The IMF and the New Frontier for Investment Funds

João Pedro Nascimento · Originally published in Valor Econômico (Palavra do Gestor column), August 2026

In the last weeks of July, the International Monetary Fund (IMF) released, under the Financial Sector Assessment Program (FSAP) it conducts jointly with the World Bank, its Financial System Stability Assessment (FSSA) for Brazil, an independent assessment of the stability, regulation and supervision of the Brazilian financial system. The FSAP ranks among the most comprehensive diagnoses of the soundness of a country’s financial system and serves as a reference for policymakers, regulators and market participants.

The central conclusion is positive. The IMF considers the Brazilian financial system sound, resilient and capable of absorbing significant macroeconomic shocks, which reflects the institutional maturity achieved since the previous assessment in 2018. Against an international backdrop of high volatility, geopolitical tensions, persistent inflation and rapid technological change, this recognition takes on special significance.

The document highlights Brazil’s progress in strengthening its regulatory and institutional framework. According to the IMF, Brazil shows a high degree of compliance with international standards for banking regulation and supervision, the result of continuous improvement pursued by the financial authorities over the past decade.

The report also recognizes the digital transformation of the system. It cites Pix, Open Finance and initiatives to promote democratization and competition as drivers of efficiency, financial inclusion and lower costs. In the capital markets, the same movement is embodied in Open Capital Market, an initiative of the Brazilian Securities and Exchange Commission (CVM) aimed at opening the market and broadening access for participants, with investment portability as one of its milestones. Brazil thus consolidates its position as an international benchmark in digital financial infrastructure and shows that innovation and stability go hand in hand when regulation is consistent.

The success of these transformations changes the nature of the risks to stability. Concerns once centered on the traditional banking system now extend to investment funds, securitizations, digital platforms and other non-bank financial institutions (NBFIs).

This shift signals maturity. More developed capital markets broaden the alternatives to bank credit, and the growth of private credit illustrates this transition well, bringing savings and investment closer together and allocating resources more efficiently.

This evolution calls for new supervisory tools. The IMF recommends strengthening the monitoring of NBFIs, expanding stress testing, improving fund liquidity management, developing more sophisticated leverage metrics and deepening the analysis of systemic risks arising from interconnections across segments. The report also emphasizes coordination among the Central Bank of Brazil (BCB), the CVM, the Superintendence of Private Insurance (SUSEP) and the National Superintendence of Pension Funds (PREVIC), information sharing among regulators and stronger cybersecurity.

My reading adds one point to the traditional agenda of international organizations. The IMF, the World Bank and the Financial Stability Board generally focus on liquidity management and leverage control, both important vectors for monitoring systemic risk. Recent episodes in Brazil, however, reveal a priority that deserves greater prominence: improving the identification of the ultimate beneficial owners of investment funds and ensuring transparency over the beneficial ownership of assets.

This discussion goes beyond the prudential sphere. Knowing who controls or benefits from investments matters as much as monitoring liquidity or leverage. In an increasingly sophisticated system, knowing the chain of economic ownership preserves market integrity and ensures that each structure serves a legitimate purpose.

The CVM’s recent progress points in this direction, particularly in strengthening investor identification rules and modernizing fund regulation. Room remains to deepen mechanisms that reveal to regulators, in a timely and reliable manner, the ownership structure of complex arrangements.

The IMF’s diagnosis points to a clear path. The next cycle in the evolution of supervision is likely to shift the focus from the traditional banking system to the capital markets, to non-bank intermediation and to the new issues raised by technological innovation. In this cycle, transparency over beneficial ownership stands out as the most promising frontier. It underpins the trust that enables the market to grow and gives consistency to the entire framework already built. That is where the next frontier of supervision lies, and Brazil has the institutional maturity to lead it.

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