Consulta Pública SNC 05/26

For financial services executives, the practical focus is disclosure quality in transactions, restructurings and other situations where historical financials are adjusted to show a hypothetical or post-event position. Issuers, underwriters, auditors and legal advisers should treat this as a targeted accounting and disclosure consultation rather than a broad prudential rule. Compliance teams should review current pro forma methodologies and governance, confirm consistency with CPC and CVM expectations, and check whether offering documents, investor materials and market communications may need updating once final guidance is issued.

The consultation deadline is 7 December 2026, so firms with Brazilian capital markets exposure have a limited window to assess gaps and, if appropriate, provide comments. Key risks include regulatory challenge over inconsistent or insufficiently explained pro forma adjustments, delayed transaction documentation, and reputational or enforcement exposure from misleading investor disclosure. Opportunities include clearer, more comparable transaction disclosures, stronger investor confidence and smoother regulatory review.

Action: inventory live and planned transactions, coordinate with auditors and counsel, map current pro forma presentation against the draft guidance, and assign ownership for any policy or template changes.