The Brazil Securities Commission (CVM) outlined outcomes from its supervisory cooperation regime with the Brazilian Financial and Capital Markets Association (ANBIMA) for the investment funds industry, which resulted in settlement agreements (termos de compromisso) with five market participants between July and December 2024. The cases primarily concerned fund portfolio compliance and distribution-related suitability issues. Two settlements addressed portfolio limit and classification (enquadramento) problems, and one covered processes and controls for updating mark-to-market rates used in portfolio asset pricing. The remaining two settlements related to distribution, covering deficiencies in due diligence over contracted investment advisers and irregularities in advertising materials and in the suitability process. In addition, ANBIMA and CVM shared three recommendation letters sent to market participants, all linked to fund compliance (enquadramento) issues. From September 2024, the cooperation has operated under a new agreement that formalises information exchange and allows CVM to leverage ANBIMA’s monitoring work to reduce duplication and align supervisory and enforcement efforts.

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