The Brazil Securities Commission’s Superintendence of Market and Intermediaries Relations (SMI) issued Circular Letter CVM/SMI 2/2026 to reiterate guidance and alert intermediaries to the duties that apply to their securities intermediation and client relationship activities in the organised over-the-counter (OTC) market. The circular emphasises compliance with CVM Resolution 35 and the requirement to register previously executed trades with organised OTC market administrators in line with CVM Resolution 135. The SMI linked the reminder to recent developments in secondary fixed income securities markets, including higher trading volumes, changes in participant profiles, and the rollout of new systems intended to facilitate trading. It noted that some intermediaries use proprietary systems while others rely on systems provided by organised OTC market administrators, and that this diversity of trading mechanisms underpins the need to reinforce the applicable duties under Resolutions 35 and 135.