In 2019, the Superintendence of Institutional Investors Relations (“Superintendência de Relações com Investidores Institucionais” – “SIN”), together with the Superintendence of Accounting Standards and Audit (“Superintendência de Normas Contábeis e de Auditoria” – “SNC”) of the Brazilian Securities and Exchange Commission (“CVM”) issued Circular Letter 01/2019 / CVM / SIN / SNC (“Circular Letter”), with clarifications on the interpretation of item 1.3.2.XX of the Accounting Plan for Investment Funds (“Plano Contábil dos Fundos de Investimento” – “COFI” ), approved by CVM Instruction No. 577/2016.
This “COFI” item establishes the obligation to disclose the sensitivity analysis for each type of market risk to which the fund is exposed at the end of the accounting period, in accordance with the guidelines of the standards applicable to publicly-held companies that deal with the disclosure of instruments financial resources.
Accordingly, it was stated in the Circular Letter that “SIN” and “SNC’ interpret that the “standards applicable to publicly-traded companies” referred to in said “COFI” item are those represented primarily by CPC 40 (R1), approved by “CVM” Resolution No. 684 / 2012, which provides the general rule regarding the disclosure of market risk.
As a general rule, the provision of item 40 of CPC 40, which establishes that the entity shall disclose: (a) a sensitivity analysis for each type of market risk to which the entity is exposed to the end of the accounting period, showing how the result and equity would be affected by changes in the relevant material variable risk reasonably possible on that date; (b) the methods and assumptions used in the preparation of the sensitivity analysis; and (c) changes from the previous period in the methods and assumptions used, and the reason for such changes.
Further information, as well as the full text of the Circular Letter, can be found on the “CVM” website (http://www.cvm.gov.br/).