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DETAILED RESEARCH · EVIDENCE & LIMITS INCLUDED

Brazil: bank-correspondent versus debtor-agent rule-body research

C_BR · pass-02Captured 2026-10-2712 tables · 26 claim records · 15 source recordsScoped coordinator review completed

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SettleADebt C_BR PASS-02 — Brazil

Narrow rule-body research · Current consolidation not fully verified · Publication holdResearch baseline: October 22, 2026. Actual access: October 26, 2026, America/Los_Angeles; October 27, 2026, UTC.

Principal finding

An important part of the correspondente no País history can now be resolved, but the complete currently operative CMN Resolution 4.935/2021 cannot yet be certified from an opened official consolidated text.

The newly opened Banco Central materials establish the following distinctions:

  1. The old rule was superseded. Banco Central’s official consolidated presentation of Resolution 3.954/2011 expressly marks its pertinent correspondent provisions as revoked effective February 1, 2022, by CMN Resolution 4.935/2021. normativos.bcb.gov.br

  2. The original 4.935 rule text has been examined, with a provenance qualification. I opened the 2021 Banco Central proposal and its full draft annex, and separately read a 14-page PDF reproducing Resolution 4.935 hosted by a bank. The latter is not publication by the issuing regulator, and the former is expressly a minuta. Their agreement helps identify the intended contracting and activity architecture; neither proves every provision’s currently operative wording. normativos.bcb.gov.br+1

  3. There was a material amendment on December 1, 2025. A Banco Central vote dated February 19, 2026 states that Joint Resolution 17/2025 took effect on December 1, 2025 and revoked CMN 4.935 article 8, which had established a prior-authorization route for corresponding contracts involving certain institution-like business names. The BCB explains that the replacement regime restricts such problematic arrangements. This is a fresh official retrospective statement of the change; the enacted full Joint Resolution 17 itself has not been read here. normativos.bcb.gov.br

  4. Institution-side is not debtor-side. The original reproduced rule’s articles 2–3 and 12 make the contractual correspondent an attendant for products or services of the contracting authorized institution, acting under that institution’s direction. Receipt and forwarding of that institution’s credit proposals is materially different from accepting independent payment to advise a borrower or negotiating the borrower’s obligations with unrelated creditors. This substantive distinction is strongly evidenced by the read historical materials, while precise contemporary rights, restrictions and qualifications remain subject to the current-text hold. cms.santander.com.br+1

P01 disposition: C_BR-P01-C021, G26 and G27 gain specific historical and 2025-amendment evidence but remain partially pending. P01 C022, C042, C044 and the other country-wide holds are unchanged.

G1. Current rule-body reconciliation

Original regulation, amendment and commencement crosswalk

Instrument/status Date and actual read evidence Effect on this narrow question Current verification status
Resolution 3.954/2011 — superseded material Banco Central’s official 15-page consolidated PDF marks the relevant articles revoked from February 1, 2022. S005, various articles. Prevents mistakenly using the older correspondent activity and contract rules as today’s rule. Verified historical transition. The old operative body was actually opened. normativos.bcb.gov.br
CMN Resolution 4.935/2021 — original enactment Dated July 29, 2021; published in the DOU August 2, 2021. Original BCB proposal annex S001 arts. 1–26; reproduced published-resolution text S002 art. 26 states effect from February 1, 2022; S005 independently records that replacement date. Established the distinct institutional-correspondent framework. Original wording substantively inspected, but not from an opened enacted official publication. S001 is a draft and S002 a non-issuer reproduction.
Joint Resolution 17/2025 — amending act Dated November 28, 2025; BCB Vote 17/2026 says it became effective on December 1, 2025. Official BCB proposal S003 included a proposed new naming/contract rule and revocation of 4.935 art. 8. Repealed the earlier art. 8 prior-approval mechanism and, as BCB later describes it, changed the treatment of misleading institution-style names. Revocation and commencement supported by opened 2026 BCB explanatory vote. Complete enacted wording, exceptions and transitions not directly read.
Current consolidated 4.935 display BCB’s indexed normative search result calls it the current version updated December 1, 2025. S006. Discovery lead for the operative text after the amendment. Indexed only; full current text not opened. A search index’s update label does not independently certify every article’s operation.
BCB Vote 17/2026 Official PDF, February 19, 2026, explanatory paragraph 7, zero-based PDF page 1. S004. Confirms 2025 revocation and describes the succeeding restriction. Actual official explanatory body read; not a substitute for the full joint resolution.
Later changes through October 26, 2026 No comprehensive post-December 2025 amendment inventory completed beyond the sources above. Could affect any unverified provision or implementation. Unknown, not “none.”

The precise 2025 change matters. The old article 8 contemplated BCB prior authorization for a correspondent contract involving a non-SFN entity with certain financial-institution-like names. BCB’s 2026 account states that Joint Resolution 17 revoked that mechanism, and that such problematic contracts became prohibited under the newer article 8 framework. It would be wrong to advise a prospective correspondent simply to apply under the old CMN 4.935 article 8. The 2025 proposed text has exceptions and adjustment periods; those cannot be certified as enacted merely because they appear in the vote annex. normativos.bcb.gov.br+1

Material provisions actually examined

Material provision or subject Where actually read What can safely be concluded now
Original 4.935 arts. 1–3 — scope, contracting institution, direction/responsibility S001 official draft, PDF indices 8–9; S002 original-text reproduction, indices 0–1 Strong historical evidence of institution-side structure; current exact formulation awaits official consolidated body.
Art. 4 — classes potentially contracted S001 draft index 8–9; S002 index 1 Historical reproduction lists sociedades, empresários e associações, not every unregistered natural person automatically. Current scope unverified.
Arts. 5–7 — restrictions and authorized-institution contracting S002 indices 1–2 Historical text read; exact current conditions not certified.
Art. 8 — historical prior-approval mechanism S002 index 2, S003 proposed repeal index 10, S004 retrospective confirmation index 1 Repeal supported. Old permission route cannot be represented as currently open.
Art. 9 — institutional director S002 index 2 Historical institution governance; current operative wording not reopened.
Art. 10 — substabelecimento S002 index 2 Original text requires initial contractual permission and institutional consent for one level, with qualifications. Current wording unverified.
Art. 11 — institutional charges and location restriction S002 indices 2–3 Historical rule addresses charges for institution-supplied products; does not settle separate debtor advice charges.
Art. 12 — permitted contracted service objects S001 draft; S002 index 3 Specific historical categories, including credit-proposal reception/forwarding; no standalone independent debtor-advice permission identified in that enumeration.
Art. 13 — foreign-exchange activity S002 indices 3–4, only to identify different product category Outside current narrow scope. Detailed exchange limits and present operation not certified.
Art. 14 — institutional contract clauses, disclosures, fee/control boundaries S002 indices 4–6 Historical detail inspected; current publication required before making definitive operational claims.
Arts. 15–16 — credit activities, persons performing them, certification S002 indices 6–9 Historical activity-specific conditions, not a universal debt-adviser certificate or blanket certificate requirement for all correspondents.
Arts. 17–20 — institution guidance, supervision, remuneration policy and credit monitoring S002 indices 9–11; S001 contemporaneous rationale Historical institution-side control design; actual present requirements await consolidated enacted text.
Arts. 21–23 — public information, claims, BCB communications S002 indices 11–12 Historical matching-entity/service verification route, not proof of any hypothetical contract.
Arts. 24–26 — final provisions and original commencement S002 indices 12–13; transition corroborated S005 February 1, 2022 original commencement supported; subsequent amendment separately dated.
Joint 17 proposed arts. 8, 13–14 S003 official draft, indices 9–10 Proposed naming-contract restriction, revocation and immediate publication effect; actual final resolution not independently opened.
Joint 17 actual enactment/repeal S004 BCB 2026 explanatory vote, index 1 December 1, 2025 entry and CMN 4.935 art. 8 repeal reported by competent regulator. Exact operative exceptions/transition clauses remain unread.

Unopened consequential bodies: the fully enacted 2021 original in the official gazette; a readable official consolidated CMN 4.935 text incorporating Joint 17; the enacted full Joint 17 provisions, including precise exceptions and adjustment clauses; and any material later amendments. Two official DOU HTML alternatives returned HTTP 502. I did not loop back through the failed P01 dynamic BCB page or PDF viewer.

G2. Actor/activity/capacity determination

The following is the conditional classification supported by the historical original text and the explicitly verified 2025 change. “Historical” refers to the reproduced original, not a certified October 2026 operative provision.

Actor or operation Original 4.935 evidence and controlling distinction Actual capacity proof still required Adverse or withheld conclusion
Contracting institution Arts. 1–3: financial institution or another BCB-authorized institution engages the correspondent for its customers/products, under its direction. C002–C003. Exact regulated institution, authorized modality, actual current correspondent contract and supervision structure. Institution’s separate authorization cannot be inherited by an unrelated adviser.
Correspondent entity Original art. 4 specifies categories of prospective contracted bodies; art. 2 requires the institution-side engagement. C004. Legal form, contracting party, date, legal name and actual duties. Mere company registration, trade name or a self-described corban does not establish a real engagement.
Natural-person staff or representative Original arts. 14–16 distinguish the contracted entity from formally engaged individual attendants and relevant qualified staff. C008–C009. Employment/service arrangement, tasks, supervision, identification and activity-specific qualification. Working for a correspondent is not a transferable personal debt-advice or legal licence.
Subcontractor / substabelecido Original art. 10 recognizes limited subdelegation subject to contractual and institution approval conditions. C008. Original contract, permission, institution consent, identity and exact delegated tasks. A chain of unsolicited affiliates or lead buyers cannot assume lawful substitution.
Electronic correspondent platform Original art. 2 §2 and arts. 12, 16 tie platform functions to defined institutional services and responsible qualified personnel for specified credit activities. C005, C009, C020. Platform operator, functional inventory, actual contract, supervising individual, data/API/funds flow. “We are software” or “we use a certified platform” is not all-purpose financial or debtor-service permission.
Consumer applying for institution credit Original art. 12(V): reception/forwarding of a credit or leasing proposal for a contracting institution; the institution decides and provides the product. C005–C006. Which institution, product, submission and approval process; disclosure of adviser’s role. Proposal receipt is not the adviser approving credit, setting autonomous terms or settling unrelated debts.
Consumer seeking debt renegotiation Original art. 12(V) includes services associated with following the institution’s credit operation. Historical art. 15 references repactuação for a remuneration calculation. C006–C007. Is the relevant debt owed to the contracting institution? Is this task actually included in a lawful current contract? Who may bind creditor/debtor? Mention of repactuação in a remuneration provision is not an independent statutory debtor-agent licence or proof of authority to compromise any debt.
Collector/servicer for institution Original art. 12 uses specified institution-provided service categories. C005–C007. Particular contract term, creditor appointment and actual collection/contact duties. No blanket creditor-collection or consumer-representation permission is inferred.
Independent debtor-paid negotiator Original art. 3 institution-side agency is different in principal, instructions, compensation and fiduciary posture. C018–C019. Separate debtor engagement, script, mandato, compensation, creditor role and funds. Correspondent contract cannot by itself legalize separate debtor-side legal advice or client-money handling.
Mixed two-sided provider Institutional service and independent debtor consultancy are distinguishable engagements. Historic art. 14 disclosures/policy create a pertinent conflict question. C019–C020. Contracts with both sides, segregated teams, payment sources, disclosures, instructions and treatment of conflicts. No categorical “dual representation always lawful” or “always banned” finding without current full rule and actual contracts.
Funds operator Original art. 12 contains institution-account payment functions; those differ from taking borrower settlement savings into the adviser’s own account. C016, C021. Account title, payment processor, who authorizes movement and BCB category. BCB 494 and separate payment authorization remain deferred.

The central distinction can be stated without promising a particular authorization:

Institution-side task: “Receive and forward my application for an identified institution’s credit product within that institution’s authorized contracted arrangement.”

Independent debtor-side task: “Advise me what to offer my existing creditors, negotiate for me, settle legal obligations and perhaps manage my settlement savings.”

These are different promises, principals, remuneration relationships and potential legal acts. The original 4.935 architecture supports that separation; the current-text hold prevents treating the table as a licence clearance for a real transaction. cms.santander.com.br+2

Remuneration, disclosures and qualifications

  • The reproduced original arts. 14 and 18 address how the contracting institution controls correspondent remuneration, policies, public description and institution-product terms. They do not establish a universal consumer debt-settlement fee schedule.
  • Original art. 14 separates the correspondent’s contract obligations from charging a customer for products supplied by the institution. The precise treatment of a hypothetical independently contracted paid service is not resolved from those clauses.
  • Original arts. 15–16 place specified qualification/certification conditions on credit and leasing service functions, with an electronic-platform variant. This cannot be generalized to all consumer budgeting or to every kind of correspondent activity.
  • For the 2025 naming issue, the issued resolution’s complete operative exceptions and transitions remain unread. A preliminary vote’s proposed exceptions cannot be used to promise continued eligibility through a date.

No fee cap, borrower charge, compensation percentage, savings guarantee, income threshold or licence duration is inferred here. cms.santander.com.br+3

G3. Exact proof and verification requirements

Before a real classification, the following facts would have to be provided under separate authority:

Evidence item What exact question it answers What it cannot establish
Contracting institution’s precise legal identity and dated BCB category Which institution is the principal and what kind of products it may offer Authority of a separate debtor-paid consultancy
Executed correspondent agreement and amendments Whether the exact provider is engaged, when, and for which activities Authority for unrelated creditors or uncontracted product categories
Current institutional policy and authorized task schedule Who controls scripts, prices, referrals and customer communications The borrower’s independent representation or litigation authority
Staff/representative and subcontractor documents Who answers calls and whether delegated activity is contractually included Universal qualification merely from a course certificate
Product-specific application process Who receives the proposal, forwards it, evaluates it and approves or refuses Any promised approval or future lender action
Customer-facing site, advertising and scripts Whether the customer can identify the institution and distinguish conflicting roles An actual regulator’s approval of the words used
Separate debtor advisory contract, if any Who pays for debtor representation, for what, and on which instructions Automatic validation by the institutional correspondent contract
Debtor mandato or creditor authority Who may negotiate, sign a compromise, receive payment or give discharge An exemption from reserved legal or financial activity
Compensation records or blank commercial schedule Whether the institution, debtor, third party or multiple parties pay Legality of an unsupported specific fee
Funds-flow and account-title diagram Whether money is controlled by an authorized institution or held by the adviser Payment-institution authorization without the current BCB rules
Generic institution/correspondent register procedure How a future checker should match name, service, date, category and institution Proof of an unsearched actual record or contract

The BCB’s public correspondent guidance describes records by contracting institution, municipality and service category, and characterizes underlying reporting as periodic. This is generic official register guidance, not an actual lookup, and cannot independently verify an absent signed contract. No register entry or named party was searched. bcb.gov.br

G4. Five invented classifications

The examples below are fictional and test legal roles. They do not describe a real provider, borrower or licence.

Invented example Conditional answer; source and claim IDs Missing evidence, adverse branch and exact next action
H01 — Institution-contracted credit proposal receiver. A finance institution engages a company to collect applicants’ identification and forward that institution’s credit proposals. The company does not advise on debts owed to other creditors. Historically fits the type of art. 12(V) institutional task. C003, C005–C006, C009; S001 draft art. 12, S002 reproduction arts. 2–3, 12(V), 15–16. Current conditions remain unverified. Need dated actual institution contract, scope, staff roles, platform information and official current rule. Adverse: proposed loan outside licensed institutional product or unauthorized originator promises. Next action: obtain a blank activity schedule showing the exact authorized product/task and identify who approves credit.
H02 — Debtor adviser using a correspondent badge. A firm says, “We are a bank correspondent, so we may charge to negotiate all your card debts,” but supplies no institutional agreement. Correspondent label is not a debtor mandate. C003, C018, C022; S002 historical arts. 2–3 and 12, P01 C004–C007/C021. Need actual creditor-side contract if claimed, debtor engagement, scripts, remuneration and legal capacity. Adverse: misleading role or reserved legal advice; potential absence of any real correspondent engagement. Next action: ask, “Which named institution engaged you, for exactly what task, and who authorized you to act for the debtor?”
H03 — Mixed roles and potential conflict. A company originates a lender’s refinancing applications, but also sells separate debtor-paid recommendations about whether the consumer should refinance or settle debts. Two distinct engagements; original public-description/remuneration controls are relevant but do not automatically decide dual-role lawfulness. C010, C018–C020; S002 arts. 14, 18, S003 proposed naming changes. Need dual contracts, pay sources, conflicts, disclosures, decision-making scripts and current full rule. Adverse: biased presentation, role confusion or unapproved acts. Next action: trace who pays for each call and whether advice is independent or directed by the institution.
H04 — Referral software with staff and subcontractor. A platform sends prospective applicants to an authorized institution. A call-centre affiliate follows up, without clear documents identifying who contracts it. Merely referring, hosting a form, operating an institution-linked credit platform and acting as a subcontracted correspondent can be different capacities. C008–C009, C020; S001/S002 arts. 2, 10, 12, 16. Need institution contract, referral agreement, delegation clause/consent, platform operator, qualified person and exact feature map. Adverse: unsupported subcontracting or a hidden regulated activity. Next action: establish whether the platform or call centre actually receives and forwards the institution’s proposal under that institution’s contract, or only supplies traffic.
H05 — Correspondent plus settlement-funds wallet. A firm may forward loan applications under one contract but separately receives monthly debtor money into an account it controls for later settlement. Loan correspondence does not settle money custody/payment category. C016, C018, C021; P01 C016–C017/C022/C044; S002 art. 12 historical, P01 S015 statutory payment definitions. Need beneficial-title chain, payment rails, account owner, refund control, processor and current operative payment rules. Adverse: unverified client-funds or financial/payment activity. Next action: ask, “Does any debtor money ever enter an account legally owned or controlled by the adviser before reaching the creditor?” BCB 494 remains deferred.

Numerical illustration: None is needed to determine institution-side versus debtor-side capacity. The original reproduced resolution contains service-related percentages and times, but applying them without a current operative instrument, actual product and contract would create a misleading business or consumer estimate. No numerical example has been invented.

Source register — PASS-02 only

The source rows below are additions or expressly identified reuse. They do not replace P01’s 40 records.

Actual access window: approximately October 26, 2026, 17:59–18:13 PDT, corresponding to October 27, 2026, 00:59–01:13 UTC. Individual search/open timestamps were not recorded; this is the observed access session window, not fabricated resource-specific clock times. Every fresh PASS-02 item below was retrieved or attempted during that window. Source publication dates, PDF creation dates and research-access dates are distinct.

READ-DRAFT = official preparatory vote and attached proposal actually read, not enacted norm. READ-REPRO = full normative text reproduced on non-issuer site actually read, not accepted as current official consolidation. READ-EXPL = competent official retrospective/explanatory text actually read, not enacted rule. READ-HIST = actual official historical/superseded norm. INDEX = official search-index material only. FAILED = attempted official body could not be read. REUSE = P01 material supplied and attributable; not reopened in this P02 pass.

Source ID Issuer, full title and complete literal URL Exact section/page; version/publication/commencement; actual access and limit
C_BR-P02-S001 Banco Central/CMN, Voto do CMN 59/2021 with BCB Vote 160/2021, attached proposed Resolução CMN on correspondents. https://normativos.bcb.gov.br/Votos/CMN/202159/VOTO_DO_CMN_59_2021_BCB_SECRE_Numerado_Manualmente_01.pdf READ-DRAFT. 39-page PDF; draft norm zero-based PDF 8–17, arts. 1–26, alongside impact assessment. Printed appended draft pages 1–10, embedded vote pagination differs. Proposal dated July 2021; not final enactment. Access Oct26 PDT/Oct27 UTC window above.
S002 Banco Santander-hosted reproduction of Resolução CMN nº 4.935, de 29 de julho de 2021. https://cms.santander.com.br/sites/WPS/documentos/arq-resolucao/23-09-26_204507_resolucao_4935.pdf READ-REPRO. 14-page PDF; relevant zero-based PDF indices 0–13, arts. 1–26, including arts. 2–4, 10–12, 14–16, 18, 21, 25–26. Original resolution dated July29 2021, art26 says effective Feb1 2022. Hosting filename date is not enactment/currentness. PDF contains historical art8 superseded in 2025; cannot be called 2026 consolidation. Access current P02 window.
S003 Banco Central/CMN, Voto do CMN 80/2025 including proposed Joint Resolution on authorized institutions’ names/public presentation. https://normativos.bcb.gov.br/Votos/CMN/202580/Voto_do_CMN_80_2025.pdf READ-DRAFT. 11-page PDF; proposed resolution zero-based indices 7–10, proposed arts. 1–14, esp. 8 §§1–2, 13–14. Attached proposal dated November2025 and contains blank resolution number/date before adoption. Not final enacted transitional text. Access P02 window.
S004 Banco Central, Voto 17/2026–BCB, de 19 de fevereiro de 2026. https://normativos.bcb.gov.br/Votos/BCB/202617/Voto_do_BC_17_2026.pdf READ-EXPL. 22-page PDF; explanatory para. 7, zero-based PDF 1, printed internal vote p. 2 of 3. Dated February19 2026; states Joint17 issued November28 2025, effective December1 2025, repealed CMN4935 art8 and describes new name restriction. The new 2026 draft later appended to the vote is not assumed enacted. Access P02 window.
S005 Banco Central, official consolidated presentation of superseded Resolução nº 3.954, de 24 de fevereiro de 2011. https://normativos.bcb.gov.br/Lists/Normativos/Attachments/49450/Res_3954_v12_P.pdf READ-HIST. 15-page PDF, zero-based indices 0–14, arts. 1–19 and related revocation annotations. Relevant marks across indices 0–13: replaced/revoked from February1 2022 by 4.935. Printed PDF “Página 1 de 15” onward aligned to zero-based index +1. Historical text is not current correspondent authorization. Access P02 window.
S006 Banco Central normative public interface, Resolução CMN 4.935/2021 — versão vigente. https://www.bcb.gov.br/estabilidadefinanceira/exibenormativo?numero=4935&tipo=RESOLU%C3%87%C3%83O+CMN INDEX/REUSE. Current search index encountered in P02 shows update December1 2025 and excerpts arts. 1–4, 12, 14. P01 S016 attempted the live body and failed; not retried here. No page/index applicable and no full 2026 body read.
S007 Banco Central normative public interface, Resolução Conjunta 17/2025. https://www.bcb.gov.br/estabilidadefinanceira/exibenormativo?numero=17&tipo=Resolu%C3%A7%C3%A3o+Conjunta INDEX. Official indexed 2025 norm and repeal of 4.935 art8, not directly opened full. Its indexed posting/currentness text is not an actual read of exceptions or operative transition. Access P02 window as search result.
S008 Imprensa Nacional, DOU HTML publication candidate for original CMN4935. https://www.in.gov.br/web/dou/-/resolucao-cmn-n-4.935-de-29-de-julho-de-2021-335456670 FAILED. Direct opening returned HTTP 502, no article text; candidate for original August2 2021 DOU, no page index. Access P02 window.
S009 Imprensa Nacional, alternate DOU English-route HTML publication candidate. https://www.in.gov.br/en/web/dou/-/resolucao-cmn-n-4.935-de-29-de-julho-de-2021-335456670 FAILED. HTTP 502; no body read, same historical publication candidate through a different path. Access P02 window.
S010 Banco Central, public July2021 CMN communication. https://www.bcb.gov.br/detalhenoticia/17457/nota INDEX/FAILED BODY. Indexed official description says original norm would enter in February2022 and includes platform/staff discussion; direct open returned a one-line body. Used only as historical discovery corroboration, not operative articles.
S011 Presidência, Lei 4.595/1964 financial-institution statute, compiled. https://planalto.gov.br/ccivil_03/leis/l4595compilado.htm REUSE P01 S014, arts. 17–18, user-supplied dated P01 row and coordinator’s selected fresh read; not reopened in P02. Establishes upper-level category only.
S012 Presidência, Lei 12.865/2013 payment services statute. https://www.planalto.gov.br/ccivil_03/_ato2011-2014/2013/lei/l12865.htm REUSE P01 S015, arts. 6 and 9/10 selected in coordinator scope; not reopened in P02. Does not answer current payment-institution exemptions.
S013 Banco Central, generic Correspondentes no País guidance. https://www.bcb.gov.br/estabilidadefinanceira/correspondentes_pais INDEX/REUSE P01 S036. P02 found indexed generic information on institution/municipality/service files; no named record, no fresh successful body opening; no actual-contract verification.
S014 Banco Central normative interface, historical P01 source S016 (same CMN4935 interface). https://www.bcb.gov.br/estabilidadefinanceira/exibenormativo?numero=4935&tipo=RESOLU%C3%87%C3%83O+CMN REUSE of failure history, not another source proof: P01 dynamic full body inaccessible; no new opening attempted. Listed separately solely to preserve exact original provenance.
S015 Imprensa Nacional, P01 original DOU PDF viewer. https://pesquisa.in.gov.br/imprensa/servlet/INPDFViewer?captchafield=firstAccess&data=02%2F08%2F2021&jornal=515&pagina=23 REUSE P01 S039 prior failure, not retried. Original DOU printed page 23 as reported by indexed metadata; zero-based PDF index not established, underlying pages not read.

Source register count: 15 displayed rows S001–S015. This is not 15 fresh operative bodies. The three substantive official new bodies are S001 preparatory vote, S003 preparatory vote and S004 explanatory vote; S005 is a newly read superseded operative PDF. S002 is a newly read private-hosted historical reproduction. The remainder are specifically labeled indexed, failed or reused material. No 2026 official current 4.935 consolidated body was successfully read.

Atomic claim/evidence register

These are the new PASS-02 claims only. Original P01 IDs are preserved unchanged.

Claim ID Provisional route; exact proposition, actor, condition, act/consequence and retained limit Sources and pinpoints
C_BR-P02-C001 A098. Earlier correspondent rule 3.954’s relevant articles ceased operating from Feb1 2022 under 4.935. This removes the old text as a present-permission source. S005 revocation notes across arts. 1–19, PDF indices 0–13.
C002 A097. The July2021 proposed 4.935 arts. 1–3 conceived institutional contracting and direction, not stand-alone debtor advocacy; a draft alone is not enacted law. S001 draft arts. 1–3, PDF 8–9.
C003 A097. Historical reproduced 4.935 arts. 2–3 place correspondent services with the contracting authorized institution and under its directions/responsibility. Present exact wording remains held. S002 arts. 2–3, PDF 0–1; S006 index only.
C004 A097. Original reproduced art. 4 lists classes of potential contractual correspondents, including sociedades, empresários e associações. It does not alone authorize any natural person or firm absent a contract. S002 art. 4, PDF 1; S001 draft, PDF 8–9.
C005 A097. Historical art. 12 enumerates institution-product services, including account applications, institution-account transfers/payments and credit/leasing proposals, subject to actual contract. Current exact text held. S002 art. 12(I)–(VII), sole paragraph, PDF 3.
C006 A097. Original art. 12(V) concerns receipt and forwarding of the contracting institution’s credit/leasing proposals and related operation-follow-up services, not independent approvals or unrelated creditor settlement. S002 art. 12(V), PDF 3; distinction partly inference.
C007 A097. Reference to repactuação in historical art. 15 remuneration provisions cannot itself establish authority to represent a debtor in settlement of any credit. S002 arts. 12(V), 15 §2, PDF 3, 7–8; qualified interpretive inference.
C008 A097. Historical arts. 10 and 14 distinguish contracted entity, limited approved subdelegation and formal staff relationship; current requirements need full official body. S002 arts. 10, 14(I), PDF 2, 4–5.
C009 A097. Historical arts. 15–16 attach staff/platform technical qualification to credit/leasing activity, not to all budget advice. S002 arts. 15–16, PDF 7–9.
C010 A097. Historical art. 14 requires disclosure of institution role/products and sets institution-contract controls on products and customer charges; these do not decide standalone debtor-consultancy fees. S002 art. 14(II)–(VII), PDF 5–6.
C011 A097. Historical art. 18 requires contracting institution controls and remuneration policy; no creditor/customer settlement result follows. S002 art. 18, PDF 9–10.
C012 A098. Historical arts. 21–23 describe institution correspondent-activity publication and regulator reporting, not proof an individual provider actually appears or has a current mandate. S002 arts. 21–23, PDF 11–12; S013 generic indexed guidance.
C013 A098. BCB’s Feb2026 explanation establishes that Joint17 took effect Dec1 2025 and repealed CMN4935 art. 8. Prior-approval path under that old article cannot be stated as current. S004 para. 7, PDF 1; S003 proposed art. 13, PDF 10 corroborative but not enacted.
C014 A098. Competent BCB description says 2025 replacement restricts certain institution-style names/partnerships. Exact final test/exceptions/transitions not established. S004 para. 7 PDF 1; S003 proposed art. 8 PDF 9.
C015 A098. BCB’s proposed, not confirmed enacted, Joint17 art. 8 includes particular exceptions and a one-year pre-existing contract adjustment framework. No operative deadline or exception claim adopted here. S003 draft art. 8 §§1–2, PDF 9.
C016 A098. BCB current search index reports Dec1 2025 consolidated update but does not certify all operative 4.935 clauses. S006 indexed heading; direct operative body failed in P01 S016.
C017 A098. Historical effective Feb1 2022 is supported by reproduced original art. 26 and official 3.954 supersession annotations; original full DOU not opened. S002 art. 26 PDF 13; S005 revocation notes; S008–S009 failed.
C018 A097. On these historical institutional provisions, correspondent capacity is materially different from an independent debtor-paid mandato. Inference, not an exhaustive negative licence conclusion. S001 proposed arts. 2–3/12; S002 reproduction arts. 2–3/12; P01 C004–C008/C021.
C019 A097. A mixed institution/borrower relationship needs distinct contract/compensation/conflict analysis; neither blanket permission nor blanket prohibition established. S002 arts. 3, 14, 18 historical; actual contracts absent.
C020 A097. Referral website, correspondent platform, individual attendant and approved subcontractor have different possible roles; no one certificate or software label classifies all. S002 arts. 2, 10, 12, 14–16 historical; operative consolidation pending.
C021 A097. A correspondent task involving institution-controlled transfers does not authorize borrower-savings custody or independent payment services by the correspondent. S002 art. 12(II)–(IV) historical; P01 S015/C016–C017/C022/C044 deferred.
C022 A098. A general public correspondent list can identify entity/service relationships if appropriately checked, but no contract or individual record was supplied/searched. S013 indexed public guidance; S002 arts. 21–23 historical.
C023 A098. Official DOU original body could not be read through either public HTML route; the 2021 bank-hosted text and draft are not an official current consolidation. S001–S002, S008–S009; explicit access limitation.
C024 A098. P01 C021 and G26/G27 can receive narrower historical/current amendment findings; current operative details and actual contracts remain missing. C001–C023; P01 S016/S039, C021, G26–G27.
C025 A098. The 2025 naming problem requires actual name, public presentation and institution contract; no brand/CNPJ/general “bank correspondent” badge grants permission. S004 para. 7; S003 proposed art. 8; exact final text held.
C026 A098. No numerical licence/resource/business-cost example is necessary or defensible for an unclassified provider; original reproduced charge/certification calculations not generalized. S002 arts. 14–16; current enacted text and actual contracts absent.

Claim total: 26 displayed P02 claims, C001–C026. The central historical institution-side propositions (C002–C012) are expressly qualified by their draft/reproduction source status. The 2025 repeal/commencement proposition (C013) rests on a read official retrospective BCB body rather than an opened enacted amendment.

G5. P01 old-to-new disposition

The requested wording is preserved, with only the appended narrow disposition shown.

Original P01 record Preserved original status P02 disposition and publication gate
C_BR-P01-C021 — “An institutional correspondente is categorically different from independent debtor advice; exact current contracting/activity requirements remain unverified.” Preserved as written. Indexed rule/failure basis remains attributed, not retroactively upgraded. Append P02 C001–C020/C023–C024. Historical architecture read and Dec2025 repeal specifically established by BCB explanation. Still not current operative body-cleared.
P01 G26 — “Correspondent-bank category”; “Institution-side, distinct from debtor adviser; C021”; “Pending body; obtain consolidated CMN 4.935 with amendments and actual contract.” Preserved. Add history and art8 revocation. Pending exact official consolidated 4.935/current Joint17 and real contract.
P01 G27 — “Credit intermediary/referral”; “Facts change class; C015, C021”; “Pending body; isolate advertising, application submission, compensation and lender authority.” Preserved. Add original art12(V) institutional proposal route, platform/staff distinctions as historically read; still pending current body and functional facts.
P01 C015 — financial institution law arts. 17–18 Original selected upper-level statute review preserved. No change or new implementing permission certified.
P01 C022 — BCB494/payment authorization Pending current implementing body. Unchanged; wholly deferred in P02.
P01 C042 — bounded absence of universal dedicated debtor-adviser permission Qualified negative remains. Unchanged; no broader affirmative permission/negative immunity inferred.
P01 C044 — client-money facts and permission Pending. Unchanged.
P01 S016/S036/S039 — BCB dynamic/generic/DOU failures Historical failure statuses preserved. No retry, no false upgrade to opened rule.
P01 40 sources / 51 claims / 107 coverage rows / 11 examples User-supplied saved reviewed-foundation metadata, coordinator’s selected-source limitations preserved. Not re-created, recalculated or independently verified in this narrow PASS-02.

COMPLETE PASS-02 granular coverage

G1–G4 and P01 reconciliation coverage

# Question or subissue P02 finding/claims Status and exact next action
P02-G01 Original 3.954 currentness C001 Historical revocation supported; use S005, do not reuse 3.954 as present rule.
P02-G02 Original 4.935 rule text C002–C003, C017 Partial; obtain official published enacted 2021 body independent of draft/private reproduction.
P02-G03 Original commencement C001, C017 Feb1 2022 supported by historical official annotations; verify final DOU when accessible.
P02-G04 2025 article 8 repeal C013 Supported by official BCB retrospective, not full enacted amendment; reopen Joint17 full text.
P02-G05 2025 replacement naming restriction C014–C015, C025 Partial; read actual Joint17 art8, exceptions, transition, effective effect.
P02-G06 Post-Dec2025 current consolidated 4.935 C016, C023 Pending operative body; obtain genuinely readable official consolidation and check each relevant article.
P02-G07 Post-Dec2025/2026 later changes C016 Unknown; compare later official CMN/BCB amendment index and full enacted acts.
P02-G08 Authorized contracting institution C003 Historical institution-side rule; verify BCB institution class, actual current contract and tasks.
P02-G09 Potential correspondent legal form C004 Historical classes read; inspect actual contracting entity and current art4.
P02-G10 Individual natural-person contractor versus employee C004, C008–C009 Conditional; examine legal form, individual role and current norm; do not infer solo private-person eligibility.
P02-G11 Representative and staff C008–C009 Conditional; obtain formal team relationship/qualifications and current arts14–16.
P02-G12 Substabelecimento/subcontractor C008, C020 Conditional; inspect actual contract permission, institution consent and current limitations.
P02-G13 Electronic platform C020 Conditional; map app features, operator, responsible person and current rule.
P02-G14 Original art12 service list C005 Historical categories read; reopen current enacted art12 before claiming present permission.
P02-G15 Credit-proposal receipt/forwarding C006 Original institution-side operation explained; verify product, institution, contract and current text.
P02-G16 Approval decision and rates C003, C006, C010 No independent approval power concluded; inspect actual institution workflow, delegated rights and current clauses.
P02-G17 Credit renegotiation/repactuação C007 No universal settlement authorization; locate actual contracted credit service and current art12/15.
P02-G18 Collector/servicer tasks C005–C007 No general collection licence derived; inspect creditor contract and applicable separate rules.
P02-G19 Independent debtor-paid adviser C018 Different principal and role; obtain debtor contract, mandate, tasks and reserved-work review.
P02-G20 Mixed/conflicted roles C019 Conditional; read real dual agreements, payments, disclosures and current rules before any approval.
P02-G21 Institutional correspondent remuneration C010–C011 Historical rule identified; obtain current text and institution contract; no universal fee conclusion.
P02-G22 Independent debtor fee/refund C010, C018 Deferred consumer/contract law; no fee entitlement or refund rule concluded.
P02-G23 Branding and disclosure C010, C014–C015, C025 Current 2025 restriction material; official enacted article/exceptions/transitions not read.
P02-G24 Qualification/certification C009, C020 Historical credit-function-specific requirements; verify current art16 and actual role; no universal certificate.
P02-G25 Institution-account transaction versus client-money holding C005, C021 Separate payment rule unresolved; map funds and defer BCB494.
P02-G26 Generic correspondent register/category verification C012, C022 No named entries/contract checked; use only official generic method if later authorized.
P02-G27 Four required hypothetical classifications H01–H04; C003–C020 Five supplied including H05 money-flow boundary; no actual provider assessment.
P02-G28 P01 C021/G26/G27 disposition C024 Partially augmented, held; no original claim replaced.
P02-G29 Numerical conditions C026 No needed defensible current calculation; no invented licence/fee/savings arithmetic.
P02-G30 Narrow-country/publication acceptance C016, C018, C023–C026 HOLD; actual current enacted texts, institutional contract and separate review remain prerequisites.

Separately named deferred families

# Deferred family Why excluded from PASS-02; exact next action
P02-D01 BCB Resolution 494 current payment rules P01 C022 remains pending. Reopen enacted current payment authorization texts in separate work.
P02-D02 Payment-institution categorization Read specific operative BCB institution categories and exceptions with actual features/funds.
P02-D03 Client-funds title, custody, safeguarding and execution Obtain legal owner/processor/transaction trail and then apply full current rules.
P02-D04 AML/COAF obligations Separately characterize activities and current controlling AML sector instruments; P01 findings not revisited.
P02-D05 OAB legal advice and court representation Apply P01 reserved-work gateways to actual scripts if supplied; no new professional review here.
P02-D06 CRA professional administration Test substantive technical work and regional interpretation in later review.
P02-D07 CORECON technical financial consultancy Test atividade básica and regional registration only against actual service.
P02-D08 Consumer fee earning, ceilings, timing and refunds Review actual engagement/consumer rules; no implication from correspondent compensation terms.
P02-D09 Independent consumer engagement contracts/disclosures Review actual offer and contract across CDC, professional rules and local law.
P02-D10 Full CDC superendividamento and repactuação No change to P01 gateway; comprehensive eligibility/process requires separate review.
P02-D11 STF operative dispositive Obtain full 2026 acórdão, effects and subsequent compliance, not a correspondent issue.
P02-D12 CMN mínimo existencial rule/current amount Separate currentness and protected-income review; unrelated to correspondent authorization.
P02-D13 Debt products and lending eligibility Each loan/security/credit product needs its own BCB and contract rules.
P02-D14 Security, guaranties and collateral Review obligor/security-specific law; no transfer from correspondent contract.
P02-D15 Collection conduct and authority Separate creditor-agent appointment, CDC communications and sanctions review.
P02-D16 Credit reporting/correction Separate CDC/LGPD/bureau authorities.
P02-D17 Prescription, accrual and interruption Separate obligation-specific Civil Code/court analysis.
P02-D18 Tax Review actual provider/customer/tax transaction only after facts.
P02-D19 Courts, judgments, execution and mediation Separate OAB/CPC/court appointment and remedies analysis.
P02-D20 State/DF and municipal local branches All 27 P01 units remain unverified locally; separately named below, no fresh geography claim.
P02-D21 Foreign law, remote service and recognition No foreign law adopted; determine Brazilian and foreign professional/financial nexus in future independent work.
P02-D22 Full-country, A097/A098 and parent acceptance HOLD pending coordinator’s independent primary-source, claim, coverage and operational review.

All 27 original territorial branches expressly preserved as deferred

These rows are inheritance of P01’s territorial inventory only. No IBGE API was called; no fresh unit, local law, Procon, court or municipality was certified. “P01 limited SP” refers solely to its two previously reported local guidance items, not a licence rule.

Unit P02 status Exact local task still outstanding
Acre (AC) Deferred; no P02 local reading Verify AC professional/consumer/Procon, target municipality, court implementation and accessibility.
Alagoas (AL) Deferred; no P02 local reading Verify AL professional/Procon, municipal service rules, CEJUSC and language/accessibility.
Amapá (AP) Deferred; no P02 local reading Verify AP councils/consumer service, municipal powers, judiciary and language duties.
Amazonas (AM) Deferred; no P02 local reading Verify AM local consumer services, councils, court/Defensoria and remote-language implementation.
Bahia (BA) Deferred; no P02 local reading Verify BA Procon, technical professions, municipality, judiciary and accessibility.
Ceará (CE) Deferred; no P02 local reading Verify CE consumer/Procon and councils, municipal and tribunal implementation.
Distrito Federal (DF) Deferred; no P02 local reading Verify DF consumer service, councils, TJDFT and accessibility rules.
Espírito Santo (ES) Deferred; no P02 local reading Verify ES councils, Procon, municipality, judicial mediation and accessible service.
Goiás (GO) Deferred; no P02 local reading Verify GO consumer/professional instruments, TJGO, municipality and language requirements.
Maranhão (MA) Deferred; no P02 local reading Verify MA Procon, professional and court materials, municipality and accessibility.
Mato Grosso (MT) Deferred; no P02 local reading Verify MT professional/service rules, Procon, TJMT and municipal scope.
Mato Grosso do Sul (MS) Deferred; no P02 local reading Verify MS Procon, councils, TJMS, border/remote and language issues.
Minas Gerais (MG) Deferred; no P02 local reading Verify MG Procon, CRA/CORECON, TJMG and target municipality.
Pará (PA) Deferred; no P02 local reading Verify PA local public consumer help, councils, TJPA and language issues.
Paraíba (PB) Deferred; no P02 local reading Verify PB consumer/professional instruments, TJPB and municipal service rules.
Paraná (PR) Deferred; no P02 local reading Verify PR Procon, councils, TJPR and municipal/accessibility obligations.
Pernambuco (PE) Deferred; no P02 local reading Verify PE consumer/professional materials, TJPE and municipality.
Piauí (PI) Deferred; no P02 local reading Verify PI councils, Procon, TJPI, municipal implementation and language.
Rio de Janeiro (RJ) Deferred; no P02 local reading Verify RJ Procon, relevant councils, TJRJ and municipal advertising/service rules.
Rio Grande do Norte (RN) Deferred; no P02 local reading Verify RN consumer/professional provisions, TJRN and municipality.
Rio Grande do Sul (RS) Deferred; no P02 local reading Verify RS Procon, councils, TJRS, municipality and accessible languages.
Rondônia (RO) Deferred; no P02 local reading Verify RO consumer/professional law, TJRO/Defensoria and municipality.
Roraima (RR) Deferred; no P02 local reading Verify RR councils/Procon, TJRR, municipal and multilingual rules.
Santa Catarina (SC) Deferred; no P02 local reading Verify SC consumer/professional instruments, TJSC and municipality.
São Paulo (SP) Deferred; P01 limited CORECON-SP/PROCON-SP guidance retained, not re-read Complete SP state provider/consumer laws, CRA, TJSP, relevant municipal Procon and accessibility review.
Sergipe (SE) Deferred; no P02 local reading Verify SE Procon, councils, TJSE, municipality and language/accessibility.
Tocantins (TO) Deferred; no P02 local reading Verify TO Procon/professional rules, TJTO/Defensoria, municipality and language.

Territorial coverage: 27 displayed individually named deferred rows. Zero new local bodies read in PASS-02.

PASS-02 researcher self-check

Check Actual result
Narrow scope Only current correspondentes no País rule-body and institution-versus-debtor-capacity question investigated.
Ordinary primary browsing Used official search, opened BCB public vote PDFs and superseded norm PDF; no private systems or API calls.
Source count 15 displayed S001–S015, each status-coded. Duplicate P01 provenance source explicitly labelled; not counted as fresh authority.
Material newly opened PDFs Five: BCB 2021 proposal; bank-hosted original reproduction; BCB 2025 proposal; BCB 2026 retrospective; BCB superseded 2011 norm.
Enacted official current 4.935 full body Not opened. Must not be certified from bank-hosted reproduction, draft or index.
Enacted official Joint17 full body Not opened. BCB 2026 retrospective supports repeal/commencement; exceptions/transition still held.
Official publication alternate Two DOU HTML paths attempted, both HTTP 502; old failed P01 BCB dynamic/DOU PDF not retried.
Claim count 26 displayed P02 claim rows C001–C026.
Narrow gateway count 30 displayed P02-G01–G30 rows.
Deferred-family count 22 displayed P02-D01–D22 rows.
Territorial count 27 individually displayed, without fresh geography/API certification.
Hypothetical count Five H01–H05, no actual party, contract or outcome.
Numerical check No unsupported fee/savings/authorization calculation. Historical statutory dates distinguished from research dates.
Preserved P01 Exact C021/G26/G27 wording and old failure status preserved; no full-country rerun or change to other P01 claims.
Coordinator status User-supplied selected-body scope acknowledged; no independent review claimed for P02.

Exact next source and acceptance blocker

The next consequential item is a genuinely readable, official, fully enacted CMN Resolution 4.935/2021 consolidated through the real access date, followed by the enacted full Joint Resolution 17/2025, especially its article 8, exceptions, contract-adjustment provisions, repeal clause and effective clause. The issuing regulator’s indexed search result and the inaccessible gazette entry are discovery pointers, not a substitute for those bodies.

Once those bodies are obtained through a permitted ordinary published format, the coordinator must independently:

  1. Re-read and date the operative arts. 1–5, 8–12, 14–16, 18 and 21–23, and any material amendments.
  2. Compare every relevant provision against the 2021 draft/reproduction and the 2025 official vote; record changes and actual commencement.
  3. Check the narrow institution/contract/representative/platform/consumer taxonomy.
  4. Preserve any additional creditor-service, professional, client-funds and local-law holds.
  5. Validate the P02 claims, examples and all coverage rows without treating this researcher self-check as approval.

Disposition: PASS-02 narrow findings submitted, current rule-body completion PARTIAL, G26/G27 still held. No named provider is classified as permitted, no loan or debt outcome is promised, and no country, contract, publication or A097/A098 acceptance follows.

END C_BR PASS-02

Every captured table

Captured cells with original header handling and explicitly labeled bounded correction overlays. Downloaded JSON retains original cells. Tables may contain source limitations, historical examples and identified corrections; the complete reading supplies context.

Read the evidence with its boundaries. These are saved research components, including revisions. A scoped coordinator review checks selected evidence; it does not certify every claim, a complete jurisdiction, current law or individual applicability. Dates and access limits remain attached to the records.

How to read the research →

Read the related correction supplements

These components repair their stated scope. They do not replace every other finding in this research series.

One bounded provenance-only repair to →
Bounded P13 payment-recipient qualification and source/claim/count traceability repair →
Bounded P14 atomic-predicate, commencement-traceability and count-unit repair →

Captured table 01

Original headerless table; first data row retained · 7 data rows

Instrument/statusDate and actual read evidenceEffect on this narrow questionCurrent verification status
Resolution 3.954/2011 — superseded materialBanco Central’s official 15-page consolidated PDF marks the relevant articles revoked from February 1, 2022. S005, various articles.Prevents mistakenly using the older correspondent activity and contract rules as today’s rule.Verified historical transition. The old operative body was actually opened. normativos.bcb.gov.br
CMN Resolution 4.935/2021 — original enactmentDated July 29, 2021; published in the DOU August 2, 2021. Original BCB proposal annex S001 arts. 1–26; reproduced published-resolution text S002 art. 26 states effect from February 1, 2022; S005 independently records that replacement date.Established the distinct institutional-correspondent framework.Original wording substantively inspected, but not from an opened enacted official publication. S001 is a draft and S002 a non-issuer reproduction.
Joint Resolution 17/2025 — amending actDated November 28, 2025; BCB Vote 17/2026 says it became effective on December 1, 2025. Official BCB proposal S003 included a proposed new naming/contract rule and revocation of 4.935 art. 8.Repealed the earlier art. 8 prior-approval mechanism and, as BCB later describes it, changed the treatment of misleading institution-style names.Revocation and commencement supported by opened 2026 BCB explanatory vote. Complete enacted wording, exceptions and transitions not directly read.
Current consolidated 4.935 displayBCB’s indexed normative search result calls it the current version updated December 1, 2025. S006.Discovery lead for the operative text after the amendment.Indexed only; full current text not opened. A search index’s update label does not independently certify every article’s operation.
BCB Vote 17/2026Official PDF, February 19, 2026, explanatory paragraph 7, zero-based PDF page 1. S004.Confirms 2025 revocation and describes the succeeding restriction.Actual official explanatory body read; not a substitute for the full joint resolution.
Later changes through October 26, 2026No comprehensive post-December 2025 amendment inventory completed beyond the sources above.Could affect any unverified provision or implementation.Unknown, not “none.”

Captured table 02

Original headerless table; first data row retained · 17 data rows

Material provision or subjectWhere actually readWhat can safely be concluded now
Original 4.935 arts. 1–3 — scope, contracting institution, direction/responsibilityS001 official draft, PDF indices 8–9; S002 original-text reproduction, indices 0–1Strong historical evidence of institution-side structure; current exact formulation awaits official consolidated body.
Art. 4 — classes potentially contractedS001 draft index 8–9; S002 index 1Historical reproduction lists sociedades, empresários e associações, not every unregistered natural person automatically. Current scope unverified.
Arts. 5–7 — restrictions and authorized-institution contractingS002 indices 1–2Historical text read; exact current conditions not certified.
Art. 8 — historical prior-approval mechanismS002 index 2, S003 proposed repeal index 10, S004 retrospective confirmation index 1Repeal supported. Old permission route cannot be represented as currently open.
Art. 9 — institutional directorS002 index 2Historical institution governance; current operative wording not reopened.
Art. 10 — substabelecimentoS002 index 2Original text requires initial contractual permission and institutional consent for one level, with qualifications. Current wording unverified.
Art. 11 — institutional charges and location restrictionS002 indices 2–3Historical rule addresses charges for institution-supplied products; does not settle separate debtor advice charges.
Art. 12 — permitted contracted service objectsS001 draft; S002 index 3Specific historical categories, including credit-proposal reception/forwarding; no standalone independent debtor-advice permission identified in that enumeration.
Art. 13 — foreign-exchange activityS002 indices 3–4, only to identify different product categoryOutside current narrow scope. Detailed exchange limits and present operation not certified.
Art. 14 — institutional contract clauses, disclosures, fee/control boundariesS002 indices 4–6Historical detail inspected; current publication required before making definitive operational claims.
Arts. 15–16 — credit activities, persons performing them, certificationS002 indices 6–9Historical activity-specific conditions, not a universal debt-adviser certificate or blanket certificate requirement for all correspondents.
Arts. 17–20 — institution guidance, supervision, remuneration policy and credit monitoringS002 indices 9–11; S001 contemporaneous rationaleHistorical institution-side control design; actual present requirements await consolidated enacted text.
Arts. 21–23 — public information, claims, BCB communicationsS002 indices 11–12Historical matching-entity/service verification route, not proof of any hypothetical contract.
Arts. 24–26 — final provisions and original commencementS002 indices 12–13; transition corroborated S005February 1, 2022 original commencement supported; subsequent amendment separately dated.
Joint 17 proposed arts. 8, 13–14S003 official draft, indices 9–10Proposed naming-contract restriction, revocation and immediate publication effect; actual final resolution not independently opened.
Joint 17 actual enactment/repealS004 BCB 2026 explanatory vote, index 1December 1, 2025 entry and CMN 4.935 art. 8 repeal reported by competent regulator. Exact operative exceptions/transition clauses remain unread.

Captured table 03

Original headerless table; first data row retained · 12 data rows

Actor or operationOriginal 4.935 evidence and controlling distinctionActual capacity proof still requiredAdverse or withheld conclusion
Contracting institutionArts. 1–3: financial institution or another BCB-authorized institution engages the correspondent for its customers/products, under its direction. C002–C003.Exact regulated institution, authorized modality, actual current correspondent contract and supervision structure.Institution’s separate authorization cannot be inherited by an unrelated adviser.
Correspondent entityOriginal art. 4 specifies categories of prospective contracted bodies; art. 2 requires the institution-side engagement. C004.Legal form, contracting party, date, legal name and actual duties.Mere company registration, trade name or a self-described corban does not establish a real engagement.
Natural-person staff or representativeOriginal arts. 14–16 distinguish the contracted entity from formally engaged individual attendants and relevant qualified staff. C008–C009.Employment/service arrangement, tasks, supervision, identification and activity-specific qualification.Working for a correspondent is not a transferable personal debt-advice or legal licence.
Subcontractor / substabelecidoOriginal art. 10 recognizes limited subdelegation subject to contractual and institution approval conditions. C008.Original contract, permission, institution consent, identity and exact delegated tasks.A chain of unsolicited affiliates or lead buyers cannot assume lawful substitution.
Electronic correspondent platformOriginal art. 2 §2 and arts. 12, 16 tie platform functions to defined institutional services and responsible qualified personnel for specified credit activities. C005, C009, C020.Platform operator, functional inventory, actual contract, supervising individual, data/API/funds flow.“We are software” or “we use a certified platform” is not all-purpose financial or debtor-service permission.
Consumer applying for institution creditOriginal art. 12(V): reception/forwarding of a credit or leasing proposal for a contracting institution; the institution decides and provides the product. C005–C006.Which institution, product, submission and approval process; disclosure of adviser’s role.Proposal receipt is not the adviser approving credit, setting autonomous terms or settling unrelated debts.
Consumer seeking debt renegotiationOriginal art. 12(V) includes services associated with following the institution’s credit operation. Historical art. 15 references repactuação for a remuneration calculation. C006–C007.Is the relevant debt owed to the contracting institution? Is this task actually included in a lawful current contract? Who may bind creditor/debtor?Mention of repactuação in a remuneration provision is not an independent statutory debtor-agent licence or proof of authority to compromise any debt.
Collector/servicer for institutionOriginal art. 12 uses specified institution-provided service categories. C005–C007.Particular contract term, creditor appointment and actual collection/contact duties.No blanket creditor-collection or consumer-representation permission is inferred.
Independent debtor-paid negotiatorOriginal art. 3 institution-side agency is different in principal, instructions, compensation and fiduciary posture. C018–C019.Separate debtor engagement, script, mandato, compensation, creditor role and funds.Correspondent contract cannot by itself legalize separate debtor-side legal advice or client-money handling.
Mixed two-sided providerInstitutional service and independent debtor consultancy are distinguishable engagements. Historic art. 14 disclosures/policy create a pertinent conflict question. C019–C020.Contracts with both sides, segregated teams, payment sources, disclosures, instructions and treatment of conflicts.No categorical “dual representation always lawful” or “always banned” finding without current full rule and actual contracts.
Funds operatorOriginal art. 12 contains institution-account payment functions; those differ from taking borrower settlement savings into the adviser’s own account. C016, C021.Account title, payment processor, who authorizes movement and BCB category.BCB 494 and separate payment authorization remain deferred.

Captured table 04

Original headerless table; first data row retained · 12 data rows

Evidence itemWhat exact question it answersWhat it cannot establish
Contracting institution’s precise legal identity and dated BCB categoryWhich institution is the principal and what kind of products it may offerAuthority of a separate debtor-paid consultancy
Executed correspondent agreement and amendmentsWhether the exact provider is engaged, when, and for which activitiesAuthority for unrelated creditors or uncontracted product categories
Current institutional policy and authorized task scheduleWho controls scripts, prices, referrals and customer communicationsThe borrower’s independent representation or litigation authority
Staff/representative and subcontractor documentsWho answers calls and whether delegated activity is contractually includedUniversal qualification merely from a course certificate
Product-specific application processWho receives the proposal, forwards it, evaluates it and approves or refusesAny promised approval or future lender action
Customer-facing site, advertising and scriptsWhether the customer can identify the institution and distinguish conflicting rolesAn actual regulator’s approval of the words used
Separate debtor advisory contract, if anyWho pays for debtor representation, for what, and on which instructionsAutomatic validation by the institutional correspondent contract
Debtor mandato or creditor authorityWho may negotiate, sign a compromise, receive payment or give dischargeAn exemption from reserved legal or financial activity
Compensation records or blank commercial scheduleWhether the institution, debtor, third party or multiple parties payLegality of an unsupported specific fee
Funds-flow and account-title diagramWhether money is controlled by an authorized institution or held by the adviserPayment-institution authorization without the current BCB rules
Generic institution/correspondent register procedureHow a future checker should match name, service, date, category and institutionProof of an unsearched actual record or contract

Captured table 05

Original headerless table; first data row retained · 6 data rows

Invented exampleConditional answer; source and claim IDsMissing evidence, adverse branch and exact next action
H01 — Institution-contracted credit proposal receiver. A finance institution engages a company to collect applicants’ identification and forward that institution’s credit proposals. The company does not advise on debts owed to other creditors.Historically fits the type of art. 12(V) institutional task. C003, C005–C006, C009; S001 draft art. 12, S002 reproduction arts. 2–3, 12(V), 15–16. Current conditions remain unverified.Need dated actual institution contract, scope, staff roles, platform information and official current rule. Adverse: proposed loan outside licensed institutional product or unauthorized originator promises. Next action: obtain a blank activity schedule showing the exact authorized product/task and identify who approves credit.
H02 — Debtor adviser using a correspondent badge. A firm says, “We are a bank correspondent, so we may charge to negotiate all your card debts,” but supplies no institutional agreement.Correspondent label is not a debtor mandate. C003, C018, C022; S002 historical arts. 2–3 and 12, P01 C004–C007/C021.Need actual creditor-side contract if claimed, debtor engagement, scripts, remuneration and legal capacity. Adverse: misleading role or reserved legal advice; potential absence of any real correspondent engagement. Next action: ask, “Which named institution engaged you, for exactly what task, and who authorized you to act for the debtor?”
H03 — Mixed roles and potential conflict. A company originates a lender’s refinancing applications, but also sells separate debtor-paid recommendations about whether the consumer should refinance or settle debts.Two distinct engagements; original public-description/remuneration controls are relevant but do not automatically decide dual-role lawfulness. C010, C018–C020; S002 arts. 14, 18, S003 proposed naming changes.Need dual contracts, pay sources, conflicts, disclosures, decision-making scripts and current full rule. Adverse: biased presentation, role confusion or unapproved acts. Next action: trace who pays for each call and whether advice is independent or directed by the institution.
H04 — Referral software with staff and subcontractor. A platform sends prospective applicants to an authorized institution. A call-centre affiliate follows up, without clear documents identifying who contracts it.Merely referring, hosting a form, operating an institution-linked credit platform and acting as a subcontracted correspondent can be different capacities. C008–C009, C020; S001/S002 arts. 2, 10, 12, 16.Need institution contract, referral agreement, delegation clause/consent, platform operator, qualified person and exact feature map. Adverse: unsupported subcontracting or a hidden regulated activity. Next action: establish whether the platform or call centre actually receives and forwards the institution’s proposal under that institution’s contract, or only supplies traffic.
H05 — Correspondent plus settlement-funds wallet. A firm may forward loan applications under one contract but separately receives monthly debtor money into an account it controls for later settlement.Loan correspondence does not settle money custody/payment category. C016, C018, C021; P01 C016–C017/C022/C044; S002 art. 12 historical, P01 S015 statutory payment definitions.Need beneficial-title chain, payment rails, account owner, refund control, processor and current operative payment rules. Adverse: unverified client-funds or financial/payment activity. Next action: ask, “Does any debtor money ever enter an account legally owned or controlled by the adviser before reaching the creditor?” BCB 494 remains deferred.

Captured table 06

Original headerless table; first data row retained · 16 data rows

Source IDIssuer, full title and complete literal URLExact section/page; version/publication/commencement; actual access and limit
C_BR-P02-S001Banco Central/CMN, Voto do CMN 59/2021 with BCB Vote 160/2021, attached proposed Resolução CMN on correspondents. https://normativos.bcb.gov.br/Votos/CMN/202159/VOTO_DO_CMN_59_2021_BCB_SECRE_Numerado_Manualmente_01.pdfREAD-DRAFT. 39-page PDF; draft norm zero-based PDF 8–17, arts. 1–26, alongside impact assessment. Printed appended draft pages 1–10, embedded vote pagination differs. Proposal dated July 2021; not final enactment. Access Oct26 PDT/Oct27 UTC window above.
S002Banco Santander-hosted reproduction of Resolução CMN nº 4.935, de 29 de julho de 2021. https://cms.santander.com.br/sites/WPS/documentos/arq-resolucao/23-09-26_204507_resolucao_4935.pdfREAD-REPRO. 14-page PDF; relevant zero-based PDF indices 0–13, arts. 1–26, including arts. 2–4, 10–12, 14–16, 18, 21, 25–26. Original resolution dated July29 2021, art26 says effective Feb1 2022. Hosting filename date is not enactment/currentness. PDF contains historical art8 superseded in 2025; cannot be called 2026 consolidation. Access current P02 window.
S003Banco Central/CMN, Voto do CMN 80/2025 including proposed Joint Resolution on authorized institutions’ names/public presentation. https://normativos.bcb.gov.br/Votos/CMN/202580/Voto_do_CMN_80_2025.pdfREAD-DRAFT. 11-page PDF; proposed resolution zero-based indices 7–10, proposed arts. 1–14, esp. 8 §§1–2, 13–14. Attached proposal dated November2025 and contains blank resolution number/date before adoption. Not final enacted transitional text. Access P02 window.
S004Banco Central, Voto 17/2026–BCB, de 19 de fevereiro de 2026. https://normativos.bcb.gov.br/Votos/BCB/202617/Voto_do_BC_17_2026.pdfREAD-EXPL. 22-page PDF; explanatory para. 7, zero-based PDF 1, printed internal vote p. 2 of 3. Dated February19 2026; states Joint17 issued November28 2025, effective December1 2025, repealed CMN4935 art8 and describes new name restriction. The new 2026 draft later appended to the vote is not assumed enacted. Access P02 window.
S005Banco Central, official consolidated presentation of superseded Resolução nº 3.954, de 24 de fevereiro de 2011. https://normativos.bcb.gov.br/Lists/Normativos/Attachments/49450/Res_3954_v12_P.pdfREAD-HIST. 15-page PDF, zero-based indices 0–14, arts. 1–19 and related revocation annotations. Relevant marks across indices 0–13: replaced/revoked from February1 2022 by 4.935. Printed PDF “Página 1 de 15” onward aligned to zero-based index +1. Historical text is not current correspondent authorization. Access P02 window.
S006Banco Central normative public interface, Resolução CMN 4.935/2021 — versão vigente. https://www.bcb.gov.br/estabilidadefinanceira/exibenormativo?numero=4935&tipo=RESOLU%C3%87%C3%83O+CMNINDEX/REUSE. Current search index encountered in P02 shows update December1 2025 and excerpts arts. 1–4, 12, 14. P01 S016 attempted the live body and failed; not retried here. No page/index applicable and no full 2026 body read.
S007Banco Central normative public interface, Resolução Conjunta 17/2025. https://www.bcb.gov.br/estabilidadefinanceira/exibenormativo?numero=17&tipo=Resolu%C3%A7%C3%A3o+ConjuntaINDEX. Official indexed 2025 norm and repeal of 4.935 art8, not directly opened full. Its indexed posting/currentness text is not an actual read of exceptions or operative transition. Access P02 window as search result.
S008Imprensa Nacional, DOU HTML publication candidate for original CMN4935. https://www.in.gov.br/web/dou/-/resolucao-cmn-n-4.935-de-29-de-julho-de-2021-335456670FAILED. Direct opening returned HTTP 502, no article text; candidate for original August2 2021 DOU, no page index. Access P02 window.
S009Imprensa Nacional, alternate DOU English-route HTML publication candidate. https://www.in.gov.br/en/web/dou/-/resolucao-cmn-n-4.935-de-29-de-julho-de-2021-335456670FAILED. HTTP 502; no body read, same historical publication candidate through a different path. Access P02 window.
S010Banco Central, public July2021 CMN communication. https://www.bcb.gov.br/detalhenoticia/17457/notaINDEX/FAILED BODY. Indexed official description says original norm would enter in February2022 and includes platform/staff discussion; direct open returned a one-line body. Used only as historical discovery corroboration, not operative articles.
S011Presidência, Lei 4.595/1964 financial-institution statute, compiled. https://planalto.gov.br/ccivil_03/leis/l4595compilado.htmREUSE P01 S014, arts. 17–18, user-supplied dated P01 row and coordinator’s selected fresh read; not reopened in P02. Establishes upper-level category only.
S012Presidência, Lei 12.865/2013 payment services statute. https://www.planalto.gov.br/ccivil_03/_ato2011-2014/2013/lei/l12865.htmREUSE P01 S015, arts. 6 and 9/10 selected in coordinator scope; not reopened in P02. Does not answer current payment-institution exemptions.
S013Banco Central, generic Correspondentes no País guidance. https://www.bcb.gov.br/estabilidadefinanceira/correspondentes_paisINDEX/REUSE P01 S036. P02 found indexed generic information on institution/municipality/service files; no named record, no fresh successful body opening; no actual-contract verification.
S014Banco Central normative interface, historical P01 source S016 (same CMN4935 interface). https://www.bcb.gov.br/estabilidadefinanceira/exibenormativo?numero=4935&tipo=RESOLU%C3%87%C3%83O+CMNREUSE of failure history, not another source proof: P01 dynamic full body inaccessible; no new opening attempted. Listed separately solely to preserve exact original provenance.
S015Imprensa Nacional, P01 original DOU PDF viewer. https://pesquisa.in.gov.br/imprensa/servlet/INPDFViewer?captchafield=firstAccess&data=02%2F08%2F2021&jornal=515&pagina=23REUSE P01 S039 prior failure, not retried. Original DOU printed page 23 as reported by indexed metadata; zero-based PDF index not established, underlying pages not read.
Source links captured in this table

Captured table 07

Original headerless table; first data row retained · 27 data rows

Claim IDProvisional route; exact proposition, actor, condition, act/consequence and retained limitSources and pinpoints
C_BR-P02-C001A098. Earlier correspondent rule 3.954’s relevant articles ceased operating from Feb1 2022 under 4.935. This removes the old text as a present-permission source.S005 revocation notes across arts. 1–19, PDF indices 0–13.
C002A097. The July2021 proposed 4.935 arts. 1–3 conceived institutional contracting and direction, not stand-alone debtor advocacy; a draft alone is not enacted law.S001 draft arts. 1–3, PDF 8–9.
C003A097. Historical reproduced 4.935 arts. 2–3 place correspondent services with the contracting authorized institution and under its directions/responsibility. Present exact wording remains held.S002 arts. 2–3, PDF 0–1; S006 index only.
C004A097. Original reproduced art. 4 lists classes of potential contractual correspondents, including sociedades, empresários e associações. It does not alone authorize any natural person or firm absent a contract.S002 art. 4, PDF 1; S001 draft, PDF 8–9.
C005A097. Historical art. 12 enumerates institution-product services, including account applications, institution-account transfers/payments and credit/leasing proposals, subject to actual contract. Current exact text held.S002 art. 12(I)–(VII), sole paragraph, PDF 3.
C006A097. Original art. 12(V) concerns receipt and forwarding of the contracting institution’s credit/leasing proposals and related operation-follow-up services, not independent approvals or unrelated creditor settlement.S002 art. 12(V), PDF 3; distinction partly inference.
C007A097. Reference to repactuação in historical art. 15 remuneration provisions cannot itself establish authority to represent a debtor in settlement of any credit.S002 arts. 12(V), 15 §2, PDF 3, 7–8; qualified interpretive inference.
C008A097. Historical arts. 10 and 14 distinguish contracted entity, limited approved subdelegation and formal staff relationship; current requirements need full official body.S002 arts. 10, 14(I), PDF 2, 4–5.
C009A097. Historical arts. 15–16 attach staff/platform technical qualification to credit/leasing activity, not to all budget advice.S002 arts. 15–16, PDF 7–9.
C010A097. Historical art. 14 requires disclosure of institution role/products and sets institution-contract controls on products and customer charges; these do not decide standalone debtor-consultancy fees.S002 art. 14(II)–(VII), PDF 5–6.
C011A097. Historical art. 18 requires contracting institution controls and remuneration policy; no creditor/customer settlement result follows.S002 art. 18, PDF 9–10.
C012A098. Historical arts. 21–23 describe institution correspondent-activity publication and regulator reporting, not proof an individual provider actually appears or has a current mandate.S002 arts. 21–23, PDF 11–12; S013 generic indexed guidance.
C013A098. BCB’s Feb2026 explanation establishes that Joint17 took effect Dec1 2025 and repealed CMN4935 art. 8. Prior-approval path under that old article cannot be stated as current.S004 para. 7, PDF 1; S003 proposed art. 13, PDF 10 corroborative but not enacted.
C014A098. Competent BCB description says 2025 replacement restricts certain institution-style names/partnerships. Exact final test/exceptions/transitions not established.S004 para. 7 PDF 1; S003 proposed art. 8 PDF 9.
C015A098. BCB’s proposed, not confirmed enacted, Joint17 art. 8 includes particular exceptions and a one-year pre-existing contract adjustment framework. No operative deadline or exception claim adopted here.S003 draft art. 8 §§1–2, PDF 9.
C016A098. BCB current search index reports Dec1 2025 consolidated update but does not certify all operative 4.935 clauses.S006 indexed heading; direct operative body failed in P01 S016.
C017A098. Historical effective Feb1 2022 is supported by reproduced original art. 26 and official 3.954 supersession annotations; original full DOU not opened.S002 art. 26 PDF 13; S005 revocation notes; S008–S009 failed.
C018A097. On these historical institutional provisions, correspondent capacity is materially different from an independent debtor-paid mandato. Inference, not an exhaustive negative licence conclusion.S001 proposed arts. 2–3/12; S002 reproduction arts. 2–3/12; P01 C004–C008/C021.
C019A097. A mixed institution/borrower relationship needs distinct contract/compensation/conflict analysis; neither blanket permission nor blanket prohibition established.S002 arts. 3, 14, 18 historical; actual contracts absent.
C020A097. Referral website, correspondent platform, individual attendant and approved subcontractor have different possible roles; no one certificate or software label classifies all.S002 arts. 2, 10, 12, 14–16 historical; operative consolidation pending.
C021A097. A correspondent task involving institution-controlled transfers does not authorize borrower-savings custody or independent payment services by the correspondent.S002 art. 12(II)–(IV) historical; P01 S015/C016–C017/C022/C044 deferred.
C022A098. A general public correspondent list can identify entity/service relationships if appropriately checked, but no contract or individual record was supplied/searched.S013 indexed public guidance; S002 arts. 21–23 historical.
C023A098. Official DOU original body could not be read through either public HTML route; the 2021 bank-hosted text and draft are not an official current consolidation.S001–S002, S008–S009; explicit access limitation.
C024A098. P01 C021 and G26/G27 can receive narrower historical/current amendment findings; current operative details and actual contracts remain missing.C001–C023; P01 S016/S039, C021, G26–G27.
C025A098. The 2025 naming problem requires actual name, public presentation and institution contract; no brand/CNPJ/general “bank correspondent” badge grants permission.S004 para. 7; S003 proposed art. 8; exact final text held.
C026A098. No numerical licence/resource/business-cost example is necessary or defensible for an unclassified provider; original reproduced charge/certification calculations not generalized.S002 arts. 14–16; current enacted text and actual contracts absent.

Captured table 08

Original headerless table; first data row retained · 10 data rows

Original P01 recordPreserved original statusP02 disposition and publication gate
C_BR-P01-C021 — “An institutional correspondente is categorically different from independent debtor advice; exact current contracting/activity requirements remain unverified.”Preserved as written. Indexed rule/failure basis remains attributed, not retroactively upgraded.Append P02 C001–C020/C023–C024. Historical architecture read and Dec2025 repeal specifically established by BCB explanation. Still not current operative body-cleared.
P01 G26 — “Correspondent-bank category”; “Institution-side, distinct from debtor adviser; C021”; “Pending body; obtain consolidated CMN 4.935 with amendments and actual contract.”Preserved.Add history and art8 revocation. Pending exact official consolidated 4.935/current Joint17 and real contract.
P01 G27 — “Credit intermediary/referral”; “Facts change class; C015, C021”; “Pending body; isolate advertising, application submission, compensation and lender authority.”Preserved.Add original art12(V) institutional proposal route, platform/staff distinctions as historically read; still pending current body and functional facts.
P01 C015 — financial institution law arts. 17–18Original selected upper-level statute review preserved.No change or new implementing permission certified.
P01 C022 — BCB494/payment authorizationPending current implementing body.Unchanged; wholly deferred in P02.
P01 C042 — bounded absence of universal dedicated debtor-adviser permissionQualified negative remains.Unchanged; no broader affirmative permission/negative immunity inferred.
P01 C044 — client-money facts and permissionPending.Unchanged.
P01 S016/S036/S039 — BCB dynamic/generic/DOU failuresHistorical failure statuses preserved.No retry, no false upgrade to opened rule.
P01 40 sources / 51 claims / 107 coverage rows / 11 examplesUser-supplied saved reviewed-foundation metadata, coordinator’s selected-source limitations preserved.Not re-created, recalculated or independently verified in this narrow PASS-02.

Captured table 09

Original headerless table; first data row retained · 31 data rows

#Question or subissueP02 finding/claimsStatus and exact next action
P02-G01Original 3.954 currentnessC001Historical revocation supported; use S005, do not reuse 3.954 as present rule.
P02-G02Original 4.935 rule textC002–C003, C017Partial; obtain official published enacted 2021 body independent of draft/private reproduction.
P02-G03Original commencementC001, C017Feb1 2022 supported by historical official annotations; verify final DOU when accessible.
P02-G042025 article 8 repealC013Supported by official BCB retrospective, not full enacted amendment; reopen Joint17 full text.
P02-G052025 replacement naming restrictionC014–C015, C025Partial; read actual Joint17 art8, exceptions, transition, effective effect.
P02-G06Post-Dec2025 current consolidated 4.935C016, C023Pending operative body; obtain genuinely readable official consolidation and check each relevant article.
P02-G07Post-Dec2025/2026 later changesC016Unknown; compare later official CMN/BCB amendment index and full enacted acts.
P02-G08Authorized contracting institutionC003Historical institution-side rule; verify BCB institution class, actual current contract and tasks.
P02-G09Potential correspondent legal formC004Historical classes read; inspect actual contracting entity and current art4.
P02-G10Individual natural-person contractor versus employeeC004, C008–C009Conditional; examine legal form, individual role and current norm; do not infer solo private-person eligibility.
P02-G11Representative and staffC008–C009Conditional; obtain formal team relationship/qualifications and current arts14–16.
P02-G12Substabelecimento/subcontractorC008, C020Conditional; inspect actual contract permission, institution consent and current limitations.
P02-G13Electronic platformC020Conditional; map app features, operator, responsible person and current rule.
P02-G14Original art12 service listC005Historical categories read; reopen current enacted art12 before claiming present permission.
P02-G15Credit-proposal receipt/forwardingC006Original institution-side operation explained; verify product, institution, contract and current text.
P02-G16Approval decision and ratesC003, C006, C010No independent approval power concluded; inspect actual institution workflow, delegated rights and current clauses.
P02-G17Credit renegotiation/repactuaçãoC007No universal settlement authorization; locate actual contracted credit service and current art12/15.
P02-G18Collector/servicer tasksC005–C007No general collection licence derived; inspect creditor contract and applicable separate rules.
P02-G19Independent debtor-paid adviserC018Different principal and role; obtain debtor contract, mandate, tasks and reserved-work review.
P02-G20Mixed/conflicted rolesC019Conditional; read real dual agreements, payments, disclosures and current rules before any approval.
P02-G21Institutional correspondent remunerationC010–C011Historical rule identified; obtain current text and institution contract; no universal fee conclusion.
P02-G22Independent debtor fee/refundC010, C018Deferred consumer/contract law; no fee entitlement or refund rule concluded.
P02-G23Branding and disclosureC010, C014–C015, C025Current 2025 restriction material; official enacted article/exceptions/transitions not read.
P02-G24Qualification/certificationC009, C020Historical credit-function-specific requirements; verify current art16 and actual role; no universal certificate.
P02-G25Institution-account transaction versus client-money holdingC005, C021Separate payment rule unresolved; map funds and defer BCB494.
P02-G26Generic correspondent register/category verificationC012, C022No named entries/contract checked; use only official generic method if later authorized.
P02-G27Four required hypothetical classificationsH01–H04; C003–C020Five supplied including H05 money-flow boundary; no actual provider assessment.
P02-G28P01 C021/G26/G27 dispositionC024Partially augmented, held; no original claim replaced.
P02-G29Numerical conditionsC026No needed defensible current calculation; no invented licence/fee/savings arithmetic.
P02-G30Narrow-country/publication acceptanceC016, C018, C023–C026HOLD; actual current enacted texts, institutional contract and separate review remain prerequisites.

Captured table 10

Original headerless table; first data row retained · 23 data rows

#Deferred familyWhy excluded from PASS-02; exact next action
P02-D01BCB Resolution 494 current payment rulesP01 C022 remains pending. Reopen enacted current payment authorization texts in separate work.
P02-D02Payment-institution categorizationRead specific operative BCB institution categories and exceptions with actual features/funds.
P02-D03Client-funds title, custody, safeguarding and executionObtain legal owner/processor/transaction trail and then apply full current rules.
P02-D04AML/COAF obligationsSeparately characterize activities and current controlling AML sector instruments; P01 findings not revisited.
P02-D05OAB legal advice and court representationApply P01 reserved-work gateways to actual scripts if supplied; no new professional review here.
P02-D06CRA professional administrationTest substantive technical work and regional interpretation in later review.
P02-D07CORECON technical financial consultancyTest atividade básica and regional registration only against actual service.
P02-D08Consumer fee earning, ceilings, timing and refundsReview actual engagement/consumer rules; no implication from correspondent compensation terms.
P02-D09Independent consumer engagement contracts/disclosuresReview actual offer and contract across CDC, professional rules and local law.
P02-D10Full CDC superendividamento and repactuaçãoNo change to P01 gateway; comprehensive eligibility/process requires separate review.
P02-D11STF operative dispositiveObtain full 2026 acórdão, effects and subsequent compliance, not a correspondent issue.
P02-D12CMN mínimo existencial rule/current amountSeparate currentness and protected-income review; unrelated to correspondent authorization.
P02-D13Debt products and lending eligibilityEach loan/security/credit product needs its own BCB and contract rules.
P02-D14Security, guaranties and collateralReview obligor/security-specific law; no transfer from correspondent contract.
P02-D15Collection conduct and authoritySeparate creditor-agent appointment, CDC communications and sanctions review.
P02-D16Credit reporting/correctionSeparate CDC/LGPD/bureau authorities.
P02-D17Prescription, accrual and interruptionSeparate obligation-specific Civil Code/court analysis.
P02-D18TaxReview actual provider/customer/tax transaction only after facts.
P02-D19Courts, judgments, execution and mediationSeparate OAB/CPC/court appointment and remedies analysis.
P02-D20State/DF and municipal local branchesAll 27 P01 units remain unverified locally; separately named below, no fresh geography claim.
P02-D21Foreign law, remote service and recognitionNo foreign law adopted; determine Brazilian and foreign professional/financial nexus in future independent work.
P02-D22Full-country, A097/A098 and parent acceptanceHOLD pending coordinator’s independent primary-source, claim, coverage and operational review.

Captured table 11

Original headerless table; first data row retained · 28 data rows

UnitP02 statusExact local task still outstanding
Acre (AC)Deferred; no P02 local readingVerify AC professional/consumer/Procon, target municipality, court implementation and accessibility.
Alagoas (AL)Deferred; no P02 local readingVerify AL professional/Procon, municipal service rules, CEJUSC and language/accessibility.
Amapá (AP)Deferred; no P02 local readingVerify AP councils/consumer service, municipal powers, judiciary and language duties.
Amazonas (AM)Deferred; no P02 local readingVerify AM local consumer services, councils, court/Defensoria and remote-language implementation.
Bahia (BA)Deferred; no P02 local readingVerify BA Procon, technical professions, municipality, judiciary and accessibility.
Ceará (CE)Deferred; no P02 local readingVerify CE consumer/Procon and councils, municipal and tribunal implementation.
Distrito Federal (DF)Deferred; no P02 local readingVerify DF consumer service, councils, TJDFT and accessibility rules.
Espírito Santo (ES)Deferred; no P02 local readingVerify ES councils, Procon, municipality, judicial mediation and accessible service.
Goiás (GO)Deferred; no P02 local readingVerify GO consumer/professional instruments, TJGO, municipality and language requirements.
Maranhão (MA)Deferred; no P02 local readingVerify MA Procon, professional and court materials, municipality and accessibility.
Mato Grosso (MT)Deferred; no P02 local readingVerify MT professional/service rules, Procon, TJMT and municipal scope.
Mato Grosso do Sul (MS)Deferred; no P02 local readingVerify MS Procon, councils, TJMS, border/remote and language issues.
Minas Gerais (MG)Deferred; no P02 local readingVerify MG Procon, CRA/CORECON, TJMG and target municipality.
Pará (PA)Deferred; no P02 local readingVerify PA local public consumer help, councils, TJPA and language issues.
Paraíba (PB)Deferred; no P02 local readingVerify PB consumer/professional instruments, TJPB and municipal service rules.
Paraná (PR)Deferred; no P02 local readingVerify PR Procon, councils, TJPR and municipal/accessibility obligations.
Pernambuco (PE)Deferred; no P02 local readingVerify PE consumer/professional materials, TJPE and municipality.
Piauí (PI)Deferred; no P02 local readingVerify PI councils, Procon, TJPI, municipal implementation and language.
Rio de Janeiro (RJ)Deferred; no P02 local readingVerify RJ Procon, relevant councils, TJRJ and municipal advertising/service rules.
Rio Grande do Norte (RN)Deferred; no P02 local readingVerify RN consumer/professional provisions, TJRN and municipality.
Rio Grande do Sul (RS)Deferred; no P02 local readingVerify RS Procon, councils, TJRS, municipality and accessible languages.
Rondônia (RO)Deferred; no P02 local readingVerify RO consumer/professional law, TJRO/Defensoria and municipality.
Roraima (RR)Deferred; no P02 local readingVerify RR councils/Procon, TJRR, municipal and multilingual rules.
Santa Catarina (SC)Deferred; no P02 local readingVerify SC consumer/professional instruments, TJSC and municipality.
São Paulo (SP)Deferred; P01 limited CORECON-SP/PROCON-SP guidance retained, not re-readComplete SP state provider/consumer laws, CRA, TJSP, relevant municipal Procon and accessibility review.
Sergipe (SE)Deferred; no P02 local readingVerify SE Procon, councils, TJSE, municipality and language/accessibility.
Tocantins (TO)Deferred; no P02 local readingVerify TO Procon/professional rules, TJTO/Defensoria, municipality and language.

Captured table 12

Original headerless table; first data row retained · 16 data rows

CheckActual result
Narrow scopeOnly current correspondentes no País rule-body and institution-versus-debtor-capacity question investigated.
Ordinary primary browsingUsed official search, opened BCB public vote PDFs and superseded norm PDF; no private systems or API calls.
Source count15 displayed S001–S015, each status-coded. Duplicate P01 provenance source explicitly labelled; not counted as fresh authority.
Material newly opened PDFsFive: BCB 2021 proposal; bank-hosted original reproduction; BCB 2025 proposal; BCB 2026 retrospective; BCB superseded 2011 norm.
Enacted official current 4.935 full bodyNot opened. Must not be certified from bank-hosted reproduction, draft or index.
Enacted official Joint17 full bodyNot opened. BCB 2026 retrospective supports repeal/commencement; exceptions/transition still held.
Official publication alternateTwo DOU HTML paths attempted, both HTTP 502; old failed P01 BCB dynamic/DOU PDF not retried.
Claim count26 displayed P02 claim rows C001–C026.
Narrow gateway count30 displayed P02-G01–G30 rows.
Deferred-family count22 displayed P02-D01–D22 rows.
Territorial count27 individually displayed, without fresh geography/API certification.
Hypothetical countFive H01–H05, no actual party, contract or outcome.
Numerical checkNo unsupported fee/savings/authorization calculation. Historical statutory dates distinguished from research dates.
Preserved P01Exact C021/G26/G27 wording and old failure status preserved; no full-country rerun or change to other P01 claims.
Coordinator statusUser-supplied selected-body scope acknowledged; no independent review claimed for P02.

Find the assertion and its boundaries

Read the evidence with its boundaries. These are saved research components, including revisions. A scoped coordinator review checks selected evidence; it does not certify every claim, a complete jurisdiction, current law or individual applicability. Dates and access limits remain attached to the records.

How to read the research →

Read the related correction supplements

These components repair their stated scope. They do not replace every other finding in this research series.

One bounded provenance-only repair to →
Bounded P13 payment-recipient qualification and source/claim/count traceability repair →
Bounded P14 atomic-predicate, commencement-traceability and count-unit repair →
C_BR-P02-C001 Saved research record

A098. Earlier correspondent rule 3.954’s relevant articles ceased operating from Feb1 2022 under 4.935. This removes the old text as a present-permission source.

Recorded check status: selected official historical or explanatory support with holds

Sources and pinpoints
S005 revocation notes across arts. 1–19, PDF indices 0–13.

Recorded coordinator check boundaries

coordinator review
Read against actual source status, all conditional examples and currentness/contract/payment holds. No enacted/current source upgrade or actual provider permission.
C_BR-P02-C002 Saved research record

A097. The July2021 proposed 4.935 arts. 1–3 conceived institutional contracting and direction, not stand-alone debtor advocacy; a draft alone is not enacted law.

Recorded check status: selected official historical or explanatory support with holds

Sources and pinpoints
S001 draft arts. 1–3, PDF 8–9.

Recorded coordinator check boundaries

coordinator review
Read against actual source status, all conditional examples and currentness/contract/payment holds. No enacted/current source upgrade or actual provider permission.
C_BR-P02-C003 Saved research record

A097. Historical reproduced 4.935 arts. 2–3 place correspondent services with the contracting authorized institution and under its directions/responsibility. Present exact wording remains held.

Recorded check status: historical reproduction or conditional inference not current clearance

Sources and pinpoints
S002 arts. 2–3, PDF 0–1; S006 index only.

Recorded coordinator check boundaries

coordinator review
Read against actual source status, all conditional examples and currentness/contract/payment holds. No enacted/current source upgrade or actual provider permission.
C_BR-P02-C004 Saved research record

A097. Original reproduced art. 4 lists classes of potential contractual correspondents, including sociedades, empresários e associações. It does not alone authorize any natural person or firm absent a contract.

Recorded check status: historical reproduction or conditional inference not current clearance

Sources and pinpoints
S002 art. 4, PDF 1; S001 draft, PDF 8–9.

Recorded coordinator check boundaries

coordinator review
Read against actual source status, all conditional examples and currentness/contract/payment holds. No enacted/current source upgrade or actual provider permission.
C_BR-P02-C005 Saved research record

A097. Historical art. 12 enumerates institution-product services, including account applications, institution-account transfers/payments and credit/leasing proposals, subject to actual contract. Current exact text held.

Recorded check status: historical reproduction or conditional inference not current clearance

Sources and pinpoints
S002 art. 12(I)–(VII), sole paragraph, PDF 3.

Recorded coordinator check boundaries

coordinator review
Read against actual source status, all conditional examples and currentness/contract/payment holds. No enacted/current source upgrade or actual provider permission.
C_BR-P02-C006 Saved research record

A097. Original art. 12(V) concerns receipt and forwarding of the contracting institution’s credit/leasing proposals and related operation-follow-up services, not independent approvals or unrelated creditor settlement.

Recorded check status: historical reproduction or conditional inference not current clearance

Sources and pinpoints
S002 art. 12(V), PDF 3; distinction partly inference.

Recorded coordinator check boundaries

coordinator review
Read against actual source status, all conditional examples and currentness/contract/payment holds. No enacted/current source upgrade or actual provider permission.
C_BR-P02-C007 Saved research record

A097. Reference to repactuação in historical art. 15 remuneration provisions cannot itself establish authority to represent a debtor in settlement of any credit.

Recorded check status: historical reproduction or conditional inference not current clearance

Sources and pinpoints
S002 arts. 12(V), 15 §2, PDF 3, 7–8; qualified interpretive inference.

Recorded coordinator check boundaries

coordinator review
Read against actual source status, all conditional examples and currentness/contract/payment holds. No enacted/current source upgrade or actual provider permission.
C_BR-P02-C008 Saved research record

A097. Historical arts. 10 and 14 distinguish contracted entity, limited approved subdelegation and formal staff relationship; current requirements need full official body.

Recorded check status: historical reproduction or conditional inference not current clearance

Sources and pinpoints
S002 arts. 10, 14(I), PDF 2, 4–5.

Recorded coordinator check boundaries

coordinator review
Read against actual source status, all conditional examples and currentness/contract/payment holds. No enacted/current source upgrade or actual provider permission.
C_BR-P02-C009 Saved research record

A097. Historical arts. 15–16 attach staff/platform technical qualification to credit/leasing activity, not to all budget advice.

Recorded check status: historical reproduction or conditional inference not current clearance

Sources and pinpoints
S002 arts. 15–16, PDF 7–9.

Recorded coordinator check boundaries

coordinator review
Read against actual source status, all conditional examples and currentness/contract/payment holds. No enacted/current source upgrade or actual provider permission.
C_BR-P02-C010 Saved research record

A097. Historical art. 14 requires disclosure of institution role/products and sets institution-contract controls on products and customer charges; these do not decide standalone debtor-consultancy fees.

Recorded check status: historical reproduction or conditional inference not current clearance

Sources and pinpoints
S002 art. 14(II)–(VII), PDF 5–6.

Recorded coordinator check boundaries

coordinator review
Read against actual source status, all conditional examples and currentness/contract/payment holds. No enacted/current source upgrade or actual provider permission.
C_BR-P02-C011 Saved research record

A097. Historical art. 18 requires contracting institution controls and remuneration policy; no creditor/customer settlement result follows.

Recorded check status: historical reproduction or conditional inference not current clearance

Sources and pinpoints
S002 art. 18, PDF 9–10.

Recorded coordinator check boundaries

coordinator review
Read against actual source status, all conditional examples and currentness/contract/payment holds. No enacted/current source upgrade or actual provider permission.
C_BR-P02-C012 Saved research record

A098. Historical arts. 21–23 describe institution correspondent-activity publication and regulator reporting, not proof an individual provider actually appears or has a current mandate.

Recorded check status: historical reproduction or conditional inference not current clearance

Sources and pinpoints
S002 arts. 21–23, PDF 11–12; S013 generic indexed guidance.

Recorded coordinator check boundaries

coordinator review
Read against actual source status, all conditional examples and currentness/contract/payment holds. No enacted/current source upgrade or actual provider permission.
C_BR-P02-C013 Saved research record

A098. BCB’s Feb2026 explanation establishes that Joint17 took effect Dec1 2025 and repealed CMN4935 art. 8. Prior-approval path under that old article cannot be stated as current.

Recorded check status: selected official historical or explanatory support with holds

Sources and pinpoints
S004 para. 7, PDF 1; S003 proposed art. 13, PDF 10 corroborative but not enacted.

Recorded coordinator check boundaries

coordinator review
Read against actual source status, all conditional examples and currentness/contract/payment holds. No enacted/current source upgrade or actual provider permission.
C_BR-P02-C014 Saved research record

A098. Competent BCB description says 2025 replacement restricts certain institution-style names/partnerships. Exact final test/exceptions/transitions not established.

Recorded check status: selected official historical or explanatory support with holds

Sources and pinpoints
S004 para. 7 PDF 1; S003 proposed art. 8 PDF 9.

Recorded coordinator check boundaries

coordinator review
Read against actual source status, all conditional examples and currentness/contract/payment holds. No enacted/current source upgrade or actual provider permission.
C_BR-P02-C015 Saved research record

A098. BCB’s proposed, not confirmed enacted, Joint17 art. 8 includes particular exceptions and a one-year pre-existing contract adjustment framework. No operative deadline or exception claim adopted here.

Recorded check status: selected official historical or explanatory support with holds

Sources and pinpoints
S003 draft art. 8 §§1–2, PDF 9.

Recorded coordinator check boundaries

coordinator review
Read against actual source status, all conditional examples and currentness/contract/payment holds. No enacted/current source upgrade or actual provider permission.
C_BR-P02-C016 Saved research record

A098. BCB current search index reports Dec1 2025 consolidated update but does not certify all operative 4.935 clauses.

Recorded check status: explicit discovery failure or remaining gap attribution preserved

Sources and pinpoints
S006 indexed heading; direct operative body failed in P01 S016.

Recorded coordinator check boundaries

coordinator review
Read against actual source status, all conditional examples and currentness/contract/payment holds. No enacted/current source upgrade or actual provider permission.
C_BR-P02-C017 Saved research record

A098. Historical effective Feb1 2022 is supported by reproduced original art. 26 and official 3.954 supersession annotations; original full DOU not opened.

Recorded check status: selected official historical or explanatory support with holds

Sources and pinpoints
S002 art. 26 PDF 13; S005 revocation notes; S008–S009 failed.

Recorded coordinator check boundaries

coordinator review
Read against actual source status, all conditional examples and currentness/contract/payment holds. No enacted/current source upgrade or actual provider permission.
C_BR-P02-C018 Saved research record

A097. On these historical institutional provisions, correspondent capacity is materially different from an independent debtor-paid mandato. Inference, not an exhaustive negative licence conclusion.

Recorded check status: historical reproduction or conditional inference not current clearance

Sources and pinpoints
S001 proposed arts. 2–3/12; S002 reproduction arts. 2–3/12; P01 C004–C008/C021.

Recorded coordinator check boundaries

coordinator review
Read against actual source status, all conditional examples and currentness/contract/payment holds. No enacted/current source upgrade or actual provider permission.
C_BR-P02-C019 Saved research record

A097. A mixed institution/borrower relationship needs distinct contract/compensation/conflict analysis; neither blanket permission nor blanket prohibition established.

Recorded check status: historical reproduction or conditional inference not current clearance

Sources and pinpoints
S002 arts. 3, 14, 18 historical; actual contracts absent.

Recorded coordinator check boundaries

coordinator review
Read against actual source status, all conditional examples and currentness/contract/payment holds. No enacted/current source upgrade or actual provider permission.
C_BR-P02-C020 Saved research record

A097. Referral website, correspondent platform, individual attendant and approved subcontractor have different possible roles; no one certificate or software label classifies all.

Recorded check status: historical reproduction or conditional inference not current clearance

Sources and pinpoints
S002 arts. 2, 10, 12, 14–16 historical; operative consolidation pending.

Recorded coordinator check boundaries

coordinator review
Read against actual source status, all conditional examples and currentness/contract/payment holds. No enacted/current source upgrade or actual provider permission.
C_BR-P02-C021 Saved research record

A097. A correspondent task involving institution-controlled transfers does not authorize borrower-savings custody or independent payment services by the correspondent.

Recorded check status: historical reproduction or conditional inference not current clearance

Sources and pinpoints
S002 art. 12(II)–(IV) historical; P01 S015/C016–C017/C022/C044 deferred.

Recorded coordinator check boundaries

coordinator review
Read against actual source status, all conditional examples and currentness/contract/payment holds. No enacted/current source upgrade or actual provider permission.
C_BR-P02-C022 Saved research record

A098. A general public correspondent list can identify entity/service relationships if appropriately checked, but no contract or individual record was supplied/searched.

Recorded check status: historical reproduction or conditional inference not current clearance

Sources and pinpoints
S013 indexed public guidance; S002 arts. 21–23 historical.

Recorded coordinator check boundaries

coordinator review
Read against actual source status, all conditional examples and currentness/contract/payment holds. No enacted/current source upgrade or actual provider permission.
C_BR-P02-C023 Saved research record

A098. Official DOU original body could not be read through either public HTML route; the 2021 bank-hosted text and draft are not an official current consolidation.

Recorded check status: explicit discovery failure or remaining gap attribution preserved

Sources and pinpoints
S001–S002, S008–S009; explicit access limitation.

Recorded coordinator check boundaries

coordinator review
Read against actual source status, all conditional examples and currentness/contract/payment holds. No enacted/current source upgrade or actual provider permission.
C_BR-P02-C024 Saved research record

A098. P01 C021 and G26/G27 can receive narrower historical/current amendment findings; current operative details and actual contracts remain missing.

Recorded check status: explicit discovery failure or remaining gap attribution preserved

Sources and pinpoints
C001–C023; P01 S016/S039, C021, G26–G27.

Recorded coordinator check boundaries

coordinator review
Read against actual source status, all conditional examples and currentness/contract/payment holds. No enacted/current source upgrade or actual provider permission.
C_BR-P02-C025 Saved research record

A098. The 2025 naming problem requires actual name, public presentation and institution contract; no brand/CNPJ/general “bank correspondent” badge grants permission.

Recorded check status: selected official historical or explanatory support with holds

Sources and pinpoints
S004 para. 7; S003 proposed art. 8; exact final text held.

Recorded coordinator check boundaries

coordinator review
Read against actual source status, all conditional examples and currentness/contract/payment holds. No enacted/current source upgrade or actual provider permission.
C_BR-P02-C026 Saved research record

A098. No numerical licence/resource/business-cost example is necessary or defensible for an unclassified provider; original reproduced charge/certification calculations not generalized.

Recorded check status: historical reproduction or conditional inference not current clearance

Sources and pinpoints
S002 arts. 14–16; current enacted text and actual contracts absent.

Recorded coordinator check boundaries

coordinator review
Read against actual source status, all conditional examples and currentness/contract/payment holds. No enacted/current source upgrade or actual provider permission.

Sources, pinpoints and access limits

Keep the source version, actual read extent and jurisdiction with the proposition. A link or researcher access claim is not a substitute for an operative primary passage.

C_BR-P02-S001 Saved research record

Banco Central/CMN, Voto do CMN 59/2021 with BCB Vote 160/2021, attached proposed Resolução CMN on correspondents. https://normativos.bcb.gov.br/Votos/CMN/202159/VOTO_DO_CMN_59_2021_BCB_SECRE_Numerado_Manualmente_01.pdf

Recorded check status: fresh selected official body with exact status limits

Exact section/page; version/publication/commencement; actual access and limit
READ-DRAFT. 39-page PDF; draft norm zero-based PDF 8–17, arts. 1–26, alongside impact assessment. Printed appended draft pages 1–10, embedded vote pagination differs. Proposal dated July 2021; not final enactment. Access Oct26 PDT/Oct27 UTC window above.
Direct source URLs
https://normativos.bcb.gov.br/Votos/CMN/202159/VOTO_DO_CMN_59_2021_BCB_SECRE_Numerado_Manualmente_01.pdf

Recorded coordinator check boundaries

coordinator check scope
Fresh selected official preparatory vote/draft arts1-4/10/12/15-16/21-23 at PDF8-16; NOT enacted or currently operative 4935. No equivalence to private reproduction certified.
C_BR-P02-S002 Saved research record

Banco Santander-hosted reproduction of Resolução CMN nº 4.935, de 29 de julho de 2021. https://cms.santander.com.br/sites/WPS/documentos/arq-resolucao/23-09-26_204507_resolucao_4935.pdf

Recorded check status: researcher attribution only not freshly verified

Exact section/page; version/publication/commencement; actual access and limit
READ-REPRO. 14-page PDF; relevant zero-based PDF indices 0–13, arts. 1–26, including arts. 2–4, 10–12, 14–16, 18, 21, 25–26. Original resolution dated July29 2021, art26 says effective Feb1 2022. Hosting filename date is not enactment/currentness. PDF contains historical art8 superseded in 2025; cannot be called 2026 consolidation. Access current P02 window.
Direct source URLs
https://cms.santander.com.br/sites/WPS/documentos/arq-resolucao/23-09-26_204507_resolucao_4935.pdf

Recorded coordinator check boundaries

coordinator check scope
Bank-hosted reproduced historical text remains researcher attribution; not primary issuer publication and not freshly certified by this review. Official draft comparison cannot turn it into enacted/current text.
C_BR-P02-S003 Saved research record

Banco Central/CMN, Voto do CMN 80/2025 including proposed Joint Resolution on authorized institutions’ names/public presentation. https://normativos.bcb.gov.br/Votos/CMN/202580/Voto_do_CMN_80_2025.pdf

Recorded check status: fresh selected official body with exact status limits

Exact section/page; version/publication/commencement; actual access and limit
READ-DRAFT. 11-page PDF; proposed resolution zero-based indices 7–10, proposed arts. 1–14, esp. 8 §§1–2, 13–14. Attached proposal dated November2025 and contains blank resolution number/date before adoption. Not final enacted transitional text. Access P02 window.
Direct source URLs
https://normativos.bcb.gov.br/Votos/CMN/202580/Voto_do_CMN_80_2025.pdf

Recorded coordinator check boundaries

coordinator check scope
Fresh official proposal art8 caput/paras1-2,13-14 at PDF9-10. Blank enactment number/date and proposed status preserved. One-year adjustment is PROPOSED only.
C_BR-P02-S004 Saved research record

Banco Central, Voto 17/2026–BCB, de 19 de fevereiro de 2026. https://normativos.bcb.gov.br/Votos/BCB/202617/Voto_do_BC_17_2026.pdf

Recorded check status: fresh selected official body with exact status limits

Exact section/page; version/publication/commencement; actual access and limit
READ-EXPL. 22-page PDF; explanatory para. 7, zero-based PDF 1, printed internal vote p. 2 of 3. Dated February19 2026; states Joint17 issued November28 2025, effective December1 2025, repealed CMN4935 art8 and describes new name restriction. The new 2026 draft later appended to the vote is not assumed enacted. Access P02 window.
Direct source URLs
https://normativos.bcb.gov.br/Votos/BCB/202617/Voto_do_BC_17_2026.pdf

Recorded coordinator check boundaries

coordinator check scope
Fresh official explanatory vote para7 PDF1, internalprinted2of3: Dec1 2025 commencement/art8 repeal and described replacement naming restriction. NOT full enacted Joint17 or later consolidation.
C_BR-P02-S005 Saved research record

Banco Central, official consolidated presentation of superseded Resolução nº 3.954, de 24 de fevereiro de 2011. https://normativos.bcb.gov.br/Lists/Normativos/Attachments/49450/Res_3954_v12_P.pdf

Recorded check status: fresh selected official body with exact status limits

Exact section/page; version/publication/commencement; actual access and limit
READ-HIST. 15-page PDF, zero-based indices 0–14, arts. 1–19 and related revocation annotations. Relevant marks across indices 0–13: replaced/revoked from February1 2022 by 4.935. Printed PDF “Página 1 de 15” onward aligned to zero-based index +1. Historical text is not current correspondent authorization. Access P02 window.
Direct source URLs
https://normativos.bcb.gov.br/Lists/Normativos/Attachments/49450/Res_3954_v12_P.pdf

Recorded coordinator check boundaries

coordinator check scope
Fresh selected historical official PDF heading and arts1-3/19/21/23 revocation annotations. Pertinent provisions revoked Feb1 2022; heading separately notes later whole-document BCB277 revocation. No universal claim every provision died under4935.
C_BR-P02-S006 Saved research record

Banco Central normative public interface, Resolução CMN 4.935/2021 — versão vigente. https://www.bcb.gov.br/estabilidadefinanceira/exibenormativo?numero=4935&tipo=RESOLU%C3%87%C3%83O+CMN

Recorded check status: researcher attribution only not freshly verified

Exact section/page; version/publication/commencement; actual access and limit
INDEX/REUSE. Current search index encountered in P02 shows update December1 2025 and excerpts arts. 1–4, 12, 14. P01 S016 attempted the live body and failed; not retried here. No page/index applicable and no full 2026 body read.
Direct source URLs
https://www.bcb.gov.br/estabilidadefinanceira/exibenormativo?numero=4935&tipo=RESOLU%C3%87%C3%83O+CMN

Recorded coordinator check boundaries

coordinator check scope
Preserve literal indexed/failed/reused status. No repeated failed fetch, no named register query, no API. No source body or currentness upgrade.
C_BR-P02-S007 Saved research record

Banco Central normative public interface, Resolução Conjunta 17/2025. https://www.bcb.gov.br/estabilidadefinanceira/exibenormativo?numero=17&tipo=Resolu%C3%A7%C3%A3o+Conjunta

Recorded check status: researcher attribution only not freshly verified

Exact section/page; version/publication/commencement; actual access and limit
INDEX. Official indexed 2025 norm and repeal of 4.935 art8, not directly opened full. Its indexed posting/currentness text is not an actual read of exceptions or operative transition. Access P02 window as search result.
Direct source URLs
https://www.bcb.gov.br/estabilidadefinanceira/exibenormativo?numero=17&tipo=Resolu%C3%A7%C3%A3o+Conjunta

Recorded coordinator check boundaries

coordinator check scope
Preserve literal indexed/failed/reused status. No repeated failed fetch, no named register query, no API. No source body or currentness upgrade.
C_BR-P02-S008 Saved research record

Imprensa Nacional, DOU HTML publication candidate for original CMN4935. https://www.in.gov.br/web/dou/-/resolucao-cmn-n-4.935-de-29-de-julho-de-2021-335456670

Recorded check status: researcher attribution only not freshly verified

Exact section/page; version/publication/commencement; actual access and limit
FAILED. Direct opening returned HTTP 502, no article text; candidate for original August2 2021 DOU, no page index. Access P02 window.
Direct source URLs
https://www.in.gov.br/web/dou/-/resolucao-cmn-n-4.935-de-29-de-julho-de-2021-335456670

Recorded coordinator check boundaries

coordinator check scope
Preserve literal indexed/failed/reused status. No repeated failed fetch, no named register query, no API. No source body or currentness upgrade.
C_BR-P02-S009 Saved research record

Imprensa Nacional, alternate DOU English-route HTML publication candidate. https://www.in.gov.br/en/web/dou/-/resolucao-cmn-n-4.935-de-29-de-julho-de-2021-335456670

Recorded check status: researcher attribution only not freshly verified

Exact section/page; version/publication/commencement; actual access and limit
FAILED. HTTP 502; no body read, same historical publication candidate through a different path. Access P02 window.
Direct source URLs
https://www.in.gov.br/en/web/dou/-/resolucao-cmn-n-4.935-de-29-de-julho-de-2021-335456670

Recorded coordinator check boundaries

coordinator check scope
Preserve literal indexed/failed/reused status. No repeated failed fetch, no named register query, no API. No source body or currentness upgrade.
C_BR-P02-S010 Saved research record

Banco Central, public July2021 CMN communication. https://www.bcb.gov.br/detalhenoticia/17457/nota

Recorded check status: researcher attribution only not freshly verified

Exact section/page; version/publication/commencement; actual access and limit
INDEX/FAILED BODY. Indexed official description says original norm would enter in February2022 and includes platform/staff discussion; direct open returned a one-line body. Used only as historical discovery corroboration, not operative articles.
Direct source URLs
https://www.bcb.gov.br/detalhenoticia/17457/nota

Recorded coordinator check boundaries

coordinator check scope
Preserve literal indexed/failed/reused status. No repeated failed fetch, no named register query, no API. No source body or currentness upgrade.
C_BR-P02-S011 Saved research record

Presidência, Lei 4.595/1964 financial-institution statute, compiled. https://planalto.gov.br/ccivil_03/leis/l4595compilado.htm

Recorded check status: precisely dated same coordinator selected reuse

Exact section/page; version/publication/commencement; actual access and limit
REUSE P01 S014, arts. 17–18, user-supplied dated P01 row and coordinator’s selected fresh read; not reopened in P02. Establishes upper-level category only.
Direct source URLs
https://planalto.gov.br/ccivil_03/leis/l4595compilado.htm

Recorded coordinator check boundaries

coordinator check scope
Precisely dated SAME-coordinator P01 selected review at2026-10-27T01:05:59.436883Z; S01417-18 or S0156/9/10 only, not complete implementing/currentness review.
C_BR-P02-S012 Saved research record

Presidência, Lei 12.865/2013 payment services statute. https://www.planalto.gov.br/ccivil_03/_ato2011-2014/2013/lei/l12865.htm

Recorded check status: precisely dated same coordinator selected reuse

Exact section/page; version/publication/commencement; actual access and limit
REUSE P01 S015, arts. 6 and 9/10 selected in coordinator scope; not reopened in P02. Does not answer current payment-institution exemptions.
Direct source URLs
https://www.planalto.gov.br/ccivil_03/_ato2011-2014/2013/lei/l12865.htm

Recorded coordinator check boundaries

coordinator check scope
Precisely dated SAME-coordinator P01 selected review at2026-10-27T01:05:59.436883Z; S01417-18 or S0156/9/10 only, not complete implementing/currentness review.
C_BR-P02-S013 Saved research record

Banco Central, generic Correspondentes no País guidance. https://www.bcb.gov.br/estabilidadefinanceira/correspondentes_pais

Recorded check status: researcher attribution only not freshly verified

Exact section/page; version/publication/commencement; actual access and limit
INDEX/REUSE P01 S036. P02 found indexed generic information on institution/municipality/service files; no named record, no fresh successful body opening; no actual-contract verification.
Direct source URLs
https://www.bcb.gov.br/estabilidadefinanceira/correspondentes_pais

Recorded coordinator check boundaries

coordinator check scope
Preserve literal indexed/failed/reused status. No repeated failed fetch, no named register query, no API. No source body or currentness upgrade.
C_BR-P02-S014 Saved research record

Banco Central normative interface, historical P01 source S016 (same CMN4935 interface). https://www.bcb.gov.br/estabilidadefinanceira/exibenormativo?numero=4935&tipo=RESOLU%C3%87%C3%83O+CMN

Recorded check status: researcher attribution only not freshly verified

Exact section/page; version/publication/commencement; actual access and limit
REUSE of failure history, not another source proof: P01 dynamic full body inaccessible; no new opening attempted. Listed separately solely to preserve exact original provenance.
Direct source URLs
https://www.bcb.gov.br/estabilidadefinanceira/exibenormativo?numero=4935&tipo=RESOLU%C3%87%C3%83O+CMN

Recorded coordinator check boundaries

coordinator check scope
Preserve literal indexed/failed/reused status. No repeated failed fetch, no named register query, no API. No source body or currentness upgrade.
C_BR-P02-S015 Saved research record

Imprensa Nacional, P01 original DOU PDF viewer. https://pesquisa.in.gov.br/imprensa/servlet/INPDFViewer?captchafield=firstAccess&data=02%2F08%2F2021&jornal=515&pagina=23

Recorded check status: researcher attribution only not freshly verified

Exact section/page; version/publication/commencement; actual access and limit
REUSE P01 S039 prior failure, not retried. Original DOU printed page 23 as reported by indexed metadata; zero-based PDF index not established, underlying pages not read.
Direct source URLs
https://pesquisa.in.gov.br/imprensa/servlet/INPDFViewer?captchafield=firstAccess&data=02%2F08%2F2021&jornal=515&pagina=23

Recorded coordinator check boundaries

coordinator check scope
Preserve literal indexed/failed/reused status. No repeated failed fetch, no named register query, no API. No source body or currentness upgrade.

What was examined—and what is still missing

The saved component-level coverage record keeps answered, partial, blank and unresolved branches distinct. A coverage label is not acceptance of a whole subject or jurisdiction.

coverage-1 Saved research record

P02-G01 Original 3.954 currentness

Recorded check status: recorded; no individual primary acceptance inferred

#
P02-G01
Question or subissue
Original 3.954 currentness
P02 finding/claims
C001
Status and exact next action
Historical revocation supported; use S005, do not reuse 3.954 as present rule.

Recorded coordinator check boundaries

coordinator acceptance
scoped_historical_or_partial_finding_with_explicit_holds
coordinator review
Actual original cell and next action retained; neither source/contract/local nor country acceptance.
coverage-2 Saved research record

P02-G02 Original 4.935 rule text

Recorded check status: recorded; no individual primary acceptance inferred

#
P02-G02
Question or subissue
Original 4.935 rule text
P02 finding/claims
C002–C003, C017
Status and exact next action
Partial; obtain official published enacted 2021 body independent of draft/private reproduction.

Recorded coordinator check boundaries

coordinator acceptance
scoped_historical_or_partial_finding_with_explicit_holds
coordinator review
Actual original cell and next action retained; neither source/contract/local nor country acceptance.
coverage-3 Saved research record

P02-G03 Original commencement

Recorded check status: recorded; no individual primary acceptance inferred

#
P02-G03
Question or subissue
Original commencement
P02 finding/claims
C001, C017
Status and exact next action
Feb1 2022 supported by historical official annotations; verify final DOU when accessible.

Recorded coordinator check boundaries

coordinator acceptance
scoped_historical_or_partial_finding_with_explicit_holds
coordinator review
Actual original cell and next action retained; neither source/contract/local nor country acceptance.
coverage-4 Saved research record

P02-G04 2025 article 8 repeal

Recorded check status: recorded; no individual primary acceptance inferred

#
P02-G04
Question or subissue
2025 article 8 repeal
P02 finding/claims
C013
Status and exact next action
Supported by official BCB retrospective, not full enacted amendment; reopen Joint17 full text.

Recorded coordinator check boundaries

coordinator acceptance
scoped_historical_or_partial_finding_with_explicit_holds
coordinator review
Actual original cell and next action retained; neither source/contract/local nor country acceptance.
coverage-5 Saved research record

P02-G05 2025 replacement naming restriction

Recorded check status: recorded; no individual primary acceptance inferred

#
P02-G05
Question or subissue
2025 replacement naming restriction
P02 finding/claims
C014–C015, C025
Status and exact next action
Partial; read actual Joint17 art8, exceptions, transition, effective effect.

Recorded coordinator check boundaries

coordinator acceptance
scoped_historical_or_partial_finding_with_explicit_holds
coordinator review
Actual original cell and next action retained; neither source/contract/local nor country acceptance.
coverage-6 Saved research record

P02-G06 Post-Dec2025 current consolidated 4.935

Recorded check status: recorded; no individual primary acceptance inferred

#
P02-G06
Question or subissue
Post-Dec2025 current consolidated 4.935
P02 finding/claims
C016, C023
Status and exact next action
Pending operative body; obtain genuinely readable official consolidation and check each relevant article.

Recorded coordinator check boundaries

coordinator acceptance
scoped_historical_or_partial_finding_with_explicit_holds
coordinator review
Actual original cell and next action retained; neither source/contract/local nor country acceptance.
coverage-7 Saved research record

P02-G07 Post-Dec2025/2026 later changes

Recorded check status: recorded; no individual primary acceptance inferred

#
P02-G07
Question or subissue
Post-Dec2025/2026 later changes
P02 finding/claims
C016
Status and exact next action
Unknown; compare later official CMN/BCB amendment index and full enacted acts.

Recorded coordinator check boundaries

coordinator acceptance
scoped_historical_or_partial_finding_with_explicit_holds
coordinator review
Actual original cell and next action retained; neither source/contract/local nor country acceptance.
coverage-8 Saved research record

P02-G08 Authorized contracting institution

Recorded check status: recorded; no individual primary acceptance inferred

#
P02-G08
Question or subissue
Authorized contracting institution
P02 finding/claims
C003
Status and exact next action
Historical institution-side rule; verify BCB institution class, actual current contract and tasks.

Recorded coordinator check boundaries

coordinator acceptance
scoped_historical_or_partial_finding_with_explicit_holds
coordinator review
Actual original cell and next action retained; neither source/contract/local nor country acceptance.
coverage-9 Saved research record

P02-G09 Potential correspondent legal form

Recorded check status: recorded; no individual primary acceptance inferred

#
P02-G09
Question or subissue
Potential correspondent legal form
P02 finding/claims
C004
Status and exact next action
Historical classes read; inspect actual contracting entity and current art4.

Recorded coordinator check boundaries

coordinator acceptance
scoped_historical_or_partial_finding_with_explicit_holds
coordinator review
Actual original cell and next action retained; neither source/contract/local nor country acceptance.
coverage-10 Saved research record

P02-G10 Individual natural-person contractor versus employee

Recorded check status: recorded; no individual primary acceptance inferred

#
P02-G10
Question or subissue
Individual natural-person contractor versus employee
P02 finding/claims
C004, C008–C009
Status and exact next action
Conditional; examine legal form, individual role and current norm; do not infer solo private-person eligibility.

Recorded coordinator check boundaries

coordinator acceptance
scoped_historical_or_partial_finding_with_explicit_holds
coordinator review
Actual original cell and next action retained; neither source/contract/local nor country acceptance.
coverage-11 Saved research record

P02-G11 Representative and staff

Recorded check status: recorded; no individual primary acceptance inferred

#
P02-G11
Question or subissue
Representative and staff
P02 finding/claims
C008–C009
Status and exact next action
Conditional; obtain formal team relationship/qualifications and current arts14–16.

Recorded coordinator check boundaries

coordinator acceptance
scoped_historical_or_partial_finding_with_explicit_holds
coordinator review
Actual original cell and next action retained; neither source/contract/local nor country acceptance.
coverage-12 Saved research record

P02-G12 Substabelecimento/subcontractor

Recorded check status: recorded; no individual primary acceptance inferred

#
P02-G12
Question or subissue
Substabelecimento/subcontractor
P02 finding/claims
C008, C020
Status and exact next action
Conditional; inspect actual contract permission, institution consent and current limitations.

Recorded coordinator check boundaries

coordinator acceptance
scoped_historical_or_partial_finding_with_explicit_holds
coordinator review
Actual original cell and next action retained; neither source/contract/local nor country acceptance.
coverage-13 Saved research record

P02-G13 Electronic platform

Recorded check status: recorded; no individual primary acceptance inferred

#
P02-G13
Question or subissue
Electronic platform
P02 finding/claims
C020
Status and exact next action
Conditional; map app features, operator, responsible person and current rule.

Recorded coordinator check boundaries

coordinator acceptance
scoped_historical_or_partial_finding_with_explicit_holds
coordinator review
Actual original cell and next action retained; neither source/contract/local nor country acceptance.
coverage-14 Saved research record

P02-G14 Original art12 service list

Recorded check status: recorded; no individual primary acceptance inferred

#
P02-G14
Question or subissue
Original art12 service list
P02 finding/claims
C005
Status and exact next action
Historical categories read; reopen current enacted art12 before claiming present permission.

Recorded coordinator check boundaries

coordinator acceptance
scoped_historical_or_partial_finding_with_explicit_holds
coordinator review
Actual original cell and next action retained; neither source/contract/local nor country acceptance.
coverage-15 Saved research record

P02-G15 Credit-proposal receipt/forwarding

Recorded check status: recorded; no individual primary acceptance inferred

#
P02-G15
Question or subissue
Credit-proposal receipt/forwarding
P02 finding/claims
C006
Status and exact next action
Original institution-side operation explained; verify product, institution, contract and current text.

Recorded coordinator check boundaries

coordinator acceptance
scoped_historical_or_partial_finding_with_explicit_holds
coordinator review
Actual original cell and next action retained; neither source/contract/local nor country acceptance.
coverage-16 Saved research record

P02-G16 Approval decision and rates

Recorded check status: recorded; no individual primary acceptance inferred

#
P02-G16
Question or subissue
Approval decision and rates
P02 finding/claims
C003, C006, C010
Status and exact next action
No independent approval power concluded; inspect actual institution workflow, delegated rights and current clauses.

Recorded coordinator check boundaries

coordinator acceptance
scoped_historical_or_partial_finding_with_explicit_holds
coordinator review
Actual original cell and next action retained; neither source/contract/local nor country acceptance.
coverage-17 Saved research record

P02-G17 Credit renegotiation/repactuação

Recorded check status: recorded; no individual primary acceptance inferred

#
P02-G17
Question or subissue
Credit renegotiation/repactuação
P02 finding/claims
C007
Status and exact next action
No universal settlement authorization; locate actual contracted credit service and current art12/15.

Recorded coordinator check boundaries

coordinator acceptance
scoped_historical_or_partial_finding_with_explicit_holds
coordinator review
Actual original cell and next action retained; neither source/contract/local nor country acceptance.
coverage-18 Saved research record

P02-G18 Collector/servicer tasks

Recorded check status: recorded; no individual primary acceptance inferred

#
P02-G18
Question or subissue
Collector/servicer tasks
P02 finding/claims
C005–C007
Status and exact next action
No general collection licence derived; inspect creditor contract and applicable separate rules.

Recorded coordinator check boundaries

coordinator acceptance
scoped_historical_or_partial_finding_with_explicit_holds
coordinator review
Actual original cell and next action retained; neither source/contract/local nor country acceptance.
coverage-19 Saved research record

P02-G19 Independent debtor-paid adviser

Recorded check status: recorded; no individual primary acceptance inferred

#
P02-G19
Question or subissue
Independent debtor-paid adviser
P02 finding/claims
C018
Status and exact next action
Different principal and role; obtain debtor contract, mandate, tasks and reserved-work review.

Recorded coordinator check boundaries

coordinator acceptance
scoped_historical_or_partial_finding_with_explicit_holds
coordinator review
Actual original cell and next action retained; neither source/contract/local nor country acceptance.
coverage-20 Saved research record

P02-G20 Mixed/conflicted roles

Recorded check status: recorded; no individual primary acceptance inferred

#
P02-G20
Question or subissue
Mixed/conflicted roles
P02 finding/claims
C019
Status and exact next action
Conditional; read real dual agreements, payments, disclosures and current rules before any approval.

Recorded coordinator check boundaries

coordinator acceptance
scoped_historical_or_partial_finding_with_explicit_holds
coordinator review
Actual original cell and next action retained; neither source/contract/local nor country acceptance.
coverage-21 Saved research record

P02-G21 Institutional correspondent remuneration

Recorded check status: recorded; no individual primary acceptance inferred

#
P02-G21
Question or subissue
Institutional correspondent remuneration
P02 finding/claims
C010–C011
Status and exact next action
Historical rule identified; obtain current text and institution contract; no universal fee conclusion.

Recorded coordinator check boundaries

coordinator acceptance
scoped_historical_or_partial_finding_with_explicit_holds
coordinator review
Actual original cell and next action retained; neither source/contract/local nor country acceptance.
coverage-22 Saved research record

P02-G22 Independent debtor fee/refund

Recorded check status: recorded; no individual primary acceptance inferred

#
P02-G22
Question or subissue
Independent debtor fee/refund
P02 finding/claims
C010, C018
Status and exact next action
Deferred consumer/contract law; no fee entitlement or refund rule concluded.

Recorded coordinator check boundaries

coordinator acceptance
scoped_historical_or_partial_finding_with_explicit_holds
coordinator review
Actual original cell and next action retained; neither source/contract/local nor country acceptance.
coverage-23 Saved research record

P02-G23 Branding and disclosure

Recorded check status: recorded; no individual primary acceptance inferred

#
P02-G23
Question or subissue
Branding and disclosure
P02 finding/claims
C010, C014–C015, C025
Status and exact next action
Current 2025 restriction material; official enacted article/exceptions/transitions not read.

Recorded coordinator check boundaries

coordinator acceptance
scoped_historical_or_partial_finding_with_explicit_holds
coordinator review
Actual original cell and next action retained; neither source/contract/local nor country acceptance.
coverage-24 Saved research record

P02-G24 Qualification/certification

Recorded check status: recorded; no individual primary acceptance inferred

#
P02-G24
Question or subissue
Qualification/certification
P02 finding/claims
C009, C020
Status and exact next action
Historical credit-function-specific requirements; verify current art16 and actual role; no universal certificate.

Recorded coordinator check boundaries

coordinator acceptance
scoped_historical_or_partial_finding_with_explicit_holds
coordinator review
Actual original cell and next action retained; neither source/contract/local nor country acceptance.
coverage-25 Saved research record

P02-G25 Institution-account transaction versus client-money holding

Recorded check status: recorded; no individual primary acceptance inferred

#
P02-G25
Question or subissue
Institution-account transaction versus client-money holding
P02 finding/claims
C005, C021
Status and exact next action
Separate payment rule unresolved; map funds and defer BCB494.

Recorded coordinator check boundaries

coordinator acceptance
scoped_historical_or_partial_finding_with_explicit_holds
coordinator review
Actual original cell and next action retained; neither source/contract/local nor country acceptance.
coverage-26 Saved research record

P02-G26 Generic correspondent register/category verification

Recorded check status: recorded; no individual primary acceptance inferred

#
P02-G26
Question or subissue
Generic correspondent register/category verification
P02 finding/claims
C012, C022
Status and exact next action
No named entries/contract checked; use only official generic method if later authorized.

Recorded coordinator check boundaries

coordinator acceptance
scoped_historical_or_partial_finding_with_explicit_holds
coordinator review
Actual original cell and next action retained; neither source/contract/local nor country acceptance.
coverage-27 Saved research record

P02-G27 Four required hypothetical classifications

Recorded check status: recorded; no individual primary acceptance inferred

#
P02-G27
Question or subissue
Four required hypothetical classifications
P02 finding/claims
H01–H04; C003–C020
Status and exact next action
Five supplied including H05 money-flow boundary; no actual provider assessment.

Recorded coordinator check boundaries

coordinator acceptance
scoped_historical_or_partial_finding_with_explicit_holds
coordinator review
Actual original cell and next action retained; neither source/contract/local nor country acceptance.
coverage-28 Saved research record

P02-G28 P01 C021/G26/G27 disposition

Recorded check status: recorded; no individual primary acceptance inferred

#
P02-G28
Question or subissue
P01 C021/G26/G27 disposition
P02 finding/claims
C024
Status and exact next action
Partially augmented, held; no original claim replaced.

Recorded coordinator check boundaries

coordinator acceptance
scoped_historical_or_partial_finding_with_explicit_holds
coordinator review
Actual original cell and next action retained; neither source/contract/local nor country acceptance.
coverage-29 Saved research record

P02-G29 Numerical conditions

Recorded check status: recorded; no individual primary acceptance inferred

#
P02-G29
Question or subissue
Numerical conditions
P02 finding/claims
C026
Status and exact next action
No needed defensible current calculation; no invented licence/fee/savings arithmetic.

Recorded coordinator check boundaries

coordinator acceptance
scoped_historical_or_partial_finding_with_explicit_holds
coordinator review
Actual original cell and next action retained; neither source/contract/local nor country acceptance.
coverage-30 Saved research record

P02-G30 Narrow-country/publication acceptance

Recorded check status: recorded; no individual primary acceptance inferred

#
P02-G30
Question or subissue
Narrow-country/publication acceptance
P02 finding/claims
C016, C018, C023–C026
Status and exact next action
HOLD; actual current enacted texts, institutional contract and separate review remain prerequisites.

Recorded coordinator check boundaries

coordinator acceptance
scoped_historical_or_partial_finding_with_explicit_holds
coordinator review
Actual original cell and next action retained; neither source/contract/local nor country acceptance.
coverage-31 Saved research record

P02-D01 BCB Resolution 494 current payment rules

Recorded check status: recorded; no individual primary acceptance inferred

#
P02-D01
Deferred family
BCB Resolution 494 current payment rules
Why excluded from PASS-02; exact next action
P01 C022 remains pending. Reopen enacted current payment authorization texts in separate work.

Recorded coordinator check boundaries

coordinator acceptance
deferred_no_substantive_completion
coordinator review
Actual original cell and next action retained; neither source/contract/local nor country acceptance.
coverage-32 Saved research record

P02-D02 Payment-institution categorization

Recorded check status: recorded; no individual primary acceptance inferred

#
P02-D02
Deferred family
Payment-institution categorization
Why excluded from PASS-02; exact next action
Read specific operative BCB institution categories and exceptions with actual features/funds.

Recorded coordinator check boundaries

coordinator acceptance
deferred_no_substantive_completion
coordinator review
Actual original cell and next action retained; neither source/contract/local nor country acceptance.
coverage-33 Saved research record

P02-D03 Client-funds title, custody, safeguarding and execution

Recorded check status: recorded; no individual primary acceptance inferred

#
P02-D03
Deferred family
Client-funds title, custody, safeguarding and execution
Why excluded from PASS-02; exact next action
Obtain legal owner/processor/transaction trail and then apply full current rules.

Recorded coordinator check boundaries

coordinator acceptance
deferred_no_substantive_completion
coordinator review
Actual original cell and next action retained; neither source/contract/local nor country acceptance.
coverage-34 Saved research record

P02-D04 AML/COAF obligations

Recorded check status: recorded; no individual primary acceptance inferred

#
P02-D04
Deferred family
AML/COAF obligations
Why excluded from PASS-02; exact next action
Separately characterize activities and current controlling AML sector instruments; P01 findings not revisited.

Recorded coordinator check boundaries

coordinator acceptance
deferred_no_substantive_completion
coordinator review
Actual original cell and next action retained; neither source/contract/local nor country acceptance.
coverage-35 Saved research record

P02-D05 OAB legal advice and court representation

Recorded check status: recorded; no individual primary acceptance inferred

#
P02-D05
Deferred family
OAB legal advice and court representation
Why excluded from PASS-02; exact next action
Apply P01 reserved-work gateways to actual scripts if supplied; no new professional review here.

Recorded coordinator check boundaries

coordinator acceptance
deferred_no_substantive_completion
coordinator review
Actual original cell and next action retained; neither source/contract/local nor country acceptance.
coverage-36 Saved research record

P02-D06 CRA professional administration

Recorded check status: recorded; no individual primary acceptance inferred

#
P02-D06
Deferred family
CRA professional administration
Why excluded from PASS-02; exact next action
Test substantive technical work and regional interpretation in later review.

Recorded coordinator check boundaries

coordinator acceptance
deferred_no_substantive_completion
coordinator review
Actual original cell and next action retained; neither source/contract/local nor country acceptance.
coverage-37 Saved research record

P02-D07 CORECON technical financial consultancy

Recorded check status: recorded; no individual primary acceptance inferred

#
P02-D07
Deferred family
CORECON technical financial consultancy
Why excluded from PASS-02; exact next action
Test atividade básica and regional registration only against actual service.

Recorded coordinator check boundaries

coordinator acceptance
deferred_no_substantive_completion
coordinator review
Actual original cell and next action retained; neither source/contract/local nor country acceptance.
coverage-38 Saved research record

P02-D08 Consumer fee earning, ceilings, timing and refunds

Recorded check status: recorded; no individual primary acceptance inferred

#
P02-D08
Deferred family
Consumer fee earning, ceilings, timing and refunds
Why excluded from PASS-02; exact next action
Review actual engagement/consumer rules; no implication from correspondent compensation terms.

Recorded coordinator check boundaries

coordinator acceptance
deferred_no_substantive_completion
coordinator review
Actual original cell and next action retained; neither source/contract/local nor country acceptance.
coverage-39 Saved research record

P02-D09 Independent consumer engagement contracts/disclosures

Recorded check status: recorded; no individual primary acceptance inferred

#
P02-D09
Deferred family
Independent consumer engagement contracts/disclosures
Why excluded from PASS-02; exact next action
Review actual offer and contract across CDC, professional rules and local law.

Recorded coordinator check boundaries

coordinator acceptance
deferred_no_substantive_completion
coordinator review
Actual original cell and next action retained; neither source/contract/local nor country acceptance.
coverage-40 Saved research record

P02-D10 Full CDC superendividamento and repactuação

Recorded check status: recorded; no individual primary acceptance inferred

#
P02-D10
Deferred family
Full CDC superendividamento and repactuação
Why excluded from PASS-02; exact next action
No change to P01 gateway; comprehensive eligibility/process requires separate review.

Recorded coordinator check boundaries

coordinator acceptance
deferred_no_substantive_completion
coordinator review
Actual original cell and next action retained; neither source/contract/local nor country acceptance.
coverage-41 Saved research record

P02-D11 STF operative dispositive

Recorded check status: recorded; no individual primary acceptance inferred

#
P02-D11
Deferred family
STF operative dispositive
Why excluded from PASS-02; exact next action
Obtain full 2026 acórdão, effects and subsequent compliance, not a correspondent issue.

Recorded coordinator check boundaries

coordinator acceptance
deferred_no_substantive_completion
coordinator review
Actual original cell and next action retained; neither source/contract/local nor country acceptance.
coverage-42 Saved research record

P02-D12 CMN mínimo existencial rule/current amount

Recorded check status: recorded; no individual primary acceptance inferred

#
P02-D12
Deferred family
CMN mínimo existencial rule/current amount
Why excluded from PASS-02; exact next action
Separate currentness and protected-income review; unrelated to correspondent authorization.

Recorded coordinator check boundaries

coordinator acceptance
deferred_no_substantive_completion
coordinator review
Actual original cell and next action retained; neither source/contract/local nor country acceptance.
coverage-43 Saved research record

P02-D13 Debt products and lending eligibility

Recorded check status: recorded; no individual primary acceptance inferred

#
P02-D13
Deferred family
Debt products and lending eligibility
Why excluded from PASS-02; exact next action
Each loan/security/credit product needs its own BCB and contract rules.

Recorded coordinator check boundaries

coordinator acceptance
deferred_no_substantive_completion
coordinator review
Actual original cell and next action retained; neither source/contract/local nor country acceptance.
coverage-44 Saved research record

P02-D14 Security, guaranties and collateral

Recorded check status: recorded; no individual primary acceptance inferred

#
P02-D14
Deferred family
Security, guaranties and collateral
Why excluded from PASS-02; exact next action
Review obligor/security-specific law; no transfer from correspondent contract.

Recorded coordinator check boundaries

coordinator acceptance
deferred_no_substantive_completion
coordinator review
Actual original cell and next action retained; neither source/contract/local nor country acceptance.
coverage-45 Saved research record

P02-D15 Collection conduct and authority

Recorded check status: recorded; no individual primary acceptance inferred

#
P02-D15
Deferred family
Collection conduct and authority
Why excluded from PASS-02; exact next action
Separate creditor-agent appointment, CDC communications and sanctions review.

Recorded coordinator check boundaries

coordinator acceptance
deferred_no_substantive_completion
coordinator review
Actual original cell and next action retained; neither source/contract/local nor country acceptance.
coverage-46 Saved research record

P02-D16 Credit reporting/correction

Recorded check status: recorded; no individual primary acceptance inferred

#
P02-D16
Deferred family
Credit reporting/correction
Why excluded from PASS-02; exact next action
Separate CDC/LGPD/bureau authorities.

Recorded coordinator check boundaries

coordinator acceptance
deferred_no_substantive_completion
coordinator review
Actual original cell and next action retained; neither source/contract/local nor country acceptance.
coverage-47 Saved research record

P02-D17 Prescription, accrual and interruption

Recorded check status: recorded; no individual primary acceptance inferred

#
P02-D17
Deferred family
Prescription, accrual and interruption
Why excluded from PASS-02; exact next action
Separate obligation-specific Civil Code/court analysis.

Recorded coordinator check boundaries

coordinator acceptance
deferred_no_substantive_completion
coordinator review
Actual original cell and next action retained; neither source/contract/local nor country acceptance.
coverage-48 Saved research record

P02-D18 Tax

Recorded check status: recorded; no individual primary acceptance inferred

#
P02-D18
Deferred family
Tax
Why excluded from PASS-02; exact next action
Review actual provider/customer/tax transaction only after facts.

Recorded coordinator check boundaries

coordinator acceptance
deferred_no_substantive_completion
coordinator review
Actual original cell and next action retained; neither source/contract/local nor country acceptance.
coverage-49 Saved research record

P02-D19 Courts, judgments, execution and mediation

Recorded check status: recorded; no individual primary acceptance inferred

#
P02-D19
Deferred family
Courts, judgments, execution and mediation
Why excluded from PASS-02; exact next action
Separate OAB/CPC/court appointment and remedies analysis.

Recorded coordinator check boundaries

coordinator acceptance
deferred_no_substantive_completion
coordinator review
Actual original cell and next action retained; neither source/contract/local nor country acceptance.
coverage-50 Saved research record

P02-D20 State/DF and municipal local branches

Recorded check status: recorded; no individual primary acceptance inferred

#
P02-D20
Deferred family
State/DF and municipal local branches
Why excluded from PASS-02; exact next action
All 27 P01 units remain unverified locally; separately named below, no fresh geography claim.

Recorded coordinator check boundaries

coordinator acceptance
deferred_no_substantive_completion
coordinator review
Actual original cell and next action retained; neither source/contract/local nor country acceptance.
coverage-51 Saved research record

P02-D21 Foreign law, remote service and recognition

Recorded check status: recorded; no individual primary acceptance inferred

#
P02-D21
Deferred family
Foreign law, remote service and recognition
Why excluded from PASS-02; exact next action
No foreign law adopted; determine Brazilian and foreign professional/financial nexus in future independent work.

Recorded coordinator check boundaries

coordinator acceptance
deferred_no_substantive_completion
coordinator review
Actual original cell and next action retained; neither source/contract/local nor country acceptance.
coverage-52 Saved research record

P02-D22 Full-country, A097/A098 and parent acceptance

Recorded check status: recorded; no individual primary acceptance inferred

#
P02-D22
Deferred family
Full-country, A097/A098 and parent acceptance
Why excluded from PASS-02; exact next action
HOLD pending coordinator’s independent primary-source, claim, coverage and operational review.

Recorded coordinator check boundaries

coordinator acceptance
deferred_no_substantive_completion
coordinator review
Actual original cell and next action retained; neither source/contract/local nor country acceptance.
coverage-53 Saved research record

Acre (AC) local scope deferred

Recorded check status: recorded; no individual primary acceptance inferred

Unit
Acre (AC)
P02 status
Deferred; no P02 local reading
Exact local task still outstanding
Verify AC professional/consumer/Procon, target municipality, court implementation and accessibility.

Recorded coordinator check boundaries

coordinator acceptance
deferred_no_substantive_completion
coordinator review
Actual original cell and next action retained; neither source/contract/local nor country acceptance.
coverage-54 Saved research record

Alagoas (AL) local scope deferred

Recorded check status: recorded; no individual primary acceptance inferred

Unit
Alagoas (AL)
P02 status
Deferred; no P02 local reading
Exact local task still outstanding
Verify AL professional/Procon, municipal service rules, CEJUSC and language/accessibility.

Recorded coordinator check boundaries

coordinator acceptance
deferred_no_substantive_completion
coordinator review
Actual original cell and next action retained; neither source/contract/local nor country acceptance.
coverage-55 Saved research record

Amapá (AP) local scope deferred

Recorded check status: recorded; no individual primary acceptance inferred

Unit
Amapá (AP)
P02 status
Deferred; no P02 local reading
Exact local task still outstanding
Verify AP councils/consumer service, municipal powers, judiciary and language duties.

Recorded coordinator check boundaries

coordinator acceptance
deferred_no_substantive_completion
coordinator review
Actual original cell and next action retained; neither source/contract/local nor country acceptance.
coverage-56 Saved research record

Amazonas (AM) local scope deferred

Recorded check status: recorded; no individual primary acceptance inferred

Unit
Amazonas (AM)
P02 status
Deferred; no P02 local reading
Exact local task still outstanding
Verify AM local consumer services, councils, court/Defensoria and remote-language implementation.

Recorded coordinator check boundaries

coordinator acceptance
deferred_no_substantive_completion
coordinator review
Actual original cell and next action retained; neither source/contract/local nor country acceptance.
coverage-57 Saved research record

Bahia (BA) local scope deferred

Recorded check status: recorded; no individual primary acceptance inferred

Unit
Bahia (BA)
P02 status
Deferred; no P02 local reading
Exact local task still outstanding
Verify BA Procon, technical professions, municipality, judiciary and accessibility.

Recorded coordinator check boundaries

coordinator acceptance
deferred_no_substantive_completion
coordinator review
Actual original cell and next action retained; neither source/contract/local nor country acceptance.
coverage-58 Saved research record

Ceará (CE) local scope deferred

Recorded check status: recorded; no individual primary acceptance inferred

Unit
Ceará (CE)
P02 status
Deferred; no P02 local reading
Exact local task still outstanding
Verify CE consumer/Procon and councils, municipal and tribunal implementation.

Recorded coordinator check boundaries

coordinator acceptance
deferred_no_substantive_completion
coordinator review
Actual original cell and next action retained; neither source/contract/local nor country acceptance.
coverage-59 Saved research record

Distrito Federal (DF) local scope deferred

Recorded check status: recorded; no individual primary acceptance inferred

Unit
Distrito Federal (DF)
P02 status
Deferred; no P02 local reading
Exact local task still outstanding
Verify DF consumer service, councils, TJDFT and accessibility rules.

Recorded coordinator check boundaries

coordinator acceptance
deferred_no_substantive_completion
coordinator review
Actual original cell and next action retained; neither source/contract/local nor country acceptance.
coverage-60 Saved research record

Espírito Santo (ES) local scope deferred

Recorded check status: recorded; no individual primary acceptance inferred

Unit
Espírito Santo (ES)
P02 status
Deferred; no P02 local reading
Exact local task still outstanding
Verify ES councils, Procon, municipality, judicial mediation and accessible service.

Recorded coordinator check boundaries

coordinator acceptance
deferred_no_substantive_completion
coordinator review
Actual original cell and next action retained; neither source/contract/local nor country acceptance.
coverage-61 Saved research record

Goiás (GO) local scope deferred

Recorded check status: recorded; no individual primary acceptance inferred

Unit
Goiás (GO)
P02 status
Deferred; no P02 local reading
Exact local task still outstanding
Verify GO consumer/professional instruments, TJGO, municipality and language requirements.

Recorded coordinator check boundaries

coordinator acceptance
deferred_no_substantive_completion
coordinator review
Actual original cell and next action retained; neither source/contract/local nor country acceptance.
coverage-62 Saved research record

Maranhão (MA) local scope deferred

Recorded check status: recorded; no individual primary acceptance inferred

Unit
Maranhão (MA)
P02 status
Deferred; no P02 local reading
Exact local task still outstanding
Verify MA Procon, professional and court materials, municipality and accessibility.

Recorded coordinator check boundaries

coordinator acceptance
deferred_no_substantive_completion
coordinator review
Actual original cell and next action retained; neither source/contract/local nor country acceptance.
coverage-63 Saved research record

Mato Grosso (MT) local scope deferred

Recorded check status: recorded; no individual primary acceptance inferred

Unit
Mato Grosso (MT)
P02 status
Deferred; no P02 local reading
Exact local task still outstanding
Verify MT professional/service rules, Procon, TJMT and municipal scope.

Recorded coordinator check boundaries

coordinator acceptance
deferred_no_substantive_completion
coordinator review
Actual original cell and next action retained; neither source/contract/local nor country acceptance.
coverage-64 Saved research record

Mato Grosso do Sul (MS) local scope deferred

Recorded check status: recorded; no individual primary acceptance inferred

Unit
Mato Grosso do Sul (MS)
P02 status
Deferred; no P02 local reading
Exact local task still outstanding
Verify MS Procon, councils, TJMS, border/remote and language issues.

Recorded coordinator check boundaries

coordinator acceptance
deferred_no_substantive_completion
coordinator review
Actual original cell and next action retained; neither source/contract/local nor country acceptance.
coverage-65 Saved research record

Minas Gerais (MG) local scope deferred

Recorded check status: recorded; no individual primary acceptance inferred

Unit
Minas Gerais (MG)
P02 status
Deferred; no P02 local reading
Exact local task still outstanding
Verify MG Procon, CRA/CORECON, TJMG and target municipality.

Recorded coordinator check boundaries

coordinator acceptance
deferred_no_substantive_completion
coordinator review
Actual original cell and next action retained; neither source/contract/local nor country acceptance.
coverage-66 Saved research record

Pará (PA) local scope deferred

Recorded check status: recorded; no individual primary acceptance inferred

Unit
Pará (PA)
P02 status
Deferred; no P02 local reading
Exact local task still outstanding
Verify PA local public consumer help, councils, TJPA and language issues.

Recorded coordinator check boundaries

coordinator acceptance
deferred_no_substantive_completion
coordinator review
Actual original cell and next action retained; neither source/contract/local nor country acceptance.
coverage-67 Saved research record

Paraíba (PB) local scope deferred

Recorded check status: recorded; no individual primary acceptance inferred

Unit
Paraíba (PB)
P02 status
Deferred; no P02 local reading
Exact local task still outstanding
Verify PB consumer/professional instruments, TJPB and municipal service rules.

Recorded coordinator check boundaries

coordinator acceptance
deferred_no_substantive_completion
coordinator review
Actual original cell and next action retained; neither source/contract/local nor country acceptance.
coverage-68 Saved research record

Paraná (PR) local scope deferred

Recorded check status: recorded; no individual primary acceptance inferred

Unit
Paraná (PR)
P02 status
Deferred; no P02 local reading
Exact local task still outstanding
Verify PR Procon, councils, TJPR and municipal/accessibility obligations.

Recorded coordinator check boundaries

coordinator acceptance
deferred_no_substantive_completion
coordinator review
Actual original cell and next action retained; neither source/contract/local nor country acceptance.
coverage-69 Saved research record

Pernambuco (PE) local scope deferred

Recorded check status: recorded; no individual primary acceptance inferred

Unit
Pernambuco (PE)
P02 status
Deferred; no P02 local reading
Exact local task still outstanding
Verify PE consumer/professional materials, TJPE and municipality.

Recorded coordinator check boundaries

coordinator acceptance
deferred_no_substantive_completion
coordinator review
Actual original cell and next action retained; neither source/contract/local nor country acceptance.
coverage-70 Saved research record

Piauí (PI) local scope deferred

Recorded check status: recorded; no individual primary acceptance inferred

Unit
Piauí (PI)
P02 status
Deferred; no P02 local reading
Exact local task still outstanding
Verify PI councils, Procon, TJPI, municipal implementation and language.

Recorded coordinator check boundaries

coordinator acceptance
deferred_no_substantive_completion
coordinator review
Actual original cell and next action retained; neither source/contract/local nor country acceptance.
coverage-71 Saved research record

Rio de Janeiro (RJ) local scope deferred

Recorded check status: recorded; no individual primary acceptance inferred

Unit
Rio de Janeiro (RJ)
P02 status
Deferred; no P02 local reading
Exact local task still outstanding
Verify RJ Procon, relevant councils, TJRJ and municipal advertising/service rules.

Recorded coordinator check boundaries

coordinator acceptance
deferred_no_substantive_completion
coordinator review
Actual original cell and next action retained; neither source/contract/local nor country acceptance.
coverage-72 Saved research record

Rio Grande do Norte (RN) local scope deferred

Recorded check status: recorded; no individual primary acceptance inferred

Unit
Rio Grande do Norte (RN)
P02 status
Deferred; no P02 local reading
Exact local task still outstanding
Verify RN consumer/professional provisions, TJRN and municipality.

Recorded coordinator check boundaries

coordinator acceptance
deferred_no_substantive_completion
coordinator review
Actual original cell and next action retained; neither source/contract/local nor country acceptance.
coverage-73 Saved research record

Rio Grande do Sul (RS) local scope deferred

Recorded check status: recorded; no individual primary acceptance inferred

Unit
Rio Grande do Sul (RS)
P02 status
Deferred; no P02 local reading
Exact local task still outstanding
Verify RS Procon, councils, TJRS, municipality and accessible languages.

Recorded coordinator check boundaries

coordinator acceptance
deferred_no_substantive_completion
coordinator review
Actual original cell and next action retained; neither source/contract/local nor country acceptance.
coverage-74 Saved research record

Rondônia (RO) local scope deferred

Recorded check status: recorded; no individual primary acceptance inferred

Unit
Rondônia (RO)
P02 status
Deferred; no P02 local reading
Exact local task still outstanding
Verify RO consumer/professional law, TJRO/Defensoria and municipality.

Recorded coordinator check boundaries

coordinator acceptance
deferred_no_substantive_completion
coordinator review
Actual original cell and next action retained; neither source/contract/local nor country acceptance.
coverage-75 Saved research record

Roraima (RR) local scope deferred

Recorded check status: recorded; no individual primary acceptance inferred

Unit
Roraima (RR)
P02 status
Deferred; no P02 local reading
Exact local task still outstanding
Verify RR councils/Procon, TJRR, municipal and multilingual rules.

Recorded coordinator check boundaries

coordinator acceptance
deferred_no_substantive_completion
coordinator review
Actual original cell and next action retained; neither source/contract/local nor country acceptance.
coverage-76 Saved research record

Santa Catarina (SC) local scope deferred

Recorded check status: recorded; no individual primary acceptance inferred

Unit
Santa Catarina (SC)
P02 status
Deferred; no P02 local reading
Exact local task still outstanding
Verify SC consumer/professional instruments, TJSC and municipality.

Recorded coordinator check boundaries

coordinator acceptance
deferred_no_substantive_completion
coordinator review
Actual original cell and next action retained; neither source/contract/local nor country acceptance.
coverage-77 Saved research record

São Paulo (SP) local scope deferred

Recorded check status: recorded; no individual primary acceptance inferred

Unit
São Paulo (SP)
P02 status
Deferred; P01 limited CORECON-SP/PROCON-SP guidance retained, not re-read
Exact local task still outstanding
Complete SP state provider/consumer laws, CRA, TJSP, relevant municipal Procon and accessibility review.

Recorded coordinator check boundaries

coordinator acceptance
deferred_no_substantive_completion
coordinator review
Actual original cell and next action retained; neither source/contract/local nor country acceptance.
coverage-78 Saved research record

Sergipe (SE) local scope deferred

Recorded check status: recorded; no individual primary acceptance inferred

Unit
Sergipe (SE)
P02 status
Deferred; no P02 local reading
Exact local task still outstanding
Verify SE Procon, councils, TJSE, municipality and language/accessibility.

Recorded coordinator check boundaries

coordinator acceptance
deferred_no_substantive_completion
coordinator review
Actual original cell and next action retained; neither source/contract/local nor country acceptance.
coverage-79 Saved research record

Tocantins (TO) local scope deferred

Recorded check status: recorded; no individual primary acceptance inferred

Unit
Tocantins (TO)
P02 status
Deferred; no P02 local reading
Exact local task still outstanding
Verify TO Procon/professional rules, TJTO/Defensoria, municipality and language.

Recorded coordinator check boundaries

coordinator acceptance
deferred_no_substantive_completion
coordinator review
Actual original cell and next action retained; neither source/contract/local nor country acceptance.

Corrections, review and scope

Read the evidence with its boundaries. These are saved research components, including revisions. A scoped coordinator review checks selected evidence; it does not certify every claim, a complete jurisdiction, current law or individual applicability. Dates and access limits remain attached to the records.

How to read the research →

No currently queued material correction is mapped to this component. This does not remove its currentness, access, jurisdiction or application limits.

Recorded review disposition

selected official historical explanatory checks completed access window unverified

Other components in this research series

C_BRpass-01

Brazil: provider perimeter and authorization gateways

Inside: Executive determination · A–C. Substantive legal perimeter · A. The controlling distinction is the activity, not the business label

10 tables51 claim records40 source recordsScoped review · limits applyCaptured 2026-10-27
C_BRpass-03

Brazil: PASS-02 source-access provenance correction

Inside: G1. Exact reusable replacement paragraph · Exact replacement paragraph · A. Source-register introductory paragraph

5 tables10 claim records0 source recordsScoped review · limits applyCaptured 2026-10-27
C_BRpass-04

Brazil: consumer-service fees, contracts, cancellation and refund framework

Inside: Executive determination · G1. Applicability, contract formation and disclosures · 1. Which engagements fall within the CDC?

12 tables49 claim records16 source recordsScoped review · limits applyCaptured 2026-10-27
C_BRpass-05

Brazil: private consumer-debt limitation and prescription

Inside: Executive determination · G1.1 Period-selection matrix · Narrow classification rule

14 tables60 claim records16 source recordsScoped review · limits applyCaptured 2026-10-27
C_BRpass-06

Brazil: negative credit-register entries, notice, duration and correction

Inside: G1.1 Covered data and excluded systems · G1.2 Actors and their distinct duties · G1.3 Consumer and business classifications

13 tables60 claim records20 source recordsScoped review · limits applyCaptured 2026-10-27
C_BRpass-07

Brazil: positive credit history and Cadastro Positivo

Inside: G1.1 Operative law and amendment timeline · G1.2 Actor matrix · G1.3 Natural persons, legal persons and territorial limits

12 tables72 claim records11 source recordsScoped review · limits applyCaptured 2026-10-27
C_BRpass-08

Brazil: LGPD data roles, legal bases and data-subject rights

Inside: G1.1 Currentness and commencement crosswalk · Anonymization boundary · G1.3 Territorial triggers and exclusions

16 tables73 claim records11 source recordsCorrections to readCaptured 2026-10-27
C_BRpass-09

Ordinary private civil repayment, consensual settlement, payment allocation, receipt and release gateway

Inside: Ordinary private civil repayment, consensual settlement, payment allocation, receipt and release gateway · G1.1 Current law and narrow currentness · G1.2 Legal classification matrix

10 tables84 claim records5 source recordsScoped review · limits applyCaptured 2026-10-27
C_BRpass-10

Ordinary consumer debt-collection communications and conduct

Inside: Ordinary consumer debt-collection communications and conduct · G1.1 Consumer and supplier nexus · G1.2 Actor matrix

12 tables65 claim records9 source recordsScoped review · limits applyCaptured 2026-10-27
C_BRpass-11

Two bounded corrections to reviewed positive-history research

Inside: Two bounded corrections to reviewed PASS-07 positive-history research · 1.1 Exact operative provision · Correction determination

9 tables15 claim records3 source recordsScoped review · limits applyCaptured 2026-10-27
C_BRpass-12

One bounded provenance-only repair to

Inside: One bounded provenance-only repair to PASS-11 · Final provenance disposition

9 tables6 claim records0 source recordsScoped review · limits applyCaptured 2026-10-27
C_BRpass-13

Ordinary civil assignment, ownership, debtor notice, defenses and creditor/payment-recipient authority

Inside: Ordinary civil assignment, ownership, debtor notice, defenses and creditor/payment-recipient authority · G1.1 Controlling bodies and commencement · G1.2 What ordinary assignment does

13 tables66 claim records8 source recordsScoped review · limits applyCaptured 2026-10-27
C_BRpass-14

Ordinary civil transaction validity, nullity and annulability gateway

Inside: Ordinary civil transaction validity, nullity and annulability gateway · G1.1 Currentness and operative-text crosswalk · G1.2 Current capacity rules

15 tables86 claim records6 source recordsScoped review · limits applyCaptured 2026-10-27
C_BRpass-15

Bounded P13 payment-recipient qualification and source/claim/count traceability repair

Inside: Bounded P13 payment-recipient qualification and source/claim/count traceability repair · R1.1 Replacement for the affected portion of P13 G2.6 · Creditor or rightful representative — art. 308

16 tables8 claim records2 source recordsScoped review · limits applyCaptured 2026-10-27
C_BRpass-16

Ordinary civil surety (fiança) and solidary/joint-obligation gateway

Inside: Ordinary civil surety (fiança) and solidary/joint-obligation gateway · G1.1 Current federal bodies · G1.2 Merely joint/divided versus solidary obligations

11 tables80 claim records13 source recordsScoped review · limits applyCaptured 2026-10-27
C_BRpass-17

Bounded P14 atomic-predicate, commencement-traceability and count-unit repair

Inside: Bounded P14 atomic-predicate, commencement-traceability and count-unit repair · Replacement C_BR-P14-C006 · Replacement C_BR-P14-C027

13 tables5 claim records1 source recordsScoped review · limits applyCaptured 2026-10-27
C_BRpass-18

Ordinary civil commencement and service-of-process gateway

Inside: Ordinary civil commencement and service-of-process gateway · Principal findings · 1.1 Amendment and commencement crosswalk

14 tables80 claim records27 source recordsScoped review · limits applyCaptured 2026-10-27
C_BRpass-19

Ordinary civil revelia and ensuing merits-judgment gateway

Inside: Ordinary civil revelia and ensuing merits-judgment gateway · 1.1 Current CPC and temporal boundaries · 1.2 Preconditions, not a service rerun

13 tables77 claim records12 source recordsScoped review · limits applyCaptured 2026-10-27
C_BRpass-20

Ordinary civil apelação from a first-instance sentence

Inside: Ordinary civil apelação from a first-instance sentence · 1.1 Principal operative body · 1.2 Material amendment crosswalk

16 tables85 claim records20 source recordsScoped review · limits applyCaptured 2026-10-27
C_BRpass-21

Ordinary civil embargos de declaração: clarification, correction and limited modifying effects

Inside: Ordinary civil embargos de declaração: clarification, correction and limited modifying effects · 1.1 Operative text and commencement · 1.2 Material currentness checks

15 tables74 claim records20 source recordsScoped review · limits applyCaptured 2026-10-27
C_BRpass-22

Ordinary civil agravo de instrumento and interlocutory-review gateway

Inside: Ordinary civil agravo de instrumento and interlocutory-review gateway · 1.1 Statute and commencement · 1.2 Material amendment/status crosswalk

15 tables80 claim records17 source recordsScoped review · limits applyCaptured 2026-10-27
C_BRpass-23

Ordinary civil agravo interno against a relator’s monocratic decision

Inside: Ordinary civil agravo interno against a relator’s monocratic decision · Principal determination · Material source limitations

18 tables70 claim records28 source recordsScoped review · limits applyCaptured 2026-10-27
Record integrity

Original saved Markdown SHA-256: 6b3599cbfed85e8bd7d5110bd40a04b8d04a68c0e3bf8d9f9450c21c831be59b. Public formatting, private-reference removal and correction annotations are separate from that immutable original.

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