How to Submit Information
Mutual Guarantee Societies (SGRs) and Public Guarantee Funds (FGCP) must provide information on all debts that have been cancelled in compliance with the guarantees that backed the respective obligations, in accordance with the provisions of the Harmonized Text of the Regulations on Mutual Guarantee Societies and the Harmonized Text of the Regulations on Public Guarantee Funds.
Find on this page all the information to upload and validate the RI and also the answers to the most frequently asked questions we receive from the entities.
What do I have to take into account when filing the Financial System Debtors Information Regime?
Submissions must comply with the provisions of Section 1, General Provisions for the Submission of Information to the BCRA.
Where can I obtain the regulations to take into account when submitting the RI-DSF?
You can find it at this link.
Ordered texts (OTs) and other related instructions
– Consolidated text of the Rules on Mutual Guarantee Societies (point 2.4. Information to the Central Bank).
– Ordered text of the Regulations on Public Guarantee Funds (point 2.7. Information to the Central Bank).
– 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 62 – Mutual Guarantee Societies and Public Guarantee Funds.
– Information Centers – Section 4 – Financial System Debtors Center.
– Ordered text of the rules on Classification of debtors. They shall comply with these rules on the basis of the borrowers’ default (point 10.1.), according to the criteria applicable to the “consumer or housing” portfolio and by application of the provisions set out in point 7.3. of Section 7. of the aforementioned law (mandatory recategorization).
Other regulatory and operational aspects
Register of the Customs Collection and Control Agency (ARCA): can be downloaded from www3 for entities with exclusive access to the site.
What is the information to be provided?
The total of the guarantees faced by each of its debtors (guarantees honored with financial institutions, non-financial credit providers and financial trusts), in accordance with the rules on “Classification of debtors”, with the exception of the BCRA and those debtors whose debt balance is less than $25 thousand.
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 are 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 amount of debt is $25,300, the “Total collateral faced” field in the file must be reported SGRFG.TXT equal to 25 (respecting the length of the field).
Instances for validation
1. Submission and registration: the information contained in the ZIP will be sent through the file transfer service. Once the file is received by the BCRA, an email will be sent to the declared email account, indicating that the upload has been completed successfully.
2. Follow-up: it will be available through the option “Follow-up Consultation of Presentations”. The submission of the ZIP 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.
When is the deadline for submission?
On the 22nd day of the month following the report (or immediately following the report). In the event of an extension of the expiration of a particular period, a Communication will be issued in this regard.
Do I have to make the presentations via the web?
Submission via the web is mandatory, through the MFT file transfer service.
Find a step-by-step guide and tutorial videos for charging via MFT.
What is the RI-DSF – SGR/FGCP regime and requirement code?
The regime code is 2 and the one corresponding to the requirement is 7.
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 MFT file transfer service?
For field loading, it is recommended to use Internet Explorer 10 or higher and have compatibility view enabled.
What do I do if after completing the fields in the “DETALLE.XML” Descriptor and selecting the files that correspond to each RI declared as “Opera”, when consulting the status of each request presented, it results 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 “202205” 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 IR presentation, it is not necessary to enter any value 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” Descriptor.
How should I proceed after uploading information?
When uploading the information you will receive an email with the “Confirmation of submission upload” with a message similar to the following:
Your file has been saved in the “XXXXX” folder
Name: XXXXX.zip
Tracking number: XXXXXXXXX
Original Size: XXX bytes
To guarantee non-repudiation at destination, we confirm that the file received is IDENTICAL to the uploaded file.
You can follow the presentation at the following link:
(https://www3.bcra.gob.ar/ConsultaPresentacionesMFT/detalle/XXXXX ).
If there is no data when entering the address, wait until the information is updated. You must enter the detailed address and check if the presentation was accepted or rejected for registering an error and not having passed the first instance of control. In the latter case, you will need to resubmit the information.
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 ZIP filing has been completed by the MFT file transfer service, it must be tracked using the “Filing Tracking Query” option in www3.
In “Details” and “Information” you will be able to consult all the submissions 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.
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”.
You must consider that precedence is controlled in all cases, that is, when presenting the information corresponding to a period, it will be verified that the immediately preceding one is validated. Otherwise, the 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.
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, since he registers greater indebtedness in the 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 analyse whether it is appropriate to recatecate.
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 Company issuing credit cards 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, since he registers greater indebtedness in FF C $7, who categorized him in situation 4.
The error arises from having reported a non-existent date (for example, 202213), because it contains non-numeric characters, the information corresponds to a period not enabled for processing, or was not integrated with the last day of the month related to the information presented.
If field 6 of the file was SGRFG.TXT 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 08 “Missing Denomination” to be reported?
The Naming field 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 cause of error 09 “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 reason for error 11 “Situation misreported”?
The cause of the error is that you have reported a code other than those provided for in the table in paragraph 62.2.1. of the operational instructions corresponding to Section 62. of Presentation of Information to the Central Bank.
What is the cause of error 14 “Days of delay in payment misreported (Applicable to field 8)”?
Field 8 “Days of delay in payment” should only be completed in the case where the debtor needs to be recategorized, i.e., when field 7 “Mandatory Recategorization” has been integrated with code 1.
The causes of error are as follows:
– Field 8 contains blanks or non-numeric characters; o
– Having reported field 7 with zero, field 8 is non-zero or non-zero.
In other words, for debtors in a situation other than normal, having completed field 7 with code “1”, field 8 must be non-zero or must not be null. When the debtor is in situation 1, field 7 must be completed with zero and consequently field 9 must be completed with zero or as null.
Why did the result of the validation process yield error 15 “Inconsistency between field 7 and field 9”?
Field 9 “Situation without reclassification” should only be completed in the case where the debtor needs to be recategorized, i.e., when field 7 “Mandatory Recategorization” has been integrated with code 1.
What is the cause of error 16 “Field 10 misreported”?
In field 10, a code belonging to the financial institution, non-financial credit provider or financial trust with which the financing guaranteed and faced by the SGR/FGCP was arranged must be provided.
The SGR/FGCP code should not be reported.
What is the reason for error 17 (Fields 3, 4 and 6 to 9 misinformed)?
Error 17 arises when for the same type and identification number the following fields are not identical:
– Field 3: Denomination
– Field 4: Situation
– Field 6: Debtor framed Art. 26 inc. 4) Law 25.326
– Field 7: Mandatory
recategorization – Field 8: Days of delay in payment
– Field 9: Situation not reclassified
What is the cause of error 18 (Inconsistency between field 4 and field 9)?
Error 18 arises when field 9 (situation without reclassification) 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), field 9 will be completed with “00” in all cases.
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 RECTPARCSF.TXT file.
They may rectify the following fields, which must always be completed:
– Location
– 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 62.4. of Section 62 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 SGRFGCP.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 correctly submitted or it was not appropriate to be reported in any period(s), the records involved may be rectified, applying the provisions of Section 61 – Partial Amendments.
When entering movements for a debtor, all current records reported in the “00002” regime, requirement “00007” in the period in question must be sent.
It is important to bear in mind that, by regulation, the situation and the mark of Article 26 subsection 4 of Law 25,326 are unique per debtor. Therefore, for each combination of type and identification number and date of information, fields 5 and 6 must contain the same information in all records, for all the codes of entities with operations faced by the FGCP.
If the debt was canceled, the periods in which the debtor registered a balance at the end of the month will be reported in his or her history. Therefore, it is not appropriate to make corrections in these cases.
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 filing is error-free, when submitting it again for validation, you must enter “N” (NORMAL) in the rectifying field of the DETALLE.XML file.
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.
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 appropriate to rectify them, instead of deleting the information, the affected periods must be correctly marked in field 6 of the RECTPARCSF.TXT file.
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.