Carlos Ibarra
Patrick Stockdale
José Mejía

Draft Bill to Amend the General Provisions Applicable to Credit Institutions

The purpose of this note is to inform you about the draft bill that aims to amend the Single Banking Circular regarding technological commission agents (the “CUB”) submitted by the National Banking and Securities Commission (“CNBV”) to the National Commission for Regulatory Improvement (“CONAMER”) on April 30th, 2024.

Publication and Current Content

The CUB aims to include the concept of the technology-based commission agent, who will be able to act on behalf of credit institutions through digital platforms to perform transactions such as account opening, granting of loans, payment for goods and services, and balance inquiries. Commission agents must comply with information security requirements and operational processes, and their access to customer data will be revoked after the transaction.

Strategic Business Plan

Credit institutions must submit a strategic business plan (PEN, for its Spanish acronym) to the CNBV before hiring commission agents, which must comply with the requirements proposed in the CUB. It is further proposed that credit institutions must adapt existing agreements with commission agents within 18 (eighteen) months from the date the CUB comes into effect.

Impact and Transition

These amendments will significantly impact the management and operation of credit institutions with technology-based commission agents, improving the security and efficiency of financial transactions and strengthening the protection of customer data.

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Written by:

Partner

Carlos is Founder and Partner at Ibarra del Paso Gallego, where he specializes in Real…

Associate

Patrick is Lead Associate in the Banking, Finance, and Capital Markets practice and an Associate…

Associate

José is an Associate at Ibarra del Paso Gallego, with expertise in Real Estate and…

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