Identification of Financial Trusts Under Global Programs

The Argentine Securities Commission (CNV) issued General Resolution 1116 on March 4, 2026, thereby replacing article 18 of Section IX of Chapter IV of Title V of the Regulations (N.T. 2013 and amendments) and introducing clarifications regarding the naming and numbering of financial trusts issued under global programs. The amendment responds to the experience gained in recent years regarding the issuance of financial trusts under global programs, which demonstrated the need to establish explicit guidelines to ensure uniformity, systematic consistency, and clarity of information in the identification of successive and structurally equivalent issuances.

As a general rule, the Resolution permits financial trusts to retain the same name and sequential numbering when issued under the same global program, provided the trustee and settlors are the same and the composition of the underlying assets is identical. Financial trusts may retain their name and numbering even if there is a change in the overall program—including the involvement of a different trustee—provided the new program retains substantially similar characteristics, the substantial identity of the settlors is maintained, and there is consistency in the underlying assets.

The regulation also addresses the case of trusts whose underlying assets consist of receivables originated by the settlor. In such cases, modifying the trust assets without altering their nature will not prevent the continuity of the numbering, if the assets class is properly identified in the designation and a specific risk consideration related to such modification is incorporated.

The Resolution also confirms that the initial identification of the trustee in the global program cannot be substituted. The procedure for incorporating new settlors is regulated, and it requires a corporate resolution and reliable information from the remaining participants.

This amendment seeks to optimize authorization and supervision processes, and strengthen the transparency and comparability of the information made available to the investing public.

This insight is a brief commentary on legal developments in Argentina; it is not intended to be an exhaustive analysis or to provide legal advice.