Brazil Securities Commission issues Q&A guidance clarifying in-kind fund capital contributions and fiduciary administrator limits under Resolution 175

The Brazil Securities Commission (CVM), through its Institutional Investors Supervision Department (SIN), issued Circular Letter CVM/SIN 2/2025 setting out additional interpretations of the General Part and Annex IV of CVM Resolution 175. The guidance focuses on when investment fund capital can be paid in assets and on the limits of the fiduciary administrator’s activities, and it also addresses operational topics relevant to participation funds. Structured as a Q&A document based on questions received from the market, the circular complements Joint Circular Letters CVM/SIN/SSE 1/2023 and 2/2023. It covers, under the General Part, in-kind capital contributions and the fiduciary administrator’s role, and under Annex IV, portfolio composition, the deadline for bringing FIP-IE and FIP-PD&I funds into compliance, the establishment and competences of committees, investments in simple loan agreements, investment limits, the list of charges, and investments in SCP (Sociedade em Conta Participação).