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SEC Comment Letter for Macro Bank (BMA) — Jan 15, 2026

Macro Bank Inc.
Date: Jan. 15, 2026 · CIK: 0001347426 · Accession: 0000000000-26-000561

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File numbers found in text: 001-32827

Date
January 15, 2026
Author
Division of
Form
UPLOAD
Company
Macro Bank Inc.

Letter

Re: Macro Bank Inc. Form 20-F for Fiscal Year Ended December 31, 2024 Response Dated September 30, 2025 File No. 001-32827 Dear Jorge F. Scarinci:

January 15, 2026

Jorge F. Scarinci Chief Financial Officer Macro Bank Inc. Avenida Eduardo Madero 1172, 24th Floor C1106ACY City of Buenos Aires Argentina

We have reviewed your September 30, 2025 response to our comment letter and have the following comments.

Please respond to this letter within ten business days by providing the requested information or advise us as soon as possible when you will respond. If you do not believe a comment applies to your facts and circumstances, please tell us why in your response.

After reviewing your response to this letter, we may have additional comments. Unless we note otherwise, any references to prior comments are to comments in our September 16, 2025 letter.

Form 20-F for Fiscal Year Ended December 31, 2024 Analysis of the allowance for loan losses and other financing, page 134

1. We acknowledge your response to prior comment one. Please revise future filings to provide qualitative information, including a narrative explanation, to explain the reasons for the changes in the expected credit loss ( ECL ) allowance during each period presented. Refer to IFRS 7.35H, .35I and .B8D for guidance. Credit loss expense on financial assets, page 162

2. We acknowledge your response to prior comment two. Please address the following:

Please tell us and revise future filings, as needed, to define "Charged-off Loans" and "Amounts Written Off" clearly identifying the differences between each term January 15, 2026 Page 2

as used in your prior reconciliation. Please provide us a reconciliation showing how the credit loss expense recognized for 2024 and 2023 is presented in the ECL rollforward line-items on page 134. Please separately identify amounts related to each various cause (e.g., "Charged- off Loans" and IAS 29 restatement). Please consider revising your ECL rollfoward, supporting disclosure or other disclosure in future filings to more clearly show the relationship between the credit loss recognized in the income statement and the line-items included in the ECL rollforward.

Please contact Victor Cecco at 202-551-2064 or Michael Volley at 202-551-3437 if you have questions regarding comments on the financial statements and related matters.

Sincerely,
Division of
Corporation Finance
Office of Finance
cc: Paola Gayoso

Show Raw Text
<DOCUMENT>
<TYPE>TEXT-EXTRACT
<SEQUENCE>2
<FILENAME>filename2.txt
<TEXT>
 January 15, 2026

Jorge F. Scarinci
Chief Financial Officer
Macro Bank Inc.
Avenida Eduardo Madero 1172, 24th Floor
C1106ACY City of Buenos Aires
Argentina

 Re: Macro Bank Inc.
 Form 20-F for Fiscal Year Ended December 31, 2024
 Response Dated September 30, 2025
 File No. 001-32827
Dear Jorge F. Scarinci:

 We have reviewed your September 30, 2025 response to our comment letter
and have
the following comments.

 Please respond to this letter within ten business days by providing the
requested
information or advise us as soon as possible when you will respond. If you do
not believe a
comment applies to your facts and circumstances, please tell us why in your
response.

 After reviewing your response to this letter, we may have additional
comments.
Unless we note otherwise, any references to prior comments are to comments in
our
September 16, 2025 letter.

Form 20-F for Fiscal Year Ended December 31, 2024
Analysis of the allowance for loan losses and other financing, page 134

1. We acknowledge your response to prior comment one. Please revise future
filings to
 provide qualitative information, including a narrative explanation, to
explain the
 reasons for the changes in the expected credit loss ( ECL )
allowance during each
 period presented. Refer to IFRS 7.35H, .35I and .B8D for guidance.
Credit loss expense on financial assets, page 162

2. We acknowledge your response to prior comment two. Please address the
following:

 Please tell us and revise future filings, as needed, to define
"Charged-off Loans"
 and "Amounts Written Off" clearly identifying the differences
between each term
 January 15, 2026
Page 2

 as used in your prior reconciliation.
 Please provide us a reconciliation showing how the credit loss
expense recognized
 for 2024 and 2023 is presented in the ECL rollforward line-items on
page 134.
 Please separately identify amounts related to each various cause
(e.g., "Charged-
 off Loans" and IAS 29 restatement).
 Please consider revising your ECL rollfoward, supporting
disclosure or other
 disclosure in future filings to more clearly show the relationship
between the
 credit loss recognized in the income statement and the line-items
included in the
 ECL rollforward.

 Please contact Victor Cecco at 202-551-2064 or Michael Volley at
202-551-3437 if
you have questions regarding comments on the financial statements and related
matters.

 Sincerely,

 Division of
Corporation Finance
 Office of Finance
cc: Paola Gayoso
</TEXT>
</DOCUMENT>