On Apr. 7, BRZ Anbima proposed adaption to new credit instrument.
BRZ Anbima issued, for public consultation, new rules for suitability of credit COE.
The public hearing that will include specific rules for risk classification for Structured Transaction Certificates (COE) in credit modality for suitability purposes is now open.
Highlights
Aim to adapt text to new definitions on instrument published at the end of last year by the National Monetary Council (CMN), which differentiated them from a Market COE.
There is minimum risk score table for each product to enable better recommendations.
Suggests risk score for instrument between 1.25 and 4 points, varies based on factors such as issuer’s rating, maturity, exposure to exchange rate fluctuations, and others.
Intermediation Services Abroad
Optional additional suitability parameters for offerIing brokerage services abroad.
Firms that choose to monitor portfolios in an integrated way will be able to adopt a lower risk score for positions held outside Brazil, not considering the risk of exposure.
Institutions must create internal policies that assess clients’ investment objectives.
Communication procedures must be set with the investor and the intermediary abroad.
Processes dealing with possible non-compliances with the client's profile in Brazil and cases in which the portfolio's exposure limit in international products is exceeded.
These situations won't have an impact on the investor's suitability in Brazil and maintaining this document does not exempt institution from its regulatory obligations.
Transparency of Information
Included clarifications re rules of transparency in the remuneration of distributors.
Managers who only distribute shares of funds under their management do not need to make disclosures related to rules re quantitative information and quarterly statement.
Private offerings of closed-end fund shares were also exempted from the rules, since the costs of these customized operations are agreed upon between the shareholders.
Quarterly statements for clients with positions in publicly offered products not needed.
Instructions for accessing data on remuneration will have already been communicated.
Consultation
Comments may be submitted on or before May 5, 2025 by email.