On October 29, 2026, the Financial Market Commission (the “CMF”), through Exempt Resolution No. 12,183, approved a document entitled “Frequently Asked Questions on NCG No. 532 – Regulatory Files for Fund Information Reporting”, aimed at clarifying various aspects relating to the implementation of the reporting obligations established under General Rule No. 532 (“NCG No. 532”).

NCG No. 532 establishes the Fund Information System Manual (the “Fund ISM”), which governs the submission of information by general fund managers (“AGFs”) for the supervision of funds and their managers.

The new document, comprising 17 questions and answers, supplements the regulations and clarifies the reporting criteria that AGFs must apply. The main clarifications include the following:

• Investment portfolios and derivatives (Questions No. 1 to 4):

The document clarifies the reporting criteria under FONDOS01 for debt instruments issued by the same issuer with different maturities, instruments acquired at different prices, and the valuation of debt instruments at amortized cost, taking into account provisions for expected credit losses. It also clarifies the circumstances under which reporting under FONDOS02 may be omitted when there are no derivative transactions subject to reporting.

• Valuation and reporting of non-redeemable investment funds (Questions No. 5, 15 and 16):

It is clarified that, where these funds do not have updated valuations available, they must maintain the latest valuation reported to the CMF, without this affecting their daily reporting obligations under FONDOS05. In particular, actual movements involving contributions, redemptions, units and unitholders must be reported as they occur. Furthermore, certain financial fields may be reported as zero while the fund has not yet obtained its first valuation.

• Expenses, fees and annual cost rate (Question No. 8):

Expenses and fees must be reported according to their actual accrual, allocation, reimbursement or charge to the fund or series, as applicable. For purposes of calculating the annual cost rate (“TAC”), where daily valuations are not available, the fund's net asset value must remain unchanged throughout the periods for which no updated valuation is available.

• Unitholders and omnibus accounts (Questions No. 6, 7, 11, 13 and 17):

The document addresses the criteria for reporting unitholders under FONDOS05 and FONDOS06, including the treatment of omnibus accounts depending on whether the AGF knows the identity of the underlying end clients, as well as funds or series with no unitholders and units held in co-ownership. It also clarifies that actual changes to the register of contributors must be reflected daily in FONDOS05.

• Collateral (Questions No. 9 and 10):

The document clarifies the reporting criteria applicable to collateral, including the transitional regime governing collateral established or updated prior to the entry into force of NCG No. 532. In particular, collateral that had not been updated as of May 31, 2026, was required to be reported no later than September 30, 2026, whereas collateral established or updated between January 1 and May 31, 2026, was exempt from such reporting requirement. Collateral established or updated after May 31, 2026, must be reported within a maximum period of ten business days. The document also clarifies the criteria for determining the value of collateral associated with short-selling transactions and how such collateral must be treated when it cannot be identified on a transaction-by-transaction basis.

The publication of these clarifications seeks to standardize reporting criteria and facilitate AGFs' compliance with their information reporting obligations, particularly in cases where the frequency of fund valuations differs from the reporting frequency required under the applicable regulations.

For further information on this matter, please contact Christian Schiessler (cschiesslerq@jdf.cl) and/or María Jesús Pérez (mjperez@jdf.cl).