BCB Normative Instruction (IN) No. 704/2026 reorganizes the filing of authorization applications with the Central Bank, with procedures, deadlines and Sisorf/Unicad tracks. The central point is not paperwork: it is increased execution complexity. Authorization comes to depend on verifiable consistency between corporate structure, governance, controls, IT and AML/CFT, especially for SPSAVs.
✦ SPSAVs | the material change
IN 704 segments the regime by regulatory maturity and creates a transition path for those already operating:
- Non-operational SPSAVs: follow the ordinary procedure, with no transition "shortcuts".
- Operating SPSAVs: a two-phase procedure, with different effects:
- Phase 1 (until 10/30/2026): eligibility/admissibility screening and minimum stabilization of control and governance; this is not full authorization.
- Phase 2 (after a favorable opinion, within a short window): substantive and prudential review: economic and financial capacity, source of funds, managers/governance and consistency between operations, technology, controls and AML/CFT.
A change of modality (broker/intermediary/custodian) now requires a separate application and revalidation of the risk profile, with greater scrutiny.
Critical outsourcing (cloud, custody, KYC/KYT, monitoring) becomes part of the core assessment; outsourcing does not reduce responsibility.
➤ CTVMs, DTVMs and foreign-exchange brokers | consolidation
Here IN 704 does not bring a substantial change, but consolidates the authorization process under the new legal and regulatory framework.
