Alerts
- 7 August 2023
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Registration of Operations – New deadline for the start of the obligation
On the last 26th, the Superintendency of Private Insurance (SUSEP) published SUSEP Circular No. 690 of July 24, 2023. The respective rule provides for changes in the following provisions: SUSEP Circular No. 655/2022, SUSEP Circular No. 673/2022, SUSEP Circular No. 675/2022, SUSEP Circular No. 679/2022 and SUSEP Circular No. 686/2023 which, in general, deal with the conditions for registering operations in the System Registry of Operations (SRO).
Recently our team made available the newsletter ‘SRO – another deadline for registration approaching’, warning about the deadlines of August 1st and September 1st as stated in the amended Circulars. However, with the publication of the new Circular, the following deadlines must be considered:
1. As of December 31, 2023, the registration of the following operations in homologated registration systems and managed by registration entities accredited by the Superintendence of Private Insurance (SUSEP) will be mandatory:
a) Open supplementary pension plan with risk coverage under the Simple Pay-as-you-go system.
b) Open Supplementary Pension Plan with risk coverage structured in a financial regime of allocation of coverage capital.
c) Open supplementary pension plan with risk coverage structured in a capitalization financial system.
d) With survival coverage in Open Supplementary Pension Plans and Personnel Insurance with survivorship in open Supplementary Pension Plans and Personnel Insurance.
e) Personal Insurance with risk coverage structured under the RCC or capitalization financial system.
f) Capitalization.
g) Financial Assistance from Open Supplementary Pension Entities and Insurance Companies.
Furthermore, it is worth mentioning that SUSEP Circular nº 690/2023 also presents the following changes:
1. Transactions with coverage in force on December 31, 2023, must be registered within 30 (thirty) business days from the date of commencement of the obligation.
2. Transactions with the coverage period ending on December 31, 2023, must be registered within 10 (ten) business days of the first financial transaction occurring after that date.
3. In the case of pension operations with collective contracts and certificates of participants with events reported and not yet paid/settled by the mandatory date, or operations related to policies and individual certificates with reported claims, due income or premiums not financially settled until the mandatory date, the registration must be made within 20 (twenty) business days from this date.
4. With regard to capitalization operations: a) they will comply with the same terms if effective on December 31, 2023, or closed up to this date and b) if they have contemplated draws, requested redemptions or with contributions not paid financially by the date of initiation of the obligation they must be registered within 20 (twenty) business days from December 31, 2023.
The new rule came into force on August 1, 2023 and, click here, it is possible to consult other regulations related to the subject.
Lefosse’s Insurance, Reinsurance and Private Pension practice will continue to follow the news and changes that impact the sector. For further clarification on the subject, or others that may be of interest to you, please contact our professionals:
Lefosse’s Insurance, Reinsurance and Private Pensions Team closely monitors the changes that impact the Brazilian Market. For further clarification on this matter, or others that may be of interest to you, contact our professionals.
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