CMN and BCB enhance liquidity rules and adjust the FGC contribution framework

The National Monetary Council (“CMN”) approved, at a session held on April 23, 2026, a set of regulatory measures aimed at enhancing liquidity management by financial institutions and strengthening the mechanisms associated with the guarantee provided by the Credit Guarantee Fund (“FGC”), as follows:

CMN Resolution No. 5,295 (“CMN Resolution 5,295”)[1];

[1]Amends CMN Resolution No. 4,222, of May 23, 2013 (“CMN Resolution 4,222”), which provides for the contributions payable by member institutions, the conditions for the provision of the special guarantee, the types of member institutions, and the bylaws and regulations of the FGC.
Resolução n.º 5.296 do CMN (“Resolução CMN 5.296”)[2]; e

[2]Provides for the minimum thresholds of the Short-Term Liquidity Coverage Ratio (“LCR”) and the Simplified Short-Term Liquidity Coverage Ratio (“LCRS”), as well as the conditions for their compliance.
Resolution No. 560 of the Central Bank of Brazil (“BCB Resolution 560” and “BCB”, respectively) [3].

[3] Provides for the minimum thresholds of the LCR and the LCRS, as well as the conditions for their compliance.

The new rules, published on the date of the aforementioned session, aim to reduce systemic risks, strengthen depositor protection, and contribute to the stability of the National Financial System.
The approved regulations are summarized below.

The approved regulations are summarized below.

CMN Resolution 5,295

CMN Resolution 5,295, which enters into force on June 1, 2026, established new rules regarding the additional contribution and the conditions under which FGC-member institutions must hold amounts allocated exclusively in federal government securities.

These measures complement the existing regulatory framework and seek to mitigate incentives for fundraising that is excessively backed by the FGC guarantee, thereby contributing to risk reduction and to the preservation of financial system stability.

Additional Contribution

Among the amendments, the regulation adjusted the triggering conditions for the additional contribution, which becomes due when the Reference Value exceeds 4 times the Adjusted Net Equity and 60% of the Reference Fundraising of the FGC-member institution, as measured in the preceding month, in accordance with the formula set forth in CMN Resolution 5,295.

Introduction of the Reference Asset Concept and Mandatory Allocation Requirements in Federal Government Securities

In addition, CMN Resolution 5,295 introduced the concept of the Reference Asset as a new parameter, related to the composition and quality of the assets of FGC-member financial institutions, for the obligation to maintain amounts allocated in federal government securities, supplementing the existing liability-based criteria.

When the volume of funds raised with the FGC guarantee exceeds the Reference Asset, the institution must direct part of such funds to federal government securities, subject to a gradual phase-in beginning July 1, 2026.

It will be incumbent upon the BCB to establish the methodology for calculating the Reference Asset, as well as the procedures relating to the calculation of the amount to be allocated and the registration of the corresponding federal government securities.

Accordingly, the FGC-member institution must maintain amounts allocated exclusively in federal government securities when the Reference Value exceeds:

6 times the Adjusted Net Equity and 80% of the Reference Fundraising;
10 times the Adjusted Net Equity; or
the Reference Asset.

Prudential Liquidity Requirements

The CMN and the BCB also approved new rules aimed at enhancing prudential liquidity requirements, through CMN Resolution 5,296 and BCB Resolution 560, which jointly set forth the minimum thresholds for the Short-Term Liquidity Coverage Ratio (“LCR”) and the Simplified Short-Term Liquidity Coverage Ratio (“LCRS”), as well as the conditions for their compliance.

The measures were implemented through complementary regulatory acts issued by the CMN and the BCB, in light of their different regulatory scopes. The distinction arises from the fact that the prudential segmentation into Segment 1 (“S1”)[4], Segment 2 (“S2”)[5], Segment 3 (“S3”)[6], and Segment 4 (“S4”)[7] does not coincide with the classification of institutions and conglomerates into Type 1 [8], Type 2[9], and Type 3[10]. Accordingly, while both regulations address liquidity requirements applicable to institutions classified within certain prudential segments, each one governs its respective institutional universe subject to the applicable regulatory authority.

[4]As defined in § 1 of Article 2 of CMN Resolution No. 4,553, of January 30, 2017 (“CMN Resolution 4,553”), S1 comprises multiple-service banks, commercial banks, investment banks, exchange banks, and savings banks that: (i) have a size equal to or greater than 10% (ten percent) of the Gross Domestic Product (“GDP”); or (ii) carry out relevant international activity, regardless of the institution’s size.
[5]As defined in § 2 of Article 2 of CMN Resolution 4,553, S2 comprises: (i) multiple-service banks, commercial banks, investment banks, exchange banks, and savings banks with a size below 10% (ten percent) and equal to or greater than 1% (one percent) of the GDP; and (ii) other institutions with a size equal to or greater than 1% (one percent) of the GDP.
[6]As defined in § 3 of Article 2 of CMN Resolution 4,553, S3 comprises institutions with a size below 1% (one percent) and equal to or greater than 0.1% (one tenth of one percent) of the GDP.
[7]As defined in § 4 of Article 2 of CMN Resolution 4,553, S4 comprises institutions with a size below 0.1% (one tenth of one percent) of the GDP.
[8]As defined in item I of Article 2 of Resolution No. 436 of the BCB, of November 28, 2024 (“BCB Resolution 436”), the following are classified as Type 1: (i) a singular institution authorized to operate by the Central Bank of Brazil, except for: (a) a payment institution; (b) a securities brokerage company; (c) a securities distribution company; and (d) an exchange brokerage company; and (ii) a prudential conglomerate led by an institution referred to in subitem “(i)” above.
[9]As defined in item II of Article 2 of BCB Resolution 436, the following are classified as Type 2: (i) a singular payment institution; and (ii) a prudential conglomerate led by a payment institution and composed exclusively of: (a) payment institutions authorized to operate by the BCB; (b) payment institutions not authorized to operate by the BCB; (c) entities that engage in the acquisition of credit operations, including real estate operations, or of credit rights, such as commercial factoring companies, securitization companies, and single-purpose entities; (d) other legal entities whose corporate purpose is exclusively the equity interest in the entities mentioned in subitems “(a)” to “(c)” above; or (e) investment funds.
[10]As defined in item III of Article 2 of BCB Resolution 436, the following are classified as Type 3: (i) a securities brokerage company, a securities distribution company, and an exchange brokerage company; (ii) a prudential conglomerate led by an institution referred to in subitem “(i)” above; and (iii) a prudential conglomerate led by a payment institution not mentioned in subitem “(ii)” of the definition of Type 2 above.

2.1 LCR e LCRS

The LCR, provided for in the international standard known as Basel III, has as its primary purpose to ensure, under normal market conditions, the formation and maintenance of a reserve of liquid assets by regulated entities, which must be available for use in periods of greater scarcity or liquidity needs, thereby allowing the fulfillment of obligations, the continuity of the institution’s operations, and the preservation of financial system stability.

The LCRS, in turn, follows a conceptual logic similar to that of the LCR and measures the ratio between the stock of high-quality liquid assets and the projected net cash outflows over a 30-day horizon, but adopts a simplified methodology compatible with the size, risk profile, and complexity of the institutions to which it applies, as further regulated by the BCB.

Scope of Application

Under CMN Resolution 5,296, the following measures were approved:

mandatory compliance with the LCR, previously applicable only to S1 institutions, is extended to S2 institutions as well, on both a consolidated and a sub-consolidated basis;
i. the LCRS becomes applicable to institutions classified in S3 or S4 that are authorized to raise funds from the public through deposits or the issuance of securities, to be observed at the level of the entities comprising the respective prudential sub-conglomerate [11] or, if the institution is not part of a prudential conglomerate, on the basis of transactions conducted in Brazil, excluding those carried out by branches abroad; and

[11] The prudential sub-conglomerate is formed by the leading institution of the prudential conglomerate and by the other entities comprising the prudential conglomerate that are incorporated in Brazil and that are not subject to any impediment, whether current or anticipated, to the timely transfer of funds to the other entities of the sub-conglomerate, pursuant to CMN Resolution No. 4,950, of September 30, 2021.
with respect specifically to credit cooperatives, the LCRS will apply to both singular cooperatives and central cooperatives that provide centralized resource allocation services to affiliated cooperatives .[12]

[12] In the case of central cooperatives, the requirement seeks to reflect their role in the liquidity management of cooperative systems, ensuring that the entity responsible for the centralized allocation of funds maintains an adequate level of high-quality liquid assets.

Under BCB Resolution 560, an equivalent framework was established for Type 3 institutions, subjecting Type 3 institutions classified in S2 to the LCR and those classified in S3 or S4 to the LCRS, provided they are authorized to raise funds from the public through deposits or the issuance of securities

Notification to the BCB and Recovery Plan

If there is a foreseeable breach of the minimum LCR or LCRS thresholds, the institution must immediately notify the BCB, indicating:

the factors that led, or may lead, the ratio to fall below the minimum threshold, including identification of whether such factors are idiosyncratic or market-wide in nature;
the contribution of each such factor to the deterioration of the ratio;
the liquidity contingency plan; and
the liquidity recovery plan, containing the estimated timeframe for restoring the ratio, the projected cash flows, the measures already taken and to be adopted, and the sources of funds to be used.

For as long as the ratio remains below the applicable minimum threshold, the institution must submit a daily detailed report to the BCB on the implementation of the liquidity recovery plan, without prejudice to the supervisory authority’s ability to request additional information.

BCB Supervisory Action

The new rules also expand the BCB’s supervisory toolkit, enabling the authority to require, both in normal periods and in financial stress scenarios, the adoption of improvements in liquidity risk management, in the liquidity contingency plan, and in the liquidity recovery plan of institutions.

In addition, the BCB may require the reduction of liquidity risk exposure and the restoration of the LCR or LCRS within a timeframe set by it, so as to ensure compliance with the applicable minimum threshold.

Implementation Schedule

The implementation of the new requirements will follow a common phased schedule, applicable to the LCR for S2 institutions and to the LCRS for S3 and S4 institutions. [13] In both cases, the minimum threshold will be 90% between January 1 and June 30, 2027, increasing to 100% from July 1, 2027 onwards.

[13] CMN, Vote 24/2026-CMN, page 1, of April 23, 2026.

[1] Amends CMN Resolution No. 4,222, of May 23, 2013 (“CMN Resolution 4,222”), which provides for the contributions payable by member institutions, the conditions for the provision of the special guarantee, the types of member institutions, and the bylaws and regulations of the FGC.
[2] Provides for the minimum thresholds of the Short-Term Liquidity Coverage Ratio (“LCR”) and the Simplified Short-Term Liquidity Coverage Ratio (“LCRS”), as well as the conditions for their compliance.
[3] Provides for the minimum thresholds of the LCR and the LCRS, as well as the conditions for their compliance.
[4]As defined in § 1 of Article 2 of CMN Resolution No. 4,553, of January 30, 2017 (“CMN Resolution 4,553”), S1 comprises multiple-service banks, commercial banks, investment banks, exchange banks, and savings banks that: (i) have a size equal to or greater than 10% (ten percent) of the Gross Domestic Product (“GDP”); or (ii) carry out relevant international activity, regardless of the institution’s size.
[5]As defined in § 2 of Article 2 of CMN Resolution 4,553, S2 comprises: (i) multiple-service banks, commercial banks, investment banks, exchange banks, and savings banks with a size below 10% (ten percent) and equal to or greater than 1% (one percent) of the GDP; and (ii) other institutions with a size equal to or greater than 1% (one percent) of the GDP.
[6] As defined in § 3 of Article 2 of CMN Resolution 4,553, S3 comprises institutions with a size below 1% (one percent) and equal to or greater than 0.1% (one tenth of one percent) of the GDP.
[7] As defined in § 4 of Article 2 of CMN Resolution 4,553, S4 comprises institutions with a size below 0.1% (one tenth of one percent) of the GDP.
[8] As defined in item I of Article 2 of Resolution No. 436 of the BCB, of November 28, 2024 (“BCB Resolution 436”), the following are classified as Type 1: (i) a singular institution authorized to operate by the Central Bank of Brazil, except for: (a) a payment institution; (b) a securities brokerage company; (c) a securities distribution company; and (d) an exchange brokerage company; and (ii) a prudential conglomerate led by an institution referred to in subitem “(i)” above.
[9] As defined in item II of Article 2 of BCB Resolution 436, the following are classified as Type 2: (i) a singular payment institution; and (ii) a prudential conglomerate led by a payment institution and composed exclusively of: (a) payment institutions authorized to operate by the BCB; (b) payment institutions not authorized to operate by the BCB; (c) entities that engage in the acquisition of credit operations, including real estate operations, or of credit rights, such as commercial factoring companies, securitization companies, and single-purpose entities; (d) other legal entities whose corporate purpose is exclusively the equity interest in the entities mentioned in subitems “(a)” to “(c)” above; or (e) investment funds.
[10] As defined in item III of Article 2 of BCB Resolution 436, the following are classified as Type 3: (i) a securities brokerage company, a securities distribution company, and an exchange brokerage company; (ii) a prudential conglomerate led by an institution referred to in subitem “(i)” above; and (iii) a prudential conglomerate led by a payment institution not mentioned in subitem “(ii)” of the definition of Type 2 above.
[11]CMN, Vote 24/2026-CMN, page 1, of April 23, 2026.
[12] The prudential sub-conglomerate is formed by the leading institution of the prudential conglomerate and by the other entities comprising the prudential conglomerate that are incorporated in Brazil and that are not subject to any impediment, whether current or anticipated, to the timely transfer of funds to the other entities of the sub-conglomerate, pursuant to CMN Resolution No. 4,950, of September 30, 2021.
In the case of central cooperatives, the requirement seeks to reflect their role in the liquidity management of cooperative systems, ensuring that the entity responsible for the centralized allocation of funds maintains an adequate level of high-quality liquid assets.