Country Manual Credits
Uruguay – Update 2024
BRP has updated its Country Manual Credits for Uruguay out of Credits institutions country of establishment (RS, BT & RT)
| Source of changes | Answers |
|---|---|
| Law / Regulation | Yes |
| New Position of the Authorities | No |
| Evolution of Expert’s Interpretation | No |
Regulatory Template
Material changes
The Country Manual has been updated and entirely reviewed to ensure that the content of the documents remains accurate and in line with the evolving interpretation of the current legal and regulatory framework.
To note is that Central Bank of Uruguay (BCU) Circular No. 2411 of December 2, 2022 which regulates the activity of “Credit Granting Entities” entered into force on January 1, 2024. Said regulation requires a specific license for lending activities exclusively or “pure ending” (i.e. activities that do not fall within the regulated activity of “financial intermediation”). This “Credit Granting Entities” license is required in case natural or legal persons that, without being credit management companies or financial services companies, habitually and professionally grant credits with their own resources or with resources/credits granted by certain third parties (as per a limited statutory list established under Section 34 of the BCU manual Charter).
As advised when we published the previous update of this Manual, BCU Circular No. 2411 does not impact the regulatory framework for credit activities of a foreign credit institution directed towards or undertaken in Uruguay. Thus, lending activities of a foreign credit institution are still permissible and do not trigger licensing requirements in Uruguay if not undertaken on a professional and customary basis in/into Uruguay.
Please note that after consultations with our local counsel, we can confirm that the cross-border rules described in the manual also apply to foreign, unlicensed credit institution’s services directed towards or performed in the Free Trade Zone of Uruguay (Zona Franca). Thus, all rules described in the manual are also applicable for credit activities in/towards the Uruguayan Free Trade Zone.
Non-material changes
Several comments have been slightly reworded (without introducing material changes) to reflect the regulatory situation/current interpretation of the regulatory framework more accurately.
Behaviour Template
The answers in the BT are aligned to those contained in the RT.
For more information, please contact us: info@brpsa.com
Geneva, October 11th, 2024