CVM Resolution 175 (RCVM 175) is the largest overhaul of the Brazilian fund industry in two decades. It replaced multiple prior instructions — CVM 555, 356, 472, and 391, among others — with a unified framework that reorganizes the relationship between fund, classes, subclasses, and series.
For fiduciary administrators, this goes well beyond a regulatory reform. It changes how the operation is registered, monitored, reported, and audited. Treating it as a cosmetic update means missing the opportunity to modernize processes that have sat untouched for 15 years.
What actually changed
Four fronts concentrate most of the operational impact:
- 1.Class and subclass structure: what used to be 'a fund' can now be a nested structure with distinct responsibilities at each level.
- 2.Service provider liability: asset manager, administrator, custodian, and auditor now have formally delimited scopes — with no more overlapping responsibilities.
- 3.Transparency and governance: stricter rules for conflicts of interest, related-party transactions, and disclosure to investors.
- 4.Migration and compliance: pre-existing funds must bring their bylaws, chart of accounts, and workflows into line within the CVM's timeline.
The invisible cost of adaptation
Most administrators underestimate two costs. The first is technical: legacy systems modeled the fund as a single entity. Breaking that assumption to support classes and subclasses requires rework across registration, accounting, NAV, and reporting.
The second is procedural: monthly close, reconciliation, and regulatory filing workflows need to be rewritten to reflect the new hierarchy. Operations teams that memorized the current steps will have to relearn them.
Last-minute adaptations tend to turn into spreadsheet workarounds. The earlier the core system is updated, the lower the risk of living with technical debt for years.
How the Arkar Fund System handles RCVM 175
The Arkar Fund System was natively modeled around RCVM 175. Classes, subclasses, series, service provider responsibilities, and governance are first-class entities in the database schema. There is no retrofit — the design took Resolution 175 as its starting point.
- ●Fund, class, and subclass registration with inheritance of rules and fees.
- ●Chart of accounts pre-mapped to the new structure.
- ●Regulatory filings (CDA, Monthly Report, FIP Quarterly Report, FIDC Statement) generated natively in the RCVM 175 format.
- ●Audit trail with explicit service provider accountability.
Practical next steps
If you are an administrator and have not yet started adapting, three immediate steps:
- 1.Inventory the funds under administration and classify them by target structure (single fund, fund with classes, fund with subclasses).
- 2.Map fund bylaws and identify the clauses that need to be rewritten.
- 3.Assess whether your current system natively supports the new structure — or whether the technical migration is the real bottleneck.
We talk to administrators about this journey every day. If you would like a quick assessment of where your operation stands against RCVM 175, get in touch.