BRZ Anbima Suitability of Credit COE

Published on: Apr 10, 2025

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.
Regulators
BRZ Anbima
Entity Types
B/D; Corp; Exch; IA; Inv Co
Reference
PR, CP, 4/7/2025
Functions
Compliance; Financial; Legal; Trading
Countries
Brazil
Category
State
N/A
Products
Clearing; Derivatives; Fund Mgt; Securities
Rule Type
Final
Regions
Am
Rule Date
Apr 7, 2025
Effective Date
May 5, 2025
Rule ID
249841
Linked to
N/A
Reg. Last Update
Apr 7, 2025
Report Section
International