — —
Loans to the private and financial sector(2) 470 50 (2) 518
Receivables from financial leases 1 2 — 3
Other assets 136 — 445 581
Total interest-earning assets 743 101 443 1,287
Interest-bearing liabilities in foreign currency
Savings 393 — 399 792
Time deposits 374 5 — 379
Subordinated notes — — — —
Liabilities with financial institutions 343 5 — 348
Other Liabilities 1 1 5 7
Total interest-bearing liabilities 1,111 11 404 1,526
Asset/liability gap (368) 90 39 (239)
Cumulative asset/liability gap (368) (277) (238)
Cumulative sensitivity gap as a percentage of total interest-earning assets (50) % (273) % (54) %
(1) Includes government securities and instruments issued by the Central Bank.
(2) Loan amounts are stated before deducting allowances for loan losses.
Foreign Currency Risk
The Risk Management Committee is responsible for deciding the net position in foreign currency to be maintained at all times according to market conditions and monitoring it regularly.
Policies regarding foreign currency risk are applied at the level of our subsidiaries. Our foreign currency risk arises mainly from our operations in our capacity as a financial intermediary.
Since May 2003, the fluctuation of the U.S. dollar has been included as a risk factor for the calculation of the market risk requirement, considering all assets and liabilities in U.S. dollars. As of December 31, 2025, the Bank’s consolidated total net asset foreign currency position subject to foreign currency risk was Ps.23,878 million, and this position generated a market risk capital requirement of Ps.1,910.2 million as of such date.
Liquidity Risk
Policies regarding liquidity risk are applied at the level of our subsidiaries. Our liquidity risk arises mainly from the operations of the Bank. Our other subsidiaries are also subject to liquidity risk, which is not significant.
The Bank defines liquidity risk as the risk of having to pay additional financial costs due to an unexpected need for liquidity. This risk arises out of the differences in amounts and maturity of the assets and liabilities held by the Bank. There are two types of Liquidity Risk:
● Funding Liquidity Risk, which results from the inability to obtain funds at market price that are needed to ensure liquidity, mainly due to the market’s perception of the Bank.
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● Market Liquidity Risk, which occurs when the Bank cannot trade its position in one or several assets at market price, which is caused by two factors:
o the assets are not sufficiently liquid and cannot be traded in the secondary market; and
o changes in the market where the assets are traded.
To manage liquidity risk, the Bank focuses on its sources of liquidity. The Bank relies on certain financial products that can provide a quick source of liquidity in extreme situations of illiquidity. To this effect, the Bank relies on the control of core metrics, the LCR, the NSFR, Daily liquidity, Broad liquidity in Pesos, and liquidity in U.S.$. The first one, with a shorter-term perspective, is aimed at assessing the availability of enough liquid assets to meet the withdrawal of deposits and other liabilities in a 30-day stress scenario. Meanwhile, the NSFR aims to promote resilience over a longer time horizon by creating incentives for banks to fund their activities with more stable sources of funding on an ongoing basis. Daily Liquidity measures Banco Supervielle's ability to finance its institutional deposits that may be canceled the following day (interest-bearing checking accounts and early redeemable term deposits) with available funding sources within that same time frame. Broad Liquidity in Pesos measures Banco Supervielle's ability to finance its peso deposits with liquid assets in that currency: available funds, Lefi, and Treasury bonds, weighted at 10%. Liquidity in Dollars measures Banco Supervielle's ability to finance its dollar deposits with liquid assets in that currency: available funds and Treasury bonds, weighted at 30%.
The Bank relies on a set of indicators that allow it to detect and take steps to prevent potential liquidity risks. The Bank’s set of indicators and risk limits are established by the Risk Management team and approved by the Board of Directors. These indicators are constantly monitored by the Risk Management Committee.
The Risk Management Committee coordinates and supervises the identification, measuring and monitoring of liquidity risk. The Assets and Liabilities Committee develops the strategies that allow for adequate liquidity risk management. The Assets and Liabilities Committee relies on several different departments within the Bank to develop and enforce these strategies, from issuing reports and risk management proposals to monitoring compliance with the established limits.
Operational Risk
We define operational risk as the risk of loss resulting from inadequate or failed internal processes due to personnel, systems or external events. The definition includes legal risk but excludes strategic and reputational risk. Legal risk can result from internal or external events and includes exposure to sanctions, penalties or other economic consequences that arise out of non-compliance with contractual or regulatory obligations.
We believe that we are pioneers in the design of operational risk management frameworks in Argentina, placing emphasis on risk identification, risk management policies and our organizational model. We have tailored our framework to the requirements established by the Central Bank, the Basel accords and international best practices. The Bank’s operational risk management processes are overseen by a correspondent, who is assisted by a network of risk, and every branch and service center has a delegate in charge of monitoring risk. The correspondents report to the Operational Risk Department, ensuring that the Bank’s entire network is working together to monitor operational risk.
Operational Risk Measuring Models
The risk management process is based on complying with several stages designed to evaluate the Bank’s vulnerability to operational risk events, minimizing operational risk. This method allows the Bank to achieve a better understanding of its operational risk profile and adopt the necessary measures to address any vulnerability. The stages are divided into:
● Identification of operational risk by implementing a Risk Control Self-Assessment model, which applies to each one of the Bank’s processes and IT assets.
● Measurement and evaluation of operational risk by establishing risk levels, evaluating the effectiveness of control mechanisms and determining residual risk for each of the Bank’s processes and IT assets.
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● Mitigation, resulting from the application of plans of action and strategies designed to maintain risks within the levels established by the Board of Directors.
● Monitoring to quickly detect and address deficiencies in the policies, processes and procedures for managing operational risk, and to ensure constant improvement.
● Documenting the incidents and losses related to operational risk by establishing a database that allows for a comparison of the frequency and impact of operational risk events with the risk control self-assessment model.
● The Bank and other subsidiaries of Grupo Supervielle, have Operational Risk Committees that are in charge of the enforcement of the operational risk policies and monitors the operational risks and operational risk events affecting the different companies. In addition, the Operational Risk Committee issues reports to the high management, Risk Management Committee and Board of Directors.
● Banco Supervielle S.A. has adopted a model that calculates (i) expected and unexpected losses, (ii) VaR (at a 99.9% confidence interval) minus accounting prevision for operational risk and (iii) the minimum capital required to cover expected and unexpected losses. The holding period used is one year.
Item 12. Description of Securities Other Than Equity Securities
Item 12.A Debt Securities
Not applicable.
Item 12.B Warrants and Rights
Not applicable.
Item 12.C Other Securities
Not applicable.
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