We are a financial group with a long-standing presence in the Argentine financial system and a leading competitive position in certain attractive market segments. We are controlled by Julio Patricio Supervielle. We trace our history back more than 130 years, when the Supervielle family, predecessors of our controlling shareholder, first entered the Argentine financial services industry in 1887. Below is a brief history of our company, including the participation of the Supervielle family.
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Supervielle y Cía. Banqueros
The predecessors of our controlling shareholder emigrated from France in the second half of the 19th century and established L.B. Supervielle y Cía. Banque Francaise (later Banco de Montevideo S.A.) in Montevideo, Uruguay. In 1887, they established Supervielle y Cía. Banqueros (a subsidiary of L.B. Supervielle y Cía. Banque Francaise) in Buenos Aires. Supervielle y Cía. Banqueros offered demand deposits, time deposits, savings accounts, securities trading orders, purchases and sales of foreign currency and drafts and letters of credit payable in European financial centers. Luis Bernardo Supervielle managed the bank until his death in 1901, whereupon the bank’s management transferred to his son, Luis Supervielle, and subsequently to Esteban Barón, son-in-law of Luis Bernardo Supervielle, who in 1905 became president of Supervielle y Cía. Banqueros. Mr. Barón managed the bank from 1905 until 1930, and subsequently served on the board of the bank as an honorary president until 1964. Mr. Barón’s son, Andrés Barón, joined the bank in 1925 and took over its general management in 1930, also becoming chairman of the board of the bank in 1940. He carried out these functions until 1964, and then served on the board of the bank as an honorary president.
On December 30, 1940, Banco Supervielle de Buenos Aires S.A., a bank controlled by the Barón and Supervielle families, acquired the assets and liabilities of Supervielle y Cía. Banqueros and listed its shares on the Buenos Aires Stock Exchange. Esteban Barón and his son, Andrés Barón Supervielle, continued to manage the operations of this bank until 1964.
In 1964, Société Générale (Paris) acquired a majority of the capital stock of Banco Supervielle de Buenos Aires S.A. from the Barón and Supervielle families, transforming it into a universal bank with 60 branches and a significant presence in the corporate market. Following the acquisition of control by Société Générale, the Supervielle family had no role in the management of Banco Supervielle. In 1997, Banco Supervielle de Buenos Aires S.A. created Société Générale Asset Management Sociedad Gerente de FCI S.A. In March 2000, the name Banco Supervielle de Buenos Aires S.A. was changed to Banco Société Générale S.A.
Banco Banex S.A.
In 1969, Jules Henri Supervielle, the father of Julio Patricio Supervielle, our controlling shareholder, and cousin of the Supervielle family members who had owned and managed Banco Supervielle de Buenos Aires S.A. until 1964, founded Exprinter de Finanzas S.A., which became Exprinter Banco S.A. in 1991. On July 15, 1996, Exprinter Banco S.A. acquired 100% of the capital stock of Banco San Luis S.A. pursuant to a public bidding process organized by its owner, the Province of San Luis. The acquisition was part of a strategic plan aimed at growing in the interior of Argentina and penetrating the retail and the SMEs segments. In 1998, Exprinter Banco S.A. and Banco San Luis S.A. merged to create Banco San Luis S.A. Banco Comercial Minorista, and was later renamed Banco Banex S.A. In 2001, Banco Banex S.A. acquired several branches of Banco Balcarce S.A.
Creation of Holding Company
Grupo Supervielle was incorporated in the City of Buenos Aires in 1979, under the name Inversiones y Participaciones S.A., changing the name to Grupo Supervielle S.A. in November 2008.
Acquisition of Banco Société Générale S.A. by Banco Banex S.A.
In March 2005, the Central Bank approved the purchase by Banco Banex S.A. of a majority stake in Banco Société Générale S.A., Supervielle Asset Management Sociedad Gerente de FCI S.A. and Sofital. Upon consummation of this acquisition, Banco Société Générale S.A.’s corporate name was changed to Banco Supervielle S.A. At the time of the purchase, the total assets of Banco Banex S.A. were 61.3% of the total assets of Banco Societé Générale S.A.
Merger of Banco Banex S.A. and Banco Supervielle S.A.
In July 2007, with the prior approval of the Central Bank, Banco Banex S.A. merged into the Bank.
Acquisition of Banco Regional de Cuyo S.A.
In September 2008, the Bank finalized the acquisition of 99.94% of the capital stock of Banco Regional de Cuyo S.A. The Banco Regional de Cuyo S.A. merged with and into the Bank in November 2010.
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Acquisition of IUDÚ
In August 2011, Grupo Supervielle and the Bank acquired 5% and 95%, respectively, of the capital stock of GE Compañía Financiera S.A., a financial services company that specialized in credit cards, personal loans and the distribution of third-party insurance products. In August 2011, the shareholders of IUDÚ Compañía Financiera approved the change of its corporate name from GE Compañía Financiera S.A. to Cordial Compañía Financiera S.A.
On November 2, 2020, the shareholders of IUDÚ Compañia Financiera S.A. approved the change of its corporate name from Cordial Compañía Financiera S.A. to IUDÚ Compañía Financiera S.A. This corporate name change was registered with the Argentine Central Bank on April 19, 2021.
On December 14, 2022, the Bank, as the absorbing entity, and Tarjeta Automática S.A. and IUDÚ Compañia Financiera S.A., as the absorbed entities, entered into merger agreements, pursuant to which Tarjeta Automática S.A. and IUDÚ Compañia Financiera S.A. merged into the Bank effective as of January 2023. On December 1, 2023, the Central Bank approved these mergers. The mergers allowed us to simplify the Group’s corporate structure and complete the Group’s corporate integration plans which began in September 2022.
Creation of Espacio Cordial de Servicios S.A.
In October 2012, our Board of Directors approved the creation of ECM S.A., which was later renamed Espacio Cordial de Servicios S.A. Cordial Servicios is an entity created to sell non-financial products and services, such as insurance plans and coverage, tourism packages, health insurance and health services, electric appliances and furniture, insurance mechanisms and plans and alarm systems.
Acquisition of Supervielle Seguros S.A.
In February 2013, we and Sofital accepted an offer for the acquisition of 100% of the shares of an insurance company named Aseguradores de Créditos del Mercosur S.A. In June 2013, 95% of the shares of Aseguradores de Créditos del Mercosur S.A. were transferred to us and the remaining 5% of the shares were transferred to Sofital. In October 2013, Aseguradores de Créditos del Mercosur S.A. was renamed Supervielle Seguros S.A.
International IPO in May 2016
Since May 19, 2016, the ordinary Class B shares of Grupo Supervielle S.A. are listed on ByMA, and its ADSs, each of which represents five ordinary Class B shares, are listed on the NYSE under the ticker “SUPV.” At the time, Grupo Supervielle made an initial public offer of its Class B shares in Argentina and of its ADSs in the international markets for an aggregate amount of U.S.$323 million. Through the offering, Grupo Supervielle placed 146,625,087 ordinary Class B shares, of which 137,095,955 were placed internationally in the form of ADSs. In the offering, 114,807,087 were newly issued ordinary Class B shares while 31,818,000 were sold pursuant to a secondary offering.
Capitalization of an in-kind contribution and resulting capital stock increase
At the ordinary and extraordinary shareholders’ meeting of Grupo Supervielle in 2017, the shareholders of Grupo Supervielle approved the capitalization of an in-kind contribution of 7,672,412 shares of common stock of Sofital made by Mr. Julio Patricio Supervielle and an increase of the capital stock of Grupo Supervielle through the issuance of up to 8,032,032 new Class B shares. In connection with the capital increase, a total of 7,494,710 new Class B shares were subscribed as follows: (i) 4,321,208 were issued to Mr. Julio Patricio Supervielle in return for the in-kind contribution, representing 57.7% of the total capital increase, and (ii) 3,173,502 Class B shares were issued to existing shareholders of Grupo Supervielle who exercised their preemptive and accretion rights with respect to the capital increase, representing 42.3% of the total capital increase.
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Successful completion of follow-on and capital increase
In September 2017, Grupo Supervielle made an increase of capital stock through an offer of Class B shares. Simultaneously with the offer, Grupo Supervielle made an offer of preemptive and accretive rights of Class B shares to existing shareholders. As a result of the offer, Grupo Supervielle issued a total of 85,449,997 new Class B shares for a total of U.S.$344 million.
Creation of Fideicomiso Financiero Fintech Supervielle I
In 2018, our Board of Directors approved the creation of Fideicomiso Financiero Fintech Supervielle I to invest in financial technology (fintech) and insurance technology (insurtech) start up projects in an amount up to U.S.$3 million. The Fideicomiso Financiero Fintech Supervielle I has made investments with minor participations in the following start-up projects since its creation: 123Seguro, Increase, Avancargo, Blended, SixClovers and Lemon Cash. The Fideicomiso Financiero Fintech Supervielle I is financed by Grupo Supervielle and the Bank. On July 15, 2022, the Fideicomiso Financiero Fintech Supervielle I entered into a limited partnership agreement with Alaya Capital Partners III LP pursuant to which the Fideicomiso Financiero Fintech Supervielle I made a contribution of all its participations in the aforementioned start-up projects to Alaya Capital Partners III LP. In October 2025, our Board of Directors approved the early termination and liquidation of the Fideicomiso Financiero Fintech Supervielle I, and Grupo Supervielle became the direct holder of the capital stock of Alaya Capital Partners III LP.
Acquisition of Micro Lending S.A.U.
In May 2018, Grupo Supervielle acquired 100% of the share capital of MILA. MILA specializes in car financing, particularly in used cars.
Acquisition of the capital stock of InvertirOnline S.A.U. and InvertirOnline.com Argentina S.A.U. (renamed as Portal Integral de Inversiones S.A.U.)
In May 2018, we acquired the capital stock of the online trading platform IOL invertironline through the purchase of InvertirOnline S.A.U. and InvertirOnline.com Argentina S.A.U. In July 2021, the platform was renamed IOL invertironline. On April 19, 2022, InvertirOnline.com Argentina S.A.U. was renamed as Portal Integral de Inversiones S.A.U.
On May 14, 2024, Grupo Supervielle transferred all the shares of InvertirOnline S.A.U. and Portal Integral de Inversiones S.A.U. to IOL Holding. On May 15, 2024, Grupo Supervielle made a capital contribution to IOL Holding in cash in the amount of U.S.$7.7 million.
Conversion of Class A shares
In April 2019, as requested by Mr. Julio Patricio Supervielle, our Board of Directors authorized the conversion of 65,000,000 Class A shares, with a par value of Ps.1.00 each and entitled to five votes per share, held by Mr. Supervielle, into Class B shares, with a par value of Ps.1.00 each and entitled to one vote per share, pursuant to Section 6(b) of our bylaws.
Bolsillo Digital S.A.U.
In June 2019, we created Bolsillo Digital S.A.U., a fintech which operated in the sector of means of payment. In August 2021, Grupo Supervielle transferred its shares of Bolsillo Digital S.A.U. to its subsidiary Banco Supervielle S.A. as part of its strategy within the sector of means of payment. Bolsillo Digital S.A.U.’s main activity until 2022 was to provide payment services under its brand Boldi (“Boldi”). In February 2023, the Boldi app was permanently closed. On March 30, 2026, the shareholders of Bolsillo Digital S.A.U. approved the early dissolution of the company and the commencement of its liquidation process pursuant to Section 94, subsection 1, of the Argentine General Companies Law. As from that date and until its deregistration, the company operates under the name Bolsillo Digital S.A.U. (in dissolution).
Creation of Supervielle Productores Asesores de Seguros S.A.
In December 2018, we created Supervielle Productores Asesores de Seguros, which has the exclusive purpose of carrying out the insurance intermediation activity, promoting the contracts of life insurance, wealth and pension insurance premiums, and advising
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customers and potential customers. Grupo Supervielle owns more than 99% of its share capital, directly or indirectly. Supervielle Productores Asesores de Seguros began operating in the second half of 2019.
Acquisition of Futuros del Sur S.A. (renamed as Supervielle Agente de Negociación S.A.U.)
In December 2019, Supervielle acquired 100% of the share ownership of Futuros del Sur S.A., a brokerage firm seeking to broaden the investment and financial services it provides to institutional and corporate customers and also drive efficient and profitable cross selling. On January 24, 2022, Futuros del Sur S.A. changed its corporate name to Supervielle Agente de Negociación S.A.U.
Acquisition of the capital stock of IOL Holding S.A. and IOL Agente de Valores S.A.
In August 2021, Grupo Supervielle acquired 95% of the shares of IOL Holding, a company incorporated in Uruguay. Sofital acquired the remaining 5% of the shares of IOL Holding.
In August 2021, IOL Holding acquired 100% of the shares of IOL Agente de Valores S.A., a company incorporated in Uruguay which is expected to provide security dealer services. In June 2022, the Central Bank of Uruguay authorized IOL Agente de Valores to act as a security dealer providing services to non-residents of Uruguay. IOL Agente de Valores S.A. is expected to provide its services through an online platform to non-residents of Uruguay who may be based in Latin America and seek to participate in the U.S. capital markets.
On May 14, 2024, Grupo Supervielle transferred all the shares of InvertirOnline S.A.U. and Portal Integral de Inversiones S.A.U. to IOL Holding and the shareholders’ meeting of IOL Holding approved the capitalization of the liabilities arising from the transfer. On May 15, 2024, Grupo Supervielle made a capital contribution to IOL Holding in cash in the amount of U.S.$7.7 million.
Merger of Tarjeta Automática S.A. and IUDÚ Compañia Financiera S.A. into the Bank
In December 2022, the Bank, as the surviving entity, and Tarjeta Automática S.A. and IUDÚ Compañia Financiera S.A., as the absorbed entities, entered into merger agreements, pursuant to which Tarjeta Automática S.A. and IUDÚ Compañia Financiera S.A. merged into the Bank effective January 2023. On December 1, 2023, the Central Bank approved the mergers. These mergers allowed us to simplify the Group’s corporate structure and complete the Group’s corporate integration plans which began in September 2022.
Executive Offices
Our principal executive offices are located at Reconquista 330, Buenos Aires, Argentina. Our general telephone number is +54-11-4340-3100. Our website is http://www.gruposupervielle.com. Information contained or accessible through our website is not incorporated by reference in, and should not be considered part of, this annual report.
We file reports, including our annual reports on Form 20-F, and other information with the SEC pursuant to the rules and regulations of the SEC that apply to foreign private issuers. The SEC maintains an internet site that contains reports, proxy and information statements, and other information regarding issuers that file electronically with the SEC. Any filings we make electronically with the SEC are available to the public over the Internet at the SEC’s web site at http://www.sec.gov.
Our agent for service of process in the United States is CT Corporation System, located at 111 Eighth Avenue, New York, New York, 10011.
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Item 4.BBusiness Overview
Overview
We are a diversified financial services group in Argentina with 1.9 million customers, operating through an integrated ecosystem that connects our diverse financial offerings into a customer-centric experience. We offer a broad range of financial products and services including lending, savings and investments, insurance, payments and cash management services, car loans, and asset management, positioning ourselves as a one-stop destination for financial needs. Our main subsidiaries are the Bank, the seventh largest private bank in Argentina in terms of loans, and IOL invertironline, Argentina’s leading digital retail brokerage platform specialized in online trading and other financial investment services. Other relevant subsidiaries in addition to the Bank and IOL invertironline include: (i) Supervielle Seguros, an insurance company; (ii) Supervielle Productores Asesores de Seguros, an insurance broker; (iii) Supervielle Asset Management, a mutual fund management company; (iv) Supervielle Agente de Negociación, a brokerage firm offering services to institutional and corporate customers; and (v) Micro Lending, a company specialized in car financing. Our vision is to be recognized as the simplest and most agile financial ecosystem in the country, distinguished by the closeness we bring to every experience and by the value we create in the everyday lives of individuals, businesses, and communities. Since May 2016, our Class B shares have been listed on the BYMA and A3 Mercados, and our ADSs have been listed on the NYSE under the “SUPV” ticker.
Our company takes advantage of the following strengths and opportunities:
● We have a dynamic and fully-integrated business ecosystem that delivers end-to-end financial solutions, deepens client engagement and fortifies brand loyalty;
● We have a growing and diversified asset portfolio with a track-record navigating through the different economic cycles;
● We have strong liquidity, solid capital base, and diversified funding sources to support our growth initiatives;
● We have adopted a digitally-enabled, customer-centric approach which enables us to understand better and be closer to our customers’ needs while unlocking growth and operating efficiencies;
● We are leveraging IOL invertironline’s leadership in retail brokerage to drive growth and profitability;
● We are the oldest private franchise in Argentina and we have a recognized presence within the Argentine financial industry, with an experienced Board of Directors and management team;
● We have developed deep expertise and strong competitive positions in several high-impact segments;
● We are positioned to capitalize on Argentina’s financial system recovery;
● We operate in an underpenetrated financial system; and
● Structural conditions support sustainable credit expansion.
Our main shareholder, Julio Patricio Supervielle, has a strong and long-standing commitment to the Argentine financial system. Through his controlling interest in Grupo Supervielle, he plays a central role in shaping our strategic direction. As Chairman of the Board of Directors and CEO of Grupo Supervielle, Julio Patricio Supervielle has led Grupo Supervielle for more than 20 years and is widely recognized for his strategic foresight and transformational leadership. Our Board of Directors is composed of experienced members with deep banking and local expertise, and strong risk management and corporate finance capabilities. Our senior management team has on average over 25 years of experience in the banking sector.
We operate exclusively in Argentina, primarily through the Bank, which serves as our main banking subsidiary, delivering a comprehensive suite of financial services to retail, SMEs and corporate customers through a network of 129 branches across eight provinces and the City of Buenos Aires, a digital and virtual platform, and WhatsApp banking. We believe the Bank maintains a competitive position in several key segments and regions. We have a geographic presence in the City of Buenos Aires and the Greater
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Buenos Aires metropolitan area, Argentina’s wealthiest and most densely populated areas, and in some of the country’s most dynamic economic regions, including Mendoza, the country’s fifth largest province by population, Neuquén, a strategic region driven by the development of the Vaca Muerta shale oil and gas formation, and San Juan, a province with growing relevance due to the development prospects of the mining sector. We deliver agile, digitally-enabled solutions that are informed by customer data and behavioral insights. Furthermore, we offer a range of tailored financial products across our core customer segments, including loans and specialized services for pensioners, where we maintain a leading market position, as well as payroll customers, SME financing, and corporate banking solutions designed to meet the needs of Argentina’s most dynamic sectors. Additionally, we provide access to investment opportunities through IOL invertironline, helping our customers grow their income and savings with innovative tools, and with high potential to cross sell within our bank ecosystem. With a small portion of IOL invertironline’s clients currently banking with the Bank, we recently launched a targeted cross-sell strategy, with a compelling suite of products aimed at deepening relationships and expanding our retail footprint.
As of December 31, 2025, on a consolidated basis, we had:
● 1.9 million customers, including 1.3 million individual bank customers, 26,000 small businesses and SMEs, 2,200 corporate customers, and IOL invertironline’s 565,000 customers;
● 129 bank branches, as well as a branch annex in the municipality of Añelo and another one in the city of San Juan, reflecting our commitments to the oil and gas and mining sectors, respectively;
● Ps.7,769.6 billion (approximately US$5,324 million) in total assets, increasing 31.2% compared to December 31, 2024;
● Ps.3,982.9 billion (approximately US$2,729 million) in loans, increasing 36.9% compared to December 31, 2024;
● Ps.5,118.9 billion (approximately US$3,507.5 million) in deposits, including Ps.4,987.6 billion from the private sector and Ps.131.3 billion from the non-financial public sector, increasing 22.6% compared to December 31, 2024;
● loans market share of 2.8% and deposits market share of 3.0%, according to Central Bank information as of December 31, 2025;
● Ps.985.3 billion (approximately US$675.1 million) in attributable shareholders’ equity, decreasing 6.1% compared to December 31, 2024;
● Ps.3,616 billion (approximately US$2,478 million) in assets under custody through IOL invertironline, increasing 34% compared to December 31, 2024;
● 3,348 employees, decreasing 3.1% compared to 3,456 employees as of December 31, 2024; and
● total capital ratio of 15.4%, of which 100% is common equity Tier 1 capital.
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We see substantial opportunities to continue enhancing cross-selling and collaboration between Banco Supervielle and IOL invertironline. This represents a major opportunity to deepen relationships and expand our financial offerings following the launch of our products Plazo Fijo IOL in March 2025 and Cuenta HIT IOL in September 2025. The following chart illustrates our business ecosystem as of December 31, 2025:
Notes: (1) Last twelve months as of June 30, 2025; and (2) Company estimates and Central Bank information as of December 2025.
Banco Supervielle
Financial Services
We own the seventh largest Argentine private bank, and the ninth largest Argentine bank considering Argentine public banks, in terms of loans. Through the Bank, we serve 1.3 million individual customers, around 23,000 small businesses, 2,800 SMEs and 2,200 middle-market and large corporates, and we maintain a competitive leading position in certain strategic segments.
According to the Central Bank, our share for the following products is as follows:
● total loans: market share in December 2025 was 2.8%, compared to a 2.9% market share in December 2024;
● total deposits: market share in December 2025 was 3.0%, compared to a 2.7% market share in December 2024.
Additionally, based on the latest information published by ANSES, we served approximately 8.6% of all senior citizen social security beneficiaries in Argentina as of September 2025.
Through the Bank, we maintain a strong geographic presence in the City of Buenos Aires and the Greater Buenos Aires metropolitan area, which is Argentina’s most commercially significant and highly populated area, and in some of Argentina’s most dynamic regions, including a leading position in Mendoza.
Moreover, we are continually evolving to offer a hyper-personalized and omnichannel experience. Our infrastructure allows us to reach customers in all parts of Argentina. Our business model combines the efficiencies of a virtual branch with the strength of face-to-face interactions. In 2025, we completed our branch transformation, implementing a new service model and updating our network.
From 2020 to 2025, the percentage of our customers who manage their banking transactions and inquiries through digital or automatic means without the need for human assistance increased from 30% to 93%. Without considering senior citizen customers, digital customers represented 85% of our customer base at year‑end 2025, representing an increase of 2 percentage points compared to
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both 2024 and 2023. This evolution reflects a structural shift in the way our customers interact with the Bank, supported by the consolidation of an integrated digital service model combining our SuperApp, WhatsApp and Virtual Banking. Our SuperApp continued to strengthen its role as the cornerstone of the Bank’s digital ecosystem, integrating payments, services, customer support and access to investment solutions within a single environment. In December 2025, mobile channels accounted for 71% of total customer transactions, as compared to 60% in 2024 and 48% in 2023, with 1.06 million monthly active users. In parallel, the use of digital payment solutions continued to grow. More than 13.5 million digital payments were processed on a monthly basis during 2025, including transactions through MODO, the systemic payment solution for banks in Argentina. We also continued to advance in the digitalization and automation of lending processes, expanding the availability of fully digital and self‑service loan origination across different products and customer segments, supporting higher efficiency, scalability and customer adoption of digital channels.
As of December 31, 2025, we increased our market share of business customers in the small businesses and SMEs segment to 6.66% from 6.37% as of December 31, 2024. In April 2025, we launched the first payroll account and SME accounts that pay interests in Pesos and U.S. dollars on a daily basis. These accounts offer agility, simplicity, and profitability, allowing individuals and SMEs to maximize the return of their money without additional paperwork or management. The Bank positions itself as the only bank in Argentina that pays interests on payroll accounts and SME accounts in Pesos and U.S. dollars.
Insurance
The insurance business is continuously adapting its products to the needs of our customers. We have access to customers through our distribution networks and aim to further develop our bancassurance distribution model by expanding the variety of insurance products offered.
We offer insurance products for individual and corporate customers through our distribution networks. We develop our insurance business primarily through a bancassurance distribution model.
During 2025, we expanded our insurance product portfolio and continued to develop digital and self‑managed channels for policy contracting and customer service. Our insurance offering includes coverage related to life, personal accident, mobility, and everyday risks. In addition, we introduced self‑managed distribution channels within our ecosystem, including digital and automated channels, to facilitate access to insurance products.
At the end of December 31, 2025 we had 396,000 active insurance policies.
Savings & Investments
During 2025, we continued to strengthen our savings and investment proposition, focusing on simplifying the customer experience, expanding access to investment instruments and consolidating the integration of Supervielle’s digital ecosystem. We enhanced Inversión Rápida with a revamped offering aimed at simplifying the investment process while supporting Banco Supervielle’s funding growth. In addition, we introduced direct access to the investment ecosystem of IOL invertironline within our mobile application, enabling customers to trade CEDEARs, stocks, bonds and other instruments in a simple and secure manner. We also relaunched a fully digital experience for the purchase and sale of U.S. dollars, complementing our existing MEP dollar offering, and renewed the digital experience for investing in mutual funds managed by Supervielle Asset Management across all our digital channels. Taken together, these initiatives contributed to the continued evolution of our mobile application into an integrated financial services environment, allowing customers to manage payments, investments and foreign currency transactions within a single digital platform.
As of December 31, 2025, assets under management accounted for Ps.1,162 billion, compared to Ps.1,386 billion assets under management as of December 31, 2024 (measured in historical currency).
Payments
In 2020, we joined Modo as shareholder with the aim of expanding the offer of financial services to our clients throughout the country, integrating technologies that facilitate the use of our applications on mobile devices, allowing them to operate in the digital market for payments and transfers through a systemic solution of the highest quality standard.
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We participate in the MODO digital payments ecosystem with the objective of expanding access to electronic payment and transfer solutions. We have integrated MODO into our mobile applications, enabling our customers to make payments and transfers through digital channels.
Our mobile applications allow customers to make payments using debit cards, credit cards, account‑based payments, and QR codes. During 2025, we incorporated additional payment functionalities into our mobile applications and implemented interoperability features within the MODO ecosystem to enable payments with different instruments.
Mobility Cars
We began developing our mobility car business in 2018 with the acquisition of MILA, a company specialized in car financing. In December 2021, we entered into an agreement to finance the operations of KAVAK, a digital platform for the sale of used cars, which was renewed in 2023.
Through these initiatives, we offer vehicle financing solutions supported by partnerships with digital platforms and specialized operators. We originate car loans through digital and partner‑based channels as part of our retail product offering. In 2025, car loans origination declined during the year, reflecting tighter credit policies designed to increase selectivity in identifying target customers. In 2025, we were positioned third in origination of car loans with a market share of 14%.
Housing
We offer mortgage loan products designed to finance the purchase, renovation, and expansion of housing. During 2025, we continued offering UVA mortgage loans through our distribution channels as part of our housing finance product offering.
Non-financial services and products
Building on our banking sector expertise, we identify cross-selling opportunities and offer targeted products to our customers at each point of contact though our brand Cordial.
Evolution of Technology in Our Value Proposition
During 2025, technology continued to have a strategic role within the Bank, evolving from a model focused on the execution of individual initiatives to an integrated framework that supports business growth, customer experience, operational efficiency, and governance. Our technology ecosystem is based on reusable platforms, shared capabilities, and a product‑aligned architecture, which enables scalable delivery of solutions and greater predictability in supporting business evolution. Portfolio prioritization and management processes were strengthened to better connect business demand with the effective capacity of our teams.
As part of this evolution, we continued to modernize our technological infrastructure and advance the migration of applications, application programming interfaces, and microservices to cloud‑based environments. This process supported the consolidation of simpler and more scalable digital solutions, while strengthening resilience, observability, and business continuity capabilities. In parallel, we progressed toward a multicloud operating model designed to enhance flexibility and risk management.
In connection with these initiatives, we continued to strengthen efficiency and cost‑management practices related to our technology platforms, focusing on optimizing resource utilization and supporting disciplined budget management.
Artificial intelligence was deployed as a cross‑cutting capability across the organization. During the year, we incorporated predictive models, generative artificial intelligence, and intelligent agents into customer‑facing channels, with the objective of improving personalization, operational efficiency, and productivity. This adoption was supported by internal training initiatives, guidelines for responsible use, and the incorporation of AI‑based tools to support technology operations.
The evolution of our digital channels continued toward an integrated, omnichannel experience. We focused on improving the availability, consistency, and scalability of our main digital platforms, combining automated solutions with human assistance when required to enhance customer service and operational effectiveness.
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During 2025, we continued to strengthen the reliability of our digital channels through ongoing modernization initiatives, enhanced monitoring, and contingency and recovery testing, supporting the continuity of critical business processes.
Customer Service Channels
At Grupo Supervielle, we continue to evolve our service model toward an increasingly integrated ecosystem that seamlessly coordinates in-person, digital, and remote channels. This approach allows us to expand access to financial services, adapt to the diverse needs of our customers, and deliver a consistent experience across all touchpoints.
By building on the consolidation of a hybrid model of virtual and in-person service, we are moving towards an operational approach that optimizes the distribution of demand across channels, strengthens operational continuity, and ensures greater consistency in the customer experience. At the same time, this framework allows us to scale our service capacity without affecting closeness, combining operational efficiency with a simpler and more accessible connection for individuals and businesses that bank with us.
This evolution is based on the progressive transformation of the physical network, the expansion of self-service areas, and the strengthening of hybrid roles that integrate in-person and virtual service. In this way, we reinforce a customer-centric model that supports business growth with greater agility, flexibility, and responsiveness.
Distribution Network
In 2025, we continued to strengthen our self-service model, expanding the operational capacity of our Lobby 24 (Espacio 24) spaces, which are spaces within our branches where our customers can make transactions during and after banking hours. The Lobby 24 spaces play a key role in the evolution of our omnichannel approach, facilitating everyday transactions in an agile, independent, and secure manner.
In line with this approach, we are moving forward with the integration of a self-service terminal network, strengthening operational control, equipment availability, and the consistency of the experience across this channel. This decision allows us to manage technological evolution and service quality in a more coordinated manner, aligning self-service capabilities with the comprehensive customer service strategy and aiming to support customers in their daily operations through simple and accessible experiences.
Digital Experience
Digital experience continues consolidating as a core component of our relationship with individual and business customers. The growing adoption of non-face-to-face channels shows a structural shift in the way people interact with the Bank, with a greater emphasis on self-service, mobility, and the permanent availability of services. In this context, we continue to evolve our digital platforms to offer simpler, more secure, and more consistent interactions throughout the entire customer journey.
SuperApp, Chat and Virtual Banking
In 2025, we continued implementing our SuperApp strategy as the cornerstone of the Bank’s digital ecosystem, integrating the highlights in our customers’ financial lives, including savings and investment, spending and benefits, and customer services, into a single environment. This evolution allowed us to align functionalities, our commercial offer and service models under a unified vision, providing a more consistent, simpler, and more secure experience throughout the entire digital journey.
Within this framework, the Bank’s WhatsApp chat service became the primary digital contact channel, leveraging generative AI to resolve queries and enable self-service options in an agile and scalable manner, with referral to customized support where needed. This channel is integrated into the Bank’s digital ecosystem, enhancing the experience and efficiency in handling queries from our customers.
Our SuperApp includes Virtual Banking, a remote service model that integrates various digital channels (including video calls and WhatsApp) with the support of specialized agents for solving more complex transactions. This system allows for a combination of self-service, assisted service, and customized support within a single user experience, seamlessly integrating remote channels and the physical network.
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In addition, we continued evolving our online banking and mobile banking platforms, with improvements aimed at offering increasingly simple, user-friendly and secure interactions, and reinforcing their role as the transactional basis of the digital relationship with our customers.
Business Customers
During 2025, we consolidated our business customers app as a key digital channel within the segment. The application features a robust security system, including soft tokens, biometrics, and other critical functionalities, strengthening mobile operations and ensuring appropriate data protection standards.
In the Business Customers segment, we continued to drive the evolution of our digital ecosystem by implementing interest-bearing account offerings both in online banking and the mobile app. Additionally, we are making progress in continuously improving the design and user experience, incorporating a simpler, clearer, and more personalized homepage with dynamic shortcuts and new features designed to optimize navigation and promote self-service within the digital channel.
We continued to strengthen our value proposition for the Business Customers segment, integrating digital solutions that enhance operational efficiency, security, and autonomy in financial management.
IOL invertironline
In 2025, IOL invertironline had more than 2 million open accounts, more than 24 million transactions were carried out by IOL invertironline customers. In addition, IOL invertironline maintained a base of 565,000 active customers (last 90 days) and its assets under custody exceeded Ps.3,616 billion representing a 34% year‑on‑year increase. During 2025, through IOL Asset Management, IOL invertironline expanded its offering of mutual funds, highlighting IOL Dólar Ahorro Plus and IOL Portafolio Potenciado, and added the development of IOL Cash Management towards. As of March 31, 2026, more than 10,000 customers of IOL invertironline opened accounts at the Bank and placed time deposits in U.S. dollars. In addition, IOL invertironline relaunched its U.S. account operations with simplified products, facilitating international diversification for its users. It also strengthened its federal expansion strategy, consolidating its commercial presence in the Argentine provinces of Córdoba, Mendoza, Rosario, Tucumán and Neuquén, with a focus on the development of Vaca Muerta. This broader reach supported the growth of both the Wealth Management and Business Banking segments, supported by the creation of a new trading desk aimed at optimizing execution for sophisticated portfolios and enabling new transactional revenue streams. These initiatives contributed to consolidating Grupo Supervielle as an integrated digital financial services platform, expanding its reach beyond the traditional banking model.
Our Vision and Strategy
We believe that 2024 was a year of significant transformation for us and for the Argentine financial system. Fueled by macroeconomic and policy changes and a surge in financing activity that has continued into 2025, although slowing down, as of December 31, 2025 we increased private-sector loans by 172% since March 2024, outpacing the financial system’s 141% growth. In parallel, we reduced our exposure to government and Central Bank’s securities, creating a leaner and healthier balance sheet primed for long-term sustainability and growth.
Our growth strategy focuses on delivering differentiated value propositions that we believe enable us to compete with fintechs, while creating unique customer-centric, personalized, and digital advantages that are not easily replicable by universal banks. A core component of this approach is strengthening our capabilities in funding and payroll customers to become the primary financial institution for a greater number of customers while also reinforcing our leadership position in pensioner banking, a historically strong segment for us. We are expanding our presence in resource-rich sectors, including oil and gas and mining, sectors which we believe will drive substantial long-term opportunities as foreign investment returns to Argentina. Our strategy for the Bank focuses on scaling high impact, segment-specific solutions, such as dual currency remunerated accounts for payroll and SME clients, service channels powered by AI, and integrated offerings through IOL invertironline, which we believe allow us to compete with digital-native platforms and universal banks by combining speed, personalization and trust. Additionally, we expect that IOL invertironline will play a growing role in our business by crystallizing cross-selling opportunities with the Bank, expanding its product offering and capturing the growing opportunities in Argentina’s financial markets.
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We have prioritized our digital-first culture over the past five years. We have migrated the majority of our applications and APIs to cloud platforms, unified digital channels, and embedded AI analytics into underwriting and service workflows.
We are committed to maintaining a solid profitability base and to driving sustainable growth, while reinforcing our corporate culture as key drivers of our strategy. We believe we are well-positioned to enhance our shareholders’ value while expanding our role in Argentina’s evolving financial landscape by building upon our solid foundation and capitalizing on emerging opportunities.
Given Argentina’s evolving macroeconomic environment, which is expected to be characterized by declining inflation and nominal interest rates, together with the resumption of economic activity following the outcome of the recent mid-term elections, we have redefined our commercial strategy to capitalize on these trends and position the Bank for the economic acceleration that is expected in Argentina in the incoming years, according to the Market Expectations Survey published by the Central Bank.
Our Strategic Growth Priorities
We are expanding our presence in high-growth industries and value chains, including oil & gas and mining, where Argentina’s resource wealth presents substantial long-term opportunities. Additionally, we expect that IOL invertironline will play a relevant role in our profitability by expanding its product offering and capturing the growing opportunities in Argentina’s financial markets, which we expect that will enhance our presence across retail, wealth, and SME segments.
We believe consumer demand will resume credit expansion in the coming quarters driven by a stabilization of asset quality, creating a unique window to reaccelerate loan growth. To capture this opportunity, we expect to optimize our portfolio mix towards higher-margin retail lending while maintaining capital efficiency and profitability. Our capital allocation strategy is designed to support balance sheet growth while upholding strong risk management discipline.
Our differentiated business model is focused on maximizing profitability and long-term value creation. By maintaining industry-leading net interest margins (“NIM”), improving ROE, and optimizing capital efficiency through fee-based income expansion and cost rationalization, we are well-positioned to generate sustainable capital, supporting continued growth and reinforcing our competitive position in the Argentine financial sector.
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Banco Supervielle’s Strategy
Our corporate structure enabled us to achieve operational efficiency and to make fast decision-making processes, allowing us to swiftly adapt to market dynamics and enhance customer service. Additionally, the Bank is implementing a comprehensive risk assessment framework to ensure that all customers have access to a credit offering, thereby driving cross-sell opportunities, deepening customer relationships, and fostering growth.
The Bank’s strategic initiatives include:
● Customer-Centric & Technology-Enabled Strategy. We are enhancing credit and service capabilities, streamlining service models, and leveraging technology to drive operational efficiency. Rather than adopting a universal banking model, we are focusing on the most profitable customer segments with a personalized, tech-driven approach, where we can achieve a competitive edge.
● We are Building a Service Ecosystem. We continue to build our ecosystem, integrating our service offerings and adding third-party partnerships and platform plays. This strategy enhances customer experience and creates synergies across our business verticals. We have been enhancing our Supervielle SuperApp, integrating AI, personalization and open ecosystems to simplify our clients’ financial lives. For example, in 2025, we launched the new “Tienda Supervielle” on the Mercado Libre platform, the largest e-commerce site in Latin America, becoming the first bank in Argentina to do so, further expanding our value proposition and reinforcing our digital commerce ecosystem. The launch of the new “Tienda Supervielle” marks a milestone in our efforts to develop our ecosystem and consolidate our position as a one-stop shop that provides customers a seamless platform to manage their finances and investments and acquire products and services.
● Cluster-Based Strategy. Our commercial approach segments customers and marketing strategies, delivering tailored value propositions that incentivize deposits and promote bundled solutions, enhancing customer retention. In our Plan Sueldo segment, we launched “Cuenta Remunerada”, a payroll account that provides benefits both to employers and employees to attract new customers, strengthening our role as a preferred payroll banking partner. In our SME segment, we introduced interest-bearing balances, and we are expanding credit options and cash management solutions to enhance value for our clients. Additionally, we were the first bank to remunerate U.S. dollar-denominated sight deposits.
● Strategic Focus on High Growth Sectors. We are reinforcing our position in key industries by collaborating with leading corporations, prioritizing growth sectors such as oil and gas, mining, and export-driven industries. In retail, we are reinforcing our position across pensions and payrolls with strong portfolio collateralization in open market customers and maintaining rigorous underwriting standards.
● Regional Leadership in Mendoza. We remain the leading financial institution in Mendoza, the fifth largest province in Argentina by population and a strategic market where we have long-standing customer relationships and a strong competitive position supported by our tailored financial solutions and unmatched regional expertise. For over 17 years, we have maintained a sustained presence and strong brand recognition in the region, which we consider a key engine of Argentina’s economic growth. Our strategy in Mendoza focuses on providing specialized financial solutions to the province’s main productive sectors, including the wine industry, where we were pioneers in creating a dedicated business unit, as well as energy, mining and other regional sectors. We aim to be our customers’ primary bank by combining a tailored service with agile credit solutions. In addition, our broader ecosystem, including banking, insurance and online investment platforms, positions us to support credit expansion and long-term investment as macroeconomic conditions stabilize. We also maintain close relationships with provincial authorities, business leaders, and the local community, reinforcing our role as a key partner in Mendoza’s social and economic development.
● Selective Expansion in Public Sector Banking. We are complementing our corporate banking strategy by providing financial solutions tailored to government institutions and publicly owned organizations. Our proven-track record in treasury services, payroll, and liquidity management has positioned us as a preferred partner for public-sector clients.
● IOL Cross-Selling and Business Expansion. We are intensifying the engagement of the Bank with IOL invertironline’s customers by integrating investing, banking and fintech solutions. As of the date of this annual report, only a small number of
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IOL invertironline’s customers maintain a principal relationship with the Bank (although such number increased in recent months), which we believe brings opportunities for customer and revenue expansion with limited acquisition costs, diversifying and increasing multi-product income.
IOL invertironline’s Strategy
As Argentina’s leading retail digital broker, IOL invertironline operates a scalable, technology driven platform that allows us to grow assets and revenues with strong operating leverage. We see a significant opportunity in the development of Argentina’s domestic capital market, which remains at an early stage relative to the size of the country’s economy and the financial savings potential. As macro conditions normalize, we expect deeper financial intermediation and greater participation in investment products. To capture that growth, we are focusing on affluent clients, corporations, and independent financial advisors, segments that allow us to accelerate growth in assets under custody while enhancing the quality and stability of our revenue mix. Our objective is not only to grow accounts, but to scale assets under custody in a disciplined and profitable way, leveraging our digital capabilities, ecosystem integration with the Bank, and a differentiated product offering across local and international markets.
IOL invertironline’s strategies is based on the following three key pillars:
● Retail & Investment Expansion: Enhancing our investment platform to serve as a “one-stop shop” for retail investors by integrating investment options across multiple asset classes and deepening partnerships with the Bank to offer a broad assortment of financial and investment products.
● SME & Affluent Customers Growth: Expanding our services for small and medium sized enterprises and affluent clients through digital account opening, liquidity management solutions and advisory capabilities, while maintaining a selective physical presence in key locations. This pillar aims to support the growth of assets under custody and long-term client relationships, contributing to a more stable and diversified revenue mix.
● Investment-as-a-Service & Capital Markets Expansion: Strengthening our role in the development of Argentina’s domestic capital markets, which remain at an early stage relative to the size of the economy and its financial savings potential. As macro conditions normalize, we expect deeper financial intermediation and greater participation in investment products.
Sustainability
At Grupo Supervielle we are committed to our employees, customers and communities to achieve sustainable growth while protecting the environment and acting with social responsibility. We integrate the sustainability strategy to our business model and promote a responsible culture among our employees. We report on our non-financial performance in a clear and transparent way, in connection with ESG factors.
In 2025, we continued developing goals and objectives that align with our sustainability strategies. We increased the use of renewable energy, with 42% of our branch network operating on sustainable sources. We also reduced all the carbon footprint that we generated in 2024 through the acquisition of certified carbon credits equivalent to 155 tCO2eq and through our contribution to a reforestation project led by Asociación Amigos de la Patagonia.
Our sustainability objectives extend across all our stakeholders. In 2025, 68% of our strategic suppliers participated in a self-assessment program based on ESG criteria, enabling us to analyze accurately their alignment with our sustainability goals. We also trained to 20,000 individuals on responsible and sustainable use of financial instruments. Additionally, we continued to develop various projects related to education, childhood, the elderly, institutional strengthening, and initiatives that promote culture and the arts. To maximize opportunities for generating shared value with our value chain, we evolved supplier risk management towards an integrated and holistic approach framed within our Third-Party Risk Management Policy.
In the corporate governance area, we continued being part of the BYMA Sustainability Index for the sixth consecutive year, which reflects our firm commitment to the integrity of the practices and policies that underpin our corporate leadership.
Regarding the development of strategic indicators of our ESG performance, on December 14, 2022 the Board of Directors of Grupo Supervielle approved the Sustainability Policy which establishes the basic principles and provides a general framework for the
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management of our sustainability agenda and its integration into the corporate strategy and business model. It applies to all of the companies of Grupo Supervielle, and the Board of Directors is responsible for its review and amedment. In 2023, the Board of Directors approved the Diversity, Equity and Inclusion Policy, which sets forth our commitment to promote a diverse work environment that values and respects differences among our personnel.
We are committed to report our financial and non-financial performance to all our stakeholders. On March 2, 2026, we published our 2025 Integrated Annual Report, which reflects our commitment towards transparency and disclosure, providing stakeholders with a clear understanding of our ESG activities and progress and enhancing our dedication to sustainable practices and responsible business operations.
The following are additional commitments of Grupo Supervielle in terms of sustainability:
● Customers
We extended the use of financial products and services (financial inclusion) to those who already have an account with Grupo Supervielle, facilitating the adoption of new digital tools and promoting financial education.
● Employees
We create opportunities to promote employees’ growth and potential, and foster a diverse and inclusive work culture that values individuals for who they are and what they contribute.
● Diversity
We have a diversity, equity and inclusion strategy in place that promotes gender equity, disability, psychological safety and equal opportunities.
● Community
We promote social investment with impact on projects related to education, minors, the elderly and institutional strengthening, and actions that promote culture and the arts.
● Corporate Governance
We do business pursuant to the highest corporate governance standards, promoting transparence, ethical behavior, respect of the principle of legality and sustainability of our activities and those of our value chain.
● Respect of the Principle of Legality
We regularly review the degree of compliance with applicable laws and regulations and we take the actions required to correct deviations.
Business Segments
We conduct our operations through the following business segments:
● Personal & Business Banking;
● Corporate Banking;
● Bank Treasury;
● Insurance; and
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● Asset Management and Other Services (which includes IOL invertironline).
The following table sets forth the breakdown of our net revenue and net income by segment for the periods indicated.
As of December 31, 2025
Attributable Net (Loss) /
Segment Net Revenue Percentage Income
(in million of Pesos)
Personal & Business Banking 423,649.7 44.8 % (186,737.2)
Corporate Banking 93,005.7 9.8 % 6,883.5
Bank Treasury 260,991.9 27.6 % 77,089.7
Insurance 39,183.1 4.1 % 18,007.3
Asset Management and Other Services 128,074.4 13.6 % 65,358.5
Total Allocated to Segments 944,904.8 100.0 % (19,398.2)
Adjustments(1) 3,713.3 (18,173.0)
Total Consolidated 948,618.1 100.0 % (37,571.2)
(1) Includes the net interest income received from the investment of liquidity at the holding company, as well as transactions between segments.
The following table sets forth the breakdown of our assets by segment as of December 31, 2025.
As of December 31, 2025
Personal Asset
and Management
Business Corporate Bank and Other Consolidated
Banking Banking Treasury Insurance Services Adjustments(1) Total
(in thousands of Pesos)
Assets
Cash and due from banks 205,935,976 11,117,258 1,261,552,983 16,714 121,866,134 (1,302,601) 1,599,186,464
Debt Securities at fair value through profit or loss 2,150,212 7,552,770 163,152,090 14,960,191 63,628,667 (1,937,429) 249,506,501
Loans and other financings 1,892,290,769 1,834,735,962 30,073,642 — 2,755,497 5,622,356 3,765,478,226
Other debt securities — — 739,981,909 6,285,032 45,029,325 13,611,562 804,907,828
Other assets 201,291,506 37,027,755 1,032,976,692 14,815,052 156,665,132 (92,290,261) 1,350,485,876
Total Assets 2,301,668,463 1,890,433,745 3,227,737,316 36,076,989 389,944,755 (76,296,373) 7,769,564,895
(1) Includes elimination of inter-segment loans and assets not directly allocated to a single segment, such as unlisted equity investments, miscellaneous receivables, premises and equipment, miscellaneous assets and intangible assets.
The following table sets forth the breakdown of our customers as of December 31, 2025 and 2024.
Customers
As of December 31,
2025 2024
Personal & Business Banking 1,314,786 1,382,317
Individuals 1,288,716 1,357,428
Small Businesses 23,249 22,420
SMEs 2,821 2,469
Corporate Banking 2,199 2,079
IOL invertironline 565,621 570,661
Total 1,882,606 1,955,057
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Personal & Business Banking Segment
Our Personal and Business Banking segment offers a wide range of financial products and services designed to meet the needs of individuals, professionals and businesses, and SMEs customers: personal loans, mortgage loans, unsecured loans, loans with special facilities for project and work capital financing, leasing, bank guarantee for tenants, salary advances, car loans, domestic and international factoring, international guarantees and letters of credit, payroll payment plans (planes sueldo), credit cards, debit cards, savings accounts, time deposits, checking accounts, and financial services and investments such as mutual funds, insurance and guarantees, and benefit payments for senior citizens. In 2025, we continued to offer these financial products and services to satisfy our customers’ needs.
Based on the assessment of their distinctive features, their needs and specific requirements, our customers are grouped in five strategic groups which are further described below: (i) professionals and businesses, which comprise individuals engaged in commercial activities, (ii) SMEs which comprise Small and medium-sized enterprises with revenues up to Ps. 5,500 million and between Ps.5,500 and Ps. 34,000 million respectively, (iii) Identité customers, which comprise affluent individuals belonging to serial ABC1 segments, (iii) mass market, which comprise individual customers without commercial activity and who do not belong to the Identité segment, and (iv) senior citizens customers, which comprise senior citizens who are paid pension benefits through accounts held in the Bank.
Personal & Business Banking Segment – Retail Customers
● Identité: In 2025, our Identité customer focused its growth on higher-value, more profitable profiles. As a result of this strategy, progress was made in consolidating a profitable portfolio aligned with the segment’s objectives as compared to December 2024.
In the second half of 2025, the strategic focus shifted to developing the executives and business owners portfolio, adding more than 1,400 new customers compared to December 2024. This growth strengthened one of the priority niches defined within Identité’s expansion and specialization plan.
In parallel, we launched Identité’s strategic restructuring project, aimed at transforming its growth and positioning model by focusing on high-value niches and evolving towards an aspirational offer of comprehensive financial advice. This initiative includes improving the segment’s differentiated value proposition, consolidating a specialized service model, and integrating with the investment ecosystem, with the goal of strengthening customer loyalty and also Identité as the Bank’s aspirational offer within the individuals banking business.
● Mass Market – Payroll Segment: With the aim of maintaining the quality of its customer base, during 2025, mass market prioritized higher profitability profiles and the development of strategic niches.
Growth was concentrated primarily in the payroll segment and in the car loan segment. Additionally, the HIT IOL account was launched, reaching 11,000 customers by year-end. Conversely, there was a reduction in Consumer Loans (formerly IUDÚ Compañia Financiera S.A.) and in open market niches, where a price-out policy was implemented to improve portfolio profitability and maintain the quality of the overall loan portfolio. Payroll reached a record high of 114,000 new customers, mainly due to the implementation of a differentiated value proposition, with the Cuenta Remunerada as its central component.
The value proposition was complemented by the incorporation of WhatsApp as a customer service channel, Mercado Libre as a store, and IOL invertironline as an investment platform, strengthening the ecosystem of solutions available to the segment.
● Senior Citizens. Since 1996, the Bank has acted as one of the paying agents of social security payments to senior citizens on behalf of the Argentine government pursuant to an agreement with ANSES. We believe the Bank remains the private bank with the second largest presence in this segment, with 531,926 customers, an increase of 2,468 customers, which represents an approximate market share of 8.6%, according to the most recent available information as of September 2025.
We offer a specialized service model with dedicated executives in branches and 24/7 virtual support through Supervielle Chat, which incorporates generative AI to provide automated support and allows users to perform banking transactions,
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such as checking their next payment due dates and downloading payment slips. We also launched financial literacy campaigns targeting this segment, with a special focus on fraud prevention and the safe use of digital channels.
Personal & Business Banking Segment – Professionals and Businesses, SMEs and Sub-Segments
During 2025, we had more than 30,600 customers, including customers with commercial activity and small and medium-sized companies, reaching a 6.66% market share in December 2025, which represents an increase of 0.29% from December 2024. During 2025, a net growth of more than 2,300 new SMEs.
The strengthening of engagement was accompanied by significant innovations. The main milestone was the launch, in April 2025, of the interest-bearing checking account for SMEs, offering daily interest on balances in pesos and dollars, with interest payments accrued upon exceeding minimum thresholds between Ps.15 million and Ps. 25 million, depending on the size of the company.
Products and services offered:
● Loans. We offer personal, car loans, mortgage loans, overdrafts, salary advances and guarantees for tenants. During 2025, there was an industry-wide increase in non-performing retail loan rates, which led to adjustments in credit policies and a moderation in asset portfolio growth. This increase was mainly driven by elevated real interest rates in the second half of 2025, combined with slower economic activity, softening in employment levels, and pressure on household disposable income. In this scenario, the Bank prioritized prudent risk management, balancing expansion and portfolio quality. We also continued developing the microcredit ecosystem, expanding our installment payment options. As of December 31, 2025, the balance of loans from individuals increased 8% compared to December 31, 2024.
● Deposits. During 2025, we recorded a year-on-year growth of 78% in funding for individual customers, above the growth in the Argentine financial system as a whole. Savings accounts denominated in Argentine pesos grew by 45%, while savings accounts denominated in U.S. dollars grew by 86%, mainly driven by increased acquisition of savings and transactional balances. During 2025, we added a simple, fast and digital U.S. dollar savings account to our product offering that is available to all our individual customers. This proposal was integrated into a broader solution that includes an interest-bearing account denominated in U.S. dollars, buying and selling official U.S. dollars, U.S. dollar time deposits with competitive rates, and transfers from abroad without fees or limits, consolidating a comprehensive range of services in U.S. dollars.
● Investment Products: During 2025, we continued to strengthen our investment proposition, focusing on simplifying the experience, expanding access to instruments and consolidating the integration of our digital ecosystem. We introduced direct access to the investment ecosystem in our app, allowing customers to trade CEDEARs, stocks, bonds, and other instruments. This initiative shows the synergy between Grupo Supervielle’s companies and expands the reach of our investment value proposition, In addition, we relaunched a simple, agile and digital experience for buying and selling U.S. dollars, complementing the existing MEP Dollar offering. We also launched a renewed experience for investing in the funds managed by Supervielle Asset Management through our digital channels, strengthening the accessibility and consistency of our own investment proposal.
● Insurance. In 2025, the offer of the insurance segment to individual customers consolidated its position based on over 340,000 active policies and strong traction in its strategic products, primarily in the car, life, and home insurance lines of business. Sales efforts focused on strengthening customer relationships, prioritizing clear value propositions and solutions tailored to everyday needs.
● Payments. In 2025, we consolidated our digitalization strategy for payment-related services, aiming to position ourselves as facilitators of our customers’ daily lives through secure, seamless digital payment solutions. This approach combined expanded functionalities, enhanced self-service options, and new integrations with the payments ecosystem.
Corporate Banking Segment
In order to respond to the daily operational and transactional needs of companies, we worked with a specialized service model, comprised of dedicated sales teams and supported by experts in leasing, cash management, foreign trade, payroll, finance, and
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investments. This structure allows us to offer comprehensive, tailored solutions to meet the operational, financial, and transactional needs of businesses. In 2025, we recorded a significant growth in our loan portfolio, driven mainly by the increase in U.S. dollar loans for exporting customers and direct suppliers in the commodity export chain.
In order to maintain a healthy credit portfolio and keep non-performing loans at appropriate levels, we streamlined our work on financial risk indicators, such as RAROC (Risk Adjusted Return on Capital), which measures risk-adjusted profitability. In this regard, we followed a moderate credit appetite policy and sought efficiency in capital placement, generating profitability through primary transaction bank relationship with customers.
Additionally, a specialized oil & gas unit was established with a dedicated sales team, operating in the Buenos Aires Metropolitan Area and the Argentine province of Neuquén, focused on developing the value chain of this strategic industry. Simultaneously, we continued to support the mining sector with products and credit policies tailored to its specific needs, further strengthening brand positioning by adding a specialized officer based in San Juan. Within this framework, we expanded our physical presence during the year with the opening of two new branches designed to directly support these value chains. One is located in Añelo, in the province of Neuquén, a key hub for oil & gas activity in Vaca Muerta, and the other in the province of San Juan, where mining is a strategic industry for regional development.
Products offered to Corporate Customers:
● Deposits: In 2025, our market share of checking account deposits from private sector companies reached an average monthly market share of 2.72% in December 2025, slightly higher than the 2.70% recorded in December 2024.
● Loans: In 2025, in a context of high interest rate volatility, we continued to strengthen our credit offering for the business segment, focusing on facilitating access to credit for companies and providing solutions tailored to their operational and investment needs. Furthermore, in line with regulatory loosening, we offered U.S. dollar-denominated financial loans in addition to traditional foreign trade facilities. We also continued with the digital transformation of the segment, improving access to unsecured loans through our online banking for businesses channel.
● Plan Sueldo: In 2025, we continued to strengthen the Payroll offer as a tool for connecting companies with their employees, with a sustained focus on improving the experience and expanding the value proposition. At functional level, optimizations were implemented on the Online Banking platform aimed at improving usability, operational efficiency, and service quality, along with specific actions designed to simplify management for company teams and their employees. In terms of value proposition, the employee savings account was enhanced with a competitive rate within the market, increasing penetration of existing accounts and the acquisition of new ones. This evolution was complemented by acquisition and retention campaigns focused on consolidating customer loyalty in both the individuals and business segments.
● Foreign Trade: As of December 31, 2025, nearly 65,000 foreign trade transactions were settled, representing an 8% increase compared to 2024. In 2025, the trading volume of these transactions exceeded US$3,446 million.
● Cash Management: Our collection and payment services are aimed at cross-sell of funding products and offer differentiated value propositions according to customers’ expectations and needs. The volumes of transactional funds in our collection and payment products grew above inflation, which shows a greater use by our customers of these products. During 2025, in the area of payments and funds management, we made progress in modernizing check and transfer operations, while for business transfers, the focus was on customer service and fraud prevention. During 2025, the range of collection solutions was expanded with the launch of two strategic products: the Supervielle Payment Button, which promotes the digitization of payment methods, streamlines the collection process, and facilitates access to settlement reports, enabling the automation of administrative tasks; and Cobros Plus, a multi-bank collection solution designed to optimize treasury management, reduce errors, and expedite controls and processes.
● Leasing: With a focus on financing capital goods for Corporate Customers, the Financial and Operational Leasing and Sale & Lease Back products are marketed through our commercial officers and our branch network with specialized service and advice in order to promote the use of this capital assets financing tool. Based on the latest data available from the Central Bank, as of December 31, 2025 we had a market share of 12.3%.
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Bank Treasury Segment
The Bank Treasury segment is primarily responsible for the allocation of the Bank’s liquidity according to the needs of the Personal and Business Banking segment, the Corporate banking segment and its own needs. The Bank Treasury segment implements the Bank’s liquidity and financial risk management, asset and liability management, financing structure planning, trading desk transactions and institutional sales. During 2025, in a context of high financial volatility, these functions were coordinated to support the prudent management of the balance sheet, expand funding sources (including lines for foreign trade and financing to SMEs) and maintain an active presence in the local capital market.
Trading Desk and Institutional Sales
The Bank’s trading desks trade financial assets on a proprietary and third-party basis, sell financial products, and implement the Asset and Liability Management Committee (“ALCO”) decisions, within the board’s policies, regarding the Bank’s liquidity and financial risk management policies. The Bank’s trading operations include money market instruments, which include institutional investor deposits, public debt instruments, foreign exchange, stocks, futures, swaps and repos. Trades develop within the limits of a comprehensive risk map which sets limits on counterparty risk and on long and short positions for each asset class, depending on volatility, traders’ seniority level, and other factors. The risk map also determines stop-loss policies.
Financial institutions and Correspondent Banking
During 2025, the availability of credit facilities for foreign trade financing increased, as a result of both the expansion of existing lines and new offers from foreign banks and multilateral organizations. This development helped strengthen the Bank’s capacity to support its customers’ international trade operations.
Additionally, the Bank entered into a structured A/B loan with the Inter-American Investment Corporation and a group of international lenders for up to US$260 million, with a term of up to three years, US$229 million of which were disbursed during 2025. The amounts disbursed under this loan will be used to finance the expansion of our loan offering to SMEs.
Capital Markets
The Bank’s capital markets department objective is to originate and structure financing products to be placed in the Argentine capital markets. The sector is mainly focused on providing specialized advisory services to companies seeking to optimize their financial resources and capital structure through capital markets. We focus on the origination, structuring and assistance in the placement of negotiable obligations and financial trusts.
During 2025, 62 transactions were completed for a total amount of approximately Ps. 3,263 trillion. This level of activity positioned the Bank among the most dynamic entities in the local market. According to the Cbonds ranking of bond issuers in Argentina, the entity ranked fourth in number of sponsored issuers and seventh in number of transactions, reflecting a sustained presence in both volume and diversity of operations.
Supporting the SME segment remained a priority, alongside ongoing work with large companies and frequent issuers. In 2025, 37% of issuances within the Capital Markets framework were for SMEs. As of December 31, 2025, the Bank maintained outstanding guarantees on 66 CNV-guaranteed SME negotiable obligations.
Furthermore, the entity maintained its commitment to issuing Social, Green, and Sustainable Securities (SVS). During the period under review, it participated in 4 of the 11 issuances of this type carried out in Argentina (1 social, 1 sustainable, and 2 green) for a total amount of Ps. 13,100 million and US$ 34.8 million, reinforcing its role in developing instruments aligned with environmental and social criteria Insurance Segment
Our insurance business is operated by our subsidiaries Supervielle Seguros and Supervielle Productores Asesores de Seguros. Supervielle Seguros offers insurance products, including life, home, protected technology, personal accidents, protected bags, ATMs, protected content, integral insurance product for entrepreneurs and SME customers and other insurance policies. These products may be accessed through any of our marketing channels, both in-person and digital, which includes the distribution network of the Bank.
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During 2025, we recorded 340,000 active policies with individual customers. We also managed over 5,000 active policies with business customers and 48,000 occupational risk insurance policies, consolidating our market presence and diversifying our portfolio.During 2025, Supervielle Seguros consolidated its offers in the following products:
Protected Bag Insurance. Protected bag insurance is insurance for personal property contained in a bag, backpack, wallet, fanny pack or other bag that is either lost or stolen. Protected bag insurance can cover items such as cellular phones, makeup, planners, lost documents, keys and locks. In addition, protected bag insurance may cover a certain amount of charges from fraudulent credit card use as a result of a lost or stolen bag.
Personal Accident Insurance. Personal accident insurance covers policy holders in the event that they suffer an accident, subject to certain exclusions.
Broken Bones. The broken bones insurance covers death as result of an accident up to the amount of the insured capital. A certain amount will be paid in the event of quadriplegia or paraplegia, according to the respective insurance plan and once such condition has been verified by a medical audit. This insurance also covers the simple breakage of bones produced as an immediate consequence of an accident.
Life Insurance. Supervielle Seguros markets its life insurance products to the Bank’s senior citizen customers and sells its products through its own sales force that works within the Bank’s branch network. The basic life insurance product includes coverage for death, and customers can add varying degrees of coverage for accidents, serious and terminal illnesses and transplants.
Home Insurance. Home insurance coverage includes fire insurance (building and content), theft of content, theft and damage of appliances, glass breakage, civil liability, personal accident coverage for domestic staff and home assistance service in cases of emergencies.
Technology Insurance. Technology insurance covers theft or accidental damage as a result of theft of electronic equipment (includes notebooks, cell phones, tablets, smartphones, cameras and GPSs). In case of theft or accidental damage as a result of theft, the cost of the stolen property or the cost of repair will be compensated up to the maximum insured amount (once the repair invoice is provided).
ATM Insurance. ATM insurance covers robbery at ATMs, death at the time of the assault and reimbursement of the costs of stolen documentation.
Protected Content. Protected content insurance covers theft and accidental damage of the personal effects that are inside a vehicle.
Integral insurance product for Small Businesses and SME customers. Integral insurance product for small businesses and SMEs customers completes the offer of services for our priority segment small businesses and SMEs, with the particularity that is fully processed by Supervielle Seguros.
Other Insurance. Pets insurance to cover accidents and illnesses, and bicycle insurance to cover theft of bicycles.
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The following table sets forth the breakdown of Supervielle Seguros’s gross written premiums per quarter as of December 31, 2025.
Gross written premiums by product
(in millions of Pesos)
4th quarter 3rd quarter 2nd quarter 1st quarter
2025 2025 2025 2025
Life insurance and total permanent disability insurance for debit balances — — — —
Mortgage Insurance 881.3 907.8 869.2 824.5
Personal Accident Insurance 337.9 390.9 415.4 490.7
Protected Bag Insurance 790.2 918.5 1,102.2 1,278.5
Broken Bones 161.2 182.8 194.6 223.5
Others 674.6 755.0 784.1 785.4
Home Insurance 1,707.0 1,877.7 1,997.0 2,281.3
Technology Insurance 484.4 557.9 659.5 773.2
ATM Insurance 391.2 475.2 533.2 586.8
Life Insurance 6,079.4 6,608.5 6,531.8 7,319.3
Total 11,507.1 12,674.4 13,087.0 14,563.3
Asset Management and Other Services segment
Grupo Supervielle offers a variety of investment services to its customers, including mutual fund products through Supervielle Asset Management. Since May 2018, Supervielle also offers brokerage and investment products and services through IOL invertironline.
SAM
Mutual Funds. SAM offers mutual funds services designed to meet customers’ particular investment objectives and risk profiles through its “Premier” funds family. As of December 31, 2025, assets under management reached Ps.1,162 billion, reaching a market share of 1.49%, representing a decrease from 2.40% in December 2024.
The Premier funds family comprises a money market fund (Premier Renta Corto Plazo en Pesos), two short term fixed income funds in Pesos (Premier Renta Plus and Premier Renta Fija Ahorro), six fixed income and mixed income funds in Pesos (Premier Renta Fija Crecimiento, Premier Capital, Premier Commodities, Premier Inversión, Premier Balanceado, Premier Estratégico and Premier Renta Mixta), two fixed income funds in U.S. dollars (Premier Renta Mixta en Dólares and Premier Performance), a variable income fund (Premier Renta Variable), two specific investment funds in assets issued by SMEs and ESG (Premier FCI Abierto Pymes and Premier Sustentable ASG, launched in 2023), a fixed income LatAm fund (Premier Global Dólares) and a close fund (Adblick Ganadería). These Premier funds family are offered to the public online.
IOL invertironline
IOL invertironline is a digital online broker that offers brokerage and savings and investment services based on an agile, simple, transparent and innovative platform, suitable for the profile of each client, with the objective of helping our clients increase their savings.
In 2025, IOL invertironline celebrated its 25th anniversary, strengthening its leading position in the Argentine capital markets. This institutional milestone was reflected in sustained growth, surpassing 2 million open accounts and reaffirming its scalability and leadership within the local investment ecosystem. During 2025, more than 24 million transactions were carried out, a base of 565,000 active customers was maintained, and assets under custody exceeded Ps. 3,616 billion, representing a 34% year-on-year increase.
IOL invertironline remained in the top 10 settlement and clearing agents (agente de liquidación y compensación) in Argentina by volume of shares and CEDEARs traded on the ByMA, and strengthened the business of primary subscriptions of negotiable obligations, participating in 38 private placements of securities for an aggregate amount of US$180 million.
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Through IOL Asset Management, IOL invertironline expanded its offering of mutual funds, highlighting IOL Dólar Ahorro Plus and IOL Portafolio Potenciado, adding the development of IOL Cash Management. The synergy with Grupo Supervielle was enhanced through the offering of time Deposits in U.S. dollars.
Additionally, IOL invertironline relaunched its U.S. account operations with simplified products, facilitating international diversification for its users. In addition, its federal expansion strategy was improved, consolidating its commercial presence in the Argentine provinces of Córdoba, Mendoza, Rosario, Tucumán, and Neuquén, with a focus on the development of Vaca Muerta. This extensive reach boosted both the wealth management segment (for affluent customers) and the Business Banking segment, supported by the creation of a new trading desk that optimized execution for sophisticated portfolios and enabled new transactional revenue streams.
These actions were accompanied by a mass-reach and segmented marketing strategy, with a strong presence in public spaces, streaming, industry events and influencer campaigns.
IOL invertironline consolidates Grupo Supervielle as an integrated platform for digital financial services, expanding its reach beyond the traditional banking model.
Market Area
Through the Bank we maintain a strong geographic presence in the City of Buenos Aires and the Greater Buenos Aires metropolitan area, which is Argentina’s most commercially significant and highly populated area, and we are leaders in terms of our banking network in some of Argentina’s most dynamic regions, including Mendoza. Moreover we are present across Argentina through our virtual and digital channels and through IOL invertironline’s digital investment platform.
We continue to evolve our service model toward an increasingly integrated ecosystem that seamlessly coordinates in-person, digital, and remote channels. This approach allows us to expand access to financial services, adapt to the diverse needs of our customers, and deliver a consistent experience across all touchpoints. By building on the consolidation of a hybrid model of virtual and in-person service, we are moving towards an operational approach that optimizes the distribution of demand across channels, strengthens operational continuity, and ensures greater consistency in the customer experience. At the same time, this framework allows us to scale our service capacity without affecting closeness, combining operational efficiency with a simpler and more accessible connection for individuals and businesses that bank with us. This evolution is based on the progressive transformation of the physical network, the expansion of self-service areas, and the strengthening of hybrid roles that integrate in-person and virtual service. In this way, we reinforce a customer-centric model that supports business growth with greater agility, flexibility, and responsiveness.
As of the date of this annual report, we have 555 total cash withdrawal machines and cash dispensers across our branch network, 149 self-service terminals mainly located within 24-hour lobby spaces.
Argentina is comprised by 23 provinces and the City of Buenos Aires. As of December 31, 2025, it had a population of approximately 46 million and a GDP per capita of approximately U.S.$14,451. As of December 31, 2025, the unemployment rate in Argentina was 7.5%. In terms of the banking sector, as of December 31, 2025 there were 60 banks and 4,131 bank branches across Argentina. During 2025, Argentina had a total of 48.9 million fixed and mobile internet connections, surpassing its total population of 46.4 million, which creates a favorable environment for the development of digital banking services.
City of Buenos Aires. The City of Buenos Aires is the capital of Argentina and the center of commerce and seat of the Argentine government. As of December 31, 2025, the City of Buenos Aires had a population of 3.1 million (approximately 6.6% of Argentina’s overall population) and was the richest city of Argentina. As of December 31, 2025, the unemployment rate in the City of Buenos Aires was 4.8%. In terms of the banking sector, as of December 31, 2025 there were 654 bank branches (out of a total of 4,131 bank branches in Argentina) in the City of Buenos Aires.
Province of Buenos Aires. The Province of Buenos Aires, which includes the Greater Buenos Aires metropolitan area, is an agricultural center focused primarily on the production of soy, wheat, corn and other agricultural products. The Province of Buenos Aires had a population of approximately 17.4 million (approximately 37.6% of Argentina’s overall population) as of December 31, 2025 and concentrates a high portion of the agricultural activity. As of December 31, 2025, the unemployment rate in the Province of Buenos Aires was 8.6%. During the last decade, agricultural production has been strong as a result of high commodity prices which has
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contributed to Argentina’s economic growth. It is expected that agriculture production will continue to be a key driver of economic growth in Argentina in the coming years. In terms of the banking sector, as of December 31, 2025, there were 1,336 bank branches (out of a total of 4,131 bank branches in Argentina) in the Province of Buenos Aires.
Mendoza. The Province of Mendoza is located in the Cuyo region and is the center of the wine industry in Argentina. Mendoza has a population of approximately 2.0 million (approximately 4.4% of Argentina’s overall population) as of December 31, 2025. As of December 31, 2025, the unemployment rate in Mendoza was 6.7%. In terms of the banking sector, as of December 31, 2025, there were 152 bank branches (out of a total of 4,131 bank branches in Argentina) in Mendoza.
San Luis. The Province of San Luis is located in the Cuyo region. San Luis had a population of approximately 536 thousand (approximately 1.2% of Argentina’s overall population) as of December 31, 2025. The primary industries in the Province of San Luis are agricultural production and tourism. As of December 31, 2025, the unemployment rate in the Province of San Luis was 2.7%. In terms of the banking sector, as of December 31, 2025, there were 43 bank branches (out of a total of 4,131 bank branches in Argentina) in the Province of San Luis.
Deposits & Loans Franchise
Deposits – General Overview
The charts below illustrate the breakdown of our Peso deposits as of December 31, 2025. Our main source of funds is the Bank’s deposit base.
As of December 31, 2025, non-or low-cost private sector demand deposits accounted for 31% of the our total Peso-denominated deposits, compared to 30% as of December 31, 2024. As of the same date, 13% of non-or low-cost private sector demand deposits corresponded to savings accounts and 18% to checking accounts. As of December 31, 2025, U.S. dollar deposits amounted US$ 1,174.6 billion increasing 42.5% compared to December 31, 2024, above financial system performance. The evolution of Peso retail and commercial deposits reflects the Company’s strategy through the launch of the remunerated account in Pesos and U.S. dollars for payroll and SME clients, which continues to strengthen our funding base, deepen primary relationships and increase client balances. Adoption has been solid, reinforcing the quality and stability of our deposit mix.
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The following tables compare the composition of the Bank’s (on a consolidated basis) total funding with those of all Argentine private banks’ in each case as of December 31, 2025:
Year ended December 31, 2025
Liabilities and Shareholders equity Banco Supervielle Private Banks
(in millions (in millions
of Pesos) % of Pesos) %
Deposits 5,118,886.5 65.9 % 119,378,223.9 65.3 %
Other Liabilities & Shareholders equity 2,650,678.4 34.1 % 63,568,212.9 34.7 %
Total 7,769,564.9 182,946,436.8
Year ended December 31, 2025
Deposits Breakdown Banco Supervielle Private Banks
(in millions (in millions
of Pesos) % of Pesos) %
Checking accounts 602,437.8 11.8 % 18,181,921.6 15.2 %
Saving Accounts(1) 1,011,081.6 19.8 % 49,899,865.1 41.8 %
Time deposits 1,407,375.2 27.5 % 40,517,928.4 33.9 %
Other deposits 2,097,991.9 41.0 % 10,778,508.7 9.0 %
Total 5,118,886.5 119,378,223.9
(1) Private banks figures includes special checking accounts
Loan Portfolio – General Overview
Each loan category in our loan portfolio faces different risks. We have established underwriting policies, standards and pricing mechanisms designed to mitigate the risks posed by each loan category. As of December 31, 2025, we had a loan portfolio of Ps.3,982.9 billion (equivalent to U.S.$2,729 million converted to U.S. dollars at the reference exchange rate as of December 31, 2025). As of December 31, 2025, we had a loan portfolio and off balance sheet guarantees of Ps.4,105.1 billion (equivalent to U.S.$2,813 million converted to U.S. dollars at the reference exchange rate as of December 31, 2025).
The following charts set forth the breakdown of our loan portfolio by segment and by product as of December 31, 2025.
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(1) For information from January 1, 2025 to December 31, 2025, the term “small businesses” refers to individuals that perform professional or commercial activities, the term “SMEs” refers to companies with annual sales up to Ps.34 billion, and the term “middle-market and large companies” refers to companies with annual sales over Ps.34 billion.
Underwriting Policies
Our policies require that most loans only be approved for borrowers that are able to provide proof of a source of repayment and demonstrate an ability to service existing and future debt. Our underwriting procedures for all loan types require consideration of the borrower, including with respect to the borrower’s financial condition, cash flow, the management skills and industry of our corporate customers, and the economic environment surrounding the issuance of any given loan.
We generally expect customers to repay loans with unencumbered cash available to them. A significant part of our loan portfolio is secured, and we assess the quality and liquidity of collateral before we grant any secured loan.
Interest Rate Terms
We price loans: (i) on both a fixed rate and floating rate basis; (ii) over different terms; and (iii) based upon different rate indexes. Our pricing structures are consistent with our interest rate risk management policies and procedures. For more information on these policies and procedures. See “—Loan portfolio - Credit Risk Management.”
Loans to individuals (personal loans, credit card loans, car loans and mortgages) are priced only on a fixed rate basis. UVA Mortgage loans and some UVA car loans principal is adjusted for inflation. Loans to small businesses and SMEs are priced on both a fixed rate and floating rate basis as follows:
● Fixed rate: promissory notes (checking and invoice discounts, work certificates for government projects and warrants), overdrafts, foreign trade loans, automobile, personal loans and mortgages with adjustable principal, based on inflation.
● Floating rate: automobile and other secured loans, receivables from financial leases.
● Both rates: corporate unsecured loans.
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Risks
Below we list our loan categories from lowest risk to highest risk in terms of repayment ability and historical default rates:
(1) Promissory notes (with recourse to the assignor), Warrants - Commodities
(2) Foreign trade loans
(3) Mortgage loans
(4) Receivables from financial leases
(5) Promissory notes (without recourse to the assignor), Warrants – Others
(6) Automobile and other secured loans
(7) Corporate credit cards
(8) Corporate unsecured loans
(9) Overdrafts
(10) Personal loans and credit card loans (from the Personal and Business Banking segment)
Promissory Notes (factoring and check discounting and warrants)
Factoring and check discounting. Check discounting is used to finance working capital needs for businesses that have a diversified accounts receivable portfolio and customers or parties that issue checks and have a favorable credit history. Most of our check discounting transactions are with recourse to the assignor (i.e., we secure repayment with a pledge over an assignment of the borrower’s cash flow). However, some of our check discounting transactions are without recourse to the assignor, in which case we only have recourse to the endorser of the check. With respect to our operations with recourse, we evaluate the creditworthiness of both the assignor and the endorser of the check, specifically assessing each party’s payment history, credit history and legal history by requiring a variety of documents to help us in our underwriting process. We accept checks that are issued in the ordinary course of business from the customer with a payment date generally no longer than 180 days.
Warrants. Warrants are granted to finance working capital needs for producers or sellers of commodities or non-commodities such as sugar, soy, wheat, corn, sunflower, peanuts, cotton and yerba mate. We take collateral in respect of the warrants for at least 20% to 50% in excess of the value of the products and its liquidity in the event of an execution, depending on the type of product. The most significant risk we face when extending warrant financing relates to the quality and preservation of the underlying assets. To mitigate this risk, we select third-party companies to assess and monitor the value and quality of the underlying products. These third-party companies have been approved by our credit committee.
Foreign Trade Loans
Foreign trade loans are granted to finance exports and imports through pre-financing and financing loans for exports, international factoring and letters of credit for imports.
In the case of pre-financing and financing loans for exports, we analyze the repayment ability of both the borrower and its foreign client. Specifically, we ensure that the credit line that we grant is tailored to the borrower’s historical export levels and projected export levels (based on contracts, purchase orders and other documentation). We generally grant pre-financing and financing loans for exports with terms ranging from 90 to 180 days, depending on the transaction and such loans are solely denominated in U.S. dollars. Interest rates for pre-financing and financing loans for exports depend on the term of the loan and market conditions.
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In the case of letters of credit for imports, generally, letters do not exceed one year and our customers pay certain fees related to these letters instead of interest. We face at least two different type of risks in connection with these letters of credit. First, the risk related to the obligation of payment in the event that the borrower defaults. Second, the risk that the borrower is not allowed to operate at the Mercado Libre de Cambios. To mitigate these risks, we ensure that the bank service is granted once the merchandise to be imported can be shipped (this is once the operation is active) and before the issuance of the letter of credit and the related disbursement of the loan, we request importers to submit all the authorizations granted by the state authorities on such import purchase to ensure at due date such letter of credit is payable.
Mortgage Loans
The Bank sets a fixed interest rate on these loans, but the remaining capital is adjusted on a monthly basis according to the UVA monthly evolution. Therefore, the loan has index-linked capital payments (the value of the capital and the installment is updated by inflation). These loans were originated between 2016 and 2018 and since May 2024, when UVA mortgage loans began to be granted again by Argentine banks.
Receivables from Financial Leases
Our financial leases are granted for financing acquisitions of capital assets, industrial equipment, road equipment and automobiles. The terms of these loans are typically between 18 and 60 months, varying based on the type of product or equipment and the useful life of such product or equipment.
The primary source of repayment for this product is cash flows from the borrower, and, therefore, we evaluate the borrower’s repayment ability before granting such loans. We also evaluate the type of asset for which the financial lease is granted in the event the borrower is unable to repay the loan. If the borrower is unable to repay the loan, we may sell the asset to recover all or part of the outstanding amount of the loan.
The primary risk associated with our financial leases is that the borrower may default on the loan and the collateral may be insufficient to recover the outstanding amount of the loan. We mitigate this risk by: (i) granting financial leases in respect of new assets that have historically shown adequate resale values, (ii) requiring a down payment of 10% to 30% (depending on the repayment ability of the customer); and (iii) for certain types of assets, requiring a commitment from the supplier of the asset to buy or find a buyer for the asset in the event of the borrower’s default. We set floating or fix interest rates for our financial leases based on prevailing market rates.
Automobile and Other Secured Loans
We grant secured loans to finance automobile purchases. The maximum amount of our automobile loans is Ps.85,000,000 with a maximum term of 60 months. Before granting this automobile and other secured loans, we evaluate a customer’s ability to meet monthly payment obligations by taking into account the prospective borrower’s earnings, minimum credit rating and financial and legal background. We also require that the vehicle serve as collateral in the event of a payment default by the borrower. We set interest rates based on the term of the automobile loan and a loan-to-value ratio ranging from 40% to 75% of the value of the vehicle at the time of sale.
Corporate Unsecured Loans
Corporate Financial Loans. Our corporate financial loans finance short-term working capital needs of up to one year or medium-term working capital needs of up to three years for businesses that require monthly or periodic amortization. These loans are granted to customers with annual revenues in excess of Ps.34 billion. We evaluate the customer’s repayment ability using the general criteria and analysis for corporate customers. We also analyze the following factors: the shareholders and management of the borrower, the equity to assets ratio, the financial and economic environment, regulatory risk and projected cash flow for the entire period during which the loan will be outstanding to ensure that the borrower will be able to comply with the scheduled payments under the loan. We take into account the potential effects that economic variables such as exchange rate volatility and inflation could have on projected cash flow. We set either a floating or fixed interest rate for our corporate financial loans based on the creditworthiness of the borrower’s business and the term of the loan.
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Loans to Small Businesses and SMEs. Our loans to small businesses and SMEs are originated at the Bank’s branches based on a policy that requires adequate credit and legal history, a minimum credit score and a certain level of revenues. Our loans to small businesses and SMEs finance the working capital needs of businesses with annual revenues of up to Ps.34 billion. The Bank’s branches may grant up to Ps.600 million of unsecured loans and Ps.1,600 million of factoring transactions and financial leases, and any excess amount must be evaluated by the Bank’s specialized credit analysis unit. We set either a floating or fixed interest rate for our loans to small businesses based on the creditworthiness of the borrower’s business and the term of the loan. The interest rates for our loans to small business are generally higher than the interest rates for our corporate financial loans reflecting the difference in size and revenues of the businesses.
Overdrafts
We grant overdrafts to businesses to finance working capital needs and ordinary course business activity. We assess whether the borrower has the ability to meet its payment obligations over a maximum 180-day period, placing an emphasis on the borrower’s line of business. Businesses with operations that do not produce short-term revenues or with cyclical operations generally must seek other types of financing. We are able to anticipate a customer’s ability to repay overdrafts by analyzing daily accounts payable, accounts receivable, credits and fluctuations. We set interest rates for our overdrafts on a monthly basis.
Personal Loans and Credit Card Loans (within the Personal and Business Banking segment)
Our Personal and Business Banking segment originates loans based on scoring systems and policies specifically tailored to our Plan Sueldo services, pension and retiree services and general clientele. For a detailed discussion of the Bank’s credit application process, credit monitoring and review process and the risks associated with personal loans and credit card loans. See “—Credit Policy—Banco Supervielle S.A.”
Retail banking in Argentina is heavily regulated, including with respect to maximum interest rates and fees. See “Item 4.B. Business Overview—Liquidity and Solvency Requirements—Interest Rate and Fee Regulations.” We tailor our policies related to issuing and granting loans and credit to comply with these regulations.
The maximum amount of our personal loans is Ps.76.5 million, while the average loan as of December 31, 2025 was Ps. 1.15. The average term of our personal loans as of December 31, 2025 was 31 months, with a maximum of 72 months. The loans are granted at a fixed rate and are paid back in monthly installments and amortized based on the French amortization system, which consists of equal monthly installments amortized in a manner in which (i) interest payments are higher at the beginning of the loan and decrease over the life of the loan, while (ii) principal payments are lower at the beginning of the loan and increase over the life of the loan.
Loan portfolio - Credit Risk Management
We define credit risk as the risk that arises from losses and/or a decline in the value of our assets as a result of our borrowers or counterparties defaulting on or not complying with their obligations. Credit risk includes any event that may cause a decline in the present value of a loan, but does not necessarily require the counterparty’s default. This risk also encompasses liquidity risk, which exists whenever a financial transaction cannot be completed or generate liquidity in accordance with an agreement. The magnitude of credit risk losses hinges upon two factors:
● the amount of exposure at the time of the default; and
● the amounts recovered by the Bank based on the payments received from the borrower and the execution of risk mitigation policies, such as guarantees that may limit losses.
With regard to risk appetite, the credit risk management is the process that leads to the identification, measurement or evaluation, mitigation and monitoring or follow-up of the risk, as considered in the entire credit cycle, since its origin until collection, recovery or loss, and in case of non-compliance. Likewise, the definition of the Bank’s risk appetite is generated through the development and monitoring of indicators, with their respective thresholds and limits for credit risk.
Our credit risk management policies also monitor concentration risk. This risk arises when the concentration of exposure has the capacity to generate enough losses (relating to results of operations, minimum capital requirements, assets or global risk levels) to
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impact the entity’s financial strength or capacity to maintain its operations and significantly change the entity’s risk profile. In 2020 we developed and implemented a portfolio limits policy to fix maximum portfolio concentration ratios based on economic sectors and customer credit rating. Economic sectors were classified as Very High, High, Mid and Low, according to their risk perception. These sectors are regularly monitored to confirm or change the classification according to their evolution. Moreover, we implemented currency limits in the different product and segments to reduce exposure to foreign currency. Since October 2022, we incorporated a module into portfolio limits that monitors the portfolio under the socio-environmental risk policy. This module allows us to classify SMEs and Corporates clients into high, medium and low risk based on their economic activities. While low and medium risks have no limits, high risk cannot exceed 5% of the total loan portfolio.
Our Board of Directors approves credit risk policies and strategies presented by the Risk Management Committee, in consultation with the Credit team, the Legal Affairs team and the Corporate Banking team, and in accordance with Central Bank regulations. The Bank’s credit risk policies and strategies seek to develop commercial opportunities and business plans, while maintaining a prudent level of risk. The credit policy is tailored to corporations and individuals from every segment.
The pillars of the Bank’s credit policy are based on an analysis of the client’s cash flow and its repayment capacity.
The Bank focuses on supporting companies belonging to sectors with great potential which tend to be successful in their activity. Within the range of credit products offered for the corporate business segment, the Bank aims to develop and lead the factoring and leasing market, as well as being leader in foreign trade.
Within the corporate banking segment, we seek to have a solid proposal for the SMEs and middle-market companies seeking to maintain proximity with customers through customer service centers, agreements with customers throughout their value chain and providing agile responses through existing credit processes.
With regard to individuals, in addition to the payroll customers and senior citizens, the retail banking is specially focused on small businesses and SMEs as well as the Identité customers We believe that loan portfolio diversification is a staple of the Bank’s credit risk management objective of distributing risk appropriately by economic segment, client type and loan amount. The same importance is given to the risk mitigation mechanisms that ensure adequate risk coverage, such as the use of credit instruments in the corporate segment that cover substantial amounts of the loan. In addition, we continuously use early detection processes to monitor the performance of the loan portfolio.
Credit Risk Measuring Models
The Bank relies on several models that estimate the distribution of possible losses arising out of the loan portfolio to calculate expected losses and minimum capital requirements. These models include:
● Credit risk measurement models. The Bank’s models estimate distribution of possible loan portfolio losses, which depend on counterparties’ default (probability of default (“PD”)), as well as the exposure assumed with them (EAD—Exposure at the time of default) and the proportion of each unfulfilled loan that the entity is able to recover (Loss in the event of default (“LGD”)). Based on these parameters, the expected loss (“PE”) and economic capital are estimated. As a result of this, a methodological and developmental plan has been developed in order to calculate the RAROC at the Bank in order to optimize the management linked to Credit Risk.
● Expected Losses Calculation. This is calculated based on the results of the PD, EAD and LGD models. The expected loss calculation analyzes portfolio information to estimate the average value of loss distributions for a one year time horizon in the case of performing loans and for a lifetime horizon in the case of underperforming or non-performing loans.
● Minimum Capital Requirement Calculation. This is represented by the difference between the portfolio’s risk value and expected losses within a 99.9% confidence interval for individuals and 99.0% confidence interval for corporate customers. We have two minimum capital requirement models (one for corporate customers and one for individuals), which include the economic capital required for our concentration risk and securitization risk.
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We assess on a forward-looking basis the expected credit losses associated to our financial assets measured at amortized cost, debt instruments measured at fair value through other comprehensive income, loan commitments and financial guarantee contracts that are not measured at fair value.
For the purposes of estimating the impairment amount, and in accordance with its internal policies, we classify its financial instruments (financial assets, commitments and guarantees) measured at amortized cost or fair value through other comprehensive income in one of the following categories:
● Normal Risk (“Stage 1”): includes all instruments that have not experienced a significant increase in credit risk since initial recognition and is not purchased or originated credit impaired.
● Normal risk under watchlist (“Stage 2”): includes all instruments that, have experienced significant increases in credit risk since initial recognition but are not yet deemed credit-impaired.
● Doubtful Risk (“Stage 3”): includes financial instruments, overdue or not, which are considered to be credit impaired. Likewise, loan commitments or financial guarantees whose payment is probable and their recovery doubtful are considered to be in Stage 3.
Significant increase in credit risk
We consider a financial instrument to have experienced a significant increase in credit risk when at least one of the following conditions per segment exists:
Individuals and Businesses
1. Maximum delay at financial asset level > 30 days.
2. If the financial asset is a refinancing.
3. The credit origination score has deteriorated by more than 30% with respect to the current performance score.
4. The difference between the current behavior score and the credit application score is less than -300 in absolute terms.
5. Internal Behavior Score at client level below the cut-off point (1)
(1) High Income: Payroll segment >=400, Open Market segment >=500 and Retirees segment >=600 and Ex>=800 segment
Corporate Banking
1.Portfolios more than 30 days past due.
2.Portfolios whose classification under Argentine Central Bank regulation is 2.
3. Probability of default higher than 30%.
4.Its rating deteriorated by more than two notes from its credit approval rating.
5. If the financial asset is a refinancing.
Sectoral Analysis
Considering that the internal impairment models are estimated with historical information, the risk of non-compliance of the companies is evaluated by type of activity based on the degree of affectation that they have due to the current economic situation, taking
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into account their characteristics and seasonality, among others. Additionally, the different activities that make up the Bank’s portfolio are classified into four types of risk. They are:
1. Low risk
2. Medium risk
3. High risk
4. Very high risk
The evaluation of significant credit increases and the calculation of ECL include prospective information. The Bank carried out a historical analysis and identified key economic variable that affect the credit risk and expected credit losses for each portfolio. Forecasts of these economic variables (“base economic scenario”) are provided on a six-month basis by the research team at the Bank and offer a better estimated outlook of the economy for the next 12 months. The impact of such economic variables on DP and LGD resulted from the statistic regression analysis to understand the impact the changes in these variables has had historically on default rates and LGD components. In addition to the base economic scenario, the research team also provides two potential scenarios together with scenario analysis. The number of other scenarios is defined in accordance with the analysis of the main products to ensure the lineal effect between the future economic scenario and related expected credit losses. The number of scenarios and its features are re-evaluated on a six-month basis, except a situation occurs in the macroeconomic framework that justifies a greater regularity.
The Bank considers the following variables for estimating expected credit losses on the different scenarios:
Parameter Segment Macroeconomic Indicators
Probability of Default Personal and Business Banking Private Sector Deposits, Real Badlar Rate (private banks), Monthly Economic Activity Estimator
Corporate Banking Real Badlar rate (private banks), Blue cheap swap rate
Loss Given Default Personal and Business Banking Real Badlar Rate (private banks), Private Sector Real Deposits
Corporate Banking Private Sector Deposits, Real Badlar Rate (private banks) , Inflation
Atomization of the loan portfolio
As a result of our risk management policies, we have a diversified loan portfolio. As of December 31, 2025, the top 10, 50 and 100 borrowers represented 10%, 26% and 33%, respectively, of our total loan portfolio, which shows an increase in the diversification of our loan portfolio, compared to December 2024.
Loan portfolio atomization December 31, 2025 December 31, 2024
%Top10 10 % 10 %
%Top50 26 % 23 %
%Top100 33 % 30 %
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Loan Portfolio breakdown by economic activity
Business Sector Dec 31, 2025 Share Dec 31, 2024 Share
Families and individuals 35.9 % 42.3 %
Agribusiness 9.4 % 9.1 %
Food & Beverages 5.3 % 5.9 %
Transport 3.4 % 2.5 %
Wine 3.1 % 2.7 %
Utilities 2.9 % 4.3 %
Oil, Gas & Mining 2.9 % 4.3 %
Financial Services 2.8 % 2.9 %
Home appliance 2.7 % 1.2 %
IT & Communications 2.4 % 2.5 %
Automobile 2.2 % 1.4 %
Construction & Public Works 2.2 % 2.0 %
Machinery & Equipment 2.2 % 2.0 %
Textile 1.8 % 1.9 %
Chemicals and plastics 1.6 % 2.2 %
Pharmaceutical 1.5 % 1.3 %
Retail 1.1 % 0.6 %
Automotive manufacturers 1.0 % 0.4 %
Others 15.9 % 10.5 %
Collateralized Loan Portfolio
As of December 31, 2025, 22% of the total commercial loan portfolio was collateralized, while 43% of the commercial non-performing loans portfolio was collateralized.
Entrepreneurs & SMEs & Middle
Loan portfolio collaterall Small Businesses Market Large Total
Collateralized Portfolio 35 % 38 % 17 % 22 %
Unsecured Portfolio 65 % 62 % 83 % 78 %
As of December 31, 2025: (i) 52% of our retail loan portfolio to individuals corresponded to loans granted to payroll and pension clients, (ii) 57% of our open market customers loan portfolio has collateral, (iii) 86% of the personal loans that we originate correspond to payroll customers (including senior citizens who receive their pensions and benefits through the Bank), and (iv) 59% of credit card volumes corresponded to payroll customers (including senior citizens who receive their pensions and benefits through the Bank).
Credit Policy
Banco Supervielle S.A.
Credit Application Process
The credit approval process is designed to facilitate an accurate risks analysis, expedient decisions and complete support information.
Potential customers are interviewed and asked to submit documentation to efficiently evaluate risk. The Credit department performs a risk evaluation using computer software and issues an opinion on the requested assistance. If credit assistance is deemed feasible, the customer’s application is submitted for approval at the appropriate level, pursuant to credit authority guidelines and depending on the facility amount requested, the term and security.
Applications by prospective retail customers and small businesses are analyzed using an electronic application. This process is conducted on an individual basis or a group basis, subject to the information that is available for the analysis.
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Credit Monitoring and Review Process
It is the Bank’s policy to continually track and monitor risk in order to anticipate or foresee changes in the macroeconomic environment and anomalies that may affect the course of customers’ activities and the repayment of loans. The Credit Risk department traces alert indicators for signals that may affect credit collection. Signals could be late payments of more than 30 days, alerts from credit bureaus, lawsuits from third parties, customers or suppliers and bounced checks. Action plans are in place to anticipate or mitigate potential nonperformance situations. The Credit Risk department tracks alert indicators by:
● analyzing loan portfolio evolution;
● verifying compliance with credit regulatory requirements;
● reviewing the factoring portfolio on a daily basis by operation, maturity, concentration, direct and indirect risk;
● verifying and analyzing customer arrears;
● detecting market alerts, customer behavior in the market and the financial system, lawsuits, etc.;
● proposing action plans;
● involving the senior credit committee or junior credit committee as applicable;
● reporting customer alerts to officials and managers; and
● establishing allowances for estimated loan losses.
Credit Approval Process
The following chart describes the levels of approval for the different types of loans:
Credit Approval Limit
(in millions of Pesos)
A- or > BB+ or > BB or <
Total Maximum
Approval Limit
Senior Committee Chief Risk Officer (as Chairman of the Committee);
CEO (as Vice chairman of the Committee); Maximum limit set by regulation Maximum limit set by regulation Maximum limit set by regulation
Chief Corporate Banking Officer;
Executive Manager. Middle-market & corporates;
Manager of SMEs business
Chief of Treasury and Global Markets;
Junior Committee
Chief Risk Officer (as Chairman of the Committee); 13,300 13,300 13,300
Manager of SMEs business;
Executive Manager. Middle-market & corporates;
Manager Corporate Banking Bs Aires and Interior;
Manager 7,700 7,700 7,700
Team Leaders 3,000 2,150 NA
Relationship officers 2,000 1,100 NA
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Recovery Process
The Bank’s Recovery Area handles the collection of past due credits. Collections are handled by different units for individual and corporate customers.
With respect to individual customers, the collections area performs a risk segmentation for management purposes, which depends on the customer’s characteristics and the amount of debt. In higher-risk cases, preventive actions are carried out at the time of payment due date. Once the customer becomes delinquent, automated actions begin on the third day; for high-risk cases, management shifts to telephone contact starting on day four. For medium- and low-risk cases, automated management continues until days 10 and 18 of delinquency respectively, after which telephone management begins. Additionally, based on their risk characteristics, between 90 and 180 days of delinquency the debt is consolidated and transferred to specialized late-stage collection agencies, at which point the initiation of legal actions may be considered.
In the case of corporate clients and SMEs, payment defaults are analyzed on a case-by-case basis, taking into consideration the loan amount and the number of days in arrears, among other factors. The Recovery Department can participate in out-of-court and judicial settlement negotiations and approve debtor payment proposals in amounts for up to Ps.50 million.
Cybersecurity; Information Security; Data Protection
See “Item 16.K. Cybersecurity.”
Competition
Over the last decade, and increasingly over the past five years, traditional banks have accelerated their digital transformation processes in order to adapt to the current environment where competition has been intensified by the disruption of fintech platforms which have entered the financial markets offering innovative digital business models, new business opportunities and new usage options. In many cases, traditional banks have combined digital banking platforms with traditional banking solutions to offer to their customers the advantages of both systems. In addition, certain traditional banks have created digital banking platforms which operate separately from the traditional banking systems. During 2025, traditional banks continued to make progress on the development of digital capabilities and certain indicators show improvements in terms of digital adoption and customer experience.
Traditional Banking
The Argentine financial system remains highly fragmented compared to the rest of Latin America. As of December 31, 2025 the Argentine financial system had 73 financial entities, of which 60 were banks, of which 14 were public banks and 46 private banks. In terms of bank ownership, as of December 31, 2025, the percentage of banks controlled by the Argentine government was 23%, the percentage of banks controlled by Argentine private entities was 57%, the percentage of banks controlled by foreign financial entities was 10%, and branches of foreign financial entities represented 10%. As of December 31, 2025, the number of financial companies operating in this segment was 13.
According to the information published by the Central Bank, as of December 31, 2025 we were one of the top 10 private banks in the Argentine financial system in terms of outstanding amount of loans. In terms of deposits, we had an estimated market share of 3.0% of deposits in December 2025, ranking eighth among the total private banks in the Argentine financial system and eleventh among total banks in the Argentine financial system. In terms of total loans, we had an estimated market share of 2.8% of loans in December 2025, ranking seventh among the total private banks in the Argentine financial system and ninth among total banks in the Argentine financial system.
The Bank faces a high degree of competition in virtually all core financial products with respect to pricing (interest rate or fee) and term. The Bank’s strategy to face this competition is to maintain aggressive business policies, to differentiate its product offering and customer service from other financial institutions. Notwithstanding this competitive challenge, our growth strategy, both organic and through acquisitions, has resulted in an increase in our financial system market share since 2005, according to the information published by the Central Bank. Taking into consideration total loan portfolio and receivables from financial leases portfolio at the end of the year 2025, total loans and leasing market share was 2.9% in 2025 compared to 0.1% as of December 31, 2001.
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Mutual Funds
With respect to the mutual fund market, based on the Chamber of Mutual Funds information we estimate that our market share was 1.5% as of December 31, 2025, and that SAM is ranked 21 out of 59 managers in the industry. Our main competitors are Galicia Administradora de Fondos S.A.S.G.F.C.I., Macro Fondos S.G.F.C.I.S.A., ICBC Investments S.A.S.G.F.C.I., Francés Administradora de Inversiones S.A.G.F.C.I. and Santander Río Asset Management G.F.C.I.S.A.
Online trading broker
During 2024, IOL invertironline strengthened its leadership in Argentina’s retail digital brokerage market, and recorded significant growth in net income and fee generation. At the end of 2025, IOL invertironline had nearly 1.9 million accounts, representing a 35% increase compared to 2024, 565,000 active customers, and approximately Ps.3.6 trillion in managed assets. During 2025, more than 24 million transactions were carried out through IOL invertironline. Additionally, in 2025, IOL invertironline continued offering U.S. dollar-denominated investment fund. As of the date of this annual report, through IOL Asset Management, IOL invertironline expanded its offering of mutual funds, highlighting IOL Dólar Ahorro Plus, IOL Portafolio Potenciado and IOL Cash Management. Along these lines, IOL Asset Management also consolidated its position, expanding its value proposition to include professional asset management, where the IOL Dólar Ahorro Plus fund ranked third among funds of its kind in Argentina.
In 2025, IOL invertironline ranked seventh in the ByMA exchange ranking on Equity and seventh in CEDEARs (Certificado de Depósito Argentinos), according to the information published by ByMA. As of the date of this annual report, IOL invertiroline has a 17% market share in terms of retail customers in the ByMA market. IOL invertironline’s main competitors are Balanz Capital Valores S.A.U., Bull Market Brokers S.A., PP Inversiones S.A. and Cocos Capital Servicios Digitales S.A.
Argentine Banking Regulation Overview
Founded in 1935, the Central Bank is the principal monetary and financial authority in Argentina. Its mission is to promote monetary and financial stability, employment and economic development with social equity. It operates pursuant to its charter, which was amended in 2012 by Law No. 26,739 and the provisions of the FIL. Under the terms of its charter, the Central Bank must operate independently from the Argentine government.
Since 1977, banking activities in Argentina have been regulated primarily by the FIL, which empowers the Central Bank to regulate the financial sector. The Central Bank regulates and supervises the Argentine banking system through the Superintendency. The Superintendency is responsible for enforcing Argentina’s banking laws, establishing accounting and financial reporting requirements for the banking sector, monitoring and regulating the lending practices of financial institutions and establishing rules for participation of financial institutions in the foreign exchange market and the issuance of bonds and other securities, among other functions.
The powers of the Central Bank include the authority to fix the monetary base, set interest rates, establish minimum capital, liquidity and solvency requirements, regulate credit, approve bank mergers, approve certain capital increases and transfers of stock, grant and revoke banking licenses, and to authorize the establishment of branches of foreign financial institutions in Argentina and the extension of financial assistance to financial institutions in cases of temporary liquidity or solvency problems.
The Central Bank establishes certain technical ratios that must be observed by financial entities, such as ratios related to levels of solvency, liquidity, the maximum credit that may be granted per customer and foreign exchange assets and liability positions.
In addition, financial entities need the authorization from the Central Bank for certain actions, such as opening branches abroad, acquiring share interests in other financial or non-financial corporations and establishing liens over their assets, among others. The opening, relocation and closure of branches in Argentina does not require prior authorization from the Central Bank, but must be notified to the Central Bank..
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As supervisor of the financial system, the Central Bank requires financial institutions to submit information on a daily, monthly, quarterly, semi-annual and annual basis. These reports, which include balance sheets and income statements, information related to reserve funds, use of deposits, classifications of portfolio quality (including details on principal debtors and any allowances for loan losses), compliance with capital requirements and any other relevant information, allow the Central Bank to monitor the business practices of financial entities. In order to confirm the accuracy of the information provided, the Central Bank is authorized to carry out inspections.
If the Central Bank’s rules are not complied with, various sanctions may be imposed by the Superintendency, depending on the level of infringement. These sanctions range from a notice of non-compliance to the imposition of fines or, in extreme cases, the revocation of the financial entity’s operating license. Additionally, non-compliance with certain rules may result in the compulsory filing of specific adequacy or restructuring plans with the Central Bank. These plans must be approved by the Central Bank to permit the financial institution to remain in business.
Banking Regulation and Supervision
Central Bank Supervision
Liquidity and Solvency Requirements
Since September 1994, the Central Bank has supervised the Argentine financial entities on a consolidated basis. Such entities must file periodic consolidated financial statements that reflect the operations of their head office or controlling entities, as well as those of their branches in Argentina and abroad, and of their significant subsidiaries, whether domestic or foreign. Accordingly, requirements in relation to liquidity and solvency, minimum capital, risk concentration and loan loss provisions, among others, should be calculated on a consolidated basis.
Permitted Activities and Investments
The FIL governs all individuals and entities that perform habitual financial intermediation and, as such, are part of the financial system, including commercial banks, investment banks, mortgage banks, financial companies, savings and loan companies for residential purposes and credit unions. Except for commercial banks, which are authorized to conduct all financial activities and services that are specifically established by the law or by regulations of the Central Bank, the activities that may be carried out by Argentine financial entities are set forth in the FIL and related rules and regulations promulgated by the Central Bank (“Central Bank Rules”). Commercial banks are allowed to perform any and all financial activities inasmuch as such activities are not forbidden by law. Some of the activities permitted for commercial banks include the ability to (i) receive deposits from the public in both local and foreign currency; (ii) underwrite, acquire, place or negotiate debt securities, including government securities, in both exchange and over-the-counter (“OTC”) markets (subject to prior approval by the CNV, if applicable); (iii) grant and receive loans; (iv) guarantee customers’ debts; (v) conduct foreign currency exchange transactions; (vi) issue credit cards; (vii) act, subject to certain conditions, as brokers in real estate transactions; (viii) carry out commercial financing transactions; (ix) act as registrars of mortgage bonds; (x) participate in foreign exchange transactions; and (xi) act as fiduciary in financial trusts. In addition, pursuant to the FIL and Central Bank Communication “A” 3086, as amended, commercial banks are authorized to operate commercial, industrial, agricultural and other types of companies that do not provide supplemental services to the banking services (as defined by applicable Central Bank Rules) to the extent that the commercial bank’s interest in such companies does not exceed 12.5% of its voting stock or 12.5% of its capital stock. Nonetheless, if the aforementioned limits were to be exceeded, the bank should (i) request Central Bank’s authorization; or (ii) give notice of such situation to the Central Bank, as the case may be. However, even when commercial banks’ interests do not reach such percentages, they are not allowed to operate such companies if (i) such interest allows them to control a majority of votes at a shareholders’ or board of directors’ meeting, or (ii) the Central Bank does not authorize the acquisition.
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Furthermore, according to the Central Bank regulations regarding “Complementary Services of the Financial Entities and Allowed Activities,” as amended, commercial banks are authorized to operate in local or foreign companies that have one or two of the exclusive corporate purposes listed in section 2.2 of said rules, in which the commercial bank’s interest either exceeds 12.5% of such companies’ voting stock or allows the commercial bank to control a majority of votes at a shareholders’ or board of directors’ meeting. The financial entities shall give notice to the Superintendency if the corporate purposes of such companies include any of the corporate purposes listed in section 2.2 of Central Bank rules regarding “Complementary Services of the Financial Entities and Allowed Activities.”. Financial institutions are prohibited from conducting or facilitating transactions involving digital assets, including crypto-assets and those whose returns are determined based on their price fluctuations, unless such assets are authorized by a competent national regulatory authority or the Central Bank.
Under Central Bank Rules regarding “Minimum Capital Requirements for Financial Institutions,” (the “Minimum Capital Regulations”) the holdings of a commercial bank in the capital stock of third parties, including participations in mutual funds, shall not exceed 60% of the Computable Regulatory Equity (“RPC”, as per its acronym in Spanish) of such commercial bank. In addition, the total amount of a commercial bank’s holdings, considered as a whole, in (i) unlisted shares, excluding holdings in companies that provide complementary services to the financial activity and holdings in state-owned companies that provide public services, (ii) listed shares and mutual fund shares that do not trigger minimum capital requirements on a market risk bases, and (iii) publicly traded shares that do not have a “market price available to the general public,” is limited to 15% of such commercial bank’s RPC. For this purpose, a given market price of the shares is considered to be “available to the general public” when market rates that measure the daily volume of significant transactions are available, and the sale of such shares held by such bank would not materially affect the share price.
Operations and Activities that Banks Are Not Permitted to Perform
Section 28 of the FIL prohibits commercial banks from: (a) creating liens on their assets without prior approval from the Central Bank, (b) accepting their own shares as security, (c) conducting transactions with their own directors or managers and with companies or persons related thereto under terms that are more favorable than those regularly offered in transactions with other clients, and (d) carrying out commercial, industrial, agricultural or other activities without prior approval of the Central Bank, except those considered financially related activities under Central Bank regulations regarding “Complementary Services of the Financial Entities and Allowed Activities”). Notwithstanding the foregoing, banks may own shares in other financial institutions with the prior approval of the Central Bank, and may own shares or debt of public services companies, if necessary to obtain those services.
Legal Reserve
Pursuant to the FIL, we are required to maintain a legal reserve which must be funded with no more than 20% and no less than 10% of yearly income. Notwithstanding the foregoing, pursuant to Central Bank Rules, we are required to maintain a legal reserve which is funded with 20% of our yearly income determined in accordance with Central Bank Rules. This reserve can only be used during periods in which a financial institution has incurred losses and has exhausted all other reserves. If a financial institution does not comply with the required legal reserve, it is not allowed to pay dividends to its shareholders.
Non-liquid Assets
Since February 2004, non-liquid assets (computed on the basis of their closing balance at the end of each month, and net of those assets that are deducted to compute the regulatory capital) plus the financings granted to a financial institution’s related parties (computed on the basis of the highest balance during each month for each customer) cannot exceed 100% of the Argentine regulatory capital of the financial institution, except for certain particular cases in which it may exceed up to 150%.
Non-liquid assets consist of miscellaneous assets and receivables, bank property and equipment, assets securing obligations, except for swaps, futures and derivative transactions, certain intangible assets and equity investments in unlisted companies or listed shares, if the holding exceeds 2.5% of the issuing company’s equity. Non-compliance with the ratio produces an increase in the minimum capital requirements equal to 100% of the excess on the ratio.
Unless otherwise indicated, the regulations explained in this section should be applied to financial information of the banks calculated in accordance with Central Bank Rules. IFRS differs in certain aspects from Central Bank Rules.
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Minimum Capital Requirements
Until July 31, 2026, the minimum capital requirement that financial institutions must maintain shall be equal to the greater of: (i) the basic capital requirement, and (ii) the aggregate of the capital requirements determined for credit risk, market risk — including the requirement applicable to daily positions in the relevant assets — and operational risk.
Effective from August 1, 2026, the minimum capital requirement that financial institutions must maintain shall be equal to the greater of: (i) the basic capital requirement, and (ii) the aggregate of the capital requirements determined for credit risk (including counterparty credit risk), market risk — including the requirement applicable to daily positions in the relevant assets — and operational risk. For these purposes, positions in financial instruments must be allocated to the banking book (subject to capital requirements for credit risk, counterparty credit risk and operational risk) or to the trading book (subject to capital requirements for counterparty credit risk, market risk and operational risk), in each case in accordance with the Minimum Capital Regulations.
As stated above under “Presentation of Financial and Other Information,” we have prepared our audited consolidated financial statements for 2025, 2024 and 2023 under IFRS. Minimum capital requirement has been prepared in accordance with the rules of the Argentine Central Bank, which is not comparable to data prepared under IFRS.
The following table sets forth information regarding excess capital and selected capital ratios of the Bank:
Year ended December 31,
2025 2024 (3) 2023 (3) (4)
(in thousands of Pesos except percentages and
ratios)
Calculation of excess capital:
Allocated to assets at risk 304,501,175 240,732,301 148,742,119
Allocated to Bank premises and equipment, intangible assets and equity investment assets 27,913,213 31,208,043 30,532,024
Market risk 16,852,852 22,794,035 8,529,904
Public sector and securities in investment account 928,905 703,052 779,764
Operational risk 45,771,893 97,959,978 67,124,101
Required minimum capital under Central Bank rules 395,968,038 393,397,409 255,707,912
Basic net worth 1,103,547,123 1,084,581,259 963,815,112
Complementary net worth — — —
Deductions (358,337,148) (307,588,949) (292,328,570)
Total capital under Central Bank rules 745,209,975 776,992,310 671,486,542
Excess capital 349,241,937 383,594,901 415,778,630
Credit Risk Weighted Assets 4,026,186,872 3,364,520,068 2,200,613,815
Risk Weighted Assets (1) 4,828,237,638 4,818,204,223 3,130,795,301
Selected capital and liquidity ratios:
Regulatory capital/credit risk weighted assets 18.5 % 23.1 % 30.5 %
Regulatory capital/risk weighted assets 15.4 % 16.1 % 21.4 %
Average shareholders’ equity as a percentage of average total assets 12.8 % 17.8 % 14.5 %
Total liabilities as a multiple of total shareholders’ equity 8.7x 5.4x 6.3x
Cash as a percentage of total deposits 28.9 % 20.2 % 14.4 %
Liquid assets as a percentage of total deposits (2) 48.2 % 55.6 % 83.1 %
Common Equity Tier 1 Capital (CET1) / Risk weighted assets 15.4 % 16.1 % 21.4 %
(1) Risk Weighted Assets includes operational risk weighted assets, market risk weighted assets, and credit risk weighted assets, Operational risk weighted assets and market risk weighted assets are calculated by multiplying their respective required minimum capital under Central Bank rules by 12.5, Credit Risk Weighted Assets is calculated by applying the respective credit risk weights to our assets, following Central Bank rules.
(2) Liquid assets include cash, government securities, government securities in guarantee, securities issued by the Central Bank, repo transactions with the Central Bank and call operations.
(3) Values adjusted for inflation.
(4)Amounts corresponding to applying Communication “A” 8009 retrospectively for comparative purposes.
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As of December 31, 2025, the Bank’s total capital ratio was 15.4%, compared to 16.1% as of December 31, 2024, and the Bank’s common equity Tier 1 ratio was 15.4%, compared to 16.1% as of December 31, 2024. On June 28, 2019, the Central Bank issued a ruling, effective January 1, 2020, requiring Group “A” financial institutions controlled by non-financial institutions (such as Grupo Supervielle and the Bank) to comply with minimum capital requirements, major exposure to credit risk regulations, liquidity coverage ratio and net stable funding ratio. These requirements apply on a consolidated basis, excluding insurance companies and non-financial subsidiaries. On March 21, 2024, the Central Bank introduced Communication “A” 7982, requiring financial institutions to submit monthly consolidated reports starting in April 2024.
The capital composition to be considered in order to determine compliance with minimum capital requirements is the financial institution’s RPC (Central Bank rules regarding “Minimum Capital Requirements for Financial Institutions,” as amended).
Basic Minimum Capital
As from June 1, 2024, the basic minimum capital requirement to be observed by financial institutions is as follows:
Banks Other financial institutions(Except Cooperative Credit Unions)
Ps. 5,000 million Ps. 2,500 million
Likewise, financial entities in operation as of June 1, 2024 must comply with the basic capital requirement set forth in the table above from January 1, 2025. From June 1, 2024, until December 31, 2024, such operating entities shall apply the requirements set forth in the following table:
Banks Other financial institutions(Except Cooperative Credit Unions)
Ps. 1,500 million Ps. 700 million
Financial institutions that are in operation since June 1, 2024, that do not meet the integration of the basic capital requirement as outlined in the previous paragraph and/or the basic capital requirement from January 1, 2025, according to the information that banks are periodically required to send to the Central Bank pursuant to the “Business Plan and Projections and Capital Self-Assessment Report” information regime, which includes the submission of a compliance program to Superintendency within 20 calendar days following the registration or projection of non-compliance, respectively, which must not exceed a 6-month period to meet the basic requirement.
Delineation Between the Banking Book and the Trading Book
Effective August 1, 2026, financial institutions must apply the following framework to distinguish between the banking book and the trading book for regulatory capital purposes.
Allocation to the Trading Book
The trading book includes all positions in financial instruments that are held for trading purposes or to hedge positions held for trading. Such positions must be measured at fair value and subject to prudent valuation standards in accordance with the Minimum Capital Regulations.
Positions included in the trading book must not be subject to legal or other restrictions that would prevent their sale, transfer, or effective hedging.
A position is considered held for trading if it is entered into for short-term resale, to benefit from short-term price movements, for arbitrage, or to hedge other trading book positions.
Unless an institution can provide documented justification to the contrary, consistent with its internal policies, the following instruments are presumed to belong in the trading book:
(i) instruments accounted for at fair value through profit or loss;
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(ii) derivatives arising from market-making activities;
(iii) certain fund investments that meet applicable transparency, information, and valuation requirements;
(iv) equity instruments listed on recognized exchanges;
(v) securitization exposures with identifiable underlying assets and a liquid secondary market;
(vi) explicit or embedded credit-linked options;
(vii) underwriting commitments for shares, bonds, or other instruments;
(viii) instruments that create net short credit risk positions in the banking book; and
(ix) repurchase or reverse repurchase transactions not included in the banking book.
Allocation to the Banking Book
Any financial instrument that does not meet the criteria for trading book treatment must be assigned to the banking book. This includes, among other items, real estate exposures.
The following positions must be included in the banking book:
(i) equity instruments not listed on recognized exchanges;
(ii) retail and SME exposures;
(iii) exposures temporarily held pending securitization;
(iv) fund investments not allocated to the trading book;
(v) derivatives and funds whose underlying assets consist of banking book instruments;
(vi) instruments used to hedge banking book positions; and
(vii) repurchase transactions entered into for liquidity management purposes or accounted for at amortized cost.
Supervisory Oversight
The Superintendency may require institutions to demonstrate that positions classified in the trading book are in fact held for trading purposes, or that positions classified in the banking book are not held for trading purposes.
If the supporting evidence is deemed insufficient, the Superintendency may require the reclassification of positions to the appropriate book, subject to the exceptions set forth in the Minimum Capital Regulations.
Reclassification Between Books
Reclassification of positions between the banking book and the trading book is permitted only in exceptional circumstances and must be irrevocable. As a general rule, prior approval from senior management and the Superintendency is required.
Any reduction in capital requirements resulting from a reclassification must continue to be recognized as a capital requirement, must be disclosed in accordance with applicable regulations, and must remain in place until the position is derecognized in the institution’s financial statements.
Governance, Policies and Internal Controls
Institutions must establish and maintain policies, procedures, and controls governing the initial classification and any reclassification of positions between books. These policies must be consistent with regulatory criteria and integrated into the institution’s risk management framework.
Institutions must also implement internal control functions and conduct internal audit reviews at least annually to ensure proper application of classification standards and to assess any exceptional reclassification events.
Internal Risk Transfers
An internal risk transfer refers to the offsetting of risk between the banking book and the trading book, or between positions within the same book.
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The Minimum Capital Regulations impose specific conditions on internal transfers of credit risk, interest rate risk, market risk, and counterparty credit risk. These include requirements relating to external hedging, documentation, supervisory approval, and prudential capital treatment.
All internal risk transfers must be properly documented, including identification of the source and magnitude of the risk being transferred. The resulting positions must be subject to the same prudential standards that would apply if the transaction had been executed with an external counterparty.
Regulatory Capital of Financial Institutions: Tier 1 and Tier 2 Capital Regulations
Argentine financial institutions must comply with guidelines similar to those adopted by the Basel Committee on Banking Regulations and Supervisory Practices, as amended in 1995 (the “Basel Rules”). In certain respects, however, Argentine banking regulations require higher ratios than those set forth under the Basel Rules.
The RPC is determined by the following formula:
RPC = PNb + PNc
Where:
RPC: Computable equity liability (total regulatory capital).
PNb: Basic net worth (Tier 1 capital), calculated as: PNb = COn1 - CDCOn1 + CAn1 - CDCAn1
COn1: Ordinary Tier 1 capital.
CDCOn1: Deductible items from ordinary Tier 1 capital.
CAn1: Additional Tier 1 capital.
CDCAn1: Deductible items from additional Tier 1 capital.
PNc: Complementary net worth (Tier 2 capital), net of corresponding deductions (CDPNc).
The Central Bank takes into consideration a financial institution’s RPC in order to determine compliance with capital requirements.
Tier 1 Capital
COn1 Capital - Ordinary Tier 1 capital
COn1 includes the following net worth items:
(i) capital stock (excluding preferred stock),
(ii) non-capitalized capital contributions (excluding share premium),
(iii) adjustments to shareholders’ equity,
(iv) earnings reserves (excluding the special reserve for debt instruments),
(v) unappropriated earnings,
(vi) other results either positive or negative, in the following terms:
● 100% of net earnings or losses recorded until the last quarterly financial statements with limited review report, corresponding to the last full fiscal year and in respect of which the auditor has not issued the audit report;
● 100% of net earnings or losses for the current year as of the date of the most recent audited quarterly financial statements;
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● 50% of profits or 100% of losses for the most recent audited quarterly or annual financial statements; and
● 100% of losses not shown in the financial statements, arising from quantification of any facts and circumstances reported by the auditor;
(vii) other comprehensive income:
(a) 100% of the results recorded in the following items: revaluation of property, plant, and equipment and intangibles; gains or losses on financial instruments at fair value with changes in other comprehensive income.
(b) 100% of the debit balance of each of the items recorded in other comprehensive income not mentioned in section a) above.
The recognition of these concepts, registered in accounts of other comprehensive income or other accumulated comprehensive income, as appropriate, will be made in accordance with the terms of sections 8.2.1.5. or 8.2.1.6., as the case may be, of the Minimum Capital Regulations.
(viii) share premiums of the instruments included in COn1, and
(ix) in the case of consolidated entities, it also includes minority shareholdings (ordinary shares issued by subsidiaries subject to consolidated supervision and belonging to third parties, if certain criteria are met).
The mentioned concepts will be reduced by applicable deductible items, as defined by the relevant regulations.
In order for the shares to fall under COn1, at the time of issuance, the financial entity must not generate any expectation that such shares will be reacquired, redeemed or amortized, and the contractual terms must not contain any clause that might generate such an expectation.
Deductible Concepts:
The above-mentioned items will be considered without certain deductions pursuant to subsection 8.4.1 and 8.4.2 (as applicable) of the Minimum Capital Regulations.
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Concepts deductible from COn1 include, among other things:
(I) the positive difference resulting from comparing the amount of the regulatory provision—derived from the application of the Minimum Capital Regulations, or the accounting provision corresponding to the balance of accounts as of November 30, 2019, whichever is greater, and the accounting provision derived from the application of Section 5.5 “Impairment” of IFRS 9. Before any deduction, the amount of the provision for credit risk related to the “normal situation” portfolio, computed as supplementary net worth, must be absorbed;
(II) favorable balances arising from the application of the minimum presumed income tax, net of provisions, that exceed 10% of the Tier 1 capital (PNb) for the previous month, and favorable balances arising from deferred tax assets;
(III) deposits maintained in a corresponding account with a foreign financial institutions that are not rated as “investment grade,”
(IV) debt securities not held by the relevant financial institutions, except in the case of securities registered by or in custody of the Central Bank (CRYL), Caja de Valores S.A., Clearstream, Euroclear or the Depository Trust Company,
(V) securities issued by foreign governments whose credit rating is less than ‘investment grade’ according to Communication “A” 5671, as amended;
(VI) subordinated debt instruments issued by other financial institutions;
(VII) shareholders;
(VIII) real property added to the assets of the financial entity and with respect to which the title deed is not duly recorded at the pertinent Argentine real property registry, except where such assets shall have been acquired in a court-ordered auction sale;
(IX) intangible assets, net of the respective accumulated depreciation;
(X) items pending allocation, debtor balances and others;
(XI) certain assets or other concepts, as required by the Superintendency resulting from differences between carry amount and the fair value of assets or actions taken to distort or disguise the true nature or scope of operations;
(XII) any deficiencies due to insufficient provisions for bad debt risk resulting from the application of Section 5.5 “Impairment of Value” under IFRS 9, as determined by the Superintendency;
(XIII) any deficiencies due to insufficiency in the calculation of regulatory provisions in accordance with the Minimum Capital Regulations as determined by Superintendency;
(XIV) equity interests in companies that have the following activities:
a. financial assistance through leasing or factoring agreements,
b. transitory equity acquisitions in other companies in order to further their development to the extent the ultimate purpose is selling such interest after development is accomplished, and
c. credit, debit and similar cards issuances;
(XV) the excess to the limits set forth for secured assets on Section 3 of the rules on “Affectation of Restricted Assets”
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(XVI) the highest balance of that month’s financial assistance granted during the month, where the advance payments set forth in Section 3.2.5 of the rules on “Lending to the non-financial public sector” surpass the authorized limit and/or are not settled within the terms established therein;
(XVII) income from sales relating to securitization transactions, as applicable, pursuant to the provisions of Sections 3.1.4., 3.1.5.1. and 3.1.5.2. of the Minimum Capital Regulations and from portfolio sales or assignments with recourse. This deduction can be applied as long as the credit risk still persists and to the extent in which the capital requirement for the underlying exposures or the sold or assigned portfolio with recourse is maintained;
(XVIII) in the case of liabilities from derivatives accounted for at fair value, unrealized gains or losses due to changes in the financial institution’s credit risk will be deductible. The deduction will be limited to the financial institution’s own credit risk adjustments only plus or minus, as the case may be); such adjustments may not be offset against adjustments for counterpart risk;
(XIX) equity interests in financial institutions subject to consolidated oversight, except where not permitted due to the existence of deductible amounts; or in the case of foreign financial institutions. In these cases, the deductions will be the net amount of the allowance for impairment and, when controlled financial institutions subject to the provisions of Section 8.2.1.6., item iii) are involved, the deductions will be 50% of the net amount of profits derived by these entities on a proportional basis to their respective interests.
CAn1 Capital
CAn1 includes certain debt instruments of financial entities not included under COn1 that meet the regulatory criteria established in section 8.3.2 of the Minimum Capital Regulations, and share premiums resulting from instruments included in CAn1. Furthermore, in the case of consolidated entities, it includes instruments issued by subsidiaries subject to consolidated supervision and belonging to third parties, pursuant to applicable regulatory requirements.
The items mentioned in the previous paragraph will be reduced, if applicable, by the deductible concepts described in the previous section (See “—Deductible Concepts”)
Moreover, instruments included under CAn1 must comply with the following requirements:
(1) Must be totally subscribed and paid in full.
(2) Must be subordinated to depositors, unsecured creditors and to the subordinated debt of the financial entity. The instruments must contemplate that in the case of the entity’s bankruptcy and once all debts with all the other creditors are satisfied, its creditors shall have priority in the distributions of funds only and exclusively with respect to the shareholders (irrespective of their class), with the express waiver of any general or special privilege.
(3) Must not be insured or guaranteed by the issuer or a related entity, and with no agreement improving, either legally or economically, the payment priority in the case of the entity’s bankruptcy.
(4) They shall not contemplate any type of capital payment, except in the case of liquidation of the financial entity. Provisions gradually increasing remuneration or other incentives for anticipated amortization are not allowed.
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(5) After five (5) years, as from the issuance date, the financial entity can buy back the debt instruments if:
(a) it has the prior authorization of the Superintendency,
(b) the entity does not create any expectations regarding the exercise of the purchase option, and
(c) the debt instrument is replaced by a RPC of equal or greater value sustained by its revenue capacity, or if it is demonstrated that once the purchase option is exercised its RPC significantly exceeds at least by 20% of the minimum capital requirements.
(6) Any capital repayment requires previous authorization from the Superintendency. In the case of a capital repayment, the financial entity must not create any market expectations regarding the granting of such authorization.
(7) The financial entity can pay dividends/interest coupons at any time, and at its sole discretion, which shall not be considered the default in itself and shall not grant bondholders the right to demand the conversion of their notes into ordinary shares. Furthermore, there shall be no restrictions to the financial entity, except with respect to dividend distribution to the shareholders.
(8) The payment of dividends/interest coupons shall be carried out through the noting of distributable entries, in the terms of the regulations on “Results Distribution” (See “- Requirements applicable to dividend distribution”).
(9) The included dividends/interest coupons shall not have periodic adjustments because of the financial entity’s credit risk.
(10) They should not have been bought by the financial entity or any other entity over which the financial entity has control or significant influence.
(11) They should not have been bought with direct or indirect financing from the financial entity.
(12) They shall not contain elements that make re-capitalization difficult.
Instruments considered liabilities must absorb losses once a pre-established triggering event takes place. The instruments must do so through their conversion into ordinary shares or a mechanism assigning final losses to the instrument with the following effects:
(a) Reduction of debt represented by the instrument in the event of winding-up of the entity;
(b) Reduction of the amount to be repaid in case a call option is exercised;
(c) Total or partial reduction of the dividends/interest coupon payments of the instrument.
Complementary Net Worth ( NWc or PNc): Tier 2
Tier 2 Capital includes:
(i) certain debt instruments of financial entities which are not included in Tier 1 Capital and meet the regulatory criteria established in section 8.3.3 of the Minimum Capital Regulations,
(ii) share premium from instruments included in Tier 2 Capital, and
(iii) loan loss provisions on the loan portfolio of debtors classified as being in a “normal situation” pursuant to Central Bank Rules on debtor classification and of financing with preferred security “A” not exceeding 1.25% of the assets measured for credit risk.
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Additionally, in the case of consolidated entities, Tier 2 Capital includes debt instruments issued by subsidiaries subject to a consolidated supervision and belonging to third parties, if they meet the criteria in order to be included under NWc.
The concepts mentioned in the preceding points shall be deducted, if applicable, by the deductible items provided in Section 8.4.2 of the Minimum Capital Regulations.
Moreover, debt instruments included under NWc must comply with the following requirements:
● Must be totally subscribed and paid in full.
● Must be subordinated to depositors, unsecured creditors and the subordinated debt of the financial entity.
● Must not be insured or guaranteed by the issuer or a related entity, and with no agreement improving either legally or economically the payment priority in case of the entity’s bankruptcy.
● Maturity: (i) original maturity date within no less than five (5) years, (ii) clauses considering gradually increasing remuneration or other incentives for anticipated amortization are not allowed, and (iii) from the beginning of the last five years of life of the indebtedness, the computable amount will be diminished by 20% of its nominal issuance value. After five (5) years as from the issuance date, the financial entity can buy back the debt instruments with the previous authorization of the Superintendency, and if the entity does not create any expectations regarding the exercise of the purchase option. The debt instrument must be replaced by an RPC of equal or greater value sustained by its revenue capacity, or if it is demonstrated that once the purchase option is exercised its RPC significantly exceeds at least in a 20% of the minimum capital requirements.
● The investor shall not be entitled to accelerate the repayment of future projected payments, except in the case of bankruptcy or liquidation.
● They cannot incorporate dividends/coupons with periodic adjustments linked to the financial entity’s credit risk.
● They should not have been bought by the financial entity or any other entity over which the financial entity has control or significant influence.
● They should not have been bought with direct or indirect financing from the financial entity.
Additionally, instruments included in NWc and CAn1, shall present the following conditions in order to assure their loss-absorbency capacity:
(a) Their terms and conditions must include a provision pursuant to which the instruments must absorb losses–either through a release from debt or its conversion into ordinary capital–once a triggering event has occurred, as described hereunder.
(b) If the holders receive compensation for the debt release performed, it should be carried out immediately and only in the form of common shares, pursuant to applicable regulations.
(c) The financial entity must have been granted the authorization required for the immediate issuance of the corresponding common shares in the case of a triggering event, as described below.
Triggering events of regulatory provisions described above are: (i) when the solvency or liquidity of the financial entity is threatened and the Central Bank rejects the amnesty plan submitted or revokes its authorization to function, or authorizes restructuring protecting depositors (whichever occurs first) or (ii) upon the decision to capitalize the financial entity with public funds in the context of the application of Section 35 bis of the FIL, due to the impact on its liquidity and solvency.
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Further criteria regarding the eligibility of items included in the RPC calculation must be followed pursuant to the regulatory requirements of minority and other computable instruments issued by subsidiaries, subject to consolidated supervision by third parties. A minority shareholding may be included in COn1 of the financial entity if the original instrument complies with the requirements established for its qualification as common shares regarding the RPC.
Deductible concepts applied to the different capital levels
(I) Investments in computable instruments under the financial entity’s RPC not subject to consolidated supervision when the entity owns up to 10% of the issuer’s ordinary capital according to the following criteria:
(i) investments include direct, indirect or synthetic interests;
(ii) investments include the acquired net position;
(iii) the holding of securities subscribed to be sold within a five business day term may be excluded; and
(iv) the investments in capital instruments that do not satisfy the criteria to be classified as COn1 (Common Equity Tier Tier 1), CAn1: (Additional Tier 1 capital) or NWc (Complementary Net Worth) of the financial institution shall be regarded as COn1 –common equity shares, for the purposes of this regulatory adjustment.
If the aggregate amount of these interests in the capital of financial institutions, companies providing services supplementary to the financial industry and insurance companies – which individually represent less than 10% of the COn1 of each issuer – exceeds 10% of the COn1 of the financial institution, net of applicable deductions, the amount over such 10% shall be deducted from each capital tier in accordance with the following method: (i) Amount to be deducted from COn1: aggregate excess amount over 10% multiplied by the proportion represented by the COn1 holdings over the aggregate equity interests; (ii) Amount to be deducted from CAn1: aggregate excess amount over 10% multiplied by the proportion represented by the CAn1 over the aggregate equity interests; and (iii) Amount to be deducted from NWc: aggregate excess amount over 10% multiplied by the proportion represented by the NWc holdings over the aggregate equity interest.
If the financial institution does not have enough capital to make the deduction pertaining to a particular capital tier, the remaining amount shall be deducted from the next higher level. Amounts below the threshold, which are not deducted, are weighted based upon the risk or are taken into account in the calculation of the market risk requirement, as applicable.
(II) Investments in instruments computed as regulatory capital of financial institutions and companies rendering services supplementary to the financial industry, not subject to consolidated oversight and insurance companies, when the institution holds more than 10% of the common equity of the issuer, or when the issuer is a subsidiary of a financial institution, shall be subject to the following criteria:
a) the investments include direct, indirect and synthetic interests (for these purposes, (a) indirect interest means an investment by a financial institution in another financial institution or company not subject to consolidated oversight, which in turn has an interest in another financial institution or company not consolidated with the first one- A synthetic interest means an investment made by a financial institution in an instrument the value of which is directly related with the equity value of another financial institution or company not subject to consolidated supervision);
b) the net acquired position is included, i.e., the gross acquired position less the position sold in the same underlying exposure, when this has the same duration than the acquired position or its residual life is at least one year;
c) the holding of securities underwritten to be sold within a five business day term may be excluded; and
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d) investments in capital instruments that do not satisfy the criteria to be classified as COn1, CAn1 or NWc of the financial institution shall be regarded as COn1, common equity shares, for the purposes of this regulatory adjustment.
The amount of these interests, taking into account the applicable type of instrument, shall be deducted from each of the applicable capital tiers of the financial institution.
If the financial institution does not have enough capital to make the deduction pertaining to a particular capital tier, the remaining amount shall be deducted from the next higher level.
(III) Own repurchased instruments that satisfy the criteria for being included in CAn1 or NWc must be deducted from the applicable capital tier.
Limits
Section 8 of the Minimum Capital Requirements Regulations sets forth the minimum thresholds applicable to capital integration:
for COn1, the amount resulting from multiplying the capital RWA by 4.5%;
for NWb, the amount resulting from multiplying RWA by 6%; and
for the RPC, the amount resulting from multiplying RWA by 8%.
The lack of compliance with any of these limitations is considered as an infringement to minimum capital integration requirements.
Pursuant to Communication “A” 5889, as amended from time to time, RWA shall be calculated as follows:
RWA = RWAc + [(MR+OR) x 12.5]
Where:
RWA: risk weighted assets
RWAc: credit risk weighted assets
MR: minimum capital requirement for market risk
OR: minimum capital requirement for operational risk
Economic Capital
The Central Bank’s “Guidelines for Risk Management of Financial Institutions” (the “Risk Management Guidelines”), require financial institutions to have an integrated global internal process in place to assess the adequacy of their economic capital based on their risk profile (the “Internal Capital Adequacy Assessment Process” or “ICAAP”), as well as a strategy aimed at maintaining their regulatory capital. If, as a result of this internal process, it is found that the regulatory capital is insufficient, financial institutions must increase regulatory capital based on their own estimates to meet the regulatory requirement.
The economic capital of financial institutions is the amount of capital required to pay not only unexpected losses arising from exposure to credit, operational and market risks, but also those arising from other risks to which the financial institution may be exposed.
Financial institutions must demonstrate that their internal capital targets are well-funded and adequate in terms of their general risk profile and operations. The ICAAP should take into consideration all material risks to which the institution is exposed. To this end, institutions must define an integral process for the management of credit, operational, market, interest rate, liquidity, securitization, graduation, reputational and strategic risks and use stress tests to assess potential adverse scenarios that may affect their regulatory capital.
The ICAAP must include stress tests supplementing and validating any other quantitative or qualitative approach employed by the institution in order to provide the board of directors and senior management with a deeper understanding of the interaction among the
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various types of risk under stress conditions. In addition, the ICAAP must consider the short- and long-term capital needs of the institution and ensure the prudent accumulation of excess capital during positive periods of the economic cycle.
The main elements of a strict capital evaluation include:
a) Policies and procedures to guarantee that the entity identifies, quantifies and informs all the important risks.
b) A process which relates economic capital with the current level of risk.
c) A process which sets forth capital sufficiency objectives related to the risk, taking a strategic approach from the entity and its business plan into consideration.
d) An internal process of controls, tests and audits, with the objective to guarantee that the general risk management process is exhaustive.
The required amount of capital of each institution shall be determined based on its risk profile, taking into consideration other external factors such as the effects of the economic cycle and the economic scenario.
As part of its review of compliance with Central Bank regulations, including the Minimum Capital Regulations and “Consolidated Supervision,” the Superintendency assesses the institution’s internal economic capital adequacy process. If the Superintendency determines that the results of the ICAAP conducted by the institution are unsatisfactory, or identifies non-compliance with the conditions and requirements set forth in the applicable regulations, it may consider adopting a broad range of potential measures, including requiring capital levels above the regulatory minimums or ordering or imposing additional actions, such as enhanced supervisory oversight, restrictions on dividend distributions, and the preparation and implementation of a capital restoration plan.
The Central Bank expects financial institutions to operate above the minimum capital requirements. If necessary, the Superintendency may require higher regulatory capital levels based on specific risks not fully addressed by the regulations. The Superintendency may also mandate increased capital for certain risks specific to the institution or the economy.
Capital adequacy for interest rate risk in the investment portfolio (“IRRBB”) must be addressed in the ICAAP, aligned with the institution’s risk appetite. The capital requirement should be based on risk measurement methodologies and assumptions, ensuring sufficient capital for both current and future risks.
Financial institutions must ensure capital adequacy for IRRBB, developing their own methodologies tailored to their risk profile. The impact of IRRBB on economic value and future results must be considered, including potential effects on capital margins due to unforeseen outcomes. Capital adequacy assessments for IRRBB should consider:
(i)the magnitude and duration of internal limits on IRRBB exposures and whether these limits are reached when calculating capital needs;
(ii)the effectiveness and cost of hedging open positions based on interest rate expectations;
(iii)the sensitivity of internal IRRBB measures to key assumptions in the models;
(iv)the impact of stress scenarios and shocks on positions related to different interest rate indices (basis risk);
(v)the effect on economic value and net interest income from mismatches in different currencies;
(vi)the impact of implied losses (the difference between book value and economic value when resulting in a loss);
(vii)capital distribution among entities within a group, and total capital adequacy on a consolidated basis;
(viii) underlying risk factors; and
(ix)circumstances under which the risk may materialize.
The capital adequacy results for IRRBB should be included in the ICAAP and translated into capital needs for business lines.
Entities in Group “A” must use internal models to quantify economic capital needs based on their risk profile within the ICAAP framework.
Entities in Groups “B” or “C” may choose between using internal models or applying a simplified methodology for quantifying economic capital needs, with the decision made by the Board of Director. Those opting for the simplified methodology must adhere to
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general risk management provisions. Group B entities which have opted for the simplified methodology shall apply the following expression:
EC = (1.05 x MC) + max [0; U EVE – 15% x NWb)]
Where:
EC: economic capital based on the risk profile (ICAAP).
MC: minimum capital requirements as provided in Section 1.1 of the Minimum Capital Regulations.
EVE: measure of risk calculated according to a standardized framework foreseen in section 5.4 of the Risk Management Guidelines.
NWb: basic net worth (tier 1 capital)
Group B Entities whose RPC is insufficient to cover the economic capital requirements arising in the first year of application of the simplified methodology will be granted a five-year phase-in period — counted from the year following the adoption of the simplified methodology — to cover the recorded economic capital shortfall (expressed as a percentage), at a minimum cumulative rate of 20% per year of such shortfall.
Requirements Applicable to Dividend Distribution
The Central Bank has imposed restrictions on the payment of dividends, substantially limiting the ability of financial institutions to distribute such dividends subject to compliance with the rules set forth in the regulations on “Earnings Distributions,” by the Central Bank, under the criterion that the amount to be distributed cannot affect the institution’s liquidity and solvency. This requirement shall be deemed satisfied when it is verified that there are no shortfalls in the minimum capital position—both on an individual and consolidated basis—at the close of the fiscal year to which the retained earnings under consideration relate, or at the last closed position, whichever presents the smaller excess over the requirement, in accordance with the applicable regulatory requirements set forth in the aforementioned regulations.
Such regulations provide that the payment of dividends (other than dividends on common shares), the acquisition of treasury shares, the payment on other tier 1 equity instruments (as determined in accordance with the provisions set forth in the Minimum Capital Regulations) and/or the payment of financial incentives (bonuses) to personnel – in this case, subject to the public order labor regulations (legal, statutory and contractual) governing the financial institutions’ relationships with their personnel– shall be subject to the regulations on “Earnings Distributions.”
Institutions may distribute earnings up to the positive amount derived from the off-balance sheet calculation set forth herein, without exceeding the limits set forth in the regulations on “Earnings Distributions.”
To such effect, the registered balances, as of the end of the fiscal year to which they belong, in the “Unappropriated Retained Earnings” account and in the voluntary reserve for future distributions of earnings shall be computed, deducting the amounts – recorded on the same date – of the legal and statutory reserves – whose creation is mandatory – and the following concepts:
1. 100% of the negative balance of each of the items recorded under “Other comprehensive retained earnings.”
2. The result derived from the revaluation of property, plant and equipment and intangible assets and investment properties.
3. The net positive difference resulting from the calculation at amortized cost and the fair market value recorded by the financial institution in connection with sovereign bonds and/or currency regulation instruments issued by the Central Bank for such instruments valued at amortized cost.
4. The asset valuation adjustments notified by the Superintendency – whether accepted or not by the institution– that are pending registration and/or those indicated by the external audit that have not been accounted.
5. The individual deductibles – regarding asset valuation – established by the Superintendency, including the adjustments derived from the failure to consider agreed adjustment plans.
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6. The lower level of provisions and the higher RPC resulting from the treatment set forth in section 2 of Central Bank Communication “A” 6946 (as amended), in connection with financing granted to MSMEs for the payment of salaries.
In addition, financial institutions shall not distribute earnings out of the income derived from the first application of IFRS, and are obliged to create a special reserve which shall only be reversed for capitalization purposes or to absorb possible negative balances in the item “Unappropriated Retained Earnings.”
The amount to be distributed, which shall not exceed the limits set forth by the Central Bank, shall not compromise the liquidity and solvency of the institution. This requirement shall be considered satisfied once it has been verified that there are no integration defects in the minimum capital position – whether individual and consolidated – as of the end of the fiscal year to which the unappropriated retained earnings pertain or in the last closed position, whichever has the lesser integration excess, recalculating them together (for such purpose only) with the following effects based on the data relevant as of each such date:
1. Those arising after deducting the concepts set forth above in items 1 to 5 above, if applicable, from the assets.
2. The failure to consider the deductibles established by the Superintendency affecting the requirements, integrations and minimum capital position.
3. The deduction of the amounts relating to the following concepts from the unappropriated retained earnings:
o the amount to be distributed and, if applicable, the amount allocated to the creation of the reserve to repay debt instruments, capable of integrating the regulatory capital;
o positive balances due to the application of the minimum presumed income tax – net of allowances for impairment – that have not been deducted from the basic shareholders’ equity, in accordance with the provisions set forth in the Minimum Capital Regulations; and
o adjustments made in accordance with items 1 to 5 above.
4. The failure to consider the limit set forth in Section 7.2. of the Minimum Capital Regulations.
The distribution of earnings shall only be admitted if none of the following events occurs:
o the institution is subject to the provisions of Section 34 “Regularization and Recovery” and Section 35 bis “Institution’s restructuring for the purpose of safeguarding loans and deposits” of the Financial Institutions Law;
o the institution has received financial assistance from the Central Bank under Section 17 of its Charter, due to illiquidity;
o the institution is delayed or in breach of the reporting regime set forth by the Central Bank;
o the institution records minimum capital integration deficits – whether individually or consolidated – (without computing the effects of the individual deductibles established by the Superintendency);
o the integration of the average minimum cash – in Pesos, in foreign currency or in sovereign securities – is smaller than the requirement applicable to the last closed position or the projected position, taking into account the effect of the earnings distribution;
o the institution has failed to comply with the additional capital margins applicable in accordance with Section 4. Financial institutions shall have prior authorization of the Central Bank for the distribution of their results.
Financial entities must obtain prior authorization from the Central Bank for the distribution of their results. In this authorization process, the Superintendency will consider, among other factors, the potential effects of the application of international accounting
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standards according to Communication “A” 6430 (Section 5.5 of IFRS 9 - Impairment of financial assets) and the re-expression of financial statements.
For the determination of distributable results, the increase in computable equity (RPC) resulting from the application of Section 11.4 of the Minimum Capital Regulations must be deducted from the calculations outlined above. Additionally, deductions must be made for lower provisions and higher RPC resulting from treatments established in point 2 of Communication “A” 6946 (and amendments) – for financing to SMEs intended for salary payments – in point 2 of Communication “A” 7427, in point 3 of Communication “A” 7659, and in Communication “A” 7928 – which postponed until January 1, 2025, on an optional and irrevocable basis for Group B and Group C financial institutions (as classified at the relevant time) that are not branches or subsidiaries of foreign banks designated as globally systemically important banks (“G-SIBs”), the application of IFRS 9, Section 5.5.
Pursuant to Communication “A” 8410, dated March 19, 2026, until December 31, 2026, financial entities may distribute results in three equal, non-cumulative monthly installments, beginning on the third business day of May 2026 and of each month in which a payment is made, subject to the prior authorization from the Central Bank. The total distributable amount may not exceed 60% of the net income for fiscal year 2025, after deducting the amounts corresponding to the legal and statutory reserves —recorded as of the same date— whose constitution is required. Such distribution of results must be consistent with the information reported under the Reporting Regime for the "Business Plan and Projections and Capital Self-Assessment Report".
The calculation of distributable income, along with the verification of liquidity and solvency, and the determination of additional capital margins, must all be conducted in the constant currency as of the date of the meeting at which the dividend distribution was decided. Furthermore, the amounts of the installments, where applicable, should be calculated using the same currency value.
Unless otherwise indicated, the regulations explained in this section should be applied to financial information of the banks calculated in accordance with the Central Bank Rules. IFRS differs in certain respects from the Central Bank Rules.
Moreover, in accordance with the Foreign Exchange Regulations, access to the Foreign Exchange Market to pay dividends to non-resident shareholders is subject to certain requirements. For more information, see “Exchange Rate Information and Exchange Controls.”
Capital Conservation Buffer
Central Bank regulations on “Earnings Distributions” state that financial entities shall maintain a capital conservation buffer in addition to the minimum capital requirements in order to ensure the accrual of owned resources to cope with eventual losses, reducing the non-compliance risk.
Financial entities considered as domestic systemically important banks (“D-SIBs”) or G-SIBs must have a capital level that permits a greater capacity for loss absorption. This requirement is based on the negative externalities that could arise from the contagion of an insolvency event involving such institutions or their foreign parent entities. Such events would not only impact the financial system but could also have significant repercussions on the broader real economy.
The conservation capital buffer shall be 2.5% of the amount of RWA. In cases of entities considered systemically important, the margin will be increased to 3.5% of the amount of capital risk weighted assets.
These margins can be increased once again, by the counter-cycle buffer. The objective of the countercyclical capital buffer is to ensure that the capital level of financial institutions corresponds to the accumulation of systemic risk associated with excessive credit expansion and the broader macro-financial environment. When, in the Central Bank’s judgment, credit growth is deemed excessive, leading to an increase in systemic risk, the Central Bank may require the establishment of the countercyclical capital buffer within a range of 0% to 2.5% of risk-weighted assets, but since April 1, 2016, through Central Bank Communication “A” 5938, the countercyclical buffer was established at 0%. Additionally, the Central Bank may modify the margin when it determines that the systemic risk has materialized or decreased. The requirement for the countercyclical capital margin will be satisfied by an increase in the capital conservation margin.
Financial entities with international activity shall consider the geographic location of their credit exposure with local and foreign residents of the private sector and calculate the counter-cycle margin as the weighted average of the capital margin requirements in the
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jurisdictions where they hold exposures. or the purpose of the weighting, credit exposures include those to the private sector subject to capital requirements for credit risk, including those recorded in the trading book. To determine the applicable jurisdiction for each exposure, financial institutions must, when possible, apply the “ultimate risk” principle, identifying the jurisdiction of the risk guarantor rather than the jurisdiction where the obligation has been booked.
The capital conservation margin and the countercyclical capital margin must be fully comprised of common equity tier 1 capital (COn1), net of deductions (CDCOn1).
When such margin is used, financial institutions are required to restore it through additional capital contributions and/or by reducing the distribution of profits. This can be achieved by limiting dividend distributions, repurchasing shares, reducing payments on other Tier 1 capital instruments, and/or adjusting economic incentives (such as bonuses) to personnel.
The dividend distribution shall be limited whenever the level and composition of the RPC, even when it complies with the minimum capital requirements, is within the range of the capital conservation buffer. This limitation applies solely the dividend distribution, but not the operation of the entity. Entities shall be able to operate normally when levels of COn1 are within the range of conservation buffer, as this does not constitute a breach of the minimum capital requirement. When the COn1 ratio, expressed as a percentage of RWA, falls within the capital conservation buffer range, extended for entities classified as systemically important—the restriction to the results distribution shall be increased whenever the coefficient of COn1 comes close to the minimum required in Section 8.5.1 of the Minimum Capital Regulations.
The concepts subject to profit distribution restrictions include dividends, repurchases of own shares, payments on other Tier 1 capital instruments, and/or economic incentives (bonuses) paid to staff.
The table below indicates the minimum capital conservation ratios applicable for different COn1 levels, including the amounts used to meet the minimum COn1 requirement of 4.5% of RWA and the impact on COn1 of the amounts to be distributed:
Coefficient of Common Equity Tier 1 (COn1) net of deductions
(CDcon1) – as percentage of RWA -
Financial Entities – That are not categorized as D-SIBs and G-SIBs Financial Minimum coefficient of capital conservation – as
D-SIBs or G-SIBs- Entities percentage of dividend distribution -
4.5 – 5.13 4.5 – 5.38 100
> 5.13 – 5.75 > 5.38 – 6.25 80
> 5.75 – 6.38 >6.25 – 7.13 60
> 6.38 – 7.0 > 7.13 – 8 40
> 7 > 8 0
As described above, the minimum limits required by the regulations are:
● for COn1, the amount resulting from multiplying the capital RWA by 4.5%;
● for NWb, the amount resulting from multiplying RWA by 6%; and
● for the RPC, the amount resulting from multiplying RWA by 8%.
COn1 must be used in the first place to satisfy the minimum capital requirement of 4.5% of RWA. Subsequently, and in the event the total does not have enough Additional Equity Tier 1 (CAn1) or Tier 2 Capital (NWc), the COn1 shall also be applied to meet requirements of 6% and 8% of Tier 1 Capital and total capital. Only the remaining COn1, if any, can be computed to satisfy the applicable conservation buffer, increased in function of the counter-cycle buffer, if applicable.
Any entity that desires to exceed the dividend distribution limits shall finance this distribution by new contributions of COn1 in the excess amount.
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Credit Risk
For the purposes of applying the provisions of this section, financial institutions will be classified into:
(i) Group 1: Entities designated by the Central as D-SIBs and branches or subsidiaries of foreign banks classified as G-SIBs.
(ii) Group 2: Financial institutions not included in item i).
In cases where specific provisions are not established for each of these groups, the same treatment shall be applied to both groups. Financial institutions that undergo a change in their classification, as outlined above, will have a period of 6 months to apply the specific provisions corresponding to their new group.
The minimum capital requirement for credit risk must be calculated applying the following equation:
CRC = (k * 0.08* RWAc) + INC
Where:
CRC : Capital requirement for credit risk.
k: Factor linked to the credit rating assigned to the entity based on the evaluation performed by Superintendency in accordance with the following scale:
CAMELBIG Rating K Factor
1 1.00
2 1.03
3 1.08
4 1.13
5 1.19
For the purposes of the calculation of the capital requirement, the rating will be that of the third month after the month of the most recent rating informed to the entity. For so long as no notice is given, the “k” factor will be equal to 1.03
“RWAc”: stands for capital risk weighted assets, calculated by adding the value obtained from applying the following formula:
A * p + PFB * CCF * p + non DvP+ (DVP + RCD + INC (significant investments in companies)) * 12.50
Where:
“A” refers to eligible assets/exposures;
“PFB”: off-balance sheet items (computable concepts not recorded in the balance sheet);
“CCF”: the credit conversion factor;
“p” refers to the risk weighting factor, expressed on a per unit basis.
“DvP” refers to failed delivery against payment transactions (for purposes of these rules, failed payment against payment (PvP) transactions are also included). The amount is determined by the addition of the amounts arrived at by multiplying the current positive exposure by the applicable capital requirement.
In addition, “no DvP” refers to transactions that do not involve delivery against payment. The amount is determined by the addition of the amounts arrived at by applying the weighting factor (p) on the relevant transactions.
“RCD” refers counterparty credit risk for over-the-counter (OTC) derivatives transaction.
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“INC (significant investments in companies)” means the incremental minimum capital requirements based on any excess over the following limits:
● equity interest held in companies: 15%
● total equity interests held in companies: 60%
The established maximum limits will be applied on the financial entity’s RPC for the last day before the relevant date, as prescribed in the Central Bank regulations on “Credit Risk Fractioning.”
INC: Increment for the following excesses:
● In the ratio of fixed assets and other concepts (Section 4 of the respective Central Bank regulations), excluding those computed for the determination of INC (significant investments in companies);
● In the limits established in the regulations on “Financing to the Non-Financial Public Sector”, excluding those computed for the determination of INC (significant investments in companies);
● In the limits established in the regulations of “Large Exposures to Credit Risk” – as outlined in the regulations on “Minimum Capital Defaults and Technical Relationships. Applicable Criteria”, excluding those computed for the determination of INC (significant investments in companies);
● In the limits for credit grading (Section of the respective Central Bank regulations);
● In the limit for derivatives on commodities or raw materials, as outlined in Section 1.2 of the regulations on “Spot and Forward Transactions, Repurchase Agreements, Collateral, Other Derivatives, and Investment Funds”. Excluded items are:
(a) securities granted for the benefit of the Central Bank for direct obligations;
(b) deductible assets pursuant to RPC regulations; and
(c) financings and securities granted by branches or local subsidiaries of foreign financial entities by order and on account of their headquarters of foreign branches or the foreign controlling entity, to the extent:
(i) the rules of the country where the parent company or controlling entity is located, the latter defined according to the provisions in force in that jurisdiction, must cover the supervision on a consolidated basis of the local branches or subsidiaries,
(ii) the entity must comply with the provisions of Section 3.1. of the rules on “Credit Evaluations”, requiring for such purpose an international risk rating within the “investment grade” category;
(iii) in case of financings, such financing must be provided by the local branches or subsidiaries only with funds from lines of credit assigned to them by the aforementioned foreign intermediaries (if the assistance is granted in a currency other than that of the foreign resources, the local entity may not assume the exchange risk); and
(iv) in case of locally granted guarantees, counter-guarantees must exist, extended by the parent company or its branches in other countries, or by the foreign controlling entity. These counter-guarantees must be enforceable unconditionally upon simple request from the local branch or subsidiary and immediately effective upon potential execution by the beneficiary.
Computation of Included Concepts
(i) Monthly Individual and Consolidated Base: The included concepts shall be calculated based on the balances as of the last day of each month (principal, interest, premiums, updates—by the CER—and exchange rate differences, as applicable), net of provisions for credit risk (including, where applicable, provisions recorded in liabilities) and devaluation, as well as accumulated depreciation and amortization attributed to them and other reconciling accounts. 100% of the provision for credit risk corresponding to the portfolio of debtors classified as “in normal situation” (sections 6.5.1 and 7.2.1 of the regulations on “Debtors Classification”) and to financings covered by preferred guarantees “A” shall not be deducted.
(ii) Quarterly Consolidated Base: The balances as of the end of the quarter will be considered, applying the corresponding provisions set forth in other aspects.
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Due Diligence
Financial institutions in Group 1 must conduct due diligence at the time of credit issuance and at least annually thereafter to ensure they have a proper understanding of the risk profile and characteristics of their counterparties. The level of sophistication in the due diligence assessments must be proportional to the size and economic importance of the financial entities, as well as the nature and complexity of their operations. Based on these evaluations, financial entities must demonstrate to the Superintendency that the assigned risk weightings are appropriate for the risk profiles of their counterparties. To this end, Group 1 financial entities must:
(a) Implement appropriate measures to assess the financial and operational performance of each counterparty through credit analysis;
(b) Have regular access to information on their counterparties to complete their analysis;
(c) Conduct exposure analysis for counterparties within consolidated groups—individually where possible. When evaluating the repayment capacity of a counterparty, institutions should consider the support of the economic group and the potential negative impact on the counterparty from issues within the group;
(d) Maintain effective policies, processes, systems, and internal controls; and
(e) Be able to demonstrate to Superintendency that their due diligence analyses are consistent with other required evaluations, such as credit risk provisioning processes and economic capital assessments, and comply with the criteria set forth in supplementary regulations.
This requirement does not apply to exposures to governments and central banks.
Criteria for Determining Risk-Weighted Assets
● Risk weighting from the table below apply based on the institution’s group. If due diligence results in higher risk weighting, Group 1 financial entities must apply the higher weighting;
● Risk weighting apply per transaction, with the highest applicable weighting being used if multiple weighting apply;
● Exposures in foreign currency or without credit risk coverage (such as retail exposures and residential mortgages) will have a risk weight of 150%, or 1.5 times the applicable risk weighting, whichever is higher;
● “Exposure” includes loans, securities, guarantees, and contingent obligations. Specific provisions apply to exposures to financial entities, companies, retail exposures;
● Exposures to non-financial public sector entities are treated as private sector exposures when applicable;
● If any exposure is in default, the entire exposure is subject to default treatment;
● Foreign currency exposures settled in pesos (U.S. dollar-linked) are treated as peso-denominated exposures; (viii) Central Counterparty (CCP) exposures and credit risk coverage follow special provisions;
● Portfolio purchases are treated like credits originated by the institution, subject to conditions.
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Each type of asset is weighted according to the level of risk assumed to be associated with it. In broad terms, the weights assigned to the different types of assets are:
Type of Asset Weighting (%)
Availabilities
Cash held in treasury, in transit (when the financial institution assumes responsibility and risk for transportation), in ATMs. 0
Checking accounts and in special accounts with the Central Bank and payment orders in charge of the Central Bank. 0
Monetary gold or gold bars of "good delivery" held within the entity or another financial institution – provided they are individualized under on an allocated basis clauses – and as long as the assets are backed by liabilities denominated in these forms 0
Cash items in the process of collection (checks and drafts for collection), cash in armored cars and in custody at financial institutions 20
Exposure to governments and central banks
To the Central Bank in Pesos, when its source of funds in in that currency 0
To the National Government and to the provincial and municipal governments and the Autonomous City of Buenos Aires in pesos, when their source of funds is in that currency. 0
To the public non-financial sector arising from financing granted to social security beneficiaries or public employees -in both cases with discount code-, to the extent that such transactions are denominated in pesos, the source of funds is in that currency and the installments of all the entity’s financing with a periodic amortization system do not exceed, at the time of the agreements, thirty percent (30%) of the debtor’s income and/or, as the case may be, of the co-debtors. 0
To the non-financial public sector and the Central Bank. Other (3)
- AAA to AA- 0
- A+ to A- 20
- BBB+ to BBB- 50
- BB+ to B- 100
- Below B- 150
- Unrated 100
To other sovereign states of their central banks (3)
- AAA to AA- 0
- A+ to A- 20
- BBB+ to BBB- 50
- BB+ to B- 100
- Below B- 150
- Unrated 100
To entities of the non-financial public sector of other sovereign states, in accordance with the credit rating assigned to the corresponding sovereign (3)
- AAA to AA- 20
- A+ to A- 50
- BBB+ to BBB- 100
- BB+ to B- 100
- Below B- 150
- Unrated 100
To the Bank for International Settlements, the International Monetary Fund, the European Central Bank, the European Stability Mechanism, and the European Financial Stability Facility 0
To the non-financial public sector of the provinces, municipalities and/or the City of Buenos Aires arising from the acquisition of sovereign bonds issued in Pesos by the central administration, when they do not have any one of the guarantees described in the regulations on “Financing to Non-Financial Public Sector”, pursuant to the credit rating assigned to the respective jurisdiction (3)
- AAA to AA- 20
- A+ to A- 50
- BBB+ to BBB- 100
- BB+ to B- 150
- Below B- 200
- Unrated 200
Exposure to the Multilateral Development Banks (MDB)
Exposure to entities that, in the judgment of the Basel Committee on Banking Supervision, meet the eligibility criteria outlined in international standards. 0
Other 50
Exposure to local financial institutions
Exposure to financial institutions by financial entities in Group 1 (SCRA) - Grade A (1)
- Short-term exposures 20
- Other. 40
Exposure to financial institutions by financial entities in Group 1 (SCRA) - Grade B (1)
- Short-term exposures 50
- Other. 75
Exposure to financial institutions by financial entities in Group 1 (SCRA) - Grade C (1)
- Short-term exposures 150
- Other. 150
Exposure to financial institutions by financial entities in Group 2.
- Short-term exposures 20
- Other. 100
Exposure to companies
Investment-grade companies 65
SMEs (Small and Medium Enterprises) not meeting the criteria set in Section 2.8.3 of the “Minimum Capital Requirements for Financial Institutions” rules 85
Specialized financing for large infrastructure projects - pre-operational stage 130
Others 100
Retail exposures
Regulatory Transactional Retail Exposures 45
Regulatory Non-Transactional Retail Exposures 75
Non-Regulatory Retail Exposures 100
Exposures guaranteed by reciprocal guaranty companies (sociedades de garantía recíproca) or public security funds registered with the registries authorized by the Central Bank 50
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Mortgage-Backed Exposures - Regulatory Exposures with Mortgage Collateral on Residential Real Estate
Regarding credit support that does not exceed 55% of the property's value 20
On the amount exceeding 55% of the property's value, the Counterparty Risk Weighting will apply (2)
Mortgage-Backed Exposures - Exposures with mortgage collateral, regulatory on commercial properties.
Up to the amount equivalent to 55% of the property value, the risk weighting of 60% or the Counterparty Risk Weighting will apply, whichever is lower. (2)
For the amount exceeding 55% of the property value, the Counterparty Risk Weighting will apply. (2)
Exposures with non-standard mortgage collateral. 150
Exposures in Default Situations
Regulatory mortgage-backed exposures on residential real estate. 100
Exposures or portions not covered by credit risk mitigants under Section 5 of the regulations on “Minimum Capital Requirements for Financial Institutions”, other than those covered in the previous item
- With specific provisions lower than 20% of the outstanding balance. 150
- With specific provisions equal to or greater than 20% but lower than 50% of the outstanding balance. 100
- With specific provisions equal to or greater than 50% of the outstanding balance. 50
Exposures to instruments (non-deductible portion of the RPC).
Exposures to Instruments by Group 1 Financial Institutions
Subordinated debt and capital instruments that do not meet the characteristics to be considered as equity shares. 50
Equity shares 50
Exposures to Instruments by Group 2 Financial Institutions
Subordinated debt 150
Capital participations. 250
Spot Transactions Pending Settlement (Non-Failed Transactions) 50
Exposures to Natural and Legal Persons Arising from Installment Purchases Made Until November 25, 2021 Using Credit Cards for Overseas Travel Tickets and Other Foreign Tourism Services (Such as Accommodation, Car Rentals, etc.), Whether Directly with the Service Provider or Through Travel Agencies and/or Tourism Platforms. 1.250
Other Assets and/or Off-Balance-Sheet Items (4) 100
Securitization exposures, failed DvP transactions, non DvP transaction, exposures to central counterparty institutions (CCP) and derivative transaction not included in said exposures receive special treatment.
(1) The risk weighting for exposures to financial entities cannot be lower than the risk weighting applicable to the jurisdiction where the counterparty is established in the following cases: (i) when the exposure is not denominated in the local currency of the counterparty's jurisdiction; or (ii) when the debt is incurred by a branch or subsidiary of the counterparty abroad, and is not denominated in the local currency of the jurisdiction where it operates. However, the treatment outlined in items (i) and (ii) does not apply to self-liquidating contingent lines for financing foreign trade with an original contractual maturity of up to one year
(2) The “Counterparty Risk Weighting” shall be the same as that assigned to an exposure without mortgage collateral. Accordingly, a risk weighting of 75% shall apply to exposures to natural persons, 85% to exposures to micro, small, and medium-sized enterprises (“SMEs”), and the risk weighting set forth in the table above shall apply to all other exposures.
(3) Based on ratings from an approved External Credit Assessment Institution (ECAI), such as Standard & Poor’s.
(4) A portion of the exposures that benefit from credit risk mitigation shall be subject to the provisions set forth in Section 5 of the Minimum Capital Regulations
(5) Off-balance sheet items, including commitments for financing and correspondent lines to foreign entities, guarantees provided, sureties on deferred payment checks, documentary credits and acceptances, rediscounted documents with other financial entities, and other credit agreements, will be converted into credit equivalents using the applicable credit conversion factors (CCF). Subsequently, the risk weighting outlined in the table above will be applied, along with any other relevant provisions.
Credit Risk Regulation – Large Exposures
General Overview
Communication “A” 6599 of the Central Bank, as amended and restated by Communication “A” 6620, and its consequent modifications (“Communication “A” 6620”), effective as of January 1, 2019, abrogated credit risk fractioning regulations (except for the provisions related to the non- financial public sector) and replaced the former regime by regulating “large exposures to credit risk.” The system seeks to limit the maximum loss that a financial entity may suffer upon the occurrence of an unexpected default of a counterparty or group of connected counterparties who do not belong to the non-financial public sector, therefore affecting its solvency. The regulations regarding the exposures to credit risk must be applied at all times with every counterparty of the entity.
In this regard, the regulations have established the concept of “group of connected counterparties”, which applies to all cases in which one of the counterparties of a financial entity have direct or indirect control over the rest or in those cases in which financial difficulties experimented by one of the counterparties causes a strong likelihood that its subsidiaries may struggle financially as well. According to the regulation, upon the detection of the existence of a group of connected counterparties by the financial entity, such group shall be considered as a single counterparty and the sum of the exposures to credit risk that a financial entity possesses with all the individual counterparties comprehended that group shall be subject to the information and disclosure requirements provided in section 2.
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One of the main aspects of Communication “A” 6620 is the introduction of the concept of “large exposure to credit risk” in Argentine banking regulations, which is defined as the sum of all values of exposure of a financial entity with a counterparty or group of connected counterparties when it is equal or above 10% of the Tier 1 Capital registered by the financial entity the immediately preceding month of its calculation.
However, the determination of the values of exposure to risk recognize the following exceptions:
● Intraday interbank exposures;
● Exposures of financial entities with qualifying central counterparties, as defined by the Minimum Capital Regulations;
● Exposures with the Central Bank; and
● Exposures with the Argentine non-financial public sector.
The balances held by financial entities in sight accounts at foreign banks, which temporarily and incidentally arise exclusively from client foreign exchange transactions, shall not be subject to the limits outlined in the “Large Credit Risk Exposures” (the “Large Credit Exposures Regulations”) regulations, provided the following conditions are met: (i) the foreign exchange transactions arise from the settlement of foreign currency inflows to the country as ordered by third parties through the respective financial entity; and (ii) the balances result from settlement mismatches due to time zone differences between the international markets where the transactions originate and the local market.
Notwithstanding the above, such balances must be reported to the Superintendency Entities under the applicable reporting regime.
Regarding the information regime, the Central Bank has established that the financial entities shall inform the Superintendency of all the values of exposure to credit risk before and after the application of mitigation techniques, detailing:
● Large credit risk exposures, as defined above;
● Every other exposure to risk which value is equal or above 10% of the Tier 1 Capital of the financial entity, without applying credit risk mitigation techniques;
● Excluded exposures to risk which values are equal or above 10% of the financial entity’s Tier 1 Capital; and
● The financial entity’s 20 largest applicable exposures to risk, regardless of its value in relation with the financial entity’s Tier 1 Capital.
Limits
On one side, Communication “A” 6620 sets at 15% the limit of exposure with a counterpart of the non-financial private sector. Nevertheless, the limit will be increased by 10 percentage points for the part of the exposures that are covered by preferred collaterals.
Specific criteria for exposures to and/or guaranteed by reciprocal guarantee companies (“SGRs”), public guarantee funds (“FGPs”), and financial entities are as follows: The exposure limit is set at 25%, even when the SGR is linked to the financial entity. This limit is increased by 25 percentage points if the lending financial entity belongs to Group B, provided that the exposures to the SGR (even if linked) or to the FGP do not exceed the basic margin set forth in Section 3.1.1 of the “Credit Rating” regulations.
Additionally, it sets special limits for operating with financial institutions in Argentina and abroad (the general rule sets it at 25%). This limit will be increased by 75 percentage points when the lending financial entity is a second-tier commercial bank and belongs to Group B. The aforementioned limits will not apply when any of the conditions set out in the following paragraph are met.
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When both the lending and borrowing financial entities are rated 4 or 5 by Superintendency, the limit will be 0%. In cases where the borrower is a foreign bank, the limit is 5% if the foreign bank does not hold an international credit rating in the “investment grade” category or fails to meet the other requirements stipulated in Section 3.1 of the “Credit Ratings” regulations.
Linked counterparties to the financial institution through control or personal relationships: The limits set forth in the regulations will apply solely on an individual basis. In cases where the linked counterparty is not subject to consolidation with the lending financial institution, these limits must also be observed in relation to the consolidated Tier 1 capital.
The global exposure limits outlined in the regulations are as follows:
● For linked counterparties, the total value of risk exposure concerning the entire set of linked counterparties, excluding those subject to individual limits exceeding 10%, must not exceed 20%.
● Regarding equities and other receivables, the total value of risk exposure in relation to equities not allocated to the trading portfolio, as specified in Section 6.1.2.1 of the Minimum Capital Regulations, must not exceed 15%. Exposures to equity holdings in public utility companies, where holding such shares is necessary to receive services, as well as in companies providing complementary financial services, are excluded from this limit.
● The total exposure limit, including equities in both investment and trading portfolios, as well as credit exposures from term operations (whether related to repos or not) carried out in authorized domestic markets and institutionalized foreign markets—along with any settlement mismatches where there is no central counterparty and the counterparty cannot be identified—must not exceed 50%.
● Concentration risk limits specify that exposures to linked or non-linked counterparties that represent 10% or more of the entity’s Tier 1 capital will be considered computable exposures. The sum of these computable exposures must not exceed three times the entity’s Tier 1 capital, excluding exposures to local financial entities. For the total of all exposures, this sum must not exceed five times the entity’s Tier 1 capital, with the preceding limit still applicable. However, for second-tier commercial banks that are lenders, this limit is increased to ten times the Tier 1 capital.
Financial entities are prohibited from directly or indirectly extending new financial assistance to linked counterparties in the following cases:
● If the counterparties have at least one classification other than “in normal situation,” according to the most recent information available from the “Central de Deudores del Sistema Financiero.”
● If the entity has outstanding debt arising from financial assistance provided by the Central Bank.
Non-compliance with the limits should be exceptional, must be immediately reported to the Superintendency, and must be rectified promptly. In a stress scenario, the Superintendency may waive non-compliance with the interbank limit, once they have occurred, to help ensure the stability of the financial system.
Minimum controls to exposures of affiliates
The regulations set forth three stages for the control of the financial entity’s affiliates exposure:
1)Reports for the entity’s management:
● Report by the CEO;
● Report by the supervisory committee; and
● Acknowledgment of the reports by the entity’s management.
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2) Evidence of the affiliation to the financial entity: the personnel responsible for the analysis and resolution of the credit operations shall expressly register whether or not the client is affiliated with the financial entity.
3) Affidavit evidencing affiliation: affiliated clients shall file an affidavit stating if they belong to the lending entity or if its relationship with such entity implies the existence of a controlling influence. The submission of affidavits by clients regarding their linked status does not relieve the institution from its responsibility to determine this status based on its own analysis.
Interest Rate Risk
Until January 1, 2013, financial entities had to comply with minimum capital requirements regarding interest rate risk. These requirements were intended to capture the sensitivity of assets and liabilities to changes in the interest rates. Communication “A” 5369 removed all rules and regulations regarding minimum capital requirements for interest rate risk. Notwithstanding this change, financial entities must continue to calculate the interest rate risk and remain subject to the Superintendence’s supervision. Communication “A” 6534, dated July 3, 2018 established that the interest rare risk shall be measured through the calculation of the Investment Portfolio Interest Rate (RTICI).
Market Risk
Market risk is defined as the possibility of incurring losses in on-and off-balance sheet recorded positions as a result of adverse changes in market prices.
Regime in Effect Until July 31, 2026
Until July 31, 2026, the capital requirement for market risk shall be the arithmetic sum of the minimum capital requirement for interest rate (trading portfolio), stock (trading portfolio), exchange rate, commodities and options risks (trading portfolio). To meet this capital requirement, entities must apply a “Standard Measurement Method” based on an aggregate of components that separately capture the specific and general market risks for securities positions.
Minimum capital requirements for market risk must be complied with on a daily basis. The information corresponding to the last day of each month must be submitted to the Central Bank on a monthly basis.
The risks subject to this capital requirement include risks arising from positions in financial instruments—securities and derivatives—assigned to the trading book, as well as risks arising from positions in foreign currencies and commodities, regardless of the book to which they are assigned.
The capital requirement for foreign exchange and commodity risk shall apply to the total position in each foreign currency and each commodity. The capital requirement for securities shall be calculated with respect to instruments assigned to the trading book, which must be prudently valued at market prices (marked to market) or using model-based valuations (marked to model). Instruments whose yield is determined by reference to the Coeficiente de Estabilización de Referencia (“CER”) shall be treated as fixed-rate instruments.
Items that must be deducted for purposes of calculating RPC, regardless of the book in which they are recorded, shall be excluded from the computation of the market risk capital requirement.
For these purposes, the trading book comprises positions in financial instruments held with trading intent or to hedge other elements of the trading book, provided that trading is unrestricted or that the instrument can be fully hedged. The trading book must be actively managed and subject to daily valuation with adequate precision.
In addition, institutions must separately calculate and hold capital for counterparty credit risk arising from derivatives and securities financing transactions recorded in the trading book, applying the methods and risk weights applicable to exposures recorded in the banking book, and must maintain clearly defined policies and procedures for assigning exposures to the trading book.
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Regime Effective as of August 1, 2026
Effective August 1, 2026, the capital requirement for market risk shall be equal to the arithmetic sum of the capital charges for interest rate risk, equity risk, foreign exchange risk, and commodity risk, each multiplied by the applicable fixed scalar.
For their determination, institutions must apply the standardized approach established by the Central Bank for each type of risk. Options positions shall be incorporated according to their underlying instrument and added to the relevant capital charge prior to the application of the applicable scalars.
The risks subject to this requirement include positions in financial instruments—securities and derivatives—assigned to the trading book, as well as positions in foreign currencies and commodities, regardless of the book to which they are assigned. Positions must be prudently valued at market prices or using models, as applicable, and instruments indexed to the CER shall be treated as fixed-rate instruments.
The market risk capital requirement must be calculated on a daily basis and satisfied at the close of each business day in accordance with the Minimum Capital Regulations.
Minimum capital requirement for Interest Rate Risk
Until July 31, 2026, the capital requirement for interest rate risk must be calculated in respect of any debt securities and other instruments accounted for as part of the trading portfolio, including any non-convertible preferred shares.
As of August 1, 2026, the capital requirement for interest rate risk must be calculated with respect to all instruments assigned to the trading book whose value is sensitive to changes in market interest rates. This includes all fixed- and floating-rate debt instruments and instruments that behave as such, including non-convertible preferred shares, as well as derivatives. In addition, a capital charge for options on debt instruments must be included, calculated in accordance with the specific treatment provided in the Minimum Capital Regulations.
This capital requirement is calculated by adding two separately calculated requirements: first, the specific risk involved in each instrument, either a short or a long position, and second, the general market risk related to the effect of interest rate changes on the portfolio. A set off of the long and short positions held in different instruments will be allowed.
Minimum capital requirement for Positions In Stock
Until July 31, 2026, the capital requirement for the risk of holding equity positions in the trading portfolio applies to both long and short positions in ordinary shares, convertible debt securities that function like shares and any call or put options for shares, as well as any other instrument with a market behavior similar to that of shares, excluding non-convertible preferred shares, which are subject to the minimum capital requirement for interest rate described in the preceding paragraph. Long and short positions in the same security may be computed on a net basis.
As of August 1, 2026, the capital requirement applies to long and short positions in common shares, convertible debt instruments that behave like equities, commitments to purchase or sell shares, and any other instrument with equity-like behavior (such as equity or equity index futures, forwards and swaps), excluding non-convertible preferred shares, which remain subject to the interest rate risk capital charge, as well as options on equities and equity indexes.
Minimum capital requirement for Exchange Rate Risk
The capital requirement for exchange rate risk establishes the minimum capital required to hedge the risk involved in maintaining positions in foreign currency, including gold. To calculate the capital requirement for exchange rate risk, entities must first quantify its exposure in each currency, and then estimate the risks inherent in the combination of long and short positions in different currencies.
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Minimum capital requirement for Commodities Risk
The capital requirement for commodities risk establishes the minimum capital required to hedge the risk involved in maintaining positions in commodities (precious metals, except for gold). For the purposes of these regulations, a commodity is defined as any physical product that is traded or negotiable on a secondary market. To calculate the capital requirements, each position in a commodity (spot and forward) must be expressed in terms of the corresponding standard unit of measurement (barrels, kilograms, grams, etc.), and following the rules set forth in the regulations on “Large Exposure to Credit Risk.”
Minimum capital requirement for Positions In Options
Entities that only purchase options — provided that the market value of the total options in the portfolio does not exceed 5% of their previous month’s RPC — or whose positions in sold options are fully covered by positions in purchased options with exactly the same contractual terms, may use the simplified method outlined in the regulations on “Large Exposure to Credit Risk.” In all other cases, they must use the delta-plus method, provided for in said regulation.
Consequences of a Failure to Meet Minimum Capital Requirements
In the event of non-compliance with capital requirements by an existing financial institution, Central Bank Communication “A” 6091, as amended, provides the following:
(i) Non-compliance reported by the institution: the entity must comply with the requirements no later than the second month following the month in which the non-compliance is recorded, or submit a remediation and regularization plan within 30 calendar days following the last day of the month in which the non-compliance occurred. In addition, non-compliance with minimum capital requirements will entail a number of consequences for the financial institution, including:
● the Superintendency may appoint an observer with powers established under the FIL;
● The Superintendency impose restrictions on: (i) transformation of financial entities; (ii) establishment of branches abroad; (iii) establishment of representative offices abroad, unless this is in replacement of a previously operational branch that is being closed contemporaneously in the same country; and (iv) Participation in foreign financial entities; and,
● the distribution of cash dividends, as well as the payment of fees, shares, or bonuses arising from the distribution of the entity’s results, will be prohibited. This limitation will remain in effect until the remediation and regularization plans are either submitted or, if submitted, have been observed or found non-compliant by Superintendency.
(ii) Non-compliance detected by the Superintendency: the institution may challenge the non-compliance determination within thirty (30) calendar days after being served notice by the Superintendency. If no challenge is made, or if the defense is dismissed, the non-compliance determination will be deemed to be final and the procedure described in item 1.3.1 of Communication “A” 6091 will apply.
Furthermore, pursuant to the Minimum Capital Regulations, in the event of a daily capital deficiency with respect to market risk capital requirements, excluding the last day of the month, arising from the calculation of requirements for interest rate, exchange rate, or equity risks, the financial institution must restore the capital and/or reduce its financial asset positions until compliance with the required standard is achieved. The institution will have a period of ten business days, starting from the first deficiency, to rectify the situation.
If the deficiency persists for more than ten business days, the entity must submit a regularization and remediation plan within the next five business days, subject to the consequences described below. In cases where deficiencies are determined by Superintendency and persist according to the most recent available information, the entity will have five business days to present an explanation, and Superintendency will respond within ten business days. For the regularization of the non-compliance as described in the previous paragraph, the institution must adhere to the ten-day deadline, starting from the date the deficiency is finalized. If the deficiency is not
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rectified within this period, the entity must submit a regularization and remediation plan within the next five business days, subject to the consequences described below.
Operational Risk
The regulation on operational risk (“OR”) recognizes the management of OR as a comprehensive practice separated from that of other risks, given its importance. OR is defined as the risk of loss resulting from inadequate or failed internal processes, people and systems or from external events. The definition includes legal risk but excludes strategic and reputational risk.
Financial institutions must establish a system for the management of OR that includes policies, processes, procedures and the structure for their adequate management. This framework must also allow the financial entity to evaluate capital sufficiency.
Seven OR event types are defined according to internationally accepted criteria:
● internal fraud;
● external fraud;
● employment practices and workplace safety;
● clients, products and business practices;
● damage to physical assets;
● business disruption and system failures; and
● execution, delivery and process management.
Financial institutions generally rely on three (3) lines of defense, the degree of implementation of which must be commensurate with the nature, size, and complexity of the institution’s operations, and aligned with its risk profile.
● The first line of defense lies within the business units, which are responsible for identifying and assessing operational risks.
● The second line of defense consists of the independent operational risk management function, which provides an objective perspective on the material operational risks identified by the business units, evaluates the design and effectiveness of key controls, and assesses risk tolerance.
● The third line of defense—typically carried out by internal or external audit—ensures that the operational risk management framework is appropriate. It is tasked with reviewing the design and implementation of the operational risk management systems and associated governance processes in both the first and second lines of defense, as well as the validation processes in place to guarantee their independence and consistent application in accordance with the institution’s policies.
Where both first and second line functions coexist within a business unit, institutions must clearly document and delineate the responsibilities of each function, emphasizing the independence of the second line.
Financial entities are charged with implementing an efficient OR management system following the Central Bank’s “Guidelines for Risk Management in Financial Institutions”. A solid system for risk management must have a clear assignment of responsibilities within the organization of financial entities. Thus, the regulation describes the roles prepared by each level of the organization in managing of OR (such as the roles of the Board of Directors, senior management and the business units of the financial institution).
A financial institution’s size and sophistication, and the nature and complexity of its products and processes, and the extent of the transaction determines the type of “OR Unit” required. For small institutions, this unit may even consist of a single person. This unit
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may functionally respond to the senior management (or similar) or a functional level with risk management decision capacity that reports to that senior management.
An effective risk management will contribute to prevent future losses derived from operational events. Consequently, financial entities must manage the OR inherent in their products, activities, processes and systems. The OR management process comprises:
(a) Identification and assessment: the identification process should consider both internal and external factors that could adversely affect the development of the processes and projections created according to the business strategies defined by the financial institution. Financial entities should use internal data, establishing a process to register frequency, severity, categories and other relevant aspects of the OR loss events. This should be complemented with other tools, such as operational risk self-assessments (including the analysis of inherent and residual risk), operational risk event databases, event management systems, monitoring frameworks and control testing, metrics, scenario analysis, and benchmarking and comparative assessments.
(b) Monitoring: an effective monitoring process is necessary for quickly detecting and correcting deficiencies in the policies, processes and procedures for managing OR. In addition to monitoring operational loss events, banks should identify forward-looking indicators that enable them to act upon these risks appropriately.
Financial institutions must maintain a robust control environment, supported by sound internal policies, procedures, systems, and controls, as well as effective risk mitigation and/or risk transfer strategies. Internal controls must ensure operational efficiency, asset protection, the reliability of financial reporting, and compliance with applicable laws and regulations.
A strong control framework should include risk assessments, control activities, information and communication mechanisms, and monitoring processes. Controls must also address operational resilience, proper segregation of duties, conflict of interest management, and specific safeguards such as periodic reconciliations, access controls, training programs, and mandatory leave policies.
Where internal controls prove to be insufficient, they may be supplemented through risk transfer tools, such as insurance, always under the oversight of the Board of Directors. In addition, institutions must manage risks associated with the outsourcing of services through proper due diligence processes, clearly defined contractual agreements, monitoring mechanisms, and contingency plans.
Financial institutions must also establish Business Continuity Plans (“BCPs”) designed to ensure operational continuity and minimize losses in the event of severe disruptions. BCPs must be aligned with the institution’s operational resilience framework, formally approved by the Board of Directors, and involve all three lines of defense.
Such plans must be based on scenario analyses and include impact assessments, recovery procedures, activation thresholds, and communication protocols. BCPs should address both internal and external critical functions, and must be tested on a regular basis, kept up to date, supported by role-specific training, and reported to senior management and the Board.
Technology and Information Security Risk Management
Financial institutions are required to implement a robust technology and information security risk management program, consistent with the broader operational risk management framework. This program must address the identification, assessment, mitigation, and continuous monitoring of risks, while ensuring the confidentiality, integrity, and availability of systems and data.
The program must align with the institution’s risk appetite and applicable regulatory requirements, be tested and updated regularly, and be supported by threat intelligence. Institutions must also be prepared to respond to disruptive events—including cybersecurity incidents and large-scale remote access failures—and must ensure the timely updating of systems, secure application development, and the implementation of appropriate user access management processes.
Transparency
Financial institutions must publicly disclose, on a regular basis through their websites or reports, their assessment of operational risk management practices and their exposure to such risk. These disclosures must be proportionate to the size and complexity of the
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institution’s operations and should include material loss events, risk management frameworks, and corporate governance practices. The institution must adopt a formal disclosure policy, approved by senior management and the Board of Directors, and subject to periodic review to ensure the adequacy and effectiveness of the published information.
The following is a summary of the key regulatory requirements applicable to financial institutions in the area of operational risk management.
For the purposes of the provisions set forth in this section, financial institutions shall be classified into Group 1 and Group 2. Institutions that undergo a change in classification—pursuant to the criteria outlined in the preceding sections—shall have a period of six (6) months to implement the specific requirements applicable to the new group to which they belong.
The capital requirement for OR for institutions in Group 1 will be determined on a monthly basis, using the following formula:
CRO = BIC x ILM
Where:
● CRO: OR capital requirement.
● BIC: business indicator component, which is the product of the business indicator (BI) and a series of marginal coefficients (αi).
The BI is an approximation of operational risk based on financial statement information. It will be determined by the following formula:
BI = VA (ILDCProm + SCProm + FCProm + RMProm)
o ILDCProm: Interest, leasing, and dividend component. It will be determined by the following formula: Min. [VA (interest income – interest expenses); 5% × interest-bearing assets] + dividend income
o SCProm: Service component. It will be determined by the following formula: Max. [other operational income; other operational expenses] + Max. [fee and commission income; fee and commission expenses]
o FCProm: Financial component. It will be determined by the following formula: VA (net result of trading portfolio) + VA (net result of investment portfolio)
o RMProm: Total monetary result VA: Absolute value.
Each term within the 3 components and the monetary result must be calculated as the average of the values of the last 3 consecutive 12-month periods prior to the month in which the calculation is made, expressed in homogeneous currency at the close of the 36-month calculation period: t, t-1, and t-2. First, the net values corresponding to each 12-month period (e.g., interest income minus interest expenses) must be determined, then the average of the 3 periods must be calculated.
The Business Indicator (BI) consists of several components:
(i) Interest, Leases, and Dividends (ILDC) include income and expenses from interest and adjustments on financial assets and liabilities, such as loans, deposits, financial leases, and derivatives. It also covers income from dividends for investments in non-consolidated subsidiaries and associates.
(ii) Services (SC) include income and expenses from services like advisory fees, asset management, and commissions, as well as other operational income and expenses from routine banking activities not captured elsewhere.
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(iii) Financial (FC) includes net results from trading portfolios and investment portfolios, covering assets held for trading or investment, realized gains and losses, and hedging accounting.
Certain items, such as administrative costs, insurance operations, and depreciation, are excluded from BI calculations.
At the consolidated level, the BI is calculated based on the consolidated values of income and expenses for the entire banking group. Subconsolidated calculations should be performed using the BI figures of the entities consolidated at each specific sublevel. At the individual level, the BI figures of each subsidiary must be used.
Financial institutions may request the Superintendency’s approval to exclude discontinued operations from the BI, with the exclusion applied immediately upon approval. For business combinations, the BI calculation must include the financial data of acquired businesses from the date of acquisition, reflecting the last three consecutive 12-month periods.
The BIC is determined by the following expression: BIC = ∑ BIi x αi
Where the marginal coefficients (αi) are determined based on the BI range.
Category BI Range (in billion euros*) Marginal Coefficients (αi)
1 ≤ 1 12%
2 1 < BI ≤ 30 15%
3 > 30 18%
The marginal coefficients increase as the size of the Business Indicator (BI) grows. For entities in Category 1 (BI equal to or less than the equivalent of €1 billion in local currency), the Business Indicator Component (BIC) equals BI multiplied by 12%. The marginal increase in BIC resulting from an increase of one unit of BI is 12% in Category 1, 15% in Category 2, and 18% in Category 3.
● ILM: Internal loss multiplier equal to 1.
RWA for OR are equal to 12.5 times the CRO
The capital requirement for OR for institutions in Group 2 will be determined on a monthly basis, using the following formula:
Where:
● “Cro”: the capital requirement for OR.
● “α”: 15%.
● “n”: the number of 12-month consecutive terms with positive IB, based on the 36 months preceding the month of calculation. The maximum value of n is 3. No overlapping months are allowed when forming the periods.
When n equals zero (n=0), the entity must comply with a requirement equivalent to the limit set in Section 7.3 of the Minimum Capital Regulations.
● “IBt”: Gross income for a 12-month consecutive period—provided it is positive—corresponding to the last 36 months prior to the month in which the calculation is made, expressed in the currency of the month preceding the calculation. Gross income is defined as the sum of: (i) financial income and income from services, minus financial expenses and service costs, (ii) other income minus other expenses, and (iii) total monetary results.
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The following items, included under i) and ii), shall be excluded as applicable:
o Charges related to the creation of provisions, reversal of provisions established in prior periods, and recoveries of previously written-off credits in the current period;
o Results from investments in financial entities and companies, to the extent they relate to items deductible from computable equity;
o Gains from the sale of assets classified and measured at amortized cost or fair value with changes in Other Comprehensive Income.
The requirement determined through application of the formula described above may not exceed:
(i) 20%, in the case of Group A entities, of the average over the preceding 36 months—prior to the month to which the requirement relates—of the minimum capital requirement for credit risk, expressed in constant currency of the month preceding the calculation;
(ii) 17%, in the case of Group B entities, of the average over the preceding 36 months—prior to the month to which the requirement relates—of the minimum capital requirement for credit risk, expressed in constant currency of the month preceding the calculation.
The maximum cap set forth above shall be reduced to 11% where the financial institution has received a rating of 1, 2, or 3, in accordance with the assessment issued by Superintendency in connection with its most recent inspection, with respect to all of the following aspects: the institution as a whole, its information technology systems, and the performance of the officers responsible for evaluating its internal control systems.
Where the financial institution has received a rating of 1 or 2 in all of the aforementioned aspects, the maximum cap shall be further reduced to 7%. For these purposes, the most recent rating notified shall be taken into account for purposes of calculating the requirement to be met in the third month following the month in which such notification is received.
The monthly minimum capital requirement for operational risk applicable to Group 1 and Group 2 financial institutions for the first month shall be equal to 10% of the aggregate capital requirements for credit risk and market risk—calculated, in the case of market risk, based on positions as of the last day of that month.
From the second month through the thirty-sixth month, the monthly requirement shall be equal to 10% of the average of the capital requirements determined for the months elapsed up to and including the calculation period, based on the aforementioned risks, in accordance with the following formula:
Minimum Cash Reserve Requirement
The minimum cash reserve requirement requires that a financial institution keep a portion of its deposits or obligations readily available and not allocated to lending transactions and it is included in the Central Bank “Rules of Minimum Cash,” as amended and supplemented from time to time (the “Minimum Cash Requirements Regulations”).
Minimum cash requirements are applicable to demand and time deposits and other liabilities arising from financial intermediation denominated in Pesos, foreign currency, or government and corporate securities, and any unused balances of advances
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in checking accounts under agreements not containing any clauses that permit the bank to discretionally and unilaterally revoke the possibility of using such balances.
Minimum cash reserve obligations exclude (i) amounts owed to the Central Bank, (ii) amounts owed to local financial institutions, (iii) obligations owed to foreign banks — including parent companies and controlling entities of local institutions and their branches — arising from financial lines granted by non-related parties (as defined in Section 1.2.2 of the Large Credit Exposures Regulations), foreign credit lines designated for the financing of foreign trade transactions, and obligations owed to multilateral development banks, (iv) cash purchases pending settlement and forward purchases, (v) cash sales pending settlement and forward sales (whether or not related to repurchase agreements), (vi) overseas correspondent banking operations, (vii) demand obligations for money orders and transfers from abroad pending settlement to the extent that they do not exceed a three business day term as from their deposit; and (viii) demand obligations with business for the sales made by debt, prepaid, credit and/or purchase cards
The liabilities subject to these requirements shall be computed based on the principal amounts actually traded, including, where applicable, quotation differences (whether positive or negative). Accordingly, accrued interest and premiums—whether due or not yet due—on said liabilities shall be excluded, to the extent such amounts have not been credited to an account or otherwise made available to third parties, as well as, in the case of UVA- and UVI-denominated time deposits, the amount accrued as a result of increases in the value of such units.
Passive repurchase transactions (repos) and borrower-side securities lending (cauciones bursátiles tomadoras) shall be computed on the basis of their combined net position, provided that such position is negative (borrower), where they share the same maturity and are conducted against a central counterparty (CCP) in a market authorized by the CNV.
The minimum cash requirement shall be determined based on the average of the daily balances of the covered obligations:
● balances recorded at the close of each day during the period preceding their fulfillment, in the case of peso-denominated requirements, except for peso deposits held in accounts of payment service providers offering payment accounts (“PSPCPs”) in which clients’ funds are deposited; and
● balances recorded at the close of each day of each calendar month, in the case of foreign currency requirements, securities, and peso deposits held in PSPCP accounts in which clients’ funds are deposited.
Averages shall be calculated by dividing the sum of daily balances by the total number of days in each relevant period. On days with no recorded activity, the balance as of the immediately preceding business day shall be carried forward.
The requirement shall be calculated and met separately for each currency and/or each security or monetary regulation instrument in which the covered obligations are denominated.
For term deposits in national government securities or Central Bank monetary regulation instruments, the requirement is determined in the same asset type, based on market value. National securities in Pesos with dual-currency yield are treated like Peso-denominated securities. The requirement remains even if these securities are no longer regularly quoted in significant amounts.
For term deposits in other securities, the requirement is based on market value, in:
●Pesos or national government securities in pesos, when the asset is in pesos; or
●U.S. dollars or national government securities in U.S. dollars, when the asset is in foreign currency.
For foreign currency transfers exceeding the maximum term of 3 business days, the requirement is allocated to the respective currency. If historical data is unavailable (e.g., for new entities), current period data must be used for calculations.
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The table below shows the percentage rates that should be applied to determine the required minimum cash reserve requirement for financial institutions, depending on whether:
(i) the financial entities are included in Group “A”, as provided by Section 4 of the Central Bank Rules on “Authorities of Financial Institutions” (the “Authorities Rules”), and/or branches or subsidiaries of foreign banks are classified as systemically important (G-SIB) not included in that group; or
(ii) the remaining financial entities.
Section 4 of the Authorities Rules classifies financial institutions into Group A or Group B. The classification is based on an indicator equal to the sum of: (i) the average total assets for the 12 consecutive months from October of the second preceding year through September of the preceding year; and (ii) the average daily deposit balances for the same 12-month period, in each case as reported under the applicable regulatory reporting regimes.
a) Group “A”: institutions for which the indicator is equal to or greater than 1% of the aggregate indicator for the Argentine financial system (the “Group A Entities”);
b) Group “B”: institutions not included in Group A (the “Group B Entities”).
Pursuant to Central Bank Communication “A” 8367, the Bank is a Group A Entity.
The indicator is calculated on an individual basis, except for controlling financial institutions subject to consolidated supervision, in which case it is determined on a consolidated monthly basis.
The classification into Group A and Group B is made annually and applies for the calendar year following the year in which the indicator is calculated. Newly licensed financial institutions are deemed to be Group B Entities until sufficient information is available to perform the calculation described above.
The following figures arise from Central Bank Communication “A” 8378, as amended:
Rate %
Group A and G-SIB Remaining Financial Institutions
Foreign
Item Pesos Currency Pesos Foreign Currency
1- Checking account deposits and demand deposits opened at credit cooperatives 45 25 20 25
2- Savings account, salary/social security accounts, special accounts (except for deposits included on items 7, 10 and 15 of this table), and other demand deposits and liabilities, pension and social security benefits credited by ANSES pending collection and immobilized reserve funds for liabilities the Minimum Cash Requirements Regulations 45 25 20 25
3- Unused balances of advances in checking accounts under executed overdraft agreements 45 25 20 25
4- Deposits in checking accounts of non-bank financial institutions, computed for purposes of meeting their required minimum cash reserve 100 100
5- Time deposits, liabilities under “acceptances” (including responsibilities for sale or transfer of credits to agents different from financial institutions), fixed-term investments with the option of early cancellation (excluding those covered under item 12 of this table) or renewal for a specified period (with variable remuneration), and other fixed-term liabilities, except deposits included in items 7, 9 and 11 of this table, as well as debt securities (including notes), classified according to their residual maturity:
(i) Up to 29 days 28.5 23 14.5 23
(ii) From 30 days to 59 days 17.5 17 10.5 17
(iii) From 60 days to 89 days 7.5 11 5.5 11
(iv) From 90 days to 179 days 3.5 5 3.5 5
(v) From 180 days to 365 days 3.5 2 3.5 2
(vi) More than 365 days 3.5 — 3.5 —
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Rate %
Group A and G-SIB Remaining Financial Institutions
Foreign
Item Pesos Currency Pesos Foreign Currency
6- Liabilities arising from foreign financial credit lines — not structured as time deposits or as the purchase of debt securities (which are subject to the requirement set forth in item 5 of the table) — obtained from related parties, as defined in Section 1.2.2 of the Large Credit Exposures Regulations, according to their original maturity
(i) Up to 179 days 20 20
(ii) More than 179 days
7- Demand and time deposits made upon a court order with funds arising from cases pending before the court, and the related immobilized balances
Demand deposits 22 10
According to their residual maturity:
(i) Up to 29 days 25,5 15 13,5 15
(ii) From 30 days to 59 days 17,5 15 10,5 15
(iii) From 60 days to 89 days 7,5 15 5,5 15
(iv) 90 days or more 3,5 15 3,5 15
8- Fixed-term investments formalized through non-transferable registered certificates in pesos, held by public sector entities that have the right to exercise an early cancellation option within less than 30 days from their issuance 28,5 14,5
9- Fixed-term deposits and investments in UVA and UVI— including savings accounts and debt securities (including notes) in UVA and UVI— classified according to their residual maturity
(i) Up to 29 days 10,5 10,5
(ii) From 30 days to 59 days 8,5 8,5
(iii) From 60 days to 89 days 6,5 6,5
(iv) 90 days or more 3,5 3,5
10- Severance Fund for Workers in the Construction Industry and for Workers covered by Law No. 20,744, denominated in UVA 10,5 11
11- Deposits and fixed term investments created in the name of minors for funds they receive freely — —
12- Peso-denominated demand deposits and fixed-term investments with an early termination option exercisable from the date the investor may exercise such option, which constitute the assets of money market mutual funds 40 40
13- Reverse repurchase agreements and securities lending transactions – as liabilities – classified according to their remaining term
(i) Up to 29 days 40 23 40 23
(ii) 30 days or more 35 17 35 17
(iii) From 60 days to 89 days 35 11 35 11
(iv) From 90 days to 179 days 35 5 35 5
(v) From 180 days to 365 days 35 2 35 2
(vi) More than 365 days 35 - 35 -
14- Deposits in Pesos in accounts PSPCP in which the funds of their clients are deposited 100 100
15- Deposits in special accounts:
15.1- In Pesos (“Special accounts for holders with agricultural activity” and “Special accounts for exporters”). 3.5 — 3.5 —
15.2- In U.S. dollars (“Special accounts to credit export financing”). — — — —
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Financial institutions may meet the requirement in Pesos, both for the period and on a daily basis, with “National Treasury Bonds in Pesos, maturing May 23, 2027,” “National Treasury Bonds in Pesos, maturing November 23, 2027,” and with the national government securities in pesos specified in the following paragraph, up to the following limits:
a) 5 percentage points above the rates set forth in item 8, in subsections (i) and (ii) of item 5, and in paragraph (a) and subsections (i) and (ii) of paragraph (b) of item 7;
b) 2 percentage points above the rates set forth in subsections (iii) of item 5 and subsection (iii) of paragraph (b) of item 7.
c) 45 percentage points of the rate specified in item 14 of the preceding table; and
d) Entities classified in Group A and branches or subsidiaries of G-SIBs not included in that group: 5 percentage points above the rates set forth in items 1 through 3 of the preceding table.
Integration with Public Securities
Financial entities may meet the minimum cash requirement in Pesos – both for the period and on a daily basis – with Central Bank Liquidity Bills (“LELIQ”), Central Bank Notes (“NOBAC”), and national government bonds in Pesos – including those adjusted by CER and with dual-currency returns (BONO DUAL), excluding those linked to the evolution of the U.S. dollar and liquidity fiscal bills (“LeFi”) – provided that the residual maturity at the time of integration does not exceed 760 calendar days, acquired through primary subscription, in accordance with the following:
● Demand deposits referred to in items 1 to 3 of the preceding table:
o Group A entities and branches or subsidiaries of G-SIBs not included in such group: up to 0 percentage points of the prescribed rate.
o Entities not included in the foregoing category: up to 6 percentage points of the prescribed rate.
● Fixed-term deposits and fixed-term investments—excluding those covered under item 12 of the referenced table—made by holders from the non-financial private and non-financial public sectors, and those referred to in items 7 and 10: the full requirement, except for the percentage points permitted to be met through integration with public securities as provided in the following paragraph.
● Variable-yield fixed-term investments made by clients engaged in agricultural activities (pursuant to section 2.5.2.2 of Central Bank Regulations on Deposits and Fixed-Term Investments): the full requirement, except for the percentage points permitted to be met through integration with public securities as provided in the following paragraph.
● Other placements:
o Group A entities and branches or subsidiaries of G-SIBs not included in said group:
up to 9 percentage points of the rate set forth in item (i) of item 5 of the preceding table;
up to 7 percentage points of the rate set forth in item (ii) of item 5 of the preceding table;
up to 3 percentage points of the rates set forth in items (i) through (iii) of item 9 of the above-mentioned table; and
up to 2 percentage points of the rate set forth in item (iii) of item 5 of the preceding table.
o Entities not included in the preceding paragraph:
i. up to 3 percentage points of the rates set forth in item (i) of item 5, and in items (i) through (iii) of item 9 of the preceding table;
ii. up to 2 percentage points of the rate set forth in item (ii) of item 5 of the preceding table.
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Financial institutions may meet the Peso-denominated requirement with the peso-denominated national public securities referred to in the preceding paragraph, provided that such securities have an original maturity of no less than 60 days at the time of subscription, as follows:
• Up to 5.5 percentage points of the rates set forth in items 1 through 3 of the preceding table, using the above-mentioned public securities subscribed through primary issuance on or after August 25, 2025.
• Up to 3.5 percentage points of the rates set forth in items 5, 7, 8 through 12, 13, and 15, using the above-mentioned public securities subscribed through primary issuance on or after August 25, 2025.
• Up to 3 percentage points of the rates set forth in items 1 through 3, using the above-mentioned public securities subscribed through primary issuance on or after November 20, 2025.
Additionally, the integration of the minimum cash reserve requirement in pesos—both periodic and daily—that under the Minimum Cash Requirements Regulations may be fulfilled with Argentine national sovereign debt securities denominated in pesos—including those indexed to the CER and with dual-currency yield (BONO DUAL), excluding those linked to the U.S. dollar exchange rate—acquired by primary subscription, may be performed with such securities having a residual maturity of not less than 300 days nor more than 730 calendar days at the time of subscription, received in swap operations arranged by the National Government for securities acquired either by primary subscription or in the secondary market.
For purposes of satisfying the requirement with peso-denominated national public securities, LELIQs and/or NOBACs as provided in this section, such instruments must be valued at market prices—regardless of the valuation criteria applied for accounting purposes—and must be deposited in Subaccount 60 (minimum cash) opened at the Central Registry and Settlement System for Public Debt Instruments, Monetary Regulation Instruments and Financial Trusts (CRYL).
Additionally, for purposes of meeting the peso-denominated minimum cash requirement provided for under the paragraph “Integration with Public Securities,” LELIQs actually used to post guarantees to cover net debit balances arising from the peso-denominated clearing processes of electronic clearing houses shall also be admissible, up to a maximum of 50% of the guarantees required for each product.
The minimum cash requirement rates applicable to items 1, 2, 3, 12, and 13 (all peso-denominated) shall be increased by 5 percentage points from August 19, 2025 through March 31, 2026. This additional requirement shall apply to Group A financial entities and to branches or subsidiaries of G-SIBs not included in such group, and may be met with the public securities referred to in the paragraph “Integration with Public Securities”, provided that such securities are acquired through primary issuance on or after November 20, 2025 and have an original maturity of no less than 60 days at the time of subscription.
The average minimum cash requirement in pesos will be reduced as explained below:
1. Compliance with the Minimum SMEs Quota and Specific Financing. As from July 1, 2024, financial entities included in the list in Annex II of Communication “A” 7859 must have met the Minimum SMEs Quota for the previous quarter in order to apply this reduction each subsequent quarter.
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The cash reserve requirement will be reduced based on the proportion of financing provided to SMEs in pesos, relative to the total financing to the private non-financial sector in pesos. The SMEs classification will be based on the criteria outlined in the regulations on “Determining the Status of Micro, Small, or Medium-Sized Enterprises”, with the classification being valid at the time of the loan issuance, as per the following table:
Participation, in the total of financing operations Deductions (over
to SMEs with respect of total of financing the total of
operations to the non-financial private sector, in the concepts included
the institution in Pesos) %
Less than 4 0
From 4 to less than 6 0.50
From 6 to less than 8 0.63
From 8 to less than 10 0.75
From 10 to less than 12 0.88
From 12 to less than 14 1.00
From 14 to less than 16 1.13
From 16 to less than 18 1.25
From 18 to less than 20 1.38
From 20 to less than 22 1.50
From 22 to less than 24 1.63
From 24 to less than 26 1.75
26 or more than 26 1.88
SMEs financing includes purchases of Electronic Credit Invoices and holdings in funds under the “Special Regime for SMEs Mutual Funds.” The percentage of SMEs financing will be based on whether the financing meets the SMEs condition at the time of granting. If the borrower no longer qualifies, only financing up to that point is considered.
The 12-month moving average of SMEs financing in pesos will be compared to total financing granted to the non-financial private sector by the entity.
2. Depending on the cash withdrawals made through institution ATMs. The minimum reserve requirement will be reduced based on the amount calculated through the following expression, without exceeding the previously determined requirement, as outlined in the previous point.
Where:
● Msi: Monthly average of total daily cash withdrawals from ATMs located at the entity’s operating branches, for the previous month, according to the jurisdiction of the entity, as defined in the Regulation on “Branch Categorization for Financial Institutions”.
● Mni: Monthly average of total daily cash withdrawals from ATMs located outside the entity’s operating branches (neutral locations), for the previous month, according to the same jurisdictional categorization.
● Psi: Weight factor applicable to the amount Msi.
● Pni: Weight factor applicable to the amount Mni.
Applicable weight factors based on the categories in which the ATMs are located
i Psi Pni
1 (category III) 4.25 7.05
2 (categories IV, V, and VI) 7.50 14.80
For this purpose, the included ATMs are those that – at least – allow users to make cash withdrawals regardless of the institution in which they are customers and the network managing such equipment and that –on a monthly average, computing business and non-business days – have remained accessible to the public for at least ten hours a day.
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When there is an excessive concentration of liabilities (in terms of holders and/or maturities) that presents a significant liquidity risk for the financial institution and/or has a major negative impact on systemic liquidity, additional minimum reserve requirements may be imposed on the institution’s liabilities and/or other complementary measures deemed necessary.
This situation will be considered to occur when, among other factors, any of the following conditions are met:
● A high percentage of liabilities is concentrated with a single holder or a group of holders.
● For term liabilities, the maturity is short.
● These liabilities represent a significant percentage of the required minimum reserve integration and/or the total private sector deposits held by the institution. Likewise, the minimum cash requirement may be increased due to non-compliance with the rules on the “Credit Line for productive investment”.
In addition to the abovementioned requirements, the reserve for any defect in the application of resources in foreign currency net of the balances of cash in the entities, in custody in other entities, in transit and in Transporters of Securities, for a certain month, shall be applied to an amount equal to the minimum cash requirement of the corresponding currency for each month. Exclusions apply to those arising from exchange operations ordered by the Federal Government, and consequently, they cannot be offset with foreign currency purchases. Deposits in “Special Accounts for Export Financing” cannot be applied to cash in the entities, in custody with other financial entities, in transit, or in securities.
Integration
The minimum cash reserve must be set up in the same currency or securities or debt instruments for monetary regulation to which the requirement applies, and may include the following:
(1) Accounts maintained by financial institutions with the Central Bank in Pesos.
(2) Accounts of minimum cash maintained by financial institutions with the Central Bank in U.S. dollars, or other foreign currency.
(3) Special guarantee accounts for the benefit of electronic clearing houses and to cover settlement of credit card, vouchers, and ATM transactions and immediate transfer funds.
(4) Checking accounts maintained by non-bank financial institutions with commercial banks for the purpose of meeting the minimum reserve requirement.
(5) Special accounts maintained with the Central Bank for transactions involving social security payments by the ANSES.
(6) Minimum cash sub-account 60, authorized in the Registration and Settlement Central for Public Debt and Financial Trusts – CRYL for public securities and securities issued by the Central Bank at their market value.
These items are subject to review by the Central Bank and may be amended in the future.
Before August 18, 2025, compliance with the minimum cash reserve requirement was measured on the basis of the monthly average of the daily balances of eligible items maintained during the relevant period. Such average was calculated by dividing the aggregate daily balances by the total number of days in the month. Offsetting deficit positions with surplus positions arising from different requirements was not permitted.
Effective August 18, 2025, the Central Bank amended the methodology for compliance with the minimum reserve requirement in Pesos, replacing the prior measurement—based on the average of daily balances of eligible items—with a daily measurement framework. As a result, the previously available carryforward mechanisms were discontinued. However, effective as of the February 2026 position, institutions may again make use of the carryforward mechanism provided under the Minimum Reserve Rules for
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purposes of integrating the Peso reserve requirement. Any such carryforward may not exceed 5% of the applicable requirement and must be fully offset in the immediately following month.
● Minimum Daily Integration in Pesos. On no day of the relevant period may the aggregate balance of the items eligible for integration, as recorded at the close of each day, be less than 75% of the period’s minimum cash requirement.
● Minimum Daily Integration in Foreign Currency. On no day of the relevant period may the aggregate balance of the items eligible for integration, as recorded at the close of each day, be less than 25% of the total minimum cash requirement, as determined for the immediately preceding period, recalculated based on the requirements and eligible items in effect during the period to which the reserves relate. Such daily requirement shall be 50% where, during the preceding computation period, an average integration shortfall exceeding the permitted carryover margin was recorded.
No minimum daily integration shall be required for deposits in securities and Central Bank monetary regulation instruments.
Non-Compliance
Shortfalls in the integration of the minimum cash requirement in pesos, foreign currency, and securities and Central Bank monetary regulation instruments, as well as shortfalls in minimum daily integration, shall be subject to a charge payable in pesos equivalent to three (3) times the Argentina Wholesale Rate (TAMAR) – total banks, as reported for the last business day of the relevant period, or, if unavailable, the most recently published rate. Where shortfalls in the average position and in minimum daily integration occur concurrently within the same period, the higher resulting charge shall apply. For purposes of determining average position shortfalls, the following shall be taken into account: (i) shortfalls for which the carryover option is not exercised, and (ii) shortfalls that cannot be carried forward to the following period because they exceed the permitted margin.
Minimum SMEs Quota
As noted above, financial institutions included in Annex II to Communication “A” 7859, including the Bank, as from April 1, 2024, are required to maintain a quarterly average of daily balances (April–June; July–September; October–December; and January–March of the following year) of covered funding equal to at least 7.5% of the institution’s peso-denominated deposits from the non-financial private sector that are subject to fractional reserve requirements — excluding the deposits referred to in Sections 3.12 and 3.13 of the Central Bank rules on “Savings Deposits, Payroll Accounts and Special Accounts”. Such percentage shall be calculated on the basis of the monthly average of daily balances corresponding to the second month preceding the relevant quarter (i.e., February, May, August and November, respectively).
For Group B Entities, the applicable minimum percentage shall be 25% of the percentage indicated above.
For these purposes, eligible balances include the outstanding residual amounts of financings allocated to: (i) the 2020, 2021, 2021/2022, 2022, 2022/2023, 2023 and 2023/2024 tranches under the Central Bank rules on the “Credit Line for Productive Investment for MiPyMEs”; (ii) Sections 7.2.1 and 7.2.2 thereof, provided such financings were disbursed on or before October 15, 2020; and (iii) prior quarters of the present quota.
In addition, in order to comply with the Minimum SMEs Quota, at least 30% of the quota must be used to finance investment projects.
Entities complying with this Minimum SMEs Quota may compute the reduction of the minimum cash requirement in Pesos described above during the following quarter.
LELIQ Global Daily Position
Pursuant to Section 8 “net position in LELIQ and NOTALIQ” of the Central Bank rules “Cash settled and forward transactions, futures, bonds, surety bonds, other derivatives and mutual funds” financial institutions may maintain a net position in short term LELIQ (including those effectively allocated to integrate the minimum cash requirement as stipulated above) up to an amount equivalent to the average daily balance of time deposits in Pesos of the previous reporting period.
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Financial institutions that have a percentage of time deposits in Pesos in relation to the total deposits in Pesos -measured as a monthly average of daily balances of the previous period, considering only capital without interest or adjustments- equal to or higher than 20%, may maintain a joint positive net position of longer term LELIQ and variable rate Liquidity Notes (NOTALIQ).
Since the current administration took office, the Central Bank has ceased issuing LELIQ and NOTALIQ instruments. The remaining balances of LELIQ and NOTALIQ matured in January 2024 and March 2024, respectively.
Pursuant to the provisions of Communication “A” 8277, financial institutions may carry forward the excess average minimum cash reserve integration in pesos recorded during the periods from July to October 2025, on a non-cumulative basis, to the position of the month following that which generated the excess, subject to the following limits:
Period Up to the percentage of the minimum cash reserve requirement in pesos for the period:
July 2025 4%
August 2025 3%
September 2025 2%
October 2025 1%
In the event that a reserve requirement transfer has been made pursuant to section 1.7 of the Minimum Cash Requirements Regulations, the applicable requirement shall be the Adjusted Minimum Cash Requirement (EEMA). For the calculation of the transfer of the integration, the amounts transferred from the relevant period will be prorated based on the number of days in the period to which the transfer is applied.
Liquidity Coverage Ratios
Group “A” Entities shall be required to comply with Central Bank regulations on “Liquidity Coverage Ratios”. For the purposes of said provisions, institutions classified as Group “A” will be considered as “internationally active banks.”
Under regulations on “Liquidity Coverage Ratios,” financial institutions must maintain an adequate stock of high-quality liquid assets (“HQLA”), which are “free of restrictions.” This stock should consist of cash or assets that can be immediately converted into cash—monetized—with minimal or no loss of market value. The HQLA must be sufficient to meet the institution’s liquidity needs for a 30-day period under a stress scenario, that includes both idiosyncratic and systemic risk factors that could lead to:
(i) Partial loss of retail deposits;
(ii) Partial loss of unsecured wholesale funding capacity;
(iii) Partial loss of secured funding;
(iv) Additional fund outflows due to contractually anticipated situations, including the establishment and replenishment of margin calls resulting from a significant deterioration in the financial institution’s credit quality;
(v) Increases in market volatility affecting the quality of collateral or potential future exposures from derivative positions, requiring higher or additional collateral, or leading to other liquidity needs;
(vi) Unexpected use of committed but unused credit and liquidity facilities granted by the financial institution to its clients; and
(vii) the need for the financial institution to repurchase debt or fulfill extracontractual obligations to mitigate reputational risk.
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The HQLA can only be made up of the following portfolio assets (considered as Tier 1 (An1)) at the day of the calculation of the LCR: cash in hand, in transit, in armored transportation companies and ATMs; deposits with the Central Bank; certain national public bonds in Pesos or in foreign currency; securities issued or guaranteed by the International Payments Bank, the IMF, the European Central Bank, the European Union or Multilateral Development Banks that comply with certain conditions and debt securities issued by other sovereign entities (or their central banks), as prescribed in the relevant regulations.
The stock must enable the institution, at a minimum, to cover liquidity issues until the thirtieth day of such period.
Financial institutions must anticipate potential cash flow mismatches during the specified period and ensure sufficient HQLA are available to cover them. They must also actively manage liquidity risk and financing needs across branches and subsidiaries, considering legal and operational constraints on liquidity transfer. Moreover, institutions must conduct stress tests to determine liquidity levels above the regulatory minimum, considering scenarios that extend beyond the 30-day period.
In the absence of a financial stress scenario, the LCR must, at all times, be greater than or equal to 1. This means that the stock of HQLA must not be less than the total net cash outflows. During financial stress periods, financial institutions may use their HQLA fund, allowing the LCR to fall below 1. However, they must still comply with the requirements set forth in Section 1.6.2 of the regulations on “Liquidity Coverage Ratios.” The Superintendency will assess the situation and adjust its actions based on the specific circumstances.
The LCR must be greater than or equal to 1, as follows:
LCR = FALAC / SENT
Where:
● FALAC: Represents the value of the stock of HQLA in a stress scenario.
● SENT: Refers to the total net cash outflows anticipated over a 30-day period in a stress scenario.
The LCR must be observed and reported in the national currency, including all foreign currency items expressed in pesos. However, financial institutions must ensure liquidity coverage in each significant currency in which they operate, whenever liabilities and other obligations in that currency represent at least 5% of the total liabilities and obligations of the institution. Additionally, the composition of the HQLA by currency should be aligned with the financial institution’s operational needs.
Financial institutions must ensure that, except for the situation outlined in the following paragraph, the value of the LCR is never below 1. To achieve this, they must calculate it regularly and report it monthly, along with their liquidity profile, to the Superintendency. In stress scenarios, the Superintendency may require more frequent reports.
Pursuant to Section 1.6.2 of the regulations on “Liquidity Coverage Ratios”, in case the LCR falls or is expected to fall below 1, the financial institution must immediately inform the Superintendency and provide an assessment of their liquidity position, the factors contributing to the decrease, and the measures they have or will take, along with their expectations on how long the situation may last. The Superintendency will evaluate each situation and may require institutions to take actions to reduce liquidity risk exposure, strengthen their overall liquidity risk management framework, or improve their contingency funding plan. A drop below 1 does not necessarily trigger the application of article 41 of the FIL.
Moreover, the Superintendency may require corrective actions if they detect a negative trend from the tools used to monitor liquidity, such as mismatches in contractual terms, funding concentration, availability of unencumbered assets, significant currency LCR, or other market-related monitoring tools.
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In addition to the LCR, there are other parameters that are used as systematic tools of control. These policies contain specific information regarding cash flows, balance structure and available underlying assets free of charge. These parameters, along with the LCR, offer basic information to evaluate the liquidity risk. The included parameters are:
● gaps in contractual terms;
● funding concentration;
● available assets free of restrictions;
● LCR for relevant currency; and
● market-related monitoring tools.
Internal Liquidity Policies
Financial institutions must adopt management and control policies that ensure the maintenance of reasonable liquidity levels to efficiently manage their deposits and other financial commitments. Such policies should establish procedures for evaluating the liquidity of the institutions in the framework of prevailing market conditions to allow them to revise projections, take steps to eliminate liquidity constraints and obtain sufficient funds, at market terms, to maintain a reasonable level of assets over the long term. Such policies should also address (i) the concentration of assets and liabilities in specific customers, (ii) the overall economic and market situation, likely trends and the effect on credit availability, and (iii) the ability to obtain funds by selling government debt securities and/or own assets, among others.
The organizational structure of the entity must place a specific unit or person in charge of managing liquidity and assign levels of responsibility to the individuals who will be responsible for managing the LCR, which will require daily monitoring. The participation and coordination of the entity’s top management authority (e.g., CEO) will be necessary.
In addition, financial institutions must designate a director or advisor who will receive reports at least weekly, or more frequently if circumstances so require, such as when changes in liquidity conditions require new courses of action to safeguard the entity. In the case of branches of foreign financial institutions the reports must be delivered to the highest authority in Argentina.
Appointed officers and managers will be responsible for managing the liquidity policy that, in addition to monitoring the LCR, includes taking the necessary steps to comply with minimum cash requirements.
Financial institutions must report the list of such officers and directors, as well as any subsequent changes, to the Superintendency within ten (10) calendar days from the date of any such change.
Net Stable Funding Ratio (“NSFR”)
Financial institutions that belong to Group “A” – considered internationally active banks - must comply with these provisions. For the purposes of these regulations, the term “financial sector” includes financial entities, foreign exchange entities, insurance companies, agents regulated by the CNV – or an equivalent foreign authority – and trustees of non-financial trusts.
The purpose of the NSFR is to allow financial institutions to finance their activities with sufficiently stable sources to mitigate the risk of future stress situations derived from their funding requirements. By requiring financial institutions to maintain a stable funding profile relative to the breakdown of their off-balance sheet assets and transactions, the NSFR limits the strong dependence on short term wholesale funding, promotes a better assessment of balance sheet and off-balance sheet items funding risk, and favors funding sources stability. The definitions of the components of the NSFR are similar to those set forth in the “Liquidity Coverage Ratio” regulations, unless otherwise expressly set forth herein.
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The NSFR is defined as the ratio between the available stable funding amount and the required stable funding amount:
Where:
● MDFE (Available Stable Funding Amount) is the portion of the capital and liabilities of the financial institution that is expected to remain available over a one-year period.
● MRFE (Required Stable Funding Amount) is the amount of funding required during this period based on the liquidity and remaining maturity of the institution’s assets and off-balance sheet commitments.
The available and required stable funding amounts, as determined by these provisions, are calibrated to reflect the expected stability of the institution’s liabilities and the liquidity expected from its assets over a one-year period.
The NSFR shall be at all times greater than or equal to 1 (NSFR > 1). It shall be supplemented with the assessment made by the Superintendency. The Superintendency may demand the institution to adopt stricter standards to reflect its funding risk profile, also taking into account the assessment made in connection with the Risk Management Guidelines in connection with the institution’s liquidity.
The Financial Institutions shall observe the NSFR all times and report it on a quarterly basis to the Superintendency.
Leverage Ratio
Pursuant to Communication “A” 6431, effective as of March 1, 2018, the Central Bank incorporated a ratio to limit the leverage of financial institutions in order to avoid the adverse consequences of an abrupt reduction in leverage in the supply of credit and the economy in general, and reinforce the minimum capital requirement with a minimum capital requirement simple and not based on risk.
The leverage ratio, which must be greater than or equal to 3%, arises from the following expression:
Ratio (as %) = Capital measure / Exposure measure
Where
● Capital measure: The capital to be considered will be the basic equity (PNb) –Tier 1 capital, as defined in the regulations on “Minimum Capital Requirements for Financial Institutions”.
● Exposure measure: Will be the sum of (i) the exposures in the asset (excluding the items corresponding to derivatives and Securities Financing Transactions (SFT)), ( ii) exposures by derivatives; (iii) exposures for SFT transactions and (iv) off-balance-sheet items.
Both measures must be calculated based on the closing balances of each quarter.
Interest rate and fee regulations
Since 2020, maximum interest rates applicable to the lending transactions were restated. Compensatory interest rates will be freely agreed upon between financial entities and clients, taking into account, where applicable, the provisions established under specific regulatory regimes.
The compensatory interest rate for credit card-linked financing must not exceed 25% above the average interest rate that the financial institution applied during the immediate previous month, weighted by the corresponding amount of unsecured personal loans granted in the same period. In the case of bank issuers, this refers to the rate the issuer applies to personal loan transactions in local
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currency for clients, whereas non-bank issuers must refer to the average system rates for such transactions, as published by the Central Bank between the 1st and the 5th of each month.Loans established under programs and/or social assistance measures, which additionally have an interest rate not exceeding the rate published by the Central Bank for deposits of more than one million pesos for terms between 30 to 35 days, from the third month prior, may be excluded from the base to be averaged. This rate is determined based on the type of financial institution (public or private), increased in accordance with the minimum cash requirement. Additionally, Section 16 of Credit Card Law No. 25,065 provides the legal basis for this limitation, establishing that the issuer may not charge compensatory or financial interest exceeding 25% above the applicable personal loan rate, depending on whether the issuer is a bank or a non-bank entity as described above.
Regulations set forth that the fixed-rate loan agreements shall not contain clauses that allow their modification under certain circumstances, unless those modifications come from decisions taken by the competent authority and the variable-rate loan contracts must clearly specify the parameters that will be used for its determination and periodicity of variation.
With respect to credit card transactions, in addition to the foregoing, Section 16 of Credit Card Law No. 25,065 provides that the compensatory or financial interest rate charged by the issuer to the cardholder may not exceed by more than 25% the rate applied by such issuer to personal loans granted in local currency to its customers. In the case of non-bank issuers, the compensatory or financial interest rate charged to the cardholder may not exceed by more than 25% the average rate for personal loan transactions in the financial system, as published by the Central Bank between the 1st and the 5th day of each month.
In the past, regulations established a minimum deposit rate for time deposits. Currently, the remuneration for time deposits at fixed rates will be freely agreed upon. The base remuneration for variable interest rate deposits will be equivalent to:
● The interest rate derived from one of the surveys conducted and published daily by the Central Bank, such as BADLAR, TAMAR.
● For deposits in U.S. dollars, British pounds, Japanese yen, Swiss francs, or euros, the applicable rate will be one of the following: Secured Overnight Financing Rate (SOFR), Sterling Overnight Index Average (SONIA), Tokyo Overnight Average Rate (TONAR), Swiss Average Rate Overnight (SARON), or Euro Short-Term Rate (ESTER).
● The higher of either the rate mentioned in sections i) and ii), plus any additional remuneration that may be agreed upon, or the fixed rate freely negotiated.
To determine the rate, each institution may consider the average of the daily rates specified within the period from 2 to 5 banking days immediately prior to the start of each computation subperiod. The minimum duration for this period is 30 days, and this option will remain fixed for the entire duration of the deposit. Once the rate is determined, it must remain unchanged for a period no shorter than 30 days. The amount of points that the deposit-taking institutions freely agree upon with depositors, which must remain unchanged for the entire term of the deposit agreement.
Central Bank regulations on the “Protection of Financial Services Users” grant broad protection to customers, including, among other things, the regulation of fees and commissions charged by financial entities for services provided. All commissions, fees, costs, expenses, insurance, and/or any other charges—excluding the interest rate—that the obligated parties receive or intend to receive from users of financial services must derive from a real, direct, and demonstrable cost, and be duly justified from both a technical and economic standpoint.
Commissions and fees should only apply to services that have been requested, agreed upon, or authorized by the user. Commissions relate to services provided by the obligated parties and may include compensation beyond the service cost, while fees relate to third-party services and can only be passed on at cost.The amount of fees charged to users cannot exceed the amount received by third-party providers in similar conditions. In credit operations, commissions can be applied to unused allocated funds. Early repayment of financing may result in commissions, but no commissions will apply if one-quarter of the original term or 180 days have passed since the financing was granted, whichever is greater.
The charging of users for concepts that do not meet the conditions set out above or that result from a service whose commission or fee is already included in other charges by the financial service provider is not allowed. Commissions or fees cannot be applied to
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users for financial services that were not requested, agreed upon, or authorized by them. Even if such services were requested, agreed upon, or authorized, and the provider communicated them to the user, fees cannot be charged if the service was not actually provided.
There are specific cases where commissions or fees cannot be applied. First, in-person transactions carried out by individual users at a branch are exempt, including cash deposits and withdrawals in pesos, as well as the receipt of checks for deposit at branches other than the one where the account is held. This applies regardless of commissions related to check collection or services that require in-person handling, such as check certification and international transfers. Second, cash deposits in pesos into accounts held by individuals or SMEs are exempt, in accordance with the rules on determining the status of such enterprises. Third, no charges can be applied for the contracting or management of insurance policies. Fourth, generating and sending account statements, including virtual statements, must be included in the account maintenance fee and cannot be charged separately. Fifth, no separate charges can be applied for the evaluation, granting, or administration of financing. Finally, charges for appraisals, notary services, or public registry fees associated with granting or canceling financing, such as for the establishment of pledges or mortgages, are not admissible.
Also, fees and charges are not applicable for immediate electronic transfers when: (i) they are ordered by final customers of financial services; (ii) the same individual or entity is the one ordering and receiving the transfer; (iii) they are ordered or received in accounts for judicial use, among others.
Regulations on the “National Payment System - Payment Services” establish that interchange fees applied by financial entities on the amount of each transaction made with debit, credit, and charge cards they issue must not exceed the following percentages.
Maximum interchange fee for debit card transactions Maximum interchange fee for credit/charge card transactions
0.60% 1.30%
For the purposes of applying the aforementioned limits, any other mechanism of remuneration or compensation to the issuers, established by acquirers, brand holders, and/or any other intermediaries in payment operations or related activities, that has an object or effect equivalent to that of the interchange fee, is considered part of the interchange fee.
Financial institutions and PSPs (Payment Service Providers) that offer interoperable digital wallet services from which the customer initiates the payment, but have not issued the credit card used, will be entitled to charge the issuer a commission of up to 0.07% of the transaction amount for each transaction.
Maximum Term for Payments to Merchants and Providers
By virtue of Communication “A” 6680, effective as of May 1, 2019, the Central Bank established a maximum term of ten business days for financial entities to deposit payments to merchants and suppliers for sales made via credit cards or purchase cards, calculated from the sale date. Furthermore, financial entities shall not charge any fee or interest related to such payment term, nor block this payment mechanism in any way. Financial institutions may not charge merchants any interest or commission related to the specified settlement period. They must also not impede or hinder in any way the use of a single-payment transaction with those cards.
Nevertheless, by virtue of Communication “A” 6680, the Central Bank excluded from the scope of its provisions the credit and/or purchase cards issued to individuals or legal entities that are intended for the payment of purchases with a deferred term or more than one month related to their productive activity, i.e. agricultural o distribution activities.
Furthermore, the regulations governing the “National Payment System – Payment Services” establish that the maximum period for financial institutions, Payment Service Providers and Card Processors (Proveedores de Servicios de Pago que ofrecen Cuentas de Pago or PSPCP), and other issuers of open-loop prepaid cards to credit the proceeds of each sale made using such cards to the demand or payment account opened in the name of the affiliated supplier or merchant shall be two (2) business days, counted from the date the corresponding purchase is made by the prepaid cardholder or beneficiary. Additionally, the maximum period for sub-acquirers to credit the amount of payments processed through their intervention to the account in the name of the affiliated supplier or merchant shall not exceed one (1) business day from the date the sub-acquirer receives the funds. The scope of these provisions excludes payment credits processed through sub-acquirers that correspond to: (i) purchases made through e-commerce platforms; and/or (ii) payments via transfers and other immediate transfers, which in all cases must be made available to the payment beneficiary within fifteen (15) seconds, even if the payment is processed without the involvement of an administrator of the immediate funds transfer scheme (i.e., under a closed-loop modality).
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Loans and Housing Units
The Central Bank has adopted measures for taking deposits and extending loans expressed in a special measuring unit adjustable by the CER. These special units are referred to as UVAs.
In addition, Law No. 27,271 provides for the adjustment of deposits and loans by reference to the construction index, expressed in a special measuring unit referred to as Housing Units UVI.
Consequently, UVAs and UVIs coexist and may be used both with respect to bank loans and deposits.
The initial value of the UVI was Ps.14.05 (the same as the UVA), representing the cost of construction of one thousandth square meter of housing as of March 31, 2016. As of December 31, 2025, the value of UVI and UVA are Ps. 1,261.39 and Ps. 1,707.79, respectively
Both units are amended based on the indices published by the INDEC and the Central Bank on their websites.
Foreign Exchange System
On September 1, 2019, with the purpose of strengthening the normal functioning of the economy, the Argentine government reinstated exchange controls. Except for individuals, the new foreign exchange controls apply with respect to access to the foreign exchange market by residents for savings and investment purposes abroad, the payment of external financial debts abroad, the payment of dividends in foreign currency abroad, payments of imports of goods and services, and the obligation to repatriate and settle for Pesos the proceeds from exports of goods and services, among others.
For further information on this topic, please refer to “Item 10.D. Exchange Controls.”
Foreign Currency Lending Capacity
Regulations on “Credit Policy” applicable to the Application of the Loan Capacity of Foreign Currency Deposits establish that the lending capacity from foreign currency deposits must be applied, in the corresponding deposit currency, indiscriminately to the following destinations:
(a) pre-financing and financing of exports to be made directly or through principals, trustees or other brokers, acting on behalf of the owner of the merchandise;
(b) other financing of exports which have a flow of future income in foreign currency and verify, in the year prior to granting the financing, a billing in foreign currency for an amount that is reasonably related to that financing;
(c) financing to producers, processors or goods collectors, provided that:
(i) they have sale contracts of their merchandise to an exporter, with a fixed price or fixed in foreign currency -independently of the currency in which the operation is settled- and in the case of fungible merchandise with quotation, in foreign currency, normal and customary in local or foreign markets, with wide diffusion and easy access to public knowledge;
(ii) their main activity is the production, processing and / or collection of fungible goods with quotation, in foreign currency, normal and usual in foreign markets, widely disseminated and easy access to public knowledge, and it is found, in the year prior to the granting of financing, a total billing of these goods for an amount that is reasonably related to that activity and its financing; and also operations aimed to finance service providers directly used in exporting process of goods (such as those provided at port terminals, international loading and unloading services, leasing containers or port warehouses, international freights ). This, provided it is verified that the flow of future income linked to sales to exporters registers a periodicity and magnitude that it is enough for the cancellation of the financing and it is verified, in the year prior to the
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granting of the financing, a billing to exporters for an amount that is reasonably related to that activity and its financing.
(d) financing for manufacturers of goods to be exported, as final products or as part of other goods, by third-party purchasers, provided that they have full foreign currency guarantees or endorsements from such third parties and/or firm sales contracts in foreign currency and/or in exportable goods;
(e) financing of suppliers of goods and/or services that are part of the production process of fungibles goods with quotation, in foreign currency, normal and usual in local or foreign markets, widely disseminated and easy access to public knowledge, provided they have firm sales contracts for those goods and/or services in foreign currency and/or on said goods;
(f) financing of investment projects, working capital and/or acquisition of all kinds of goods, including temporary imports of inputs, which increases or are linked to the production of exporting products. Even if exporters’ revenues do not come entirely from foreign sales, financing may be allocated as long as the repayment is sufficiently covered by the foreign currency inflows from their exports. Transactions in which financing is granted through the entity’s participation in “syndicated loans,” whether with local or foreign entities, are included;
(g) financing for commercial and commercial portfolio clients of credits for consumption or housing -according to the provisions established in the rules on “Debtor Classification”, whose destination is the importation of capital goods (“BK” in accordance with the Mercosur’s Common Nomenclature established in Annex I to Decree No. 690/02 and other complementary provisions), which increase the production of merchandise destined for the domestic market;
(h) foreign currency debt securities or financial trust participation certificates including other payment rights specifically recognized on trust agreements whose underlying assets are loans made by the financial entities in the manners set forth in (a) to (d) above and first sentence of (f), or documents in which cash flows in Pesos or foreign currency have been assigned to the trustee, in foreign currency credit agreements, under the terms and conditions set forth in items mentioned before;
(i) financings for purposes other than those mentioned in (a) to (d) and (f) above, included under the IDB credit program (“Préstamos BID N° 119/OC-AR”), not exceeding 10% of the lending capacity;
(j) inter-financing loans;
(k) Central Bank bills (Letras y Notas) denominated in U.S. dollars;
(l) direct investments abroad by companies that reside in Argentina, which seek the development of productive activities of non-financial goods and/or services, either through contributions and/or purchases of shares in companies, to the extent that they are constituted in countries or territories considered cooperators for the purposes of fiscal transparency according to the provisions of Section 1 of Decree No. 589/13 as amended;
(m) financing of investment projects, including working capital, which allows the increase of production in the energy sector and have firm sales contracts and/or endorsements or guarantees in foreign currency.
(n) national treasury bills in foreign currency, up to an amount equivalent to one third of the total of the applications made in accordance with the provisions of this section;
(o) financing of investment projects for bovine cattle, including their working capital, without exceeding 5% of deposits in foreign currency of the entity;
(p) financing of foreign importers for the acquisition of goods and / or services produced in the country, either directly or through credit lines to foreign banks; and
(q) Financing of local residents that are secured by letters of credit (“stand-by letters of credit”) issued by foreign banks or multilateral development banks that comply with the provisions of point 3.1. of regulations on “Credit assessments,”
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requiring for that purpose an international rating of investment grade risk, to the extent that such letters of credit are unrestricted and that the accreditation of the funds is made immediately at the simple request of the beneficiary entity.
The application of the lending capacity of foreign currency deposits to import-related operations (as provided in items (e), (f), and the portion attributable to these under items (g) and (h)) may not exceed the value determined by the following formula:
Ct x max (Fbase / Cbase ; 0.05)
Where:
● Ct: Lending capacity for the relevant month.
● Fbase: Financing of eligible imports corresponding to the August–October 2008 quarter.
● Cbase: Lending capacity corresponding to the August–October 2008 quarter.
Financing granted to debtors classified as “unrecoverable” and fully provisioned cannot be allocated to the lending capacity of foreign currency deposits.
The lending capacity shall be determined for each foreign currency captured, and is calculated as the sum of deposits and interbank loans received, provided that the lending financial institution has reported them as derived from its foreign currency deposit lending capacity, net of the minimum cash requirement on deposits. The computation of assets and liabilities is based on the monthly average of daily balances (principal and interest) recorded in each calendar month.
Financing is accounted for net of provisions for uncollectible risks, depreciation, and, where applicable, the “portfolio acquisition difference.”
Net shortfalls in application, after deducting cash balances held by financial entities, those held in custody by other institutions, in transit, and in TV, up to the amount of such shortfall, will be subject to an equivalent increase in the minimum cash requirement in the respective foreign currency.
Shortfalls resulting from exchange transactions mandated by the Federal Government cannot be offset by foreign currency purchases. Additionally, deposits in “Special Accounts for Crediting Export Financing” cannot be applied to cash balances in financial entities, custody in other banks, in transit, or in TV.
Regarding the capacity to extend foreign currency loans,, on February 20, 2025, the Central Bank issued Communication “A” 8202, whereby the provisions of section 1.4. of the “Credit Policy” regulations were repealed, and consequently, certain limitations applicable to loans granted by financial institutions using foreign currency resources derived from their liabilities allocated to financial intermediation ceased to be in effect.
Foreign Currency Net Global Position
The foreign currency net global position (the “FCNGP”) shall consider all assets, liabilities, commitments and other instruments and transactions through financial intermediation in foreign currency or linked to exchange rate movements, including cash, forward transactions and other derivative contracts, deposits in foreign currency in accounts opened with the Central Bank, gold position, the Central Bank monetary regulation instruments in foreign currency, subordinated debt in foreign currency and debt instruments in foreign currency.
Forward transactions under master agreements executed in local markets authorized by the CNV paid by settlement of the net amount without delivery of the underlying asset are also included. Likewise, certificates or notes issued by financial trusts and claims under common trusts are also included in the relevant proportion, provided that the underlying assets are denominated in foreign currency. The net position amount of transactions involving commodities will be included in the FCNGP. For this purpose, all opposing positions must be netted, regardless of whether they involve different products, maturities, or whether there is a legal possibility of contractual offsetting between them.
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The value of the position in currencies other than U.S. dollars shall be expressed in that currency, at the respective exchange rate published by the Central Bank.
Decreases in foreign currency assets, due to the pre-cancellation of local financing to private sector customers, can only offset the FCNGP up to the original term of maturity, accompanied by the net increase in holdings of National Treasury securities in foreign currency.
Secondary market sales of foreign currency–denominated negotiable obligations acquired through primary issuance on or after June 9, 2023 shall not be subject to the offset mechanism set forth in the preceding paragraph, provided that such sales are carried out after 90 consecutive days have elapsed from the date of primary subscription.
Where a financial institution has acquired National Treasury securities denominated in foreign currency through primary issuance on or after December 10, 2025, any secondary market sales that result in a reduction of its FCNGP may be offset only up to the original maturity date of such securities against the net increase in holdings of other foreign currency–denominated National Treasury securities, unless such sale is carried out after 90 consecutive days have elapsed from the date of primary subscription.
At the original maturity of local financing in foreign currency, offsetting may occur with the purchase of any foreign currency assets eligible for inclusion in the FCNGP.
When determining a bank’s FCNGP, the following concepts shall be excluded from the calculation:
(i) deductible assets to determine the Banks’s RPC,
(ii) the included concepts that the financial entity registers in its branches abroad,
(iii) Federal government securities in pesos with dual-currency returns,
(iv) the balances corresponding to the “Special accounts for holders with agricultural activity” and the “Special accounts for exporters”,
(v) the non-transferable domestic bills of the Central Bank of the Argentine Republic in Pesos settleable at the Reference Exchange Rate Communication “A” 3500 (“LEDIV”) at zero rate (LEDIVs were rendered ineffective through Communication “A” 7898 dated November 30, 2023), and
(vi) the public and private securities in Pesos adjustable by the exchange rate, provided they do not exceed the net between the deposits referenced in item (iv) and the LEDIV.
Negative FCNGP
This position (where liabilities exceed assets) calculated as the daily balance converted into pesos at the reference exchange rate as of the close of the month preceding the month in which this ratio is calculated, may not exceed 30% of the RPC for the month immediately preceding the relevant period.
Positive FCNGP (assets exceeding liabilities)
The Net Global Foreign Currency Position, calculated as the daily balance converted into pesos at the reference exchange rate as of the close of the month preceding the month in which this ratio is calculated, may not exceed 5% of the RPC for the month immediately preceding the relevant period. Any variation in this position arising from exchange transactions ordered by the National Executive Branch may be covered only through one of the applications provided for in Section 2 of the “Credit Policy” regulations or through foreign exchange forward transactions settled in pesos.
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Spot Foreign Currency Position
The spot position includes the net global foreign currency position as previously defined, minus the following:
(i) The net position in transactions conducted on a term basis, spot-to-settle, futures, options, and other derivative products. For foreign exchange transactions, only those with an original term greater than 1 business day will be considered.
(ii) The net position in instruments linked to the evolution of the foreign currency’s value (except those accounted for in item d).
(iii) The positive difference between the cash balances and the foreign currency resource application deficit – as outlined in Section 1.8 of the Minimum Capital Regulations – measured as the average of daily accumulated balances up to the date of the spot position calculation, provided the cash in hand does not exceed 10% of the foreign currency deposits measured on the previous business day.
(iv) Pre-financings of exports whose foreign currency funding, for the same amount, is accounted for as liabilities linked to the evolution of the foreign currency’s value.
(v) The balance of guarantees established for operations with debit, credit, and purchase cards abroad for an amount equivalent to five consecutive days of consumption.
At the entity’s option, the balance of foreign financing received with an original average life of at least 12 months may be excluded from the spot foreign currency position. In any event, this daily position—calculated as the daily balance converted into pesos at the reference exchange rate as of the close of the month preceding the month in which this ratio is calculated—must remain within a range between an amount equivalent to minus 30% and 0% of the RPC for the month immediately preceding the relevant period. In addition, this position may not increase on the last business day of the month compared to the balance recorded on the immediately preceding day.
The Central Bank allows that the Positive FCNGP may reach up to 30% of the RCP, while the total excess over the general limit originates only as a result of:
a) National Treasury Bills, as of June 18, 2018, due to:
(A) An increase in the position in U.S. Treasury bills in U.S. dollars with respect to those held as of June 15, 2018, and/or
(B) The institution’s position in U.S. Treasury bills in U.S. dollars as of June 15, 2018, maintained as excess admitted to the current limit as of that date.
(C) An increase in the position in National Treasury bills linked to U.S. dollars with respect to those held as of May 13, 2019.
b) Peso-denominated financings with variable remuneration based on the variation of the U.S. dollar exchange rate, whose purpose is not included in section 2.1 of the Central Bank’s Credit Policy Regulations, granted as of July 10, 2025.
As provided by Communication “A” 7093 (as amended), it includes national treasury bills denominated in foreign currency that the institutions receive in exchange for National Treasury Bills – under Law 27,556 – that they have imputed to this point on the Business Day immediately preceding the day on which they are delivered in exchange.
To determine the FCNGP, loans in pesos with a variable return based on the fluctuation of the U.S. dollar exchange rate, agreed until May 27, 2020, will be excluded if they are not covered by term investments with a variable return based on the U.S. dollar exchange rate.
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Furthermore, any foreign currency position that financial entities might hold – under the framework established in Communication A 7997 related to the regulations on “Earnings Distributions” – due to the subscription of BOPREAL until credited to non-resident shareholders will also be excluded from the calculation of their FCNGP.
The excesses of these ratios are subject to a charge equal to 3 times the TAMAR – total for banks. To determine the charge, the rate provided by the Central Bank will be applied on the excess amount in pesos, based on the rate for the last business day of the reporting period, or, if unavailable, the most recent one. If excesses occur concurrently in both the net global position and the spot position, the higher charge will apply.
Charges not paid on time will incur an interest penalty during the non-compliance period, calculated at a rate 50% higher than the one applied to the excesses.
In addition to the above-mentioned charge, sanctions set forth in section 41 of the FIL shall apply (including: caution; warning; fine; temporary or permanent disqualification to dispose of a banking current account; temporary or permanent disqualification to act as promoters, founders, directors, administrators, members of surveillance committees, comptrollers, liquidators, managers, auditors, partner or shareholders; and license revocation).
Fixed Assets and Other Items
The Central Bank establishes that fixed assets and other items held by financial entities must not exceed 100% of the entity’s RPC.
Such fixed assets and other items include:
· Shares of local companies;
· Various loans;
· Real estate, machinery, and equipment; and
· Other assets.
The calculation of these assets shall be based on month-end balances, net of impairments, accumulated amortization, and provisions for uncollectibility.
Failure to comply with this ratio shall result in an increase in the minimum capital requirements equivalent to 100% of the excess over the established limit.
Credit Ratings
As of November 28, 2014, the Central Bank’s Communication “A” 5671 — as supplemented and amended— replaced all prior regulatory provisions regarding credit rating requirements issued by local credit rating agencies. Under the updated rules on "Credit Assessments," the previously applicable requirements tied to local credit ratings are no longer in effect. Where regulations still call for a minimum international credit rating, the new criteria under the Credit Assessments framework will apply on a complementary basis.
The provisions of Communication “A” 5671 are basic guidelines to properly assess the credit risk that financial institutions must observe when implementing Central Bank Rules including the requirement of a particular rating and do not replace the credit assessment that each financial institution must make to their counterparts. International credit ratings that refer to these provisions shall be issued by rating agencies that have a code of conduct based on the “Principles of the Code of Conduct for Agents Rate Risk” issued by the International Organization of Securities Commissions.
Annex II of Communication “A” 5671 provides a table regarding the new qualification requirements for financial institutions. This table classifies the credit ratings requirements for different transactions.
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Debt Classification and Loan Loss Provisions
Unless otherwise indicated, the regulations explained in this section should be applied to financial information of the banks calculated in accordance with the Central Bank Rules. IFRS differs in certain aspects from the Central Bank Rules.
Credit Portfolio
The regulations on debt classification are designed pursuant to Central Bank Rules, which differ from IFRS to establish clear guidelines for identifying and classifying the quality of assets, as well as evaluating the actual or potential risk of a lender sustaining losses on principal or interest, in order to determine (taking into account any loan security) whether the provisions against such contingencies are adequate. Banks must classify their loan portfolios into two different categories:
(1) Commercial portfolio. Includes all financing, except for consumer or housing loans.
Loans exceeding Ps. 1,198,966,000, linked to the client’s business or productive activity, are classified as commercial. At the entity’s discretion, commercial loans up to Ps. 1,198,966,000 may be grouped with consumer or housing loans, treated as such. Consumer loans are combined with commercial ones to determine classification, with collateral-backed loans weighted at 50%.
This option must apply to the entire portfolio and be outlined in the “Classification and Provision Procedures Manual,” with six months’ notice to the Superintendency for changes.
(2) Consumer or housing portfolio. Includes:
a. Consumer loans (personal, family, professional, for consumer goods, credit card financing).
b. Housing loans (purchase, construction, refurbishment).
c. Microcredit loans – up to Ps. 239,793,200, and microenterprise loans.
d. Commercial loans up to Ps. 1,198,966,000, with or without preferred collateral, if opted by the entity.
Under the current debt classification system, each customer, as well as the customer’s outstanding debts, are included within sub-categories. The debt classification criteria applied to the consumer loan portfolio are primarily based on objective factors related to customers’ performance of their obligations or their legal standing, while the key criterion for classifying the commercial loan portfolio is each borrower’s paying ability based on their future cash flow.
Clients with no previous credit history with the entity, who later receive financing that does not exceed the amount derived from applying the percentage in section 2.2.5 of the “Minimum Provisions for Uncollectible Risk” regulations to their debt balance, may be classified based only on a projected cash flow analysis.
To ensure compliance with obligations without requiring new financing or refinancing, additional credit facilities will not be considered refinancings if they do not exceed 10% of the limit assigned during the last credit assessment, and if they are in line with normal business operations and the client can meet their other financial obligations. New financings and refinancings related to increased investment due to business expansion are also excluded, provided the projected cash flow supports full repayment of obligations.
Refinancings granted to agricultural producers under the Agricultural Emergency Law will not count as refinancing for classification purposes. However, the projected cash flow at the end of the emergency period must be considered, and the classification cannot improve based on the client’s pre-emergency situation, nor extend beyond the emergency period.
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Commercial Loans – Regulatory Classification
The principal criterion used to evaluate a loan pertaining to the commercial portfolio is its borrower’s ability to repay, whose ability is mainly measured by such borrower’s future cash flow. Pursuant to Central Bank rules, commercial loans are classified as follows:
Classification Criteria
Performing Borrowers that demonstrate their ability to comply with their payment obligations. High repayment capacity.
Subject to Special Monitoring/Under observation Borrowers that, among other criteria, are up to 90 days past due and, although considered to be able to meet all their financial obligations, are sensitive to changes that could compromise their ability to honor debts absent timely corrective measures.
Subject to Special Monitoring/Under negotiation or refinancing agreement Borrowers who are unable to comply with their obligations as agreed with the bank and, therefore, formally state, within 60 calendar days after the maturity date, their intention to refinance such debts. The borrower must enter into a refinancing agreement with the bank within 90 calendar days (if up to two lenders are involved) or 180 calendar days (if more than two lenders are involved) after the payment default date. If no agreement has been reached within the established deadline, the borrower must be reclassified to the next category according to the indicators established for each level.
Subject to special Monitoring / Special Treatment For refinancings granted for the first time within the calendar year, once the first installment is paid, the client may be reclassified to this category only once. After this refinancing, only the overdue obligations will be considered for classification purposes.Subsequent refinancings will be treated under the general provisions outlined in these regulations.
Troubled Borrowers with difficulties honoring their financial obligations under the loan on a regular basis, which, if uncorrected, may result in losses to the bank.
With High Risk of Insolvency The client's cash flow analysis indicates that it is highly unlikely they will be able to meet all of their financial obligations.
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Classification Criteria
Irrecoverable The debts of clients in this category are considered uncollectible. Although these assets may have some recovery value under certain future circumstances, their uncollectibility is evident at the time of analysis. The borrower will not meet its financial obligations with the financial institution.
Indicators of Uncollectibility (A) The client has a poor financial situation, with suspended payments, bankruptcy, or filing for bankruptcy, and is forced to sell significant assets at a loss. The cash flow does not cover production costs.(B) The client has been overdue for more than a year, with capital and interest refinanced, and financed operational losses. Refinancing will not interrupt the delinquency period unless overdue obligations are fully settled. If at least 15% of refinanced obligations and all accrued interest are paid, the debtor may be reclassified to a higher category.(C) The client has incompetent and/or dishonest management, or has the potential for fraudulent acts, with no internal control.(D) The client has inadequate information systems, making it impossible to accurately assess their financial situation, with unreliable and outdated information.(E) The client operates in an industry in decline or requiring widespread restructuring.(F) The client is in the lowest segment of their industry, unable to compete, and has outdated, unprofitable technology.(G) Clients with overdue obligations over 180 days, according to the Central Bank's “List of Irregular Debtors,” including liquidated entities and certain financial entities.(H) Foreign financial entities or non-resident borrowers failing to meet the “Credit Evaluation” criteria must have an international risk rating of “investment grade.”(I) Private sector clients whose debt exceeds 2.5% of the entity’s computed equity or Ps. 599.483.000, and who have not submitted an affidavit regarding their relationship with the intermediary financial institution. This also applies to clients not evaluated regularly, unless exempted under specific circumstances (e.g., ongoing bankruptcy proceedings).
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Consumer or Housing Loans – Regulatory Classification
The principal criterion used in the assessment of loans in the consumer and housing portfolio is the duration of the default on such loans. Under the Central Bank rules, consumer and housing borrowers are classified as follows:
Classification Criteria(2)
Performing If all payments on loans are current or less than 31 calendar days overdue and, in the case of checking account overdrafts, less than 61 calendar days overdue.
Low Risk / Under observation Loans upon which payment obligations are overdue for a period of more than 31 and up to 90 calendar days.
Low Risk / Special Treatment For refinancings granted for the first time within the calendar year, once the first installment is paid, the client may be reclassified to this category only once. After this refinancing, only overdue obligations will be considered for classification purposes. Subsequent refinancings will be subject to the general treatment outlined in these provisions.
Medium Risk Loans upon which payment obligations are overdue for a period of more than 90 and up to 180 calendar days.
High Risk Loans in respect of which a legal action seeking collection has been filed or loans having payment obligations overdue for more than 180 calendar days, but less than 365 calendar days.
Irrecoverable This category includes clients who are insolvent or in bankruptcy with little or no chance of credit recovery, or who have overdue payments exceeding one year.It also includes clients undergoing judicial management, or those who have requested preventive bankruptcy or extrajudicial preventive agreements, even if there is a chance of credit recovery, once more than 540 days of overdue payments have passed.Clients whose debts have been refinanced through periodic payment obligations (monthly or bimonthly) may be reclassified to the next higher level if they have made timely payments or have arrears not exceeding 31 days for three consecutive installments, or, in the case of lump-sum payments, bimonthly or irregular payments, if at least 15% of their refinanced obligations (principal) have been paid.A refinanced debtor who meets the above conditions may be reclassified to the next higher level if, additionally, the rest of their debts meet at least the requirements for that level.If a debtor classified in this category has refinanced their debt—regardless of whether they have paid the required installments or percentage—and has received additional credit as outlined in point Section.2.5 of the “Minimum Provisions for Uncollectibility Risk” guidelines, and if such additional financing remains unpaid, they must remain in this category for at least 180 days from the date the additional credit was granted or the refinancing agreement was made.This category also includes clients who meet the conditions outlined below:(a) Clients with overdue obligations over 180 days, according to the Central Bank's “List of Irregular Debtors,” including liquidated entities and certain financial entities. (b) Foreign financial entities or non-resident borrowers failing to meet the “Credit Evaluation” criteria must have an international risk rating of “investment grade.”(b) Private sector clients whose debt exceeds 2.5% of the entity’s computed equity or the reference amount in section 3.7., and who have not submitted a sworn statement regarding their relationship with the intermediary financial institution. This also applies to clients not evaluated regularly, unless exempted under specific circumstances (e.g., ongoing bankruptcy proceedings).
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Minimum Credit Provisions
Unless otherwise indicated, the financial regulations described in this section have been prepared in accordance with Central Bank regulations. IFRS differs in certain aspects from Central Bank regulations. See Item 5B. “Critical accounting policies”.
The following minimum credit provisions are required to be made by Argentine banks in relation to the credit portfolio category:
Category With Preferred Guarantees Without Preferred Guarantees
1. Normal situation 1% 1%
2. With special monitoring / Low risk
Under observation 3% 5%
Under negotiation or refinancing agreement 6% 12%
Special treatment 8% 16%
3. With problems / Medium Risk 12% 25%
4. With high risk of insolvency / High Risk 25% 50%
5. Irrecoverable 50% 100%
The Superintendency may require additional provisioning if it determines that the current level is inadequate.
In accordance with Central Bank Rules financial entities are required to develop procedures for the analysis of the credit facilities assuring an appropriate evaluation of a debtor’s financial situation and a periodic revision of its situation concerning objective and subjective conditions of all the risks taken. The procedures established have to be detailed in a manual called “Manual of Procedures for Classification and Allowances” which shall be permanently available for the Superintendency. The frequency of the review of existing classifications must answer to the importance considering all facilities. The classification analysis shall be duly documented.
In the case of commercial loans, applicable regulations require a minimum frequency of review. Such review must take place:
(i) On a quarterly basis, with respect to individually considered clients whose financing at any point is equivalent to 5% or more of the RPC or the financial trust assets for the month preceding the end of the respective period, depending on whether the client is an entity or a financial trust. For these purposes, the group of connected counterparties shall be treated as a single client;
(ii) On a semi-annual basis, with respect to individually considered clients whose financing at any point is between 1% (or the equivalent of Ps. 1,198,966,000, whichever is lower) and less than 5% of the RPC or the financial trust assets for the month preceding the end of the respective period, depending on whether the client is an entity or a financial trust. For these purposes, the group of connected counterparties shall be treated as a single client.
At the close of the first calendar semester, the review must cover at least 50% of the total commercial portfolio, including clients referred to in section 6.3.1. Therefore, to meet this percentage, the review must also include clients whose financing is below 1% of the mentioned RPC or financial trust assets (or the equivalent of Ps. 1,198,966,000), proceeding in decreasing order based on the magnitude of their financing.
(iii) During the fiscal year, in other cases, the review must cover the entire commercial portfolio by the end of the period.
In addition to the minimum frequency outlined above, the classification must be reviewed – with a reasoned record of the decision made in the client’s file – and, if necessary, amended whenever any of the following circumstances occur:
1. Modification of any of the objective classification criteria arising from these regulations (e.g., terms of delinquency, legal status of the client or their debts, compliance with refinancings, and requests for refinancing of obligations).
2. A negative change in the client’s classification in the “Central de Deudores del Sistema Financiero”, downgrading it to a lower degree than the one assigned by the entity, by at least another financial entity or trust whose claims represent at
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least 10% of the total reported by all creditors.
3. Notification of the Superintendency’s final determination regarding the adjustment of provisions, as indicated by inspection activities.
4. When there is a discrepancy of more than one level between the classification given by the financial entity and those assigned by at least two other entities or financial trusts in categories lower than the one assigned by the entity, with their combined claims representing at least 20%, but less than 40%, of the total reported by all creditors, according to the latest available information from the “Central de Deudores del Sistema Financiero.”
The reassessment must be immediate for clients whose covered financing equals or exceeds 1% of the entity’s computable net worth or the trust’s assets, from the month prior to the occurrence of any of the circumstances mentioned, or the equivalent of Ps. 599,483,000, whichever is lower, and within three months for all other included clients.
Allowances for Loan Losses
The Central Bank Rules establish minimum requirements for allowances for loan losses, in accordance with the category assigned to the client and the type of guarantee. Entities may have allowances for amounts higher than the minimum requirements, as deemed reasonable. Allowances are designed pursuant to the Central Bank Rules which differ from IFRS.
Increases in the allowance are based on the level of growth of the loan portfolio, as well as on the deterioration of the quality of existing loans, while decreases in the allowance are based on regulations requiring the write-off of non-performing loans classified as irrecoverable after a certain period of time and on decisions of the management to write off non-performing loans evidencing a very low probability of recovery.
Priority Rights of Depositors
Under Section 49 of the FIL, in the event of judicial liquidation or bankruptcy of a bank all depositors, irrespective of the type, amount or currency of their deposits, will be senior to the other remaining creditors (such as shareholders of the bank), with exceptions made for certain labor liens (section 53 paragraphs “a” and “b”) and for those creditors backed by a pledge or mortgage, in the following order of priority: (a) deposits of up to Ps.50,000 per person (including all amounts such person deposited in one financial entity), or its equivalent in foreign currency, (b) all deposits of an amount higher than Ps.50,000, or its equivalent in foreign currency, and (c) the liabilities originated in commercial lines granted to the financial institution and which directly affect international commerce. Furthermore, pursuant to section 53 of the FIL, as amended, Central Bank claims have absolute priority over other claims, except for pledged or mortgaged claims, certain labor claims, the depositors’ claims pursuant to section 49, paragraph e), items i) and ii), debt granted under section 17, paragraphs (b), (c) and (f) of the Central Bank’s Charter (including discounts granted by financial entities due to a temporary lack of liquidity, advances to financial entities with security interest, assignment of rights, pledges or special assignment of certain assets) and debt granted by the Banking Liquidity Fund backed by a pledge or mortgage.
The amendment to section 35 bis of the FIL by Law No. 25,780 sets forth that if a bank is in a situation where the Central Bank may revoke its authorization to operate and become subject to dissolution or liquidation by judicial resolution, the Central Bank’s Board of Directors may take certain actions. Among these actions, in the case of excluding the transfer of assets and liabilities to financial trusts or other financial entities, the Central Bank may totally or partially exclude the liabilities mentioned in section 49, paragraph e), as well as debt defined in section 53, giving effect to the order of priority among creditors. Regarding the partial exclusion, the order of priority of point e) section 49 must be followed without treating liabilities of the same grade differently.
Mandatory Deposit Insurance System
Law No. 24,485, passed on April 12, 1995, as amended, created a Deposit Insurance System, or “SSGD”, which is mandatory for bank deposits, and delegated the responsibility for organizing and implementing the system to the Central Bank. The SSGD is a supplemental protection to the privilege granted to depositors by means of section 49 of the FIL, as mentioned above.
The SSGD has been implemented through the establishment of a Deposit Guarantee Fund, or “FGD,” managed by a private-sector corporation called Seguro de Depósitos Sociedad Anónima, (Deposit Insurance Corporation, or “SEDESA”). According to Decree No. 1292/96, the shareholders of SEDESA are the government through the Central Bank and a trust set up by the participating financial
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entities. These institutions must pay into the FGD a monthly contribution determined by Central Bank regulations. The SSGD is financed through regular and additional contributions made my financial entities, with the additional contribution differentiated based on factors such as the rating assigned by the Superintendency, the ratio of excess computable equity responsibility relative to the minimum capital requirement, and the quality of the active portfolio, with the additional contribution not exceeding the normal contribution.
Financial entities must make regular monthly contributions to the FGD equivalent to 0.015% of their monthly average daily balances of the deposits listed in the following paragraph, recorded in the second month prior to the contribution. The Central Bank may require an advance contribution of up to the equivalent of twenty-four (24) minimum normal contributions, with a notice period of no less than thirty calendar days, to cover the FGD’s resource needs. The first contribution was made on May 24, 1995.
The Central Bank may also require financial entities to advance the payment of up to the equivalent of two years of monthly contributions and debit the past due contributions from funds of the financial entities deposited with the Central Bank. The Central Bank may require additional contributions by certain institutions, depending on its evaluation of the financial condition of those institutions, as described above.
The SSGD’s coverage applies to deposits in pesos and foreign currency made in participating entities in the form of: current accounts, demand accounts opened in Cooperative Credit Unions, savings accounts, fixed-term deposits, salary/social security accounts, basic, universal free, and special accounts, term investments, and immobilized balances derived from the above concepts.
The SSGD does not cover: (i) deposits and term investments in transferable paper acquired through endorsement, even if the last endorsee is the original depositor; (ii) demand deposits with interest rates exceeding the reference rate, and term deposits or investments exceeding 1.3 times the reference rate or the reference rate plus 5 percentage points, as well as those influenced by additional incentives; (iii) deposits from financial entities in other intermediaries, including those acquired through secondary market transactions; (iv) deposits made by related parties to the entity, as defined in the “Large Credit Risk Exposures” regulations; (v) fixed-term deposits in securities, acceptances, or guarantees; (vi) immobilized balances from excluded deposits or transactions; (vii) term deposits and investments structured through Electronic Certificates for Deposits and Term Investments (CEDIP) transmitted after the issuing financial entity falls under the conditions outlined in Section 49 of the Central Bank’s Organic Charter or Section 35 bis of the FIL.
The guarantee will cover the return of the deposited capital, interest, adjustments (based on the Reference Stabilization Coefficient, “CER,” for UVA deposits and the Construction Cost Index, “ICC”, for UVI deposits), and exchange rate differences, up to a limit of Ps.50,000,000, accrued until the date of revocation of the authorization or suspension of the entity under Article 49 of the Central Bank’s Organic Charter. For accounts held by two or more individuals, the guarantee limit will be Ps.50,000,000, distributed proportionally among the account holders. The total guarantee for any individual, including accumulated accounts and deposits covered by this scheme, will not exceed the Ps.50,000,000 limit.
Effective payment on this guaranty will be made within thirty (30) business days after revocation of the license of the financial institution in which the funds are held; such payments are subject to the exercise of the depositor’s priority rights described above.
In view of the circumstances affecting the financial system, Decree No. 214/2002 provided that SEDESA may issue registered securities for the purpose of offering them to depositors in payment of the guarantee in the event it should not have sufficient funds available.
When the contributions to the FGD reach the greater of Ps.2 billion or 5.0% of the total deposits of the financial system, whichever is greater, the Central Bank may suspend or reduce the obligation to make contributions to the FGD, reinstating the obligation in whole or in part when the contributions subsequently fall below that level.
Other Restrictions
Pursuant to the FIL, financial institutions cannot create any kind of liens over their assets without the Central Bank’s authorization. Furthermore, in accordance with section 72 of Capital Markets Law, publicly offered companies are forbidden to enter into transactions with their directors, officers or affiliates in terms more favorable than arms-length transactions.
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Capital Markets
Commercial banks are authorized to subscribe for and sell shares and debt securities. At present, there are no statutory limitations as to the amount of securities for which a bank may undertake to subscribe. However, under Central Bank regulations, underwriting of debt securities by a bank would be treated as “financial assistance” and, accordingly, until the securities are sold to third parties, such underwriting would be subject to limitations.
On September 9, 2013, the CNV published Resolution No. 622/2013 (the “CNV Rules”) supplementing the Capital Markets Law. On May 9, 2018, the Argentine Congress approved the Argentine Productive Financing Law No. 27,440, which modernized and completed the legal framework of the Argentine capital markets. Law No. 27,440 amended the legal framework of the capital markets (Law No. 26,831), mutual funds (Law No. 24,083), negotiable obligations (Law No. 23,576), the Argentine Civil and Commercial Code (Law No. 26,994, as amended from time to time), financing of housing and construction (Law No. 24,441), the subjects obliged to report on concealing and asset laundering of criminal origin in the capital market framework (Law No. 25,246), and the tax relief regime for the purchase of private securities (Law No. 20,643).
Financial Institutions with Economic Difficulties
The FIL provides that any financial institution, including a commercial bank, (i) with its solvency impaired, in the judgment of the Central Bank; (ii) recording deficiencies on the minimum cash reserve requirement during the periods established by the Central Bank; (iii) recording repeated failures to comply with the various limits or technical relations established; or (iv) that could not maintain the minimum asset liability required for its particular class, location or characteristics, must (upon request from the Central Bank and in order to avoid the revocation of its license) prepare a restructuring plan (plan de regularización y saneamiento). The plan must be submitted to the Central Bank on a specified date, no later than thirty (30) calendar days from the date on which a request to that effect is made by the Central Bank. If the institution fails to submit, secure regulatory approval of, or comply with, a restructuring plan, the Central Bank will be empowered to revoke the institution’s license to operate as such, without prejudice to the application of the penalties provided for in the aforementioned law.
The Central Bank may appoint overseers with veto power, require the provision of guarantees and limit or forbid the distribution or remittance of profits, temporarily admit exceptions to the relevant limits and technical relations, exempt or defer the payment of charges and/or fines as provided by the Financial Institutions Law.
The Central Bank’s charter authorizes the Superintendency to fully or partially suspend, exclusively subject to the approval of the President of the Central Bank, the operations of a financial institution for a term of thirty (30) days if the liquidity or solvency thereof is adversely affected. Such term could be renewed for up to ninety (90) additional days, with the approval of the Central Bank’s Board of Directors. During such suspension term an automatic stay of claims, enforcement actions and precautionary measures is triggered, any commitment increasing the financial institution’s obligations shall be null and void, and debt acceleration and interest accrual shall be suspended.
Institution Restructuring to Safeguard Credit and Bank Deposits
If a financial institution meets the Central Bank’s criteria and is found to be in any of the situations set forth in Section 44 of the FIL, the Central Bank may authorize the restructuring of the financial institution in defense of depositors, prior to revocation of the authorization to operate. The restructuring plan may consist of certain steps, including, among others:
● adoption of a list of measures to capitalize or increase the capital of the financial institution;
● revoke the approval granted to the shareholders of the financial institution to hold interests therein;
● exclusion or transfer assets and liabilities;
● judicial intervention of the institution, displacing the statutory administrative authorities, and determine the capabilities needed to comply with the assigned function.
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Revocation of the License to Operate as a Financial Institution
The Central Bank may revoke the license to operate as a financial institution (a) at the request of the legal or statutory authorities of the institution; (b) in the cases contemplated by the Argentine Civil and Commerce Code or in the laws governing its existence as a legal entity; (c) when, to the judgment of the Central Bank, the affections to the solvency and/or liquidity of the institution cannot be solved through a regularization and sanitation program; (d) in the rest of the cases provided by the FIL.
Liquidation of Financial Institutions
As provided in the FIL, the Central Bank must notify the revocation decision to a competent court, which will then determine who will liquidate the entity: the corporate authorities (extrajudicial liquidation) or an independent liquidator appointed by the court for that purpose (judicial liquidation). The court’s decision will be based on whether there are sufficient assurances that the corporate authorities are capable of carrying out such liquidation properly, prior authorization of the Central Bank and in the cases provided by subsections a) and b) of section 44 of the FIL.
Bankruptcy of Financial Institutions
According to the FIL, financial institutions are not allowed to file their own bankruptcy petitions. In addition, the bankruptcy shall not be adjudged until the license to operate as a financial institution has been revoked.
Once the license to operate as a financial institution has been revoked, a court of competent jurisdiction may adjudge the former financial institution in bankruptcy, or a petition in bankruptcy may be filed by the Central Bank or by any creditor of the bank, in this case after a period of sixty (60) calendar days has elapsed since the license was revoked.
Once the bankruptcy has been adjudged, provisions of the Bankruptcy Law No. 24,522 (the “Bankruptcy Law”) and the FIL shall be applicable; provided however that in certain cases, specific provisions of the FIL shall supersede the provisions of the Argentine Bankruptcy Law (i.e. priority rights of depositors).
Merger and Transfer of Goodwill
Merger and transfer of goodwill may be arranged between entities of the same or different type and will be subject to the prior approval of the Central Bank. The new entity or the buyer must submit a financial-economic structure profile supporting the project in order to obtain authorization from the Central Bank.
Financial System Restructuring Unit
The Financial System Restructuring Unit was created to oversee the implementation of a strategic approach towards those that benefit from assistance provided by the Central Bank. This unit is in charge of rescheduling maturities, determining restructuring strategies and action plans, approving transformation plans, and accelerating repayment of the facilities granted by the Central Bank.
Holding Companies
On June 28, 2019, the Central Bank ruled, through Communication “A” 6723, with effect from January 1, 2020, that Group “A” financial entities which are controlled by non-financial entities (as in our case in relation with the Bank) shall comply with the Minimum Capital requirements (see “Argentine Banking Regulation—Liquidity and Solvency Requirements— Minimum Capital Requirements”), the Major Exposure to Credit Risk regulations (see “Argentine Banking Regulation—Credit Risk Regulation — Large Exposures”), the Liquidity Coverage Ratio (see “Argentine Banking Regulation— Liquidity Coverage Ratios”) and the Net Stable Funding Ratio (see “Argentine Banking Regulation—Liquidity Parameters—Net Stable Funding Ratio”) on a consolidated basis comprising the non-financial holding and all its subsidiaries (excluding insurance companies and non-financial subsidiaries).
Additionally, Group “A” financial institutions may not grant direct or indirect financial assistance of any kind to its holding company whenever it is a non-financial institution.
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Fintech Regulations
The Central Bank issued Communication “A” 6885 (as amended from time to time, regulations on “Payment Service Providers”), by means of which it regulates certain aspects of Fintech operations. Through these communications, PSPs as defined as legal entities that, although not classified as financial entities, perform at least one function within a retail payment system, as part of the broader framework of the national payment system.
By means of these rules, PSPs operations are regulated and a specific registry for them was created. Entities that are not eligible to operate as PSPs include legal entities that are not regularly incorporated in the country, or those that, while incorporated abroad as private legal entities, have failed to meet the requirements outlined in the General Corporations Law No. 19,550 and its amendments, specifically regarding the regular exercise of activities within their corporate purpose in Argentina. Additionally, entities recognized by the CNV as markets, clearinghouses, or any other type of agents are excluded from operating as PSPs. Furthermore, legal entities whose shareholders, voting rights, or governing and supervisory bodies involve individuals who fall under the provisions of sections a), b), d), e), or f) of Article 10 of the Financial Entities Law, or who have been convicted of crimes such as property offenses, public administration crimes, economic and financial offenses, or offenses against public faith, including violations of privacy or association crimes, are also disqualified. However, this does not apply to shareholdings acquired in securities markets that do not exceed 20% of the capital or voting rights.
Regarding the registry, regulations on “Payment Service Providers” stipulate that PSPs performing the functions outlined below are required to register in the ‘Payment Service Providers Registry’ managed by the Superintendency:
1. Virtual Account Provision: provision of virtual accounts for performing debits and credits within a payment scheme. The accounts offered by PSPs are referred to as payment accounts; these are freely available accounts in pesos that allow for the ordering and receiving of payments. PSPCPs may allow for these accounts to have more than one holder.
2. Acceptance: Enroll merchants into payment schemes with transfers. This includes, among other tasks, facilitating the mechanisms to initiate payments, transmitting payment order information to the administrator or other participants of the scheme, and, if authorized, confirming the operations.
3. Initiation (registration is required only if they provide digital wallet services): Send a valid payment instruction at the request of a payer to the provider of a payment account (or a sight account) or to the issuer of the payment instrument.
4. ATM Networks: Manage transactions ordered through ATMs.
5. Electronic Funds Transfer Networks (processing or operation): Transmit electronic instructions for fund movements between financial entities and, where applicable, notify the PSP providing payment accounts of the credits to their sight accounts so that it can proceed with the fulfillment of the transfer function.
6. Acquiring: Enroll merchants into payment schemes with cards. This includes, among other tasks, facilitating the mechanisms to initiate payments, transmitting payment order information to the administrator or other participants of the scheme, and, if authorized, confirming the operations.
7. Aggregation or Sub-acquiring: Provide merchants with access to payment schemes that the aggregator has contracted with one or more acquirers, using the aggregator’s or sub-acquirer’s merchant identifier (ID), which acts as the receiving customer of the funds from the settlement of various payment schemes.
8. Non-Banking Collection Companies for Taxes and/or Services: Provide payment and/or collection services for taxes and/or services on behalf of third parties through agent networks, using cash and/or payment instruments.
PSP regulations establish that all funds credited to payment accounts offered by PSPCPs shall be (i) available at all times, for an amount at least equivalent to the one credited in the payment account; (ii) deposited in Pesos, in on-sight accounts in Argentine financial entities; and (iii) on an independent on-sight account from the one used for trading for own account (e.g.: creditor or salary payments).
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Any breach of the rules as set on the abovementioned communication is submitted to the sanctions of the FIL.
By means of Communication “A” 7156, the Central Bank extended the application of the provisions of the FIL to “Other non- financial credit providers” covered by the rules on “Non-financial credit providers”, and among other measures, it provided that as from February 1, 2021, other non-financial credit providers and non-financial companies issuing credit and/or purchase cards will be subject to the provisions set forth in the rules on “Protection of financial services users”, for the financing they grant.
On February 24, 2022, the Central Bank issued Communication “A” 7462 (as amended from time to time) providing for the creation of the “Register of interoperable digital wallets” and establishing that any PSP wishing to provide a digital wallet service that allows making transfer payments initiated by reading QR codes must be registered therein. In addition, it defines a “digital wallet” service as the service offered by a financial institution or payment service provider (PSP) through an application on a mobile device or web browser that must allow making payments with transfer (PCT) and/or with other payment instruments.
Pursuant to Communication “A” 7593, the Central Bank amended the rules on “Protection of Financial Services Users” to include Payment Service Providers that offer payment accounts and Payment Service Providers that perform the function of initiation and provide the digital wallet service among the obligated parties.
On the other hand, as regards the rules on “Payment Service Providers”, it establishes that they must submit a compliance report prepared by professionals or associations of licensed professionals, which must be prepared in accordance with the model to be established from time to time, and verify compliance with the rules issued by the Central Bank that are applicable according to the type of provider in question and submitted to the Superintendency on an annual basis.
By means of Communication “A” 7783 (as amended and supplemented from time to time), the Central Bank approved the rules on “Minimum requirements for the management and control of technology and information security risks associated with digital financial services” applicable to both PSPCP and financial entities.
Gender Parity Requirements
On September 3, 2020, by means of Communication “A” 7100 (as amended from time to time), the Central Bank amended the rules on “Guidelines for Corporate in Financial Institutions” (Lineamientos para el gobierno societario en entidades financieras) to include a requirement of gender parity.
By virtue of such Communication, the Central Bank suggested to financial institutions to consider the progressive incorporation of women on new appointments and/or renewals, until gender parity is achieved. In this regard, the Central Bank defined gender parity as the guideline that aims at equalizing the participation of men and women in labor decision-making spaces, ensuring the right to equal opportunities and non-discrimination on the bases of gender.
Mandatory Tender Offer Regime
We are subject to the mandatory tender offer rules set forth in the Argentine Capital Markets Law. These rules provide that any person who, individually or through a concerted action (as defined in Argentine Capital Markets Law), effectively acquires a controlling interest in a company whose shares are admitted to the public offering regime shall be required to make a tender offer at a fair price (“OPA”), determined in accordance with the Argentine Capital Markets Law and the CNV Rules.
The offer must be filed with the CNV as soon as possible and no later than one month after the effective acquisition of the controlling interest.
Concept of a “Significant Share”
The Argentine Capital Markets Law provides that a person will be deemed to have, individually or through concerted action (as defined in the Argentine Capital Markets Law), a controlling interest when:
● they have directly or indirectly reached voting rights equal to or greater than fifty percent (50% ) of the voting capital stock of the company, excluding from the calculation any treasury shares; or
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● they have reached a holding participation of less than fifty percent (50%) of the voting capital stock of a company, but otherwise act as a controlling shareholder of such company, as defined by the Argentine Capital Markets Law.
Fair Price in a Mandatory Tender Offer Due to a Change of Control
In accordance with the Argentine Capital Markets Law, the fair price in a mandatory tender offer due to a change of control shall be the highest of the following: (a) the highest price that the offeror or any persons acting in concert with the offeror have paid or agreed to pay for the securities subject to the offer during the 12 months preceding the start date of the mandatory tender offer period; and (b) the average price of the securities subject to the offer during the 6 months immediately preceding the announcement of the transaction by which the change of control is agreed, regardless of the number of trading sessions in which they were negotiated. For the purposes of clause (a) above, insignificant acquisitions in relative terms shall not be considered, provided they were made at market price, in which case the highest price paid for the remaining acquisitions in the reference period shall apply. If the percentage of shares listed on a CNV-authorized market represents at least 25% of the issuer’s share capital, and liquidity conditions determined by the CNV are met, then the price referenced in subsection (b) shall not apply to mandatory tender offers due to a change of control
Additionally, for the purpose of determining the fair price in a mandatory tender offer due to a change of control, the CNV Rules shall apply.
Fair Price in Other Mandatory Tender Offers
Both Argentine Capital Markets Law and the CNV Rules set forth specific provisions regarding the determination of the fair price for mandatory tender offers in the cases of near-total control (squeeze out) and voluntary withdrawal from the public offering (delisting).
Tender Offer Regime in the Case of a Voluntary Withdrawal from the Public Offering and Listing System in Argentina
Argentine Capital Markets Law and CNV Rules established that when a company whose shares are publicly offered and listed in Argentina agrees to withdraw voluntarily from the public offering and listing system in Argentina, it must follow the procedures provided for in the CNV’s regulations and it must likewise launch an OPA for its aggregate shares or subscription rights or securities convertible into shares or stock options under the terms provided for in such regulation. It is not necessary to extend the public offering to those shareholders that voted for the withdrawal at the shareholders’ meeting.
The acquisition of one’s own shares must be made with liquid and realized profits or with free reserves, whenever paid up in full, and for the amortization or disposition thereof, within the term set forth in Section 221 of the Argentine General Companies Law and the company must present the CNV with evidence that it has the necessary solvency to effect such purchase and that the payment for the shares will not affect its solvency.
Section 88.II of the Argentine Capital Markets Law establishes that in the case of an OPA for voluntary delisting and for near-total control, the following price criteria shall be followed:
a) the highest price that the offeror or persons acting in concert with the offeror have paid or agreed to pay for the securities subject to the offer during the twelve (12) months prior to the notification to the minority shareholder or the unilateral declaration by the controlling shareholder in the case of OPAs for near-total control, or the agreement to request delisting in the case of OPAs for voluntary delisting;
b) the average price of the securities subject to the offer during the immediately preceding six-month period prior to the notification to the minority shareholders or the unilateral declaration by the controlling shareholder in the case of OPAs for near-total control, or the agreement to request delisting in the case of OPAs for voluntary delisting, or from such other date on which the offer must be made;
c) the book value of the shares, considering for the purposes of acquisition in the case of voluntary delisting a special delisting balance sheet;
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d) the value of the company, assessed according to discounted cash flow criteria and/or indicators applicable to comparable companies or businesses; and
e) the liquidation value of the company.
The fair price offered may not be lower than the price indicated in items (a) and (b) above. Furthermore, in cases where the mandatory tender offer must be made without the offeror having previously acquired the securities, the fair price may not be lower than that calculated according to the valuation methods contained in item (b) above, and price adjustment rules apply where appropriate.
In addition to the aforementioned legal provisions, our bylaws provide that, in the event that we launch a tender offer for our shares,there shall be no difference in the price offered for common shares, regardless of their class. Likewise, in the case of a tender offer triggered by a change of control, the fair price to be offered may not be lower than the highest price that the offeror, acting individually or in concert with its affiliates and/or any other persons, has paid or agreed to pay for any class of our common shares during the 180 consecutive days prior to the date on which the offer is made. The procedure for conducting the tender offer shall comply with the Argentine Capital Markets Law and the regulations of the CNV.
Mandatory or Voluntary Tender Offer in the Case of Near-Total Control
If a shareholder, whether an individual or legal entity, directly or through one or more companies controlled by it, acquires 95% or more of the outstanding capital stock of a publicly traded company subject to the Argentine Capital Markets Law (“near-total control”), any minority shareholder may request that the controlling shareholder launch an OPA for all outstanding shares of such company. Likewise, any such individual or legal entity that, directly or through one or more companies holds 95% or more of the outstanding capital stock of a publicly traded company subject to the Argentine Capital Markets Law may issue a unilateral declaration of their intention to purchase all outstanding shares of the company within six months following the date of acquisition of “near-total control”, and may delist the company from public offering and remove its shares from listing and trading. In either case, the purchase price must be equitable, as described above.
Penalties for Breach
In the event of non-compliance with the obligation to make a mandatory public tender offer, the CNV after formally requiring the obligated parties to comply with such obligation shall order the auction of the acquired shareholdings, without prejudice to any other applicable sanctions. Additionally, the CNV may determine that any persons failing to comply with the obligation to make a public tender offer shall not exercise the voting rights attached to the shares of the company, regardless of the title under which such rights may be exercised. Any acts adopted in the exercise of such rights shall be deemed null and void.
A party shall be deemed to have failed to comply with the mandatory public tender offer obligation if: (1) it fails to submit the offer within the maximum period established; (2) it submits the offer with manifest irregularities, as determined by the CNV’s rules; (3) it submits the offer beyond the maximum period established; and/or (4) it fails to execute the offer within the time frame set forth in the regulations issued by the CNV, from the moment the mandatory public tender offer obligation arises
Obtained Exemptions and Other Regulations
Given the Bank’s nature and purpose, the Central Bank has approved certain exemptions for the Bank and other regulations regarding compliance with certain technical ratios and monetary regulations. The main standards applicable to the Bank, effective as of December 31, 2024 and 2023 are as follows:
● The Central Bank’s Resolution No. 232 dated June 15, 2000 allows the Bank to compute, for the purpose of establishing the individual minimum capital requirement, any monthly surplus recorded by Banco de Inversión y Comercio Exterior.
● The Central Bank’s Resolution No. 139/2009, as amended by Resolutions No. 152/2009, 195/2010, 128/2011, excluding from certain limitations under prudential regulations with the Non-Financial Public Sector, all contingent liabilities for foreign trade transactions (including opening and use of letters of credit and other guarantees related to foreign trade) and financing applied to the payment of fuel and/or electric power imports, under the conditions set forth therein.
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● Through Resolution No. 76 dated March 12, 2009, as amended, pursuant to Law No. 21799 and Article 74 of Law No. 26422, the Central Bank sets forth the process for financial assistance to the Argentine Public Sector to be implemented by the Bank, stating the following requirements for implementation:
(i) The total amount of financings granted in accordance with Article 74 of Law No. 26422 and the percentage (established according to the remaining term) of guarantees and other undertakings by the Bank in favor of the Argentine Non-Financial Public Sector, taking into account principal, interest, exchange rate differences and other ancillary values, shall not exceed 30% of public sector deposits with the Bank, upon deduction of the “Official Accounts Unified Fund” (“FUCO”) and the amount of deposits offered as guarantee under any concept. (Res. No. 76 section 1.2).
(ii) The total amount of financings granted by the Bank to the Argentine Non-Financial Public Sector and the percentage (established according to the remaining term) of guarantees and other undertakings in favor thereof, taking into account principal, interest, exchange rate differences and other ancillary values, shall not be higher than total relevant deposits plus 50% of the Bank’s Computable Equity for the prior month. (Res. No. 76 section 3).
For calculating limits, the average of daily balances of Argentine Non-Financial Public Sector deposits net of indicated deductions for the latest sixty business days shall be taken into account. The limits must be met both when requesting authorization to the Central Bank and at the time of granting or undertaking. When requesting authorization to the Central Bank, the Ministry of Economy should be involved, and one of the external auditors of the Bank must submit a special report on compliance with requirements as of such date. At the time of granting, the Bank must comply with the latest filings required under the reporting system as regards such concepts. It is also established that any excess recorded by the Bank in respect of the limits indicated shall be considered as increase of the minimum capital for credit risk, as provided for under the Minimum Capital Regulations.
● On February 23, 2018, the Central Bank issued Resolution No. 70/2018 which, for the purpose of calculating the limits established in sections 1.2 and 3 of Resolution No. 76/2009, establishes that deduction of the FUCO use by the Argentine Non-Financial Public Sector shall not be taken into consideration and that the amount of deposits is net of deposits offered as guarantee.
Anti-Money Laundering, Terrorism Financing and Proliferation of Weapons of Mass Destruction Financing Regime
The concept of money laundering is generally used to denote transactions aimed at introducing funds from illicit activities into the institutional system and thus transform gains from illegal activities into assets of a seemingly legitimate source.
Terrorist financing (“TF”) consists of providing funds for terrorist activities. This may involve funds raised from legitimate sources, such as personal donations and profits from businesses and charitable organizations, as well as from criminal sources, such as drug trade, weapons and other goods smuggling, fraud, kidnapping and extortion.
Proliferation of weapons of mass destruction financing consists of providing financial support or resources to assist in the development, manufacture, acquisition, or spread of nuclear, chemical, or biological weapons and their delivery systems, in contravention of national laws or, where applicable, international obligations.
On April 13, 2000, the Argentine Congress passed Law No. 25,246, (subsequently amended and complemented, the “AML/CTF/CPF Law”), which created at the national level the Anti- Money Laundering, Counter- Terrorist Financing and the Financing of Proliferation of Weapons of Mass Destruction Regime (“AML/CTF/CPF Regime”), criminalizing money laundering, creating and designating the Financial Information Unit (“UIF”, for its acronym in Spanish) as the enforcement authority of the regime, while also imposing legal obligations on certain public and private sector entities and professionals (the “Reporting Entities”) to report and cooperate with the UIF.
The UIF is a decentralized agency that operates with autonomy and financial independency under the Argentine Ministry of Justice, and its mission is to prevent and deter money laundering, terrorism financing and proliferation of weapons of mass destruction financing crimes.
The following are certain provisions relating to the AML/CTF/CPF Regime established by the Argentine Criminal Code, the AML/CTF/CPF Law, including regulations issued by the UIF, the CNV and the Central Bank. It is recommended that holders consult their own legal advisors and read the AML/CTF/CPF Law and its complementary regulations.
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Money Laundering, Terrorist Financing and Proliferation of Weapons of Mass Destruction in the Argentine Criminal Code
Money laundering
Section 303 of the Argentine Criminal Code (the “ACC”) defines money laundering as a crime committed whenever a person converts, transfers, manages, sells, encumbers, acquires, conceals or in any other way puts into circulation in the market, property derived from an unlawful act, with the possible consequence that the origin of the original property or the subordinate property acquires the appearance of a lawful origin. Section 303 of the ACC establishes the following penalties:
(i) If the amount of the transaction exceeds the sum of 150 Minimum, Vital, and Mobile Wages at the time of the events (as of the date of this annual report, this equals Ps. 52.860.000), either in a single act or by the repetition of various acts linked to each other, the penalty shall be imprisonment for a term of three (3) to ten (10) years and fines of two (2) to ten (10) times the amount of the illicit transaction. This penalty may be increased by one third of the maximum and half of the minimum, when the perpetrator of the crime:
(a) regularly commits such crimes or participates in organizations or associations specially designed for committing such crimes;
(b) is a public official who committed the act in the exercise or occasion of their duties. In this case, he/she shall also be subject to a penalty of special disqualification of three (3) to ten (10) years. The same penalty shall be imposed to anyone who has acted in the exercise of a profession or occupation requiring special qualification.
(ii) Anyone who receives money or other property from a criminal offense for the purpose of applying them in an operation as described above, which gives them the possible appearance of a lawful origin, shall be punished with imprisonment for a term of six (6) months to three (3) years.
(iii) If the value of the goods does not exceed 150 minimum wages, the penalty shall be a fine of five (5) to twenty (20) times the amount of the illicit transaction.
These provisions shall apply even if the preceding criminal offence was committed outside the scope of applicability of Argentine Criminal Code, insofar as the criminal offence was also punishable in the place where it was committed.
Penalties for legal persons
Furthermore, Section 304 of the ACC provides that when the criminal acts have been committed in the name of, or with the intervention of, or for the benefit of a legal person, the following sanctions shall be imposed to the entity jointly or alternatively:
(i) fine of two (2) to ten (10) times the value of the property subject to the offense;
(ii) total or partial suspension of activities, which in no case shall exceed ten (10) years;
(iii) debarment for public tenders or bidding processes or any other State-related activities, which in no case shall exceed ten (10) years;
(iv) dissolution and liquidation of the legal person when it was created for the sole purpose of committing the offense, or such acts constitute the main activity of the entity;
(v) loss or suspension of any State benefit that it may have;
(vi) publication of an extract of the condemnatory sentence at the expense of the legal entity.
In order to calibrate these sanctions, the Court will take into account the failure to comply with internal rules and procedures, the omission of vigilance over the activity of the authors and participants; the extent of the damage caused, the amount of money involved in the commission of the offense, the size, nature and economic capacity of the legal entity. In the cases in which it is essential
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to maintain the operational continuity of the entity, or of a public work, or particular service, the sanctions of suspension of activities or dissolution and liquidation of the legal person shall not be applicable.
Terrorist Financing and Proliferation of Weapons of Mass Destruction Financing
Section 306 of the ACC criminalizes the financing of terrorism and the proliferation of weapons of mass destruction. This offense is committed by any person who directly or indirectly collects or provides property or money, with the intention of it being used, or in the knowledge that it will be used, in full or in part:
(i) to finance the commission of acts which have the aim of terrorizing the population or compelling national public authorities or foreign governments or agents of an international organization to perform or refrain from performing an act (according to section 41.5 of the ACC);
(ii) by an organization committing or attempting to commit crimes for the purpose set out in (i);
(iii) by an individual who commits, attempts to commit or participates in any way in the commission of offenses for the purpose set out in (i);
(iv) to finance, for themselves or for third parties, the travel or logistics of individuals and/or things to a State other than that of their residence or nationality, or within the same national territory for the purpose of perpetrating, planning, preparing or participating in the purpose set out in (i);
(v) to finance, for themselves or for third parties, the provision or receipt of training for the commission of offenses for the purpose set out in (i);
(vi) to finance the acquisition, production, development, possession, supply, exportation, importation, storage, transportation, transfer, or in any way the use of weapons of mass destruction of the nuclear, chemical, biological type, their delivery systems, means of delivery and their related materials, including dual-use technologies and goods to commit any of the crimes provided for in the ACC or in international regulations.
The penalty for this offense is imprisonment for a term of five (5) to fifteen (15) years and a fine of two (2) to ten (10) times the amount of the illicit transaction. Likewise, the same penalties shall apply to legal persons as described for the crime of money laundering.
The same penalty of imprisonment and fine shall apply to anyone who produces, manufactures, develops, possesses, supplies, exports, imports, stores, transports, transfers, employs, or in any way proliferates, increases, reproduces or multiplies the weapons of mass destruction referred to in (vi) above, their means of delivery and related materials intended for their preparation.
The penalties described above will be applied regardless of the occurrence of the crime for which the financing was intended and, if the latter is committed, regardless of whether the goods or money were used for its commission.
These provisions shall apply even if the offense financed or intended to be financed is committed outside the territorial scope of application of the ACC, or, in the cases described in (ii) and (iii), if the organization or individual is located outside Argentine territory, provided that the conduct is also punishable in the relevant jurisdiction.
Reporting Entities Required to Report and Cooperat with the UIF
The AML/CTF/CPF Regime, in line with international AML/CTF/CPF standards, not only designates the UIF as the agency in charge of preventing money laundering, terrorism financing and proliferation of weapons of mass destruction financing crimes. It also imposes obligations on various public and private sector entities and individuals, designated as Reporting Subjects ( “Sujetos Obligados”), report and cooperatewith the UIF.
Pursuant to Section 20 of the AML/CTF/CPF Law, the following, among others, are Reporting Entitiesbefore the UIF:
(i) banks, financial entities and insurance companies;
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(ii) exchange agencies and natural and legal persons authorized by the Central Bank to intervene in the purchase and sale of foreign currency with funds in cash or checks issued in foreign currency or through the use of debit or credit cards or in the transfer of funds within or outside the national territory;
(iii) virtual asset service providers, non-financial credit providers, issuers, operators and/or providers of collection and/or payment services, central securities depository agents and corporate and trust service providers
(iv) settlement and clearing agents, trading agents; natural and/or legal persons registered with the CNV acting in the placement of investment funds or other collective investment products authorized by such agency; crowdfunding companies, global investment advisors and the legal persons acting as financial trustees whose trust securities are authorized for public offering by the CNV, and the agents registered by the above mentioned controlling agency that intervene in the placement of negotiable securities issued within the framework of the above mentioned financial trusts;
(v) government organizations such as the Central Bank, the Customs Collection and Enforcement Agency (“ARCA,” as per its acronym in Spanish), the Superintendence of Insurance of the Nation (“SSN,” as per its acronym in Spanish), the CNV and the IGJ; and
(vi) professionals in economic sciences, lawyers and notaries public, when they are involved in certain transactions.
Pursuant to Section 21 of the AML Law, Reporting Entities have the following duties:
(i) obtaining documents that indisputably prove the identity, legal status, domicile and other relevant information, about their clients’ operations (“know your customer” policy);
(ii) reporting any suspicious events or transactions. For the purposes of the AML/CTF/CPF Law, suspicious transactions are those that, appear unusual, lack economic or legal justification, or are unusually or unjustifiably complex, whether conducted once or repeatedly (regardless of their amount);
(iii) refraining from disclosing to customers or third parties any actions taken in compliance with the AML/CTF/CPF Law;
(iv) registering before the UIF;
(v) documenting procedures for the prevention of money laundering, terrorism financing and proliferation of weapons of mass destruction financing crimes, establishing internal manuals that reflect the tasks to be developed with a risk based approach;
(vi) appointing compliance officers within the governing body who shall be responsible before the UIF (in case the obliged entity is an individual, such individual will be considered the compliance officer);
(vii) obtaining information and determining the purpose and nature of the relationship with the client;
(viii) determining the risk of money laundering, terrorism financing and financing of proliferation of weapons of mass destruction associated to clients and transactions;
(ix) carriyng out due diligence procedures to (i) determine the risk of money laundering, terrorism financing and financing of proliferation of weapons of mass destruction associated to clients and transactions, and (ii) review transactions during the course of the relationship with the client;
(x) identifying the individuals who exercise functions of management and representation of the client and those who have powers of disposition;
(xi) adopting specific measures to mitigate the risk of money laundering, terrorism financing and financing of proliferation of weapons of mass destruction;
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(xii) having appropriate risk management systems in place to determine whether the client or final beneficial owner is a politically exposed person;
(xiii) determining the source and legality of funds; and
(xiv) keeping, for ten (10) years, all necessary records of transactions, client files and business communications.
These obligations are supplemented by sector-specific UIF resolutions that establish more detailed and targeted requirements depending on the activity performed by each Reporting Entity. By way of example, Reporting Entities operating in the financial sector are subject to UIF Resolution No. 14/2023 as amended by Resolution 199/2024, while those operating in the capital markets are subject to UIF Resolution No. 78/2023, which set forth more granular rules on matters such as customer due diligence, ongoing monitoring, internal controls and risk mitigation measures. Resolution 14/2023, which sets out specific rules for the financial sector, inter alia, prohibits the maintenance of anonymous accounts or accounts under fictitious names, emphasizes the need to apply enhanced due diligence measures to clients commensurate with the risks identified, and provides for the possibility for financial institutions to rely on third parties to carry out certain due diligence measures.
In addition, the UIF has issued resolutions of general application addressing specific risk factors applicable across all sectors. For example, UIF Resolution No. 35/2023 establishes obligations for reporting entities in relation to politically exposed persons (“PEPs”), while UIF Resolution No. 112/2021 sets forth rules for the identification and verification of beneficial owners. Overall, this framework follows a risk-based approach aligned with FATF recommendations, requiring reporting entities to identify, assess and mitigate their money laundering, terrorism financing and proliferation of weapons of mass destruction financing crimes risks through proportionate measures.
With respect to PEPs, Resolution No. 35/2023 requires Reporting Entities to assess the level of risk at the time of initiating or continuing a contractual relationship and to apply enhanced, proportionate due diligence measures where appropriate. These measures include, among others: (i) obtaining approval from the Compliance Officer to initiate or continue relationships with foreign PEPs or domestic PEPs classified as high risk; (ii) adopting reasonable procedures to determine whether a client and/or beneficial owner qualifies as a PEP, both at onboarding and on an ongoing basis; (iii) requiring clients to submit sworn statements regarding their PEP status, including updates in the event of any change; and (iv) identifying and documenting the PEP status of beneficial owners, where applicable. The Resolution also regulates the duration of PEP status, establishing a two-year maintenance period, after which Reporting Entities must reassess the risk level based on factors such as the relevance of the public function performed, decision-making authority over funds, and seniority. The same duration applies to persons classified as PEPs due to kinship or close association.
Within their respective regulatory frameworks, the relevant sectoral authorities, such as the CNV and the Central Bank, also issue rules applicable to their regulated entities that reflect and operationalize AML/CFT/CPF requirements established by the UIF. In this context, the CNV regulations stipulate, among other provisions, that the Reporting Subjects under its control shall only perform the operations provided for under the public offering system when these operations are performed or ordered by persons constituted, domiciled or resident in countries, domains, jurisdictions, territories or associated states not considered to be non-cooperative or high risk by the FATF. Similarly, they establish payment modalities and control procedures for the reception and delivery of funds from and to clients.
Asset Freezing Regime and Terrorism Financing/Proliferation Financing Reporting Regime
Executive Decree No. 918/2012, as amended, establishes the legal framework and procedures for the reporting of transactions linked to terrorism financing and proliferation of weapons of mass destruction financing, as well as for the freezing of assets related to such activities.
In this context, UIF Resolution No. 207/2025 and 3/2026, regulate the implementation of Executive Decree No. 918/2012 and establish, among other matters: (i) the obligation for Reporting Entities to verify clients are not listed in terrorism financing and proliferation of weapons of mass destruction financing associated lists, including designated by the United Nations Security Council pursuant to Resolution No. 1267 (1999), 1718 (2006), 1737 (2006) or linked to criminal actions under Section 306 of the Argentine Criminal Code; (ii) the procedures for reporting suspicious transactions of terrorism financing and proliferation of weapons of mass
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destruction financing; and (ii) the administrative procedures applicable to the freezing of assets of natural or legal persons or entities related to terrorism financing and proliferation of weapons of mass destruction financing.
For purposes of facilitating compliance with these obligations, Executive Decree No. 489/2019 created the Public Registry of Persons and Entities Linked to Acts of Terrorism and Its Financing (Registro Público de Personas y Entidades vinculadas a actos de Terrorismo y su Financiamiento – “RePET”), a national public registry that consolidates: (i) the relevant United Nations Security Council designations and persons or entities linked to terrorism-related offenses under Argentine law; cases where court order or a ruling from the Public Prosecutor's Office formally charging or admitting the initiation of an investigation for committing or financing a terrorist act; And cases where The Financial Information Unit (FIU) has ordered the freezing of financial assets for any reason.
Supervision and Administrative Enforcement
The UIF is vested with supervisory and enforcement powers over Reporting Entities and may monitor compliance with AML/CFT/CPF obligations, conduct inspections and request information. In sectors subject to specific regulatory oversight, the UIF carries out its supervisory functions with the assistance of the relevant specific control authorities (“órganos de contralor específico”). In particular, the Central Bank assists the UIF with respect to reporting entities in the financial sector, and the National Securities Commission (CNV) assists the UIF with respect to reporting entities operating in the capital markets.
Reporting Entities are subject to administrative sanctions under the AML/CFT/CPF Law for failures to comply with applicable obligations. The UIF is empowered, following administrative proceedings, to impose the following sanctions:
(i) a fine ranging from one (1) to ten (10) times the total value of the assets involved in the transaction in cases of failure to report a suspicious transaction or of reporting it outside the prescribed timeframes and formal requirements; in the case of other infringements consisting of formal non-compliance, a fine ranging from fifteen (15) to two thousand five hundred (2,500) units, updated annually (currently set at ARS 54,140);
(ii) a warning;
(iii) a warning with the obligation to publish the operative part of the resolution; and
(iv) for compliance officers, disqualification for up to five (5) years from performing such functions.
Administrative liability extends both to the reporting entity and to the members of its management body and is subject to a statute of limitations of five (5) years.
Corporate Criminal Liability Law
The Corporate Criminal Liability Law No. 27,401 sets forth a criminal liability regime applicable to legal entities involved in certain corruption offenses directly or indirectly committed in their name, on their behalf or in their interest and from which a benefit may arise. The individual offenders may be employees or third parties — even unauthorized third parties, provided that the company ratified the act, even tacitly.
In accordance with such law, the Board of Directors has approved a Corruption and Anti-Bribery Policy that sets forth the ethical and compliance standards regarding officer corruption practices, under the scope of the Corporate Criminal Liability Law and the applicable international laws. The Board of Directors expressly prohibits this kind of practices and applies the same criterion in similar cases where private sector individual acts as counterparty.
In turn, the Board of Directors has implemented a Code of Conduct applicable to all employees, contractors, suppliers and agents, with the prohibitions, restrictions and conditions imposed upon them under the Integrity Program approved by us, which was previously discussed by the Appointment and Corporate Government Committee.
For an extensive analysis of the AML/CTF/CPF Regime and Anti-Bribery and Anti-Corruption Regime in effect as of the date of this annual report, investors should consult legal counsel and read Title XIII, Book 2 of the Argentine Criminal Code and any regulations issued by the UIF, the CNV and the Central Bank in their entirety. For such purposes, interested parties may visit the websites of the Argentine Ministry of Economy, (www.argentina.gob.ar/economia), the Argentine Ministry of Justice (https://www.argentina.gob.ar/justicia), the UIF (www.argentina.gob.ar/uif), the CNV (www.argentina.gob.ar/cnv), or the Central Bank (www.bcra.gov.ar). The information found on such websites is not a part of this annual report.
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Item 4.COrganizational structure
The following diagram illustrates our organizational structure as of the date of this annual report.
The following information is related to our subsidiaries and investees as of the date of this annual report:
Jurisdiction of Name under which the subsidiary does
Subsidiary incorporation business
Banco Supervielle S.A. Argentina Supervielle
Supervielle Seguros S.A. Argentina Supervielle Seguros
Supervielle Asset Management S.A. Sociedad Gerente de Fondos Comunes de Inversión S.A. Argentina Supervielle Asset Management / Premier
Espacio Cordial de Servicios S.A. Argentina Cordial
Micro Lending S.A.U. Argentina MILA
InvertirOnline S.A.U. (1) Argentina IOL invertironline
Portal Integral de Inversiones S.A.U. (1) Argentina IOL invertironline / IOL inversiones / IOL Academy
Supervielle Productores Asesores de Seguros S.A. Argentina Supervielle Broker de Seguros
Supervielle Agente de Negociación S.A.U. Argentina Supervielle Agente de Negociación
Bolsillo Digital S.A.U. (in dissolution) Argentina N/A
Sofital S.A.U.F. e I. Argentina N/A
IOL Holding S.A. Uruguay N/A
IOL Agente de Valores S.A. (1) Uruguay N/A
(1) InvertirOnline S.A.U., Portal Integral de Inversiones S.A.U. and IOL Agente de Valores S.A. are subsidiaries of IOL Holding S.A.
Banco Supervielle S.A.
We own 97.12% of the share capital of the Bank and Sofital owns 2.78%. The Bank is a universal commercial bank and our largest subsidiary. The Bank on an individual basis accounted for 94.8% of our total assets as of December 31, 2025. The Bank operates in Argentina, and substantially all of its customers, operations and assets are located in Argentina. It offers a wide variety of financial products and services to retail, corporate and institutional customers.
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According to the information published by the Central Bank, as of December 31, 2025 we were one of the top 10 private banks in the Argentine financial system in terms of outstanding amount of loans. In terms of deposits, we had an estimated market share of 3.0% of deposits in December 2025, ranking eighth among the total private banks in the Argentine financial system and eleventh among total banks in the Argentine financial system. In terms of total loans, we had an estimated market share of 2.8% of loans in December 2025, ranking seventh among the total private banks in the Argentine financial system and ninth among total banks in the Argentine financial system. As of December 31, 2025, the Bank on a consolidated basis had total assets of Ps.7,381 billion, a total loan portfolio of Ps.3,983.0 billion and total deposits of Ps.5,121 billion, and its attributable shareholders’ equity amounted to Ps.739.1 billion. For more information regarding the Bank’s business performance, see “—Business Segments.”
Espacio Cordial de Servicios S.A.
Espacio Cordial was created in October 2012 and began operating in December 2012. Espacio Cordial provides non-financial services in Argentina related to insurance, tourism, health care services, security and other contemplated in the bylaws of this business unit. We have direct service channels across the Bank’s branches located in Argentina. With respect to indirect channels, we reach open market customers through digital channels and third-party distributors.
Until March 4, 2024, Cordial Servicios owned 3.20% of the share capital of Sofital. On March 4, 2024, Grupo Supervielle purchased from Espacio Cordial all the shares that Espacio Cordial owned in Sofital S.A.U.F. and I., totaling 689,238 ordinary shares, non-transferable and with a nominal value of one Peso, each with one vote per share, representing 3.20% of the total shares of Sofital S.A.U.F. and I.
We own 95% of the share capital of Cordial Servicios and Sofital owns the remaining 5%. Until 2022, Grupo Supervielle had a Consumer Finance segment which included Cordial Servicios, among other subsidiaries. On December 1, 2023, the Central Bank approved the merger of IUDÚ Compañia Financiera S.A. into the Bank, and therefore IUDÚ Compañia Financiera S.A. and Tarjeta Automática S.A. were merged into the Bank, effective January 2023. As a result of this merger, the Company reclassified financial figures from Consumer Finance segment in 2023 and allocated the results of Cordial Servicios in the Asset management & other segment.
Micro Lending S.A.U.
MILA is a company that provides car financing loans and was acquired by Grupo Supervielle on May 2, 2018. We own 100% of the share capital of MILA. MILA promotes origination of car loans for the purchase of cars through greater efficiency and capillarity of the commercial network, new financial products and the use of synergies within the companies of Grupo Supervielle.
Until 2022, Grupo Supervielle had a Consumer Finance segment which included MILA, among other subsidiaries. On December 1, 2023, the Central Bank approved the merger of IUDÚ Compañia Financiera S.A. into the Bank, and therefore IUDÚ Compañia Financiera S.A. and Tarjeta Automática S.A. merged into the Bank, effective January 2023. As a result of this merger, the Company reclassified financial figures from Consumer Finance segment in 2023 and allocated the results of MILA in the Personal & Business Banking segment.
Supervielle Seguros S.A.
In June 2013, we and Sofital purchased 100% of the shares of Supervielle Seguros (formerly, Aseguradores de Créditos del Mercosur S.A.), which began to operate in October 2014.
Through Supervielle Seguros, the Company offers a wide range of insurance products to its clients. These are marketed through our network of branches, across various digital channels, and through the insurance specialized sales force which is focused on two major customer segments: Senior Citizens, and small businesses and SMEs.
For more information regarding the Supervielle Seguros’ business performance, see “—Business Segments.”
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Supervielle Productores Asesores de Seguros S.A.
On December 21, 2018, we created Supervielle Productores Asesores de Seguros and began to operate in the second half of 2019. Its purpose is to offer a wide range of products to clients in the small businesses, SMEs, and medium and large corporates segments, ensuring adequate coverage for their risks at competitive prices with the leading insurers in the market. As of the date of this annual report, the Company’s commercial focus on corporate insurance is on offering occupational risk administrator services, fleet, integral commerce, surety, and agricultural insurances, among others. We directly own 95.24% and indirectly own 100.0% of the share capital of Supervielle Productores Asesores de Seguros.
For information regarding Supervielle Productores Asesores de Seguros’ business performance, see “—Business Segments.”
Supervielle Asset Management S.A.
Supervielle Asset Management offers customized investment and savings solutions to its clients through investment funds. We participate in the mutual funds market through our “Premier” funds family.
We own 95% of the share capital of SAM and Sofital owns the remaining 5%.
For information regarding Supervielle Asset Management’s business performance, see “—Business Segments.”
Invertironline S.A.U. and Portal Integral de Inversiones S.A.U.
IOL invertironline is a digital online broker established 25 years ago that offers brokerage and savings and investment services based on an agile, simple, transparent and innovative platform, suitable for the profile of each client, with the objective of helping our clients increase their savings.
IOL invertironline offers investment alternatives in the Argentine stock market and in the United States and provides our customers with education tools on financing matters.
We indirectly own 100% of the share capital of InvertirOnline and Portal Integral de Inversiones S.A.U. through IOL Holding.
For information regarding IOL invertironline’s business performance, see “—Business Segments.”
Bolsillo Digital S.A.U.
On June 12, 2019, we created Bolsillo Digital S.A.U. Bolsillo Digital S.A.U. is Grupo Supervielle’s PSP (“Payment Service Provider”) fintech business which is registered with the Argentine Central Bank. Bolsillo Digital S.A.U.offered in-person and digital payment and collection solutions to businesses. On August 5, 2021, Grupo Supervielle, within the framework of the commercial strategy for its payment services business, transferred all of its shares of Bolsillo Digital S.A.U.to its subsidiary Banco Supervielle S.A. Bolsillo Digital S.A.U.’s main activity until 2022 was to provide payment services under its brand Boldi. In February 2023, the Boldi app was permanently closed. On March 30, 2026, the shareholders of Bolsillo Digital S.A.U. approved the early dissolution of the company and the commencement of its liquidation process pursuant to Section 94, subsection 1, of the Argentine General Companies Law. As from that date and until its deregistration, the company operates under the name Bolsillo Digital S.A.U. (in dissolution).
Supervielle Agente de Negociación S.A.U. (formerly, known as Futuros del Sur S.A.)
Supervielle Agente de Negociación provides trading agent services and is registered with the CNV. We acquired Supervielle Agente de Negociación in 2019 to expand our financial and investment services to institutional and corporate customers and increase cross selling in an efficient and profitable way.
We own 100% of the share capital of Supervielle Agente de Negociación.
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IOL Holding S.A. and IOL Agente de Valores. S.A.
On August 6, 2021, Grupo Supervielle acquired 95.24% of the shares of IOL Holding, a company incorporated in Uruguay. Sofital acquired the remaining 4.76% of the shares of IOL Holding.
On August 23, 2021, IOL Holding acquired 100% of the shares of IOL Agente de Valores S.A., a company incorporated in Uruguay which is expected to provide security dealer services. On June 16, 2022, the Central Bank of Uruguay authorized IOL Agente de Valores to act as a security dealer providing services to non-residents of Uruguay. IOL Agente de Valores S.A. is expected to provide its services through an online platform to non-residents of Uruguay who may be based in Latin America and seek to participate in the U.S. capital markets.
On May 14, 2024, Grupo Supervielle transferred all the shares of InvertirOnline S.A.U. and Portal Integral de Inversiones S.A.U. to IOL Holding and the shareholders’ meeting of IOL Holding approved the capitalization of the liabilities arising from the transfer. On May 15, 2024, Grupo Supervielle made a capital contribution to IOL Holding in cash in the amount of U.S.$7.7 million.
Sofital S.A.U.F. e I.
Sofital is a holding company that owns shares of the same companies owned by Grupo Supervielle. As of the date of this annual report, Sofital holds 2.7784% of the capital stock of the Bank, 5.0% of the capital stock of Cordial Servicios, 5.0% of the capital stock of Supervielle Seguros, 5.0% of the capital stock of SAM, 4.75903% of Supervielle Productores Asesores de Seguros and 0.0001% of IOL Holding. On March 19, 2024, our ordinary and extraordinary shareholders’ meeting approved the change of the legal status of Sofital to private single-entity limited company (“sociedad anónima unipersonal” or “S.A.U.”).
Item 4.DProperty, plants and equipment
The Bank owns 6,053 square meters of office space at Reconquista 330 and at San Martin 344 in Buenos Aires and Mendoza, for management, administrative and other commercial purposes and for central area personnel. The Bank also owns 15,196 square meters for retail branch properties in Mendoza, Córdoba, San Luis and Buenos Aires, and 639 square meters and 3,309 square meters of land in the City of San Luis and in the City of Mendoza, respectively.
Supervielle Seguros owns 1,953 square meters of office space located at Reconquista 330 in Buenos Aires.
IOL invertironline owns 527 square meters of office space located at Humboldt 1550 in Buenos Aires.
The rest of our administrative buildings and offices (including our headquarters), branches, sales and collection centers and storage properties are leased pursuant to arm’s length agreements.
Item 4.ESelected Statistical Information
You should read this information in conjunction with our audited consolidated financial statements and related notes, and the information under “Item 5.A. Operating Results” included elsewhere in this annual report. We prepared this information from our financial statements, which are prepared in conformity with IFRS. For further information, see Note 1.1 and Note 2 to our audited consolidated financial statements.
Average Balance Sheets, Interest earned on Interest-earning Assets and Interest Paid on Interest-bearing Liabilities
The average balances of our interest-earning assets and interest-bearing liabilities, including the related interest that is receivable and payable, are calculated on a daily basis.
Average balances have been separated between those denominated in Pesos and those denominated in U.S. dollars. The nominal interest rate is the amount of interest earned or paid during the period divided by the related average balance.
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The following tables show average balances, interest amounts and nominal rates for our interest-earning assets and interest-bearing liabilities for the years ended December 31, 2025, 2024 and 2023.
Year ended December 31,
2025 2024 2023
Average Average Average
Average Interest Nominal Average Interest Nominal Average Interest Nominal
Balance Earned Rate Balance Earned Rate Balance Earned Rate
(in thousands of Pesos)
ASSETS
Interest-Earning Assets
Investment Portfolio
Government and Corporate Securities 1,635,388,952 585,670,100 35.8 % 1,319,392,434 908,621,599 68.9 % 654,022,373 588,953,401 90.1 %
Pesos 1,396,715,254 517,856,342 37.1 % 1,217,859,533 874,415,076 71.8 % 457,135,192 421,056,365 92.1 %
Dollars 238,673,698 67,813,758 28.4 % 101,532,901 34,206,523 33.7 % 196,887,181 167,897,036 85.3 %
Securities Issued by the Central Bank 12,785,558 1,026,554 8.0 % 6,235,066 6,211,592 99.6 % 1,302,418,742 1,205,065,340 92.5 %
Pesos 37,996 — — % 2,898,673 6,211,592 214.3 % 1,295,712,272 1,205,065,340 93.0 %
Dollars 12,747,562 1,026,554 8.1 % 3,336,393 — — % 6,706,470 — — %
Year ended December 31,
2025 2024 2023
Average Average Average
Average Interest Nominal Average Interest Nominal Average Interest Nominal
Balance Earned Rate Balance Earned Rate Balance Earned Rate
Total Investment Portfolio 1,648,174,510 586,696,654 35.6 % 1,325,627,500 914,833,191 69.0 % 1,956,441,115 1,794,018,741 91.7 %
Pesos 1,396,753,250 517,856,342 37.1 % 1,220,758,206 880,626,668 72.1 % 1,752,847,464 1,626,121,705 92.8 %
Dollars 251,421,260 68,840,312 27.4 % 104,869,294 34,206,523 32.6 % 203,593,651 167,897,036 82.5 %
Loans
Loans to the Financial Sector 55,332,692 26,041,509 47.1 % 11,769,388 4,770,152 40.5 % 6,942,078 3,713,715 53.5 %
Pesos 55,332,692 26,041,509 47.1 % 11,764,238 4,770,152 40.5 % 6,814,274 3,713,506 54.5 %
Dollars — — — % 5,150 — — % 127,804 209 0.2 %
Overdrafts 207,709,156 108,911,966 52.4 % 191,962,908 109,482,955 57.0 % 135,717,706 127,221,537 93.7 %
Pesos 207,708,654 108,911,966 52.4 % 191,941,358 109,482,955 57.0 % 135,717,706 127,221,537 93.7 %
Dollars 502 — — % 21,550 — — % — — — %
Promissory notes 321,943,237 145,066,738 45.1 % 242,400,094 122,386,763 50.5 % 253,985,762 193,280,153 76.1 %
Pesos 315,184,188 144,623,452 45.9 % 239,017,675 122,284,165 51.2 % 252,221,717 193,202,882 76.6 %
Dollars 6,759,049 443,286 6.6 % 3,382,419 102,598 3.0 % 1,764,045 77,271 4.4 %
Mortgage loans 363,050,668 118,950,801 32.8 % 223,750,157 191,952,162 85.8 % 201,056,953 178,638,569 88.8 %
Pesos 363,050,668 118,950,801 32.8 % 223,750,157 191,952,162 85.8 % 201,056,953 178,638,569 88.8 %
Dollars — — — % — — — % — — — %
Automobile and Other Secured Loans 278,589,049 147,429,426 52.9 % 131,251,133 74,860,118 57.0 % 58,980,537 36,022,380 61.1 %
Pesos 278,589,049 147,429,426 52.9 % 131,251,133 74,860,118 57.0 % 58,980,537 36,022,380 61.1 %
Dollars — — — % — — — % — — — %
Personal Loans 475,283,905 297,636,833 62.6 % 210,694,463 154,073,612 73.1 % 229,578,418 190,367,869 82.9 %
Pesos 475,283,905 297,636,833 62.6 % 210,694,463 154,073,612 73.1 % 229,578,418 190,367,869 82.9 %
Dollars — — — % — — — % — — — %
Corporate Unsecured Loans 449,052,241 181,774,226 40.5 % 338,308,069 199,442,192 59.0 % 357,242,133 275,371,868 77.1 %
Pesos 449,052,241 181,774,226 40.5 % 338,308,069 199,442,192 59.0 % 357,242,133 275,371,868 77.1 %
Dollars — — — % — — — % — — — %
Credit Card Loans 358,909,835 100,237,249 27.9 % 230,878,989 64,934,866 28.1 % 299,249,966 120,330,555 40.2 %
Pesos 346,037,838 100,237,238 29.0 % 223,773,698 64,934,863 29.0 % 290,878,381 120,330,417 41.4 %
Dollars 12,871,997 11 — % 7,105,291 3 — % 8,371,585 138 — %
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Year ended December 31,
2025 2024 2023
Average Average Average
Average Interest Nominal Average Interest Nominal Average Interest Nominal
Balance Earned Rate Balance Earned Rate Balance Earned Rate
Receivables from Financial Leases 97,846,492 48,669,939 49.7 % 91,823,284 36,070,280 39.3 % 81,407,109 51,186,807 62.9 %
Pesos 96,568,105 48,630,661 50.4 % 88,471,858 35,574,383 40.2 % 74,242,662 50,155,268 67.6 %
Dollars 1,278,387 39,278 3.1 % 3,351,426 495,897 14.8 % 7,164,447 1,031,539 14.4 %
Total Loans excl. Foreign trade and U.S.$.loans 2,607,717,275 1,174,718,687 45.0 % 1,672,838,485 957,973,100 57.3 % 1,624,160,662 1,176,133,453 72.4 %
Pesos 2,586,807,340 1,174,236,112 45.4 % 1,658,972,649 957,374,602 57.7 % 1,606,732,781 1,175,024,296 73.1 %
Dollars 20,909,935 482,575 2.3 % 13,865,836 598,498 4.3 % 17,427,881 1,109,157 6.4 %
Foreign Trade Loans and U.S.$.loans 588,776,511 40,276,677 6.8 % 248,070,964 12,616,962 5.1 % 112,668,339 9,109,774 8.1 %
Pesos — — — % — — — % — — — %
Dollars 588,776,511 40,276,677 6.8 % 248,070,964 12,616,962 5.1 % 112,668,339 9,109,774 8.1 %
Total Loans 3,196,493,786 1,214,995,364 38.0 % 1,920,909,449 970,590,062 50.5 % 1,736,829,001 1,185,243,227 68.2 %
Pesos 2,586,807,340 1,174,236,112 45.4 % 1,658,972,649 957,374,602 57.7 % 1,606,732,781 1,175,024,296 73.1 %
Dollars 609,686,446 40,759,252 6.7 % 261,936,800 13,215,460 5.0 % 130,096,220 10,218,931 7.9 %
Repo transactions 1,288,985 499,619 38.8 % 575,154,804 567,069,976 98.6 % 794,436,940 638,800,470 80.4 %
Pesos 1,288,985 499,619 38.8 % 575,154,804 567,069,976 98.6 % 794,436,940 638,800,470 80.4 %
Dollars — — — % — — — % — — — %
Total Interest-Earning Assets 4,845,957,281 1,802,191,637 37.2 % 3,821,691,753 2,452,493,229 64.2 % 4,487,707,056 3,618,062,438 80.6 %
Pesos 3,984,849,575 1,692,592,073 42.5 % 3,454,885,659 2,405,071,246 69.6 % 4,154,017,185 3,439,946,471 82.8 %
Dollars 861,107,706 109,599,564 12.7 % 366,806,094 47,421,983 12.9 % 333,689,871 178,115,967 53.4 %
Year ended December 31,
2025 2024 2023
Average Average Average
Average Interest Nominal Average Interest Nominal Average Interest Nominal
Balance Earned Rate Balance Earned Rate Balance Earned Rate
Non Interest-Earning Assets
Cash and due from banks 1,455,505,368 808,960,092 580,473,724
Pesos 650,578,956 286,115,564 233,228,127
Dollars 804,926,412 522,844,528 347,245,597
Premises and equipment and miscellaneous and intangible assets and unallocated items 413,452,225 429,560,369 425,044,082
Pesos 413,452,225 429,560,369 425,044,082
Dollars — — —
Allowance for loan losses (126,951,028) (50,085,585) (70,853,766)
Pesos (122,394,476) (45,359,664) (64,793,396)
Dollars (4,556,552) (4,725,921) (6,060,370)
Other assets 353,615,866 290,062,906 453,325,831
Pesos 326,923,276 278,707,953 438,499,072
Dollars 26,692,590 11,354,953 14,826,759
Year ended December 31,
2025 2024 2023
Average Average Average
Average Interest Nominal Average Interest Nominal Average Interest Nominal
Balance Earned Rate Balance Earned Rate Balance Earned Rate
Total Non Interest-Earning Assets 2,095,622,431 1,478,497,782 1,387,989,871
Pesos 1,268,559,981 949,024,222 1,031,977,885
Dollars 827,062,450 529,473,560 356,011,986
Total Assets 6,941,579,712 5,300,189,535 5,875,696,927
Pesos 5,253,409,556 4,403,909,881 5,185,995,070
Dollars 1,688,170,156 896,279,654 689,701,857
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Year ended December 31,
2025 2024 2023
Average Average Average
Average Interest Nominal Average Interest Nominal Average Interest Nominal
Balance Paid Rate Balance Paid Rate Balance Paid Rate
(in thousands of Pesos)
LIABILITIES
Interest-Bearing Liabilities
Special Checking Accounts 1,907,507,711 309,784,773 16.2 % 1,382,380,437 512,059,715 37.0 % 1,534,095,272 1,073,754,083 70.0 %
Pesos 1,248,435,607 301,026,035 24.1 % 1,066,682,647 508,808,753 47.7 % 1,347,784,829 1,073,311,336 79.6 %
Dollars 659,072,104 8,758,738 1.3 % 315,697,790 3,250,962 1.0 % 186,310,443 442,747 0.2 %
Time Deposits 1,562,315,674 419,616,634 26.9 % 1,130,442,813 620,752,662 54.9 % 1,486,504,770 1,257,621,838 84.6 %
Pesos 1,141,322,973 406,961,642 35.7 % 1,033,238,164 619,262,312 59.9 % 1,445,611,697 1,257,441,628 87.0 %
Dollars 420,992,701 12,654,992 3.0 % 97,204,649 1,490,350 1.5 % 40,893,073 180,210 0.4 %
Borrowings from Other Financial Institutions and Unsub Negotiable Obligations 636,122,989 145,021,890 22.8 % 53,890,633 18,943,209 35.2 % 35,566,601 18,316,771 51.5 %
Pesos 378,878,418 129,682,953 34.2 % 25,929,912 17,346,794 66.9 % 19,756,190 16,813,349 85.1 %
Dollars 257,244,571 15,338,937 6.0 % 27,960,721 1,596,415 5.7 % 15,810,411 1,503,422 9.5 %
Subordinated Loans and Negotiable Obligations — — — % — — — % — — — %
Pesos — — — % — — — % — — — %
Dollars — — — % — — — % — — — %
Total Interest-Bearing Liabilities 4,105,946,374 874,423,297 21.3 % 2,566,713,883 1,151,755,586 44.9 % 3,056,166,643 2,349,692,692 76.9 %
Pesos 2,768,636,998 837,670,630 30.3 % 2,125,850,723 1,145,417,859 53.9 % 2,813,152,716 2,347,566,313 83.4 %
Dollars 1,337,309,376 36,752,667 2.7 % 440,863,160 6,337,727 1.4 % 243,013,927 2,126,379 0.9 %
Year ended December 31,
2025 2024 2023
Average Average Average
Average Interest Nominal Average Interest Nominal Average Interest Nominal
Balance Paid Rate Balance Paid Rate Balance Paid Rate
(in thousands of Pesos)
Low and Non-Interest Bearing Deposits 1,245,928,310 954,846,561 1,212,062,321
Savings Accounts 754,128,869 12,053,748 1.6 % 547,865,270 5,503,404 1.0 % 648,719,206 5,516,741 0.9 %
Pesos 352,135,408 9,979,086 2.8 % 297,236,833 5,435,950 1.8 % 449,346,757 5,467,770 1.2 %
Dollars 401,993,461 2,074,662 0.5 % 250,628,437 67,454 — % 199,372,449 48,971 — %
Checking Accounts 491,799,441 34,531,858 7.0 % 406,981,291 563,343,115
Pesos 476,461,911 34,531,858 7.2 % 385,604,635 538,160,153
Dollars 15,337,530 — — % 21,376,656 25,182,962
Other Liabilities 543,235,934 750,371,681 724,675,362
Pesos 499,860,188 612,153,764 683,134,170
Dollars 43,375,746 138,217,917 41,541,192
Non-Controlling Interest Result — — 3,711,592
Pesos — — 3,711,592
Dollars — — —
Stockholders’ equity 1,046,469,095 1,044,111,706 879,081,009
Pesos 1,046,469,095 1,044,111,706 879,081,009
Dollars — — —
Total Low and Non-Interest Bearing Deposits 2,835,633,339 2,749,329,948 2,819,530,284
Pesos 2,374,926,602 2,339,106,938 2,553,433,681
Dollars 460,706,737 410,223,010 266,096,603
Total Liabilities and Stockholders’ equity 6,941,579,713 5,316,043,831 5,875,696,927
Pesos 5,143,563,600 4,464,957,661 5,366,586,397
Dollars 1,798,016,113 851,086,170 509,110,530
Changes in Interest Income and Interest Expense; Volume and Rate Analysis
The following tables allocate, by currency of denomination, changes in our interest income and interest expense. The changes are segregated for each major category of interest-earning assets and interest-bearing liabilities into amounts attributable to changes in the average volume and changes in their respective nominal interest rates for the year ended December 31, 2025 compared to the year ended December 31, 2024, and for the year ended December 31, 2024 compared to the year ended December 31, 2023. We have calculated volume variances based on movements in average balances over the period and rate variance based on changes in interest rates on average interest-earning assets and average interest-bearing liabilities. We have allocated variances caused by changes in both volume and rate to volume. As stated above under “Presentation of Financial and Other Information,” we have prepared our audited consolidated financial statements for 2025, 2024 and 2023 under IFRS.
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Year ended December 31,
2025/2024 2024/2023
Increase (Decrease) Due to Changes in
Net
Volume Rate Net Change Volume Rate Change
(in thousands of Pesos)
ASSETS
Interest-Earning Assets
Investment Portfolio
Government and Corporate Securities 105,279,323 (428,230,822) (322,951,499) 514,070,097 (194,401,899) 319,668,198
Pesos 66,313,853 (422,872,587) (356,558,734) 546,195,037 (92,836,326) 453,358,711
Dollars 38,965,470 (5,358,235) 33,607,235 (32,124,940) (101,565,573) (133,690,513)
Securities Issued by the Central Bank 757,876 (5,942,914) (5,185,038) (2,770,381,692) 1,571,527,944 (1,198,853,748)
Pesos — (6,211,592) (6,211,592) (2,770,381,692) 1,571,527,944 (1,198,853,748)
Dollars 757,876 268,678 1,026,554 — — —
Total Investment Portfolio 106,037,199 (434,173,736) (328,136,537) (2,256,311,595) 1,377,126,045 (879,185,550)
Pesos 66,313,853 (429,084,179) (362,770,326) (2,224,186,655) 1,478,691,618 (745,495,037)
Dollars 39,723,346 (5,089,557) 34,633,789 (32,124,940) (101,565,573) (133,690,513)
Loans
Loans to the Financial Sector 20,504,845 766,512 21,271,357 2,007,107 (950,669) 1,056,438
Pesos 20,504,845 766,512 21,271,357 2,007,107 (950,460) 1,056,647
Dollars — — — — (209) (209)
Overdrafts 8,267,577 (8,838,566) (570,989) 32,069,855 (49,808,437) (17,738,582)
Pesos 8,267,577 (8,838,566) (570,989) 32,069,855 (49,808,437) (17,738,582)
Dollars — — — — — —
Promissory Notes 35,170,744 (12,490,769) 22,679,975 (6,706,248) (64,187,142) (70,893,390)
Pesos 34,949,291 (12,610,004) 22,339,287 (6,755,338) (64,163,379) (70,918,717)
Dollars 221,453 119,235 340,688 49,090 (23,763) 25,327
Mortgage loans 45,640,757 (118,642,118) (73,001,361) 19,468,186 (6,154,593) 13,313,593
Pesos 45,640,757 (118,642,118) (73,001,361) 19,468,186 (6,154,593) 13,313,593
Dollars — — — — — —
Automobile and Other Secured Loans 77,971,279 (5,401,971) 72,569,308 41,220,104 (2,382,366) 38,837,738
Pesos 77,971,279 (5,401,971) 72,569,308 41,220,104 (2,382,366) 38,837,738
Dollars — — — — — —
Personal Loans 165,693,731 (22,130,510) 143,563,221 (13,809,187) (22,485,070) (36,294,257)
Pesos 165,693,731 (22,130,510) 143,563,221 (13,809,187) (22,485,070) (36,294,257)
Dollars — — — — — —
Corporate Unsecured Loans 44,828,718 (62,496,684) (17,667,966) (11,162,167) (64,767,509) (75,929,676)
Pesos 44,828,718 (62,496,684) (17,667,966) (11,162,167) (64,767,509) (75,929,676)
Dollars — — — — — —
Credit Card Loans 35,416,420 (114,037) 35,302,383 (19,472,501) (35,923,188) (55,395,689)
Pesos 35,416,415 (114,040) 35,302,375 (19,472,500) (35,923,054) (55,395,554)
Dollars 5 3 8 (1) (134) (135)
Receivables from Financial Leases 4,013,490 8,586,169 12,599,659 5,157,338 (20,273,865) (15,116,527)
Pesos 4,077,183 8,979,095 13,056,278 5,721,535 (20,302,420) (14,580,885)
Dollars (63,693) (392,926) (456,619) (564,197) 28,555 (535,642)
Total Loans excl. Foreign trade and U.S.$.loans 437,507,561 (220,761,974) 216,745,587 48,772,487 (266,932,839) (218,160,352)
Pesos 437,349,796 (220,488,286) 216,861,510 49,287,595 (266,937,288) (217,649,693)
Dollars 157,765 (273,688) (115,923) (515,108) 4,449 (510,659)
Foreign Trade Loans and U.S.$.loans 23,306,785 4,352,930 27,659,715 6,886,617 (3,379,429) 3,507,188
Pesos — — — — — —
Dollars 23,306,785 4,352,930 27,659,715 6,886,617 (3,379,429) 3,507,188
Total Loans 460,814,346 (216,409,044) 244,405,302 55,659,104 (270,312,268) (214,653,164)
Pesos 437,349,796 (220,488,286) 216,861,510 49,287,595 (266,937,288) (217,649,693)
Dollars 23,464,550 4,079,242 27,543,792 6,371,509 (3,374,980) 2,996,529
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Year ended December 31,
2025/2024 2024/2023
Increase (Decrease) Due to Changes in
Volume Rate Net Change Volume Rate Net Change
(in thousands of Pesos)
Repo transactions (222,434,137) (344,136,220) (566,570,357) (216,199,734) 144,469,240 (71,730,494)
Pesos (222,434,137) (344,136,220) (566,570,357) (216,199,734) 144,469,240 (71,730,494)
Dollars — — — — — —
Total Interest-Earning Assets 238,380,209 (560,545,264) (322,165,055) (160,540,630) (125,843,028) (286,383,658)
Pesos 214,915,659 (564,624,506) (349,708,847) (166,912,139) (122,468,048) (289,380,187)
Dollars 23,464,550 4,079,242 27,543,792 6,371,509 (3,374,980) 2,996,529
LIABILITIES
Interest-Bearing Liabilities
Time Deposits 48,272,842 (249,408,870) (201,136,028) (246,289,118) (390,580,058) (636,869,176)
Pesos 38,539,811 (250,840,481) (212,300,670) (247,152,492) (391,026,824) (638,179,316)
Dollars 9,733,031 1,431,611 11,164,642 863,374 446,766 1,310,140
Special Checking Accounts 48,388,019 (250,662,961) (202,274,942) (132,753,647) (428,940,721) (561,694,368)
Pesos 43,824,746 (251,607,464) (207,782,718) (134,086,039) (430,416,544) (564,502,583)
Dollars 4,563,273 944,503 5,507,776 1,332,392 1,475,823 2,808,215
Borrowings from Other Financial Institutions and Unsub Negotiable Obligations 134,479,332 (8,400,651) 126,078,681 4,823,866 (4,197,428) 626,438
Pesos 120,807,632 (8,471,473) 112,336,159 4,130,145 (3,596,700) 533,445
Dollars 13,671,700 70,822 13,742,522 693,721 (600,728) 92,993
Subordinated Loans and Negotiable Obligations — — — — — —
Pesos — — — — — —
Dollars — — — — — —
Total Interest-Bearing Liabilities 231,140,193 (508,472,482) (277,332,289) (374,218,899) (823,718,207) (1,197,937,106)
Pesos 203,172,189 (510,919,418) (307,747,229) (377,108,386) (825,040,068) (1,202,148,454)
Dollars 27,968,004 2,446,936 30,414,940 2,889,487 1,321,861 4,211,348
Low and Non-Interest Bearing Deposits
Savings Accounts 2,336,943 4,213,401 6,550,344 (2,768,034) 2,754,697 (13,337)
Pesos 1,555,758 2,987,378 4,543,136 (2,781,829) 2,750,009 (31,820)
Dollars 781,185 1,226,023 2,007,208 13,795 4,688 18,483
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Interest-earning Assets: Net Interest Margin and Spread
The following table analyzes, by currency of denomination, our levels of average interest-earning assets and net interest income, and illustrates the comparative margins and spreads for each of the years indicated.
Year ended December 31,
2025 2024 2023
(in thousands of Pesos, except percentages)
Average interest-earning assets(1)(2)
Pesos 3,984,849,575 3,454,885,659 4,154,017,185
Dollars 861,107,706 366,806,094 333,689,871
Total 4,845,957,281 3,821,691,753 4,487,707,056
Net interest earned
Pesos 844,942,357 1,254,217,437 1,086,912,388
Dollars 70,772,235 41,016,802 175,940,617
Total 915,714,592 1,295,234,239 1,262,853,005
Net Interest Margin
Pesos 21.2 % 36.3 % 26.2 %
Dollars 8.2 % 11.2 % 52.7 %
Weighted average yield(3) 18.9 % 33.9 % 28.1 %
Yield Spread
Pesos 15.3 % 22.1 % 10.7 %
Dollars 10.5 % 12.0 % 52.9 %
Weighted interest spread(4) 18.9 % 27.0 % 17.1 %
Gross Yield
Pesos 42.5 % 69.6 % 82.8 %
Dollars 12.7 % 12.9 % 53.4 %
(1) Includes all loans, leasing agreements and investments (including public and private bonds and Central Bank notes) and other receivables from financial intermediation that earn interest.
(2) These figures represent daily averages.
(3) Takes into account the average interest earned on interest-earning assets and is weighted in accordance with the volume of each asset.
(4) Takes into account the average interest earned on interest-earning assets, net of average interest paid on interest-bearing liabilities.
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Investment Portfolio
We own, manage and trade a portfolio of securities issued by the Argentine government, the Central Bank, and other public sector and corporate issuers. The following table sets out our investments in Argentina and other governments and corporate securities, as of December 31, 2025 and 2024 by type and currency of denomination.
12/31/2025 12/31/2024
(in thousands of Pesos )
Debt Securities at fair value through profit or loss
LOCAL
Government securities
Letras tesoro vinc al U$S Vto.16/01/26 31,336,280 -
Letras tesoro vinc al U$S Vto.30/01/26 34,137,548 -
Letras tesoro Aj CER $ Vto.29/05/26 46,118,526 -
Letras tesoro Cap $ Vto.29/05/26 12,160,163 -
Bontes $ a Desc Aj CER Vto.15/12/26 14,140,619 5,033,798
Bono Nación $ Dual Vto 15/09/26 6,348,111 -
Títulos Discount Denominados $ 2033 5,830,823 212,368
Bono Tesoro Nac $ CER Vto 31/03/27 5,736,958 -
Bono Tesoro Nacional Cap $ Vto 30/04/27 9,942,140 -
Letras tesoro Cap $ Vto.17/04/26 6,148,691 -
Letras tesoro vinc al U$S Vto.16/01/26 385,946 -
Bontes $ a Desc Aj CER Vto.15/12/26 2,056 71,021
Bono Nación $ Dual Vto 15/09/26 4,623,624 12,662,250
Bono Tesoro Nacional Cap $ Vto 30/04/27 3,010,939 25,160,896
BONO REP ARG AJ CER V30/06/26 $ CG 3,470,489 2,125,081
Bono del Tesoro Boncer Vto 31/03/26 2,327,647 4,194,331
BONO PCIA BS AS REGS NEW U$S 2037 197 -
BONO REP ARG AJ CER V30/06/27 1,769 -
BONO NACION TASA DUAL16/03/26 $ 789,601 -
BONO NACION TASA DUAL 30/06/26 $ 636,054 -
BONO NACION TASA DUAL15/12/26 $ CG 94,358 -
BONO TESORO NAC CAP V.15/01/27 727 -
LETRAS DEL TESORO NACIONAL CAPITALIZABLES EN PESOSVto 16/01/2026 25,308 -
Letra Tesoro Nacional Capitalizable 30/04/26 $ 7,038,000 -
Letras Del Tesoro Cap $ V 30/10/2026 6,351,531 -
Letra Tesoro Nacional Capitalizable 27/02/26 206 -
BONO TESORO NACIONAL CAPITALIZABLE 31/05/27 4,911,218 -
Letra Tesoro Nacional Capitalizable 30/11/26 $ 1,503,458 -
GLOBAL REP. ARGENTINA USD STEP UP 2041 41,703 39,028
Others 15,789,071 255,673,954
Securities issued by the Central Bank
Bopreal S.1 B Vto.31/10/27 U$S - 596,988
Bopreal S.1 A Vto.31/10/27 U$S - 342,932
Bopreal S.1 D Vto.31/10/27 U$S - 123,152
Bopreal S.3 Vto.31/05/26 U$S - 133,829
Bopreal S.1 C Vto.31/10/27 U$S - 37,837
Bopreal S.1 C Vto.31/10/27 U$S - 122,980
BOPREAL S.3 VTO31/05/26 U$S 103 -
Corporate Securities
VDFF Individual Milaires UVA Vto 26/12/28 3,708,598 4,638,778
On Cia Gen.Comb U$S V28/02/26 722,157 630,451
On Capex CL.6 U$S Vto.07/09/26 693,500 -
On Pyme Sion CL13 Vto18/01/27 UVA 575,609 509,929
On P Argensun U$S Vto.14/12/26 370,809 479,306
On Petro. Aconcagua 18 $ Vto.25/08/30 344,450 -
On Capex Cl.7 U$S Vto 07/09/27 335,949 290,272
On Petro Aconcagua 20 $ Vto.25/08/32 208,859 -
On Luz Tres Picos 4 U$S 29/09/26 201,550 173,796
On Cresud Cl 40 U$S Vto 21/12/26 91,747 -
ON YPF Ener.Elec. C.12 V.29/08/26 U$S Cg 512 756
ON LOMA NEGRA Vto. 11/03/2026 24 26
ON LOMA NEGRA Vto. 21/12/2025 - 771
On Gemsa Cl 30 Uva Vt 08/03/2027 212,650 1,575,819
ON GEMSA XXVII UVA 189,813 -
ON TELECOM CL. 15 DLK 0% 02/06/26 704,775 -
Others 18,241,635 31,579,899
Total debt securities 249,506,501 346,410,248
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12/31/2025 12/31/2024
OTHER DEBT SECURITIES
Measure at fair value through changes in Other Comprehensive Income
LOCAL
Government securities
TD Mun. Cordoba $ Vto 13/02/27 497,750 -
TD P Muni Cba Gar 2024 S.1 $ Vto 09/09/26 219,454 282,579
Bono Rep. Argentina Usd Step Up 2030 11,958 28,957,171
LT Fiscal de Liquidez $ Vto 17/07/25 - 118,641,674
Bono Tesoro Nac $ Cap Vto 17/10/2025 - 142,256
Corporate Securities
On Msu SAS15 U$S Vto 16/04/29 7,005,200 -
On YPF Cl 39 U$S Vto 22/07/30 6,507,316 -
On Msu Green Energy Cl.3 U$S Vto.20/12/28 6,377,651 6,778,606
On Edemsa CL.1 UVA Vto.06/05/26 6,094,438 5,381,082
On Petro Aconcagua 21 U$S Vto 25/08/32 4,444,580 -
On Oiltanking Ebytem Vto 01/11/28 U$S 4,422,033 4,107,835
Vdff Mercado Crédito 42 $ Vto 15/09/26 4,334,502 -
On Cresud S31 Vto 15/11/28 U$S 4,234,347 4,106,684
Vdff Mercado Crédito 41 $ Vto 15/08/26 3,973,188 -
Vdff Mercado Crédito 38 $ Vto 15/06/26 3,025,200 -
On Gemsa Cl 30 Uva Vt 08/03/2027 957,126 -
ON SPI ENERGY SA CL.1 US$ V.27/06/2026 SPC10 360,100 -
Otros 42,852,588 105,419,883
On Edemsa Cl.7 18/12/26 $ 758,394 -
ON CA River plate 386,153 -
On Tarjeta Naranja Cl.66 S.1 30/11/2026 $ 1,031,627 -
ON RIZOBACTER S.10 CL.B V28/11 65,291 -
On Edemsa Cl.5 V12/05/26 $ Cg 1,050,949 -
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12/31/2025 12/31/2024
Measure at amortized cost
LOCAL
Government securities
Bontes $ a Desc Aj CER Vto.15/12/26 174,816,376 183,430,837
Letras tesoro tamar Cap $ Vto.16/01/26 152,844,528 -
Letras tesoro Cap $ TAMAR Vto.30/04/26 156,417,746 -
Letras tesoro Aj CER $ Vto.29/05/26 77,991,825 -
Bono Nación $ Dual Vto 15/09/26 36,858,945 -
Bono Nación $ Dual Vto 15/12/26 22,260,355 -
Bono Nación $ Dual Vto 16/03/26 22,252,914 -
Bono Rep Arg Aj CER $ Vto.30/06/28 7,339,174 13,845,499
Bono Rep. Arg. $ Vto.23/05/27 6,486,951 12,989,461
Bono Tesoro Nac $ CER Vto 31/03/27 9,715,979 1,496,430
Bontes $ a Desc Aj CER Vto.15/12/27 6,158,565 -
Bono Nación $ Dual Vto 30/06/26 9,813,547 -
BONO DEL TESORO NACIONAL EN PESOS CERO CUPÓN AJ CER VTO 30/10/2026 1,073,341 373,952
BONO DEL TESORO NACIONAL $ CERO CUPÓN CON AJ CER VTO 31/03/2026 1,399,622 8,417,266
BONO DEL TESORO NACIONAL CAP EN PESOS VTO 13/02/2026 611,628 599,977
BONO REP ARG AJ CER V30/06/26 $ CG 675,547 -
Others 16,799,742 572,798,561
Securities issued by the Central Bank
Bopreal S.1 C Vto.31/10/27 U$S 1,255,473 -
Bopreal S.1 B Vto.31/10/27 U$S 127,389 -
Bopreal S.1 D Vto.31/10/27 U$S 42,170 -
Corporate Securities
Pagaré U$S Mat.05/13/25 1,089,923 -
Pagaré U$S Mat.10/18/24 266,243 350,239
FF Red Surcos XXXIII - 666,197
Pagaré U$S Mat. 04/24/25 - 300,923
ON Msu CL 6 U$S Mat.11/02/24 - 267,162
Total other debt securities 804,907,828 1,069,354,274
Investments in equity instruments
Measured at fair value through profit and loss
LOCAL
A3 Mercados S.A. 4,294,797 -
Cedear SPDR Dow Jones Ind 3,606 3,261
Cedear SPDR S&P 3,448 3,041
Cedear Financial Select Sector 3,278 2,940
Cedear Ishares MSCI Brasil 1,145 830
Aluar SA - 4,129
Ternium Arg S.A.Ords."A"1 Voto Esc - 29,856
Holcim Arg - 14,273
Acciones Banco Galicia - 10,548
Measured at fair value through changes in Other Comprehensive Income
LOCAL
Others 1,399,669 (1) 866,079
Total investments in equity instruments 5,705,943 934,957
Total 1,060,120,272 1,416,699,479
(1) Includes an equity investment in Modo of Ps.99,170 thousand. The Bank owns 2.2651% of the shares of Modo, which is a company fully owned by most banks operating in Argentina. Modo is a standalone app or it can be embedded in the banking apps and is a strong player in the digital payment segment.
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The following table sets out the weighted average yield for each range of maturities, to debt securities that are not held at fair value:
Grupo Supervielle S.A.
As of December 31, 2025
After 5
After 1 year year
Debt securities that are not held at Within 1 through through After 10
fair value year 5 years 10 years years Total
Weighted average yield 10.2 % 14.9 % — — 10.5 %
The weighted average yield was calculated as the sum of each bond’s returns divided by the sum of each bond’s average holding considering their remaining maturity.
The following table sets out the aggregate book value of securities from a single issuer that exceeds 10% of Grupo Supervielle Shareholder’s equity:
%Shareholder´s
Single Issuer 12/31/2025 Equity
(in thousands of Pesos except percentages)
Argentine government(1) 927,149,708 94.10 %
Central Bank 1,425,135 0.14 %
928,574,843
(1) Includes Ps.610.1 billion of Treasury Bonds considered in the minimum reserve requirements.
Loans and other Financing
Our loan and other financing portfolio are included in Note 25 to our audited consolidated financial statements. Loans and The Other Financing of our audited consolidated financial statements.
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Maturity Composition of the Loan and Other Financing
The following table analyzes our loan and other financing as of December 31, 2025 by type and by the time remaining to maturity. Loans and other financings are stated before deduction of allowances for loan losses.
Grupo Supervielle S.A.
Maturing as of December 31, 2025
After 1 After 5
year year
Within 1 through through After 15
year 5 years 15 years years Total
(in thousands of Pesos except percentages)
Loans and other financing
To the non-financial public sector 8,604,827 130,615 — — 8,735,442
To the financial sector 322,300,302 10,185,436 — — 332,485,738
To the non-financial private sector and foreign residents:
Overdrafts 379,551,140 — — — 379,551,140
Promissory notes 619,625,746 186,135,159 — — 805,760,905
Mortgage loans 17,420 1,426,597 78,071,183 292,150,173 371,665,373
Automobile and other secured loans 64,134,194 217,381,228 190,030 — 281,705,452
Personal loans 108,906,187 367,130,179 15,240,791 247,403 491,524,560
Credit card loans 373,367,509 — — — 373,367,509
Foreign trade loans and U.S. dollar loans 653,467,289 106,500,464 5,398,528 — 765,366,281
Others 70,549,151 6,790,255 324,445 (363,180) 77,300,671
Receivables from financial leases 7,149,343 98,677,248 3,939,634 — 109,766,225
Total loans and other financing 2,607,673,108 994,357,181 103,164,611 292,034,396 3,997,229,296
Interest Rate Sensitivity
The following table analyzes the amount of our loan and other financing portfolio due after one year at fixed and variable interest rate. Loans and financings are stated before deduction of allowances for loan losses.
Grupo Supervielle S.A.
Amount due after one year at
Fixed Variable
interest rate interest rate Total
(in thousands of Pesos except percentages)
Loans and other financing
To the non-financial public sector — 130,615 130,615
To the financial sector 10,185,436 — 10,185,436
To the non-financial private sector and foreign residents:
Overdrafts
Promissory notes 67,562,820 118,572,339 186,135,159
Mortgage loans 220,077,837 151,570,116 371,647,953
Automobile and other secured loans 149,875,195 67,696,063 217,571,258
Personal loans 382,146,936 471,437 382,618,373
Credit card loans — — —
Foreign trade loans and U.S. dollar loans 111,898,992 — 111,898,992
Others 6,751,521 — 6,751,521
Receivables from financial leases 74,257,551 28,359,331 102,616,882
Total loans and other financing 1,022,756,288 366,799,901 1,389,556,189
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Amounts Past Due Loans and Other Financing
The following table analyzes amounts past due in our loan and other financing portfolio, by type of loan and other financing as of the dates indicated. The past due loans listed in the table below include loans of the Bank.
Grupo Supervielle S.A.
Year ended December 31,
2025 2024 2023
(in thousands of Pesos except percentages)
Past Due
Loans and other Financing
To the non-financial private sector and foreign residents
Overdrafts 16,070,485 2,138,161 3,391,335
Promissory notes 32,776,940 2,015,552 2,123,206
Mortgage loans 3,166,717 709,683 2,230,705
Automobile and other secured loans 36,756,573 8,025,537 997,636
Personal loans 77,310,497 25,537,681 10,974,611
Credit card loans 43,313,732 12,446,514 11,966,162
Foreign trade loans 5,732,289 4,618,265 7,472,555
Other loans 12,551,288 8,122,640 9,319,650
Receivables from financial leases 3,773,019 1,335,583 1,508,990
Total Past Due Loans and other financing 231,451,540 64,949,616 49,984,850
Past Due Financings
With Preferred Guarantees 41,215,739 10,395,783 4,753,847
Without Guarantees 190,235,801 54,553,833 45,231,003
Total Past Due Financings 231,451,540 64,949,616 49,984,850
Analysis of the Allowance for Loan Losses
The analysis of the allowances for loan losses are included in Note 1.11 and Note 25 to our audited consolidated financial statements. See “Item 5.E. Critical Accounting Estimates—Allowances for Loan Losses.”
The following table analyses the ratio of allowances for loans losses to total loans:
Grupo Supervielle S.A.
Year ended December 31,
2025 2024 2023
(in thousands of Pesos except percentages)
Allowances for loan losses 231,751,070 64,949,614 49,984,847
Loans and other financing 3,997,229,296 2,919,660,541 1,432,051,505
Allowances as a percentage of Loans 5.80 % 2.22 % 3.49 %
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The following table analyzes the ratio of net charge-offs to average loans, disclosed by loan category.
Grupo Supervielle S.A.
As of December 31,
2025 2024 2023
Write-offs Net Charge- Write-offs Net Charge- Write-offs Net Charge-
and offs/average and offs/average and offs/average
Average reversals loans Average reversals loans Average reversals loans
(in thousands of Pesos except percentages)
Loans:
Promissory notes 321,943,237 (330,688) (0.10) % 242,400,094 (86,195) (0.04) % 253,985,762 (133,452) (0.05) %
Unsecured corporate loans 449,052,241 (11,161,958) (2.49) % 338,308,069 (3,175,286) (0.94) % 357,242,133 (7,222,702) (2.02) %
Overdrafts 207,709,155 (1,659,013) (0.80) % 191,962,908 (324,848) (0.17) % 135,717,706 (613,196) (0.45) %
Mortgage loans 363,050,668 — — % 223,750,157 (1,377,901) (0.62) % 201,056,953 (2,102,204) (1.05) %
Automobile and other secured loans 278,589,049 (6,014,894) (2.16) % 131,251,133 (421,544) (0.32) % 58,980,537 (2,326,137) (3.94) %
Personal loans 475,283,905 (20,599,896) (4.33) % 210,694,463 (5,375,841) (2.55) % 229,578,418 (17,831,775) (7.77) %
Credit card loans 358,909,834 (15,545,343) (4.33) % 230,878,989 (5,343,145) (2.31) % 299,249,966 (14,483,605) (4.84) %
Foreign Trade Loans 588,776,511 — — % 248,070,964 — — % 112,668,339 — — %
Loans to the Financial Sector 55,332,693 — — 11,769,388 — — 6,942,078 — —
Receivables from financial leases 97,846,493 (47,245) (0.05) % 91,823,284 (111,468) (0.12) % 81,407,109 (71,735) (0.09) %
Total 3,196,493,786 (55,359,037) (1.73) % 1,920,909,449 (16,216,228) (0.84) % 1,736,829,001 (44,784,806) (2.58) %
Allocation of the Allowance for Loan Losses and Other Financing
The allocation of allowances for loan and other financing losses by category of loans are included in Note 1.11 and Note 25 to our audited consolidated financial statements. See “Item 5.E. Critical Accounting Estimates—Allowances for Loan Losses.”
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Loans and Other Financing Portfolio by Economic Activity
The table below analyzes our loan and other financing portfolio according to the borrower’s main economic activity as of December 31, 2025, 2024 and 2023.
Grupo Supervielle S.A.
As of December 31,
2025 2024 2023
% of % of % of
Loan Loan Loan Loan Loan Loan
Portfolio Portfolio Portfolio Portfolio Portfolio Portfolio
(in thousands of Pesos, except percentages)
Oils and oilseeds 5,050,240 — % 7,948,531 0.3 % 4,774,670 0.3 %
Agriculture, crops and fruit 252,910,733 6.3 % 153,503,355 5.3 % 93,520,557 6.5 %
Manufactured foodstuff, cattle beef 142,777,636 3.6 % 90,694,013 3.1 % 51,385,528 3.6 %
Household items, sales / Trading 14,005,521 0.4 % 5,888,070 0.2 % 2,074,783 0.1 %
Automotive vehicles and car parts 66,424,108 1.7 % 44,121,850 1.5 % 45,090,540 3.1 %
Sugar 16,139,387 0.4 % 13,801,249 0.5 % 16,585,057 1.2 %
Foreign and local banks 128,292 — % 423,457 — % 615,967 — %
Alcoholic beverages 482,517 0.0 % 15,781,227 0.5 % 2,647,028 0.2 %
Civil construction 45,136,247 1.1 % 36,767,202 1.3 % 18,568,183 1.3 %
Road works and specialized construction 115,715,746 2.9 % 75,487,383 2.6 % 52,627,197 3.7 %
Cooperatives and small financial institutions 463,494,529 11.6 % 168,731,754 5.8 % 63,637,055 4.4 %
Private and public mail services 1,663,430 — % 1,704,686 — % 186,403 — %
Cattle raising 66,789,862 1.7 % 47,526,491 1.6 % 32,253,818 2.3 %
Leather 1,165,339 0.0 % 1,142,929 — % 909,258 0.1 %
Electricity and gas distribution 59,894,618 1.5 % 51,731,459 1.8 % 39,737,408 2.8 %
Home appliances, audio and video devices, production and importation 31,615,918 0.8 % 11,003,883 0.4 % 10,877,617 0.8 %
Hydrocarbon extraction and production 36,282,155 0.9 % 34,447,871 1.2 % 4,550,127 0.3 %
Families and individuals(1) 1,579,007,678 39.5 % 1,411,411,904 48.3 % 578,335,665 40.4 %
Hypermarkets and supermarkets 8,193,086 0.2 % 9,089,525 0.3 % 11,198,120 0.8 %
Machines and tools – Production, sale and/or lease 100,155,152 2.5 % 42,045,285 1.4 % 18,845,627 1.3 %
Motorcycles, parts and accessories 3,349,216 0.1 % 107,375 — % 2,616,500 — %
Paper and cardboard 20,859,713 0.5 % 14,952,787 0.5 % 5,620,814 0.4 %
Plastic - Manufactures 26,147,282 0.7 % 15,895,781 0.5 % 7,236,341 0.5 %
Metal products 20,033,026 0.5 % 44,115,165 1.5 % 10,079,957 0.7 %
Pharmaceutical products and laboratories 41,340,891 1.0 % 18,368,392 0.6 % 13,625,732 1.0 %
Chemical products 73,804,287 1.8 % 53,481,606 1.8 % 17,136,057 1.2 %
Waste collection and recycling 24,199,046 0.6 % 29,939,682 1.0 % 29,463,448 2.1 %
Corporate services 46,302,696 1.2 % 20,327,001 0.7 % 28,355,260 2.0 %
Health services 38,238,531 1.0 % 22,747,976 0.8 % 17,940,815 1.3 %
Mineral extraction and production 79,301,178 2.0 % 106,034,676 3.6 % 24,026,264 1.7 %
Telecommunications 50,587,282 1.3 % 5,671,667 0.2 % 7,688,400 0.5 %
Textile industry 89,230,601 2.2 % 79,303,320 2.7 % 56,179,725 3.9 %
Cargo transportation 121,112,734 3.0 % 79,989,793 2.7 % 32,120,060 2.2 %
Wine industry 116,691,344 2.9 % 80,499,145 2.8 % 66,974,225 4.7 %
Real estate agencies 2,710,233 0.1 % 2,083,782 0.1 % 3,260,302 0.2 %
Other(2) 236,289,042 5.9 % 122,890,269 4.2 % 61,306,998 4.3 %
Total 3,997,229,296 100.0 % 2,919,660,541 100.0 % 1,432,051,506 100.0 %
(1)Loans for personal consumption.
(2)Includes all other industries. None of such industries exceeds 1% of the total loan and other financing portfolio.
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Composition of Deposits
The following table sets out the composition of each category of deposits by currency of denomination that exceeded 10% of average total deposits at December 31, 2025, 2024 and 2023.
Grupo Supervielle S.A.
As of December 31,
2025 2024 2023
Average Average Average
Average nominal Average nominal Average nominal
balance rate balance rate balance rate
(in thousands of Pesos, except percentages)
Deposits in domestic bank offices by local depositors
Non-interest-bearing current accounts
Average
Pesos 476,461,683 — % 385,613,823 — % 394,438,295 — %
Dollars 15,337,530 — % 21,377,166 — % 18,457,278 — %
Total 491,799,213 — % 406,990,989 — % 412,895,573 — %
Grupo Supervielle S.A.
As of December 31,
2025 2024 2023
Average Average Average
Average nominal Average nominal Average nominal
balance rate balance rate balance rate
(in thousands of Pesos except percentages)
Savings accounts
Average
Pesos 352,115,651 2.9 % 297,297,494 1.8 % 329,524,461 1.9 %
Dollars 401,887,837 — % 250,570,339 0 % 146,080,383 0 %
Total 754,003,488 1.6 % 547,867,833 1.0 % 475,604,844 1.3 %
Special checking accounts
Average
Pesos 1,248,435,607 24.1 % 1,067,873,381 47.6 % 988,620,547 109.7 %
Dollars 659,072,104 1.3 % 315,705,313 1.0 % 136,551,986 0.3 %
Total 1,907,507,711 16.2 % 1,383,578,694 37.0 % 1,125,172,533 96.5 %
Time deposits
Average
Pesos 1,141,312,246 35.7 % 1,033,244,396 59.9 % 1,059,496,212 118.8 %
Dollars 420,982,773 3.01 % 97,204,878 1.53 % 29,971,644 0.60 %
Total 1,562,295,019 26.9 % 1,130,449,274 54.9 % 1,089,467,856 115.5 %
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Grupo Supervielle S.A.
As of December 31,
2025 2024 2023
Average Average Average
Average nominal Average nominal Average nominal
balance rate balance rate balance rate
(in thousands of Pesos, except percentages)
Deposits in domestic bank offices by foreign depositors
Non-interest-bearing current accounts
Average
Pesos 228 4 —
Dollars — — —
Total 228 4 —
Savings accounts
Average
Pesos 19,757 22,708 27,340
Dollars 105,624 64,071 45,101
Total 125,381 86,779 72,441
Time deposits
Average
Pesos 10,727 18,393 31,878
Dollars 9,928 2,088 —
Total 20,655 20,481 31,878
2025 2024 2023
(in thousands of Pesos)
Uninsured deposits 4,015,635,379 3,188,182,241 3,580,490,594
Maturity of Deposits
The following table sets forth information regarding the maturity of our time deposits exceeding the SEDESA insurance limit at December 31, 2025.
Grupo Supervielle S.A.
As of December 31,
2025
(in thousands of Pesos)
Time Deposits
3 months or less; 1,288,695,652
Over 3 months through 6 months; 49,692,554
Over 6 months through 12 months; 52,479,430
Over 12 months 4,195,513
Total Time Deposits(1) 1,395,063,149
(1)Only principal. Excludes the CER and UVA adjustment.
Law No. 24485 and Decree No. 540/95 established the creation of the Deposit Insurance System to cover the risk attached to bank deposits, in addition to the system of privileges and safeguards envisaged in the Financial Institutions Law.
The maximum amount for this insurance system to demand deposits and time deposits denominated either in Pesos and/or in foreign currency was set at Ps.1,000,000 as from March 1, 2019 and increased to Ps.1,500,000 as of May 1, 2020. However, pursuant to Communication “A” 7661, the Central Bank raised the amount covered by the Deposit Insurance System to Ps.6,000,000. Pursuant to Communication “A” 7985, the Central Bank raised the amount covered by the Deposit Insurance System to Ps.25,000,000 effective April 1, 2024. Pursuant to Communication "A" 8407, the Central Bank raised the amount covered by the Deposit Insurance System to Ps.50,000,000 effective April 1, 2026.
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This system does not cover deposits made by other financial institutions (including time deposit certificates acquired through a secondary transaction), deposits made by parties related to Banco Supervielle S.A., either directly or indirectly, deposits of securities, acceptances or guarantees and those deposits set up at an interest rate exceeding the one established regularly by the Argentine Central Bank.
Short-term Borrowings
The table below shows our short-term borrowings as of the dates indicated.
Grupo Supervielle S.A.
As of December 31,
2025 2024 2023
Annualized Annualized Annualized
Amount Rate Amount Rate Amount Rate
(in thousands of Pesos, except percentages)
International banks and Institutions:
Total amount outstanding at the end of the reported period 371,944,377 6.7 % 23,043,360 6.4 % 732,767 10.8 %
Average during period 114,148,309 1.6 % 16,690,451 9.1 % 7,546,553 18.8 %
Maximum monthly average 380,227,657 39,588,646 13,997,473
Financing received from Argentine financial institutions:
Total amount outstanding at the end of the reported period 109,151,786 45.4 % 28,533,446 43.8 % 7,281,777 42.3 %
Average during period 53,085,164 38.1 % 7,076,400 58.3 % 8,541,671 65.2 %
Maximum monthly average 119,611,688 21,340,616 9,614,764
Other(1)
Total amount outstanding at the end of the reported period 228,989,181 — % 232,662,483 — % 192,247,918 — %
Average during year 187,307,179 — % 146,623,264 — % 99,623,578 — %
Maximum monthly average 225,883,832 214,986,430 167,523,860
Unsubordinated Corporate Bonds
Total amount outstanding at the end of the reported period 170,810,132 18.2 % 65,446,444 — % — — %
Average during year 231,988,788 23.4 % 17,824,748 34.0 % 122,251 72.6 %
Maximum monthly average 349,911,358 66,326,354 1,467,012
(1)Includes mainly collections and other transactions on behalf of third parties, miscellaneous (payment orders abroad) and social security payment orders pending settlement.
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Return on Equity and Assets
The following table presents certain selected financial information and ratios for the dates indicated.
Grupo Supervielle S.A.
As of December 31,
2025 2024 2023
(in thousands of Pesos, except percentages)
Net Income for the year attributable to owners of the parent company (37,571,322) 137,459,742 147,861,490
Average total assets(1) 6,941,579,715 5,316,043,832 5,875,696,924
Average shareholders’ equity 1,046,469,095 879,081,009 863,814,739
Shareholders’ equity at the end of the period attributable to owners of the parent company 985,313,918 1,049,410,954 977,928,230
Net income as a percentage of:
Average total assets (0.5) % 2.6 % 2.5 %
Average shareholders’ equity (3.6) % 15.6 % 17.1 %
Declared cash dividends (2) — 32,881,326 36,784,395
Dividend payout ratio(3) — % 23.9 % 24.9 %
Average shareholders’ equity as a percentage of average total assets 15.1 % 16.5 % 14.7 %
(1) Calculated on a daily basis.
(2) No cash dividends were recommended to pay for the year ended December 31, 2025.
(3) Calculated by dividing dividend paid in the year by net income for the year attributable to owners of the parent company under IFRS. As mentioned in Note 24 to our audited consolidated financial statements, dividends are paid based on distributable retained earnings calculated in accordance with the rules of the Argentine Central Bank.
Minimum Capital Requirements
Our main subsidiary, the Bank, is required to satisfy minimum capital requirements. The following table sets forth the Bank consolidated minimum capital requirements set by the Superintendency as of the dates indicated.
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As stated above under “Presentation of Financial and Other Information,” we have prepared our audited consolidated financial statements for 2025, 2024 and 2023 under IFRS. Minimum capital requirements have been prepared in accordance with the rules of the Argentine Central Bank, which is not comparable to data prepared under IFRS.
Year ended December 31,
2025 2024 (3) 2023 (3) (4)
(in thousands of Pesos, except percentages)
Calculation of excess capital:
Allocated to assets at risk 304,501,175 240,732,301 148,742,119
Allocated to Bank premises and equipment, intangible assets and equity investment assets 27,913,213 31,208,043 30,532,024
Market risk 16,852,852 22,794,035 8,529,904
Public sector and securities in investment account 928,905 703,052 779,764
Operational Risk 45,771,893 97,959,978 67,124,101
Required minimum capital under Central Bank regulations 395,968,038 393,397,409 255,707,912
Basic net worth 1,103,547,123 1,084,581,259 963,815,112
Complementary net worth — — —
Deductions (358,337,148) (307,588,949) (292,328,570)
Total capital under Central Bank regulations 745,209,975 776,992,310 671,486,542
Excess capital 349,241,937 383,594,901 415,778,630
Credit Risk Weighted Assets (1) 4,026,186,872 3,364,520,068 2,200,613,815
Risk Weighted Assets (1) 4,828,237,638 4,818,204,223 3,130,795,301
Selected capital and liquidity ratios:
Regulatory capital/credit risk weighted assets 18.5 % 23.1 % 30.5 %
Regulatory capital/risk weighted assets 15.4 % 16.1 % 21.4 %
Average shareholders’ equity as a percentage of average total assets 12.8 % 17.8 % 14.5 %
Total liabilities as a multiple of total shareholders’ equity 8.7x 5.4x 6.3x
Cash as a percentage of total deposits 28.9 % 20.2 % 14.4 %
Liquid assets as a percentage of total deposits(2) 48.2 % 55.6 % 83.1 %
Common Equity Tier 1 Capital (CET1) / Risk weighted assets 15.4 % 16.1 % 21.4 %
(1) Risk Weighted Assets includes operational risk weighted assets, market risk weighted assets, and credit risk weighted assets, Operational risk weighted assets and market risk weighted assets are calculated by multiplying their respective required minimum capital under Central Bank rules by 12.5, Credit Risk Weighted Assets is calculated by applying the respective credit risk weights to our assets, following Central Bank rules.
(2) Liquid assets include cash, government securities, government securities in guarantee, securities issued by the Central Bank, repo transactions with the Central Bank and call operations.
(3) Values adjusted for inflation.
(4) Amounts corresponding to applying Communication “A” 8009 retrospectively for comparative purposes.
As of December 31, 2025, the Bank’s total capital ratio was 15.4%, compared to 16.1% as of December 31, 2024, and the Bank’s common equity Tier 1 ratio was 15.4%, compared to 16.1% as of December 31, 2024. On June 28, 2019, the Central Bank issued a ruling, effective January 1, 2020, requiring Group “A” financial institutions controlled by non-financial institutions (such as the Company and the Bank) to comply with Minimum Capital requirements, Major Exposure to Credit Risk regulations, Liquidity Coverage Ratio and Net Stable Funding Ratio. These requirements apply on a consolidated basis, including the non-financial holding and all its subsidiaries (excluding insurance companies and non-financial subsidiaries). On March 21, 2024, the Central Bank introduced Communication “A” 7982, requiring financial institutions to submit monthly consolidated reports starting April 2024, covering the non-financial holding and all its subsidiaries (excluding insurance companies).
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Item 5. Operating and Financial Review and Prospects