Global Programs for Real Estate Financial Trusts Now Eased

The Argentine Securities Commission (CNV) issued General Resolution 1105/2026 on January 21, 2026, introducing targeted amendments to Title I and Title V of the CNV Rules (N.T. 2013, as amended), focusing on Global Programs of financial trusts linked to the real estate sector and on the regulatory definition of “CNV SME.”

Global Programs for real estate financial trusts

The main change the Resolution introduces is that it incorporates Section II, Chapter VIII, Title V, article 8 BIS, which allows trustors to waive the requirement to identify trust settlors at the time of establishing certain Global Programs. This waiver applies exclusively when the program contemplates the creation of financial trusts under the regime applicable to real estate trusts and/or where the underlying assets consist of mortgages, divisible mortgages, mortgage notes, mortgage loans, and/or similar instruments.

In such cases, the Resolution also requires that the prospectus expressly defines the purpose of the trusts and/or the nature of the underlying assets. Accordingly, the amendment introduces operational flexibility for structures in which the composition of assets and the identification of trust settlors may be defined issuance by issuance within the program, while maintaining the disclosure requirements of the applicable regime.

Adjustment to the definition of “CNV SME”

In turn, the Resolution replaces the definition of “CNV SME” in Title I. The new wording preserves its scope with respect to an issuer that qualifies as an SME and issues shares or negotiable obligations under the regimes provided for in the Rules but expressly adds an additional case for collective investment products. Specifically, it includes—with respect to classic money market mutual funds (FCI) and financial trusts (FF)—entities holding a valid MiPyME Certificate, provided they are not subject to the restrictions in article 2 of Chapter VI of Title II of the Rules. In this way, the CNV clarifies the scope of the definition of “CNV SME” to expressly cover cases linked to collective investment products, without modifying the substantive requirements or limitations applicable to the relevant entities.