BRZ CVM published Circular 7/2024/CVM/SIN with guidelines related to the compliance period for funds with respect to disclosure of the remuneration of service providers.
Direct Remuneration Payment
Addresses prohibition on direct payment of remuneration to manager of the allocating fund, certain providers will not be able to be remunerated by the invested classes.
It is regular to divide management and performance fees between the invested and investing classes at the end of the period so funds can adapt to CVM Resolution 175.
Reiterates the prohibition on rebate structures in CVM Resolution 175, so that it is so that remuneration received by the service providers would not impair decision making.
Adapting Remuneration Arrangements
The new rules related to transparency and segregation of the remuneration of fund service providers came into force on Nov. 1, 2024, under the Anbima self regulation.
Funds set up/adapted, in both cases before Nov. 1, 2024, will have until the end of the period (Jun. 30, 2025) to adapt to CVM Resolution 175 re segregation of provider fees.
Deadlines
Fund remuneration arrangements and performance fees considered regular under the agreed terms until Dec. 2024, which was the end date for fund adaptation of Res 175.
Deadline for investment funds to adapt to Resolution 175 postponed under terms of CVM Resolution 200, so remuneration arrangements are delayed until Jun. 30, 2025.
