Guidelines on the Submission of the Self-Assessment Checklist as part of the Submission of Audited Financial Statements

OFFICE OF THE DEPUTY GOVERNOR I FINANCIAL SUPERVISION SECTOR MEMORANDUM NO. M-2026- 024 _________ To : ALL COVERED BSP-SUPERVISED FINANCIAL INSTITUTIONS Subject : Guidelines on the Submission of the Self-Assessment Checklist as part of the Submission of Audited Financial Statements To reinforce accountability on the completeness and accuracy of Audited Financial Statements (AFS) submitted to the Bangko Sentral ng Pilipinas (BSP), all covered BSP-Supervised Financial Institutions (BSFIs) shall accomplish and submit the AFS-Self Assessment Checklist (SAC) (attached as Annexes A, A-1, A- 2) together with the AFS reports based on the following guidelines beginning with the 2025 AFS: 1. The AFS-SAC can be downloaded from the BSP website at www/bsp.gov.ph/SES/reporting_templates or directly requested from BSP-Department of Supervisory Analytics (DSA) through [email protected] if access to the website is unavailable. Requesting said file shall follow the prescribed format as the subject, [REQUEST] AFS – SAC Template. 2. Covered BSFls shall electronically transmit (in word document and in Portable Document Format – PDF) the SAC, not later than 120 calendar days after the close of the calendar year or fiscal year adopted by the covered BSFI, duly certified and signed by the authorized official of the reporting BSFI, to the DSA as follows: Type of Institution Email Address File Name File Format Universal / Commercial [email protected] Banks Digital Banks [email protected] Rural and Cooperative [email protected] Banks Thrift Banks [email protected] Non-Banks with Quasi- [email protected] Banking Functions Non-Stock Savings and Reports in [email protected] Word Loan Association Trust Corporations [email protected] AFS-SAC- Document basis1 and Portable Non-Bank Financial Document Institutions w/o Quasi- [email protected] Format (PDF) Banking Functions Electronic Money [email protected] Issuers Virtual Currency [email protected] Exchanges dsapawnshop- Pawnshops [email protected] Money Services [email protected] Businesses 1 Where basis is the type of report (i.e., SOLO, CONSO or TRUST), e.g., AFS_SAC_SOLO, AFS_SAC_CONSO, and AFS_SAC_TRUST

using the following prescribed format as subject: AFS<space><BSFI Name>,<space><Reference period in dd Month yyyy> For Example: To : [email protected] Subject : AFS <BSFI Name>, 31 December 2025 3. Only electronic submissions originating from officially registered e-mail address/es of the BSFIs shall be recognized and accepted by the DSA. The same registered e-mail address/es shall be used by the DSA to electronically acknowledge the submitted reports. Hard copy submissions shall not be accepted. 4. Report submission should continue to comply with existing BSP reporting standards. Only files prescribed by the BSP for the report shall be accepted and validated, subject to applicable sanctions for reporting violations as provided under existing regulations. 5. Covered BSFIs that are unable to transmit electronically may coordinate with DSA for assistance. Queries regarding AFS Reports related regulations, and guidelines should be sent via e-mail to the appropriate supervising department following the prescribed format as the subject, [INQUIRY] AFS Reports. For compliance. Digitally signed by Lyn I. Javier LYN I. JAVIER Date: 2026.06.05 13:52:50 +08'00' Deputy Governor Atts.: As stated. 05 June 2026 ___

NAME OF BANK Audited Financial Statements Self-Assessment Checklist 31 December YYYY COMPLIANCE REMARKS [YES / NO] I. Regulatory and reportorial requirements under Section 174 of the Manual of Regulations for Banks (MORB). 1. Banks shall cause an annual financial audit by an PLEASE SELECT external auditor (EA) included in the List of Selected EAs for BSFIs not later than 30 calendar days after the close of the calendar or fiscal year adopted by the bank. 2. The Audited Financial Statements (AFS) required to be PLEASE SELECT submitted shall in all respect be Philippine Financial Reporting Standards (PFRS)/ Philippine Accounting Standard (PAS) compliant. The guidelines under Section 172 shall be adopted. II. Checklist of BSP requirements in the submission of AFS under Appendix 55 of the MORB The AFS shall be submitted by the bank to the appropriate supervising department of the BSP, accompanied by the documentary requirements enumerated under Appendix 55 of the MORB. Deadline: Not later than 120 calendar days* after the close of the calendar year or fiscal year adopted by the Bank *unless otherwise indicated 1. AFS PLEASE SELECT a. Balance Sheet b. Income Statement c. Statement of Changes in Equity d. Statement of Cashflow e. Notes to Financial Statements f. EA opinion AFS of banks with subsidiaries shall be presented side by side on a solo basis (parent) and on a consolidated basis (parent and subsidiaries) 2. Certification by the EA on compliance with the PLEASE SELECT following: a. Confidentiality clause pertinent to read-only access to the Report of Examination; and b. Disclosure requirements under Section 174 and other information that may be required. 3. Reconciliation statement, including copies of adjusting PLEASE SELECT entries on the reconciling items, between the AFS and the prudential reports (i.e., Balance Sheet and Income Statement for bank proper (regular and FCDU) and Financial Reporting Package for Trust Institutions for trust department/ institutions, following the formats in Annexes B and C of Appendix 55 (for the bank proper and for the trust department, respectively). 4. Letter of Comments (LOC) indicating material PLEASE SELECT weaknesses in internal control and risk management system as well as other issues, which may include findings on the quality of governance, that should be brought to the attention of the Board of Directors (Board)/ Management along with the recommendations for corrective action. Otherwise, a certification by the EA that there are no issues noted in the course of the audit to warrant the submission of the LOC. 5. Copy of the board resolution (containing the date of PLEASE SELECT receipt of the AFS and LOC by the Board) showing the actions on the AFS and the submitted LOC, if any. In case of foreign banks with branches in the Philippines, in lieu of the board resolution, a report by File Ref. No. FSD I-2025-09-0189a-FSD1-Oth-BPIDB * Page 1 of 3 Classification: GENERAL

the Country Head on the action taken by management (head office or regional) on the AFS and LOC, if any. 6. Report of EA on any matter adversely affecting the PLEASE SELECT condition or soundness of the BSFI, such as, but not limited to the following cases: a. Any material finding involving fraud or error; b. Actual or potential losses the aggregate of which amounts to at least 10% of the consolidated total assets of the BSFI; c. Significant doubt as to the ability of the BSFI to continue as a going concern; d. Material breach of laws or BSP rules and regulations such as but not limited to prescribed capital and liquidity ratios, significant deficiency in allowance for credit losses (ACL), material weaknesses in fair value measurement methodology, significant vulnerabilities to money laundering and combating the financing of terrorism; e. Material internal control weaknesses which may lead to financial reporting problems; and f. Findings on matters of corporate governance that may require urgent action by the BSP. In case there are no matters to report (e.g., fraud, dishonesty, breach of laws, etc.), a notarized certification that there is none to report. Deadline: Within 15 calendar days upon discovery. 7. AAR - For banks under the concurrent jurisdiction of the PLEASE SELECT BSP and Commission on Audit (COA). Deadline: Within 40 calendar days after receipt of the AAR by the Board of Directors. III. Disclosure requirements to the AFS under Annex A of Appendix 55 of the MORB Page1 Remarks 1. Notes to the financial statements a. Capital position on solo and consolidated bases. These shall include Common Equity Tier 1 (CET1) capital (applicable only to universal and commercial banks), Tier 1 capital, Total Qualifying Capital, Total Risk-Weighted Assets; Capital Adequacy Ratio (CAR), Tier 1 ratio, and CET 1 ratio (applicable only to universal and commercial banks), as applicable; b. Leverage ratio and Total Exposure Measure both on solo and consolidated bases; c. Liquidity position on solo and consolidated bases. It shall include the Liquidity Coverage Ratio (LCR) and Net Stable Funding Ratio (NSFR); In the case of stand-alone thrift banks, rural banks, cooperative banks and quasi-banks, only the Minimum Liquidity Ratio (MLR) shall be disclosed. d. Provisioning methodology and key assumptions used in determining ACL; e. Accounting policies which shall include, but not limited to, general accounting principles, valuation policies for financial instruments and Real and Other Properties Acquired (ROPA), and policies on securitizations, foreign currency translations, and repurchase agreements. 2. Supplementary Information 1 Specify the Range of Covered Pages per Part (i.e., 1 , 12-14) File Ref. No. ____ * Page 2 of 3 Classification: GENERAL

a. Basic quantitative indicators of financial performance such as return on average equity, return on average assets and net interest margin; b. Description of capital instruments used; c. Significant credit exposures (30.0% of the total loan portfolio or 10.0% of Tier 1 capital) as to industry/economic sector; d. Breakdown of total loans as to: (i) security (secured, including type of security, and unsecured), and (ii) status (performing and non-performing per product line); e. Information on related party loans broken down as follows: COMPLIANCE [YES / NO] Particulars Related Party Loans DOSRI Loans (Inclusive of DOSRI Loans) Outstanding loans PLEASE SELECT PLEASE SELECT Percent of DOSRI/Related Party PLEASE SELECT PLEASE SELECT loans to total loan portfolio Percent of unsecured PLEASE SELECT PLEASE SELECT DOSRI/Related Party Loans to total DOSRI/Related Party loans Percent of past due DOSRI/Related PLEASE SELECT PLEASE SELECT Party loans to total DOSRI/Related Party loans Percent of non-performing PLEASE SELECT PLEASE SELECT DOSRI/Related Party Loans to total DOSRI/Related Party loans f. Aggregate amount of secured liabilities and assets pledged as security; and g. Nature and amount of contingencies and commitments arising from off-balance sheet items [include direct credit substitutes (e.g., export LCs confirmed, underwritten accounts unsold), transaction-related contingencies (e.g., performance bonds, bid bonds, standby LCs), short-term self- liquidating trade-related contingencies arising from the movement of goods (e.g., sight/usance domestic LCs, sight/usance import LCs), sale and repurchase agreements not recognized in the balance sheet; interest and foreign exchange-rate related items; and other commitments. Prepared by: Certified Correct: Name Name Position (BSFI) Position (BSFI) Date: Date: 1 Specify the Range of Covered Pages per Part (i.e., 1 , 12-14) File Ref. No. ____ * Page 3 of 3 Classification: GENERAL

NAME OF BSFI-NBFI Audited Financial Statements Self-Assessment Checklist 31 December YYYY REPORTORIAL, MEASUREMENT, AND DISCLOSURE COMPLIANCE REMARKS REQUIREMENTS [YES / NO] I. Regulatory and reportorial requirements under Sections 154-S and 163-S, 134N and 133N of the Manual of Regulations for Non-Bank Financial Institutions (MORNBFI). 1. NBFIs shall cause an annual financial audit by an PLEASE SELECT external auditor (EA) included in the List of Selected EAs for BSFIs not later than 30 calendar days after the close of the calendar or fiscal year adopted by the NBFI. 2. The Audited Financial Statements (AFS) required to be PLEASE SELECT submitted shall in all respect be Philippine Financial Reporting Standards (PFRS)/Philippine Accounting Standard (PAS) compliant. The guidelines under Section 141-N shall be adopted. II. Checklist of BSP requirements in the submission of AFS under Appendix S-17, N-20 of the MORNBFI. The AFS shall be submitted by the NBFIs to the appropriate supervising department of the BSP, accompanied by the documentary requirements enumerated under the pertinent BSP regulations. Deadline: Not later than 120 calendar days* after the close of the calendar year or fiscal year adopted by the Bank *unless otherwise indicated 1. AFS PLEASE SELECT a. Balance Sheet b. Income Statement c. Statement of Changes in Equity d. Statement of Cashflow e. Notes to Financial Statements EA opinion 2. Certification by the EA on compliance with the PLEASE SELECT following: a. Confidentiality clause pertinent to read-only access to the Report of Examination; and Disclosure requirements under Section 174 and other information that may be required. Reconciliation statement, including copies of adjusting PLEASE SELECT entries on the reconciling items, between the AFS and the prudential reports submitted to the Bangko Sentral (i.e. balance sheet and income statement for NBFI) following the format in Annexes A Letter of Comments (LOC)1 indicating material weaknesses PLEASE SELECT in internal control and risk management system as well as other issues, which may include findings on the quality of governance2, that should be brought to the attention of the proprietor/ partners/management/ board of directors along with the recommendations for corrective action. Otherwise, a certification by the EA that there are no issues noted in the course of the audit to warrant the submission of an LOC. 3. Copy of the board resolution showing the actions on the PLEASE SELECT AFS and the submitted LOC, if any. For single proprietorship pawnshops and MSBs, the proprietor shall issue a certification or report on actions taken. 4. The external auditor shall report directly to the Bangko PLEASE SELECT Sentral the following: a. Any material finding involving fraud or error; 1 LOC or equivalent letter to proprietor/partners/management/board of directors 2 Reportable issues on the quality of governance shall only pertain to financial reporting matter. File Ref. No. FSD I-2025-09-0189a-FSD1-Oth-BPIDB * Page 1 of 4 Classification: GENERAL

b. Actual or potential losses the aggregate of which amounts to at least 10% of the consolidated total assets of the NBFI; c. Significant doubt as to the ability of the BSFI to continue as a going concern; d. Material breach of laws or BSP rules and regulations such as but not limited to prescribed capital and liquidity ratios, significant deficiency in allowance for credit losses (ACL), material weaknesses in fair value measurement methodology, significant vulnerabilities to money laundering and combating the financing of terrorism; e. Material internal control weaknesses which may lead to financial reporting problems; and f. Findings on matters of corporate governance that may require urgent action by the BSP. In case there are no matters to report (e.g., fraud, dishonesty, breach of laws, etc.), a notarized certification that there is none to report. Deadline: Within 15 calendar days upon discovery. 5. AAR - For banks under the concurrent jurisdiction of the BSP and Commission on Audit (COA). Deadline: Within 40 calendar days after receipt of the AAR by the Board of Directors. IV. Presentation, Recognition and Measurement Requirements in compliance with the PFRS and PAS Page1 Remarks 1. Notes to the Financial Statements Explicit and unreserved statement of Compliance with PFRS/PAS in the notes. Financial statements should not be described as PFRS/PAS compliant unless they meet with all the requirements of the standards. 2. BSP disclosure requirements on the reclassification of financial assets. Appendix M-7 Annex B Disclosure Requirements to the AFS. RTCs/MCs/FXDs/EMIs/VASPs shall include the following supplementary information at the end of the notes to the financial statements 1. Total volume/value of remittance and/or money changing/foreign exchange, and/or electronic money transactions (absolute value) with breakdown as to (1) domestic and/or foreign, and (2) transactions facilitated through VC (using the prescribed template) 2. Total and breakdown of liquid assets equal to the electronic balance, including the total amount held in trust for the purpose of e-money balance liquidation 3. Return on Average Equity 4. Return on Average Assets Additional required disclosures to the notes to the financial statements for NSSLAs, as provided under Appendix S- 15-b of the MORNBFI 1. Capital position which shall include Total Risk- Weighted Assets and Capital-to-Risk Assets Ratio; 2. Leverage ratio and Total Exposure Measure 3. Liquidity position which shall include minimum liquidity ratio; 1 Specify the Range of Covered Pages per Part (i.e., 1 , 12-14) File Ref. No. ____ * Page 2 of 4 Classification: GENERAL

4. Provisioning methodology and key assumptions in providing allowance for credit losses; and 5.Accounting policies which shall include, but shall not be limited to, general accounting principles, valuation policies for financial instruments and Real and Other Properties Acquired (ROPA), and policies on foreign currency translations. Supplemental information, as provided under Appendix S-17 (Annex B) of the MORNBFI: 1. Basic quantitative indicators of financial performance such as (a) return on average equity (b) return on average assets and (c) net interest margin; 2. Breakdown of total loans as to (a) security (secured, including type of security, and unsecured); and (b) status (performing and non-performing) per product line; 3. Breakdown of Exposures to Trustees, Officers, and their Related Interests (TORI) as to: (a) Outstanding loans to TORI (b) Percent of TORI loans to total loan portfolio (c) Percent of unsecured TORI loans to total TORI loans (d) Percent of past due TORI loans to total TORI loans (e) Percent of non-performing TORI loans to total TORI loans 4. Aggregate amount of secured liabilities and assets pledged as security; and 5. Nature and amount of contingencies and commitments arising from off-balance sheet items (include late deposit/payment received, items held as collateral, deficiency claims; receivable and other contingent accounts). Appendix P-18 Annex P-18-b Disclosure Requirements to the AFS (Appendix to Section 901-N Pawnshops shall include the following supplementary information at the end of the notes to the financial statements 1. Details of liabilities on borrowings, particularly: i. Number of creditors; ii. Portion, as of end of the reference calendar year, used for the purpose of acquiring fixed assets for business operations 2. If with corollary business, disclosure of total liabilities and income directly attributable to said business. Pawnshops with money service business 1 Specify the Range of Covered Pages per Part (i.e., 1 , 12-14) File Ref. No. ____ * Page 3 of 4 Classification: GENERAL

operations shall also comply with disclosures required thereto under Section 901-N. 3. Total Borrowings to Pledge Loans Additional information from Pawnshops and MSBs: Assessment of compliance with minimum capital requirements. Prepared by: Certified Correct by: Name Name Position (BSFI) Position (BSFI) Date: Date: 1 Specify the Range of Covered Pages per Part (i.e., 1 , 12-14) File Ref. No. ____ * Page 4 of 4 Classification: GENERAL

NAME OF TRUST CORPORATION Audited Financial Statements Self-Assessment Checklist 31 December YYYY REPORTORIAL, MEASUREMENT, AND DISCLOSURE COMPLIANCE REMARKS REQUIREMENTS [YES / NO] Regulatory and reportorial requirements on the Annual Financial Audit as required under Section 181-T and Appendix T-6 of the Manual of Regulations for Non-Bank Financial Institutions (MORNBFI) 1. Trust Corporations (TCs) shall cause an annual financial PLEASE SELECT audit by an external auditor (EA) included in the List of Selected External Auditors not later than 30 calendar days after the close of the calendar year or the fiscal year adopted by the TC. The financial audit shall cover the financial statements of both the TC proper and the trust and managed funds of the TC. 2. The Audited Financial Statements (AFS) shall be PLEASE SELECT submitted by the TC to the appropriate supervising department of the Bangko Sentral accompanied by the documentary requirements as enumerated under Appendix T-6. Deadline: Not later than 120 calendar days after the close of the calendar year or the fiscal year adopted by the TC. a. AFS PLEASE SELECT b. Certification by the EA on compliance with the PLEASE SELECT following: • Confidentiality clause pertinent to read-only access to the Report of Examination; and • Disclosure under Section 132-T and other information that may be required. c. Reconciliation statement, including copies of PLEASE SELECT adjusting entries on the reconciling items, following the formats in Annexes a and b of Appendix T-6, which shall be between the: (a) AFS and FRP; and (b) AFS and the FRP for Trust Institution (FRPTI) for each of the general categories of contractual relationships (i.e., UITF trust, institutional trust and individual trust; other fiduciary; institutional-agency, and individual-agency; and special purpose trust) of the TC with its clients. d. LOC indicating material weaknesses on internal PLEASE SELECT control and risk management system as well as other issues, which may include findings on the quality of governance, that should be brought to the attention of the Board/Management along with the recommendations for corrective action. Otherwise, a certification by the external auditor that there are no issues noted in the course of the audit to warrant the submission of the LOC. e. Copy of the board resolution showing the actions PLEASE SELECT on the AFS and the submitted LOC, if any. f. The EA shall report directly to the Bangko Sentral PLEASE SELECT the following: • Any material finding involving fraud or error; • Actual or potential losses the aggregate of which amounts to at least ten percent (10%) of the consolidated total assets of the TC; • Significant doubt as to the ability of the TC to continue as a going concern; • Material breach of laws or Bangko Sentral rules and regulations such as but not limited to prescribed capital and liquidity ratios, File Ref. No. FSD I-2025-09-0189a-FSD1-Oth-BPIDB * Page 1 of 2 Classification: GENERAL

significant deficiency in allowance for credit losses, material weaknesses in fair value measurement methodology, significant vulnerabilities to money laundering and countering the financing of terrorism; • Material internal control weaknesses which may lead to financial reporting problems; and • Findings on matters of corporate governance that may require urgent action by the Bangko Sentral. Deadline: Within 15 calendar days from discovery. In case there are no matters to report (e.g., fraud, dishonesty, breach of laws, etc.), a notarized certification that there is none to report. Deadline: Not later than 120 calendar days after the close of the calendar year or fiscal year adopted by the TC. Disclosure Requirements in the notes to the Audited Financial Statements under Section 181-T (Annex C of Appendix T-6) Page1 Remarks a. Notes to the financial statements (1) Minimum required capital pursuant to Section 113T; (2) Provisioning methodology and key assumptions used in determining allowance for credit losses. (3) Accounting policies which shall include, but not limited to, general accounting principles, valuation policies for financial instruments and Real and Other Properties Acquired (ROPA). b. Supplementary information (1) Basic quantitative indicators of financial performance such: (i) Return on average equity (ii) Return on Average Assets (%) (iii) Percentage of total trust fees to total AUM (%) (2) Total outstanding investment, loans and other credit accommodations to TC’s DOSRI and related parties with name of DOSRI/related parties, and breakdown, if applicable, as to (i) security (secured, including type of security; and unsecured) and (ii) status (performing and non-performing); (3) Large exposures as defined under 203T; (4) Nature and amount of contingencies and commitments arising from off-balance sheet items, if any; and (5) Aggregate amount of secured liabilities and assets pledged as security Prepared by: Certified Correct by: Name Name Position (Trust Corp) Position (Trust Corp) Date: Date: 1 Specify the Range of Covered Pages per Part (i.e., 1 , 12-14) File Ref. No. ____ * Page 2 of 2 Classification: GENERAL