Information Regime for Debtors of the Financial System (IR – DSF) Providers of credit services between individuals through platforms

Requirements

What do I have to take into account when filing the Financial System Debtors Information Regime (RI-DSF)?

Submissions must comply with the provisions of Section 1, General Provisions for the Submission of Information to the BCRA.

Regulations

Where can I obtain the regulations to take into account when submitting the RI-DSF?

You can find it on this website at Sistema Financiero | Legal and Regulatory Framework | Ordinances and summaries.

Ordered texts and other related instructions

–Ordered text Providers of credit services between individuals through platforms- Point 1.7.

–Monthly Accounting Information Regime – Debtors of the Financial System (Rules of Procedure, Sections A and B).

– Submission of information to the BCRA – Section 1 – General provisions.

–Submission of information to the BCRA – Section 75 – Debtors of the Financial System – Providers of credit services between individuals through platforms.

– Submission of information to the BCRA – Section 61 – Debtors of the Financial System – Partial Amendments.

–Information Centers – Section 4 – Central of Debtors of the Financial System.

– Ordered text of the rules on “Classification of debtors”. The criteria applicable to the “consumption or housing” portfolio and the provisions provided for in point 7.3 must be observed. of Section 7. of the aforementioned law (mandatory recategorization).

-ARCA Register: it can be downloaded from the www3 site, exclusively for entities.

Financing

What is the scope of PSCPP?

The PSCPPs registered in the “Registry of Credit Service Providers between Individuals through Platforms” are those legal entities that offer – as a main or ancillary activity of their corporate purpose – the service of bringing one or more offerors into contact with credit seekers to carry out loan operations in pesos. As established in point 1.1. of the Ordered Text of the Rules on “Providers of credit services between individuals through platforms”.

Amounts

From what minimum amount of debt must be reported?

From $25 thousand per debtor, from the information corresponding to July 2024 (from $1 thousand per debtor to the information corresponding to June 2024 inclusive).

How should I express the amounts to be reported?

The amounts will be expressed in thousands of pesos without decimals. For those debts greater than the minimum amount, the values will be increased by one unit when the first digit of the fractions is equal to or greater than 5, discarding those that are lower.

For example, if the debt amount is $25,300, the “Total debt” field in the file must be reported PSCPP.TXT equal to 25. Debtors of the Financial System the last presentation made?

It may be due to the fact that an update of the Financial System Debtors’ Central has not yet been generated or that the presentation made by the entity has been rejected for not having passed the monitoring instance or for not having validated the IR.

Presentation

Instances for validation

1. Submission and Registration: The information contained in the ZIP file will be sent through the file transfer service. Once the file is received by the BCRA, an e-mail will be sent to the declared email account, indicating that the upload was completed correctly.

2. Follow-up: it will be available through the option “Follow-up Consultation of Presentations”. The submission of the ZIP file will be verified in its integrity and format. If it does not comply with the request, the filing will not be registered with the BCRA and the entity must make it again.

3. Validation: it will be available in “Consultation of Information Submitted” and the validation receipt or the list of errors can be downloaded.

What is the first mandatory period to file the RI-DSF?

The registration date will be the date of registration on the website of the Customs Collection and Control Agency (ARCA) through Clave Fiscal.

The first mandatory presentation is that of the month of your registration.

For example, if the registration was made on April 20, 2022, the information regime corresponding to April 2022 must be entered for the first time, whose presentation expires on the tenth business day of the following month.

How do I process the registration?

The PSCPP included must be registered in the Registry of “Providers of credit services between individuals through platforms” enabled by the Superintendence of Financial and Exchange Entities (SEFyC). They must enter the website of the Customs Collection and Control Agency (ARCA) using the tax code of the legal entity that makes the registration.

When is the deadline for submission?

The tenth business day of the month following the reported period. In the event of an extension of the expiration of a particular period, a Communication will be issued in this regard.

How is the monthly filing done?

The submission must be made via the web, through the file transfer service in www3 (MFT).

Find a step-by-step guide and tutorial videos for charging via MFT.

Load

What is the regime code and requirement of the DSF R.I. – Providers of credit services between individuals through platforms?

The regime code is 2 and the one corresponding to the requirement is 8.

What do I do if it does not allow me to fill in the fields in the record prior to uploading the information within the file transfer service in www3 (MFT)?

To load the fields, the use of Internet Explorer 10 or higher and have the compatibility view enabled must be considered.

After completing the fields in the “DETALLE.XML” Descriptor and selecting the files that correspond to each information regime (R.I.) declared as “Opera”, when consulting the status of each request presented, the result is that the uploaded file is not found.

To complete the “File Folder/Path” field, you must specify a certain value whenever you need to report more than one period for the same RI presentation. The name entered in “File Folder/Path”, has to be created as a folder within the ZIP file -which will be created later- and copy into this folder (created in the ZIP) the files that make up the IR presentation.

For example, the folder name can be “202204” and then make sure to create it within the ZIP. Always the DETALLE.XML Descriptor is stored in the ZIP in its root directory and not inside any other folder.

If it is not necessary to report more than one period in the same I.R. submission, no value needs to be entered in the “File folder/Path” data. That way no folder will be created inside the ZIP and the files that make up the presentation will be “copied” to the same root directory where the Descriptor (DETALLE.XML) is stored in the ZIP.

Do I have to enter the RI-DSF if I do not have data to report in a certain period?

Yes, the RI-DSF must be entered monthly.

If you do not have data, you must complete the opera=false option within the “DETALLE.XML.

Tracking

How should I proceed after uploading information?

When uploading the information, you will receive an email with the “Confirmation of upload of information submission to the BCRA” similar to the following:

Your file has been saved in the “XXXXX” folder

Name: XXXXX.zip

Nro. Follow-up : XXXXXXXX

Original Size: XXX bytes

For the purposes of non-repudiation, it has been confirmed that the file received is IDENTICAL to the file uploaded.

Use the following URL and your username/password to track the uploaded presentation. If there is no data when entering the address, please wait a few moments until the information is updated .

(https://www3.bcra.gob.ar/ConsultaPresentacionesMFT/detalle/XXXXX ).

You must enter the detailed address and check if the presentation was accepted or rejected because it registered an error and did not pass the first instance of control. In the latter case, the information must be resubmitted.

This email does not imply that the submission is accepted or validated, but that it must always be followed up.

How do I follow up on the submissions made?

Once the submission of the “ZIP file” has been sent by the File Transfer Service, it must be tracked using the “Submission Tracking Query” option on the www3 website.

There, by clicking on “Details” and “Information”, you will be able to consult all the presentations made or each one individually by the “Tracking Number” assigned.

In the “Information” option, you will be able to view for each IR the status of acceptance or rejection of the follow-up, after applying the controls specified in Section 1 of Reporting to the BCRA.

Validation

How do I check the validation result of the information submitted?

Once the status is accepted in the monitoring instance, and after the information has been processed, the result of the validation process will be available on the secure site www3, where you must enter with your username and password and once logged in you must select the option “Consultation of information presented” and choose the corresponding Regime/Requirement and the desired period in “Information date”.

In all cases, precedence is controlled. When submitting the information corresponding to a period, it will be verified that the immediately preceding period is validated. Otherwise, the new submissions will remain pending processing.

Why is the validation voucher not available in “Filing Follow-Up Consultation”?

Because only the receipts of the last submissions made are available, in accordance with the periodicity of the regime in question and its date of submission (point 1.2.4.1. of Section 1 of Submission of Information to the Central Bank). The BCRA considers that its responsibility has been fulfilled from the moment the results of the validation processes are available on the secure site.

Recategorization

How do I carry out the mandatory recategorization?

The recategorization is carried out in accordance with the provisions of point 7.3 of the Ordered Text of the Rules on the Classification of Debtors:

– The debtor must be recategorized when there is a discrepancy of more than one level between the classification given by the financial institution and those granted by at least two other financial entities or trusts or non-financial entities issuing credit cards in the “closed system” modality in categories lower than the one assigned by the financial institution. whose debts – together – represent 40% or more of the total reported by all creditors, according to the latest information available in the “Central of debtors of the financial system”.

-The recategorization of the debtor will be carried out as of the month following the month in which the relevant information is made available from said center, at least in the category immediately above the one in which it registers the highest level of indebtedness, considering, for this purpose, that set of entities, financial trusts and non-financial entities issuing credit cards in the “closed system” modality that represent at least 40% of the total reported by all creditors according to the latest information available in the “Central of debtors of the financial system”.

-To this end, the classifications made according to the evaluation of the entities, i.e. categories 1 to 5, will be taken into account.

Examples:

1) The debtor is in situation 2 in the Other Non-Financial Credit Provider A that is going to analyze whether its recategorization is appropriate.

The latest information available in the Central Bank of Debtors of the Financial System is:

– Other Non-Financial Credit Provider (PO) A $12 situation 2.

– Financial Institution (FI) B $9 situation 1.

– Financial Institution (FI) C $5 situation 5.

– Financial Trust (FF) D $7 situation 4.

– Non-financial credit card issuing company (TC) E $4 situation 3.

– SGR/FGCP F $8 situation 4.

– Other Non-Financial Credit Provider (PO) G $13 situation 5.

– Provider of credit services between individuals through platforms (PSCPP) H $14 situation 4.

The debtor must be recategorized because:

– There is a discrepancy of more than one level between the classification in the Other Non-Financial Credit Provider A (situation 2) and those granted by at least two other FIs or FFs or TCs in categories lower than the one assigned by the former (in this case there would be three entities: EF C situation 5 and FF D situation 4, the OPs, the SGR/FGCP and the PSCPPs should not be considered given the normative provisions and the TC because they do not have more than one level of discrepancy) and their claims together (EF C $5 + FF D $7 = $12) represent more than 40% of the total reported by all creditors (EF B $9 +EF C $5 + FF D $7 + TC E $4 = $25, 40% of 25 would be $10). Therefore, $12 is greater than $10 and the debtor must be recategorized.

– In the following month, the debtor must be informed in at least situation 3, because he registers greater indebtedness in FF D $7, who categorized him in situation 4.

2) The debtor is in situation 2 in the non-financial company issuing credit cards A, which will analyze whether it is appropriate to recategorize it.

The latest information available in the Central Bank of Debtors of the Financial System is:

– Non-financial credit card issuing company (TC) A $13 situation 2.

– Financial Institution (FI) B $5 situation 5.

– Financial Trust (FF) C $7 situation 4.

– SGR/FGCP D $8 situation 4.-Other Non-Financial Credit Provider (PO) E $15 situation 5.

– Provider of credit services between individuals through platforms (PSCPP) F$14 situation 4.

The debtor must be recategorized because:

– There is a discrepancy of more than one level between the classification in the Non-Financial Credit Card Issuing Company A (situation 2) and those granted by at least two other EFs or FFs or TCs in categories lower than the one assigned by the former (in this case they would be two entities: EF B situation 5 and FF C situation 4, the OPs, the SGR/FGCP and the PSCPPs should not be considered given the normative provisions) and their claims together (EF B $5 + FF C $7 = $12) represent more than 40% of the total reported by all creditors (TC A $13 + EF B $5 + FF C $7 = $25, 40% of 25 would be $10). Therefore, $12 is greater than $10 and the debtor must be recategorized.

– In the following month, the debtor must be informed in at least situation 3, because he or she registers greater indebtedness in FF C $7, who categorized him or her in situation 4.

Most frequent errors and queries

What is the cause of error 03 “Wrong or early date”?

The error arises from having reported a non-existent date (for example, 202213), because it contains non-numeric characters; or the information corresponds to a period not enabled for processing; or does not correspond to the last day of the month of the information presented; or the filing date is prior to the first day of the month following the month to which the information corresponds.

If field 6 of the PSC.TXT file was completed with 1, why is that debtor not informed in the Central Debtors of the Financial System?

That debtor will not appear in the Central Debtors of the Financial System because it is covered by Art. 26 inc. 4) Law 25.326.

What is the reason for error 05 “Information already submitted and accepted”?

The error arises when the same reporting period was submitted for information that has already been validated, declaring “Normal” as the Filing Type.

When does error 06 “Format Error” occur?

The error arises if some non-numeric character was integrated into a numeric field, or field 5 with zeros or as null, or unsupported values were integrated into a character field according to the record layout, or is blank for field 3, or an unsupported value was integrated for fields 1, 4, 6, 7 and 9.

Likewise, the error is pointed out when field 3 “Denomination” does not comply with the following guidelines: it must be engraved with capital letters, without an accent and must not use the new line character (Enter), the semicolon character (;), tab characters, quotation marks, umlaut, apostrophes, or + or $ signs. The letter “Ñ” is accepted.

What is the reason for error 10 “Debtor not understood”?

The cause of the error is having reported a debtor with a debt of less than $25 thousand, for information as of July 2024 or having reported a person with a debt of less than $1 thousand for the periods prior to July 2024.

What is the cause of error 13 “Days late in payment misreported (field 8)”?

Field 8 “Days of delay in payment” must only be completed in the case that the debtor must be recategorized, that is, when field 7 “Mandatory recategorization” has been integrated with code 1.

The cause of the error is as follows: field 7 having been reported with code zero, field 8 is non-zero or null.

In other words, for debtors in a situation other than normal, having completed field 7 with code 1, field 8 must be different from 0000 or it must not be null. When the debtor is in situation 01, field 7 must be completed with zero and consequently field 8 must be completed with zeros or as null.

Field 8 “Days of delay in payment” must only be completed in the case in which the debtor must be recategorized, that is, when field 7 “Mandatory recategorization” has been integrated with code 1.

The cause of the error is as follows: field 7 having been reported with code zero, field 8 is non-zero or null.

In other words, for debtors in a situation other than normal, having completed field 7 with code 1, field 8 must be different from 0000 or it must not be null. When the debtor is in situation 01, field 7 must be completed with zero and consequently field 8 must be completed with zeros or as null.

What is the cause of error 15 (Inconsistency between field 4 and field 9)?

Error 15 arises when field 9 (situation not reclassified) was integrated with a value worse than or equal to that reported in field 4 (situation).

When should I complete field 9 “Unreclassified situation”?

When the guidelines established in point 7.3. of the Ordered Text of the Rules on “Classification of debtors”, in field 9 the situation prior to the reclassification of the debtor shall be reported, having reported field 7 (Mandatory recategorization) equal to 1. When it is not appropriate to use the field “Situation not reclassified” (field 7 is equal to 0), the field will be completed as null.

Do I need to fill in the entire length of the fields in the designs?

No, the flat file that will be sent with the requested information will be of variable length, in accordance with the corresponding registry design and taking into account the following specifications:

– They must respect the ANSI – 1252 character encoding.

– The “;” symbol will be used (semicolon) as a field separator.

– To separate each record, the hexadecimal characters that represent a “Carriage Return” and a “Line Feed” must be entered.

– The last field of each record must NOT contain the symbol “;” at the end of it. That is, the number of “;” per record is equal to the number of expected fields minus 1. For example, for the “PSC.TXT” file, 9 fields per record are expected, therefore there will be 8 “;”.

– It is not necessary to fill in the field until the maximum expected length is filled (i.e., fill the numerics with 0 on the left or the alphanumeric ones with blank characters).

– If you do not want to report a field (“NULL” value or absence of value), the field separators (“;”) must be completed successively without blank spaces.

– Description fields must be generated in uppercase characters without an accent. They must not contain tab characters or quotation marks. The new line character (Enter) and the semicolon character (;)) should not be used in these fields.

Rectification

How can I rectify the information submitted?

It can be done through two modalities: partial rectification and total rectification, both must be entered considering the provisions of point 1.2.2 of Section 1 of Presentation of Information to the Central Bank, accessing the link “MFT File Transfer Service” through the Home page of the secure site https://www3.bcra.gob.ar and identifying yourself with the user code and password of unique access per entity.

When to file a partial rectification?

In the event that it is necessary to modify or delete records of certain debtors for certain periods, a partial rectification may be entered, in accordance with the provisions of Section 61 of Submission of Information to the Central Bank.

The DETALLE.XML file (descriptor file) must be entered, indicating “Rectifying” in the Type field and in the Period field the date corresponding to the day on which the filing is made, in addition to the RECTPARC.TXT file.

They may rectify the following fields, which must always be completed:

• Situation
• Debtor framed Art.26 inc. 4) Law 25.326
• Amount.

The date to be completed in field 1 corresponds to the reporting period to be deleted or rectified.

It is possible to delete records by integrating 1 in field 4 and reporting fields 5, 6 and 7 as null.

1 file may be entered per day containing a maximum of 250 records. A record shall be reported for each debtor and reporting period to be deleted or rectified.

It is not possible to incorporate an uninformed debtor in a timely manner in a given period. In these cases, it is necessary to submit a total rectification of all the periods involved.

When to enter a total rectification?

A full amendment will be filed when it is necessary to replace the complete filing of a given period, because it contains errors in the validated information for all records or for a very significant amount.

They must be carried out in accordance with the provisions of point 75.4. of Section 75 of Presentation of Information to the Central Bank.

It will be necessary to make a new submission for each previously validated period in which it is pertinent to modify any data contained in the PSC.TXT file. In all cases, “Rectifying” must be entered in the DETALLE.XML file type field.

In each period to be rectified, the following must be reported:

• those debtors who were validated in a timely manner and it is correct that they continue to be informed identically.
• those debtors who were validated in a timely manner and it is correct that they continue to be informed, but it is appropriate to rectify some of the data.
• those debtors that should be eliminated (those debtors who were erroneously incorporated in the previously validated normal filing should not be reported).
• those debtors who had not been informed in the normal validated filing.

If a debtor was wrongly informed or his debt was completely cancelled, how is the data incorrectly submitted modified or deleted from his or her history?

If the debtor’s situation was not submitted correctly or should not be reported in any period(s), the records involved may be rectified, applying the provisions of Section 61 – Partial Amendments.

If the debt was cancelled, the periods in which the debtor registered a balance at the end of the month will be reported in his or her history, so no rectification should be made.

What should I take into account when submitting partial and total rectifications for the same reporting period?

It should be taken into account that, if a partial rectification is submitted and then a total one for a certain period, the latter will fully replace the information for that month including the partial rectifications duly validated.

What do I do if the filing turns out to be incorrect?

If the normal presentation results in errors, when submitting it again for validation, you must enter “Normal” in the File Type field DETALLE.XML.

Canceled debts

How should you proceed when debtors completely cancel their financing?

When cancelling their obligations, debtors lose their status and, consequently, should not be included in the information regime, from the month in which the cancellation took place.

Debtors must continue to be informed as long as the collection of their debts continues.

Suppression

How do I delete the register of a misinformed debtor by means of partial rectifications?

In the event of completely deleting the record of a debtor, the fields Situation, Debtor framed Art. 26 inc. 4) Law 25,326 and Amount must be integrated as “NULL” and field 4 with 1.

What is the difference between marking or deleting a debtor?

The difference between marking or deleting a debtor lies in how it affects the dissemination of their credit history and in the regulatory and legal implications. Suppressing a debtor does not have the same impact as marking him as a debtor according to paragraph 4 of article 26 of Law 25,326. Even if the information is not disseminated in the CDSF in that particular month, the information reported must be accurate, up-to-date and reflect reality, as required by the Personal Data Protection Law (LPDP).

When complaints are received about debtors who could be covered by subsection 4 of Article 26, if applicable, it is necessary to review the information disseminated for the last 24 months and also all the periods previously reported. In addition, the periods spent in ceding entities (if there were assignments) must be reviewed. All this analysis is important to calculate the 5 years since the debt became due. In these cases, if it is necessary to rectify them, instead of deleting the information, the affected periods must be correctly marked in field 6 of the RECTPARC.TXT file.

Suppression

How do I delete the register of a misinformed debtor by means of partial rectifications?

In the event of completely deleting the record of a debtor, the fields Situation, Debtor framed Art. 26 inc. 4) Law 25,326 and Amount must be integrated as “NULL” and field 4 with 1.

What is the difference between marking or deleting a debtor?

The difference between marking or deleting a debtor lies in how it affects the dissemination of their credit history and in the regulatory and legal implications. Suppressing a debtor does not have the same impact as marking him as a debtor according to paragraph 4 of article 26 of Law 25,326. Even if the information is not disseminated in the CDSF in that particular month, the information reported must be accurate, up-to-date and reflect reality, as required by the Personal Data Protection Law (LPDP).

When complaints are received about debtors who could be covered by subsection 4 of Article 26, if applicable, it is necessary to review the information disseminated for the last 24 months and also all the periods previously reported. In addition, the periods spent in ceding entities (if there were assignments) must be reviewed. All this analysis is important to calculate the 5 years since the debt became due. In these cases, if it is necessary to rectify them, instead of deleting the information, the affected periods must be correctly marked in field 6 of the RECTPARC.TXT file.

Update

What is the periodicity of updating the Central Bank of Debtors of the Financial System considering the rectifications (modifications/deletions)?

The database of the Central Debtors of the Financial System is disseminated on a monthly basis, with periodic updates.

Why does the last presentation made not appear in the Central Debtors of the Financial System?

It may be due to the fact that an update of the Financial System Debtors’ Central has not yet been generated or that the presentation made by the entity has been rejected for not having passed the monitoring instance or for not having validated the IR.

Contact

Information Management
(011) 4348-3500 inmates: 2632|2957|4550|2629.