The use of 66% of the official fiscal value is intended as a conservative and transparent metric based on a public, auditable reference (National Registry). Official fiscal values tend to lag market prices and are generally below recent transaction levels, so applying a 34% haircut to this already conservative baseline results in a prudent collateral coverage ratio. Independent third‑party appraisals may be commissioned to provide an additional market‑based view, but our intention is not to rely solely on potentially more volatile market valuations for minimum coverage tests.