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PIC FAL Regime Approved

The CNV approved the final text of the PIC FAL regulations, introducing changes to authorized entities, default assignment, and investment policy.

September 28, 2026
PIC FAL Regime Approved

Following the public consultation launched through General Resolution 1161about which you can read more in this link--on September 16, 2026, the Argentine Securities Commission (CNV) issued General Resolution 1167, approving the final regime for Labor Assistance Fund Collective Investment Products (PIC FALs). The final text retains the general framework of the proposal but introduces amendments in response to the comments received.
 

The main changes include:

  • Authorized entities: The requirements to act as an authorized entity have been relaxed through a lower minimum threshold. Financial trustees that already have at least one financial trust with an outstanding public offering, and mutual fund management companies that already manage at least one mutual fund, may act as authorized entities. Those without such a track record must have at least five financial trusts or mutual funds and an aggregate outstanding amount or net asset value of at least UVA 10,000,000.
  • Default assignment: Any authorized entity may express its willingness to be eligible for default assignment and may withdraw it at any time. Consequently, the CNV will assign employers to vehicles in the chronological order in which the vehicles were created. Assignments may only be rejected on objective and duly justified grounds. In such cases, the CNV will make a new assignment and may exclude from this mechanism any PIC FALs with repeated or unjustified rejections.
  • Investment policy: PIC FALs will be governed exclusively by the diversification and liquidity rules of Resolution 1276/2026 of the Ministry of Economy, rather than those applicable to openend mutual funds. The Resolution clarifies that all corporate bonds, including those issued by state-owned financial institutions, as well as UVA-adjusted instruments, qualify as eligible assets, and also raises from 5% to 10% the threshold for investing in securities issued by employers participating in the same vehicle.
  • Other participants: The range of agents that may participate in PIC FALs has been expanded. Settlement and clearing agents (ALyCs), trading agents (ANs), and producer agents (APs) may take part in their distribution. Collective investment product management agents (AAPICs), ALyCs, ANs, and global investment advisory agents (AAGIs) may act as investment advisors. None of this displaces the authorized entity's responsibility.
  • Fees and expenses: The Resolution clarifies that the 1% cap includes VAT. Extraordinary expenses, such as those arising from legal contingencies or the judicial recovery of assets, are excluded from its calculation.
  • Portability: Authorized entities may freely set the portability windows between their own vehicles. In addition, if a PIC FAL is liquidated, employers may exercise portability, and the authorized entity must give at least three months' prior notice.
  • FAL Fact Sheet: A monthly fact sheet must be prepared for each vehicle in clear, nontechnical language. The authorized entity must publish it on its website, with information on portfolio composition, net asset value, and historical returns net of fees.