The eleven dark months
An audit reads a closed period once a year. What a fund prices is the gap between two audit dates, and that gap is where every loss in this market has been found after the fact.
A fund does not price the audited period. It prices the gap between two audit dates, and in Mexican non-bank lending that gap has a measurable cost: the sector reports a past-due ratio roughly half its adjusted one, cohorts inside a single healthy book differ nearly fourfold, and when reporting stops, ratings are withdrawn rather than lowered.
None of what follows says Mexican lenders are dishonest. It says the discount a fund applies for not knowing is not a mood. It is a number, it is visible in public documents, and in the failures of the past five years it was paid in cash by whoever could not see the collections.
The interval is the standard revaluation cycle, not a Mexican defect
The Financial Stability Board put the cycle in writing this year: valuations in private credit «are updated infrequently, often on a quarterly basis, which may be adequate in normal market conditions but less so under stress».
The IMF had named the mechanism two years earlier. Private credit loans «tend to suffer from stale valuations because of the absence of secondary markets, limited comparable transactions, and irregular appraisals», and the failure mode it forecast was «a delayed realization of losses followed by a spike in defaults and large valuation markdowns». Delay, then spike. That is a statement about timing, and timing is what a reporting cycle controls.
Mexico is where that general condition meets a statutory perimeter which removes the backstops a foreign investor assumes are there.
How the two kinds of credit arrive at a value, and who does the arriving.
- A price exists every day, made by somebody with money at risk.
- A secondary market, so a disagreement about value is settled by a trade.
- Comparable transactions to mark against.
Bad news arrives as a price move, continuously, in small pieces.
- Valuations updated infrequently, often quarterly, which the Financial Stability Board records as adequate in normal conditions and less so under stress.
- No secondary market, limited comparable transactions, irregular appraisals.
- The description in between is written by the party being valued.
Bad news arrives as a revision, at a date, in one piece.
The interval is not a Mexican defect and not a sign of a bad lender. It is the standard revaluation cycle of the whole asset class, and the failure mode that follows from it was named in advance: a delayed realisation of losses, then a spike in defaults and large valuation markdowns. Delay, then spike, is a statement about timing, and timing is what a reporting cycle controls.
In Mexico the gap is written into the statute rather than left over by practice
A SOFOM, sociedad financiera de objeto múltiple, is the corporate form through which most Mexican non-bank lending is done. It lends, leases and factors, and it takes no deposits. It exists in two variants: the SOFOM ER, entidad regulada, under full prudential supervision by the Comisión Nacional Bancaria y de Valores, and the SOFOM ENR, entidad no regulada, which is the majority form. Who these lenders are and on whose money they lend is mapped separately.
Whether a SOFOM is regulated is a question about its shareholders, not about its size or its risk. Article 87-D of the Ley General de Organizaciones y Actividades Auxiliares del Crédito makes a SOFOM regulated principally where it «mantenga vínculos patrimoniales con una institución de crédito», that is, where a bank owns part of it. Regulation follows the share register. It does not follow the size of the book, the leverage on it, or whether third-party capital funds it.
For the non-regulated majority the supervisory relationship is narrower than most foreign investors expect. The CNBV states the whole of it in one line: SOFOMES ENR are subject to CNBV supervision and must comply with obligations «en materia de PLD/FT», that is, anti-money-laundering and counter-terrorist financing (CNBV, SOFOMES ENR Preguntas Frecuentes). Its Informe Anual 2024 repeats the perimeter, describing these entities as «supervisadas exclusivamente en materia de PLD/FT», and refers readers to CONDUSEF's SIPRES registry for the population count rather than holding that count itself.
The intensity of supervision matches the scope. CONDUSEF carried out 28 scheduled verification visits to SOFOM ENR in the whole of January to June 2025, against a registered universe in the thousands.
of supervision in six months, across a registered universe in the thousands
CONDUSEF scheduled verification visits to SOFOM ENR, January to June 2025.
Nor is there a periodic financial return anywhere. Article 87-B fraction V of the LGOAAC obliges a SOFOM to provide information and documentation to the finance ministry, the CNBV, Banco de México and CONDUSEF, with a fine for non-compliance. It is a duty to answer, not a duty to file. Somebody has to ask first, and in the ordinary case nobody does.
Below a tax threshold there is no legal obligation to be audited at all
The premise most funds start from, one audited period a year, is more generous than the law. Under article 32-A of the Código Fiscal de la Federación an audit dictamen by a registered public accountant is compulsory only for corporates with prior-year accumulable income at or above MXN 2,013,710,870, or with shares listed among the investing public. It is merely optional above income of MXN 157,785,270, assets of MXN 124,650,380, or 300 employees.
Most Mexican non-bank lenders sit below the compulsory line. Where an audit exists for them it exists because a facility agreement demanded it or because the company chose it, not because a statute imposed it. Where the dictamen does apply, article 32-A sets its delivery date at 15 May of the following year. For a 31 December period end that is 135 days later.
What a capital provider can independently confirm across a year, against what the lender already transmits in the same year.
The verified window is one closed period that arrives on 15 May at the earliest, and for most lenders it is contractual rather than legal. Meanwhile a loan-level file leaves the building every month and goes to a credit bureau.
The rulebook that stops a restructured loan looking healthy binds banks, not the lenders a fund is buying
Mexico has a precise answer to deterioration being postponed by restructuring. It is CNBV Criterio B-6, Cartera de crédito, in Anexo 33 of the Circular Única de Bancos. B-6 lets a restructured loan leave the past-due book only on evidence of pago sostenido, defined as payment without delay of the full amount due «como minimo de tres amortizaciones consecutivas».
Cartera vencida, for a reader meeting the term here, is the past-due portion of a Mexican loan book. Around the definition of how to leave it sit clauses whose only purpose is to close specific routes back to a healthy-looking book, and each one exists because the route exists.
- A restructured overdue loan stays in cartera vencida until sustained payment is evidenced.
- A loan over one year with a single bullet payment, restructured mid-life, is treated as overdue outright.
- A renewal where the borrower has not paid accrued interest and 25% of the original principal is treated as overdue until sustained payment appears.
- Early payment does not count as sustained payment.
- Write-offs, haircuts, waivers and discounts do not count as payments at all.
- Where several credits to one borrower are consolidated, the whole balance takes the treatment of the worst of them.
The applicability point is the whole argument. HR Ratings states it for the sector in writing: no standardised methodology is observed across non-bank financial intermediaries for calculating reserves, which «deriva del alto porcentaje de entidades que operan bajo la figura de SOFOM, Entidad No Regulada, por lo que no tienen un requerimiento específico de apegarse a la metodología establecida por la CNBV».
Who Criterio B-6 of the banking rulebook applies to, and who is outside it.
- Banks, under the Circular Única de Bancos.
- A SOFOM ER, through the group it belongs to.
- Consequence: a restructured overdue loan stays in the past-due book until sustained payment is evidenced across at least three consecutive scheduled payments.
Early payment does not count. Write-offs, haircuts, waivers and discounts do not count as payments at all.
- A SOFOM ENR, which is the majority form.
- No standardised methodology for calculating reserves is observed across the sector, which the rating agency attributes directly to the share of entities operating as unregulated SOFOMes.
- Consequence: every definition behind every metric is management's own, and it can move between periods.
Two lenders can publish the same ratio and mean two different things by it, with no way for a reader to tell.
The sophistication of the bank rule is a map of what happens where the rule is absent. Every clause above exists because the route it closes exists, and none of them closes for the majority form. That is not an accusation. It is the reason two Mexican lenders' past-due numbers are not the same unit of measurement.
The sophistication of the bank rule is a map of what happens where the rule is absent.
Even for the entities the rule does bind, recognition can be switched off by administrative act. Under the COVID-era criterios contables especiales issued through oficio P325/2020, restructured loans stayed in cartera vigente because paragraph 79 of Criterio B-6 was disapplied, and those loans «no fueron reportados como créditos vencidos ante las sociedades de información crediticia».
Without a shared rule there is no shared unit, and the gap between recognised and real is close to double
IMOR, índice de morosidad, is the reported past-due ratio: past-due portfolio over total portfolio. IMOR ajustado adds the write-offs of the trailing twelve months back in, which is the standard way of asking what the book would show if nothing had been removed from it.
For the Mexican non-bank sector the two numbers are not close. HR Ratings measured its sample at IMOR 3.9% against adjusted IMOR 7.1% as of June 2025. In pesos: past-due portfolio of MXN 10,630 million against trailing-twelve-month write-offs of MXN 9,636 million. The write-offs of one year were nearly the size of the entire recognised past-due book.
What the sector reports, against what the same sector removed from its own books over the preceding twelve months.
In pesos the two halves are almost the same size: cartera vencida of MXN 10,630m against castigos of MXN 9,636m over twelve months. A fund underwriting off the reported ratio is underwriting off the half of the picture that has not yet been erased.
The sector's own trade body uses a word with no date in it. ASOFOM reports cartera catastrófica, which its national president Javier Garza Hoeffer described as the equivalent of a bank's cartera vencida, «pero se saca despues de agotar todas las instancias para recuperar el adeudo». A category defined by the exhaustion of collection attempts cannot be dated, and an undated number cannot be compared across two lenders or two quarters.
Restructuring is where the postponement becomes visible when somebody measures it. In Sofagro, a SOFOM ENR, restructured loans were 21.8% of the portfolio at the fourth quarter of 2024 against 12.2% a year earlier, with 68% of that concentrated in five of its ten largest borrowers, while repossessed assets rose from MXN 49.7 million to MXN 177.8 million over the same year (HR Ratings review, BMV, data to 4Q24).
Even the central bank could not hold its series steady. A footnote in Banco de México's Financial Stability Report of December 2025 records that a new and preliminary time series for non-regulated sofomes is shown from June 2023 onwards «due to corrections made by entities in their data submissions».
An annual average is the wrong denominator, because one healthy book swings nearly fourfold by vintage
A vintage, or static pool, is a cohort of loans grouped by the period in which they were originated and tracked over its own life, so the 2019 cohort is never mixed with the 2022 cohort. It is the only view in which an underwriting decision and its consequence appear in the same column.
Default rate above ninety days by origination cohort, in a Mexican non-bank lender that did not default.
An investor shown one blended delinquency number cannot tell a 3.5% cohort from a 13.5% cohort, and the spread inside this one performing lender is wider than the entire reported sector ratio. TIH across the last three mature cohorts is 5.7%, and the published stress case reaches 31.6%.
Age of the newest delivered audited period, day by day across two calendar years, drawn from the statutory calendar alone: a 31 December period end and the 15 May delivery date under CFF article 32-A.
The line falls only twice in two years, on the two delivery dates. Everywhere else it rises, which is the only thing an interval can do.
The shaded stretches are the part of every cycle in which the only audited description of the book is more than a year old, and they run five months in twelve. Nothing here is estimated. It is the arithmetic of two dates, and it is the same for a lender with a perfect book and one with none.
When the description does fail, it fails by withdrawal rather than by drift
The public record of Mexican non-bank losses does not show a delinquency line rising until it becomes untenable. It shows a financial statement being taken back.
On 20 April 2021 Alpha Holding, S.A. de C.V., the issuer behind AlphaCredit, announced that it would restate its financial statements for the years ended 31 December 2019 and 2018 to correct an accounting error in its derivatives position, and stated that the previously issued statements, the 2020 quarterly reports and any other communication relating to those periods «NO DEBEN SER TOMADOS EN CUENTA». Two of the three error categories the company itself listed were loss-recognition items: the provision for credit losses, and reserves for certain receivables.
No payment had been missed. On the following day, per TRACE, the US$300 million notes due 2022 fell more than 40 cents to 35.75 cents on the dollar and the US$400 million notes due 2025 fell around 34 cents. Half the value of the paper moved on a disclosure about the past, which is the cleanest available measurement of what the information itself was worth.
The order of learning was public too. Moody's had already cut the long-term foreign-currency senior unsecured rating to Caa2 from B3 and placed all long-term ratings on review «la semana anterior» to the public announcement, «tras haber sido informada de los errores contables». Alexis Panton of Stifel described everyone else's position at the time as the likelihood that «los inversionistas se mantengan en la oscuridad durante algun tiempo».
The order in which the market learned, at one Mexican issuer, over eight days in April 2021.
- The agency is informedMoody's cuts the long-term foreign-currency senior unsecured rating to Caa2 from B3 and puts all long-term ratings on review, the week before anything is public, after being told of the accounting errors.
- The statements are withdrawnThe issuer announces it will restate 2019 and 2018, and says the previously issued statements, the 2020 quarterly reports and any other communication relating to those periods must not be taken into account. Two of the three error categories it lists are loss-recognition items.
- The price finds outThe US$300 million notes due 2022 fall more than forty cents to 35.75 cents on the dollar; the US$400 million notes due 2025 fall around thirty-four cents.
Read the order rather than the events. The rating moved first, because the agency was told first. The public disclosure came second. The price came third, and it moved more than forty cents on a statement about the past. That is the cleanest available measurement of what the information itself was worth, because nothing about the loans changed in those eight days.
Crédito Real shows the same boundary from the other side. Its last filed financial information on the Bolsa Mexicana de Valores issuer record is the fourth quarter of 2021, timestamped 25 February 2022 at 15:32, sixteen days after the default of 9 February 2022 on a CHF 170 million bond with no grace period. After that entry the index carries one further item, a change of external auditor dated 25 September 2023, and the share series reads SUSPENDIDA.
The 2021 audited financials were never produced. The company «has missed the extended deadline to produce its 2021 audited financials and the first quarterly report for 2022. Without these statements, we are unable to ascertain Crédito Real's current financial status». The rating that priced the paper was last refreshed five days before the default: the Fitch release downgrading the company to «RD» on 9 February 2022 records the date of the last rating update as 4 February 2022.
The reported category had to be rebuilt before anyone could price it
The strongest document in this record is not a rating action. It is the reconciliation the creditor group's advisers performed on the last quarterly report the company filed.
Materials prepared by Jefferies LLC at the request of counsel for the ad hoc creditor group, circulated 10 June 2022 and marked as a preliminary draft subject to material revision, set out a payroll portfolio reconciliation at 31 December 2021: payroll loans of MXN 26,900.3 million, plus advances to distributors of MXN 1,984.7 million, plus direct loans to distributors of MXN 852.8 million, plus other of minus MXN 219.4 million, equal to payroll loans as reported in the fourth-quarter report of MXN 29,518.3 million.
Read plainly, MXN 2,837.5 million of the MXN 29,518.3 million reported as the payroll portfolio at that date, or 9.6%, was advances and direct loans to the distributors who originated the loans rather than loans to payroll borrowers, before a capitalized-interest difference of MXN 573.9 million is considered. No delinquency series would have shown that. A loan tape, the loan-by-loan file listing every contract with its balance, terms, payment history and status, would have shown it on the first day it was read. What a fund asks for in that file, item by item, is a separate piece.
Reconciliation of the payroll portfolio as reported at 31 December 2021, performed by the creditor group's advisers.
Millions of pesos. The two middle columns are the ones that are not loans to payroll borrowers, before a capitalised-interest difference of MXN 573.9 million is considered.
No delinquency series would have shown this, because nothing here is delinquent. A loan tape would have shown it on the first day it was read, since advances to distributors and loans to payroll borrowers are different counterparties on different rows. MXN 2,837.5 million of the MXN 29,518.3 million reported, or 9.6%, was not what the line said it was.
The pattern repeats across names, and the reported ratio never leads it
The Wall Street Journal reported on 8 July 2022 that three Mexican non-bank lenders, Crédito Real, AlphaCredit Capital and Grupo Finmart, «have discredited some financial statements as unreliable» and that «all retained the same auditor for years: Deloitte Mexico».
In a fourth name the auditor left before the numbers were questioned. El CEO reported on 25 July 2024 that Galaz, Yamazaki, Ruiz Urquiza, the Deloitte member firm, resigned as auditor of Operadora de Servicios Mega in March 2024. A PCR Verum rating action of 26 June 2024 records the company reporting cartera vencida of 3.9% for the quarter ended 31 March 2024. In mid-August 2024, when the coupon fell due on its international notes with US$376 million outstanding, the company announced it would defer the payment, noting a thirty-day grace period, and the payment was ultimately missed the following month. CONDUSEF later cancelled the company's registration, published in the Diario Oficial de la Federación on 8 December 2025, a step that under the LGOAAC places a company in dissolution and liquidation without a prior shareholders' resolution.
One Mexican non-bank lender, in the order the public record produced each event.
What happened, and when it became visible
The registration was cancelled the following year, a step that places the company in dissolution and liquidation without a shareholders' resolution.
The reported delinquency figure was not a leading indicator of anything. It was a description of a quarter that had already closed, published after the auditor had already gone, and the market read it as current. Every date on this line is public, and the only one that describes the future is the first.
Read the sequence in order. The auditor left in March, the 3.9% describing March was published in June, the coupon was deferred in August, the payment was missed in September. The reported delinquency figure was not a leading indicator of anything. It was a description of a quarter that had already closed, published after the auditor had already gone.
When information stops arriving, the market does not re-price, it stops pricing
Fitch states the rule procedurally: where the information available is insufficient to form a rating opinion, no rating will be assigned or maintained, and an existing rating is withdrawn if sufficient information ceases to be available.
It has applied that rule to Mexican paper. Fitch withdrew all ratings on Mexarrend, S.A.P.I. de C.V. on 4 April 2023, moving them from «RD» to «WD» due to insufficient information. Seven days later the company, by then operating as Tangelo, confirmed a MXN 655 million write-off of the loan portfolio which it attributed to accounting errors, said it had engaged Kroll Associates Iberia to determine the cause, and warned of possible additional material write-offs.
What each rating action tells a holder, and what it leaves them able to do.
- A new opinion, formed on information the agency has.
- The paper still has a price, so a holder can mark it, sell it or hold it against a limit.
- The market re-prices.
Bad news, priced.
- No opinion at all. Where the information available is insufficient to form one, no rating is assigned or maintained.
- An asset with no rating is one a regulated allocator cannot easily hold, mark or sell.
- The market stops pricing.
No news at all, and that is the event.
Seven days after all ratings on one Mexican lender were withdrawn for insufficient information, the company confirmed a MXN 655 million write-off of the loan portfolio, attributed it to accounting errors and warned of possible further material write-offs. The withdrawal was the earlier signal, and it was not a signal about credit. It was a signal about information.
A downgrade is a price. A withdrawal is the absence of one, and an asset with no price is an asset a regulated allocator cannot easily hold, mark or sell.
The agency covering the sector has published its diagnosis of the whole of it: «the majority of Mexican NBFIs are not subject to regulation... Lack of financial transparency and supervision resulted in accounting errors and strategic deficiencies. Defaulted entities disclosed little information beyond what was required by the limited regulation.» The same note expects «continued delays in regulatory reform». The gap is not closing from the regulatory side on any published timetable.
The loan-level data already exists every month, and it is routed away from the fund
Here is the part that makes the interval absurd rather than merely unfortunate. Article 87-C Bis of the LGOAAC requires that every SOFOM be a user of at least one sociedad de información crediticia, «debiendo proporcionar periódicamente la información sobre todos los créditos que otorgue».
Read that against everything above. The one periodic duty in the statute that touches the loan book is loan-level, covers every credit granted, and runs on a regular cycle. The lender already extracts it, formats it and transmits it. The recipient is a private credit bureau, and the beneficiary is other lenders underwriting the same borrowers. The regulator does not receive it. The fund that financed the book does not receive it.
The eleven dark months are a routing problem, not a data problem.
Nothing in the mechanism requires new information to be created. It requires an existing monthly extract to be pointed at a second destination, on terms the lender agrees to, with the capital provider reading the same file the bureau reads.
recovered by unsecured creditors, while structured paper on the same loans was paid in full
Implied recovery on unsecured claims at 31 December 2024, per the issuer's own filing.
Inside the same failures, the creditors who could see the collections were repaid in full
There is a control group, and it sits inside the collapses themselves. A master collection trust is a trust into which borrower payments are deposited directly, so cash never passes through the originator's own accounts. Aforo, or overcollateralisation, is the excess of pledged receivables over the notes they support. A substitute servicer is a replacement collection agent contracted in advance, so that if the originator stops operating, someone with the right and the systems to collect is already appointed.
Recovery outcome by creditor position across the 2021 to 2025 Mexican non-bank failures.
| Creditor position | What it held | Outcome | Why |
|---|---|---|---|
| Structured | CREALCB 17, CRELCB 19, ALPHACB 18 | Paid in full. ALPHACB 18 fully amortised 22 June 2022, during the concurso | Collections into a master collection trust, aforo 1.35x to 1.89x, pre-contracted substitute servicer |
| Unsecured, Crédito Real | The same loans, one step further from the cash | Implied recovery 20% at 31 December 2024 and 19% at 31 January 2025 | Payroll portfolio not sold, valued at the present value of collections using a 20% discount rate |
| Unsecured, Unifin | The same loans, one step further from the cash | MXN 15.4bn recovered from a MXN 54.5bn past-due portfolio, 28.3% | 78% of the book sat in the over-90-day bucket at 31 October 2023 |
Same loans, same borrowers, same management. What separated par from a recovery near a fifth of the claim was whether the cash could be seen from outside, continuously, and whether somebody else could take over collection without renegotiating anything.
Same loans, same borrowers, same management. What separated full repayment from a recovery near a fifth of the claim was not credit selection. It was whether cash and performance were observable outside the originator, continuously, and whether someone else could take over collection without renegotiating anything.
A lender that routes collections observably, publishes cohort performance instead of a blended average, and lets its capital provider read the tape monthly is not offering reassurance. It is removing a discount that the documents above show being applied, in cents, to everyone who could not be read.
What the same book looks like when it is read continuously
The interval above is a reporting cycle, so what closes it is a shorter one. These are the readings a continuously connected book produces between two audits, on demonstration data.
Outstanding
1,246.8M
MXN, rebuilt from the loan management system rather than submitted
- Borrowers
- 1,842
- Unmeasured
- 173
- Last read
- 01 Aug
One borrower in ten is unmeasured rather than late, and priced as if it were both.
Grey is not a softer red. A grey borrower is current and unmeasurable, and a fund that cannot separate the two prices both as the worse one.
Growth with falling arrears prices a facility. Growth with rising arrears reprices it, and a quarterly summary shows neither.
The covenant is drawn as a line rather than reported as a number, so the distance to a breach is read instead of computed.
Every figure, borrower and counterparty in this block is demonstration data created for illustration. It is not a real portfolio. The instruments are the ones on our analytics page, shown here because the article above is about what cannot be seen between two audits.
Effect is not a bank, a lender, a broker-dealer, an investment adviser or a credit rating agency. Nothing here is investment advice or a recommendation on any security, and no outcome is promised. Public companies are described only from filings, issuer documents, rating actions and reported coverage, in terms of how information reached the market. Every figure carries its source and its as-of date so that a reader can check it rather than take it.
Where every figure on this page comes from19 sources
- 01Financial Stability Board, Report on Vulnerabilities in Private Credit, 6 May 2026.
- 02IMF, Global Financial Stability Report, April 2024, Chapter 2, The Rise and Risks of Private Credit.
- 03Código Fiscal de la Federación, article 32-A. Text current to DOF 9 April 2026; thresholds compiled to DOF 28 December 2025.
- 04Ley General de Organizaciones y Actividades Auxiliares del Crédito, articles 87-B, 87-C Bis and 87-D. Article 87-C Bis added by DOF of 10 January 2014.
- 05CNBV, SOFOMES ENR Preguntas Frecuentes, and Informe Anual 2024.
- 06CONDUSEF, Informe de Autoevaluación Enero-Junio 2025.
- 07CNBV, Circular Única de Bancos, Anexo 33, Criterio B-6, Cartera de crédito.
- 08HR Ratings, Sectorial IFNB's, filed to the BMV, published 9 September 2025, data to June 2025.
- 09HR Ratings, Sofagro review, filed to the BMV, data to the fourth quarter of 2024.
- 10HR Ratings, EXITUCB 24, filed to the BMV, 2024, data to February 2024. The 3.9 multiple is our arithmetic: 13.5 divided by 3.5.
- 11NAFIN, Información complementaria a los estados financieros, 30 September 2022, on oficio P325/2020.
- 12Banco de México, Financial Stability Report, December 2025.
- 13ASOFOM, Javier Garza Hoeffer, via Mundo Ejecutivo Edomex, 11 September 2025.
- 14Alpha Holding, S.A. de C.V., restatement press release, 20 April 2021. Note prices per TRACE, reported by Bloomberg via Yahoo Finanzas, 21 April 2021. Moody's action reported by El Economista, 22 April 2021.
- 15Bolsa Mexicana de Valores, issuer financial information page for CREAL, read 5 August 2026. Fitch Ratings action of 9 February 2022. JMMB Investment and Research, Crédito Real Investor Update, August 2022.
- 16Jefferies LLC and Akin Gump, Consolidated Blowout Materials, 10 June 2022, balances as of 31 December 2021.
- 17The Wall Street Journal, 8 July 2022. El CEO, 25 July 2024. PCR Verum rating action, 26 June 2024. Axis Negocios, 13 September 2024. Diario Oficial de la Federación, 8 December 2025.
- 18Fitch Ratings, The Rating Process, presented 4 March 2025; Mexarrend rating withdrawal, 4 April 2023; Mexican Non-Bank Financials Governance, Regulation Lag Banking System, 27 November 2023. Company release via PR Newswire, 11 April 2023.
- 19Crédito Real, Announces Chapter 15 Recognition, Annex I, 12 March 2025. Unifin, final restructuring plan, 2 January 2024. Issuer and BMV documents on CREALCB 17, CRELCB 19 and ALPHACB 18, 2022.
Questions this raises
- What exactly are the eleven dark months?
- The eleven dark months are the interval between two verified reporting points, during which a capital provider reads a description of the loan book written by the lender itself. The Financial Stability Board records that private credit valuations are updated quarterly at best, so the interval belongs to the standard cycle rather than to an exception.
- Is a SOFOM ENR unsupervised?
- No. A SOFOM ENR is supervised by the CNBV, but only for anti-money-laundering and counter-terrorist-financing compliance, per the CNBV's own FAQ and its Informe Anual 2024. It files no periodic financial return describing its loan book to the CNBV, Banco de México or CONDUSEF.
- Is a Mexican non-bank lender required to be audited?
- Not necessarily. Under article 32-A of the Código Fiscal de la Federación an audit dictamen is compulsory only above MXN 2,013,710,870 of prior-year accumulable income or for companies with publicly listed shares. Where it does apply, the statutory delivery date is 15 May, which is 135 days after a 31 December period end.
- Why is adjusted IMOR a better starting point than reported IMOR?
- Reported IMOR counts only loans still on the book and still classified as past due, while adjusted IMOR adds back the write-offs of the previous twelve months. For the Mexican non-bank sample those were 3.9% and 7.1% as of June 2025, so the reported figure omits erased exposure roughly equal to the exposure it shows.
- Does continuous monitoring replace the audit?
- No. An audit is an independent opinion on a closed period and nothing here substitutes for it. Monitoring covers the interval between audits, which is where, on the record above, the losses in these cases surfaced.