CVM publishes accounting guidelines for investment funds

On Friday (24/01/2025), the Brazilian Securities and Exchange Commission (CVM) published Joint Circular Letter CVM/SNC/SSE/SIN No. 01/2025, which provides clarifications on the preparation of financial statements for investment funds and classes of quotas, in addition to the criteria set out in CVM Resolution 175/22 vis-à-vis the accounting standards currently in force for investment funds.

Published in the form of questions and answers, the letter aims to clarify additional and specific doubts arising from the consultation formulated by the Brazilian Association of Financial and Capital Market Entities (ANBIMA).

Among the various clarifications addressed, we highlight the following:

(i) for investment funds constituted with a single class, only the class needs to present financial statements, provided that the conditions set out in the Official Letter are complied with;

(ii) with regard to the financial statements of funds with different classes of quotas, the provisions of paragraph 1 of art. 67 of CVM Resolution 175/22 must be followed; and

(iii) there is no need to talk about the equity and financial position of subclasses within the same class of quotas, given that there is no segregation of the assets of the class at the level of the subclass. However, there must be adequate bookkeeping to segregate and demonstrate the charges debited to each sub-class and the movement of the class's equity.

The Capital Markets team at Barcellos Tucunduva Advogados will be happy to answer any questions you may have on the above subject at mercadodecapitais@btlaw.com.br.