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Banks, Financial Services, Fintechs and Digital Assets Newsletter – January 2025

February 6th, 2025

REGULATIONS

Central Bank of Brazil 

BCB Resolution No. 452, dated January 21, 2025

BCB Resolution No. 452, of January 21, 2025, amends BCB Resolutions No. 229, of May 12, 2022; No. 437, of November 28, 2024; and Circular No. 3,748, of February 27, 2015.

BCB Resolution No. 452, published by the Central Bank of Brazil (“BC”), establishes new guidelines for maintaining adequate levels of capital, liquidity, and risk exposure of financial institutions. These measures aim to trigger the financial system’s resilience to crises and further mitigate losses to society, even in scenarios of instability.

BCB Resolution No. 452 entered into force on January 31, 2025.

Read BCB Resolution No. 452 in full

 

BCB Resolution No. 450, dated January 15, 2025

BCB Resolution No. 450, of January 15, 2025, establishes the essential activities required to fulfill the BC’s institutional mission which must be fully operational in the event of a shutdown or strike.

BCB Resolution No. 450 outlines the indispensable services and functions that guarantee compliance with the BC’s institutional goals – as established by Complementary Law No. 179, of February 24, 2021 –, such as ensuring price stability, safeguarding the stability and efficiency of the financial system, moderating fluctuations in economic activity, and fostering full employment.

In addition, the resolution specifies that, in the event of a strike or shutdown, responsible units must observe the legal duty to comply with the obligations subject to specific deadlines, whose failure could severely impact the municipality, its employees, or the community. These obligations include: ensuring the proper functioning of Pix in cases involving serious risk to its normal functioning; filing sanctioning administrative proceedings and notifying other bodies about facts under the statute of limitations; meeting external requests from constituted powers (judges, prosecutors, delegates, Congress, etc.); among other obligations provided for by this resolution.

BCB Resolution No. 450 entered into force on the date of its publication.

Read BCB Resolution No. 450 in full

 

BCB Normative Instruction (“IN”) No. 584, dated January 28, 2025

BCB IN No. 584, of January 28, 2025, establishes the accounting items to be used in the calculation of the minimum requirements for the Simplified Reference Equity (“PRS5”) and the Reference Capital of a Payment Institution (“PRIP”).

Additionally, it describes the accounting items relating to the calculation of the minimum requirements for simplified risk-weighted assets (“RWAS5”), as well as risk-weighted assets for payment institutions (“RWAIP”).

BCB IN No. 584 entered into force on January 31, 2025.

Read BCB IN No. 584 in full

 

BCB IN No. 581, dated December 30, 2024

BCB IN No. 581, of December 30, 2025, amended BCB IN No. 511, of August 30, 2024, which establishes the essential procedures for joining Pix. The resolution aims to adjust provisions relating to the user institution, the Automatic Pix, and resources within the scope of Pix participant processes.

Furthermore, BCB IN No. 581 introduces new forms and adjustments to Pix adherence processes, including implementing the “Automatic Pix – Receiving” (Pix Automático – Recebimento). These forms – such as the intention to offer products and services as well as the one involving Automatic Pix journeys – aim to facilitate the integration of financial institutions into the system, ensuring greater efficiency and safety in transactions. The resolution also reinforces the need to comply with the templates available in the specific attachments, thus fomenting standardization to benefit both institutions and end users.

BCB IN No. 581 entered into force on January 01, 2025.

Read BCB IN No. 581 in full

 

BCB IN No. 580, dated December 30, 2024

BCB IN No. 580, of December 30, 2024, amends BCB IN No. 508, of August 30, 2024, which establishes the necessary procedures for formal homologation tests within the scope of Pix, aiming to amend provisions involving the user institution.

BCB IN No. 580 entered into force on January 01, 2025.

Read BCB IN No. 580 in full

 

BCB IN No. 579, dated December 27, 2024

BCB IN No. 579, of December 27, 2024, amends BCB IN No. 318, of November 04, 2022, which outlines the accounting subgroups of the list of accounts integrating the Accounting Standard of Institutions Regulated by the BC (“COSIF”), to be used by financial and other institutions authorized to operate by the BC.

As BCB Resolution No. 390, of June 12, 2024, postponed to January 2030 the extension of the number of subgroup digits as well as the subgroup code breakdown for accounting items integrating the list of COSIF accounts, provided for in BCB Resolution No. 92, of May 06, 2021, the BC decided to publish BCB IN No. 579. This IN postponed the effectiveness of BCB IN No. 318, of 2022, which establishes the COSIF subgroups, already considering the extension of the number of digits, to align it with the changes implemented by BCB Resolution No. 390, of 2024.

BCB IN No. 579 entered into force on January 01, 2025.

Read BCB IN No. 579 in full

 

BCB IN No. 578, dated December 26, 2024

BCB IN No. 578, of December 26, 2024, revokes BCB IN No. 450, of January 18, 2024, and establishes the applicable percentages for cash withdrawal, deposit, and exchange transactions intended for remunerating Banco do Brasil, the custodian institution.

BCB IN No. 578 entered into force on the date of its publication.

Read BCB IN No. 578 in full

 

BCB IN No. 577, dated December 26, 2024

BCB IN No. 577, of December 26, 2024, reviews and amends BCB IN No. 428 and BCB IN No. 433, both dated December 01, 2023, aimed at creating accounting items in COSIF’s list of accounts.

The resolution includes new accounting items in the annexes of BCB IN No. 428 and BCB IN No. 433, aiming to record negative adjustments of expected equity losses. These amendments seek to ensure greater accuracy and transparency in the accounting of expected losses, in compliance with the criteria established in CMN Resolution No. 4,966, of 2021, and BCB Resolution No. 352, of 2023.

BCB IN No. 577 entered into force on January 01, 2025.

Read BCB IN No. 577 in full

 

NEWS

BC extends deadline for public consultation on interoperability fees between payment arrangement receivables registrars

On January 21, 2024, the BC published Public Consultation Notice (“ECP”) No. 114, amending the deadline for ECP No. 113, which provides for BC’s proposed resolution regulating the standardization of interoperability events that can be charged between payment arrangement receivables registrars, in addition to establishing the maximum limits for the amounts of these fees and their collection methods.

Following this innovation, the public consultation published on December 20, 2024, will end on March 05, 2025, and no longer on February 03, 2025, totaling 75 days for submitting contributions to improve the interoperability fee structure. According to the BC, the changes introduced by ECP No. 113 are aimed at improving the provision of interoperability services between payment arrangement receivables registrars, as well as fostering competition within the credit market based on such receivables.

Interested parties can submit contributions by March 05, 2025, through www.gov.br/participamaisbrasil and www.bcb.gov.br, and the following e-mail address: decem.dipea@bcb.gov.br.

Read the article in full

Read ECP No. 113/2024 and ECP No. 114 in full

 

Public consultation on foreign exchange operations between financial institutions continues, with contributions due by March 14

The BC published Public Consultation (“CP”) No. 112/2024 in December 2024, establishing that public contributions can be submitted by March 14, 2025.

The aforementioned CP aims to align interbank exchange operations with recent changes in foreign exchange regulation, introduced primarily by Law No. 14,286, of December 29, 2021 (Foreign Exchange and Capital Law). ECP No. 112 seeks to improve the efficiency of operations within the foreign exchange market and streamline information provision to the BC.

ECP No. 112 suggests that interbank foreign exchange transactions be treated as exchange transactions with clients, allowing them to be freely formalized. Moreover, it establishes specific time slots (from 7 a.m. to 7 p.m.) for providing information to the BC and allows for automatic early settlements – as well as operation changes or cancellations, provided that both parties agree.

The innovations will require adjustments and tests to be implemented in the information systems of the institutions authorized to operate within the foreign exchange market and BC systems. These changes will be introduced progressively from 2025 to 2026.

Read the article in full

Read ECP No. 112/2024 in full

 

BC campaigns for shielding Drex from fake news

The BC launched a campaign to protect its digital currency, Drex, from misinformation. The initiative aims to inform the public about Drex’s functioning and safety while combating fake news that could hinder its acceptance.

The campaign includes educational videos, informational materials, and partnerships with digital influencers to spread accurate information. The goal is to ensure that the population trusts the new digital currency and comprehends its benefits.

Read the article in full

 

Pix Forum holds discussions for improving instant payment mechanism

On December 05, 2024, the BC held the 23rd Plenary Meeting of the Pix Forum. The meeting discussed improvements to Pix safety, including the Special Return Mechanism (“MED 2.0”), scheduled for the first quarter of 2026. MED 2.0 will allow the tracking of fraudulent resources beyond the first receiving account, thus increasing the system’s safety.

Another innovation is “Pix-by-proximity”, which is already operating. This modality allows payments to be made by approaching one’s smartphone to the recipient’s device through a Near Field Communication (“NFC”) technology. Digital wallets and financial institution applications can offer this service.

Additionally, the Automatic Pix has been available since October 2024, and allows recurring payments to be made automatically, upon prior authorization of the user. This will facilitate paying monthly bills and other recurring services.

Read the article in full

 

BC swears new president and directors into office

The BC announced that the new president, Gabriel Galípolo, and three new directors have taken office, as follows: Izabela Correa, Gilneu Vivan, and Nilton David.

Gabriel Galípolo has replaced Roberto Campos Neto as BC’s president.

Izabela Correa has replaced Carolina de Assis Barros as Director of Relationship, Citizenship, and Conduct Supervision.

Gilneu Vivan has replaced Otavio Damaso as Regulatory Director.

Nilton David has replaced Gabriel Galípolo as Monetary Policy Director.

Read the article in full

 

BC holds cyber exercise simulations with authorized entities

From December 09 to December 13, 2024, the BC held the 1st Cyber Exercise with Supervised Entities. The five largest retail banks in Brazil have attended the event.

The goal was to improve the response to cyber crises by simulating problems such as ransomware attacks (that is, cyber attacks involving information theft). The participating institutions responded according to their continuity and crisis management plans, further discussing solutions in collective sessions. The evaluation of the exercise was positive, thus highlighting the importance of establishing a collaboration between institutions to address cyber incidents.

Read the article in full

 

BC postpones deadline for closing three CPs

On January 30, 2025, the BC’s Board of Directors extended the deadlines for CP No. 108, CP No. 109, and CP No. 110 until February 28, 2025.

 

CP No. 108 – Banking as a Service (“Baas”)

This CP seeks contributions to regulate Baas business models, which involve partnerships between institutions authorized by the BC and other companies to offer financial services. The previous deadline was January 31, 2025.

 

CP No. 109 and CP No. 110 – Virtual Asset Service Providers (“PSAVs”)

Both consultations aim to regulate PSAVs. CP No. 109 addresses the creation and operation of PSAVs and the collection of tariffs. CP No. 110 addresses the authorization processes for operating PSAVs and other distribution institutions, such as foreign exchange brokers, securities brokers, and securities distributors. The previous deadline was February 07, 2025.

The extensions aim to allow for a more detailed and cautious analysis of the proposals, given that the regulations for these services are still incipient.

Read the article in full

Read ECP No. 115/2025 and ECP No. 116/2025 in full

Related Partners

Related Lawyers

Fausto Muniz Miyazato Teixeira

fmteixeira@demarest.com.br

Guilherme Zeppelini Inaba

gzinaba@demarest.com.br

Yuri Kuroda Nabeshima

ynabeshima@demarest.com.br


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