Brazil Securities Commission issues circular clarifying remuneration, order routing and certification expectations for securities advisers

The Brazil Securities Commission’s Superintendence of Institutional Investor Supervision (SIN) published a circular letter setting out its technical interpretations of CVM Resolution 19, which regulates securities advisory activity, in response to the increasing number of market participants registered in this role. The circular clarifies SIN’s understanding of issues covering advisers’ remuneration, the forwarding of investment orders and the advisory report, and certification. It also reiterates key duties for securities advisers, including providing professional guidance and recommendations, acting independently from issuers and distributors, and meeting a fiduciary duty to understand the client’s profile, assess risks, costs and advantages of recommendations, and base advice on the client’s best interests.