What cartera vencida means for a Mexican lender
The CNBV day counts that move a Mexican loan into cartera vencida, why banks call it etapa 3 since 2022, and why an unregulated SOFOM's number needs its own rule checked.
Cartera vencida is the past-due part of a Mexican loan book. For banks and regulated lenders the regulator fixes when a loan enters it: 30 days late for a single payment at maturity, 90 days for loans paid in instalments, 60 days for revolving credit. Since January 2022 it is called etapa 3. An unregulated lender sets its own rule.
For a bank, cartera vencida is a day count written by the regulator, not a judgement
The rule is Criterio B-6, Cartera de crédito, in Anexo 33 of the Circular Única de Bancos, the accounting criteria the Comisión Nacional Bancaria y de Valores (CNBV) sets for Mexican banks. It moves a loan into cartera vencida on one of two events. The first is the borrower being declared in concurso mercantil, Mexico's court insolvency procedure. The second is a payment unpaid past a threshold that depends on how the loan amortises, down to revolving credit with «dos periodos mensuales de facturación vencidos», two monthly billing periods past due.
Two details change how the number reads. What moves is the «saldo insoluto», the whole outstanding balance of the loan, not the late instalment. And from the moment of the transfer the lender stops recognising accrued interest as income, as the notes of Banco Base for the second quarter of 2018 and of Banco Azteca at 30 September 2025 both state. A loan in cartera vencida earns nothing on paper until it is cured.
Thresholds in calendar days past due. Source: CNBV Criterio B-6, Cartera de crédito, Diario Oficial de la Federación; the same counts for the transfer to etapa 3 since 1 January 2022, per Banco Azteca's notes at 30 September 2025.
| How the loan is repaid | Enters cartera vencida (etapa 3) |
|---|---|
| Principal and interest in one payment at maturity | 30 or more days past due |
| Principal at maturity, interest paid periodically | 90 or more days on interest, or 30 or more on principal |
| Periodic instalments of principal and interest, mortgages included | 90 or more days past due |
| Revolving credit | Two monthly billing periods past due, or 60 or more days |
| Borrower declared in concurso mercantil | When the lender learns of the declaration |
The threshold follows the repayment schedule, not the product name. A consumer loan paid in monthly instalments and a mortgage both move at 90 days; a bullet loan moves at 30. Two lenders with the same delinquency can report different cartera vencida if their books amortise differently.
Since January 2022 the same bucket is called etapa 3, and the day counts stayed
On 13 March 2020 the CNBV published a resolution aligning the banks' accounting criteria with IFRS 9 through the Mexican standard NIF C-16, on impairment of financial instruments. A later resolution of 4 December 2020 set the start for 1 January 2022, and Criterio B-6 was restated once more in the Diario Oficial on 30 December 2021. Banobras described the result in its 2022 disclosure as the change from «cartera vencida a Cartera de crédito con riesgo de crédito (Etapas 1, 2 y 3)».
The new name did not move the line. Banco Azteca's notes at 30 September 2025 list the thresholds for transfer to etapa 3 as 30 days for a single payment at maturity, 90 on interest or 30 on principal for a bullet loan with periodic interest, and 90 days for periodic instalments, the same counts B-6 used for cartera vencida. The old term survives outside the financial statements: HR Ratings' sector report on non-bank lenders of 9 September 2025 still measures them by cartera vencida.
the line an instalment loan crosses into etapa 3 under the CNBV rule
Binding on banks and regulated SOFOMs. A SOFOM E.N.R. answers to its own policy.
A SOFOM E.N.R. answers to no CNBV day count, so its cartera vencida means what its policy says
A SOFOM, sociedad financiera de objeto múltiple, is a Mexican company that lends without taking deposits. The CNBV describes two regimes. A SOFOM is regulated, an entidad regulada or E.R., when it has a capital link to a bank, a popular savings company or a credit cooperative, when it funds itself with debt securities registered in the Registro Nacional de Valores, or when it asks to be. Every other one is an entidad no regulada, E.N.R., which the CNBV inspects only for anti-money-laundering rules, under article 95 Bis of the law on auxiliary credit organisations.
An E.N.R. keeps its books under the Normas de Información Financiera like any Mexican company, and Criterio B-6 does not bind it. When one of its loans enters what it calls cartera vencida, and when that loan is written off, is its own accounting policy. The audited notes describe the policy where audited statements exist. A presentation that prints the percentage usually does not.
A write-off takes a loan out of cartera vencida, which is why the ratio flatters
A past-due ratio counts only the loans still on the book. Once a loan is written off, a castigo in Mexican usage, it leaves both the numerator and the denominator. In HR Ratings' sample of non-bank lenders at June 2025 the reported past-due ratio was 3.9%; adjusted for twelve months of write-offs it was 7.1%. In pesos the two halves were almost the same size: MXN 10,630m of cartera vencida against MXN 9,636m written off over the year. What that gap looked like in lenders that later defaulted is the subject of The eleven dark months.
The sector's trade body uses a looser word still. ASOFOM reports cartera catastrófica, which its national president Javier Garza Hoeffer described as the equivalent of a bank's cartera vencida, «pero se saca después de agotar todas las instancias para recuperar el adeudo», taken out only after every route to recovery is exhausted. A category with no date in it cannot be compared across two lenders or two quarters.
Cartera vencida in a bank's statements is a rule. In an unregulated lender's deck it is a label, and the fund has to ask which rule sits under it.
A fund rebuilds it from the loan tape with the regulator's rule, whatever the lender calls it
The comparable number comes from loan-level data, not from the ratio. The loan tape, the file with one row per loan, gives each loan's repayment schedule and days past due at every month end; the write-off file gives the date and amount of every castigo. Apply the five B-6 thresholds to the first, add back twelve months of the second, and the result is an etapa 3 that means the same thing for every lender in a fund's pipeline.
Three questions close the remaining gaps. Which day count moves a loan, product by product. When a loan is written off, and whether that comes before or after it reaches cartera vencida. And when a restructured loan returns to performing: B-6 requires pago sostenido, at least «tres amortizaciones consecutivas» paid in full and on time. Read by origination cohort, as in a static pool, the same data shows whether a newer vintage is deteriorating faster than an older one.
Questions this raises
- What does cartera vencida mean?
- Cartera vencida is the past-due portion of a Mexican loan portfolio. Under CNBV Criterio B-6 a loan's whole outstanding balance enters it 30, 60 or 90 days after a missed payment, depending on how the loan repays, or when the borrower is declared in concurso mercantil.
- When does a loan become cartera vencida in Mexico?
- Under Criterio B-6: 30 days for principal and interest due in one payment at maturity, 90 days on interest or 30 on principal for a bullet loan with periodic interest, 90 days for periodic instalments including mortgages, and two monthly billing periods or 60 days for revolving credit.
- Is cartera vencida the same as etapa 3?
- For banks it is the same bucket under a new name. Since 1 January 2022 the CNBV's criteria, aligned with IFRS 9 through NIF C-16, classify loans in etapas 1, 2 and 3, and the day counts that used to move a loan into cartera vencida now move it into etapa 3.
- Does the CNBV rule apply to a SOFOM E.N.R.?
- No. The CNBV inspects an unregulated SOFOM only for anti-money-laundering rules, and it keeps its books under Mexican financial reporting standards like any company. When it treats a loan as past due, and when it writes one off, is set by its own accounting policy.
- Why can a cartera vencida ratio understate losses?
- Written-off loans leave the ratio entirely. In HR Ratings' sample of Mexican non-bank lenders at June 2025 the reported past-due ratio was 3.9%, and 7.1% once twelve months of write-offs were added back.
Effect is not a bank, a lender, a broker-dealer, an investment adviser or a credit rating agency. Nothing here is investment, legal, accounting or tax advice. Every rule carries the version of the document it was read from, read on 7 October 2026.
Where every figure on this page comes from8 sources
- 01CNBV, Criterio B-6, Cartera de crédito, Anexo 33 of the Disposiciones de carácter general aplicables a las instituciones de crédito, as published in the Diario Oficial de la Federación: transfer to cartera vencida.
- 02CNBV, resolution amending the Disposiciones for credit institutions, Diario Oficial de la Federación, 13 March 2020; start date set by the resolution of 4 December 2020; Criterio B-6 restated, 30 December 2021.
- 03Banobras, disclosure under article 181, section XX, of the Disposiciones, September 2022: changes in accounting policies.
- 04Banco Azteca, notes to the financial statements at 30 September 2025: transfer to cartera de crédito con riesgo de crédito etapa 3.
- 05Banco Base, notes to the financial statements, second quarter of 2018: suspension of interest accrual on cartera vencida.
- 06CNBV, Sofomes, description of the regulated and unregulated regimes.
- 07HR Ratings, Sectorial IFNB's, 9 September 2025, data at June 2025.
- 08Javier Garza Hoeffer, national president of ASOFOM, interview with Mundo Ejecutivo Edomex, on cartera catastrófica.