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SettleADebt C_BR PASS-07 — Brazil

Distinct narrow component: Cadastro Positivo / positive payment-history databases only.

Baseline: October 22, 2026, America/Los_Angeles. Fresh source-access dates: October 26, 2026 PDT / October 27, 2026 UTC. Individual source-search and opening clock times were not logged and remain unknown. No inferred session window is used. Status: Narrow federal research report and publication hold. It is not an actual credit-file review, score explanation, database-manager authorization, consumer complaint, provider clearance, or country acceptance.

PASS-04, PASS-05 and PASS-06 remain saved but unreviewed. None of their consumer-contract, prescription or negative-register conclusions is adopted as an accepted premise. This pass independently reads the positive-history regime.

Executive determination

Brazil’s present Cadastro Positivo regime is an opt-out positive-payment-history system, not the original 2011 opt-in system.

1. Opening no longer requires prior consent. Lei Complementar 166/2019 replaced the original consent-first model. A qualifying database manager may open a positive record for a natural or legal person under Lei 12.414/2011, subject to later notice, cancellation rights and the other statutory safeguards. The substantive opt-out amendments took effect 91 days after the April 9, 2019 official publication—July 9, 2019. Planalto+1
2. **Opening, consultation and full-history disclosure are three different events.**Opening may occur without prior opt-in.No information may be furnished to a consulente during the first 60 days after opening.A score may be furnished after the applicable waiting period and for a permitted credit-risk purpose.Disclosure of the full credit history requires the registered person’s prior, specific authorization. Planalto+1
3. Post-opening notice is mandatory but has a statutory exception. Notice must occur without cost within 30 days after opening, directly by the manager or through a source, and must clearly identify available cancellation channels. The notice may be dispensed with if that person already has a positive record open at another database. Planalto
4. The data are defined and bounded. The regime concerns financial and payment information for paid or current credit operations and payment obligations. The implementing decree identifies fields such as origination date, obligation value, due dates, amounts due, and full or partial payments. Unrelated or excessive information and specified sensitive information may not be recorded or used for scoring. Planalto+1
5. **Cancellation and score suspension are separate rights.**A person may request free cancellation or reopening through any manager by telephone, physical channel or electronic channel.The receiving manager has up to two business days to act and forward the request; the other managers receive their own two-business-day period after receipt.A person may instead suspend third-party access to the score while retaining access to their own score.Cancellation prevents statutory use of the credit history, but does not necessarily erase legally retained audit records, delete negative entries, cancel the underlying debt or erase unrelated datasets. Planalto+2
6. **Access and correction have multiple clocks.**The registered person has free access to their data, history and score without needing to justify the request.Specific source, sharing and consultant-access information is subject to a 10-day statutory response period.Erroneous information must be corrected or cancelled across the databases that shared it within 10 days.A source asked to verify challenged information has a separate two-business-day duty, and must update or correct information previously supplied within 10 days. Planalto+1
7. Score transparency is meaningful but not unlimited. A person may learn the principal elements and criteria used in risk analysis and request review of a decision made exclusively through automated means. Trade secrets remain protected. The decree gives the consulente seven business days to provide the result of an automated-decision review. No law examined guarantees a higher score, credit approval or a particular interest rate. Planalto+1
8. Positive-history information has a different duration structure from an ordinary negative entry. Lei 12.414 art. 14 sets a maximum of 15 years for positive payment information. Separately, Decreto 9.936 requires retention of certain authorization, cancellation, reopening and correction records for audit purposes for at least 15 years from cancellation. Those are not the same clock and do not establish public availability for the whole audit period. Planalto+1
9. Financial-origin data are subject to a special manager-registration branch. Institutions authorized by Banco Central may provide covered credit-operation information only to database managers registered with Banco Central, and financial-origin sharing is limited to registered managers. That registration does not make the manager a financial institution and does not constitute a general licence for SettleADebt or another debt adviser. Planalto+3

G1. Current primary law, actors and data

G1.1 Operative law and amendment timeline

The current compiled Lei 12.414 and Decreto 9.936 were read through the actual operative bodies. No later amendment was inferred merely from a search absence.

G1.2 Actor matrix

These distinctions come from Lei 12.414 arts. 1–2, 12 and 17 and the current regulation. Planalto+2

G1.3 Natural persons, legal persons and territorial limits

Lei 12.414 expressly covers both natural and legal persons. Its rights to access, cancellation, reopening, correction and automated-decision review are therefore not limited to natural persons merely because the LGPD defines a data titular as a natural person. The LGPD overlay directly concerns personal data connected to natural persons; company-level rights in this regime arise primarily from Lei 12.414. Planalto+2

For a natural person, the LGPD can add purpose, necessity, transparency, quality, access, correction and automated-review requirements. Its art. 7(X) permits processing for credit protection, “including” under the specific credit-protection legislation. That basis does not nullify the specific Lei 12.414 requirement for authorization before disclosing full credit history to a consultant. Planalto+1

For a legal person:

• Lei 12.414 applies directly;
• the full-history authorization may last up to 12 months rather than the three-month natural-person limit;
• CDC remedies depend on separate consumer classification;
• LGPD natural-person rights do not automatically attach to company data merely because the data concern a company; and
• personal data about directors, owners, guarantors or employees may still engage LGPD separately.

For remote or foreign actors, LGPD art. 3 can create a Brazilian nexus for natural-person data processing, but the complete cross-border, jurisdiction, recognition and international-transfer analysis is deferred. Planalto

G1.4 What constitutes positive payment history?

Lei 12.414 defines histórico de crédito as financial and payment information concerning paid or current credit operations and payment obligations. Decreto 9.936 specifies:

• date credit was granted or the obligation assumed;
• original credit or obligation amount;
• amounts due and their maturity and payment dates;
• amounts paid, including partial payments;
• the nature of the relationship—credit, commercial, continuous service or another defined category; and
• identifying and contact data necessary to operate the system. Planalto+2

For financial institutions, Resolução CMN 4.737 covers credit, leasing, consortium self-financing and other credit-like operations and requires reporting fields including origination date, original amount, instalment due dates and full or partial amounts paid. Banco Central do Brasil Normativos+1

Continuous-service providers—including water, sewer, electricity, gas and telecommunications—are expressly included as possible sources under the amended statutory definition. The former separate opt-in utility provision was repealed, so a utility source is now analyzed under the general current framework, not the old art. 11 consent model. Planalto+1

G1.5 Prohibited and out-of-scope data

The positive register may retain only objective, clear, true, understandable data necessary to assess economic status and credit risk. It may not record excessive information unrelated to credit-risk analysis or specified sensitive data concerning social or ethnic origin, health, genetic information, sexual orientation or political, religious and philosophical convictions. Score criteria are subject to overlapping prohibitions, including sex and information about unrelated third parties. Planalto+1

The reviewed provisions do not authorize indiscriminate disclosure of:

• deposit-account balances;
• itemized purchases;
• income and assets generally;
• transaction narratives unrelated to payment performance;
• medical or genetic information;
• political, religious or philosophical views;
• a family member’s information merely because they share an address; or
• public tax, court or governmental-debt records outside the specific positive-history system.

LC 105 art. 1 §3(VII) supplies a bank-secrecy exception for the defined financial and payment information sent to managers under the specific positive-history law. It is not a general exception for unrelated banking information. Planalto

Public-law databases maintained by domestic public-law entities are expressly governed by specific legislation rather than automatically by Lei 12.414’s ordinary private positive-register model. Planalto

G1.6 Manager requirements versus a general provider licence

Decreto 9.936 sets manager-level economic, technical, governance, security, consumer-service and audit requirements. It includes a R$100 million minimum net-worth requirement for the manager, subject to the regulation’s detailed composition rules; through December 31, 2026, the permitted controller/associate contribution percentage described by §6 is 10%. Those figures concern the database manager’s regulatory structure—not a consumer charge, adviser bond, SettleADebt authorization or required capital for an ordinary non-database consultancy. Planalto+1

A Banco Central registration under Lei 12.414 art. 12 and Resolução 4.737 is required for a manager to receive covered information from BCB-authorized institutions. Lei 12.414 expressly states that such managers are not thereby subjected to the legal regime governing financial institutions. Planalto+1

G2. Opening, notice, consultation, consent and cancellation

G2.1 Opt-in to opt-out transition

The original 2011 rule required prior informed authorization to open the record. LC 166 replaced it with express authority for the manager to:

• open a positive record;
• make positive-payment annotations;
• share registered and payment information with other managers;
• provide a score; and
• provide full credit history only after prior specific authorization. Planalto+1

LC 166 was officially published April 9, 2019. Its art. 7 made most of the opt-out changes effective after 91 days:

April 9, 2019 + 91 calendar days = July 9, 2019.

That is the operative transition date expressly used by Decreto 9.936. Planalto+1

G2.2 Opening notice

After opening, the communication must:

1. occur within 30 days;
2. be free;
3. be made by the manager directly or through a source; and
4. clearly explain the available cancellation channels. Planalto

The communication uses personal data supplied by the person to a source, including residential, commercial or electronic addresses. The read provisions do not prescribe one exclusive communication technology or a universal proof package. Actual delivery, content, address provenance and operator procedure remain factual. Planalto

Notice exception

Notice is dispensed with where the person already has a positive record open at another database. That exception does not erase cancellation rights or authorize consultation before the 60-day period; it only concerns the statutory opening communication. Planalto

Previously expressed opt-out

A manager must automatically cancel a record for a natural or legal person who had previously expressed—by telephone, physical or electronic means—the wish not to have a record opened. Planalto

G2.3 Sixty-day consultation barrier

Information about the registered person may be furnished to consultants only 60 days after opening, subject to the relevant purpose and authorization conditions. The barrier applies before consultant access; it does not prevent the registered person from exercising their own access or cancellation rights. Planalto

The statute does not create a second consent requirement for a score merely because the 60 days elapse. It instead distinguishes score access from full-history access:

• score: may be furnished under art. 4(IV)(a), the 60-day rule, permitted-purpose rule and any score-access suspension;
• full history: requires all those conditions plus prior specific authorization under art. 4(IV)(b). Planalto+1

G2.4 Full-history authorization

The authorization may be physical or electronic, may be delivered directly or through the prospective consultant and extends to all managers. It may authorize:

• one access;
• fixed access for up to three months when granted by a natural person;
• fixed access for up to 12 months when granted by a legal person; or
• indefinite access by a BCB-authorized institution, but only while its contractual relationship with the registered person continues. Planalto+1

It may be revoked unilaterally at any time. The manager must maintain adequate procedures proving the authorization’s authenticity and validity. A generic privacy clause, broad marketing consent or mere credit inquiry request is not automatically equivalent to the specific full-history authorization. Planalto+1

G2.5 Permitted consultation purpose

A consultant may access information only where it maintains or intends to maintain a commercial or credit relationship with the registered person. Permitted uses are limited to credit-risk analysis or supporting credit, deferred sale or another transaction presenting financial risk to that consultant. Planalto+1

The regime does not establish:

• general public access;
• access for curiosity, employment screening or unrelated marketing;
• authority for a debt adviser to pull another person’s history merely because the person contacted the adviser;
• automatic entitlement to full-history data from a signed general service agreement; or
• authority to disclose individual source identities to the consultant.

G2.6 Sharing among managers

The 2019 amendments permit sharing of registration and positive-payment information among managers. A receiving manager assumes statutory duties concerning challenges, cancellations and correction, while the originating manager must keep shared information updated without charge. Planalto+1

For information originating with BCB-authorized institutions, sharing is allowed only among BCB-registered managers. Planalto

Manager-to-manager sharing does not eliminate the specific authorization required before a consultant receives the full history.

G2.7 Cancellation and reopening

Cancellation and reopening:

• are free;
• may be requested from any manager;
• may be requested by telephone, physical channel or electronic channel;
• require the receiving manager to close or reopen within two business days;
• require that manager to relay the request to the others within the same period; and
• require the other managers to comply within their own two-business-day period after receipt. Planalto

Decreto 9.936 requires an express request and permits electronic requests. It also requires telephone and electronic tracking systems. Planalto

Effects of cancellation

Cancellation prevents managers from using the person’s history for the purposes of Lei 12.414, including use in composing third-party scores. New positive annotations may not be added after two business days from the request. Partial deletion is not available merely because the person wants some accurate items omitted; partial deletion remains possible where information was improperly recorded. Planalto+1

Cancellation does not, by itself:

• cancel the underlying obligation;
• amend a contract;
• delete an ordinary negative-register entry;
• delete a protest;
• remove a judgment;
• require destruction of audit records;
• eliminate all data kept for another lawful regime; or
• guarantee an improved score.

The regulation expressly requires certain audit records to remain for at least 15 years from cancellation. Planalto

Reopening

Reopening follows the same free request and two-business-day manager workflow. The read law and decree do not expressly state whether every reopening must produce a new 30-day opening notice. That precise re-notice question remains unresolved rather than being inferred.

G2.8 Score-access suspension

Instead of cancelling the whole positive record, a person may request indefinite suspension of consultant access to their score. The receiving manager has two business days to suspend access and forward the request; other managers must act within two business days after receiving it. The person retains access to their own score. Planalto

Score suspension is therefore not equivalent to:

• cancellation of the positive register;
• revocation of one consultant’s full-history authorization;
• correction of inaccurate information; or
• a score recalculation.

G3. Access, correction, transparency, scoring and use

G3.1 Free access

A registered person may access, free of charge and without giving a reason:

• all information about them in the database;
• their credit history;
• their score;
• the sources of the information, with contact details;
• the managers with which data were shared;
• all consultants that accessed their information during the preceding six months;
• a summary of their rights and available government bodies; and
• confirmation of cancellation. Planalto+1

Decreto 9.936 requires secure, free website access and telephone access. Each consultant response must show the last update date. The manager may disclose source identities to the registered person but may not reveal individual sources to consultants. Planalto+1

G3.2 Access clocks

The law contains several different response concepts:

• Lei 12.414 art. 6(I) defines the requested dataset as the information present at the moment of the request.
• Art. 5 §3 gives up to 10 days for the information in art. 5(II) and (IV)—the person’s information/history/score and the principal risk-analysis elements and criteria.
• Art. 6 §2 gives 10 days for the source, shared-manager, six-month consultant-access and rights-summary items.
• Decreto 9.936 requires free website and telephone systems but does not convert every statutory 10-day item into an instantaneous duty. Planalto+2

The data snapshot should correspond to the request date even where the response is furnished within an applicable later period.

G3.3 Correction and refusal

A person who challenges erroneous information has the right to correction or cancellation in all databases that shared it within 10 days. A receiving manager must accept and process the challenge; sharing does not force the person to locate every downstream manager individually. Planalto+1

The source has distinct duties:

• verify and confirm or correct challenged information within two business days when asked by a manager or directly by the person;
• update or correct previously supplied information within 10 days;
• maintain records supporting what it supplied; and
• supply information to managers on nondiscriminatory terms. Planalto

These clocks operate together rather than replacing one another. For example, a manager’s 10-day correction result cannot be extended automatically merely because the source also has its own two-business-day verification task.

Potentially correctable fields include:

• identity or CPF/CNPJ;
• source;
• nature of the commercial or credit relationship;
• origination date;
• original obligation amount;
• instalment amount;
• due date;
• payment date;
• full versus partial payment;
• amount paid;
• status of an obligation as current or paid; and
• whether a consultant accessed a history or score.

An accurate but unfavorable datum is not an “error” merely because it contributed to a lower score or adverse decision.

G3.4 Score criteria and transparency

The person may learn the principal elements and criteria used in risk analysis, subject to commercial secrecy. The manager must publish a clear and accessible policy describing collection and use of personal data for credit-risk analysis. Planalto+1

The score may not use:

• information unrelated to credit risk;
• specified sensitive categories;
• information about people without a first-degree family or economic-dependency relationship;
• information penalizing the person for exercising their own access right; or
• discriminatory or abusive processing prohibited by the LGPD. Planalto+1

These transparency rights do not necessarily require disclosure of:

• source code;
• model weights;
• proprietary formulae;
• trade-secret thresholds;
• another person’s data; or
• a guaranteed method to increase the score.

G3.5 Automated decisions

Lei 12.414 allows the registered person to ask the consulente to review a decision made exclusively by automated means. Decreto 9.936 requires the consultant to provide the review result within seven business days from the request. Planalto+1

For natural-person data, LGPD art. 20 supplies a related automated-decision review and criteria-explanation right, also subject to commercial and industrial secrecy. Lei 12.414 remains important because it also expressly covers legal persons. Planalto

Neither statute guarantees:

• human approval;
• reversal of the adverse decision;
• credit approval;
• a specific interest rate;
• a score increase;
• disclosure of every proprietary model detail; or
• damages merely because the result was adverse.

G3.6 Duration and retention

Two 15-year periods must be kept distinct:

G3.7 Limited LGPD crossover

For natural-person data only, this pass confirms the following limited overlaps:

• national-territorial nexus under LGPD art. 3;
• purpose, necessity, free access, data quality, transparency, security and non-discrimination;
• credit protection as a legal basis under art. 7(X);
• access and correction rights;
• a legally constituted representative’s ability to submit a request;
• simplified immediate access or a complete declaration within 15 days under art. 19, subject to sector-specific regulation; and
• review of solely automated decisions under art. 20. Planalto+3

This is not a complete LGPD module. Controller/operator allocation, international transfers, retention outside the positive-register law, biometrics, children’s data, security incidents, sanctions, civil actions and damages are separately deferred.

G3.8 Generic registration and regulatory verification

A generic verification would ask:

1. Is the entity actually a gestor or merely a source, consultant or service provider?
2. Does it receive data originating with BCB-authorized institutions?
3. If so, does it claim the Banco Central manager-registration category required by Lei 12.414 art. 12 and Resolução 4.737?
4. Which exact activities does the registration cover?
5. What is the effective date and status?
6. Which manager, source and consultant act in the specific data flow?
7. What authorization exists for full-history consultation?
8. What proof exists for notice, cancellation, access and correction?

No actual manager, source, consultant, institution, record or registration was searched. The publicly indexed Resolução BCB 14 procedure could not be substantively read, so detailed filing requirements and current forms remain unresolved.

G4. Ten fictional workflows

All persons, companies, data, dates and outcomes below are invented. They demonstrate conditional classification and clocks only.

H01 — Automatic opening without prior opt-in

Facts: A manager opens a positive record for a natural person on Monday, October 5, 2026. The person never signed a prior opt-in.

Actors/data: Manager, natural-person cadastrado, positive payment information.

Primary claims: C_BR-P07-C019–C026.

Conditional result: Lack of prior opt-in does not alone invalidate opening under the post-July 9, 2019 regime. The manager must satisfy the post-opening notice rule and may not furnish information to consultants during the first 60 days.

Notice calculation:

• Opening day: October 5, 2026.
• Exclude the opening day under the ordinary Civil Code art. 132 convention.
• Day 1: October 6.
• Day 30: Wednesday, November 4, 2026.
• Formula: October 5, 2026 + 30 calendar days = November 4, 2026.

The calculation assumes no different specific convention and no factual dispute over when opening occurred. Civil Code art. 132 moves a holiday endpoint to the next business day; no local holiday is assumed here. Planalto

Sixty-day branch:

• The 60th calendar day after October 5 is Friday, December 4, 2026.
• The statute permits furnishing information only after 60 days.
• If the precise opening timestamp is unknown, the first unambiguously complete calendar day is December 5.

Adverse branch: Notice is excused if the person already had a record open at another manager, but the 60-day consultation condition and cancellation rights remain.

Missing facts: Exact opening timestamp, prior record status, notice content, channel and proof.

Exact next question: Was this the person’s first open positive record, and on what exact date and time did the manager open it?

H02 — Missing or delayed opening notice

Facts: A legal person’s record is opened, but no notice is sent within 30 days. The manager says notice was unnecessary because the company “probably already had another record.”

Primary claims: C022–C025.

Conditional result: The statutory exception depends on an existing open record at another database, not speculation. If that predicate is absent, delayed or missing notice is a compliance defect.

Required act: Identify the existing other record or establish timely free notice with clear cancellation channels.

Clock: Thirty calendar days after opening; no separate grace period was identified.

Adverse branch: The legal person may already have another open record, making the statutory communication dispensable.

Missing facts: Other-manager status, opening date, notice record, address/contact source.

Exact next question: What contemporaneous evidence showed that another positive record was already open when the new manager relied on the exception?

H03 — Consumer requests cancellation

Facts: A natural person submits an express electronic cancellation request to one manager on Monday, October 19, 2026. Assume no holidays.

Primary claims: C037–C045.

Conditional calculation for the receiving manager:

• Request date: Monday, October 19.
• Tuesday, October 20 = business day 1.
• Wednesday, October 21 = business day 2.

The receiving manager must close the record and transmit the request by Wednesday, October 21, under the stipulated no-holiday assumption.

Each other manager receives a separate two-business-day period beginning from its receipt of the transmitted request.

Consequences: No new positive annotations may be made after two business days from the request. Statutory use of the history must stop, while audit records may remain.

Adverse branch: If Monday or a subsequent day is a relevant holiday, the endpoint changes. A request sent after an operator cutoff may create a factual receipt-date issue not resolved here.

Missing facts: Receipt timestamp, tracking number, holiday calendar, transmission and downstream acknowledgments.

Exact next question: When did each manager actually receive the express request?

H04 — Later reopening after cancellation

Facts: Six months after cancellation, the same person requests reopening through another manager.

Primary claims: C037–C046.

Conditional result: Reopening is free, may be requested through any manager and follows the two-business-day workflow.

Adverse branch: The read bodies do not expressly resolve whether reopening triggers a new 30-day opening notice. That point remains held.

Missing facts: Prior cancellation status, reopening request authentication, receipt date and shared-manager list.

Exact next question: Does the operative manager procedure treat reopening as requiring a new art. 4 §4 communication, and what current official instrument supplies that rule?

H05 — Score-only consultation versus full-history access

Facts: A retailer plans an instalment sale and asks for a consumer’s score. It then asks for the complete payment-by-payment history but has no specific authorization.

Primary claims: C026–C035.

Conditional result:

• Score-only access may be possible after the 60-day period, for the permitted commercial/credit purpose and absent score-access suspension.
• Full-history access requires prior specific authorization.
• A general retail privacy clause is not automatically the required authorization.

Adverse branch: Even score access is improper if the retailer has no actual or contemplated commercial/credit relationship.

Missing facts: Opening date, purpose, consultant identity, score-suspension status and authorization record.

Exact next question: Is the request limited to a score, or will it disclose the underlying payment history?

H06 — Inaccurate partial-payment datum

Facts: A source reports that no payment was made on an instalment. The registered person produces proof of a partial payment and challenges the field on Friday, October 16, 2026.

Primary claims: C052–C055.

Conditional source-verification calculation, assuming no holidays:

• Monday, October 19 = business day 1.
• Tuesday, October 20 = business day 2.

The source must verify and confirm or correct the challenged information within two business days. The broader result across shared databases remains subject to the 10-day correction rule.

Required act: Verify the payment, correct amount/date/status where appropriate and propagate the correction.

Adverse branch: The payment may have been allocated to another obligation or reversed; a receipt alone may not resolve allocation.

Missing facts: Source request timestamp, payment clearing, allocation and shared-manager list.

Exact next question: Which obligation and instalment did the partial payment legally satisfy?

H07 — Accurate datum but adverse credit decision

Facts: Payment history is accurate, but a lender rejects an application through an automated process. The applicant believes the score should be higher.

Primary claims: C056–C061.

Conditional result: Accuracy correction is not available merely because the outcome was adverse. The person may request the principal elements and criteria and request review of an exclusively automated decision. The consultant has seven business days to provide the review result.

Adverse branch: A mixed human-and-automated decision may require different analysis. Trade-secret limits remain.

Missing facts: Whether the decision was exclusively automated, review request date, criteria supplied and decision purpose.

Exact next question: Was any human decision-maker substantively involved before the rejection?

H08 — Legal-person business record

Facts: A corporation’s commercial payment obligations are included. It asks for its history and authorizes a prospective supplier to access it for nine months.

Primary claims: C002, C030–C035, C049–C051.

Conditional result: Lei 12.414 covers legal persons. A fixed nine-month full-history authorization is within the decree’s 12-month legal-person maximum, assuming the authorization is specific and valid.

Adverse branch: LGPD personal-data rights do not automatically attach to purely corporate information, although personal data about directors or guarantors require separate analysis.

Missing facts: Authorization wording, consultant relationship, corporate authority and personal-data fields.

Exact next question: Who had authority to grant the company’s full-history authorization, and did it identify the consultant and purpose specifically?

H09 — Representative requests access

Facts: An adult child asks a manager for a parent’s full positive history and score but supplies no authorization.

Primary claims: C049–C051 and C062–C065.

Conditional result: The parent has free access rights, and a legally constituted representative can exercise natural-person LGPD rights. The requester must establish valid authority and identity; family relationship alone does not establish access.

Adverse branch: An unreasonable verification process may obstruct statutory rights, but that requires the actual procedure.

Missing facts: Mandate, identity, capacity and requested dataset.

Exact next question: What legally valid authority allows the representative to receive the parent’s history and score?

H10 — Utility and financial-source edge

Facts: An electricity provider reports partial monthly payments; a bank reports a loan history. Both send data to the same manager.

Primary claims: C007, C014–C018 and C066–C070.

Conditional result:

• The utility is an expressly recognized source under the general law.
• The bank’s covered credit-operation data may go only to a BCB-registered manager.
• The data should be limited to the regulated payment-history fields.
• The bank-secrecy exception does not authorize disclosure of unrelated account balances or transaction details.

Adverse branch: The manager may satisfy the general Decreto 9.936 operating regime yet lack the BCB registration needed for financial-origin data.

Missing facts: Manager category, registration status, reporting fields, source contracts and data layout.

Exact next question: Does the manager receive financial-institution-origin information, and what current registration category authorizes that receipt?

G5. P01 old-to-new disposition

Literal reviewed P01 row preserved

Original coordinator acceptance: explicit_deferred_hold_preserved.

PASS-07 narrow addition

PASS-07 source register

Access date for every row: October 26, 2026 PDT / October 27, 2026 UTC. Source-specific clock times are unknown.

FRESH-READ—OPERATIVE means the actual current enacted/compiled body was read. FRESH-READ—AMENDMENT means an enacted amendment body was read. FRESH-READ—LIMITED means only the stated crossover provisions were read. HISTORICAL—REVOKED means nonoperative history. INDEX/FAILED BODY means the official title or index was identified, but the full dynamic body was not substantively readable.

Source count: 11 displayed rows: seven freshly read operative/amending bodies, two limited crossovers, one historical revoked body, and two dynamic/index failures contained within the 11-row register.

Atomic claim/evidence register

Claim count: 72 displayed atomic and qualified claims, C_BR-P07-C001–C072.

Complete granular core coverage

Core-coverage count: 88 displayed rows, P07-G01 through G88.

Separately named deferred families

Deferred-family count: 36 displayed rows.

All 27 inherited state and Distrito Federal branches

These names are inherited from the saved P01 territorial inventory. No geography API, IBGE endpoint or fresh territorial certification was used. No state, DF or municipality is cleared by the federal analysis.

Territorial count: 27 displayed rows; zero state/DF branches cleared.

Evidence-backed article, checklist and conditional-tool opportunities

A safe positive-history tool should display:

“This result classifies the statutory workflow only. It does not verify an actual database, score, source, authorization, credit decision, underlying debt or legal remedy.”

It should never produce “Your score will rise,” “You will be approved,” or “Cancellation deletes all credit information.”

Researcher self-check

Exact evidence still required for a real positive-history assessment

1. Identity of the actual manager, source and consultant.
2. Exact record-opening date and timestamp.
3. Whether another positive record was already open.
4. Post-opening notice, content, channel and proof.
5. Consultant-access dates and purpose.
6. Whether the request was score-only or full-history.
7. Full-history authorization and its duration.
8. Cancellation, reopening, score-suspension or authorization-revocation records.
9. Exact source fields and payment-history data.
10. Correction requests, source verification and downstream propagation.
11. Six-month consultant-access log.
12. Automated-decision details and review request.
13. Manager category and, if financial-origin data are involved, relevant BCB registration.
14. Applicable state/DF/municipal procedures.
15. Current versions of every consequential federal instrument at the actual use date.

Final disposition: PASS-07 establishes the narrow current federal framework for Cadastro Positivo opening, notice, consultation, authorization, cancellation, access, correction, scoring and financial-origin manager registration. It does not establish that any actual record, score, data use, authorization, cancellation, credit decision, provider or database is lawful, unlawful, accurate, removable, compensable or approved.

END C_BR PASS-07