The purpose of this Policy is to establish procedures to ensure the preservation of value and liquidity of Electronic Currencies issued by FacilitaPay in the context of the institution's management of FacilitaPay Accounts. This Policy was developed in accordance with BCB Resolution No. 96/21, BCB Resolution No. 198/22, BCB Resolution No. 80/21, BCB Resolution No. 237/22, BCB Resolution No. 208/21, and FacilitaPay's risk management policies, strategies, routines, and procedures.

This Policy is applicable to all FacilitaPay Employees who perform Liquidity Risk management for FacilitaPay and/or manage FacilitaPay Accounts.

When issuing Electronic Currencies in FacilitaPay Accounts, FacilitaPay must maintain liquid resources corresponding to the balances of Electronic Currencies held in FacilitaPay Accounts, calculated at the closing of the regular operating schedule of STR participants, plus: (i) balances of electronic currencies in transit between FacilitaPay Accounts; and (ii) amounts received by FacilitaPay for credit to a FacilitaPay Account, while not available for free movement by the end-user holder of the recipient FacilitaPay Account.

All such liquid resources, made available by Clients in FacilitaPay Accounts, must be allocated by FacilitaPay exclusively to: (i) cash, in the CCME; or (ii) federal government securities, registered with SELIC.

The allocation of resources in CCME must occur considering the daily position recorded at the closing of the regular operating schedule of participants in the STR, before the start of the additional window for contributions to the Instant Payment Account (PI Account), as addressed in the STR Regulations.

In the case of allocation to federal government securities registered with SELIC, the allocation can be made including through repurchase agreements, held in a specific account in the aforementioned system, based on the daily position recorded at the closing of SELIC.

In the repurchase agreements mentioned above, one of the contracting parties must be a multiple bank, commercial bank, or savings bank qualified to carry out these operations. The free movement agreement of securities subject to resale commitment in the aforementioned repurchase agreements is prohibited.

FacilitaPay may only allocate Client resources applied in FacilitaPay Accounts to federal government securities that fall under the following conditions: (i) they are denominated in reais and acquired in the secondary market; (ii) they have a maximum term of 540 (five hundred and forty) days until maturity; and (iii) they are not referenced in foreign currency.

FacilitaPay performs daily submission to the BCB of information on the accounting balances of FacilitaPay Accounts, of an active and passive nature, referring to Electronic Currency, under the terms of BCB Resolution No. 208/22.

Gains resulting from the application of Electronic Currency balances in federal government securities are freely movable by FacilitaPay.

The remuneration calculated based on the SELIC Rate using the following formula: R = S x [(1 + Selic)^(1/252) – 1], where:

(a) R = remuneration to be credited, expressed with 2 (two) decimal places, with mathematical rounding;

(b) S = balance subject to remuneration; and

(c) Selic = annual SELIC Rate, in unitary format, expressed with 4 (four) decimal places, referring to the date of the balance to be remunerated. The aforementioned remuneration will be credited to the CCME on the next business day by 4:30 PM (sixteen hours and thirty minutes).

Debit or credit transfers to the CCME are carried out through messages from the Electronic Currency-Related Payment Services Group (SME Services Group) and messages from the Liquidity Services Group for Instant Payment Account (LPI Services Group), from the National Financial System Services Catalog, observing the operating time schedules of the STR.

The debit transfer from the CCME is commanded by FacilitaPay itself.

Returns of improper transfers involving the CCME must be commanded by the institutions within sixty minutes after the respective credit, observing that such returns must occur in a single command and correspond to the total amount originally received by FacilitaPay.

The resource transfer messages of the SME Services Group are available for sending during operation under Internet Contingency and Telephone Contingency regimes as addressed in the Regulation annexed to BCB Resolution No. 105, of June 9, 2021.

In order to control and mitigate liquidity risk, processes have been defined and developed with the objective of monitoring activities, addressing occurrences mitigating liquidity risk and suggesting improvements

Such processes, risk identification, contingency plans, and liquidity risk management structure can be found in a specific policy ("Liquidity Contingency and Mitigation Policy").

This Policy must remain available to the BCB and be approved and reviewed, with a minimum frequency of 1 (one) year, by FacilitaPay's Senior Management.