The Brazil Securities Commission (CVM) has clarified that administrators and managers of Credit Rights Investment Funds (FIDCs) may not allocate all or part of a fund’s performance fee to a specialist consultant hired by the manager. The fee is reserved exclusively for the fund manager. Linking the performance fee to a consultant may constitute unauthorized portfolio management. This could result in liability for the consultant, the FIDC manager or its administrator.
2026-09-11Brazil Securities Commission (CVM)
Brazil Securities Commission bars FIDC performance fees from being allocated to specialist consultants
The Brazil Securities Commission has clarified that FIDC performance fees cannot be allocated, in whole or in part, to specialist consultants hired by fund managers. Such arrangements may constitute unauthorized portfolio management and expose the consultant, manager or administrator to liability.