The Brazil Securities Commission (CVM), through its Superintendence of Securitization and Agribusiness, issued a circular letter to guide administrators of Credit Rights Investment Funds (FIDC), Real Estate Investment Funds (FII) and Agro-Industrial Production Chain Investment Funds (FIAGRO) on late submission of periodic information and the resulting ordinary coercive fine. The guidance explains the criteria and procedures used to apply these fines and to assess appeals, stressing that the mechanism is objective and automatic once a filing deadline is missed and is intended to ensure compliance rather than function as a sanction. It reiterates that information required under CVM Resolution 175 is mandatory and subject to automatic daily fines under CVM Resolution 47, with each fine tied to a specific delay and capable of accumulating across repeated late filings. Responsibility for submission rests with the administrator in place on the relevant due date, even if the fund’s administrator is later replaced, and the reporting obligation runs from the first capital contribution through fund cancellation, including during liquidation. Extensions granted under CVM Deliberation 848 are clarified as having applied only to 2020, and appeals repeating arguments addressed in the circular letter will be rejected immediately.

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