Report on Banks

Monthly report that analyzes the situation of the Argentine financial system.

About the use of inclusive language in this publication

The use of language that does not discriminate and that makes all gender identities visible is an institutional commitment of the Central Bank of the Argentine Republic. This publication recognizes the influence of language on ideas, feelings, ways of thinking and evaluation schemes.

This document has sought to avoid sexist and binary language. However, for ease of reading, resources such as “@” or “x” are not included.

Executive summary

• In October, credit in pesos to the private sector continued to grow in real terms, in a framework in which the aggregate financial system preserved its strong features characterized by high margins of solvency, liquidity and forecasts. This scenario is partly caused by the actions of the BCRA in recent months, which has managed to temper the procyclical behavior of credit, providing support to the financial situation of companies and families.

• In the month, the balance of financing in pesos to the private sector presented a positive performance, increasing 0.7% in real terms (+4.5% nominal). This increase was mainly driven by commercial lines (documents and advances), cards and pledges. In a year-on-year comparison (y.a.), the real balance of credit in pesos to the private sector accumulated a growth of 8.7%, being disseminated among the groups of banking entities, thus registering six consecutive months with positive year-on-year rates of change.

• In order to continue promoting the flow of credit to the private sector in a scenario of gradual normalization in economic activity – although still with heterogeneity between sectors – in October the BCRA approved a new Financing Scheme for Productive Investment of MSMEs. This scheme is intended for companies that were affected by the pandemic, which are rebuilding their working capital and payment chain, as well as MSMEs that wish to expand their production processes. In this framework, loans for a total of $147,864 million have been disbursed until the end of December, already reaching 49,619 companies.

• In order to continue supporting companies and families that are beginning to resume their activity – within the framework of the pandemic – the BCRA recently decided to extend until March 31, 2021 the modification of the parameters for classifying debtors and the possibility of transferring unpaid installments at the end of the life of the loan, accruing only compensatory interest. In this context, the irregularity of credit to the private sector stood at 4.3% of the total balance in October, 0.3 p.p. less than last month. The level of forecasting recorded by the financial system in October remained relatively high. In the month, the total balance of forecasts represented 5.4% of the total balance of credit to the private sector and 132.5% of the portfolio in an irregular situation, levels higher than the average of the last 10 years.

• In October, the balance of deposits in pesos of the private sector fell in real terms compared to September. However, in a year-on-year comparison, in October the balance of deposits in national currency of the private sector increased 40.6% in real terms, with increases in demand and time accounts.

• Maintaining a robust coverage in historical terms, the sector’s liquidity in the broad sense – availabilities, integration of minimum cash and BCRA instruments, in domestic and foreign currency – fell by 1.8 p.p. of total deposits in October to 64.2%.

• In October, the BCRA updated its monetary policy guidelines. Among other measures, policy interest rates continued to be aligned: the interest rate on 1-day passive passes was increased on successive occasions, it was decided to offer 7-day passes, and the LELIQ rate was subsequently adjusted. In addition, with the aim of offering positive returns with respect to inflation and strengthening savings instruments in local currency, in November the minimum guaranteed interest rate on fixed-term deposits in pesos was raised once again.

• From high levels compared to the last 10 years, in the month the regulatory capital of the financial system decreased slightly to a total of 23% of risk-weighted assets (RWA). In line with the measures carried out by other Central Banks since the beginning of the health emergency, and in accordance with the macroprudential policy adopted, it was recently decided to maintain the suspension of the distribution of financial institutions’ results until June 30, 2021.

• The sector’s profitability ratios in homogeneous currency in the first half of 2020 were lower than those of the same period in 2019, a dynamic that has deepened in recent months, reaching a negative result for the system’s aggregate in October. Even so, in the first 10 months of 2020, the financial system as a whole accrued total comprehensive results in homogeneous currency equivalent to 2.2% annualized (a) of assets (ROA) and 15% y. of net worth (ROE).

I. Financial intermediation activity

In October, the balance of credit in national currency to the private sector increased in real terms compared to September, thus registering six consecutive months of positive year-on-year growth rates.

Based on the estimated cash flow for items in national currency¹, in October the main sources of resources for all financial institutions were the reduction of liquidity in the broad sense, and to a lesser extent, of financing to the public sector. On the other hand, the decrease in private sector deposits, as well as the increase in credit to the private sector, were the main applications of funds in the period. These movements were verified in a similar way in all groups of financial institutions².

In October, the balance of financing to the private sector in pesos increased by 0.7% in real terms (+4.5% in nominal terms)³. Within the framework of the measures adopted by the BCRA aimed at boosting credit in pesos with subsidized rates, the monthly performance was mainly explained by commercial lines (documents and advances), cards and pledges (see Graph 1). Public financial institutions led the monthly increase in financing in pesos to the private sector (with a real growth of 1.2% in this period), followed by national private financial institutions⁴.

In order to continue promoting the flow of credit in pesos to the private sector in the face of the new scenario of normalization of economic activity⁵, in mid-October the BCRA launched a new Financing scheme for Productive Investment of MSMEs. These new lines are aimed at companies that were affected by the pandemic, which are rebuilding their working capital and payment chain, as well as MSMEs⁶ that wish to expand their production processes. They have maximum interest rates that depend on the destination of the financing requested. Through this new scheme, from its entry into force until the end of December, loans totaling $147,864 million have been disbursed, benefiting 49,619 companies (see Graph 2)⁷. National private financial institutions were the main promoters of these lines, followed by public and foreign private ones.

In addition, within the framework of the line of financing at subsidized interest rates for companies registered in the “Emergency Assistance Program for Work and Production” (ATP)⁸, $10,301 million have been granted, reaching 455,503 workers.

For their part, in the period, credit lines aimed at single-tax and self-employed persons continued to be gradually extended. In particular, through the Zero Rate Credit Line⁹ , 561,929 loans have been granted for a total of $66,474 million until mid-December (99% already disbursed). As a result of the implementation of this line, more than 249,200 new credit cards have been issued so far and 777 demand accounts have been opened. At the same time, through the Cultura¹⁰ Zero-Rate Credit line, 2,843 loans have been granted for a total of $300 million (87% already credited).

In a year-on-year comparison, the real balance of credit in pesos to the private sector accumulated an increase of 8.7% in October, a performance mainly explained by private financial institutions, and to a lesser extent, by public ones (see Chart 3).

In October, the balance of credit in foreign currency to the private sector fell by 6.1% – in the currency of origin – compared to the previous month. As a result, total financing to the private sector (in domestic and foreign currency) accumulated a fall of 0.4% in real terms compared to September and 8.5% y.o.y. in real terms.

In terms of funding in the financial system, in October the balance of deposits in pesos of the private sector fell 3.5% in real terms compared to September (+0.1% nominal) (see Chart 4). The monthly performance was explained by time deposits in pesos, which verified a real decrease of 8.1% in the month (-4.7% nominal). The performance of the private sector’s time deposits in pesos was partly explained by the transfer of funds to the Treasury Bonds linked to the value of the dollar tendered in the month by the National Government. In addition, during the period, there was evidence of a change in the composition of the FCI Money Market portfolio (they increased their interest-bearing demand deposits and reduced term investments with an early cancellation option)¹¹. Meanwhile, demand deposits increased 0.6% in real terms in October (+4.4% nominal).

For their part, private sector foreign currency deposits fell 9% in October – in source currency – to later stabilize their balance in November. In this context, the set of financial institutions continued to have a comfortable coverage of deposits with liquid assets in foreign currency. Given the performance of both the domestic currency and foreign currency segments, the real balance of total private sector deposits decreased 4.9% in October, accumulating a year-on-year increase of 19.4% in real terms.

The balance of public sector deposits in pesos fell by 1.3% in real terms in October (2.5% nominal). Thus, total deposits (from the public and private sectors) fell 3.2% in real terms compared to the previous month (0.5% nominal).

Given the prevailing economic and financial conditions, in early October the BCRA updated the guidelines of its monetary policy¹². In particular, measures were included to progressively harmonize monetary policy interest rates: increasing the interest rate on overnight passes, offering seven-day passes and, later in November, increasing the LELIQ rate (see Chart 5). In addition, in November, the minimum guaranteed interest rate on fixed-term deposits in pesos was raised, in order to offer positive returns with respect to inflation, and to promote savings instruments in national currency¹³.

In a year-on-year comparison, in October the balance of deposits in national currency of the private sector increased 40.6% y.o.y. in real terms (93% y.o.y. nominal); Public sector deposits in national currency increased in a similar way. Thus, the balance of total deposits in pesos grew by 39.4 y.o.y. in real terms in the period (91.3% y.o.y. nominal).

II. Aggregate composition of the balance sheet

In October, the total assets of the financial system fell by 2.8% in real terms (+0.8% nominal). It should be noted that as of July, the total assets of all institutions stopped growing at relatively high real rates (see Chart 6), as had been observed in the first part of 2020. In particular, after the period of greatest economic impact of the pandemic and the health measures taken to address it – especially in the second quarter of 2020 – the need to cover with monetary issuance the extraordinary measures promoted by the National Government to assist families and companies began to be gradually reduced¹⁴. Consequently, and gradually, the need to sterilize this monetary issuance through LELIQ and passes was also limited. It should be remembered that, to a large extent, the flip side of the monetary sterilization carried out by the BCRA via LELIQ and passes in the first part of the year, was reflected in the increase evidenced in the assets of the financial system.

With regard to the composition of the total assets of the financial system, in October the importance of credit to the private sector in national currency increased (+1 p.p. to 29.3% of the total, see Chart 7) and credit to the public sector (+0.5 ^p.p.15 to 11.4% of the total). On the other hand, compared to September, the relative importance of the most liquid assets – both in pesos and in foreign currency – decreased. In the month, credit to the private sector in foreign currency continued to reduce slightly its share of total assets.

Within the composition of the total funding (liabilities plus net worth) of the financial system, and in line with the performance of deposits (see Section I of the Report), in October private sector demand placements in national currency increased their weighting (+0.9 p.p., to 25.7%, see Chart 8). For their part, in the month, time deposits in national currency of the private sector reduced their participation in funding (-1.2 p.p. to 21.1%). In October, private sector deposits in foreign currency continued to lose relative weight in funding.

In the month, assets in foreign currency represented 19.1% of the sector’s total assets, without significant changes compared to September (-9 p.p. y.o.y.). Liabilities in this denomination reached 17.1% of total funding, falling 0.8 p.p. in the month (-9.4 p.p. y.o.y.). The reduction in the share of liabilities in foreign currency was mainly explained by the decrease in private sector deposits in this denomination. On the other hand, liquid assets and credit to the private sector in foreign currency decreased. However, the aggregate of foreign currency items did not lose weight in the total assets of the financial system, mainly due to the incorporation of National Treasury bonds linked to the dollar offered in the latest PEN auctions. As a result, from moderate levels, the spread between foreign currency assets and liabilities in the aggregate financial system—including off-balance sheet foreign currency forward purchase and sale operations—stood at 14.5% of regulatory capital in October, increasing 4.4 p.p. compared to September and 2.1 p.p. y.o.y. (see Chart 9).

III. Portfolio quality

As presented in the previous section, the financial system’s exposure to credit to the private sector in pesos increased compared to the previous month, while the foreign currency credit segment continued to lose relevance. Thus, the total credit balance to the private sector (including domestic and foreign currency) in terms of assets amounted to 33.9% on October¹⁶, increasing 0.8 p.p. compared to last month (see Chart 10). The monthly performance was generalized among the different groups of financial institutions.

In order to continue supporting companies and families that are beginning to resume their activity – within the framework of the pandemic – the BCRA recently decided to extend until March 31, 2021 the modification of the parameters for classifying debtors and the possibility of transferring unpaid installments at the end of the life of the loan, accruing only compensatory interest¹⁷. In this context, the irregularity of credit to the private sector stood at 4.3% of the total balance in October, 0.3 p.p. less than in the previous month (see Chart 11). This decrease was verified in all groups of financial institutions and reached both the business and household segments.

The level of forecasting recorded by the financial system in October remained relatively high. The total balance of forecasts represented 5.4% of credit to the private sector in the month, with no significant changes compared to September and 0.8 p.p. higher than a year ago (see Chart 12). The total forecasts in terms of the private sector’s portfolio in an irregular situation stood at 132.5% at the aggregate level in October, increasing 5.6 p.p. compared to last month and 32.2 p.p. y.o.y. The estimated balance of regulatory forecasts attributable to the non-performing portfolio (following the criteria of the minimum forecast standards for bad debt risk, without using the IFRS criteria for entities A) stood at 109% of these loans in October.

An indicator that allows us to account for the level of resilience of the financial system in the face of credit risk is to measure regulatory capital in terms of the total balance of credit to the private sector net of forecasts. This indicator helps to clarify some features of the group of entities, such as the relatively low gross exposure to the private sector and high coverage in terms of forecasting and capital. As of October, this ratio was around 39.9%, slightly lower than in the previous month, although it was 12.4 p.p. higher than that verified in October 2019¹⁸.

IV. Liquidity and solvency

In October, all banks continued to operate within a framework of high liquidity and solvency margins, which exceed internationally recommended regulatory standards¹⁹.

The liquidity ratios that emerged within the framework of the Basel Committee’s recommendations – Liquidity Coverage Ratio (LCR) and Stable Net Funding Ratio (NSFR) – remained at levels that were almost double the minimum threshold required at the local level for the aggregation of obligated entities (Group A)²⁰, ²¹.

In October, the broad liquidity indicator²² for all entities stood at 64.2% of total deposits (59.3% for items in pesos and 85.7% for the foreign currency segment), 1.8 p.p. below the level observed in September (-2.3 p.p. and +1.5 p.p. for items in local currency and foreign currency, respectively) (see Graph 13). In the month, the composition of ample liquidity in pesos turned towards a greater participation of net passes against the BCRA, and a reduction in the holdings of LELIQ and the balance in the current accounts held by the entities in this Institution²³, ²⁴. In the last 12 months to October, broad liquidity increased by 8.6 p.p. of deposits, a performance mainly explained by liquid assets in foreign currency.

From high levels compared to the last 10 years, capital integration (PRC) of the aggregate of entities decreased 0.7 p.p. of risk-weighted assets (RWA) in October to 23% (25.2% for private entities and 18.8% for public entities, see Chart 14). Meanwhile, the capital position (difference between RPC and regulatory requirement) of all entities represented 169% of the regulatory capital requirement in the month (206% for private entities and 107% for public entities), 9.4 p.p. less than in September. The sector continued to verify, on an aggregate basis, the additional capital conservation margins (2.5% of RWAs for all entities, with an additional 1 p.p. for those with systemic importance).

In line with the measures carried out by other Central Banks since the beginning of the health emergency, this Institution adopted different micro and macroprudential policies that contributed in part to sustaining the aforementioned solvency levels. Among others, it was recently decided to maintain the suspension of the distribution of results of financial institutions until June 30, 2021²⁵.

With respect to the endogenous generation of the sector’s solvency, in the first 10 months of 2020, the financial system accrued total comprehensive results in homogeneous currency equivalent to 2.2% annualized (a.) of assets (ROA) (15% y. in terms of net worth (ROE). In this sense, the recent performance of the system’s monthly earnings has been reflected in a gradual decline in the sectoral profitability indicators accumulated for 2020. On the other hand, according to the information available, the sector’s profitability ratios in the first half of 2020 were lower than those of the same period in 2019²⁶, a dynamic that deepens when considering the August-October period, reaching negative levels in this last month. In particular, in October the financial system accrued an ROA of -0.3%y. (ROE was -1.8%y).

The evolution of implicit interest rates (active and passive) and their differential reflect, to a certain extent, how a significant part of the sector’s sources of income and expenditure develop for each peso channeled into financial intermediation²⁷. In this regard, it is estimated that in the last two months the nominal implicit lending interest rate in national currency increased slightly, while the nominal funding cost for deposits in the same denomination saw a slight reduction²⁸. As a result, the differential between both nominal items increased by 0.6 p.p. in the period (see Graph 15). However, it should be considered that inflation in the last two months was higher than in the previous two months. When taking this effect into account and estimating real implied interest rates, it would be observed that the differential between the implicit lending rate and the cost of funding is reduced by 1.1 p.p. compared to the previous two-month period, as a sign of lower profitability in real terms.

Year-to-date, the financial margin represented 11.2% of assets. Interest income (8.6% y/y of assets) and securities earnings (8.3% y/y) were the main positive items of the financial margin in the first 10 months of²⁹ years, while interest expenses (8.7% y/y of assets) stood out as the main financial expenditures of the system in the same period. Among the non-financial items in the income statement, net income from services (1.9% y/y of assets) was the most relevant source of results, while administrative expenses (6.6% y/y of assets) and charges for uncollectibility (1.5% y/y of assets) represented the main non-financial expenses in the^30th period.

V. Payment system

The operations of the payment system continued to develop in a scenario in which health restrictions are gradually being relaxed in different parts of the country. In this context, the BCRA promotes measures to minimize risks, while seeking to stimulate transactions through the use of digital payment channels.

The total immediate transfers made during November (latest available information) were lower than those recorded in October, both in terms of amounts and real amounts, although they remain at values that exceed the monthly average of 2020 (see Graph 16). In year-on-year terms, total immediate transfers almost doubled in terms of amounts, growing 49.4% in real amounts. This performance was accompanied by all the channels through which immediate transfers are made, highlighting the dynamism of mobile banking (+220% YoY in amounts and 148% YoY in real amounts). In this context, in the last year, the relative share of immediate transfers through mobile banking increased significantly from low levels (+8.7 p.p. to 22.8% in amounts and +3.4 p.p. to 8.6% in real amounts).

Since the beginning of December, the BCRA has enabled the Transfers 3.0 program seeking to boost digital payments and promote greater financial inclusion. Within this framework, Payment by Transfer was created in order to expand the scope of immediate transfers. Payment by Transfer has a number of features. First, interoperability: the Standardized Payment Interface (IEP) is created with an open architecture that will allow the operation of all accounts (bank and virtual wallets). Secondly, immediacy: businesses will receive accreditation automatically (24 hours a day, 7 days a week). Third, it’s an inexpensive with no hidden costs. Fourth, the system is competitive, since businesses considered as MSMEs that adhere to the system will not have commissions during the first three months of use of the service, for the first 50,000 pesos they invoice each month. Finally, it is a Flexible system: it will allow the operation of cards, QR, DNI, payment requests and biometrics (for example, fingerprint).

In October (latest available information), debit card transactions grew significantly (8.9% in amounts and 9.5% in real amounts) compared to the immediately previous month, registering one of the highest levels of the year (see Chart 17). Compared to September, operations increased both in their face-to-face format (POS) (increased 10.6% in quantities and 12% in real amounts), as well as through e-commerce (the number of operations grew 4.8%, +3.9% in real terms). Compared to the same month of the previous year, debit card operations increased both in amounts (20.7%) and in real amounts (33.6%).

Cash withdrawals through ATMs increased during October (latest available information) (see Chart 18). Regarding the annual average, the number of withdrawals in October was similar, while the withdrawal amount was 6.9% higher in real terms. Compared to the same month of the previous year, ATM withdrawals decreased in amounts (8%) and increased in real amounts (24.4%), thus increasing the average amount of each withdrawal measured in constant currency (+$1,275, to almost $5,000 per withdrawal). It should be noted that, given the current health situation, in order to continue guaranteeing an efficient use of the system’s ATM network, the BCRA recently decided to extend until the end of March 2021 free ATM operations (regardless of the bank and the network) and the possibility of withdrawing at least $15,000 in a single operation³¹.

Regarding check clearing operations, during November (latest available information) there was a monthly decrease in the number of operations (-2.5%) and in real amounts (-0.7%) compared to October, thus placing it below the 2020 annual average. The monthly compensation was increased again in its electronic version (ECHEQs) and decreased in its physical format both in quantities and in real amounts (see Graph 19). Thus, since April, the relative share of ECHEQ operations increased significantly (+8.7 p.p. to 11.3% in terms of the number of operations, and +17.6 p.p. to reach 31% in terms of total real amounts). In year-on-year terms, the total clearing of checks decreased in amounts (-28.3%) and in real amounts (-18.1%).

On the other hand, in November the ratio of check rejections due to lack of funds over the total compensated decreased slightly (-0.01 p.p. to 0.65% in amounts and -0.01 p.p. to 0.5% in amounts), thus placing it below the average observed in the year (see Graph 20). Compared to the same month of the previous year, this quotient also fell (-0.4 p.p. in quantities and -0.3 p.p. in amounts), being lower, in turn, than the monthly average recorded throughout 2019. Considering exclusively the subset of ECHEQs, during November the ratio of rejections over the total compensated was also reduced (-0.1 p.p. to 0.7% in quantities and -0.3 p.p. to 0.4% in amounts)³².

References

¹ Differences in balance sheet balances expressed in homogeneous currency.

² Considering the segment of items in foreign currency —in the currency of origin—, in October the reduction in liquid assets and, to a lesser extent, in financing to the private sector were the most relevant sources of funds for the system. For its part, the decrease in private sector deposits was the main application of resources in October for the aggregate of financial institutions, followed by the increase in holdings of public securities tied to the dollar rate.

³ Includes principal adjustments and accrued interest.

⁴ Throughout the Report, when reference is made to groups of private (national and/or foreign) and public financial institutions, it corresponds to banking entities. Non-bank entities will be referred to as “EFNBs”.

⁵ For more detail, see Section 2 of the Financial Stability Report of December 2020 (“IEF II-20″).

⁶ See communication “A” “7140” and amendments.

⁷ Within the framework of this new line, recently through Communication “A” “7161”: a) financing alternatives were expanded and b) an additional regulatory benefit was incorporated in terms of Minimum Cash for financing for investment projects (with maximum interest rates of 30% TNA).

⁸ See communication “A” “7082” and communication “A” “7102”.

⁹ See Communication “A” “6993”.

¹⁰ See Communication “A” “7082”.

¹¹ For more information see “Monthly Monetary Report” of October 2020.

¹² See Guidelines for a “Monetary Policy in an Economy in Macroeconomic Transition” of October 2020.

¹³ It is set at 37% nominal annual for deposits of up to $1 million constituted by individuals and 34% nominal annual for the rest. See Communication “A” “7160”.

¹⁴ For more details, see the latest edition of the “Monetary Policy Report (IPOM)”.

¹⁵ As part of the progress made in the reconstruction of the local debt market, in October the National Government placed instruments that were partly acquired by all entities, mainly with regard to bonds tied to the price of the dollar.

¹⁶ The ratio rises to 32% when the forecasts for the credit balance are met.

¹⁷ Communication “A” “6938”, Communication “A” “7107” and Point 2.1.1. of the Ordered Text “Financial Services in the Framework of the Health Emergency Provided for by Decree No. 260/2020 CORONAVIRUS (COVID-19)”. For more details on the recent extension of some of these measures, see Communication “A” “7181”.

¹⁸ For more detail, see Section 3.1 of the “IEF II-20”.

¹⁹ For more detail on the main strengths of the local financial system, see “IEF II-20”.

²⁰ The LCR considers the liquidity available to deal with a potential outflow of funds in the event of a possible stress scenario in the short term. See Ordered Text —TO— “Liquidity Coverage Ratio”.

²¹ The NSFR takes into account the availability of stable funding of the entities, in line with the terms of the business to which it applies. See TO “Stable Net Funding Ratio”.

²² Considers availability, integration of minimum cash and BCRA instruments, in national and foreign currency.

²³ In October, a series of measures came into force that had an impact on the composition of liquidity. On the one hand, the progressive increase in interest rates on 1-day pass-by-passes and the possibility of making 7-day pass-through passes, while reducing the interest rate on LELIQs, had an impact. On the other hand, since the beginning of October, the BCRA has ordered a reduction of 20 p.p. in the net surplus position in LELIQ of financial institutions with respect to that registered in September (see Communication “A” “7122”).

²⁴ During the month, some modifications to the minimum cash regime also took place. For more details, see the “Normative Annex” and Communications “A” “7132” and “A” “7140”.

²⁵ Communication “A” “7181”.

²⁶ For more detail, see Box “Year-on-year evolution of the profitability in homogeneous currency of the financial system” of the “IEF II-20”.

²⁷ These calculations do not take into account concepts such as administrative expenses, tax expenditures, cost of capital or other components associated with risks assumed by the entities.

²⁸ Accumulated 2 months and annualized.

²⁹ It is estimated that this value represented approximately 10.3% of the assets when considering both the accumulated cash flows in the income statement and in other comprehensive income.

³⁰ With regard to results by service, it should be noted that in the context of the health situation in the country and in order to continue to guarantee an efficient use of the ATM network, this institution also ordered a new extension for the suspension of the collection of fees for ATM operations. which will remain free of charge until 3/31/2021. Until March 31, 2021, financial institutions may not charge charges or commissions for transactions carried out through all ATMs, without any distinction between customers and non-customers, regardless of the type of demand account on which the corresponding transaction is carried out and the financial institution and/or ATM network to which it belongs. For more details, see “Press Release” of December 17 and Communication “A” “7181”.

³¹ For more details see Communication “A” “7181”.

³² According to the information available, the rejection rate of ECHEQs corresponds to the total number of reasons for rejection.