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21. Financial Institutions

09/09/25

FINANCIAL INSTITUTIONS

I. INTRODUCTION

I.1. According to the Brazilian Federal Constitution1, the National Financial System (“SFN”) – which shall be regulated by supplementary laws2 – must promote the balanced development of the Country and serve the collective interests in all its component elements.

I.2. Although supplementary bills aimed at regulating various SFN-related matters are pending Congress approval, and some specific subjects in this field have already been approved, no specific supplementary law regulating the SFN in its entirety has been enacted since the Federal Constitution was promulgated in 1988.

I.3. The main laws currently in force3 governing the SFN with respect to currency, credit, capital, and foreign exchange control are:

  1. Law No. 4,595 of December 31, 1964 (“Law No. 4,595/64”), which governs monetary, banking, foreign exchange, and credit policies and institutions in Brazil;
  2. Law No. 6,385 of December 7, 1976 (“Law No. 6,385/76”), which governs the securities’ market, specifying the assets deemed as securities and the activities to be governed, as well as the rules for supervision and sanctioning of its agents, and establishes the Brazilian Securities and Exchange Commission; and
  3. Law No. 4.131 of September 3, 1962, which initially set out the rules applicable to foreign investments in Brazil and to remittances of funds abroad, as amended and supplemented by Law No. 14,286 of December 29, 2021, the so-called “New Foreign Exchange Framework”, which set forth new rules applicable to (a) the foreign exchange market; (b) Brazilian assets held abroad by Brazilian tax residents; (c) foreign assets held in Brazil by non-resident tax payers in Brazil; and (d) the provision, to the Central Bank of Brazil, of information related to the above mentioned items for the purpose of compiling official macroeconomic statistics.

I.4. The SFN is composed of the following institutions:

  1. Financial institutions governed by Law No. 4,595/64: (a) the National Monetary Council, a regulatory body; (b) the Central Bank of Brazil, a supervisory body; and (c) the operational institutions Banco do Brasil S.A., National Bank for Economic and Social Development – BNDES, and other public and private financial institutions;
  2. The capital markets supervisory authority, governed by Law No. 6,385/76: the Brazilian Securities and Exchange Commission;
  3. Private insurance-related institutions, governed by Decree-Law No. 73 of November 21, 1966: (a) the Brazilian Private Insurance National Council (Conselho Nacional de Seguros Privados – CNSP), a regulatory body; (b) the Brazilian Private Insurance Superintendence (Superintendência de Seguros Privados – SUSEP), a supervisory body; and (c) the system’s operational institutions: insurance and reinsurance companies, open pension entities, and capitalization companies; and
  4. Institutions related to closed pension entities, governed by Decree No. 7,123 of March 3, 2010: (a) the National Complementary Pension Council (Conselho Nacional de Previdência Complementar – CNPC), a regulatory body; (b) the Brazilian National Complementary Pensions Superintendence (Superintendência Nacional de Previdência Complementar – Previc), a supervisory body; and (c) the system’s operational institutions: closed private pension entities (funds).

1 Federal Constitution of the Federative Republic of Brazil, 1988.

2 Article 192 of the Brazilian Federal Constitution.

3 The legislation and regulations mentioned throughout this chapter consider all amendments made to them up to August 31st, 2025.

 

II. THE NATIONAL MONETARY COUNCIL – REGULATORY AND SUPERVISORY BODIES4

II.1. The National Monetary Council

II.1.1. For the coordination of the Federal Government’s macroeconomic policy, Law No. 4,595/64 established the National Monetary Council (“CMN”)5, a regulatory body in charge of formulating monetary, foreign exchange, and credit policies, as well as of setting inflation targets, guidelines for foreign exchange, and the main rules governing the operation of financial institutions. The CMN issues rules that must be followed by all participants of the SFN and by the Central Bank of Brazil (“BCB”).

II.1.2. The CMN is chaired by the Minister of Finance and includes, in addition to the Minister, the President of the BCB and the Minister of Planning and Budget as members. The CMN members meet on a monthly basis in order to resolve on matters within their jurisdiction and also to: (i) guide the application of financial institutions’ resources; (ii) promote the improvement of institutions and financial instruments; (iii) ensure the liquidity and solvency of financial institutions; and (iv) coordinate monetary, credit, budgetary, and internal and external public debt policies. The CMN is assisted by the Currency and Credit Technical Commission, a body composed of specialists, for the formulation of monetary and credit policy.

II.2 The Central Bank of Brazil

II.2.1. The BCB is the body in charge of enforcing CMN regulations and responsible for regulating, supervising, and overseeing the SFN7 and the payment systems8, as well as for conducting monetary, foreign exchange, credit, and external financial policies. Its main mission is to ensure the purchasing power of the currency, to safeguard adequate liquidity in the economy, to maintain international reserves at an appropriate level, to encourage savings, to ensure stability, and to promote the continuous improvement of the SFN. The President and the Directors of the BCB are appointed by the President of the Republic following approval by the Federal Senate9. The BCB conducts its regulatory functions through the issuance of resolutions, circulars, and circular letters.

II.2.2. The BCB’s responsibilities include10:

      1. issuing, managing, distributing, withdrawing, and destroying currency (banknotes and coins);
      2. receiving compulsory and voluntary deposits from financial and banking institutions;
      3. conducting rediscount and lending operations to financial institutions;
      4. exercising credit control;
      5. conducting purchase and sale operations of federal public securities;
      6. exercising control over foreign capital;
      7. ensuring the regular functioning of the foreign exchange market, of the relative stability of exchange rates, and the equilibrium in the balance of payments, being allowed for such purposes to buy and sell gold and foreign currency, as well as to carry out credit operations abroad;
      8. supervising financial institutions and applying penalties in cases of non-compliance with applicable rules, fraud, mismanagement, or other irregularities;
      9. authorizing the operation of financial institutions, corporate structure, shareholders’ control and bylaws changes, as well as transfers of headquarters and premises;
      10. establishing the conditions for holding any executive positions in financial institutions; and
      11. maintaining ongoing oversight of the financial and capital markets to identify interference by other companies that, directly or indirectly, affect these markets.

II.2.3. On February 24, 2021, Complementary Law No. 179 was enacted, establishing the autonomy of the BCB and granting it a special status characterized by the absence of attachment to any ministry, lack of oversight or hierarchical subordination, technical, operational, administrative, and financial autonomy, fixed-term appointment of its executives, and stability during their terms11. This ensures greater stability to the SFN by increasing the likelihood that the institution will make strictly technical decisions.

II.3. The Brazilian Securities and Exchange Commission

II.3.1. Law No. 6,385/76 created the Brazilian Securities and Exchange Commission of Brazil (“CVM”) and set out the foundations for the organization and supervision of the Brazilian capital market. Activities related to the issuance, distribution, intermediation, and trading of securities, the organization and operation of stock exchanges and over-the-counter markets, and entities engaged in any of the activities mentioned above—such as DTVMs and CTVMs, investment funds12, portfolio managers etc.—are subject to regulation and supervision by the CVM.

II.3.2 The CVM, an autonomous agency with a special status, linked to the Ministry of Finance, with its own legal personality and assets, is endowed with independent administrative authority, lack of hierarchical subordination, fixed-term appointments and stability of its executives, and financial and budgetary autonomy13. Law No. 6,385/76 assigned the CVM the responsibility to supervise, regulate, oversee, and develop the securities market in Brazil.

II.3.3. The CVM, acting in conjunction with the CMN, has the following responsibilities14:

      1. encouraging the creation of savings and their investment in securities;
      2. promoting the expansion and the efficient and orderly operation of the stock market, and encouraging investments in publicly-held companies under domestic private capital control;
      3. ensuring the efficient and orderly operation of stock exchanges and over-the-counter markets;
      4. protecting market investors against (a) irregular securities’ offerings, (b) illegal acts by managers and controlling shareholders of publicly-held companies, (c) illegal acts by portfolio managers, and (d) the use of material non-public information in the securities market;
      5. preventing or curbing fraud and market manipulation aimed at creating artificial conditions of demand, supply, or securities prices;
      6. ensuring public access to information about traded securities and their issuers;
      7. ensuring compliance with fair trading practices in the securities market; and
      8. ensuring compliance in the market with credit usage conditions established by the CMN.

4 Except for those referred to in 1.4.(iii) and 1.4.(iv) above, which will be addressed in separate chapters.

5 Article 3 of Law No. 4,595/64.

6 The Commission is composed of the President and Directors of the Central Bank of Brazil, the President of the Brazilian Securities and Exchange Commission, the Executive Secretary of the Brazilian Ministry of Planning and Budget, the Executive Secretary of the Brazilian Ministry of Finance, the Secretary of the Brazilian National Treasury of the Ministry of Finance, the Secretary of Economic Reforms of the Brazilian Ministry of Finance, and the Secretary of Economic Policy of the Brazilian Ministry of Finance.

7 Article 9 of Law No. 4,595/64.

8 The Brazilian Payment System – SBP, which will be addressed later in 4.2 below.

9 Article 84, Paragraph XIV, of the Federal Constitution.

10 Article 10 and 11 of Law No. 4,595/64.

11 Article 6 of Complementary Law No. 179, of February 24, 2021.

12 CVM Resolution No. 175, of December 23, 2025.

13 Article 5 of Law No. 6,385/76.

14 Article 4 of Law No. 6,385/76.

 

III. FINANCIAL INSTITUTIONS

III.1. Federal Government Public Banks

III.1.1. Banco do Brasil S.A.: Banco do Brasil S.A. (“BB”)15 is a mixed-capital company16, and it acts as an instrument for implementing the Federal Government’s credit and financial policy. The BB operates under the supervision of the CMN and is required to provide the BCB with the information necessary for its role as supervisor of the financial market. Among other responsibilities, the BB always operates within the limits established by law and the CMN, acting: (i) as the financial agent of the National Treasury, receiving revenues, taxes, and credits, and making payments to execute the budget on its behalf; (ii) as the main executor of the Federal Government’s banking services; and (iii) as an entity in charge of providing credit to finance industrial and agricultural activities, as well as imports and exports. The President of the Republic appoints the President of the BB following approval by the Federal Senate17. The same rules applicable to other financial institutions referred to in 3.2.1.(i)(c) and 3.2.1.(iv) below apply to holders of statutory positions.

III.1.2. The National Bank for Economic and Social Development – BNDES: The National Bank for Economic and Social Development (Banco Nacional de Desenvolvimento Econômico e Social – BNDES), established by Law No. 1,628 of June 20, 1952, is a federal public company12 linked to the Ministry of Development, Industry, Trade, and Services, and acts as an auxiliary body in executing the Federal Government’s credit, long-term financing, and investment policies across various sectors of the national economy. The BNDES has two subsidiaries: (i) BNDESPar, which promotes the development of the capital market through long-term investments in domestic companies; and (ii) the Special Agency for Industrial Financing – FINAME, dedicated to fostering the production and commercialization of machinery and equipment for domestic companies.

III.2. Other Financial Institutions – General Aspects of Public and Private Institutions

III.2.1. Financial Institutions: Law No. 4,595/64 defines financial institutions19 as public or private legal entities the main or ancillary activities of which are the collection, intermediation, or investment of their own or third-party’s financial resources, in national or foreign currency, and the custody of assets owned by third parties. For purposes of the applicable legislation, individuals who conduct any of the activities listed above, whether on a permanent or occasional basis, are treated as financial institutions. Financial institutions require prior authorization from the BCB to operate in the country, except for foreign institutions, which require a decree from the President of the Republic. In general, the rules applicable to the establishment, maintenance, and operation of financial institutions can be described as follows:

      1. CMN Resolution No. 4,970 of November 25, 2021 (“CMN Resolution No. 4,970/21”) establishes the rules for granting authorization for the operation of financial institutions (except those subject to specific rules), as well as the requirements for granting such authorization, which include, among others: (a) the economic and financial feasibility of the enterprise; (b) the economic and financial capacity of the controllers; (c) that members of statutory or contractual bodies, controllers, and holders of significant ownership stakes have an unblemished reputation20 and meet the requirements mentioned in 3.2.1.(v) below; and (d) that the occupants of statutory or contractual bodies and the controllers meet certain technical requirements mentioned in 3.2.1.(iv) below21.
      2. Several corporate transactions are also subject to BCB authorization, including those that may result in changes to (a) the corporate control of the institution, including mergers, spin-offs, and incorporations; (b) the amount of share capital; (c) the corporate purpose; (d) the corporate name; (e) the corporate type; and (f) the bylaws22.
      3. The BCB may revoke an operating authorization if, at any time, it verifies any of the following situations: (a) failure to habitually engage in the activity for which the authorization was granted; (b) that the institution is not located at the address provided to the BCB; (c) interruption, for more than four months without justification, of the submission to the BCB of statements, reports, and information required by applicable regulations; or (d) noncompliance with the business plan during its applicable period, without sufficient justification, at the discretion of the BCB23.
      4. The qualification and exercise of duties by members of statutory and contractual bodies depend on BCB authorization24, which requires that the professionals (a) have experience in the business segment in which the institution intends to operate25, and (b) possess technical qualifications compatible with the functions to be performed26.
      5. Furthermore, as conditions for holding positions in statutory or contractual bodies and for assuming the status of controller or qualified shareholder in institutions, in addition to other requirements established by law and applicable regulations, a person shall: (a) be a resident of Brazil, in the case of an executive position; (b) not be barred by law nor convicted of certain crimes referred to in the applicable regulations; (c) be eligible to hold positions in statutory or contractual bodies of financial institutions and other entities of the SFN, as well as entities subject to the supervision of the Brazilian Securities and Exchange Commission; and (f) not have been declared bankrupt or insolvent27.
      6. The BCB may order the removal of members of statutory or contractual bodies holding an active mandate if, at any time, circumstances are identified that constitute non-compliance with the requirements set forth in 3.2.1.(i)(c) and 3.2.1.(v) above.

III.2.2 Public Financial Institutions: Federal public financial institutions28 are bodies which assist in the implementation of the Federal Government’s credit policy. Federal public financial institutions have their activities, capacities, and operational modalities regulated by the CMN29 and their respective presidents are appointed by the President of the Republic following approval by the Federal Senate. Non-federal public financial institutions are subject to the provisions applicable to private financial institutions.

III.2.3. Private Financial Institutions: Private financial institutions, except for credit cooperatives, must be organized as corporations30, with their voting share capital represented by registered shares31. The minimum share capital requirement depends on the type of activity(ies) conducted by the financial institution. At the subscription of the initial capital and any subsequent increases in cash, shareholders shall pay at least 50% of the subscribed amount, with the remainder to be paid within one year from the respective approval by the BCB32. The portion of a capital increase not paid in cash33, may be fulfilled through the incorporation of reserves, in accordance with the rules established by the CMN, and by revaluation of fixed assets, respecting the maximum limit set by the National Economic Council34.

III.2.3.1. Brazil also adopts the recommendations of the Basel Committee on Banking Supervision, known as Basel III35, which, among other things, establish capital levels, liquidity requirements, counterparty credit risks, and leverage ratios. These recommendations have been implemented through regulations issued by the CMN and the BCB.

III.2.3.2. Private financial institutions shall apply, preferably, no less than 50% of the public deposits they collect in the respective federative unit where they are established, or in other regions and/or federative units as determined by the CMN36. Private financial institutions, except investment banks, may only participate in the capital of other companies if they obtain prior authorization from the BCB, which may grant it explicitly, provided the request is properly justified, except in cases of subscription guarantees as defined by the CMN37.

15 Article 19 of Law No. 4,595/64.

16 A mixed-capital company is an enterprise created by law, the controlling shares of which belong to the Federal Government, and which has minority participation of private capital.

17 Article 21 of Law No. 4,595/64.

18 Article 23 of Law No. 4,595/64.

19 Article 17 of Law No. 4,595/64.

20 Article 12 of CMN Resolution No. 4,970/21 states that, for the purpose of determining compliance with the requirement of unblemished reputation, the following must be absent: (i) criminal proceedings or police investigations;
(ii) judicial or administrative proceedings related to the SFN or the Brazilian Payment System; (iii) proceedings concerning insolvency, liquidation, intervention, bankruptcy, or judicial reorganization; (iv) default on obligations; and
(v) other similar situations, occurrences, or circumstances.

21 Article 2 of CMN Resolution No. 4,970/21.

22 Article 3 of CMN Resolution No. 4,970/21.

23 Article 23 of the CMN Resolution No. 4,970/21.

24 Article 3, Paragraph V, of CMN Resolution No. 4,970/21.

25 Article 2, Paragraph VII, of CMN Resolution No. 4,970/21.

26 Article 2, Paragraph VII, of CMN Resolution No. 4,970/21.

27 Article 14 of CMN Resolution No. 4,970/21.

28 Article 22 of Law No. 4,595/64.

29 Article 22, § 1, of Law No. 4,595/64.

30 Law No. 6,404 of December 15, 1976, as amended, sets forth the rules applicable to corporations; however, Law No. 4,595/64 and subsequent BCB regulations set forth specific rules regarding corporate structure, capital structure, governance, and other particularities that must be adopted by financial institutions. In certain cases, some financial institutions may be organized as limited liability companies, with such exceptions specified in their respective descriptions.

31 Article 25 of Law No. 4,595/64.

32 Articles 26 and 27 of Law No. 4,595/64.

33 Article 28 of Law No. 4,595/64.

34 The Brazilian National Economic Council was established by Article 205 of the Brazilian Federal Constitution and regulated by Law No. 970 of December 16, 1949.

35 The Basel III rules were introduced in Brazil through BCB Communication No. 20,615 of February 17, 2011.

36 Article 29 of Law No. 4,595/64.

37 Article 30 of Law No. 4,595/64.

 

III.3. Other Financial Institutions – Types of Public and Private Institutions

III.3.1. Savings Banks: The Federal Saving Bank (Caixa Econômica Federal – CEF) is a Brazilian public institution linked to the Brazilian Ministry of Finance, established by Decree-Law No. 759 of August 12, 1969. Like the state savings banks, which are linked to their respective federative units, CEF conducts typical commercial banking activities, with an institutional priority for granting loans and financing for social programs and projects. It operates as a public company with its own assets and administrative autonomy. CEF manages the resources of the Severance Indemnity Fund (Fundo de Garantia do Tempo de Serviço – FGTS)38 and other funds of the Brazilian Housing Finance System (Sistema Financeiro de Habitação, “SFH”)39. It is also responsible for the Brazilian Social Integration Program (Programa de Integração Social – PIS)40 and the Unemployment Insurance, in addition to holding the monopoly on federal lottery sales.

III.3.2. Commercial Banks: A commercial bank is a financial institution the main activity of which is the intermediation of financial resources and the custody of assets, and it may engage in the following activities: (i) raising funds from the public in the form of demand and term deposits or through the issuance of securities; (ii) granting credit operations, guarantees, sureties, and endorsements; (iii) providing collection and payment services; (iv) operating in the foreign exchange market; (v) conducting purchase and sale operations, on its own behalf or on behalf of third parties, of precious metals in the physical market, and intermediating the placement, in the over-the-counter market, of public offerings—primary or secondary—of securities; and (vii) performing other activities provided for by law or specific regulations41.

III.3.3. Multiple Banks: A multiple bank is a financial institution established with at least two of the following portfolios, one of which must be either commercial or investment: (i) commercial; (ii) investment; (iii) development; (iv) real estate credit; (v) credit, financing, and investment; and (vi) leasing42.

III.3.4. Cooperative Banks: A cooperative bank is a financial institution organized as a commercial or multiple bank, under the corporate control of central credit cooperatives. If established as a multiple bank, it must necessarily include a commercial portfolio43.

III.3.5. Investment Banks: An investment bank44 is a private financial institution specializing in temporary equity participation operations, financing productive activities for fixed and working capital, and managing third-party funds.

III.3.5.1. In addition to such activities, an investment bank is authorized to: (i) conduct purchase and sale operations, on its own behalf or on behalf of third parties, of precious metals in the physical market and of any securities in the financial and capital markets; (ii) operate on commodity and futures exchanges, as well as organized over-the-counter markets, on its own behalf and for third parties; (iii) operate in all forms of credit provision for financing fixed and working capital; (iv) participate in the issuance, subscription for resale, and distribution of securities; (v) operate in the foreign exchange market; (vi) coordinate processes of reorganization and restructuring of companies and conglomerates, financial or otherwise, through consulting services, equity participation, and/or granting of loans or financing; and (vii) carry out other operations provided for by law or specific regulations.

III.3.5.2. An investment bank may use, in its activities, not only its own resources but also funds from: (i) term deposits, with or without certificates; (ii) resources originating abroad, including through interbank transfers; (iii) official fund transfers; (iv) interbank deposits; and (v) other forms of funding provided for by law or specific regulations.

III.3.6. Development Banks: A development bank is a public financial institution established and controlled by a federative unit45. The primary objective of a development bank is to provide the necessary resources for the medium-term and long-term financing of programs and projects aimed at promoting the economic and social development of its respective federal unit, with a priority focus on supporting the private sector.

III.3.6.1. To achieve its objectives, a development bank may support initiatives aimed at: (i) expanding the productive capacity of the economy; (ii) encouraging productivity improvements; (iii) promoting the organization of regional economic sectors and the restructuring of companies; (iv) fostering agricultural production; and (v) promoting the adoption and development of production technology, managerial improvement, and the training and enhancement of technical personnel.

III.3.6.2. In its activities, a development bank may use, in addition to its own resources, funds from: (i) term deposits, with or without certificates; (ii) loans and financing obtained domestically and abroad; (iii) credit operations or contributions from the federal, state, or municipal public sector; (iv) issuance or trading of mortgage notes and real estate credit notes; (v) trading of agribusiness securities, notes, and certificates; (vi) issuance of agribusiness credit bills; (vii) issuance of financial bills; (viii) trading of bank credit note certificates; and (ix) other forms of funding provided for by law or specific regulations.

III.3.7. Foreign Exchange Banks: A foreign exchange bank46 is a financial institution authorized to carry out the following operations: (i) purchase and sale of foreign currency; (ii) transfer of funds to and from abroad; (iii) financing of imports and exports; (iv) advances on foreign exchange contracts (ACC); and (v) other operations, including the provision of services, as set forth by foreign exchange market regulations.

III.3.7.1. In addition to such activities, foreign exchange banks may:
(i) operate in the financial market, on exchanges (commodities and futures segments) and over-the-counter markets, conducting transactions on their own behalf, denominated in foreign currencies or linked to foreign exchange operations; (ii) make interbank deposits, in accordance with applicable regulations; and (iii) carry out other activities authorized by the BCB.

III.3.7.1. Foreign exchange banks may use, in addition to their own resources, funds originating from: (i) interbank transfers; (ii) interbank deposits; and (iii) resources raised abroad. Foreign exchange banks may maintain non-interest-bearing deposit accounts, non-transferable by the account holder, with funds designated for conducting operations or contracting the services they are authorized to provide.

III.3.8. Securities Brokers and Distribution Companies: Securities Brokers (Corretoras de Títulos e Valores Mobiliários, “CTVMs”) and Securities Distribution Companies (Distribuidoras de Títulos e Valores Mobiliários, “DTVMs”) may be organized as corporations or limited liability companies and operate in the financial, capital47 and foreign exchange markets, acting as intermediaries in the trading of securities between investors and borrowers48. The main difference between the two was that only CTVMs were authorized to operate directly in over-the-counter and stock exchange trading systems. However, with the enactment of BCB/CVM Joint Decision No. 17, dated March 3, 2009, DTVMs were authorized to perform virtually the same operations as CTVMs.

III.3.8.1. The main activities of DTVMs and CTVMs are: (i) buying and selling securities on their own behalf and on behalf of third parties; (ii) operating on commodity and futures exchanges on their own behalf and for third parties; (iii) intermediating public offerings and distributing securities in the market; (iv) operating on stock exchanges; (v) managing portfolios and custody of securities; (vi) subscribing to securities issued in the market; (vii) performing the functions of a fiduciary agent; (viii) establishing, organizing, and managing investment funds and clubs; (ix) intermediating foreign currency purchase and sale operations, as well as other foreign exchange market operations; (x) conducting purchase and sale operations of precious metals in the physical market, on their own behalf and for third parties; (xi) carrying out repurchase operations; (xii) conducting margin account operations; and (xiii) providing intermediation, advisory, or technical assistance services in operations and activities in the financial and capital markets.

III.3.9. Foreign Exchange Brokerage Companies: A foreign exchange brokerage company may be incorporated either as a corporation or as a limited liability company, and its exclusive corporate purpose shall be the intermediation of foreign exchange transactions and the conduct of operations in the foreign exchange market.

III.3.10. Consortium Management Companies: A consortium management company may be incorporated either as a corporation or as a limited liability company, and its main corporate purpose shall be the management of consortium groups. It may also provide other consortium management companies with services related to the sale and placement of quotas, the management of groups, and the performance of registration, research, and consultancy services.

III.3.11. Credit Unions: Credit unions51 are non-profit institutions established by the association of individuals to provide financial services exclusively to their members. The members are at the same time the owners and the users of the cooperative, participating in its management and benefiting from its products and services. The main services available in credit unions are checking accounts, financial investments, credit cards, loans, and financing.

III.4. Other Financial Institutions – Foreign Institutions

III.4.1. Foreign Financial Institutions: Foreign financial institutions may have a presence in the country through a subsidiary, branch, or representative office.

III.4.1.1. Subsidiaries and Branches: Until the supplementary law that will govern the SFN is approved by the National Congress, Article 52 of the Transitional Constitutional Provisions Act of the Federal Constitution remains in force, which prohibits the granting of authorization for the establishment of new financial institutions and branches of financial institutions domiciled abroad, as well as the increase of the ownership percentage held by individuals or legal entities residing or domiciled abroad in the capital of financial institutions with main place of business in Brazil; and excepts from such prohibition authorizations that result from international agreements, reciprocity, or the interest of the Brazilian Government. The recognition of the interest of the Brazilian Government in the establishment of new financial institutions domiciled abroad and their branches, as well as in the increase of the ownership percentage in the capital of financial institutions with main place of business in Brazil by individuals or legal entities residing or domiciled abroad, falls within the responsibility of the BCB and will depend on compliance with the requirements established by the CMN and the BCB. It shall also meet the requirements and procedures for incorporation, authorization to operate, revocation of authorization, changes in control, and corporate reorganizations of financial institutions, as provided for in the applicable regulations53.

III.4.1.2. Representative Office: The presence in the country of a financial institution or a similar entity domiciled abroad depends on prior authorization from the BCB54, which will take national interest into account when granting or denying such authorization. The representative office must be operated by an individual or legal entity domiciled in the country, which may only engage in commercial contacts and transmit information to the head office. The BCB shall have unrestricted access to all documents, reports, data, and information regarding the activities conducted by the representative.

38 FGTS is a fund established to protect workers dismissed without cause, through the opening of an account linked to their Employment Agreement.

39 SFH is a housing finance program aimed at reducing the country’s housing deficit.

40 PIS is a social contribution paid by private companies to finance benefits for workers, such as unemployment insurance, the annual bonus, and profit-sharing from company revenues.

41 Article 3 of CMN Resolution No. 5,060, of February 16, 2023 (“CMN Resolution No. 5,060/23”).

42 Article 4 of CMN Resolution No. 5,060/23.

43 Article 5 of CMN Resolution No. 5,060/23.

44 CMN Resolution No. 5,046, of November 25, 2022.

45 CMN Resolution No. 5,047, of November 25, 2022.

46 Resolution No. 3,436, of December 21, 2006.

47 CTVMs and DTVMs, like other institutions, are subject to regulation by the Securities and Exchange Commission of Brazil (CVM) for operations involving securities.

48 CMN Resolution No. 5,008, of March 24, 2022.

49 CMN Resolution No. 5,009, of March 24, 2022.

50 BCB Resolution No. 234, of July 27, 2022.

51 CMN Resolution No. 5,051, of November 25, 2022.

 

IV. NON-BANKING INSTITUTIONS55

IV.1. Credit, Financing, and Investment Companies: Credit, financing, and investment companies (Sociedades de Crédito, Financiamento e Investimento, “SCFIs”), commonly known as “finance companies,” have historically provided loans and financing for the acquisition of goods, services, and working capital, either linked to banks or as the financial arm of commercial and industrial groups.

IV.1.1. In 2024, the BCB issued Public Consultation No. 101/24 with the aim of modernizing and unifying the rules for SCFIs, which, since their establishment56, had been subject to scattered and already outdated regulations. As a result of the public consultation, on July 24, 2025, the CMN approved CMN Resolution No. 5,237 (“CMN Resolution No. 5,237/25”), which consolidates and updates the rules applicable to SCFIs, in addition to significantly expanding their scope of activities. In this context, CMN Resolution No. 5,237/25 incorporated into SCFIs the practices of more recent institutions, such as credit fintechs57 and payment institutions58, creating incentives for these companies to migrate to the SCFI segment as they expand their operations.

IV.1.2. As of September 1, 2025, the effective date of CMN Resolution No. 5,237/25, the credit and financing activities of SCFIs were expanded so that they are now authorized to: (i) buy and sell securities on their own account, operate in unorganized over-the-counter markets, and manage securities portfolios; (ii) operate as a fintech issuing electronic money and post-paid payment instruments (such as credit cards), acting as a payment transaction initiator and as an acquirer; (iii) operate in the foreign exchange market; (iv) act as a correspondent; (v) acquire, assign, refinance, and manage loans and credit rights, as well as perform credit analysis and collection services for third parties; (vi) act as a fiduciary agent; (vii) act as an insurance representative for the distribution of insurance related to their activities; and (viii) invest available funds in interbank deposits and enter into repurchase agreements.

IV.1.3. For this purpose, in addition to using their own resources, the means by which SCFIs may raise funds from third parties have been expanded and are now as follows: (i) issuance of certificates of bank deposit, agribusiness credit bills, real estate credit bills, secured real estate bills, financial bills, exchange bills, real estate credit notes, bank credit note certificates, deposit receipts, certificates of structured operations, and fundraising instruments abroad with certain limitations; (ii) interbank deposits and term deposits with special guarantees; (iii) transfers of loans and financings originating from (a) national financial institutions and other institutions authorized to operate by the BCB, (b) foreign financial institutions, and (c) national and foreign official entities and funds aimed at promotion and development actions.

IV.2. Real Estate Credit Company: A Real Estate Credit Company (Sociedade de Crédito Imobiliário, “SCI”)59 is a type of financial institution specialized in housing finance, part of the SFH, focused on financing for the construction of residential units, providing credit for the purchase or construction of owner-occupied homes, and financing working capital for real estate developers, as well as producers and distributors of construction materials. SCIs may function as fiduciary agents in real estate credit operations secured by mortgages and operate in real estate financing modalities for the allocation of funds raised through savings deposits within the Brazilian Savings and Loan System (Sistema Brasileiro de Poupança e Empréstimo – SBPE)60.

IV.3. Mortgage Company: Mortgage Company (Companhia Hipotecária, “CH”)61 was initially established to promote real estate financing outside the scope of the SFH, with the purpose of granting residential and commercial real estate loans, loans secured by mortgages or fiduciary transfer of property, and the transfer of funds related to real estate programs, in addition to managing real estate investment funds. With the establishment of the low income housing finance My House, My Life Program (Programa Minha Casa, Minha Vida – PMCMV)62, CHs became part of the SFH; however, unlike SCIs, they do not receive or allocate funds raised through savings deposits within the Brazilian Savings and Loan System (Sistema Brasileiro de Poupança e Empréstimo – SBPE). CHs raise funds through the issuance of mortgage bonds, real estate credit bills, secured real estate bills, financial bills, mortgage notes, real estate credit notes, certificates of bank credit notes, in addition to interbank deposits, and loans and financings both domestically and abroad.

IV.4. Development Agency: Development Agencies (agências de fomento, “AFs”) were established within the scope of the Program to Encourage the Reduction of Public Sector Participation in Financial Activities (Programa de Incentivo à Redução da Presença do Setor Público na Atividade Financeira – PROES)63 and are regulated by the BCB64. AFs are institutions established by the different federative units and have as their main objective the financing of working capital for enterprises aimed at expanding or maintaining the productive capacity of goods and services, as provided in the economic and social development programs of the federative unit in which they have their main place of business. The beneficiaries of the financing are infrastructure projects, self-employed professionals, and micro and small enterprises. AFs finance infrastructure projects in various sectors, such as industry, commerce, agriculture, technology, and agribusiness.

IV.5. Leasing Company: A Leasing Company (Sociedade de Arrendamento Mercantil, “SAM”)65 is an institution supervised by the BCB and is treated as a financial institution, being subject to the same operational conditions as financial institutions under Law No. 4.595/64. The main purpose of SAMs is to perform leasing transactions, which are defined as legal arrangements entered into between a legal entity, as the lessor, and an individual or legal entity, as the lessee, having as their object the leasing of assets acquired by the lessor according to the specifications of the lessee and for the latter’s own use66.

IV.5.1. Leasing transactions are classified as either operating leases or financial leases. The main differences are as follows:

      1. in financial lease transactions, (a) the lease payments and other amounts owed by the lessee under the agreement must be sufficient for the lessor to recover the cost of the leased asset during the term of the contract and to obtain some profit on the resources invested, (b) expenses related to maintenance, technical assistance, and services associated with the leased asset are the responsibility of the lessee, and (c) the price for exercising the purchase option of the leased asset may be agreed upon between the parties; and
      2. in operating lease transactions, (a) the lease payments must cover the cost of leasing the asset and the services necessary to make the asset available to the lessee, and the present value of the payments may not exceed 90% of the cost of the asset, (b) the contractual term must be shorter than 75% of the useful life of the asset, (c) the price for exercising the purchase option must correspond to the market value of the leased asset, and (d) payment of the guaranteed residual value (GRV) may not be included.

IV.6. Savings and Loan Association: A Savings and Loan Association (Associação de Poupança e Empréstimo, “APE”) is an institution organized as a civil association, with a restricted regional scope, the fundamental purposes of which are to provide or facilitate the acquisition of home ownership for its members and to raise, encourage, and promote savings. APEs are participants in the SFH, and their managers are subject to the same rules applicable to financial institutions67.

IV.6.1. A cash deposit made by an individual into an APE creates a membership relationship, and the individual becomes a member. Deposits may be intended either for obtaining real estate financing or for building savings. The CMN68 determines the funding sources of APEs (which, in addition to deposits received from members, may raise interbank deposits, issue real estate credit bills, secured real estate bills, and real estate credit notes; and obtain loans and financings) and the investments that must be directed to the real estate market, including the SFH. According to the BCB, over time APEs have lost significance in the SFN, leaving only Poupex – – Associação de Poupança e Empréstimo (savings and loan association), the sole APE still in operation, established by Law No. 6,855, of November 18, 1980.

IV.7. Microentrepreneur and Small Business Credit Company: Microentrepreneur and Small Business Credit Companies (Sociedade de Crédito ao Microempreendedor e à Empresa de Pequeno Porte, “SCMEPP”)69 are organized as closely-held corporations or limited liability companies and are supervised by the BCB70. The primary activity of SCMEPPs is the granting of financing to individuals, microenterprises, and small businesses, with the purpose of enabling professional, commercial, or industrial undertakings.

IV.8. Virtual Asset Service Providers: On December 21, 2022, Law No. 14,478 was enacted, establishing the legal framework for virtual asset services, considered to be the landmark legislation for cryptocurrencies. Decree No. 11,563, of June 13, 2023, in regulating the law, assigned the BCB the authority to regulate the provision of virtual asset services, and to regulate, authorize, and supervise virtual asset service providers, except in cases in which financial assets are considered securities, in which case the authority falls to the CVM. The BCB is in the process of conducting public consultations and preparing regulations related to the provision of these services.

IV.9. Corresponding Companies: CMN Resolution No. 4,935, of July 29, 2021 (“CMN Resolution No. 4,935/21”) sets forth that financial institutions and other institutions authorized to operate by the BCB may engage corporations, individual entrepreneurs, associations71, notarial and registry service providers72, and public companies to act as correspondents in providing customer and user service activities. Prior approval from the BCB is not required for the engagement of these entities, except if the entity is not part of the SFN and its name employs terms characteristic of SFN institutions, or similar expressions in other languages. The corresponding company may provide services in person or through an electronic platform and must act on behalf of and under the guidelines of the contracting institution, which assumes full responsibility for the services provided. The contracting institution is responsible for ensuring the integrity, reliability, security, and confidentiality of transactions conducted through the correspondent, as well as compliance with the laws and regulations applicable to such transactions. Services provided by correspondents include: (i) receiving and forwarding proposals for the opening of deposit and payment accounts maintained by the contracting institution; (ii) performing receipts, payments, and electronic transfers for the movement of deposit and payment accounts held by clients with the contracting institution; (iii) handling receipts and payments of any nature, and other activities arising from the execution of service contracts and agreements maintained by the contracting institution with third parties; (iv) executing payment orders, both actively and passively, processed through the contracting institution at the request of clients and users; (v) receiving and forwarding proposals for credit and leasing transactions granted by the contracting institution, as well as other services necessary to monitor the operation; (vi) handling receipts and payments related to bills of exchange accepted by the contracting institution; and (vii) executing foreign exchange operations under the responsibility of the contracting institution.

IV.10. Corresponding Companies for Foreign Exchange Transactions: CMN Resolution No. 4,935/21 established the rules for the provision of services in foreign exchange transactions, which basically include: (i) the purchase and sale of foreign currency in cash, by check, or by traveler’s check, as well as the loading of foreign currency onto prepaid cards; (ii) the active or passive execution of payment orders related to unilateral transfers to or from abroad; and (iii) the receipt and forwarding of proposals for foreign exchange transactions. Such services are restricted to foreign exchange transactions limited to USD 3,000.00 per transaction. In the case of the purchase or sale of foreign currency in cash with the delivery of the equivalent amount in domestic currency also in cash, the limit is USD 1,000.00, or the equivalent amounts in other currencies.

IV.11. Credit Fintechs: Credit Fintechs are companies that use financial technology to conduct lending and financing operations73. There are two types of credit fintechs: Direct Credit Companies (Sociedades de Crédito Direto, “SCDs”) and Peer-to-Peer Lending Companies (Sociedades de Crédito Direto, “SEPs”).

IV.11.1. Direct Credit Companies: SCDs are financial institutions the purpose of which is to carry out lending, financing, and the acquisition of credit rights exclusively through electronic platforms, using their own resources or through transfers and loans originating from the BNDES. They may also provide the following services: (i) credit analysis and collection on behalf of third parties; (ii) acting as insurance representatives for the distribution, via electronic platforms, of insurance related to their activities; and (iii) issuance of electronic money, post-paid payment instruments, and initiation of payment transactions.

IV.11.2. Peer-to-Peer Lending Companies: SEPs are financial institutions the purpose of which is to conduct lending and financing operations between individuals exclusively through electronic platforms. They may also provide the following services: (i) credit analysis and collection for clients and third parties; (ii) acting as insurance representatives for the distribution, via electronic platforms, of insurance related to their activities; and (iii) issuance of electronic money and initiation of payment transactions.

52 Resolution Decree 10,029, of September 26, 2019.

53 BCB Circular Letter No. 3,977, of January 22, 2020.

54 BCB Resolution No. 2,592, of February 25, 1999.

55 Non-banking institutions are options for clients and consumers to access financial services other than through banks. These institutions may not accept demand deposits nor make money through credit operations. The regulation and supervision of these institutions and/or their activities, as well as the authorization for their operation, unless otherwise specified in the description of the respective institution, fall within the responsibility of the BCB and the CMN. Activities related to securities will also be supervised and subject to the rules of the CVM.

56 SCFIs were originally established by the Ministry of Finance Ordinance No. 309, of November 30, 1959.

57 See 4.11 below.

58 See 5.3.1 and 5.3.2 below.

59 CMN Resolution No. 5,000, of March 24, 2022.

60 CMN Resolution No. 5,197, of December 19, 2024.

61 CMN Resolution No. 4,985, of February 17, 2022.

62 Law No. 11,977, of July 7, 2009.

63 Program created in 1996 by a provisional measure, which was reissued numerous times during the implementation of the Program.

64 BCB Resolution No. 2,828, of March 30, 2001.

65 CMN Resolution No. 4,977, of December 16, 2021.

66 Definition established by Law No. 6,099, of September 12, 1974, which, in defining the tax treatment applicable to leasing transactions, also set forth their nature and characteristics.

67 Decree-Law No. 70, of November 21, 1966.

68 CMN Resolution No. 5,052, of November 25, 2022.

69 Law No. 10,194, of February 14, 2001.

70 BCB Resolution No. 4,721, of May 30, 2019.

71 As defined in Law No. 10,406, of January 10, 2002.

72 As defined in Law No. 8,935, of November 18, 1994.

73 CMN Resolution No. 5,050, of November 25, 2022, as amended by CMN Resolution No. 5,159, of July 24, 2024, was affected by CMN Resolution No. 5,237/25 (see 5.3.2 below), which, among other innovations, facilitated the transformation of SCDs into SCFIs, granting access to new fundraising alternatives and greater operational flexibility.

 

V. BRAZILIAN PAYMENT SYSTEM (SPB) AND PAYMENT SCHEMES

V.1. Brazilian Payment System: Law No. 10,214, of March 27, 2001, established the legal foundations of the Brazilian Payment System (Sistema de Pagamentos Brasileiro, “SPB”) by instituting rules for the clearing and settlement of transfers of funds and other financial assets. Subsequently, Law No. 12,865, of October 9, 2013, introduced regulations on electronic payments and electronic money. The SPB is composed of two segments: Financial Market Infrastructures (Infraestruturas do Mercado Financeiro, “IMFs”); and Payment Schemes that are part of the SPB (Arranjos de Pagamento Integrantes do SPB, “SPB Payment Schemes”), which are subject to regulation by the CMN, in addition to oversight by the BCB and the CVM in operations involving their respective competencies.

V.1.1. Financial Market Infrastructures: IMFs74 form a multilateral system among participating institutions, which comply with a set of rules, carry out established procedures, and maintain an operational structure to perform the clearing, settlement, centralized custody, and recording of payments and financial assets. IMFs may be organized in different forms, depending on the purpose for which they are established. There are five types of IMFs75:

        1. Payment Systems (PS): systems for the settlement of fund transfers or foreign currency and high-value payments, generally operated by central banks;
        2. Securities Settlement Systems (SSS): systems that perform the final transfer of securities and money;
        3. Central Counterparties (CCP): clearing and settlement entities that interpose themselves between counterparties in a transaction to guarantee its performance;
        4. Central Securities Depositories and Registration Entities (CSD): providers of centralized custody services for financial assets and securities; and
        5. Trade Repositories (TRs): entities that maintain centralized electronic records of transaction data (financial assets and securities, counterparties, derivatives) and may also perform recordkeeping functions.

V.1.1.1. IMFs are operated by the BCB and Operators of Financial Market Systems (Instituições Operadoras de Sistemas do Mercado Financeiro – IOSMF)76, and their participants are Financial Market Systems (Sistemas do Mercado Financeiro – SMFs)77.

V.1.2. Payment Schemes that are part of the SPB: The SPB Payment Schemes78 are defined as the set of rules and procedures governing the provision of a given payment service to the public, accepted by more than one payee, with direct access by end users, and which, among other requirements, involve amounts and numbers of transactions exceeding certain thresholds79. Its participants, financial institutions and payment institutions80, manage the procedures required for a payment system to operate, in compliance with the regulations of the CMN and the BCB. Examples of SPB Payment Schemes are the credit, debit, and prepaid card networks; institutions issuing or receiving Electronic Fund Transfers (Transferência Eletrônica Disponível – TED); institutions receiving or processing payment slips; and the instant payment platform – Pix.81

V.2. Payment Schemes Not Part of the SPB: Payment schemes that do not meet the requirements to be part of the SPB82 or that cannot be integrated into the SPB under applicable regulations, are not subject to regulation by the BCB. Examples include cards issued by large retailers that can only be used at the issuing store or in affiliated networks (private label), payments for public services (such as water, electricity, and gas), or the charging of prepaid transport cards meal vouchers, and food vouchers.

V.3. Payment Schemes and Payment Institutions: A payment scheme comprises (i) a payment institution (Instituição de Pagamento, “IP”)83, (ii) the means through which the payment will be made (such as a payment slip, credit card, mobile phone, etc.), and (iii) the scheme founder, which is the legal entity responsible for creating and organizing the scheme (for example, credit card labels). In a payment scheme, all participants in the payment chain must adhere in advance to the rules of the scheme established by the founder, so that the payer and the payee can conduct and accept payments. These rules define the procedures and conditions of a payment scheme, such as the settlement timeframe, security rules, and participation requirements.

V.3.1. Payment Institutions: BCB Resolutions No. 80 and No. 81, of March 25, 2021, define IPs as legal entities incorporated as limited liability companies or corporations that enable the provision of purchase, sale, and fund transfer services within the scope of a payment scheme, without requiring the user to have a relationship with banks or other financial institutions84. IPs are non-financial institutions subject to supervision by the BCB. In summary, the types of IPs are: (i) electronic money issuers85, which manage prepaid payment accounts for end users, where funds are deposited prior to the transaction (for example, prepaid card issuers and meal voucher providers); (ii) post-paid payment instrument issuers (e.g., credit cards), which manage the end user’s payment account where funds are deposited to settle the debt; (iii) acquirers, which enable merchants to accept the payment instrument used (for example, Cielo and Rede); and (iv) payment initiators, which initiate payment transactions without managing the payment account or receiving the funds (for example, WhatsApp Pay).

V.3.2. CMN Resolution No. 5,237/25, which consolidated and updated the rules applicable to SCFIs86, will allow payment and credit services to be provided by the same type of institution (the so-called “financeiras”, a type of finance company), enabling a single institution to unify different operations previously performed by separate entities. This simplifies operations within its digital wallet, allows it to execute certain types of payment schemes, and simultaneously function as an acquirer, enabling merchants to accept payment instruments.

74 IMFs follow the rules and guidelines set out in the Principles for Financial Market Infrastructures (PFMI), published by the Bank for International Settlements (BIS) in cooperation with the International Organization of Securities Commissions (IOSCO). The PFMIs are international recommendations that must be followed by payment systems, central securities depositories, custody and settlement systems, central counterparties, and other entities providing infrastructure for financial institutions.

75 These five types of IMFs are established by the PFMIs.

76 BCB Resolution No. 304, of March 20, 2023.

77 Examples of SMFs include the Instant Payment System (SPI), the Special System for Settlement and Custody (SELIC), and the Reserve Transfer System (STR).

78 BCB Resolution No. 150, of October 6, 2021 (“BCB Resolution No. 150/21”).

79 Article 2, item II, of BCB Resolution No. 150/21 sets forth that the consolidated volume of transactions occurring in the previous 12 months must (i) have a total value exceeding BRL 20 billion, and (ii) comprise more than one hundred million transactions.

80 See 5.3.1 below.

81 The BCB, to modernize the SFN and make transfers faster, more efficient, and more accessible, established the Pix payment scheme through the issuance of Resolution No. 1, of August 12, 2020. Pix is a free, instant payment system, available on a permanent basis (24/7), and has achieved broad acceptance, with user adoption steadily increasing.

82 BCB Resolution No. 150/21.

83 In addition to PIs, financial institutions may also participate in the payment scheme.

84 Fintechs that operate with debit cards, credit cards, and card readers, and that process up to a certain amount of funds, are an example of PIs.

85 BCB Resolution No. 257, of November 16, 2022, establishes value limits under which an electronic money issuer is exempt from applying for authorization to operate with the BCB.

86 See 4.1 and following above.

 

VI. OPEN FINANCE SYSTEM – OPEN FINANCE

VI.1. In order to increase the efficiency of the SFN and the SPC, encourage innovation, and promote competition among participants, on May 4, 2020, the CMN and the BCB issued Joint Resolution No. 1, which established Open Finance. Open Finance consists of the standardized sharing of data and services through the opening and integration87 of systems of financial institutions, payment institutions, and other entities authorized to operate by the BCB. Since then, the BCB has been issuing regulations for the gradual implementation of Open Finance.

VI.2. Mandatory participants in Open Finance are: (i) for data sharing: (a) multiple banks, commercial banks, investment banks, exchange banks, and savings banks with a size exceeding 1% of GDP, or that engage in significant international activity; and (b) other institutions with a size equal to or greater than 1% of GDP; (ii) for sharing payment initiation services: (a) institutions that maintain demand deposit accounts, savings accounts, and prepaid accounts; and (b) institutions acting as payment initiators; and (iii) for sharing and forwarding credit proposals: financial institutions that have contracts with correspondents to receive and forward credit operation proposals via electronic platforms. Open Finance also allows voluntary participation of institutions and may exempt institutions from participation, provided they meet certain requirements established by the BCB.

VI.3. With the customer’s consent (individual or legal entity), Open Finance enables the sharing, among one or more participating institutions of their registration data (such as name, tax ID, address, and phone number), account and credit card statements, credit operations, investments, foreign exchange transactions, and other financial data related to checking accounts and banking history. Such sharing allows participating institutions to offer products better suited to the customer’s profile, with better rates and lower fees, and to expedite processes for product contracting and account opening. It also facilitates the use of electronic platforms for money transfers between accounts, online payments, scheduling transfers between institutions, recurring transactions, linking for debits on e-commerce sites and digital wallets, and other operations.

87 The sharing of data and services is carried out through APIs (Application Programming Interfaces), which are application programming interfaces used worldwide for communication between software over the Internet.

Autor: Daniel F. Pita

Chiarottino e Nicoletti Advogados

Av. Juscelino Kubitschek, 1700 • 5º e 11º andares
Edifício Plaza JK • Vila Olímpia
04543-000 • São Paulo • SP • Brasil
Tel +55 11 2163-8989
www.chiarottino.com.br

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