Impact of COVID-19 at the Argentine Superintendence of Insurance

Interruption of opening hours and the suspension of all administrative deadlines

The Argentine Superintendence of Insurance (the "SSN" after its acronym in Spanish) ordered remote work for all the personnel (and only for urgent tasks that cannot be postponed), the interruption of opening hours and the suspension of all administrative deadlines up to and including September 20, 2020. The activities of the SSN have been suspended since March 17, 2020.

Through Circular IF-2020-17497739 issued on March 17, the SSN established preventive measures in relation to the Coronavirus pandemic. These measures were originally adopted until March 31, 2020. Then, on April 1, through Circular IF-2020-21436607, the SSN extended these measures until April 12, and subsequently, on April 13, it issued Circular IF-2020-25441839 that extended the measures up to and including April 26.

On April 27, 2020 the SSN issued Circular IF-2020-28258722, by which it extended the measures up to and including May 10, 2020 and on May 11, 2020 the SSN issued Circular IF-2020-31222670, by which it extended the measures up to and including May 24. On May 26, 2020 the SSN extended the measures once again up to and including June 7, 2020 through Circular IF-2020-34256594 and on June 8, 2020 issued Circular IF-2020-36841718 that extended the measures up to and including June 28.

Subsequently, the SSN issued a new extension of the measures through Circular IF-2020-41487419 that ruled from June 29 until and including July 17, which was later extended from July 20 up to and including August 2, 2020 by Circular IF-2020-46429562. Then, on August 3, 2020, through Circular IF-2020-50529731, the SSN ordered a new extension of the measures that ruled from and including August 16. Subsequently, on August 18, 2020, the SSN issued Circular IF-2020-54190856 that extended the measures up to and including August 30.

Finally, on August 31, 2020, the SSN issued a new extension of the measures that will be enforce up to and including next September 20, 2020. This extension was ordered through Circular IF-2020-57546768.

To sum up, from March 17 to September 20, opening hours have been interrupted and administrative deadlines suspended. However, the acts and procedures currently being carried out or complied with are valid. Only the official platform for governmental filings ("TAD") remains operational. The procedures presented through the TAD are attended by the SSN officers working remotely and only for urgent tasks that cannot be postponed.

The SSN established the following email address as the only means of communication. This is for urgent inquiries only: consultasentidades@ssn.gob.ar.

Powers of inspection

Through Circular IF-2020-57546768 dated August 30, 2020, the SSN informed that, notwithstanding the suspension of all the administrative deadlines ordered up to and including September 20, the SSN may request from the entities subject to its control all the information and / or documentation that might be necessary. This power is exercised by article 3 of Decree 715/2020 dated August 30, 2020 and in accordance with the provisions of articles 68 to 70 of Law No. 20.091.

The SSN established the power of inspection in Circular IF-2020-28258722 dated April 27 and maintained it in the successive extensions of the measures.

Extension of term to file financial statements

Considering the difficulties in auditing the financial statements of the entities due to the mandatory isolation, on June 10, 2020 the SSN issued Resolution 156/2020 by which it extended until September 30, 2020 the term established in point 39.8.2 of the General Regulation of the Insurance Activity for the submission of financial statements closing on June 30, 2020.