Compliance; Banking | Brazilian Central Bank Regulates Proactive Credit Offers to Consumers: Impacts on Financial Institutions, Fintechs, and Other Entities

The Brazilian Central Bank (BACEN) has approved three resolutions that expand the responsibilities of financial institutions, fintechs, securities brokerage firms (DTVMs), and other entities regarding the offering and granting of consumer credit.

Resolutions (BCB) 601, 602, and 603, dated October 23, regulate advertising and proactive offers of credit operations, mandate the creation of a consolidated debt dashboard for each client, and place limits on credit offers made to users initiating a Pix transaction.

Below are some key aspects of the Central Bank’s regulations for financial institutions, fintechs, and other regulated entities concerning the offering and granting of consumer credit.

1. Impacts of Resolution BCB 602 (Proactive Credit Offers): This resolution applies to: (i) advertising and individual proactive offers of credit operations, virtual asset services, foreign exchange transactions, and payment services—including the issuance of post-paid payment instruments—by financial institutions and other authorized entities; and (ii) advertising and individual proactive offers of products and services provided by payment institutions, foreign exchange brokerage firms, securities brokerage firms (DTVMs and CTVMs), virtual asset service providers, and consortium administrators.

The resolution aims to regulate procedures for advertising and proactive offers of products and services directed at clients, prevent excessive practices, and provide information to the Central Bank for monitoring and supervisory purposes. The regulation enters into force on March 31, 2027.

2. Impacts of BCB Resolution 601 (Consolidated Debt Dashboard): This Resolution mandates the implementation of a “Consolidated Debt Dashboard” by financial institutions, fintechs, and other regulated entities. It applies to individual customers, including sole proprietors.

The resolution defines the Consolidated Debt Dashboard as an electronic interface—accessible via applications and digital platforms—that provides a consolidated view of data and information regarding: a customer’s financial obligations; an assessment of the suitability of credit products for the customer’s profile; and the extent to which the customer’s monthly repayment capacity is committed. The regulation enters into force on July 1, 2027.

3. Impacts of BCB Resolution 603 (Credit Offers via PIX): This resolution stipulates that any offer of credit made to a payer during the initiation of a PIX transaction must strictly comply with the terms set forth therein.

The regulation enters into force on July 1, 2027.

Financial institutions, fintechs, securities brokerage firms (DTVMs/CTVMs), and other authorized entities that offer and grant credit to consumers must pay close attention to these new regulations, which take effect in 2027 and significantly expand their responsibilities toward consumers.

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