Registration of Fund Managers as Broker-Dealers Regulated

On December 30, 2025, the Argentine Securities Commission (CNV) issued General Resolution 1102, which regulates the activities of fund managers that also apply for registration as a broker-dealer (AN), and further modifies the regime on authorized depositors under Title VIII.

 

Purpose and scope

 

The Resolution establishes the operating framework for the dual category (fund manager + AN), aligning organizational, control, and accounting-record requirements so that each business unit is supervised individually, prioritizing the interests of clients and unitholders. It also harmonizes the rules of Titles V and VII of the CNV rules applicable to ANs and introduces adjustments to the parties authorized to act as depositors before the Argentine central securities depository.

 

Dual registration and incompatibilities

 

The Resolution updates the registration and functional regime: a fund manager may apply for registration as an AN and/or as a liquidation and compensation agent (ALyC, in its sub-categories) and/or as a comprehensive placement and distribution agent (ACyDI). However, the dual status ACyDI + AN is incompatible. In addition, the fund manager may not register as an AN when it is a financial institution. At the same time, fund managers registered as AN or ALyC are subject to the agent-level rules under Title VII, which ensures a uniform compliance baseline.

 

Internal organization, fitness, and control

 

The Resolution incorporates specific rules for entities that simultaneously act as fund managers and as AN. It especially requires functional and administrative segregation, with accounting breakdown of income and expenses by operating unit; manuals and procedures consistent with the type, complexity, and volume of operations; and staffing registered in the Registry of Qualified Personnel, identifying the unit in which each person serves. Entities must appoint a Regulatory Compliance and Internal Control Officer to assess the effectiveness of controls, monitor internal mechanisms, verify regulatory compliance, and submit an annual report via its information system (Autopista de Información Financiera or AIF) within 70 days of year-end, with business-by-business information. In line with this, the financial statements must include a note disclosing net income by operating unit corresponding to the categories in which the entity is registered.

 

Operational limitations

 

Furthermore, the Resolution establishes limitations to prevent conflicts of interest: an entity registered as both AN and fund manager may not participate—whether directly or through affiliates—in the execution, recording, settlement, or clearing of transactions related to the management of collective investment portfolios of the funds it manages. In addition, an entity registered as AN RUCA may not, concurrently, be a fund manager.

 

Authorized depositors and omnibus accounts

 

Regarding depositors, the Resolution replaces provisions of Title VIII to update the list of entities authorized before Caja de Valores (the Secretariat of Finance, FGS, Markets, Clearing Houses, ALyC, registration and payment agents (ACRyP), insurance companies, local and foreign financial institutions with local representation, foreign central securities depositories, foreign managers and funds, mutual guarantee companies (SGR), registered PSAVs, among others). It also specifies operational requirements when omnibus accounts are used, including identification and segregation of positions, protection of client collateral, appropriate accounting, and controls. Finally, central securities depositary agents (ADCVN) are required to open accounts for all eligible entities and to immediately notify the CNV if there are any issues.