Recommendation: SELL · Rating 3.9/10
Our current reading of FISC11 is SELL, with a score of 3.9/10. This score comes neither from the manager nor the administrator: it is Rico aos Poucos' editorial assessment, built from the documents the fund files with the CVM. Below is what supports it — and what argues against it.
18th out of 34 in the bucket. Lite analysis: significant book discount (P/BV 0.59) masked by a 3.6% p.a. management fee — among the highest in the sector — and near-zero liquidity (R$ 5.5k/day, 221 unitholders). Practically nonexistent secondary market.
Safety in a REIT is not yes or no — it is how much risk you accept. FISC11 has a muito_alto risk profile. What that means in practice:
| Component | Level |
|---|---|
| Concentração | 5.0 |
| Price volatility | 3.0 |
| Distribution volatility | 3.0 |
| Liquidez | 5.0 |
| Underlying asset risk | 4.0 |
| Financial risk / cost structure | 5.0 |
The P/BV of 0.55 may look attractive to value investors, but the discount reflects rational pricing of real risks: liquidity of R$ 5.5k/day and a 3.6% p.a. fee. With so few unitholders, the discount could persist indefinitely.
No catalyst identified for discount narrowing in this lite analysis
With an average daily trading volume of R$ 5.5k, a R$ 50k position would take over 9 business days to liquidate without moving the price — and with price impact, it could take weeks.
Enter only with capital that can be locked up for an indefinite period
The 3.6% p.a. fee on net assets of R$ 188.9M implies an annual cost of ~R$ 6.8M in fees. With 1.7M units, this equals ~R$ 4.00/unit/year consumed in fees — representing more than 50% of distributed dividends.
Verify whether the fee includes all services or if there are additional layers (performance, custody)
| Scenario | Description |
|---|---|
| Partial discount narrowing with improved liquidity | If the fund expands its unitholder base and improves liquidity, the 45% discount could narrow partially. Significant theoretical upside but very low probability without structural changes. |
| Discount persists indefinitely | With only 221 unitholders and liquidity of R$ 5.5k/day, the discount can remain elevated for years without a narrowing catalyst. |
| Worsening vacancy in an adverse macro environment | Current vacancy of 9.42% could worsen in an economic slowdown scenario, further reducing distributable earnings. |
The FISC11 is an extreme niche office building fund: only 221 unitholders, average daily trading volume of R$ 5.5k, and a management fee of 3.6% p.a. — one of the highest among all brick-and-mortar FIIs listed on B3. The fund has existed since July 2019 and holds net assets of R$ 188.9M, but this scale does not translate into accessibility for ordinary investors.
The P/BV of 0.55 may look attractive at first glance, but it represents rational pricing of real risks. With a management fee 3–4× above the sector average, the manager consumes ~R$ 4/unit/year in fees — more than 50% of distributed dividends. In a Selic environment of 14.75%, the 9.56% DY does not compensate for the risks assumed.
This lite analysis was built using public data from the last 6 months (Investidor10 and StatusInvest). For a complete evaluation of the portfolio, leases, management history, and dividend sustainability, mining of CVM/FundosNet documents is required, which will be performed in a subsequent analysis.
Current recommendation: SELL. Rating 3.9/10. The FISC11 is a niche office building fund: only 221 unitholders, average daily trading volume of R$ 5.5k, and a management fee of 3.6% p.a. — one of the highest among brick-and-mortar FIIs. The P/BV of 0.55 indicates a 45% discount to book value, but the discount is partially…
Our current read on FISC11 is “SELL”. Rating 3.9/10. Assess it against your risk profile and the points of attention listed above.
The main points of attention for SC 401 Real Estate Fund (FII) include: Initial LITE analysis — based on public data from the last 6 months; Management fee of 3.6% p.a. — among the highest in the sector; Near-zero liquidity — R$ 5.5k/day; Minimal unitholder base — only 221 investors.
FISC11 is suitable for: Investors with privileged access to the fund's assets (e.g., property partners) Very aggressive profile willing to accept minimal liquidity and an indefinite horizon Those who deeply understand the portfolio assets and have conviction in the discount-narrowing thesis